City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Office of Emergency Services
Meeting Date: October 7, 2024
Report #:2407-3313
TITLE
Adopt a Resolution Approving a Local Hazard Mitigation Plan Volume I and II and Adopt the LHMP into the City‘s 2030 Comprehensive Plan Safety Element; CEQA status - Resolution 9270, no additional environmental review required.
RECOMMENDATION
Staff recommends the City Council: Adopt a resolution (Attachment A) approving the Palo Alto Local Hazard Mitigation Plan (LHMP) including Volume I of the 2023 County of Santa Clara Multi-Jurisdictional Hazard Mitigation Plan and Volume II the Palo Alto Jurisdictional Annex (Attachment B), and adopting this LHMP into the City’s 2030 Comprehensive Plan Safety Element.
EXECUTIVE SUMMARY
Adoption of this resolution finalizes the local hazard mitigation planning process, required by FEMA by the Federal Disaster Mitigation Act of 2000 for eligibility in disaster mitigation funding, is administered by the County of Santa Clara, with each city providing an annex to the 2023 County of Santa Clara Multi-Jurisdictional Hazard Mitigation Plan (MJMHP). This is one of the 2024 City Council priority objectives. The MJHMP contains two Volumes:
- Volume I: The Base Plan.1 This is a robust and comprehensive document which describes the planning process, goals and objectives, county profile, descriptions of hazards of concern and assessment of risk and mitigation strategy.
1 Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan, Volume I. https://www.cityofpaloalto.org/files/assets/public/v/1/oes/plans/final_-vol-i-santa-clara-county-mjhmp_7-26- 2024.pdf
- Volume II: Jurisdictional Annexes.2 The Palo Alto Annex of the MJMHP is provided in this staff report in isolation from the other jurisdictional plans within the county. The jurisdictional annex describes the jurisdiction profile, public outreach and engagement, community capability assessment, hazard risk evaluation, and mitigation strategy.
In the 2023 Palo Alto Annex, there are 17 actions being carried over from the 2017 plan, while staff recommended 10 new actions in the 2023 plan for a total of 27 mitigation actions the City will work towards over the next five-year planning cycle.
The City shared information regarding public opportunities to participate in the draft plan update utilizing a digital survey and seven in-person and virtual public outreach meetings, and a public comment period.
The City also has the opportunity to meet the requirements of Assembly Bill 2140 (2006), by incorporating the updated LHMP into the City’s Safety Element of its Comprehensive Plan. AB 2140 compliance is not a requirement; however, if the City is compliant, it is eligible to be considered for an additional 6.25% local share to be funded by the state, essentially covering the entire local-share cost for eligible Public Assistance projects in the future. Therefore, the resolution also adopts the updated Palo Alto LHMP into the Safety Element, Policy S2.1, of the Comprehensive Plan, and also provides a web link to the updated LHMP within the Safety Element to comply with Cal OES guidance issued in April 2024.3
BACKGROUND
The Federal Disaster Mitigation Act of 2000 (DMA 2000) requires all cities, counties, and special districts to adopt a LHMP to be eligible for participation in and to receive disaster mitigation funding from the Federal Emergency Management Agency (FEMA) Hazard Mitigation Grant Program (HMGP). The LHMP identifies strategies that reduce or eliminate long-term risk to people and property from the effects of natural disasters. It contains courses of action that the City currently follows, or may consider for future implementation, that reduce vulnerability and exposure to future disaster events. The LHMP, which assesses natural hazards, must be updated and adopted by resolution every five years for the City to be eligible for local disaster mitigation funds.
In 2004 and 2010, the Association of Bay Area Governments (ABAG) led regional efforts to address hazard mitigation planning for jurisdictions within its area of responsibility. This 2 Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan, Volume II. https://www.cityofpaloalto.org/files/assets/public/v/1/oes/plans/final_vol-ii-santa-clara-mjhmp_city-of-palo-alto- annex-1.pdf
3 https://www.caloes.ca.gov/wp-content/uploads/Hazard-Mitigation/Documents/AB-2 regional template was used by numerous counties and cities within the ABAG planning area to achieve compliance under the DMA.
In 2016, the Santa Clara County Office of Emergency Services (OES) and Santa Clara County jurisdictions partnered to prepare an updated countywide hazard mitigation plan that would best suit the needs and capabilities of the County and its planning partners. This plan focused on more localized concerns, newly available data and tools to enhance the risk assessment, considering FEMA’s Community Rating System (CRS) for flood insurance, and identifying cost- effective actions. Each individual jurisdiction prepared an “Annex” to the County LHMP, with mitigation strategies specific to the hazard impacts of that jurisdiction. The City’s 2017 LHMP identified 38 mitigation projects that could at least be started over the five-year period through 2022. Palo Alto OES reported on the status of these projects on an annual basis as an Informational Item to City Council over the past five years. In the final update on the 2017 plan, 11 out of 38 initiatives (29%) were completed, 11 out of 38 initiatives (29%) indicated work is conducted as an ongoing capability; 11 out of 38 initiatives (29%) reported progress toward completion; and 5 out of 38 initiatives (13%) reported no progress.
Resolution 9714, the previous council adoption of the City of Palo Alto Local Hazard Mitigation Plan, is dated October 16, 2017. There was a long delay in starting the five-year update of the LHMP at the County level, and there was a lengthy post planning review process at the State and Federal level. Palo Alto has not faced any detrimental actions as a result, since our LHMP update was in progress despite our local plan being out of date. Staff submitted a hazard mitigation project in 2023 that is still under evaluation at the federal level, and FEMA approved disaster grant reimbursements submitted by staff for federal disasters described below.
FEMA’s approval of the 2023 Santa Clara County MJHMP remains for a period of five years from the original approval date of February 8, 2024 for all approved participants. Prior to February 8, 2029, Santa Clara County and all participating jurisdictions are required to review and revise the plan to reflect changes in development, progress in local mitigation efforts, and changes in priorities, and resubmit updates for approval in order to continue to be eligible for mitigation project grant funding.
The Resolution to approve the 2023 Santa Clara County MHMJP, inclusive of the City of Palo Alto Jurisdictional Annex, and to incorporate the plan update into the City’s Safety Element, is Attachment A.
Having a FEMA-approved, and Council-adopted LHMP made the City of Palo Alto eligible to apply for public assistance grant funds under Presidentially Declared Disasters for COVID-19 related expenses (DR4482), and for the winter storms of 2023 (DR4683 and DR4699). As of this report the City was eligible to receive $272,100 in federal reimbursements for DR4482, and has requested $753,300 in federal reimbursements for DR 4683. The Utilities Department is processing a work project under DR4699 for $386,754 to replace a gas line under Arastradero Creek impacted by storm erosion.
ANALYSIS
In 2023, The Santa Clara County Office of Emergency Services (OES) and Santa Clara County local jurisdictions once again partnered to prepare an updated countywide multi-jurisdictional hazard mitigation plan (MJHMP). This planning process began in December 2022 and was completed at the local level in September 2023. It included monthly project meetings at the County and local jurisdictional level, as well as community outreach efforts. A state and federal review process started in September 2023 which took 10 months to reach an approval of the MJMHP.
This planning process followed the requirements identified in 44 CFR section 201.6 (Local Mitigation Plans) and as described in FEMA’s Local Mitigation Planning Handbook, including:
•Identification of hazards unique to the jurisdiction and not addressed in the master planning document
•The conduct of a vulnerability analysis and an identification of risks, where they differ from the general planning area
•The formulation of mitigation goals responsive to public input and development of mitigation actions complementary to those goals. A range of actions must be identified specific for each jurisdiction.
•Demonstration that there has been proactively offered an opportunity for participation in the planning process by all community stakeholders (examples of participation include relevant involvement in any planning process, attending meetings, contributing research, data, or other information, commenting on drafts of the plan, etc.) •Documentation of an effective process to maintain and implement the plan •Formal adoption of the Multi-jurisdictional Hazard Mitigation Plan by the jurisdiction’s governing body (each jurisdiction must officially adopt the plan) Palo Alto participated the County stakeholder meetings and workshops, but also formed an internal working group of City staff members to develop the Palo Alto Annex (Volume II) of this MJHMP.
The MJHMP contains two volumes.
•Volume I: The Base Plan. This is a robust and comprehensive document which describes the planning process, goals and objectives, county profile, descriptions of hazards of concern and assessment of risk and mitigation strategy. It contains a wealth of information in the articulation of risks for each hazard of concern across the county. An understanding of Volume I will be helpful in better understanding Volume II. •Volume II: Jurisdictional Annexes. The Palo Alto Annex of the MJMHP (the City’s updated LMHP) is provided in this staff report in isolation from the other jurisdictional plans within the county. The City LHMP describes the jurisdiction profile, public outreach and engagement, community capability assessment, hazard risk evaluation, and mitigation strategy.
Below is a discussion of the major components of the MJHMP.
Community Capabilities Assessment.
A thorough understanding of community capabilities can help decisionmakers identify feasible hazard mitigation actions. The capability assessment is an evaluation of the authorities, policies, programs, staffing, funding and resources available to accomplish hazard mitigation in the City.
The evaluation included the building codes, land use and development codes, ordinances and regulations key to reducing risk. It also described ways the City can expand on and improve its capabilities. It forms the basis for the mitigation actions the City may advance during this planning cycle. This assessment demonstrates that the City of Palo Alto is well staffed and resourced to carry out a meaningful mitigation program and has been doing so for decades as evidenced by: an emphasis on capital improvements to infrastructure, stewardship of open spaces, long-standing focus on natural hazard mitigation, adherence to current building codes, and implementation of sustainable policies and programs, to name a few.
Hazard Risk Evaluation.
Volume 1 of the MJHMP describes the range of natural hazards that communities face across Santa Clara County. Risk assessment is the process of measuring the potential loss of life resulting from natural hazards, as well as personal injury, economic injury, and property damage, in order to determine the vulnerability of people, buildings, and infrastructure to natural hazards.
As part of a comprehensive risk assessment, county wide planning partners used a hazard risk index to evaluate the probability of occurrence, potential life impact, property impact, percentage of planning area impacted, and extent for each applicable hazard. The overall hazard risk index (1-5 scale) results based on an average of county partner indices is shown below in Table 1.
Table 1: Countywide Hazard Index
Based on the average overall hazard risk index results from county wide planning partner risk indices:
•The earthquake hazard has the highest risk results, followed by wildfire/smoke/air quality.
•The inclement weather, drought, climate change hazards were a moderate risk to the Operational Area.
•The dam failure, flood, and landslide/mass movement hazards were a lower risk to the Operational Area.
•The tsunami hazard poses the lowest risk to the Operational Area, as not all planning partners can be impacted by this hazard due to geographic location.
This methodology does not compare hazards to each other or rank hazards against one another. Instead, this process provides a sense of hazard priorities or relative risk and allows comparison of the same hazard across participating jurisdictions. This risk evaluation does follow a different methodology than was used in the 2017 plan. Along with the evaluation process, new climate hazards were added to comply with current federal guidance.
Mitigation Strategy.
The Mitigation Strategy is often referred to as the heart of the plan, or the blueprint for breaking the cycle of disaster response and recovery. A risk-based, capabilities-informed mitigation strategy outlines the framework for short-term and long-term community resilience.
Planning team members assessed the mitigation actions from the previous plan and updated them where needed, and developed new mitigation actions that could start within the next five years. These actions were then compiled in the City’s LHMP in an action plan format which included information on the time, cost, funding source, and lead agency. At least one action is included for each hazard of concern listed in the plan.
In the 2023 City LHMP, there are 17 actions being carried over from the 2017 plan, while staff recommended 10 new actions in the 2023 plan for a total of 27 mitigation actions the City will work towards over the next five-year planning cycle. These actions when completed or while sustained will reduce the City’s exposure to these given risks. This action plan can be found in in full in Attachment B, Volume II of the LHMP.
Table 2: Action Plan
Action
Item # Action Item Description Hazard(s) Mitigated
PA-2 San Fransicquito Creek Upper Reach Flood Reduction and Ecosystem Restoration Project to widen channel, improve floodwalls, and replace the Pope-Chaucer Bridge
Flood, Heavy
Precipitation/Atmospheric
River
PA-3 Newell Creek Bridge replacement project to accommodate a 100-year flood event.
Flood, Heavy Rain, High Wind,
Atmospheric River
PA-6 Storm Drain System Replacement and Rehabilitation to maintain the integrity of the storm drain system of deteriorated storm drain infrastructure to eliminate potential pipeline blockages that could cause street flooding
Flood, Heavy Rain, High Wind,
Atmospheric River
PA-7 Recycled Water Pipeline Expansion Project to expand the recycled water purple pipeline within South Palo Alto towards Stanford Research Park.
Drought, Climate Change
PA-8 Continue to maintain good standing and compliance in the NFIP and improve Community Rating System Class to provide higher CRS premium discounts.
Flood, Heavy Rain, High Wind
PA-10 Construct new public Safety Building to mitigate current risks to public safety essential services.
Earthquake, Terrorism
PA-11 Rebuild Fire Station 4 to reduce impact from seismic events Earthquake, Terrorism PA-13 Replace the Baylands Tide Gate to reduce flood hazards in the Palo Alto flood zone.
Flood, Heavy Rain, High Wind,
Atmospheric River, Dam and
Levee Failure, Tsunami
PA-15 Implement Wastewater Long-Range Facilities Plan to improve facilities for treatment and discharge of waste; and to improve water recycling opportunities
Flood, Heavy Rain, High Wind,
Extreme Heat, Earthquake,
Sea Level Rise
Action
Item # Action Item Description Hazard(s) Mitigated
PA-19 Install Fiber Optic Service to Black Mountain Radio Repeater Site to improve public safety communications along Skyline Drive.
Earthquake, Heavy
Precipitation/Atmospheric
River, High Wind, Wildfire,
Space Weather
PA-21 Construct a second electrical transmission interconnection to PG&E using a new corridor to reduce the single dependency of our connection to the electric grid.
Wildfire, Power Outage,
Heavy Precipitation /
Atmospheric River, Extreme
Heat/Extreme Cold, High
Wind, Space Weather
PA-27 Address hazardous fuels and reduce structural ignitability in the Foothills region in accordance with the Community Wildfire Protection Plan and Foothills Fire Management Plan.
Wildfire, Extreme
Temperature
PA-29 Consider a policy for Seismic Retrofitting of earthquake prone structures.
Earthquake
PA-32 Conduct public education that raises awareness of Palo Alto threats and hazards and improves community resilience.
All hazards, including
Earthquake, Dam Failure,
Flood, Wildfire, Landslide,
Tsunami, Heavy Rain, High
Wind, Extreme Heat, Drought
PA-36 Where appropriate, support retrofitting, purchase or relocation of structures located in high hazard areas and prioritize those structures that have experienced repetitive losses.
All hazards, including
Earthquake, Flood, Dam
Failure, Heavy Rain, High
Wind, Wildfire
PA-37 Integrate the hazard mitigation plan into other plans, ordinances and programs that dictate land use decisions within the community.
All hazards, including
Earthquake, Flood, Dam
Failure, Wildfire, Landslide,
Tsunami, Heavy Rain, High
Wind, Extreme Heat, Drought
PA-38 Actively participate in the plan maintenance protocols outlined in Volume 1 of the hazard mitigation plan.
All hazards
1 Seismic retrofit two existing potable water storage reservoirs.
Foundation work and anchorage will be retrofitted along the lower sections of the tank shell to restrain the tank against uplift, The tanks have a combined storage capacity of 2.0 million gallons, and they are planned to store emergency water storage for the City of Palo Alto.
Earthquake, Landslide
2 Replace non-seismically restrained potable water piping in liquification zones with new fused and fully restrained piping. 10 miles of unrestrained pipe within a liquification zone will be replaced with fused HDPE piping.
Earthquake
3 Install two permanent standby stationary generators at Dahl and Park Pumping Potable Water Stations. These stations are located in WUI areas and service other WUI designated properties. Power lines are deenergized during wildfire events and standby stationary generators will be imperative to ensure power supply and continued operation of critical pumping facilities during a wildfire event.
Earthquake, Wildfire, Power
Outages, High Wind
Action
Item # Action Item Description Hazard(s) Mitigated
4 Wildfire hardening of critical utilities infrastructure. This action would remove and replace the existing roof and install a new roofing system, soffit, fascia, and front door with WUI compliant materials, systems, and techniques. All vent screens will be removed and replaced with WUI compliant mesh. All vegetation within 30-feet of the structures will be removed and trees limbed for adequate defensible space around each structure. There is a total of four structures located at four different sites, located in and round the Foothills Nature Preserve Area in the City of Palo Alto.
Wildfire, Smoke, Air Quality,
High Wind
5 Conduct an assessment for electrification of City facilities to achieve at least an 80 percent reduction in current natural gas usage by 2030. This assessment will provide a schedule, cost estimate, and timeline of what facilities this electrification must occur at to achieve the goals of the SCAP per this scenario.
Climate Change
6 Apply mitigation techniques to approximately 11 miles of overhead line to mitigate the possibility of a wildfire due to overhead electric lines.
This could include the utilization of more robust equipment or construction practices; rerouting to avoid vegetation and improve access for inspection and maintenance; or converting the overhead lines to underground where feasible.
Wildfire, Smoke, Air Quality,
High Wind
7 Study a location of historic seepage from the Foothills Nature Preserve Dam. This project will investigate and monitor the seepage flow by channelizing seepage flow and potentially installing weir(s).
Dam-Levee Failure,
Earthquake, Flood, Landslide,
Climate Change
8 Restore the width and height of the earthen flood levee between Harbor Road near the Baylands Interpretive Center and the perimeter levee of the airport to six inches above its original height.
Dam-Levee Failure, Flood,
Tsunami, Climate Change
9 Improve the quality of the tertiary-treated recycled water by microfiltration or ultrafiltration followed by reverse osmosis to reduce the level of Total Dissolved Solids (TDS).
Drought, Climate Change
10 Evaluate options for protecting electric substations from outside vandalism and intrusion. If necessary, fences and other protections will be repaired. Security lighting will be designed and issued for construction.
Terrorism and Weapons of
Mass Destruction, Active
Shooter
Approval and Adoption.
The MJMHP planning process culminated in September 2023 with the completion of final draft documents that the County provided to the State of California OES for review. This initiated the higher-level review process by the State and by the Federal Emergency Management Agency.
This review process took eleven months to receive State and Federal approval of the plan.
FEMA’s approval of the Santa Clara County Multijurisdictional Hazard Mitigation Plan 2023 remains for a period of five years from the original approval date of February 8, 2024 for all approved participants. Prior to February 8, 2029, Santa Clara County and all participating jurisdictions are required to review and revise the plan to reflect changes in development, progress in local mitigation efforts, and changes in priorities, and resubmit it for approval in order to continue to be eligible for mitigation project grant funding.
With final State and FEMA approval of the MJMHP and Jurisdictional Annexes, the City Council can now formally adopt the City’s LHMP by resolution (Attachment A). The City also can meet the requirements of Assembly Bill 2140 (2006). There are several steps the City is taking to adhere to these requirements and Cal OES guidance:
•Formally adopt the most current, approved LHMP into the Safety Element of the General Plan via resolution.
oThis language is included in the council resolution for this staff report. •Include language within the Safety Element of your General Plan that references your LHMP.
oThis is already done in Comprehensive Plan policy S2.1 •Included a web link, appendix, or language within the Safety Element that directs the public to the most current, approved LHMP in its entirety. oThis is included in the Council resolution as an exhibit. •E-mail the link to the updated Comprehensive Plan Safety Element web page along with the signed, adoption resolution(s) to the Cal OES AB 2140 inbox [email protected] for review and approval.
oOES will do this once all steps are complete.
Compliance with these steps makes the City eligible to be considered for part or all of its local- share costs on eligible Public Assistance projects to be provided by the state through the California Disaster Assistance Act (CDAA). AB 2140 compliance is not a requirement; however, if the City is compliant, it is eligible to be considered for an additional 6.25% local share to be funded by the state, essentially covering the entire local-share cost for eligible Public Assistance projects in the future.
In order to fulfill the requirements of AB 2140, staff made a small amendment to Policy S2.1 to add a web link location for the current Local Hazard Mitigation Plan on the City‘s website. This amendment triggered California Government Code 65302.5 to provide the amendment to these State agencies for review: California Geologic Survey with a 30 day review period and State Board of Forestry and Fire Protection with a 45 day review period. Staff received comments back from both agencies, neither being substantive enough to require any further changes to the Safety Element, but with two recommendations for consideration during the next comprehensive Safety Element update. The California Geological Survey suggests that staff use seismic risk source material from their website in the determination of risks, and provide web links to seismic maps provided on their website.
Mitigation Plan Status Update.
On an annual basis, the Office of Emergency Services will provide an Information Report to the City Council with an update on the status of the 27 projects in the 2023 LHMP.
FISCAL/RESOURCE IMPACT
There is no financial impact associated with approving this report. Each of the mitigation actions will come with an associated cost based on the type of project. The actions listed are a combination of CIP, for which funding is already established, general funded projects that are already ongoing within departments (existing departmental funds are used), and projects that would require other sources of funding (grant funding, or other agency funding). Of the 17 actions moving forward from the 2017 plan, seven actions fall within departmental general funds for implementation, eight actions are CIP-funded, and two are reliant on other agency funds to implement. As needed, departments will review actions as part of the annual budget development.
STAKEHOLDER ENGAGEMENT
The City’s Local Planning Team Members participated in the MJHMP by attending meetings on the Plan Kick-Off, Risk Assessment, Capabilities Assessment, Mitigation Strategy, Wrap-up, and one-on-one meetings with the planning consultant. The City also shared information regarding public opportunities to participate in the draft plan update utilizing the digital survey and seven in-person and virtual public outreach meetings. Further, the City team was provided the opportunity to review the draft plan prior to submittal to Cal OES and FEMA.
The City supported a “whole community” approach to this plan update. Neighboring communities, local and regional agencies involved in mitigation activities, agencies that have the authority to regulate development as well as businesses, academia, and other private and nonprofit interests were invited to be involved in the planning process by participating in planning meetings, public meetings, or reviewing the draft plan. In addition to the wide variety of stakeholders identified by the County, other stakeholders the City of Palo Alto recommended including were the Palo Alto Planning and Transportation Commission, San Francisquito Creek Joint Powers Authority, Stanford University, Stanford Healthcare, Palo Alto Medical Foundation, Emergency Services Volunteer Representatives, Palo Alto Chamber of Commerce, City of East Palo Alto, City of Menlo Park, Palo Alto Unified School District, Life Moves, Avenidas, Downtown Streets Team, Ravenswood Family Health Center, and Vista Center for the Blind and Visually Impaired. Additional stakeholders that were able to participate are listed in Volume I of this plan.
In addition to inviting a wide range of stakeholders, the City supported public outreach and engagement through distributing a digital survey utilizing social media. This survey reached members of underserved populations, including primarily non-English speaking households.
ENVIRONMENTAL REVIEW
This staff report is not a project under the California Environmental Quality Act (CEQA).
Adoption of the City’s 2023 LHMP into the Safety Element of the 2030 Comprehensive Plan also does not require additional environmental review; on November 13, 2017, the City Council adopted Resolution 9720, certifying an Environmental Impact Report for City of Palo Alto Comprehensive Plan 2030, of which the Safety Element is a part. This amendment to the Safety Element will not result in any new impacts or increase in the severity of previously identified impacts and therefore no additional environmental review is required.
ATTACHMENTS
Attachment A: Resolution Adopting the Multi-Hazard Jurisdiction Plan.
Attachment B: Volume II – City of Palo Alto Jurisdictional Annex Attachment C: Palo Alto Action Plan
APPROVED BY:
Chief Ken Dueker, Director Office of Emergency Services