CITY COUNCIL
Regular Meeting
Monday, June 16, 2025
Council Chambers & Hybrid
5:30 PM
Amended Agenda
Amended agenda items appear below in RED
Palo Alto City Council meetings will be held as “hybrid” meetings with the option to attend by teleconference or in person. Information on how the public may observe and participate in the meeting is located at the end of the agenda. The meeting will be broadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen Media Center https://midpenmedia.org.
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PUBLIC COMMENTS
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TIME ESTIMATES
Listed times are estimates only and are subject to change at any time, including while the meeting is in progress. The Council reserves the right to use more or less time on any item, to change the order of items and/or to continue items to another meeting. Particular items may be heard before or after the time estimated on the agenda. This may occur in order to best manage the time at a meeting or to adapt to the participation of the public. 1 June 16, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas.
CALL TO ORDER
AGENDA CHANGES, ADDITIONS AND DELETIONS
PUBLIC COMMENT (5:35 - 6:05 PM)
Members of the public may speak in-person ONLY to any item NOT on the agenda. 1-3 minutes depending on number of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard at the end of the agenda.
COUNCIL MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS (6:05 - 6:15 PM) Members of the public may not speak to the item(s).
CONSENT CALENDAR (6:15 - 6:20 PM)
Items will be voted in one motion unless removed from the calendar by three Council Members.
1. Approval of Minutes from June 2, 2025 Meeting
2. Adoption of a Resolution Revising the Citywide Records Retention Schedule and Repealing Resolution No. 9565
3. Approval of Office of the City Auditor Emergency Preparedness: Wildfire Audit Report as Recommended by the Policy & Services Committee
4. Recommendation that the City Council to Refer to the Policy and Services Committee an Update to the City of Palo Alto Advocacy Process Manual to Address Sponsorship of Legislation; CEQA – Not a Project
5. Policy & Services Committee Recommends Approval to Amend the City Auditor Bakertilly FY2024 and FY2025 Budgets for Task Orders to Realign the Authorized Budgets with a Net Zero Impact; CEQA - Not a Project
6. Approval of the Council Appointed Officers (CAO) Committee‘s Recommendation to Approve the CAO Annual Evaluation Process, Timeline, and Questions; and Approval of Professional Services Contract Number C25193915 with the Municipal Resources Group, LLC (MRG) in an Amount Not to Exceed $208,500 for Council Appointed Officer Performance Evaluation Services for a Period of Three Years. CEQA Status - Not A Project
7. Recommend the City Council Adopt the Fiscal Year 2026 Investment Policy as Recommended by the Finance Committee: CEQA Status – Not a Project
8. Adoption of Memoranda of Agreement with International Association of Fire Fighters (IAFF) Local 1319, Fire Chiefs Association (FCA), and Utilities Managers and Professionals Association of Palo Alto (UMPAPA) for Terms Ending June 30, 2028, and Adoption of the
2 June 16, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at
www.paloalto.gov/agendas
.
Updated Management and Professional Compensation Plan and Corresponding Salary Schedules; CEQA Status – Not a Project
Supplemental Report added, Public Comment
9. Approval of a Surveillance Use Policy for Security Cameras at Ada's Café at Mitchell Park Community Center and Library; CEQA Status - Not a Project Updated Consent Questions
10. City Council Appointment of the Castilleja Neighborhood Committee in Accordance with Condition Number 33 Contained in Record of Land Use Action 2022-22 Authorizing Redevelopment of Private School at 1310 Bryant Street (Castilleja School).
Environmental Assessment: Exempt from CEQA Pursuant to CEQA Guidelines Section 15061(b)(3).
11. Accept Electric System Reliability Key Performance Indices; CEQA – Not a Project
12. Approval of a Director’s Interpretation Pursuant to PAMC Section 18.01.025 Concluding That Noncomplying Residential Gross Floor Area may not be Relocated Within a Structure; Denial of the Associated Appeal; Direction to Prepare a Future Code Amendment for Administrative De Minimis Exceptions to the Zoning Code; CEQA:
Exempt Pursuant to CEQA Guidelines Section 15061(b)(3)
Consent Questions
13. Approve and Authorize the City Manager or Designee to Execute Purchase Orders as Needed with the Okonite Company, Extending the Term for the Blanket Purchase Order for Purchase and Standardization of Underground Cable Through December 31, 2025, and to Increase the Not-to-Exceed Amount by $100,000, for the Extension Period. CEQA Status: Not a Project.
14. Approval of Construction Contract No. C25194279 with Estate Design and Construction, Inc. in the Amount Not-to-Exceed $283,770 and Authorization for the City Manager or Their Designee to Negotiate and Execute Change Orders up to a Not-to-Exceed Amount of $28,377 for the University Underpass Refurbishment Project; Capital Improvement Program University Avenue Parking Improvements (PF-14003) and Street Lights Improvements (PO-05054) projects; CEQA Status – Exempt under CEQA Guidelines Section 15301(c)
3 June 16, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at
www.paloalto.gov/agendas
.
15. Approval of Change Order No. 3 to Contract C22183580 with MP Nexlevel of California, Inc., to reallocate funding from Change Order No. 2 to the Fiber-to-the-Premises (FTTP) Project and to incorporate FTTP into the Scope of Work extending through August 31, 2025; CEQA Status - For FTT P, Council action on this item is within the scope of the Final Initial Study and Mitigated Negative Declaration (IS/MND) for the Fiber-to-the-Premises Project, adopted on June 17, 2024; otherwise exempt.
Public Comment
16. Approval of Two Professional Services Contracts for a Term of Two Years: C25193536 with 4Leaf, Inc. in an Amount Not-to-Exceed $291,253 and C25194267 with Interface Engineering, Inc. in an Amount Not-to-Exceed $101,585 for Fire Station 4 Replacement Capital Improvement Program Project (PE-18004); CEQA Status - Exempt under CEQA Guidelines Sections 15302 and 15303
Public Comment
17. Approval of Contract Amendment No. 4 to Contract Number C19171363 with Professional Account Management LLC, dba Duncan Solutions, to Extend the Contract for one year to June 30, 2026, and to Adjust Billing Rates, Without an Increase to Compensation, for a Not -to-Exceed Amount of $767,000 for Parking Permitting and Citation Management Services; CEQA Status -- Not a Project.
Updated Consent
Questions
18. Approval of Amendment No. 3 to Contract Number C23184827 with Nomad Transit, LLC (Via) in the Amount of $1,100,000 for a total not to exceed $4,901,550 over a Four-Year Term to Continue the City of Palo Alto On-Demand Transit Service through June 30, 2026; CEQA status - not a project.
Item Deferred to June 17, 2025 City Council Meeting
19. QUASI-JUDICIAL. 1033 Amarillo Avenue [25PLN-00015]: Request for a Parcel Map with Conditional Exceptions to Subdivide a 20,774-Square-Foot R-1 Property into Two Lots (10,661 and 10,113 Square Feet). Exceptions include Minimum Lot Width, Maximum Lot Size, and Residential Density. Zoning District: R-1 Single Family Residential. CEQA:
Exempt pursuant to CEQA Guidelines Section 15301 (Existing Facilities).
20. SECOND READING: Ordinance of the Council of the City of Palo Alto Amending: Chapter
18.14 (Housing Incentives) of the Palo Alto Municipal Code to Implement Program 3.4E of the 2023-2031 Housing Element to Expand and Revise Regulations for the El Camino Real Focus Area; Making Conforming Amendments to Chapter 16.58 (Development Impact Fees) (FIRST READING: May 27, 2025; PASSED: 5-0-2, Lu, Veenker recused) Public
Comment
21. SECOND READING: Ordinance of the Council of the City of Palo Alto Amending Title 16 (Building Regulations) and Title 18 (Zoning) of the Palo Alto Municipal Code to Amend
4 June 16, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at
www.paloalto.gov/agendas
.
Requirements Relating to Accessory Dwelling Units and Junior Accessory Dwelling Units (FIRST READING: May 12, 2025; PASSED 7-0)
CITY MANAGER COMMENTS (6:20 - 6:35 PM)
BREAK (15 MINUTES)
ACTION ITEMS (Item 22: 6:50 - 7:50 PM, Item 23: 7:50 - 9:20 PM, Item 24: 9:20 - 10:00 PM) Include: Report of Committees/Commissions, Ordinances and Resolutions, Public Hearings, Report of Officials, Unfinished Business and Council Matters.
22. PUBLIC HEARING & PROPOSITION 218 HEARING: Finance Committee Recommends Adoption of Six Resolutions: 1) Approving the Fiscal Year 2026 Wastewater Collection Utility Financial Forecast and Reserve Management Practices, Amending Wastewater Collection Rate Schedules S-1, S-2, S-6 and S-7, and Repealing Wastewater Collection Rate Schedules S-3 and S-4; 2) Approving the Fiscal Year 2026 Water Utility Financial Forecast, Reserve Management Practices and Reserve Transfers, and Amending Water Rate Schedules W-1, W-2, W-3, W-4, and W-7; 3) Approving the Fiscal Year 2026 Gas Utility Financial Forecast and Reserve Management Practices, Reserve Transfer, and General Fund Transfer, Approving the Distribution of a Climate Credit to Small and Medium Capacity G-2 Customers in December 2025, and Amending Gas Rate Schedules G-1, G-2, G-3 and G-10; 4) Approving the Fiscal Year 2026 Electric Utility Financial Forecast, Reserve Management Practices and Reserve Transfers, and Amending Electric Rate Schedules E-1, E-2, E-2-G, E-4, E-4-G, E-4 TOU, E-7, E-7-G, E-7 TOU, E-14, E-16, E- EEC-1, and E-NSE-1; 5) Amending Utility Rate Schedules EDF-1 and EDF-2, and Approving the Palo Alto Fiber Broadband Internet Services Rate Schedule F-1; and 6) Amending Storm Water Utility Rate Schedule D-1; CEQA Status: Not a project under CEQA Guidelines Sections 15378(b)(4) and (5) and Exempt Under Section 15273(a) Staff
Presentation, Public Comment
23. PUBLIC HEARING: Presentation on Status of Vacancies and Recruitment and Retention Efforts and Adoption of Budget Ordinance for Fiscal Year 2026, Including the Operating and Capital Budgets and Municipal Fee Schedule; Adoption of a Resolution determining the Appropriations Limit for Fiscal Year 2026; Vacancies and Recruitment Update (AB2561 Compliance); and Approval of FY 2026 Non-Profit Workplan Phase I Awards as Recommended by the Policy & Services Committee;
and Adoption of a Resolution to
Extend and Amend the Development Services Reserve Fund Policy ; CEQA Status – Not a
Project
Title Updated, Supplemental Report added, Staff Presentation, SEIU Presentation, Public Comment
24. Approval of Five Items to Support the Newell Road/San Francisquito Creek Bridge
5 June 16, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at
www.paloalto.gov/agendas
.
Replacement Project PE-12011: 1) Construction Contract No. C25194068 with Granite Construction Company in the Amount Not-to-Exceed $9,399,787 and Authorization for the City Manager or Their Designee to Negotiate and Execute Change Orders to the Contract up to a Not-to-Exceed Amount of $939,979; 2) Approval of Professional Services Contract No. C25190454 with Zoon Engineering, Inc, in the Amount of $2,559,915 for Construction Management Services through December 31, 2026; 3) Approval of Amendment No. 7 to Contract No. C12142825 with NV5, Inc. to extend the contract term through December 31, 2026 for Construction Support; 4) Approval of Amendment No. 3 to a Cost Share Agreement with Santa Clara Valley Water District Providing Local Matching Funds in the Amount $155,458 for Design, Right of Way Appraisal and Acquisition and Construction Support for the Newell Road/San Francisquito Creek Bridge Replacement Project; and 5) Adoption of a FY 2025 Budget Amendment in the Capital Improvement Fund; CEQA Status - Environmental Impact Report for Newell Road/San Francisquito Creek Bridge (Resolution No. 9889) Staff
Presentation, Public Comment
ADJOURNMENT
INFORMATION REPORTS
Information reports are provided for informational purposes only to the Council and the public but are not listed for action or discussion during this meeting’s agenda.
A.
Boards, Commissions, and Committees Mid-Year Attendance Report; CEQA Status - Not a Project
B.
Summary of Downtown Housing Plan Community Assessment Report and Next Steps.
CEQA Status: Exempt under CEQA Guidelines Section 15262.
C.
Rental Residential Vacancy Rate Determination for Properties Containing Three or More Dwelling Units for the First Half of 2025. CEQA: Not a Project, Pursuant to CEQA Guidelines Section 15378(b).
OTHER INFORMATION
Standing Committee Meetings this week
Finance Committee June 17, 2025 CANCELED
Retail Committee June 18, 2025
Public Comment Letters
Schedule of Meetings
6 June 16, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at
www.paloalto.gov/agendas
.
AMENDED AGENDA ITEMS
8. Adoption of Memoranda of Agreement with International Association of Fire Fighters (IAFF) Local 1319, Fire Chiefs Association (FCA), and Utilities Managers and Professionals Association of Palo Alto (UMPAPA) for Terms Ending June 30, 2028, and Adoption of the Updated Management and Professional Compensation Plan and Corresponding Salary Schedules; CEQA Status – Not a Project
Supplemental Report added
18. Approval of Amendment No. 3 to Contract Number C23184827 with Nomad Transit, LLC (Via) in the Amount of $1,100,000 for a total not to exceed $4,901,550 over a Four-Year Term to Continue the City of Palo Alto On-Demand Transit Service through June 30, 2026; CEQA status - not a project.
Item Deferred to June 17, 2025 City Council Meeting
23. PUBLIC HEARING: Presentation on Status of Vacancies and Recruitment and Retention Efforts and Adoption of Budget Ordinance for Fiscal Year 2026, Including the Operating and Capital Budgets and Municipal Fee Schedule; Adoption of a Resolution determining the Appropriations Limit for Fiscal Year 2026; Vacancies and Recruitment Update (AB2561 Compliance); and Approval of FY 2026 Non-Profit Workplan Phase I Awards as Recommended by the Policy & Services Committee;
and Adoption of a Resolution to Extend and Amend the Development Services Reserve Fund Policy
; CEQA Status – Not a Project
Title Updated, Supplemental Report
added
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City Council
Staff Report
Report Type: CONSENT CALENDAR
Lead Department: City Clerk
Meeting Date: June 16, 2025
Report #:2506-4766
TITLE
Approval of Minutes from June 2, 2025 Meeting
RECOMMENDATION
Staff recommends that the City Council review and approve the minutes.
ATTACHMENTS
Attachment A: June 2, 2025 Draft Action Minutes
APPROVED BY:
Mahealani Ah Yun, City Clerk
Item 1
Item 1 Staff Report
Item 1: Staff Report
Pg.
1 Packet Pg. 9 of 1138
CITY COUNCIL
DRAFT ACTION MINUTES
Regular Meeting
June 2, 2025
The City Council of the City of Palo Alto met on this date in the Council Chambers and by virtual teleconference at 5:30 P.M.
Present In Person: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker Present Remotely:
Absent:
Board and Commission Appointments
1. Appointment of Candidates to the Vacancies on the Architectural Review Board; CEQA Status - Not a Project
Architectural Review Board
First Round Voting for Three (3) vacancies (seats 1, 2, 5) on the Architectural Review Board ending March 31, 2028
Ashutosh Gupta: Lauing, Stone
Bei Xu: Lu, Lythcott-Haims
David Hirsch: Lauing, Stone, Lu, Veenker, Reckdahl, Burt, Lythcott-Haims Grace Lee: Burt
Khelan Bhatt: Veenker
Marton Jojarth: Reckdahl, Burt
Naveen Govind:
Sema Yavuz:
Yingxi Chen: Lauing, Stone, Lu, Veenker, Reckdahl, Lythcott-Haims Candidate David Hirsch receiving seven votes is appointed to the full -term expiring March 31, 2028 (seat 2).
Candidate Yingxi Chen receiving six votes is appointed to the full -term expiring March 31, 2028 (seat 5).
No other candidate received four votes required to be appointed to the full -term expiring March 31, 2028. A second round of voting is required.
Item 1
Attachment A - June 2,
2025 Draft Action
Minutes
Item 1: Staff Report
Pg.
2 Packet Pg. 10 of 1138
DRAFT ACTION MINUTES
City Council Meeting
Draft Action Minutes: 06/02/2025
Second Round Voting for One (1) vacancy (seat 1) on the Architectural Review Board ending March 31, 2028
Ashutosh Gupta: Lauing, Stone
Bei Xu: Lythcott-Haims, Lu
Grace Lee:
Khelan Bhatt: Veenker
Marton Jojarth: Reckdahl, Burt
Naveen Govind:
Sema Yavuz:
No candidate received four votes required to be appointed to the full -term expiring March 31, 2028. A third round of voting is required.
Third Round Voting for One (1) vacancy (seat 1) on the Architectural Review Board ending March 31, 2028
Ashutosh Gupta: Lauing
Bei Xu: Stone, Lythcott-Haims, Lu
Khelan Bhatt:
Marton Jojarth: Veenker, Reckdahl, Burt
No candidate received four votes required to be appointed to the full -term expiring March 31, 2028. A fourth round of voting is required.
Fourth Round Voting for One (1) vacancy (seat 1) on the Architectural Review Board ending March 31, 2028.
Ashutosh Gupta:
Bei Xu: Lu, Stone, Lythcott-Haims
Marton Jojarth: Lauing, Reckdahl, Burt, Veenker
Candidate Marton Jojarth receiving four votes is appointed to the full -term expiring March 31, 2028 (seat 1).
Closed Session
2. CONFERENCE WITH LEGAL COUNSEL—EXISTING LITIGATION
Subject: Downtown Vibrancy v. City of Palo Alto, et al., Santa Clara County Superior Court
Case No. 25CV464012
Authority: Government Code Section 54956.9(d)(1)
AA1. CONFERENCE WITH REAL PROPERTY NEGOTIATORS
Authority: Government Code Section 54956.8
Item 1
Attachment A - June 2,
2025 Draft Action
Minutes
Item 1: Staff Report
Pg.
3 Packet Pg. 11 of 1138
DRAFT ACTION MINUTES
City Council Meeting
Draft Action Minutes: 06/02/2025
Property: 2575 East Bayshore Road; Assessor’s Parcel Number 008-03-015 Negotiating Parties: C H LLC. City Negotiators: Ed Shikada, Kiely Nose, Alan Kurotori, Sunny Tong
Subject of Negotiations: Purchase and/or Lease Price and Terms of Payment MOTION: Council member Veenker moved, seconded by Council member Lu to go into Closed Session.
MOTION PASSED: 7-0
Council went into Closed Session at 5:57 P.M.
Council returned from Closed Session at 7:15 P.M.
Mayor Lauing announced no reportable action.
Agenda Changes, Additions and Deletions
Public Comment
Council Member Questions, Comments and Announcements
Study Session
3. Bicycle and Pedestrian Transportation Plan (BPTP) Update: Draft Project Prioritization Framework and Prioritized Project Lists
NO ACTION
Consent Calendar
MOTION: Council member Burt moved, seconded by Council member Reckdahl to approve Agenda Item Numbers 4-11.
MOTION PASSED: 7-0
4. Approval of Minutes from May 19, 2025 Meeting
Item 1
Attachment A - June 2,
2025 Draft Action
Minutes
Item 1: Staff Report
Pg.
4 Packet Pg. 12 of 1138
DRAFT ACTION MINUTES
City Council Meeting
Draft Action Minutes: 06/02/2025
5. Approval of and Authorization of City Manager or their Designee to Execute an Exchange Agreement with Midpeninsula Regional Open Space District for Replacement of Overhead Utility Facilities with Underground Facilities and Exchange and Transfer Real Property Interests within Monte Bello Open Space Preserve and Rancho San Antonio Open Space Preserve, Assessor’s Parcel Numbers 351 -25-014, 351-06-025, 351- 09-002, and 351-12-069; CEQA Status – Exempt Under CEQA Guidelines Section 15302
6. Adoption of a Resolution Approving the Safe Streets for All (SS4A) Safety Action Plan as Recommended by the Policy & Services Committee
7. Approval of Contract Amendment Number 4 to Contract Number C16166822 with ARC Document Solutions in the Amount of $1,020,000, Bringing the New Total Not To Exceed to $3,855,340, for Copiers/Printers to increase; CEQA Status - Not a Project
8. Approval of Contract Amendment No. 2 to Contract Number C21179340 with Baker Tilly US, LLP in the Amount of $2,126,250 and to Extend Term to June 30, 2026, with Option to Extend for Two Years, for Internal Auditing Services; Revised Total Not to Exceed is $5,552,500, CEQA Status – Not a Project.
9. Approval of Construction Contract Number C25194073 with G. Bortolotto & Company Inc. in the Amount of $3,817,942 for the Fiscal Year 2025 Asphalt Paving Project; Capital Improvement Program Projects PE -86070, PE -09003, PL -12000, and PG -06001; and Authorization for the City Manager or Their Designee to Negotiate and Execute Change Orders up to a Not‐to‐Exceed Amount of $376,926; CEQA Status – Exempt under CEQA Guidelines Section 15301(c)
10. Approval of Construction Contract No. C25193583 with Stronger Building Services in the Not-to-Exceed Amount of $440,250 for the Lucie Stern Community Center Theater Roof Underlayment Replacement Project as part of the Roofing Replacement Program, Capital Improvement Program PF-00006 and Authorization for the City Manager or Their Designee to Negotiate and Execute Change Orders for Related Additional but Unforeseen Work that May Develop During the Project Up to a Not -to-Exceed Amount of $44,025; CEQA status - Exempt under CEQA Guideline Sections 15301 and 15302
11. Adoption of a Resolution for Senate Bill 1, the Road Repair and Accountability Act, for Fiscal Year 2026, Providing the Project List for the Street Maintenance Project, Capital Improvement Program Project (PE-86070); CEQA Status – Not a Project
City Manager Comments
Ed Shikada, City Manager
Item 1
Attachment A - June 2,
2025 Draft Action
Minutes
Item 1: Staff Report
Pg.
5 Packet Pg. 13 of 1138
DRAFT ACTION MINUTES
City Council Meeting
Draft Action Minutes: 06/02/2025
Action Items
12. LEGISLATIVE. Adoption of a Temporary, Emergency Ordinance Amending Title 18 and Title 21 to Reflect Changes in State Law in Accordance with Senate Bill 1123 and Related Direction to Staff Regarding Updates to the Land Use Element of the Comprehensive Plan. CEQA Status: Exempt Pursuant to Government Code Sections 65852.28 and 66499.41.
Agenda Item Number 12 deferred to a future City Council meeting June 9, 2025.
Adjournment: The meeting was adjourned at 9:47 P.M.
ATTEST: APPROVED:
____________________ ____________________
City Clerk Mayor NOTE: Action minutes are prepared in accordance with Palo Alto Municipal Code (PAMC)
2.04.160(a) and (b). Summary minutes (sense) are prepared in accordance with PAMC Section
2.04.160(c). Beginning in January 2018, in accordance with Ordinance No. 5423, the City Council found action minutes and the video/audio recordings of Council proceedings to be the official records of both Council and committee proceedings. These recordings are available on the City’s website.
Item 1
Attachment A - June 2,
2025 Draft Action
Minutes
Item 1: Staff Report
Pg.
6 Packet Pg. 14 of 1138
City Council
Staff Report
From: City Clerk
Report Type: CONSENT CALENDAR
Meeting Date: June 16, 2025
Report #:2504-4575
TITLE
Adoption of a Resolution Revising the Citywide Records Retention Schedule and Repealing Resolution No. 9565; CEQA Status – Not a Project
RECOMMENDATION
Staff recommends that the City Council adopt a Resolution adopting a revised Records Retention Schedule and repealing Resolution No. 9565.
BACKGROUND
The City Clerk’s Office oversees the administration and retention of the City’s official records through the Records and Information Management (RIM) Program. The program facilitates public access to City information, protects the City’s vital records, provides a process for the disposal of obsolete records, and provides the availability of essential information for the resumption of operation in the event of a major disaster.
The City’s Records Retention Schedule is an integral part of the RIM Program. The Schedule describes the type of records each department maintains, how long records will be retained and the relevant statutory reference, and department remarks, if any. Departments use their respective retention schedule to organize and properly dispose of obsolete records past their retention date.
ANALYSIS
The City last updated its Records Retention Schedule in 2015 1. Staff from the City Clerk’s Office, City Attorney’s Office, and each department collaborated on the Schedule update. The revised schedule includes updated statutory references, reflects recordkeeping best practices, and incorporates department needs and preferences, subject to retention requirements.
Departments may retain certain records longer than the statutory minimum desired or Redline 1 City Council, December 7, 2015; Agenda Item #9; SR #6392 https://portal.laserfiche.com/Portal/DocView.aspx?id=57088&repo=r-704298fc& Item 2
Item 2 Staff Report
Item 2: Staff Report
Pg.
1 Packet Pg. 15 of 1138
and clean versions of the revised Schedule are included as Attachment B and Attachment C. versions of the revised Schedule are included as Attachment B and Attachment C.
FISCAL/RESOURCE IMPACT
There is no fiscal impact.
STAKEHOLDER ENGAGEMENT
Departments developed Records Retention Schedules in cooperation with the offices of the City Clerk and City Attorney to address the records held by each respective department. Owning departments have reviewed their respective schedules for administrative, historical, and fiscal value. The City Attorney’s Office has reviewed and approved the Retention Schedules for compliance with records retention regulations.
ENVIRONMENTAL REVIEW
City Council action on this item is not a project as defined by CEQA because it is an organizational or administrative activity that will not result in direct or indirect physical changes in the environment. CEQA Guidelines section 15378(b)(5).
ATTACHMENTS
Attachment A: Resolution Adopting a Citywide Records Retention Schedule and Repealing Resolution No. 9565
Attachment B: 2025 Records Retention Schedule - Redline Attachment C: 2025 Records Retention Schedule - Clean
APPROVED BY:
Mahealani Ah Yun, City Clerk
Staff: Christine Prior, Deputy City Clerk
Item 2
Item 2 Staff Report
Item 2: Staff Report
Pg.
2 Packet Pg. 16 of 1138
1 Resolution No. ______
Resolution of the Council of the City of Palo Alto Adopting a Citywide Records Retention Schedule and Repealing Resolution No. 9565
R E C I T A L S
A. The destruction of certain public records is authorized by State law in Government Code sections 34090, et seq.
B. A system for the retention and schedule for the destruction of records and working papers that are no longer needed for administrative, legal, fiscal, historical, or research purposes is deemed appropriate.
C. The City Clerk has developed and is responsible for the City's Records and Information Management ("RIM") Program, including guidelines and procedures prepared pursuant to that Program.
D. On April 22, 1996 pursuant to Resolution No. 7579, the Council adopted records retention schedules for the Police, Planning and Community Environment, Public Works, and Utilities Departments and amended records retention schedules for the offices of the City Attorney, City Auditor, City Clerk and City Manager, Administrative Services, Community Services, Fire and Human Resources Departments.
E. The Council adopted revised citywide records retention schedules on February 5, 2007 pursuant to Resolution No. 8688 and on December 7, 2015 pursuant to Resolution 9565.
F. It is now necessary and desirable to adopt revised citywide records retention schedules.
G. The City Attorney has reviewed and approved the proposed records retention schedules.
The Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council hereby authorizes the head of each department to maintain and destroy records in accordance with their respective departmental retention schedules, attached hereto and incorporated herein by reference, subject to the written approval of the City Attorney prior to any proposed destruction, and subject further to the Records and Information Management Program and any guidelines or procedures the City Clerk may from time to time promulgate thereunder.
Item 2
Attachment A -
Resolution Adopting a
Citywide Records
Retention Schedule and
Repealing Resolution No.
9565
Item 2: Staff Report
Pg.
3 Packet Pg. 17 of 1138
2 SECTION 2. Resolution No. 9565 is hereby repealed.
SECTION 3. The Council finds that the adoption of this resolution does not constitute a project for purposes of the California Environmental Quality Act, and, therefore, no environmental assessment is required.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
Deputy City Attorney City Manager
City Clerk
Item 2
Attachment A -
Resolution Adopting a
Citywide Records
Retention Schedule and
Repealing Resolution No.
9565
Item 2: Staff Report
Pg.
4 Packet Pg. 18 of 1138
READING THE RETENTION SCHEDULE:
A "HOW TO" GUIDE
BACKGROUND
The Retention Schedule, as approved by the City Co uncil through Resolution, is a legal document. It identifies the types of records and information used and managed by a department, how long that information must be retained at the office and/or off‐site, and when it may be destroyed.
Each department is required to have a current Schedule. It is the responsibility of the department to notify the City Clerk’s Office of any business, organization
al, functional, or legal changes which would impact
their specific Schedule. The City Clerk’s Office coordinates with the departments and Office of the City Attorney (who which reviews them the schedules for compliance with all government codes and regulations) prior to approval by the City Council. The Schedules should be reviewed for accuracy every two to three years by the City Clerk’s and City Attorney’s Offices in conjunction with each respective department.
USING RETENTION SCHEDULES DEFINITIONS
Description – This is the general description of a group of record s with similar business functions and
retention requirements. The description must coincide with file titles maintained by the department.
Total Retention – This refers to the length of time a record must be kept before it is eligible for destruction.
C – Current refers to the current calendar year in which a record is made. The Re tention period begins the
first day of the following calendar year. (For example, Cur+2 means that any record created in 20215 is kept for the two following years, 20216 and 20217. The record would be eligible for destruction after December 31, 20217).
PER – Permanent refers to records that should be kept in perpetuity and never destroyed.
SUP – Supersede indica
tes that old items are replaced by a more current version.
TER—Termination refers to the end date of a contract, agreement, term, etc.
Statutory Refer
ence – This s field includes regulations and codes that govern the retention of a specific record type. All references are to California Code unless otherwise noted.
Remarks – This field includes general comments about the information in this row. When "Department
Opinion" is noted in this column, it means that the Department has decided to maintain the record longer than the legal requirement. "Attorney Opinion" indicates that the retention requirement was established pursuant to the opinion of the City Attorney based on research, past litigation history, and/or the potential for future
litigation on this topic. The 2025 revision preserves Department and Attorney Opinions from previous versions of the schedule.
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
5 Packet Pg. 19 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATION
Correspondence, Messages,
Timecards, Staff Meetings, Studies
C+3
Auditors Opinions
2 OTHER DEPARTMENTS – Finance
Committee‐Agendas, Minutes,
Records, Retention Schedule,
Reports, Audit Work papers,
While
useful Duplicate of City Manager, Auditor
and City Clerk
3 Gifts to the City, Cash & Tangible
Property
C+6 Scanned list on CD Rom in Admin
Svcs Dept files
TREASURY
4 INVESTMENT MANAGEMENT‐
Security Purchases, Sales &
Investment Reports
C+7
Auditors Opinion
5 DEBT MANAGEMENT‐
(a) Deceased Insurance C+3 Department Opinion
(b) Final Bond TER+4 Duplicate Stored Offsite as vital copy backup
(c) Covenant Compliance TER+7 Duplicate stored offsite as vital copy backup
(d) Bank Records C+7 Duplicate stored offsite as vital copy backup
REVENUE COLLECTION
6 (a) Deposit/Reconciliation
Documentation
C+2 GC 34090
(b) Parking Permit Records C+4 GC 34090
(c) Collection Records – UUT, Hand
Written Parking Citations,
Delinquent Accounts, Reconciliation,
Transient Occupancy Tax
C+5
Department Opinion
(d) Utility Receipt Stubs GC 34090
BUSINESS LICENSE TER+4 GC 34090;
CCP 337
LIENS & RELEASES
(a) Recorded Liens & Releases
(b) Supporting Recorded
Documentation
PER
TER+2 GC 34090
BUDGET
7 BUDGET
(a) Final Budget, CIP Budgets, Fee
Schedule
TER+4
(b) Supporting Documents for
Change Requests, Amendments,
Worksheets, Fee Schedules & Cost
Plans
C+2
Auditors Opinion
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
6 Packet Pg. 20 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
(c) Long Range Plans Studies,
Reports, Measurements, Forecasts
& Projections
C+3
Auditors Opinion
REAL ESTATE
8 BINDING INSTRUMENTS
(a) Land – Deeds, Easements PER Duplicate of City Clerk (b) Easement Vacations, Leases &
Purchases
PER Duplicate of City Clerk
(c) Encroachments, Agreements &
Conveyances
PER Duplicate of City Clerk
PURCHASING
9 (a) Council Approved Contracts,
Solicitations & Documents. All Open
Council Approved Contracts,
Solicitations & Documents
TER+ 4 While
Useful
CCP 337.2
CCP 343
Council Approved Contracts
Dduplicate of City Clerk
(b) Service Contracts, Purchase
Orders, Blanket Purchase Orders &
Solicitations & Documents
i. Purchase Orders/Blanket Orders
ii. Service Order Contracts
iii. Council Approved
TER+34
TER+45
TER+7
While
Useful
CCP 337.2
CCP 343
Duplicate of City Clerk
(c) Bids Unawarded Solicitations &
Documents
C+2 GC 34090 Department Opinion vital while
orders are open
10 INTERNAL VENDORS ‐ (Stores &
Print Shop) Reports, Orders,
Returns, Disposal Forms Journal &
Requisitions
C+4
Department and Auditors Opinion
ACCOUNTING
11 YEAR‐END REPORTS
(a) Budget‐to‐Actual C+2 GC 34090
(b) Comprehensive Annual Financial
Report (ACFR)
PER
(c) General Ledger, Encumbrance
Report
C+2 GC 34090
(d) Management Benefits
Transactions, Accruals
C+2 GC 34090
(e) Audit Work Papers & Journal
Entries
C+2
GC 34090
Digital copies of audit work
papers: saved on S drive, Jourrnal
Entries saved on SAP effective
March 2023
(f) ANNUAL PUBLIC IMPROVEMENT
CORPORATION‐STATE
CONTROLLERS REPORT
C+7
Digital copies only
(g) PIC TAX Return C+7 Digital copies only
(g) Annual Street Report C+7 Digital copies only
(h) City Financial Transaction Report Digital copies only Utility Receipt Stubs C+2
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
7 Packet Pg. 21 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ACCOUNTS PAYABLE
12 A/P + UTILITY CHECK
REGISTERS (WARRANTS)
C+7
C+7 Department and Auditors Opinion
(voided checks) Digital copies only
13 CANCELLED/VOIDED
WARRANTS. CHECK VOID FORMS +
BACKUP
C+4
C+7
Department and Auditors Opinion
(VOIDED CHECKS) Digital copies
only
14 VOUCHER PACKETS.
GENERAL WARRANT COPIES WITH
BACKUP FOR A/P, UTILITY REFUNDS,
3RD PARTY AND WIRE TRANSFERS
C+5
C+7 Department and Auditors Opinion
Digital copies only
15 CAPITAL PROJECTS TER+7
Department and Auditors Opinion
Project Files, Street Reports, &
Community Development Block
Grant (CDBG) Billings
Community Development Block
Grant (CDBG) Billings / Drawdown
Digital copies only
ANNUAL PUBLIC IMPROVEMENT
CORPORATION‐STATE
CONTROLLERS REPORT
C+7
CALIFORNIA AVENUE SPECIAL
ASSESSMENT PARKING DISTRICT
C+7
UNIVERSITY AVENUE SPECIAL
ASSESSMENT PARKING DISTRICT
C+7 Digital copies only
ANNUAL INTERGOVERNMENTAL
EXPENDITURES REPORT
C+7 Digital copies only
ZFIR03 AUTHORIZED SIGNATURE
COVER SHEETS
C+7
Cover sheet for batches off
invoices from departments sent to
A/P. Has list of invoices enclosed
and department authorization to
process the invoices.
A/P JOURNAL LOG C+7 Digital copies only
AUTHORIZING SIGNATURE FORMS C+7 Digital copies only TAX RECORDS – Sales Tax Filings,
1099 Tax Filings & Registers
C+7 Digital copies only
16 GENERAL LEDGER‐ General Journal
Entries
C+7 saved on SAP
ACCOUNTS RECEIVABLE and CASH RECEIPTS
16 Backup for invoices created (such as
Airport, Avenidas, & Palo Alto
Community Childcare, Stanford, VTA
and others)
(a) Grants, Disaster Assistance,
Project Fund Requisitions, Arbitrage
Calculations
C+7
Federal & State Audit
Requirements
Duplicate stored offsite as vital
copy backup
Department Opinion
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
8 Packet Pg. 22 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
b) Invoices, Facility Cash Receipts,
and Revenue Collections Cash
Receipts, Cash Receipt Journals and
Utility Cash Receipts
C+7 GC 34090,
CCP 338
Federal & State Audit
Requirements
Duplicate stored offsite as vital
copy backup
Department Opinion
Digital copies only
18 STATE REPORTS – City Reports,
Transit Operators and Component
Units
C+7
Department and Auditors Opinion
19 UTILITIES‐
(a) Loan Reconciliation Work Papers,
Bonds, Banking, Adjustments
(b) Receipts
C+7 GC 34090 Department and Auditors Opinion
20 FIXED ASSETS – Cost Reports,
Reconciliation, Resume of Activity &
Journal Entries
TER+3
Department and Auditors Opinion
21 PAYROLL
C+7 29 CFR
Section
1627.3
Labor
Relations
Section
1174
California
Labor Code
Section
1174
Public Employees Retirement
System and Department Opinion ‐‐
Duplicate stored offsite as vital
copy backup
Garnishment Orders C+7 SB 807 1/2022 CA Record
Retention ‐ 4 Years
Direct Deposit/ W4 Changes C+7 IRS Requirement ‐ 4 years Copies of PSO PAF C+7 4 Years HR owns original copy retention
CalPers Reporting C+7 4 Years HR owns original copy retention
Third Party Reporting C+7 4 years
Payroll Quarterly Tax Reports C+7 IRS Requirement ‐ 4 years Payroll Masterfile C+7 4 years
Payroll Reconciliations C+7 In accordance with GL
Payroll Journals C+7 In accordance with GL
W2 Copies C+4 IRS Requirement ‐ 4 years
Processing Reports by Paydate
ENTERPRISE/ GENERAL LEDGER ACCOUNTING
22 Backup for invoices created (Airport,
Avenidas, & Palo Alto Community
Childcare)
C+7
23 Loan reconciliations and backup GL
Accounts Reconciliations
C+7
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
9 Packet Pg. 23 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
24 Reconciliations of utility and other
clearing accounts
C+5
25 Receipts/stubs from the daily utility
payments process (batch detail)
C+2+2
months GC 34090
26 Audit Backup & Journal Entries
Backup
C+2 GC 34090
27 Utility / Airport cash receipts C+7
28 Fixed assets backup of journal
entries, capitalization, disposals &
reconciliations
TER + 3
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
10 Packet Pg. 24 of 1138
City of Palo Alto
Records Retention Schedule
City Attorney’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
100 General Info/Subject Files C+9 GC 34090
Restricted access to any files may contain
confidential documents. Keep files until
subject matter is no longer active.
Required to keep until reasonable threat
of legal action has passed.
100‐
01 General Correspondence C+9 GC 34090
600
Purchasing/Contracts, invoices,
and purchase orders originating
in City Attorney’s Office
TERC+10 Duplicate of Purchasing Division; Review
on a file by file basis for destruction
100‐
04 Chron File C+9 GC 34090
100‐
04 Newsletters C+2 GC 34090
SUBJECT FILES
202‐
01 Planning Reports As
Needed Duplicate of Planning and Community
Environment (PCE)
202‐
02 thru
202‐
11 Development Plan/Certificates of
Compliance/Subdivision
As
Needed Duplicate of City Clerk, Planning & Public
Works
202‐
12 thru
202‐
25 General Plan/Comprehensive
Plan/State Mandated Planning
As
Needed Duplicate of PCE. Files to be reviewed for
destruction on a file by file basis.
203‐
01 thru
203‐
10 Regional Planning As
Needed Duplicate of Planning; review on a file by
file basis
204‐
01 thru
204‐
04 Environmental Assessment C+4 Review on file‐by‐file basis for destruction
205‐
01 thru
205‐
13 Stanford University C+9 Review on file by file basis for destruction
206‐
01 thru
206‐
10 Building C+9 Review on file by file basis for
destruction
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
11 Packet Pg. 25 of 1138
City of Palo Alto
Records Retention Schedule
City Attorney’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
207‐
01 thru
207‐
08 Transportation C+9 Duplicate of Transportation
301‐
01 thru
301‐
06 Legal memoranda to City Council C+11 Review on file by file basis for destruction
Settlement Agreements C+10 Settlement agreements with ongoing relevance retained for as long as needed
Municipal prosecutions TER+10 Review on file by file basis for destruction
Attorney‐led investigations C+10 Review on file by file basis for destruction
302‐
01 thru
302‐
11 Boards/Commissions/Committees C+11
303 American with Disabilities Act C+4
304 Records Management, Records
Retention Schedule C+4 Duplicate of City Clerk
305 Management Studies/Surveys C+4
401‐
01 thru
401‐
14 Finance Administration C+4 Duplicate of Administrative Services, Public Works and Utilities
402‐
01 thru
402‐
07 Auditor Administration C+9 Duplicate of Auditor’s Files 403 General Audits C+9
500 Personnel Files C+9
GV 12946
& Title 29
Chpt XIV,
Sections
1602.30;
32; 38.
Some files may need to be retained until
threat of legal action passed. Review on
file by file basis for destruction
600 Purchasing/Contracts C+10 Duplicate of Purchasing Division; Review on a file by file basis for destruction
700 Legislative/Legal C+14 Review on file by file basis for destruction
800 Public
Works/Engineering/Construction C+10 Review on file by file basis for destruction;
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
12 Packet Pg. 26 of 1138
City of Palo Alto
Records Retention Schedule
City Attorney’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
900 Litigation/cClaims CTER+10
Required to keep until reasonable threat
of legal action has passed. On a file by
file basis assign archive time
Civil litigation files C+10
Required to keep until reasonable threat
of legal action has passed. On a file by
file basis assign archive time
1000 Real Estate C+15
Duplication of Real Estate Division/CLK.
Review on file by file basis for
destruction
1100 Parks C+4
Duplicate of Community Services.
Review on file by file basis for
destruction
1200 Municipal Utilities C+4 Duplicate; review on file by file basis 1300 Police Administration C+9 GC 34090 Review on file by file basis for destruction
1400 Community Services C+4 GC 34090 Review on file by file basis for destruction
1500 Fire Administration C+9 GC 34090 Review on file by file basis for destruction
1600 Information Resources C+6 GC 34090 Review on file by file basis for destruction
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
13 Packet Pg. 27 of 1138
City of Palo Alto
Records Retention Schedule
City Auditor
Series Description Total
Retention
Statutory
Reference
Remarks
ADMINISTRATIVE RECORDS
1 a. Office Budget and A/P C+5 Department Policy
2 b. Meeting Notes, Memo’s,
Correspondence, Management
Reports, Office Administrative
files and Working files
C+5 Department Policy
3 Contracts (All Open Council
Approved Contracts, Service
Contracts, Purchase Orders,
Blanket Purchase Orders,
Solicitations, and Documents
C+4 Duplicating of ASD Purchasing and
City Clerk
SUBJECT FILES
4 Publications (Audit Reports),
Status Reports, Revenue
Reports, Council Reports
PER
Department Policy.Post‐2025,
publications included City Council
/Committee agenda packets are
kept by CLK
5 Work Papers (supporting
documentation for published
reports)
C+7
Department Policy While City
Auditor is outsourced, duplicates
kept by relevant department as
needed.
6 Revenue Audit Work Papers
(Sales, TOT, UUT, Prop. Tax
etc.)
C+7
Department Policy (Confidential)
While City Auditor is outsourced,
duplicates kept by relevant
department as needed.
7 Fraud, Waste, and Abuse
Hotline documentation CLTER+5
Department Policy While City
Auditor is outsourced, duplicates
may be kept by another associated
department as needed.
GC 34090
GC 34090
GC 34090
GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
14 Packet Pg. 28 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
100
a) Budget
b) Purchase Orders
c) Domestic Partnership
Affidavits & Statements
C+2
C+2
PER
GC 34090.7 Duplicate of ASD
101
FINANCIAL DOCUMENTS
EXTERNAL VENDORS –
a) Contracts awarded by City
Clerk Department, except
construction
b) Contracts awarded by City
Council, except construction
c) City Clerk Purchase Orders
d) Construction contracts
awarded by City Council
C+2
TER+4
TER+4
C+2
PERM
PAMC 2.08.110;
CCP 337
PAMC 2.08.110;
CCP 337
City Clerk Purchase Orders
duplicate of ASD
102 General Correspondence C+2 GC 34090
103 LEGAL ADVERTISING C+4
CCP 337;
54960.1(c)(1);
CCP 343, 349 et
seq.;
GC 911.2
Includes public hearing notices,
legal publications
104
PUBLIC RECORDS REQUESTS
– Requests, responses, and
log
TERCL+2 GC 34090 TERCL = Resolution Date
ADMINISTRATIVE HEARING RECORDS
105 Administrative Citations C+5 GC 34090 Noise, Animal 106 Alarm and Parking Ticket
Aappeal Hearings CTER+2 GC 34090 Includes Initial Review document
107 Animal Bite Hearings C+15 GC 34090
108 Other Administrative
Hearings C+5 GC 34090GC
34090
Public Works and Community
Services Department hearings
109 Parking Citation Adjudications
(Request for Initial Review) CTER+2 GC 34090 GC
34090
Department
OpinionDepartment opinion
110 Utility User Tax Hearings C+10 GC 34090
ELECTIONS/POLITICAL REFORM ACT
111 AB1234 ETHICS TRAINING –
Proof of training attendance C+5 GC 53235.2(2)b
112 BALLOTS TER+1 EC 17302,
17304, 17306;
RESTRICTED ACCESS
TER = date of election
Department Opinion 8/14
113
CAMPAIGN DISCLOSURE
STATEMENTS‐
a) Elected Members & Log of
Filers (paper)(paper), their
Controlled Committees, and
committees supporting such
officeholders and candidates
PER
PAMC 2.08.110
GC 81009
(ab)(g)
(b)(g)
GC 81009(g) ‐– After two years
on file, an electronic copy of
the statement may be put on a
space saving device retained
and originals discarded (GC
81009(g))
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
15 Packet Pg. 29 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
b) Non‐elected candidates
members (paper), committee
supporting non‐elected
candidates
c) Others ‐‐ Committees,
Supporting/Opposing
Measures (paper), General
Purpose, Independent
expenditure, major donor
committees
d) Copies received (e.g. Form
410)(paper)
e) Electronically filed
C+5
C+7
C+4
C+10PER
GC 81009(b)
GC 81009(c)
GC 81009(f)
GC 84615(i)
Original electronic form must
be kept for at least 10 years
114 CONFLICT OF INTEREST CODE PER
C +4 PAMC 2.08.110 Code is Adopted by Resolution,
Resolution is Permanent
115
FPPC AGENCY FORMS
a) Gift to Agency Report ‐‐
Form 801
Behested Payment Report ‐‐
Form 803
c) 804 New Positions ‐‐ Form
804
d) Consultants ‐‐ Form 805
e) Public Official
Appointments ‐‐ Form 806
C+7
C+7
CS+4
C+4
C+2
FPPC 18944
GC 82015
FPPC 18734
FPPC 18734
FPPC
18705.5GC
34090
Current on Agency Website
FPPC Retention
Current on Agency City
Website
116
NOMINATION
PAPERSCANDIDATES
a) Elected
b) Non‐elected
PERTER+4
TER+2
EC 17100
Department Opinion 6/2014
Non‐elected TER = Certif. of
elections results date or failure
date Term of office or failure
date
Unless requested per EC
17100(b)
117
PETITIONS, INITIATIVES,
REFERENDUM, RECALL &
CHARTER AMENDMENTS
Petition
TER+1
PERMTER+8
months
EC 17200
EC 17400
(Recall
petitions)
GC 6253.5.
7924.100‐
7924.110 (PRA
reference)
RESTRICTED ACCESS
TER = date of election result
certification
Department Opinion 8/14
Certain records may be kept for
historical/reference purposes
Department Opinion 1/25 ‐
historical/reference value
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
16 Packet Pg. 30 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
PA Charter
Articles VI and
IX
117b Certification of Election
Results C+10 EC 15372
118 SAMPLE BALLOT PER GC 34090
119
STATEMENT OF ECONOMIC
INTEREST – Form 700
(Designated Filers) & Log of
Filers
C+7 GC 81009(e)‐(g)
Originals retained C+7
Copies retained C+4 "Wet"
paper filed forms can be
digitized after 2 years
120
STATEMENT OF ECONOMIC
INTEREST – Form 700 (GC
87200 Filers) & Log of Filers
C+4 GC 81009(d)‐(g)
Originals forwarded to State.
Copies retained C +4
GC 87200 Filers include City
Council Members, the City
Attorney, City Manager,
Planning Commissioners, and
the Administrative Services
Director (CFO)
LEGISLATIVE HISTORY
121
BOARDS & COMMISSIONS
a) Applications &
Appointments
I. Appointed
II. Not Appointed
b) Letters of Appointment
c) Notices of Termination
d) Oaths of Office
e) Recruitment Outreach
f) General Correspondence
g) BCC Handbook
TER+5
CL+2
TER+2
TER+2
TER+6
TER+2
C+2
S
GC 34090a;
GC 40801
TER = Leaving Office date
CL = Close of recruitment
TER = Leaving Office date
TER = Leaving Office date
122 CITY COUNCIL ROSTER PER Department Opinion
Paper C+2
123
COUNCIL & STANDING
COMMITTEES MEETINGS
a) Agenda Packets ‐‐ Docs.
and information submitted to
Council including questions
and answers to Council
agenda items
cb) Agendas
cb) Minutes
cd) DVDs/Recordings
ed) Proof of Agenda Posting
PER
C+2
PER
PER
PER
C+2
GC 34090;
GC 40801
54960.1(c)(1)
GC 34090
Department Opinion
Department Opinion 2025
Agenda Packets not PER before
2024
Department Opinion 10/14
124
COUNCIL MEMBER –
b) Biographies
c) Photos
d) Emergency Standby Council
Oaths of Office and Report
PER
PER
PER
Department Opinion 10/14
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
17 Packet Pg. 31 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
125 OATHS OF OFFICE
a) Elected Council Member
TER+2 6
PER
GC 34090;
29 USC 1113
Department Opinion
TER = Leaving Office date
Department Opinion 8/14
126 ORDINANCES PER GC 34090;
PAMC 2.08.110
127 PROCLAMATIONS C+2 GC 34090
128 RESOLUTIONS PER GC 34090;
PAMC 2.08.110
128a MUNICIPAL CODE PER GC 34090 Added in 2025
129
RECORDS & INFORMATION
MANAGEMENT‐
a) Retention Schedules &
Manuals
b) Destruction Certificates
c) Transfer Lists
d) Inventory Database
SC+4
PER
C+2 PER
SC+2
CCP 343
GC 34090
GC 34090
Department Opinion 8/14
Department Opinion
Record of on/off‐site records
130
STATE OF THE CITY ADDRESS
‐ DVD/recording and Speech
Hard Copy
PER GC 34090 Department Opinion 8/14
REAL PROPERTY
131 ANNEXATIONS/ACQUISITIONS PER GC 34090a
132 ASSESSMENTS PERTER+2 Department Opinion
133
BINDING INSTRUMENTS
a) Land ‐‐ Deeds, Easements,
Record of Land Use Action
b) Easements, Vacations,
Leases & Purchases
c) Encroachments,
Agreements & Conveyances
d) Community Development
Block Grants (CDBG)
i. Deeds of Trust
ii. Promissory Notes
iii. Agreements
e) Certificates of Compliance.
f) Real Property Agreements,
i.e. Regulatory Agreements,
Declaration of Restrictive
Covenants, Occupancy, Land
Use, and Development
Restriction Agreements
a) PER
b) PER
c)PER
d)TER+6
TER
e) PER
f) PER
GC 340 90a
Department Opinion
Duplicate of County Recorder
TER = paid in full
TER = paid in full
134 BONDS While Useful
TER+10
GC 34090
CCP 337.5 Duplicate of County Recorder
135 DEEDS OF TRUST TER+6 CCP 336a
136 LIENS, CONDEMNATION PER GC 34090a
137 SUBDIVIDER AGREEMENTS PER GC 65864 &
65869.5
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
18 Packet Pg. 32 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
SUBJECT FILES
138 CABLE TELEVISION –
Franchise & Licenses PER GC 34090 City Attorney Opinion 9/87 139 CEQA POSTINGS C+2 PRC 21152 (c)
GC 34090
140 CIVIL GRAND JURY REPORTS PER CPC 933
141 CLAIMS AGAINST THE CITY C+52 PAMC 2.28.230
& 2.28.240
Duplicate of City Attorney
142 FLOOD BASIN PER GC 34090 City Attorney Opinion 9/87 143
NORTHERN CALIFORNIA
POWER AGENCY –
Agreements including
Transmission Agency of
Northern California
PER PAMC 2.08.110 City Attorney Opinion 9/87
144 PAC BELL/PG&E PER GC 34090 Department Opinion 1992 145 POLICE AUDITOR REPORTS PER GC 34090 Department Opinion 4/2015 146
POLICIES
(a) Administrative Policies
(ab) Council Policies
C+2
SUP+2
GC 34090
147
STANFORD (Including Sand
Hill Road, Willow Rd.
Extension)
PER PAMC 2.08.110 City Attorney Opinion 9/87
148
SUBJECT FILES – All subject
files included, unless
specifically set forth
elsewhere.
C+2
GC 34090
Confidential Legal Opinions are
not public information and are
restricted from public access.
149 WATER RIGHTS – Agreements
and Clean Up PER GC 34090 City Attorney Opinion 1995 150 YACHT HARBOR PER PAMC 2.08.110 City Attorney Opinion 9/87 SISTER CITIES C+2 GC 34090 Department Opinion 8/14
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
19 Packet Pg. 33 of 1138
City of Palo Alto
Records Retention Schedule
City Manager’s Office
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
001
Personnel Information,
Budget Information, Records
Retention Schedule
While
useful Duplicate records of
other departments
002
Staff Reports CMRs (City
Manager Reports) – including
supporting documents
PER GC34090.5
May be scanned to CD
after 5 years and paper
copy offered to the
Historical Society
003
Economic Development Files
for Projects throughout City of
PA
PER May be stored off‐site
Sister Cities C+2 GC 34090
LEGISLATIVE HISTORY
004 Legislative Letters C+5
Consistent with State
Legislation – Reviews
and Changes
SUBJECT FILES
005
Files established pertaining to
various subjects, Project files,
Chronological Files
C+2 GC 34090
POLICIES AND PROCEDURES
006 Official copies of all City
Policies and procedures PERS
Each department should
have a current copy of
the Policies &
Procedures
TRANSPORTATION
TRANSPORTATION‐
BICYCLES
016
a) Bike Boulevard PER GC 34090 Unique project,
historical significance,
model for other
jurisdictions in and out
of U.S.
b) Bike Counts C+5 GC 34090
c) Bike Facilities, Lockers/
and Racks
C+2 GC 34090
d) Bike Locker Rental
Program
C+2 GC 34090
e) Bike Operations
(signing/striping, signal
detection), paths, Routes
and Trails
C+2 GC 34090
f) Pedestrian and Bicycle
Advisory Committee
C+5 GC 34090 Department Opinion
017 FUNDING‐Fuel Efficient
Traffic Signal Management PER GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
20 Packet Pg. 34 of 1138
City of Palo Alto
Records Retention Schedule
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Program (FETSIM)
Applications, Prop 116
Applications, Surface
Transportation Program
(STDP)/Congestion
Mitigation and Air Quality
(CMAQ)Applications and
Transportation
Development Act (TDA)
Article 3 Applications
24 CFR
200.334
24 CFR
570.502
29 CFR
97.42 018 NEIGHBORHOOD STUDIES C+2 Department Opinion
PARKING
019 a) Assessment Districts PER Multiple Depts Opinion b) Carpool/Vanpool
Program C+2 GC 34090
c) Facilities(garages/lots) PER GC 34090 Department Opinion d) Permit
Policy/Management CS+2 Department Opinion
e) Residential Permit
Parking C+2
f) Structures PER Department Opinion
g) Surveys C+2
h) Zones C+2 Department Opinion
i) Congestion Pricing C+5 Department Opinion
020
PERMITS/TRAFFIC
CONTROL‐Certificates of
Insurance and Traffic
Control Plans
C+2 GC 34090
TRAFFIC REFERENCE
021
a) Bike‐correspondence,
other jurisdiction bike plans,
safety/education
C+2 GC 34090
Department
Opinion/Online
Reference
b) Demographic Data PER Department Opinion
c) Traffic Flow Maps C+5 GC 34090
022 REGIONAL AGENCIES C+2 GC 34090
023 SCHOOL SAFETY C+2 GC 34090
024 TRAFFIC STUDIES C+5 GC 34090
Department Opinion
a) Traffic Calming C+2
b) Traffic Signals C+2
c) Other Traffic Studies C+2
025
Traffic Operations Accidents
(high accident
location/accident data and
reports)
C+2 GC 34090
026 Plans PER H&S 19850
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
21 Packet Pg. 35 of 1138
City of Palo Alto
Records Retention Schedule
Community Services Department
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE SERVICES
1 Personnel – Current Employees Performance
Reviews & Work Schedules C+2
2 Security Documents, Work Orders,
Correspondence Inventories, Logs & Reports C+2 GC 34090 3 Policy – Policies, Procedures & Forms SC CA Opinion 4 Other Departments –
a) Stores Req,
b)Purchase Orders,
c) Contracts & Records Retention Schedule
C +2
TER+3
TER+3
TER+4
5 Volunteer Records C+2 GC 34090
6 Accounting – Sales Receipts, Deposits, Sales
Logs, Ledgers, Fees/Fines, Contracts Under
$25,000, Bills & Transit Books
C+2 Community
Services Opinion
ARTS & SCIENCES DIVISION
7 Art Loan Program C+2 GC 34090
8 Theatre Records – Costume & Prop Loans and
Booth Level Settings C+2 GC 34090
9 Art Collection C +2 Community
Services Opinion
10 Public Art Commission –
a) Action Agenda
ab) Proof of PublicationPosting
bc) Minutes of all meetings
cd) General Correspondence
de) Proof of Agenda Posting
PERC+2
C+2
PER
C+2
C+2
Community
Services Opinion
Agendas
Duplicates of
City Clerk
11 Exhibits – Junior Museum & Baylands
Interpretive Center PER Community
Services Opinion
12 Animal Permits – Junior Museum & Zoo TER+2
Fish & Game
Sections 3200,
3204
HUMAN SERVICES & CUBBERLEY DIVISION
Human Relations Commission –
a) Action Agendas and Packets
b) Proof of Publication
c) Minutes of all meetings
d) General Correspondence
e) Proof of Agenda Posting
PERC+2
C+2
PER
C+2
C+2
GC 34090
Agendas
Duplicates of
City Clerk
RECREATION AND GOLF DIVISION
20 Use Permits – Fields, Parks, Courts, Certificates
of Insurance, Facilities Applications & Logs and
Group Agreements
C+2 GC 34090
21 Waivers, Cancellation/Transfer Forms C+2 GC 34090 22 Recreation Foundation – Minutes,
Correspondence & Financial Information C+21
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
22 Packet Pg. 36 of 1138
City of Palo Alto
Records Retention Schedule
Community Services Department
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Parks & Recreation Commission ‐
a) Action Agenda
ab) Proof of PublicationPosting
bc) Minutes of all meetings
cd) General Correspondence
de) Proof of Agenda Posting
PER C+2
C+2
PER
C+2
C+2
GC 34090
Agendas
Duplicate of
City Clerk
Fee Reduction Program C+2 Department
Opinion 2024
ANIMAL SERVICES
23 Veterinary Medical Records – all records
relating to animal inventory and care TER+3
BP 4081
FAC 32003€
PC 597.1(d)
Previously in
Police Dept.
retention
schedule.
Retained by
contractor
Pets in Need
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
23 Packet Pg. 37 of 1138
City of Palo Alto
Records Retention Schedule
Development Center
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Series Description Total Retention Statutory
Reference
Remarks
Note: Development Center Retention Schedule merged into Planning & Development Center Retention Schedule.
ADMINISTRATIVE RECORDS
1 OTHER DEPARTMENTS
Personnel Records, Safety Files, Purchase
Orders, Payment Claim Vouchers, City
Manager’s Reports, Legislation, Litigation,
Final Budget, Equipment and Facility
Maintenance, Time Sheets, Correspondence
with Other Departments and Retention
Schedules
While Useful GC 34090
Duplicate of
other
Departments
2 DEPARTMENT ADMINISTRATION
C+2 GC 34090
Daily Deposit Copies, Department
Procedures, Equipment, Inventories, Budget
Preparation, and Final Budget
Correspondence
3 CONTRACTS
a) Contracts under $85,000 plus all records
associated
b) Full Cost Recover Contracts
c) Contracts over $85,000 plus all records
associated
C+2TER + 4
Until
CompletionTER +4
C+2TER +4
PAMC 2.30.075
CCP 337.2
CCP 343
GC 34090
Duplicate of
Administrative
Services
City Council
approved
contracts
Dduplicate of
City Clerk
004 PERMIT RECORDS
Address changes, Permit applications,
Building Use & Occupancy applications and
certificates, Department correspondence.
PER GC 34090 Electronically
Stored in
Geographic
Information
System (GIS)
or Accela
005 INSPECTION RECORDS
Survey letters, Special inspection
– final inspection reports, SB407 certificate
of compliance forms, Stop work
correspondence.
PER GC 34090
006 Plans PER H&S 19850
7 CODE ENFORCEMENT
Complaints, inspections, photographs,
violations, reports, correction notices,
citations
CTER+2 GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
24 Packet Pg. 38 of 1138
City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
1 DEPARTMENT
MANAGEMENT C+2 GC 34090
General Order, Special
Orders, Bulletins While Useful Department Opinion
Policies and
Procedures SUP+6 GC 34090
45 CFR Part 164.530
Memorandum of
Agreements
While
UsefulTER+4
Duplicate of People Strategy
and Operations (PSO)Human
Resources (HR)
General
Correspondence C+2 GC 34090
001(a) Code Books,
Ordinances PER GC 34090(e)
California Fire Code, Ordinances
duplicate of City Clerk PAMC
amendments, etc.
2 DEPARTMENT PLANS PER
Strategic Plans/Master
Planning Documents While UsefulS+2
3 GENERAL
CORRESPONDENCE &
REPORTS
C+ 2 GC 34090
Correspondence,
memos, emails, press
releases
While UsefulC+2 GC 34090
Committee reports,
minutes, public file
review requests
While Useful Duplicate of City Clerk
Special studies,
community relations While Useful
4 BIDS‐UNACCEPTED While Useful Duplicate of Purchasing 5 OTHER DEPARTMENTS While Useful Duplicate of Other Departments
Staffing roster,
timecards, leave
reports
While Useful Duplicate of Administrative
Services (ASD)
Contracts and
accounting reports,
purchase orders,
deposits, receipts
While
UsefulTER+4
CCP 337
CCP 337.15
Duplicate of ASD; Council
approved contracts duplicate of
City Clerk and City Clerk
Records retention
schedule SUP Duplicate of City Clerk
6 EMPLOYEE FILES
006(a) Training records,
certificates C+ 2 GC 34090 Duplicate of HRPSO
006(b) Employee records While Useful Duplicate of PSOHR 006(c) DMV Driver Tests and
records C+ 2 GC 34090 Duplicate of PSOHR
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
25 Packet Pg. 39 of 1138
City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
7 EMPLOYEE
INJURY/EXPOSURE While Useful Duplicate of PSOHR
Employee accident and
exposure reports PER 29CFR1910.1020 Department Opinion Individual and
summary statistics PER
SUBJECT FILES
FIRE PREVENTION
8 FIRE PREVENTION:
Code Enforcement
actions
TERCL+5 CFC 104.6
Site Plans While Useful
Requests for service,
complaints. C+2
Sprinkler system & Fire
Alarm periodic testing
reports & inspections
C+6
Electronic 5 Year tests: Keep C+6
Stored by 3rd Party Vendor
008(a) FIRE INVESTIGATION
REPORTS & PHOTOS TERCL+ 6 CFC 104.6.2 104.3.2;
PC 801
TER= T+for as long as the
structure or activity to which
such records relate remains in
existence
008(b)
FIRE/HOMICIDE
INVESTIGATION
REPORTS & PHOTOS
PER PC 799 C+6 onsite; PER offsite
008(c) ARSON /JUVENILE
FIRESETTER SUSPECTS CLC+ 6 CFC 104.6104.3.2;
PC 801
Include interviews,
documentation and classroom
materials for junior firesetters
9 ANNUAL FIRE (CFC)
PERMITS C+ 2 GC 34090
10 STREET & NUMBER
ASSIGNMENT While Useful CFC 103.3.4
PAMC 16.36.030
Duplicate of Planning and
Community
EnvironmentDevelopment
Services
11 FIRE INSPECTIONS
(Bureau and Engine
Company inspections)
CLTER+ 6 CFC 104.6.2103.3.4
Department Opinion
CFC 103.3.4 requires CL+3
However, longer period desired
due to 3 year inspection cycle
for some facilities
Records of Inspection;
routine, special, new
construction & tenant
improvement‐related.
PER CFC 104.6.2 Electronically stored in Accela
Pre‐Citation Letters,
Notice of Violation
letters.
While UsefulC+2
GC 34090
12 CERTIFICATIONS GC 34090
Flame Resistance PER Electronically stored in Accela
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
26 Packet Pg. 40 of 1138
City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Use and Occupancy
Certificate PER Electronically stored in Accela
13 SPRINKLERS & FIRE
SUPPRESSION
SYSTEMS
Life of Building
(LoB)
GC 34090(a)CFC
104.6
Pertains to real property. May
include blueprints, reports,
inspection results, permits.
Keep 2 years onsite, permanent
offsite
Design, Flow,
Installation documents LoB
Plan review comments LoB
14 BUILDING PROJECTS LoB GC 34090(a)
Pertains to real property. May
include blueprints, reports,
inspection results, permits.
Keep 2 years onsite, permanent
offsite
New Construction &
Tenant Improvement
Projects, including
underground tank
installations and
repairs
PER
Electronic Electronically stored in Accela
Alternate means and
methods applications PER CFC 104.6.4 2007 CFC 104.6.4 Electronically stored in Accela
Plan review comments PER Electronically stored in Accela
SUPPRESSION
15 INCIDENTS (fire,
medical, hazmat, etc.) PER Electronically stored in RMS 015(a) Dispatch and daily logs C+ 2 GC 34090 Release to Union; do not destroy
015(b) Fire Incident Reports;
all except arson related PER CFC 104.6104.3.2,
PC 801 Electronically stored in RMS
015(c)
Fire Incident and other
Field Reports; arson
related
PER CFC 104.6104.3.2,
PC 801 Electronically stored in RMS
015(d)
Fire Incident and other
Field Reports; arson
with death involved
PER PC 799 Electronically stored in RMS
015(e) Pre‐Hospital Care
Report (PCR) PER 45 CFR Part 164.530 Electronically stored in RMS 16 ENGINE/TRUCK
EQUIPMENT GC 34090
016(a) Daily & Monthly logs C+ 2 GC 34090
016(c) Maintenance Program. C+ 2 GC 34090
HAZARDOUS MATERIALS
17 ANNUAL HAZARDOUS
MATERIALS STORAGE
PERMIT
CTER+ 2 GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
27 Packet Pg. 41 of 1138
City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
18 CALCULATIONS‐
Seismic and secondary
containment
C+ 2 GC 34090
19 SITE CLEANUP Spill
Reports & facility
closure related
information; related
inspections. Does not
include reports for
activities regulated by
Calif. Regional Water
Resources Control
Board or Calif Dept of
Toxic Substances.
PER GC 34090(a)
Pertains to real property.
Previous retention was 30
years‐OHSA Guideline cited no
specific document reference.
Electronically stored in
California Environmental
Reporting Service (CERS)
20 HAZARDOUS
MATERIALS &
UNDERGROUND TANK
INSPECTIONS, routine,
special, and
enforcement related
CL + 6 CCR 27, 15188
Department Opinion
C+5 Required. Keep additional
time for consistency with other
inspection records.
Electronically stored in CERS
21 HAZARDOUS
MATERIALS BUSINESS
PLANS
C+ 2 GC 34090 Electronically stored in CERS
UNDERGROUND TANKS
22(a)
UST closures and/or
removals and related
documentation. Does
not include reports for
activities regulated by
Calif. Regional Water
Resources Control
Board or Calif. Dept of
Toxic Substances.
PER GC 34090(a)
Pertains to real property. May
include blueprints, reports,
inspection results, permits
Electroniccally stored in CERS
022(b)
Periodic testing,
monitoring and special
reports
C+ 2 GC 34090 Electronically stored in CERS
PROGRAMS
23 SPECIAL PROGRAMS:
Strike teams and
mutual aid response
C+12 GC 34090
Existing Department Opinion is
C+12. Note that GC 34090
requires only C+2
23 (a)
Disaster Service
Worker:
All associated
documents
TER + 30 CCR 19, 2573.2,
GC 3105, 6250 Required for injury Claims
24 PARAMEDICS: Training
and testing C+ 4 CCR 22, Div 9, sec
100101100392
Retained by Human Resources?
(TER+3, 29 CFR 1627.3)
PCR – see Suppression
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
28 Packet Pg. 42 of 1138
City of Palo Alto
Records Retention Schedule
Human Resources
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
1 GENERAL – Correspondence,
Timecards, Contracts, Subject
Files, Budgets, Projects , and
Records Retention Schedule*
C+2 GC 34090 Duplicate of City Clerk and
Administrative Services
2 STANDARDS – Policies, Rules,
Bills, & Regulations C+2 GC 34090
EMPLOYMENT
4 RECRUITMENT – Applications,
Resumes, Alternate Lists,
Testing
C+3
492 USC Sections
2000e‐8; 2000c‐12;
29 CFR Section
1602.12 and 1602.14
Restricted Access
5 PERSONNEL FILES (a) Regular
Employees TER+15
29 CFR Section
1627.3
Labor RelationsCode
Section 1174
Access may digitally store after
2 years and shred
Restricted Access
PERSONNEL FILES (b) Water
Quality Control Plant ‐‐ Senior
Chemist, Chemist, Laboratory
Tech, Senior Industrial Waste
Investigator, Industrial Waste
Investigator, Senior Mechanic,
Mechanic, Senior Operator,
WQC Plant Operators I/II,
Industrial Waste Inspectors,
Electricians, Supervisor, WQCP
Operations, Manager/Assistant
Manager, WQCP, and Manager,
TER+30
29 CFR
1910.1020;
Cal OSHA 8 Cal
Code Regs 3204
Access may digitally store after
2 years and shred
Restricted Access
*There may be other
employees in safety‐sensitive
position in other locations with
same extended retention
schedule
5 PERSONNEL FILES (c) Hourly
Employees TER+5
29 CFR Section
1627.3 Labor
Relations
Labor Code Section
Section 1174
Access may digitally store after
2 years and shred
Restricted access
6 RETIREMENT – Public Employee
Retirement System TER+4
29 USC Sections
1001 – 1381
29 CFR Section
1627.3
Restricted Access
7 CLASSIFICATION: Requests for
reclassification, PDQ's, Job
Descriptions, Desk Audits
C+32 Labor Code Section
1197.5(de)
PDQ = Position Description
Questionnaire
BENEFITS
8 EMPLOYEE BENEFIT FILES ‐
DCCAP (dependent care),
Deferred Comp, Dental, EAP,
Life, Medical, Vision/LTD Claim
Applications, Leave, Domestic
Partner Reimbursement
C+4 29 CFR Section
1627.3
Restricted Access
DCAP = Dependent Care
Assistance Program
EAP = Employee Assistance
Program
LTD = Long Term Disability
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
29 Packet Pg. 43 of 1138
City of Palo Alto
Records Retention Schedule
Human Resources
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
9 FPPC AGENCY FORMS
a) 804 New Positions ‐‐ Form
804
b) Consultants ‐‐ Form 805
C+4
C+4
FPPC 18734
FPPC 18734 Duplicate of City Clerk
RISK MANAGEMENT/WORKERS' COMP
10 WORKERS COMPENSATION
Claim Files
TER+5 (if
claim is
active)PER
Labor Code Section
5410
8 CCR 3204(d)(1)
8 CCR 10102
GC 12946
Files are held at Administrator’s
Office, City only keeps working
file
Restricted Access
11 Authority for California Cities
Excess Liability (ACCEL) JPA
Agenda Files
C+3 Department Opinion
12 DMV Employer Pull Notice
Program ReportsDMV – Pull
Notices
C+4 (only
if
employee
has
violation
on record)
Department Opinion
Restricted Access
13 DRUG TESTING C+5
49 CFR Section 193‐9
DOT 49 CFR Part 40
Subpart P Sect
40.333; 49 CFR
40.333 and Sect
40.25 Restricted Access
14 SAFETY REPORTS
a) Investigation Reports
b) Hearing Tests
PER
TER+5
C+4
8 CCR 3203(b)(1)‐(2),
8 CCR 3203(c)(2),
FC 406.2
Department Opinion
INSURANCE
(a) Insurance bond policies
(b) Insurance certificates
TER+10
PER
CCP 337.2; 343
GC 34090
INFECTIOUS DISEASE &
OCCUPATION EXPOSURE FILES PER
29CFR 1910.1030(h);
29 CFR 1910.1020;
8CCR3204(d)(1)(B)
OCCUPATIONAL MEDICAL TEST TER+5
FMLA 1993 US OSHA;
29 CFR
1910.1020; 29 CFR
1602.30‐
1602.32; OSHA;
8CCR5100(d)(2)OSHA
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
30 Packet Pg. 44 of 1138
City of Palo Alto
Records Retention Schedule
Human Resources
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
LEAVE ‐ DI
SABILITY TER+5
FMLA 1993 US OSHA;
29 CFR
1910.1020; 29 CFR
1602.30‐
1602.32; OSHA
8CCR5100(d)(2)OSHA
Acciden t, Incident, and Injury
Reports PER
8 CCR 10102
GC 12946
HUMAN RESOURCES DEVELOPMENT
16 TRAINING – Program Lists,
Instructor Lists, Class Rosters, &
Evaluations
C+2 49 CFR 199.17
49 CFR 199.227 Department Opinion
EMPLOYEE RELATIONS
17 NEGOTIATIONS – Notes,
Notebooks, Correspondence,
Contracts, & MOA
C+10 29 USC Sections 211
(c), 203 (m), 207 (g) Restricted Access
18 COMPENSATION – Mgmt.
Salary History Sheets, Job
Descriptions, Salary Surveys,
Compensation Plans
C+7 Department Opinion
19 GRIEVANCES – Arbitration,
Grievances Reports, SEIU
Window Period Requests,
Sexual Harassment &
Discrimination
C+7 29 CFR Section
1602.21 (h) Restricted Access
PERSONNEL MANAGEMENT
21 EMPLOYEE RIGHTS: Safety and
General Employees TER+5 GC 12946, 29 CFR
1602.12
23 CLASSIFICATION AND
COMPENSATION SURVEYS C+2
GC 12946, 34090; 29
CFR 516.6(2); 29 CFR
1602.14
25 LEAVE ‐ MEDICAL TER+5
FMLA 1993 US OSHA;
29 CFR 1910.1020;
29 CFR 1602.30
27 SALARY INFORMATION ‐ Salary
schedule, Salary resolutions PER GC 34090; GC 12946;
29 CFR 516.6(2)
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
31 Packet Pg. 45 of 1138
City of Palo Alto
Records Retention Schedule
Information Technology
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
001
a) Budget
b) Purchase Orders
C+2
C+2
GC
34090.7
Duplicate of Administrative
Services (ASD)
Duplicate of ASD
001 Subject files, general
correspondence, C+2 GC 34090
SUBJECT FILES
002 Phone Log Files C+2 GC 34090 Call records
003 Service Desk Tickets C+2 GC 34090 IT Service Desk Tickets 004 Financial System Data
Backup C+7 GC
34090 SAP Database Backups
005
Contracts
a) Under $5000
b) $5000 and over
c) $85000 and over
TER+43
TER+43
TER+43
CCP 37.2
CCP 343
GC 34090
Duplicate of ASD
City Council approved contracts
Dduplicate of City Clerk
006 Hardware and software
inventories S+2 GC 34090
Running inventories of hardware
and software used to track
locations, to whom assigned,
and licensing information, as
needed
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
32 Packet Pg. 46 of 1138
City of Palo Alto
Records Retention Schedule
Library
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
Department Administration
Work Schedules, Volunteer
Records, Budget Preparation,
Surveys, Statistics, Projects, Staff
Reports, Org Chart,
Memberships, Legal Opinion,
Staff Development and Training,
Community Relations, Benchmark
Data
C+2 GC 34090
Standards
Department Policies and
Procedures, Strategic Plan,
Safety/Security Manual, Disaster
Plan
Until
SupersededS GC 34090
General Correspondence &
Reports
Correspondence, Memos, Emails,
Press Releases, Committee
Reports, Meeting Notes, Working
Files
C+2 GC 34090
Email messages related to
a current project or a
policy‐making decision
should be retained along
with related records
Other Departments
Staffing Roster, Timecards, Leave
Requests, Contracts,
Amendments, Purchase Orders,
Change Orders, Invoices, Travel,
Final Budget, Fines and Fees
Scheule, Library Bond Measures,
Building Plans, Deposits, Cash
Receipts, Information Technology
Management Records, Records
Retention Schedule
While useful GC 34090 Duplicate of other
departments
Employee Files (Regular & Hourly)
PAFs, Appraisals, Work Injury, Job
Descriptions, Requests for
Reclassificiation, Recruitment ‐‐
applications, resumes,
While useful Duplicate of HRPeople
Strategy and Operations
LEGISLATIVE HISTORY
Library Advisory Commission
a) Agenda
b) Proof of Publication
c) Minutes of Meetings
d) General Correspondence
e) Proof of Agenda Posting
C+2PER
C+2
PER
C+2
C+2
GC 34090
If posted by Library
StaffLibrary Advisory
Commission dissolved in
2020.
SUBJECT FILES
Library Databases
Customers, Circulation and
CS+2
GC 34090
Patron use Registration
and circulation records are
exempt from Public
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
33 Packet Pg. 47 of 1138
City of Palo Alto
Records Retention Schedule
Library
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Inventory
Subscriptions and Licenses
Records Act under certain
conditions; GC 7927.105,
GC7927.100GC6254, GC
6254.5, GC6255, GC6267
Grants & Donations
Applications
Awards
Non‐monetary Donations
Reimbursements
C+5
GC 34090
24 CFR 200.334
24 CFR 570.502
29 CFR 97.42
Department Opinion
Capital Improvements
Project Files, Specifications,
Contracts, Agreements,
Equipment, Maintenance,
Licenses, Inventory
Life of
building GC 34090
Duplicate of Public Works
City Council approved
contracts duplicate of City
Clerk
Publicity/Publications
Promotional Materials C+2 GC 34090
State Library
Public Library Survey
Reimbursements
C+2 GC 34090
Operational Reports
Daily Log, Cash Handling, Bank
Deposits, Debt Collection
Management
Incident Reports
C+2
C+5
GC 34090
Public Programming
Development and Administration
of Programs for the Public
(children, students, adults)
C+2 GC 34090
Collection Development Records
Records documenting the
selection and acquisition of new
materials for the Library's
collections and the physical
movement of materials between
the facilities and storage areas
C+2 GC 34090
Collection Movement Records
Records documenting the physical
movement of materials between
the facilities and storage areas
C+2
Historical Reference
History of Palo Alto City Library PER GC 34090 Department Opinion
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
34 Packet Pg. 48 of 1138
City of Palo Alto
Records Retention Schedule
Office of Emergency Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
1 DEPARTMENT MANAGEMENT
General Order, Special Orders,
Bulletins, Policies and Procedures S GC 34090
Employment Memorandum of
Agreements
While
Useful GC 34090 Duplicate of Human Resources Peope
Strategy and Operations (PSO)
2 DEPARTMENT PLANS PER Department Opinion
Strategic Plans/ Master Planning
Documents C+2 GC 34090
3 GENERAL CORRESPONDENCE &
REPORTS C+2 GC 34090
Correspondence, memos, emails,
press releases
Committee reports, minutes,
public file review requests
Special studies, community
relations
003c
Budgets, Purchase Order's Time
Keeping, Correspondence,
Surveys, Statistical Reports
C+5 GC 34090
004h Equipment Records TER+2 GC 34090
Retained until termination of
equipment's use; Manuals,
instructions, procedures, assignments,
maintenance
EMPLOYEE FILES
006(a) Training records, certificates C+2 GC 34090
Duplicate of HR Retained by HR
(TER+3, 29
CFR 1627.3)
006(b) Employee records While
Useful Retained by HR (TER+3, 29
CFR 1627.3)
SPECIAL PROGRAMS
023(a)
Disaster Service Worker:
Emergency Services Volunteers
All associated documents
TER+30
CCR 19,
2573.2,
GC 3105,
6250
Required for injury claims
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
35 Packet Pg. 49 of 1138
City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMIN
ISTRATION
001
OTHER DEPARTMENTS
Personnel Records, Purchase
Orders, Payment Claim
Vouchers, Legislation, Final
Budget, Correspondence with
Other Departments and
Records Requests
While
Useful GC 34090
Duplicate of Other Departments
002
DEPARTMENT
ADMINISTRATION
Department Procedures,
Equipment, Inventories,
Budget Preparation, and Final
Budget Correspondence,
General Correspondence
C+2 GC 34090
003
CONTRACTS
a) Contracts under 85,000 plus
all records associated
b) Full Cost Recovery Contracts
TER+4C+2
TER+4Until
Completion
CCP 337
CCP 343
GC 34090
Department Opinion
004
ADMINISTRATIVE REFERENCE
Fee Schedules, Orgs, List,
Ordinance Binder, Planning
Ethics, Data Collection
While
Useful plus
online
archivesS
GC 34090 Department Opinion
LEGISLATIVE HISTORY
5 PLANNING COMMISSION,
ARCHITECTURAL REVIEW
BOARD, AND HISTORIC
RESOURCES BOARD AND
DIRECTOR'S HEARINGS
a) Minutes ‐ Online
b) Agendas and Packets‐ Online
c) Correspondence with
Staff/Public ‐ project based
d) Proof of Publication
de) Proof of Agenda Posting
PER
PERC+2
C+2
C+2
C+2
GC 3409
0 Video and Audio Tapes are recycled
after 90 days except for Director's
Hearing ‐‐ 5 years of DVD/CD
Hardcopy form
at, Boards ‐ Summary.
PTC ‐– Verbatim
Agendas duplicates of City Clerk
SUBJECT FILES
6 COUNTY OF SANTA CLARA While
Useful GC 34090 Duplicate of Santa Clara County
7 BUILDING PLANS GC 3409 0
a) A pproved PER H&S 19850 Digital Format
b) Su perseded C+2 H&S 19850 Hardcopies
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
36 Packet Pg. 50 of 1138
City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
8 DISCRETIONARY PLANNING
ENTITLEMENTS
a) Applications
b) Maps ‐ Zoning, Tentative
Subdivision, Preliminary Parcel,
Comp Plan Land Use, et al
c) Permit Extensions
(currently a 2‐yr window with a
1‐yr extension)
d) Record of Land Use Actions
e) CEQA determinations, ‐EIR,
‐Negative Declarations
PER
PER
C+2
PER
PER
GC 34090
Department Opinion
Digital Format (stored offsite)
Digital Format
Saved Within Application files that
are scanned into GIS/DOXview
10 HISTORIC INVENTORY PER GC 34090 Digital Format‐‐Currently updated via GIST
11 ZONING ORDINANCES PER GC 34090 Duplicate of City Clerk 12 COMPREHENSIVE PLAN AND
AMENDMENTS‐‐ Available
Website reference only
PER GC 34090
Duplicate stored offsite as vital copy
backup w/ Amendments
Resolutions Duplicate of City Clerk
13 COMMUNITY DEVELOPMENT
BLOCK GRANTS (CDBG) PAMC 2.30
a) Project Files TER+5 C+2
24 CFR Part
570
2 CFR
200.334
.502
State of California HCD CDBG Grants
Management Manual, Chapter 10
https://www.hcd.ca.gov/grants‐and‐
funding/programs‐
active/community‐development‐
block‐grant
b) Deeds of Trust and
Promissory Notes GC 34090 Duplicate of City Clerk
14 COMMUNITY DEVELOPMENT Human Relations Commission Acts as Committee
BLOCK GRANTS (CDBG)
b) Program Reference Forms,
Procedures and Brochures C+3
15 HOUSING
a) General Information and
References ‐ Outside Materials
While
Useful Department Opinion
b) Housing Studies and
Programs C+3 GC 34090
c) HOME Funding‐General (If
individual home loans keep
permanently)
C+3TER+5
GC 34090
24 CFR Part
570
Federal regulation federally funded
programs and labor standard
compliance files
d) Below Market Rate (BMR)
Units, In Lieu Hosing Mitigation PER GC 34090 Department Opinion e) Below Market Rate
Administration
C+2While
Useful GC 34090
16 TRANSPORTATION‐BICYCLES GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
37 Packet Pg. 51 of 1138
City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
a) Bike Boulevard PER
Unique project, historical
significance, model for other
jurisdictions in and out of U.S.
b) Bike Counts C+5
c) Bike Facilities, Lockers
and Racks C+2
d) Bike Locker Rental
Program C+2
e) Bike Operations
(signing/striping, signal
detection), paths, Routes and
Trails
C+2
f) Bicycle Advisory
Committee C+5 Department Opinion
17 FUNDING‐Fuel Efficient Traffic
Signal Management
Program(FETSIM) Applications,
Prop 116 Applications, Surface
Transportation
Program(STDP)/Congestion
Mitigation and Air Quality
(CMAQ)Applications and
Transportation Development
Act (TDA) Article 3 Applications
PER
18 NEIGHBORHOOD STUDIES C+2 Department Opinion
19 Parking
a) Assessment Districts PER
b) Carpool/Vanpool
Program C+2
c) Facilities(garages/lots) PER Department Opinion d) Permit
Policy/Management C+2 Department Opinion
e) Residential Permit
Parking C+2
f) Structures PER Department Opinion
g) Surveys C+2
h) Zones C+2 Department Opinion
i) Congestion Pricing C+5 GC 34090 Department Opinion 20 PERMITS/TRAFFIC CONTROL‐
Certificates of Insurance and
Traffic Control Plans
C+2 GC 34090
22 TRAFFIC REFERENCE GC 34090
a) Bike‐correspondence,
other jurisdiction bike plans,
safety/education
C+2 Department Opinion/Online
Reference
b) Demographic Data PER
c) Traffic Flow Maps C+5
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
38 Packet Pg. 52 of 1138
City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
23 REGIONAL AGENCIES C+2
24 SCHOOL SAFETY C+2 GC 34090
25 TRAFFIC STUDIES GC 34090
a) Traffic Calming C+5
b) Traffic Signals Department Opinion
c) Other Traffic Studies
26 TRAFFIC OPERATIONS
a) Accidents (high accident
location/accident data and
reports)
C+2
DEVELOPMENT CENTER ADMINISTRATIVE RECORDS
1 OTHER DEPARTMENTS
Personnel Records, Safety
Files, Purchase Orders,
Payment Claim Vouchers, City
Manager’s Reports,
Legislation, Litigation, Final
Budget, Equipment and
Facility Maintenance, Time
Sheets, Correspondence with
Other Departments and
Retention Schedules
While Useful GC 34090 Duplicate of other Departments
2 DEPARTMENT
ADMINISTRATION C+2 GC 34090
Daily Deposit Copies,
Department Procedures,
Equipment, Inventories,
Budget Preparation, and Final
Budget Correspondence
3 CONTRACTS
a) Contracts under $85,000
plus all records associated
b) Full Cost Recover Contracts
c) Contracts over $85,000 plus
all records associated
C+2TER + 4
Until
CompletionTER
+4
C+2TER +4
PAMC
2.30.075
CCP 337
CCP 343
GC 34090
Duplicate of Administrative
Services
City Council approved contracts
Dduplicate of City Clerk
DEVELOPMENT CENTER SUBJECT FILES
004 PERMIT RECORDS
Address changes, Permit
applications, Building Use &
Occupancy applications and
certificates, Department
correspondence.
PER GC 34090 Electronically Stored in Geographic
Information System (GIS) or Accela
005 INSPECTION RECORDS
Survey letters, Special
inspection
– final inspection reports,
SB407 certificate of
PER GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
39 Packet Pg. 53 of 1138
City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
compliance forms, Stop work
correspondence.
006 Plans PER H&S 19850
7 CODE ENFORCEMENT
Complaints, inspections,
photographs, violations,
reports, correction notices,
citations
CTER+2 GC 34090
NOTE: Development Center Retention Schedule merged into Planning & Development Center Retention Schedule and transportation records merged into City Manager’s Office.
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
40 Packet Pg. 54 of 1138
City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
3 (a) Personnel Training SUP GC 34090 Bulletins, training class certificates
3 (a)(1) Lesson Plans C+15 GC 34090 Scope, content, time period of courses
3 (a)(2) Applicant Fingerprint
Files TERM+2 GC 34090
Includes paperwork
authorizing fingerprinting
and background checks for
City employment
applicants, all license and
permit applicants and
volunteer applicants
3 (a)(3)(b) Personnel (copies) TERM+7 GC 34090
Paperwork documenting
officer& non‐
swornProfessional Staff
internal and external
training
3 (b)(1) Applicant Fingerprint
Files TER+3 GC 34090
Includes paperwork
authorizing fingerprinting
and background checks for
City employment
applicants, all license and
permit applicants and
volunteer applicants.
3 (a)(b)(c) Volunteer Files TERM+2 GC 34090 Volunteers’ identification, contact information
003b Policy, Forms, Brochures TERMC+2 GC 34090
003c
Budgets, PO’s Time Keeping,
Correspondence, Surveys,
Statistical Reports, Contracts
CTER+5 GC 34090
CCP 337
003d Demographic Data Collection
Cards C+2 GC34090 Program ended 6‐30‐2010
003e Alarm Records C+2 GC 34090
Alarm packets, documents
& correspondence, alarm
permit
applications/permits, false
alarm notifications, false
alarm records
001q
Administrative/Internal Affairs
Investigations – Documents
relating to complaints or
investigations in responses to
citizens’ complaints regarding
members of the Department.
a) UnNot sustained
b) Sustained
C+5 TER + 5
TER+15
PC 832.5(b),
EVC 1045,
PC 801.5,
PC 803(c),
VC 2547
GC 12946
Provided documents are
not evidence in any claim
filed or criminal
investigation, or part of any
pending records request or
litigation exists.
TER = conclusion of
investigation
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
41 Packet Pg. 55 of 1138
City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
001k PressNews Releases C+2 GC 34090
Website 2 years; moved to
the Investigatory file if
applicable
001k Social Media Content C+2 GC 34090
001t Administrative Citations TERC+25 GC 34090
Noise, Animal,
Parking/Traffic
TER = conclusion of
administrative review
hearing, if held.
001r PAPD Policy Manual SUP GC 34090 Living Document ANIMAL SERVICES RECORDS
001p
Nuisance Complaints, Animal
Bite Reports and Hearings,
PAMC Violations and warnings
issued.
C+10
GC 34090
PAMC
6.28.030
FAC 32003(e),
31621 ‐ 31626
PAMC = Palo Alto Municipal
Code
001s Veterinary Medical Records C+3 BP 4081 Move to CSD/PIN 10 Animal Licenses C+2 GC 34090 Dog – 3 years from expiration
001n HumaneAnimal Control Officer
– Activity records and logs C+2 GC 34090
001m
Animal Control – All records
relating to animal inventory
and care
C+2 GC 34090 Move to CSD/PIN
COMMUNICATION RECORDS
1 (a) 911 Recordings
(b) Other Phone
Recordings, not on
911 lines
T + 180 days‐
T + 180 days‐
C+2 years and 1 day
GC 34090.6
PC 1054 et seq
Exception: Recordings
used‐ flagged as evidence
in a criminal prosecution or
claim filed or litigation hold
request receivedd or
potential claims and
litigation ‐shall be
preserved for 100 days
after conclusion of the
court action, or as needed.
System programed to re‐
write unless flagged
003f Mobile Audio Video Records
(MAV) C+2 GC 34090.6
PC 1054
Exception: ‐ Recordings
used‐ flagged as evidence
in a criminal prosecution or
claim filed o‐r litigation
hold request received or
potential claims and
litigation shall wbe
preserved for 100 days
after conclusion of the
court action or as needed.
DAR ‐ Digital Audio Recordings C+2‐
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
42 Packet Pg. 56 of 1138
City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
System programmed to re‐
write unless flagged
003g Interior Video Recordings
AIB or ISD when initiated C+12 GC 34090.6
PC 1054
Exception‐: Recordings
flagged used‐ as evidence
in a criminal prosecution or
claim filed or‐ litigation
hold received or potential‐
claims and litigation shall‐
be preserved for 100 days
after conclusion of the
court action, or as needed
003h Routine Perimeter Security
Video 100 Days GC 34090.6 Automated self‐
recycled/re‐use technology
INVESTIGATIVE RECORDS
001e
Police Reports – ODI (Optical
Document Imaging) System
and supporting hard copy
Reports
PERC+100
GC 34090 Reports scanned into the
ODI system from 6‐15‐92 to
12‐31‐06. Unless report is a
Permanent Record or
ordered Sealed by Court
Order
PC 800
PC 801
PC 799
001f
Non Criminal Police Reports –
Lost/Found Property, Injured
or sick persons; missing
persons where person has
returned; traffic collision
reports not used as the basis
for criminal charges etc.
C+2010 GC 34090
Any CLETS entry must be
canceled prior to purge if
applicable.
Applies to Police Reports
taken prior to 6‐15‐1992
prior to Optical Imagining.
001e Traffic Collision Fatality Reports PERC +20 GC 34090 Regardless of the medium 001e
(1)Police Reports/PDF Scanned
– All Felonies, high
Misdemeanor cases.
PERC +100
PC 800
PC 801
PC 799
(Felony
Capital Crimes
punishable by
Death, Life
Imprisonment
)
PC 1054
Starting 2007 Hard Copies
will be kept in conjunction
with PDF
Prosecution for an offense
punishable by
imprisonment in state
prison for 8 years or more
must commence within 6
years after offense
commission.
Commencement of
prosecution defined in PC
804. *Excep
tion: PC 803 –
Tolling/Extension of time
periods; Appeals process
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
43 Packet Pg. 57 of 1138
City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
and “Three Strikes”‐ also
considerations in assigning
retention‐.
001f
(1)Non Criminal Police
Reports/PDF Scanned –
Lost/Found Property, Injured
or sick persons; missing
persons where person has
returned; traffic collision
reports not used as the basis
for criminal charges etc.
C+150 GC 34090
Starting 2007 Reports will
be scanned to PDF.
Any CLETS entry must be
canceled prior to purge if
applicable.
12‐1‐2021 – all reports
scanned as PDF
001v
Arrest/Conviction HS Section
11357 (b), (c), (d), (e) or H&S
Section 11360 (b) violations –
Occurring after January 1, 1996
Mandatory
destruction from
date of conviction or
date of arrest with
no conviction
HS 11361.5
Applicable to convictions
occurring after 1‐1‐1996 or
arrests not followed by a
conviction occurring after
1‐1‐1996; Exc
eption: H&S
11357(e), the record shall
be retained until a juvenile
offender attains 18 years of
age – then destroyed
pursuant to 11361.5
001l FI Cards – Field interview Cards C+2 GC 34090 Includes photo if taken 001k (1) Daily Bulletins C+2 GC 34090
001e (2) Registrants – Sex, Arson,
Narcotics
PER
TER or until S
DOJ
Guidelines
Fingerprint Card, Photo and
info forwarded to DOJ
001e
(3) Criminal Reports
(Misdemeanor low Felony) and
Domestic Violence Reports
C+15 FC 6228(de)
GC 34090
Remove property from
CLETS, no suspect or open
investigations pending.
MISC REPORTS AND DOCUMENTS
004a Court Board C+12 GC 34090 Court Notices
004b Court Liaison Tracking Systems C+25 GC 34090
Booking/Filing Lists and
Logs, In/Fformal Discovery
requests and
Correspondence. Formal
Discovery scanned to
Investigatory File
004c Subpoenas (Duplicate) C+2 GC 34090
Subpoena Duces Tecum
(SDT) filed with case Report
once completed if
applicable
004d Statistical – Crime Analysis and
other reports C+2 GC 34090
Internally generated
information using activity
logs, citizen calls requests,
and current and past crime
statistics. Reports created
for a variety of purposes.
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
44 Packet Pg. 58 of 1138
City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Some original reports sent
to DOJ & FBI
004e
Statistical – UCR (Uniform
Crime Report) LEOKA,
Homicide, Arson, DV, Hate,
Arrest & Citation, Death in
Custody, Crimes against Senior
C+25 GC 34090 Originals to DOJ & FBI
004f Sealed – Adult /Factual
Innocent
Mandatory
Destruction upon
and pursuant to
Court Order
PC 851.8
Unless sealed pursuant to
PC 851.91 and PC 851.92.
Does not include letter of
finding sent to the
defendant for
grants/denials
001j Restraining Orders C or until S
Destroy after law
enforcement actions
described in PC 273.5,
273.6, 646.9, 12028.5,
13700 and Family Code
Sections 6380‐6383 are
fulfilled and effective date
of Restraining Order has
expired
001g
Traffic Citations (copies)
*Except Juvenile offender
program graduates – those not
forwarded to court of program
successfully completed.
C+2 GC 34090
Original hard copy is
forwarded to court, citation
records are sent
electronically to the court..
Agency copy kept for
processing. Parking
Citations forwarded to
Revenue Collections
004h
Equipment Records – includes
Drager Logs, PAS Records and
Radar Calibration Logs,
Weapons Records, ALPR Stats;
Flock and Star Chaser Forms
TERM+2 GC 34090
Retained until termination
of equipmentsequipment
use; Manuals, instructions,
procedures, assignments,
maintenance
004i License/Permits C+2 GC 34090
Parade, Noise Exemption,
Special Events, Block Party,
Taxi, Masseuse. No longer
interested forms to be sent
to DOJ for applicant
expired applicant
information.
004j Warrants: Warrants attaining purge
date are sent to Santa Clara
Co DA’s office for review of
extension of warrant/
Active case or purge. All
(1) Felony Felony – C+ 10 GC 34090
(2) Misdemeanor Misdemeanor – C+7 PC 799
(3) Infraction Infraction – C+7 PC 800/801
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
45 Packet Pg. 59 of 1138
City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
CLETS/AWS systems must
be u
pdated or cancelled.
004k NCIC Validations C+2 GC 34090 Copies sent monthly to DOJ ???
004l
Records requests,
miscellaneous correspondence,
no record, RFP’s
C+2 GC 34090
The destruction of fe
lony, misdemeanor, and infraction Crime/Supplemental Reports is permitted providing:
(1) They do not relate to an unadjudicated arrest except for HS 11357 or HS 11360 violations; (2) They do not relate to unserved warrants;
(3) They do not involve identifiable items which have not been recovered; (4) The do not relate to PC 290, PC 457.1, or HS 11590 Registrants; (5) Th
ey do not relate to violations listed in PC Sections 799 and PC 800; (6) The cases are not presently involved in either a civil or criminal litigation.
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
46 Packet Pg. 60 of 1138
City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = S upersede
ADMINISTRATION
1 PERSONNEL
Confidential Documents
While
useful
Duplicate of Human
ResourcesPeople Strategy and
Operations (PSO)
1 Contracts/purchase orders
awarded by PW Department,
except construction/capital
improvement
TER+4 CCP 337
CCP 343
AIRPORT
A
GREEMENTS/CONTRACTS While
useful
TER+4
CCP 337
CCP 343
Duplicate of ASD and CLK
1 BUDGET
Budget Change Requests PER Duplicate of Office of Management & Budget
2 CAPITAL IMPROVEMENTS
a) Project Files, Work Orders,
Schedules, Bidders List,
Correspondence, Change Order
b) Specifications, Reports Plans,
Contracts and Subdivisions
PER
H&S
19850
GC 4003
Life of Structure
2 GENERAL
Correspondence
Membership Information
Notice to Airmen (NOTAM)
C+2 GC 34090
GRANT S
Applications
Awards
PER 2 CFR
200.334 Department Opinion
OPE RATIONAL REPORTS
Daily, Weekly, Monthly,
Quarterly, and Annually
C+4 GC 34090 Federal Aviation Administration
(FAA)
PERMITS PER
STAF
F
Evaluations
Personnel Action Forms
S+5UP
Labor
Code
Section
5410
Duplicate of HR PSO
TENANT FIL ES
Applications
Payments/Receipts Log
Leases
PER
ENGINEERING SERVICES
005
013
ASSESSMENT DISTRICT
Boundaries & Rolls PER GC 34090
006
020
BENCHMARK DATA
Horizontal, Vertical & Control PER GC 34090 Department Opinion ‐ Need this data for historical reference material
007
011
CAPITAL IMPROVEMENTS
a) Project Files, Work Orders,
Schedules, Bidders List,
Correspondence,
PER
H&S
19850
GC 4003
Life of Structure
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
47 Packet Pg. 61 of 1138
City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Change Order
b) Specifications, Reports Plans,
Contracts and Subdivisions
c) Street Reports
8 CERTIFICATES OF COMPLIANCE PER GC 34090 Duplicate of City Clerk 9 CERTIFICATES OF INSURANCE SUP GC 34090
10 ENCROACHMENT PERMITS
a) Permanent Encroachments
b) Temporary Encroachments
PER
C+2
GC 34090
11 FLOOD ZONE
Elevation Certificates & Letter
of Map Amendments
PER GC 34090
12 MAPS – Annexations, Park
Dedication, Tract, & Block SUP GC 34090 Keep current map version only 13 PERSONNEL
Evaluations
Personnel Action Forms
SUP Duplicate of HRPSO
14 PRIVATE DEVELOPMENT
REVIEWS C+2 GC 34090
15 SOIL REPORTS PER Department Opinion ‐ Need this data for historical reference material
16 STREET WORK PERMITS PER GC 34090
17 SUBDIVISIONS
a) Agreements
b) Parcels and Subdivision Maps
PER
CS+2
GC 34090 Keep current map version only
18 SURVEYS – Recording Data and
Maps PER GC 34090 Department Opinion ‐ Need this
data for historical reference material
ENVIRONMENTAL SERVICES
19 ENVIRONMENTAL FILES PER Department Opinion
20 Discharger permits and permit
support documents
Permit
expiration
or facility
closure + 3
years
40 CFR Federal Pretreatment Regulations
Other Discharger data and
records C+122 40CFR 40
CFR 141.91 Federal Pretreatment Regulations
WATER QUALITY CONTROL PLANT
35 FLOW
Discharge Data and Reports PER 40 CFR
122.41 Department Opinion
36 MAINTENANCE
Flow Strip charts, Instrument
Calibrations, Operations,
Maintenance & Laboratory
Records, & Crane Maintenance
and Certification, State
Certification
C+4 Department Opinion
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
48 Packet Pg. 62 of 1138
City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
37 NPDES (National Pollution
Discharge Elimination System) –
Permits and Reports
PER 40 CFR
122.28 Department Opinion
38 PERMITS
Pressurized Vessels, Air &
Industrial Waste
TERC+4 GC 34090
39 SAFETY
Meetings and Training C+4 GC 34090
40 SEPTIC & RECLAIMED WATER
Permits, Fees, Billings C+4 GC 34090 Department Opinion 41 PERSONNEL
Staff with aAccident report,
accident investigation, or
important disciplinary
matterother personnel event
resulting in change of policy
TER+30
Department Opinion
Duplicate of PSHR
ZERO WASTE
Landfill Daily Log Operator
Assignments and Maintenance
Activities
C+5
GC 34090
Landfill Reports & Records PER GC 34090
Landfill tollbooth receipts C+5
Household Hazardous Waste
Manifest & Reports PER
SMaRT Station & Kirby contract
data C+10 Department Opinion
Waste Contractor data ‐‐
GreenWaste of Palo Alto C+10 Department Opinion
Recycling Programs S+2 GC 34090
SUSTAINABILITY
Climate Action Plan Reporting C+25 GC 34090 Department Opinion Sustainability Project
Documentation C+10 GC 34090 Department Opinion
Greenhouse Gas Inventory Data PER GC 34090 Department Opinion EQUIPMENT MANAGEMENT
21 Transactions – Parts, Fuel, and
Gas Tags C+2 GC 34090
22 Vehicles – Registrations & DMV
Correspondence
Life of
Vehicle DMV Requirement
FACILITIES MANAGEMENT
23 BUILDING MAINTENANCE
Custodial cContracts
City Manager Reports
Specifications
Bidders List
Change Orders
Payment Files
TER+4
C+2
GC 34090
CCP 337
CCP 343
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
49 Packet Pg. 63 of 1138
City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
24 CAPITAL IMPROVEMENTS
a) Project Files, Work Orders,
Schedules, Bidders List,
Correspondence, Change Order
b) Specifications, Reports Plans,
Contracts and Subdivisions
PER
H&S
19850
GC 4003
CCP
337.15
Department Opinion
25 GENERAL ‐ Correspondence
Forms C+2 GC 34090
26 PERSONNEL
Division Staff Schedules
Personnel Action Forms
Injury/Accident Reports
TER
Labor
Code
Section
5410
Originals to HR, copy kept in
individual’s file until employee
termination
27 REPORTS
Quarterly Summary of
maintenance labor and material
costs for Parking Lots
C+2 GC 34090
28 SUBJECT FILES C+2 GC 34090
22 Internal Working Files
29 WORK REQUESTS
Labor and Material Tracking
Key Requests
Service Calls
C+2 GC 34090
STREETS/SIDEWALKS/STORM DRAIN
30 26
32 25
DAILY REPORTS
Operator assignments &
equipment status
Storm Drain
Work Orders
C+5 GC 34090
33 Tree line clearing, landscaping
plans, pesticide spraying,
inventory & irrigation plans
C + 2 GC 34090
34 WORK ORDERS
Streets, sidewalk, signs,
sweeping, trees
C+5 GC 34090
35 Urban Forestry C+2 GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
50 Packet Pg. 64 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
001
Management books, CIP Budget,
Working Files, Operating &
Safety, Staff Meetings,
Correspondence, Budget Change
Requests, Journal Entries
Shipping Receipts, Depreciation,
Proof of Publication
C+2 GC 34090
Master Plans PER Department Opinion
WGW Ops Dailies
WGW Ops Stand‐by/Call Out
Time Report
Shipping records Internal vs.
Outside Vendor
C+2
C+2
C+2
Department Opinion
SUBJECT FILES
002
Policies, Procedures, Processes,
Marking Requirements,
Engineering Standards, Electric
Service Requirements, Cable
Specs, Forms, Best Management
Practices
S+2C+2 GC34090 Department Opinion
003 Drivers License Records While
Useful Duplicate of DMV
004
Other Departments – City
ManagerStaff Reports,
Personnel, Pos, Time Cards,
Claim Vouchers, Invoices,
Abandonments, Annexations,
Council Agendas, Unaccepted
bids, Finance Reports,
Encroachment Permits & Records
Retention Schedule
While
Useful
Duplicate records – originating
department maintains official
document
CONTRACTS
005 Construction & Services/Products
over $25,000
While
Useful CCP 337 Council approved contracts
Dduplicate of City Clerk
005 Services/Products under $25,000 TER+5 CCP 337 City Attorney Opinion Construction PER CCP 337.15 Council approved contracts duplicate of City Clerk
005 Unaccepted Bids C+2 GC 34090
Electric and Gas Meter SUP+7 Duplicate of City Clerk Purchase and Sales Agreements ‐
EEI & NAESB SUP+7 Department Opinion for
retention in Dept. files
Renewable Energy Certificate
Master Agreement SUP+7
Duplicate of City Clerk
Dept. Opinion for retention in
Dept. files
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
51 Packet Pg. 65 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Master Agreement ‐‐ Transaction
and/or Confirmation Agreements
‐‐ including supporting
documentation (deal sheet,
shopping sheet, authorization
etc.)
TER+7 CCP 337 Retained in Utilities Dept.
Bilateral Commodity and/or
related service agreements TER+7
If within City Manager
authority, then retained in
Utilities Dept. If Council
approved, retained in City
Clerk's Office
PROJECT FILES
006 Internal working files PER Department opinion RATES
007 Rates – All Services PER Department opinion
REPORTS
009
Statistical, sales, annual
consumption analysis and
various spreadsheets
C+2 GC 34090
UTILITY ADVISORY COMMISSION
010
Agenda
Proof of PublicationPosting
Minutes of all meetings
General Correspondence
Proof of Agenda Posting
C+2PER
C+2
PER
C+2
C+2
Agendas Duplicate of City Clerk
010 Correspondence and Data Tapes C+2 GC 34090
TASK FORCE
011 City of Palo Alto and SCVWD
Meetings C+2 GC 34090
011 Any task force – internal and/or
external C+2 GC 34090
REGULATIONS
013
National Gas Act
Pipeline Safety Act
Natural Gas Policy Act
CVPIA
While
Useful
C+2
C+2
C+2
Duplicate of Other Agency
CVPIA = Central Valley Project
Improvement Act
CVPIA = Central Valley Project
Improvement Act
013 Correspondence w/ Agency C+2 GC 34090
STUDIES ‐ SURVEYS
014
Gas System Study
Distribution
Electro Magnetic Field Survey
and Energy Case Studies
Commodity Resource
C+2
C+2
C+2
GC 34090
CUSTOMER SERVICES
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
52 Packet Pg. 66 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
015 Customer Correspondence
Letters, faxes, emails C+2 Department Opinion
015
Service:
GC 34090 All listed will be scanned and
retained electronically
Residential Service
Agreement C+3
Residential Service
Application C+3
Commercial Service
Agreement PER
Commercial Service
Application PER
Utilities Account Change C+3
Make Change to Account C+3
Account Closure Request C+3
Close Utilities Account C+3
Revert to Owner Request PER
Revert to Owner Application PER
015
Demolition Request
Demolition Application
Temporary Power
Temporary Power Application
Hydrant Water Application
Hydrant Meter Application
C+3
C+3
C+2
C+2
C+2
C+2
Department Opinion
Department Opinion
015
Billing
Consumption Adjustment
Correct Misread and Billings
Miscellaneous Adjustment
Apply Credit or Debit
Invoice Cancellation
Cancel Rebill Invoice
PV Statements
Monthly PV Status
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
All are created and saved on
electronic templates
Bank drafts
Bank draft confirmation
Returned items
Bank draft application
C+2
C+2
C+2
Duplicate of Admin. Services
Bank Items
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
53 Packet Pg. 67 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
015
Credit & Collections
Rate Assistance
Annual Application Renewal
Project Pledge
One time Submission
Bankruptcy
LIHeap
LIHeap send discs
C+21
C+21
PER
PER
C+3
C+21
C+21
Department Opinion
LIHeap = Low Income Home
Energy Assistance Program
015
Meter Reading
C+1
C+1
C+2
C+2
C+1
C+1
Department Opinion
Customer Read Cards
Reads Submitted by
Customers
Customer Read Emails
Electronic Read Submitted
by Customers
On/and Off Orders
Electronic in SAP
CONSTRUCTION
016
Acquisitions, Easement, Design,
Drawings, Specifications, Photos,
Permits, Soil Reports,
Correspondence, Quotes,
Payments & Schedules
PER GC 34090 Historical
CPAU Work Orders
As‐Built Maps
Valve Cards
PER California Department of
Transportation
CPAU Work Orders of
Abandoned Pipe
As‐Built Maps of Abandoned
Pipe
Valve Cards of Abandoned Valves
PER Department Opinion
ICOMMM Lateral Work Orders
ACP Forms
C+5
C+5 Department Opinion
REGULATORY AGENCIES
017 Reports to
Federal Register
C+2 GC 34090
U.S. Dept of Energy
PG&E
State Regulatory Agencies
(e.g. Public Utilities
Commission)
California Energy
Commission
California Air Resource
Board
REGULATORY RECORDS
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
54 Packet Pg. 68 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Sanitary Sewer Overflow (SSO)
Reports
Sanitary Surveys
C+5
C+10
40 CFR 141.33
RWQCB
Statistics, reports,
correspondence
Water Discharge Form
Water Discharge Monitoring
C+5
C+5
40 CFR 122.41
Annual Report for Public Works
Storm Water Department
Water Connection Records,
Device Locations, and Water
Maps
PER GC 34090
Reports:
Compliance documentation
Average amount of pollution
discharged into waters
Compliance documentation
Corrosion Control C+12 40 CFR 141.91
Discharge Monitoring C+5 40 CR 141.91
Drinking Water Corrections C+10 40 CFR 141.33
Lead Service Line C+12 40 CFR 141.91
Water/Sewer Infrastructure Data
in GIS SUP GC 34090
Underground Utility Locating C+6
CAGC Title 1 Division 5
Chapter 3.1 Article 2
Section 4216
Exception Collection Reviews,
Waste Logs C+2 GC 34090
Paradigm Data Sheets
Cathodic Work Orders
Cathodic Protection with Gas
Distribution Map
Exposed Pipe Reports
Steel Pipeline Tapping Coupon
Records
Annual Report to DOT
Emergency Response Plan
Operations and Maintenance
Manual
PER
PER
PER
PER
TER+5
C+5
C+5
C+5
California Department of
Transportation
EMPLOYEE TEST RECORDS
Gas Operator Qualification C+5 California Department of Transportation
Employee Water Distribution
Certification
Employee Water Treatment
Certification
Employee Backflow Certification
Employee Cross Connection
Certification
C+3
C+3
C+3
C+3
State
Welding Record (form 225A) PER California Department of Transportation
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
55 Packet Pg. 69 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
TESTS/INSPECTIONS/SURVEYS
Backflow Annual Certifications C+3 State
FSR Gas Leak Investigations
(818 Form)
FSR Stop Card Database
Gas Shop Stop Card
Water Shop Stop Card
C+7
PER
PER
PER
California Department of
Transportation
Gas Receiving Stations
Odorant and Oil Drip
Water Meter Test Results
Gas Meter Test Results
Meter Leak Tags
Abnormal Operating Conditions
(AOC)
PER
PER
PER
PER
PER
PER
California Department of
Transportation
Water Quality‐Water Sources:
Testing
Fluoride Summary
Ground Water Elevation
Bacteriologic Analysis
Chemical Analysis
Reservoirs, Wells & Rainfall
Gauge
Water Maintenance Records
Water Discharge Form
C+10
C+5
C+5
Title 22 CCR
66261.24(a)(7)
40 CFR 141.33
State
CPAU Gas Pipeline Patrol
Program
CPAU WGW Operations Pre‐
Tested Pipe Tag (Form 503)
CPAU WGW Operations Grade 1
Log Re‐Checks
Gas Leakage Survey
C+5
PER
C+5
C+5
California Department of
Transportation
PERMANENT RECORDS
019 Equipment Records Life of Equip
+ 2 GC 34090
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
56 Packet Pg. 70 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
019
General Information
Regulating
Specifications & Testing
Gas Leakage Survey
Meter Leak Tag
AOC
CPAU/WGW Operations Pre‐
Tested Pipe Tag
Gas/Water Shop Stop Card
Odorant & Oil Dip
Valve Cards
Valve Cards of Abandoned Valve
Welding Record
Gas Receiving Station
PER
Form 503
Form 225A
ELECTRIC UTILITY
052
048
Electric‐‐Circuit Map, Electric
Distribution, Street Light Block,
EV Charger Maps
C+2
GC 34090 Duplicate stored offsite as vital
copy backup
Maps: Electric Distribution, Pole
Test Block, Distribution Block,
Street Light Block, Hardware and
Coax
Current
while
active,+ 2
years off
site
053
049
Underground District:
Transmission Line Logs &
Correspondence
C+2 GC 34090
054
050
Work Orders:
Pacific Bell, Cable Co‐op, PG&E,
and Intents
PER Department Opinion
055
051
Acquisitions, Design, Drawings,
Specs, Permits, Correspondence
quotes, Payments & Schedules
CIP/Construction
PER Department Opinion ‐
Historical
056 Electric Vehicles:
Power Delivery Records
Life of
Vehicle +2
off site
GC34090
057
Street Lights:
Lighting, Program Materials C+2 GC 34090
058 Joint Pole Applications TER+5 Department Opinion Customer Services Projects
Applications, Plans, Invoices C+2
ELECTRIC OPERATIONS
059
Compliance/Inspections/Locating
Field Switch/Man on Line
Logs
Overhead/Underground
Compliance Records
PER
PER
C+1 on site
C+1 on site
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
57 Packet Pg. 71 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Underground Service Alert
Notices
a. Completed Tickets
b. Original Email Notices
C+6
C+21
Onsite
060 Customer Service – UCC
Dispatch Logs PER Electronic copy on S drive
061
Street Lights/Traffic Signal/Fiber
Notifications – SL & TS
Maintenance – WO ‐ TS
C+6
Work transaction recorded in
SAP. Mark‐up records
maintained on site
062
055
Substations
a) Equipment (transformers,
switches, breakers, capacitors,
relays)
Specifications
Inspection
Inventory
Replacement
Disposal
Life of Equip
+2
Department Opinion
Duplicate stored offsite as vital
copy backup
062
055
Substations
b) Operations (troubleshooting,
line logs, load reports, power
factor, fences, cost data)
C+6
18 CFR Sections
125.3(23) & 125.3(26)
Inspection records and
equipment test records stored
electronically on F:drive
C+3 on site + 3 years off‐site
064
055
Substations
c) Relay and fuse curves, fault
current, calculations, supervisory
control, automation and
distribution automation (SCADA)
and Control Information
C+2 GC 34090
Duplicate stored offsite as vital
backup copy
MARKETING SERVICES
Program Development PER Department Opinion
061
064
Customer Applications
Smart Energy Program
CAP
PV Partners Program
Solar Water Heating Program
Solar Water Heating Loan
Program 1970‐1990
Palo Alto Green Program
Palo Alto Green Gas/New PA
Green
Fiber Program
Customer Applications
Rebate Application & agreement
Rebate Applications
Old Program ‐‐ files at The State
Signed Agreements
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
GC 34090
Department Opinion
Department Opinion
Department Opinion
Department Opinion
Council approved contracts
Dduplicate of City Clerk
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
58 Packet Pg. 72 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
062
066
Vendor contract invoices
3rd Pary Programs
Monthly/quarterly/annual
electronic records
While
contract is
in
effectTER+4
CCP 337 Department Opinion
063
066
Key Account Engineering Audit
Reports
BI Reports
Pcard receipts
C+2
C+2
C+2
GC 34090 Department Opinion
067
Public Outreach
Program marketing materials
Customer Workshops & Facility
Manager Meetings
C+6
C+2
Department Opinion
SUPPLY RESOURCE GROUP
070
Settlement Date
Commodity Invoices/payment
records
TER+2
PER
Department Opinion
Keep for two years past
contractual limitation of
invoice dispute
071
Regulatory Reference Materials
(e.g. – laws, ruling, orders, court
cases, settlements)
While
Useful Duplicate of Other Agency
Risk Management
FO and BO Transaction oversight
Monthly BO reports
FO and BO Quarterly reports
FO Weekly Reports
C+6 Department Opinion
078
Rates Documents
Rates/Pricing
Cost of Service Studies
SUP+7
080
Resource Plans
Long‐term Electric Acquisition
Plan, Gas Long‐Term Plan, Water
Integrated Resources Plan
SUP+2
Department Opinion
Adopted plans duplicate of City
Manager and City Clerk
Electric Portfolio Models
Commodity Costs Protections &
Uncertainty Assessment
‐ load and resource balance
‐ supply costs
‐ transmission cost
‐ interconnection
‐ agency costs
‐ hydrology
‐ plant operation and
maintenance
‐ regulatory costs
C+7 for
annual
budget
models
Maintained in electronic
models
‐ overwritten as necessary
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
59 Packet Pg. 73 of 1138
City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Electric Procurement Plan
Procurement Plans ‐‐ Needs
Analysis Load/Resource
Balance Targets
Authorizations
C+5 Department opinion
Voluntary Certification and
Verification
C+7
Department Opinion
§ Reports to certifying and
verifying agencies such as The
Climate Registry for GHG
Inventory and for Carbon Neutral
Plan (Electric Power Sector)
§ Reports from certifying and
verification agencies such as
audit reports
§ Risk Oversight Committee
§ New Models
§ Standards of Conduct
R&D Program
PET Projects related
documentation
C+6 Department Opinion
Policies
Analysis of plans, programs, and
policies that become adopted by
Council
SC+2 Department Opinion
Item 2
Attachment B - 2025
Records Retention
Schedule - Redline
Item 2: Staff Report
Pg.
60 Packet Pg. 74 of 1138
READING THE RETENTION SCHEDULE:
A "HOW TO" GUIDE
BA
CKGROUND
The
Retention Schedule, as approved by the City Council through Resolution, is a legal document. It identifies the types of records and information used and managed by a department, how long that information must be retained at the office and/or off-site, and when it may be destroyed.
E
ach department is required to have a current Schedule. It is the responsibility of the department to notify the City Clerk’s Office of any business, organizational, functional, or legal changes which would impact their specific Schedule. The City Clerk’s Office coordinates with the departments and Office of the City Attorney (which reviews the schedules for compliance with all government codes and regulations) prior to approval by the City Council. The Schedules should be reviewed for accuracy every two to three years by the City Clerk’s and City Attorney’s Offices in conjunction with each respective department.
D
EFINITIONS
D
escription – This is the general description of a group of records with similar business functions and retention requirements. The description must coincide with file titles maintained by the department.
To
tal Retention – This refers to the length of time a record must be kept before it is eligible for destruction.
C
– Current refers to the current calendar year in which a record is made. The Retention period begins the first day of the following calendar year. (For example, C +2 means that any record created in 2025 is kept for the two following years, 2026 and 2027. The record would be eligible for destruction after December 31, 2027).
PER
– Permanent refers to records that should be kept in perpetuity and never destroyed.
S
– Supersede indicates that old items are replaced by a more current version.
T
ER—Termination refers to the end date of a contract, agreement, term, etc.
St
atutory Reference – This field includes regulations and codes that govern the retention of a specific record type. All references are to California Code unless otherwise noted.
R
emarks – This field includes general comments about the information in this row. When "Department Opinion" is noted in this column, it means that the Department has decided to maintain the record longer than the legal requirement. "Attorney Opinion" indicates that the retention requirement was established pursuant to the opinion of the City Attorney based on research, past litigation history, and/or the potential for future litigation on this topic. The 2025 revision preserves Department and Attorn ey Opinions from previous versions of the schedule.
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
61 Packet Pg. 75 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATION
Correspondence, Messages,
Timecards, Staff Meetings, Studies
C+3
Auditors Opinions
3 Gifts to the City, Cash & Tangible
Property
C+6 Scanned list on CD Rom in Admin
Svcs Dept files
TREASURY
4 INVESTMENT MANAGEMENT‐
Security Purchases, Sales &
Investment Reports
C+7
Auditors Opinion
5 DEBT MANAGEMENT‐
(a) Deceased Insurance C+3 Department Opinion
(b) Final Bond TER+4 Duplicate Stored Offsite as vital copy backup
(c) Covenant Compliance TER+7 Duplicate stored offsite as vital copy backup
(d) Bank Records C+7 Duplicate stored offsite as vital copy backup
REVENUE COLLECTION
6 (a) Deposit/Reconciliation
Documentation
C+2 GC 34090
(b) Parking Permit Records C+4 GC 34090
(c) Collection Records – UUT,
Parking Citations, Delinquent
Accounts, Transient Occupancy Tax
C+5
Department Opinion
BUSINESS LICENSE TER+4 GC 34090;
CCP 337
LIENS & RELEASES
(a) Recorded Liens & Releases
(b) Supporting Recorded
Documentation
PER
TER+2 GC 34090
BUDGET
7 BUDGET
(a) Final Budget, CIP Budgets, Fee
Schedule
TER+4
(b) Supporting Documents for
Change Requests, Amendments,
Worksheets, Fee Schedules & Cost
Plans
C+2
Auditors Opinion
(c) Long Range Plans Studies,
Reports, Measurements, Forecasts
& Projections
C+3
Auditors Opinion
REAL ESTATE
8 BINDING INSTRUMENTS
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
62 Packet Pg. 76 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
(a) Land – Deeds, Easements PER Duplicate of City Clerk (b) Easement Vacations, Leases &
Purchases
PER Duplicate of City Clerk
(c) Encroachments, Agreements &
Conveyances
PER Duplicate of City Clerk
PURCHASING
9 (a) Council Approved Contracts,
Solicitations & Documents. All Open
Council Approved Contracts,
Solicitations & Documents
TER+ 4
CCP 337.2
CCP 343
Council Approved Contracts
duplicate of City Clerk
(b) Service Contracts, Purchase
Orders, Blanket Purchase Orders &
Solicitations & Documents
i. Purchase Orders/Blanket Orders
ii. Service Order Contracts
TER+4
TER+4
CCP 337.2
CCP 343
(c) Bids Unawarded Solicitations &
Documents
C+2 GC 34090 Department Opinion vital while
orders are open
10 INTERNAL VENDORS ‐ (Stores &
Print Shop) Reports, Orders,
Returns, Disposal Forms Journal &
Requisitions
C+4
Department and Auditors Opinion
ACCOUNTING
11 YEAR‐END REPORTS
(a) Budget‐to‐Actual C+2 GC 34090
(b) Comprehensive Annual Financial
Report (ACFR)
PER
(c) General Ledger, Encumbrance
Report
C+2 GC 34090
(e) Audit Work Papers & Journal
Entries
C+2
GC 34090
Digital copies of audit work
papers: saved on S drive, Journal
Entries saved on SAP effective
March 2023
(f) ANNUAL PUBLIC IMPROVEMENT
CORPORATION‐STATE
CONTROLLERS REPORT
C+7
Digital copies only
(g) PIC TAX Return C+7 Digital copies only
(g) Annual Street Report C+7 Digital copies only
(h) City Financial Transaction Report Digital copies only Utility Receipt Stubs C+2
ACCOUNTS PAYABLE
12 A/P + UTILITY CHECK
REGISTERS (WARRANTS)
C+7
C+7 Department and Auditors Opinion
(voided checks) Digital copies only
13 CANCELLED/VOIDED
WARRANTS. CHECK VOID FORMS +
BACKUP
C+4
C+7
Department and Auditors Opinion
(VOIDED CHECKS) Digital copies
only
14 VOUCHER PACKETS.
GENERAL WARRANT COPIES WITH
C+5
C+7 Department and Auditors Opinion
Digital copies only
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
63 Packet Pg. 77 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
BACKUP FOR A/P, UTILITY REFUNDS,
3RD PARTY AND WIRE TRANSFERS
15 CAPITAL PROJECTS TER+7
Department and Auditors Opinion
Project Files, Street Reports, &
Community Development Block
Grant (CDBG) Billings
Community Development Block
Grant (CDBG) Billings / Drawdown
Digital copies only
UNIVERSITY AVENUE SPECIAL
ASSESSMENT PARKING DISTRICT
C+7 Digital copies only
ANNUAL INTERGOVERNMENTAL
EXPENDITURES REPORT
C+7 Digital copies only
ZFIR03 AUTHORIZED SIGNATURE
COVER SHEETS
C+7
Cover sheet for batches off
invoices from departments sent to
A/P. Has list of invoices enclosed
and department authorization to
process the invoices.
A/P JOURNAL LOG C+7 Digital copies only
AUTHORIZING SIGNATURE FORMS C+7 Digital copies only TAX RECORDS – Sales Tax Filings,
1099 Tax Filings & Registers
C+7 Digital copies only
ACCOUNTS RECEIVABLE and CASH RECEIPTS
16 Backup for invoices created (such as
Airport, Avenidas, & Palo Alto
Community Childcare, Stanford, VTA
and others)
b) Facility Cash Receipts, Revenue
Collections Cash Receipts, and
Utility Cash Receipts
C+7 GC 34090,
CCP 338
Federal & State Audit
Requirements
Duplicate stored offsite as vital
copy backup
Department Opinion
Digital copies only
21 PAYROLL
C+7 29 CFR
Section
1627.3
Labor
Relations
Section
1174
California
Labor Code
Section
1174
Public Employees Retirement
System and Department Opinion ‐‐
Duplicate stored offsite as vital
copy backup
Garnishment Orders C+7 SB 807 1/2022 CA Record
Retention ‐ 4 Years
Direct Deposit/ W4 Changes C+7 IRS Requirement ‐ 4 years
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
64 Packet Pg. 78 of 1138
City of Palo Alto
Records Retention Schedule
Administrative Services
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Copies of PSO PAF C+7 4 Years HR owns original copy retention
CalPers Reporting C+7 4 Years HR owns original copy retention
Third Party Reporting C+7 4 years
Payroll Quarterly Tax Reports C+7 IRS Requirement ‐ 4 years Payroll Masterfile C+7 4 years
Payroll Reconciliations C+7 In accordance with GL
Payroll Journals C+7 In accordance with GL
W2 Copies C+4 IRS Requirement ‐ 4 years
ENTERPRISE/ GENERAL LEDGER ACCOUNTING
23 GL Accounts Reconciliations C+7
24 Reconciliations of utility and other
clearing accounts
C+5
25 Receipts/stubs from the daily utility
payments process (batch detail)
C+2+2
months GC 34090
26 Audit Backup & Journal Entries
Backup
C+2 GC 34090
27 28
Fixed assets backup of journal
entries, capitalization, disposals &
reconciliations
TER + 3
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
65 Packet Pg. 79 of 1138
City of Palo Alto
Records Retention Schedule
City Attorney’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
General Info/Subject Files C+9 GC 34090
Restricted access to any files may contain
confidential documents. Keep files until
subject matter is no longer active.
Required to keep until reasonable threat
of legal action has passed.
General Correspondence C+9 GC 34090
Contracts, invoices, and purchase
orders originating in City
Attorney’s Office
TER+10 Review on a file by file basis for
destruction
SUBJECT FILES
Legal memoranda to City Council C+11 Review on file by file basis for destruction
Settlement Agreements C+10 Settlement agreements with ongoing relevance retained for as long as needed
Municipal prosecutions TER+10 Review on file by file basis for destruction
Attorney-led investigations C+10 Review on file by file basis for destruction
900 Claims TER+10
Required to keep until reasonable threat
of legal action has passed. On a file by
file basis assign archive time
Civil litigation files C+10
Required to keep until reasonable threat
of legal action has passed. On a file by
file basis assign archive time
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
66 Packet Pg. 80 of 1138
City of Palo Alto
Records Retention Schedule
City Auditor
Series Description Total
Retention
Statutory
Reference
Remarks
SUBJECT FILES
4 Publications (Audit Reports),
Status Reports, Revenue
Reports, Council Reports
PER GC 34090
Department Policy.Post-2025,
publications included City Council
/Committee agenda packets are
kept by CLK
5 Work Papers (supporting
documentation for published
reports)
C+7 GC 34090
While City Auditor is outsourced,
duplicates kept by relevant
department as needed.
6 Revenue Audit Work Papers
(Sales, TOT, UUT, Prop. Tax
etc.)
C+7 GC 34090
While City Auditor is outsourced,
duplicates kept by relevant
department as needed.
7 Fraud, Waste, and Abuse
Hotline documentation TER+5 GC 34090
While City Auditor is outsourced,
duplicates may be kept by another
associated department as needed.
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
67 Packet Pg. 81 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
100 Domestic Partnership
Affidavits & Statements PER GC 34090
101
FINANCIAL DOCUMENTS
a) Contracts awarded by City
Clerk Department, except
construction
b) Contracts awarded by City
Council, except construction
c) City Clerk Purchase Orders
d) Construction contracts
awarded by City Council
TER+4
TER+4
C+2
PERM
PAMC 2.08.110;
CCP 337
PAMC 2.08.110;
CCP 337
City Clerk Purchase Orders
duplicate of ASD
102 General Correspondence C+2 GC 34090
103 LEGAL ADVERTISING C+4
CCP 343, 349 et
seq.;
GC 911.2
Includes public hearing notices,
legal publications
104 PUBLIC RECORDS REQUESTS
Requests, responses, and log TER+2 GC 34090 TER = Resolution Date
ADMINISTRATIVE HEARING RECORDS
106 Alarm and Parking Ticket
Appeal Hearings TER+2 GC 34090 Includes Initial Review
document
108 Other Administrative
Hearings C+5 GC 34090 Public Works and Community
Services Department hearings
109 Parking Citation Adjudications
(Request for Initial Review) TER+2 GC 34090 Department opinion 110 Utility User Tax Hearings C+10 GC 34090
ELECTIONS/POLITICAL REFORM ACT
111 AB1234 ETHICS TRAINING –
Proof of training attendance C+5 GC 53235.2b
113
CAMPAIGN DISCLOSURE
STATEMENTS-
a) Elected Members & Log of
Filers, their Controlled
Committees, and committees
supporting such officeholders
and candidates
b) Non-elected candidates,
committee supporting non-
elected candidates
c) Others -- Committees,
Supporting/Opposing
Measures, General Purpose,
Independent expenditure,
major donor committees
d) Copies received (e.g. Form
410)(paper)
e) Electronically filed
PER
C+5
C+7
C+4
PER
GC 81009 (g)
GC 81009(b)
GC 81009(c)
GC 81009(f)
GC 84615(i)
After two years on file, an
electronic copy of the
statement may be retained and
originals discarded (GC
81009(g))
Original electronic form must
be kept for at least 10 years
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
68 Packet Pg. 82 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
114 CONFLICT OF INTEREST CODE PER PAMC 2.08.110 Code is Adopted by Resolution, Resolution is Permanent
115
FPPC AGENCY FORMS
a) Gift to Agency Report --
Form 801
b) Behested Payment Report -
- Form 803
c) New Positions -- Form 804
d) Consultants -- Form 805
e) Public Official
Appointments -- Form 806
C+7
C+7
S+4
C+4
C+2
FPPC 18944
GC 82015
FPPC 18734
FPPC 18734
FPPC18705.5
FPPC Retention
Current on City Website
116 NOMINATION PAPERS TER+4 EC 17100
Non-elected TER = Term of
office or failure date
Unless requested per EC
17100(b)
117
PETITIONS, INITIATIVES,
REFERENDUM, RECALL &
CHARTER AMENDMENTS
Petition
TER+8
months
EC 17200
EC 17400
(Recall
petitions)
7924.100-
7924.110 (PRA
reference)
PA Charter
Articles VI and
IX
RESTRICTED ACCESS
TER = date of election result
certification
Department Opinion 8/14
Certain records may be kept for
historical/reference purposes
117b Certification of Election
Results C+10 EC 15372
118 SAMPLE BALLOT PER GC 34090
119
STATEMENT OF ECONOMIC
INTEREST – Form 700
(Designated Filers) & Log of
Filers
C+7 GC 81009(e)-(g)
Originals retained C+7
Copies retained C+4 "Wet"
paper filed forms can be
digitized after 2 years
120
STATEMENT OF ECONOMIC
INTEREST – Form 700 (GC
87200 Filers) & Log of Filers
C+4 GC 81009(d)-(g)
Originals forwarded to State.
Copies retained C +4
GC 87200 Filers include City
Council Members, the City
Attorney, City Manager,
Planning Commissioners, and
the Administrative Services
Director (CFO)
LEGISLATIVE HISTORY
121
BOARDS & COMMISSIONS
a) Applications &
Appointments
I. Appointed
II. Not Appointed
b) Letters of Appointment
TER+5
C+2
TER+2
GC 34090;
GC 40801
TER = Leaving Office date
CL = Close of recruitment
TER = Leaving Office date
TER = Leaving Office date
Item 2
Attachment C - 2025
Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
69 Packet Pg. 83 of 1138
City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
c) Notices of Termination
d) Oaths of Office
e) Recruitment Outreach
f) General Correspondence
g) BCC Handbook
TER+2
TER+6
TER+2
C+2
S
122 CITY COUNCIL ROSTER PER Department Opinion
Paper C+2
123
COUNCIL & STANDING
COMMITTEES MEETINGS
a) Agenda Packets -- Docs.
and information submitted to
Council including questions
and answers to Council
agenda items
b) Agendas
c) Minutes
d) DVDs/Recordings
e) Proof of Agenda Posting
PER
PER
PER
PER
C+2
GC 34090;
GC 40801
54960.1(c)(1)
GC 34090
Department Opinion
Department Opinion 2025
Agenda Packets not PER before
2024
Department Opinion 10/14
124
COUNCIL MEMBER –
b) Biographies
c) Photos
d) Emergency Standby Council
Oaths of Office and Report
PER
PER
PER
Department Opinion 10/14
125 OATHS OF OFFICE
a) Elected Council Member
TER+2 6
PER
GC 34090;
29 USC 1113
TER = Leaving Office date
Department Opinion 8/14
126 ORDINANCES PER GC 34090;
PAMC 2.08.110
127 PROCLAMATIONS C+2 GC 34090
128 RESOLUTIONS PER GC 34090;
PAMC 2.08.110
128a MUNICIPAL CODE PER GC 34090 Added in 2025
129
RECORDS & INFORMATION
MANAGEMENT-
a) Retention Schedules &
Manuals
b) Destruction Certificates
c) Transfer Lists
d) Inventory Database
S+4
PER
PER
S
GC 34090
GC 34090
Department Opinion 8/14
Department Opinion
130 STATE OF THE CITY ADDRESS
- DVD/recording and Speech PER GC 34090 Department Opinion 8/14
REAL PROPERTY
131 ANNEXATIONS/ACQUISITION PER GC 34090a
132 ASSESSMENTS PER Department Opinion
133
BINDING INSTRUMENTS
a) Land -- Deeds, Easements,
Record of Land Use Action
b) Easements, Vacations,
Leases & Purchases
a) PER
b) PER
c) PER
GC 340 90a
Department Opinion
Duplicate of County Recorder
TER = paid in full
TER = paid in full
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
City Clerk’s Office
Series Description Total
Retention
Statutory
Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
c) Encroachments,
Conveyances
d) Community Development
Block Grants (CDBG)
i. Deeds of Trust
ii. Promissory Notes
iii. Agreements
e) Certificates of Compliance.
f) Real Property Agreements,
i.e. Regulatory Agreements,
Declaration of Restrictive
Covenants, Occupancy, Land
Use, and Development
Restriction Agreements
d) TER+6
e) PER
f) PER
134 BONDS TER+10 GC 34090
CCP 337.5 Duplicate of County Recorder
135 DEEDS OF TRUST TER+6 CCP 336a
136 LIENS, CONDEMNATION PER GC 34090a
137 SUBDIVIDER AGREEMENTS PER GC 65864 &
65869.5
SUBJECT FILES
138 CABLE TELEVISION –
Franchise & Licenses PER GC 34090 City Attorney Opinion 9/87 139 CEQA POSTINGS C+2 PRC 21152 (c)
GC 34090
140 CIVIL GRAND JURY REPORTS PER CPC 933
141 CLAIMS AGAINST THE CITY C+5 PAMC 2.28.230
& 2.28.240
Duplicate of City Attorney
142 FLOOD BASIN PER GC 34090 City Attorney Opinion 9/87 143
NORTHERN CALIFORNIA
POWER AGENCY –
Agreements including
Transmission Agency of
Northern California
PER PAMC 2.08.110 City Attorney Opinion 9/87
144 PAC BELL/PG&E PER GC 34090 Department Opinion 1992
145 POLICE AUDITOR REPORTS PER GC 34090 Department Opinion 4/2015 146 POLICIES
(a) Council Policies S+2 GC 34090
147
STANFORD (Including Sand
Hill Road, Willow Rd.
Extension)
PER PAMC 2.08.110 City Attorney Opinion 9/87
148
SUBJECT FILES – All subject
files included, unless
specifically set forth
elsewhere.
C+2 GC 34090
Confidential Legal Opinions are
not public information and are
restricted from public access.
149 WATER RIGHTS – Agreements
and Clean Up PER GC 34090 City Attorney Opinion 1995
150 YACHT HARBOR PER PAMC 2.08.110 City Attorney Opinion 9/87
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City of Palo Alto
Records Retention Schedule
City Manager’s Office
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
001 Personnel Information,
Budget Information
While
useful Duplicate records of other
departments
003
Economic Development Files
for Projects throughout City
of PA
PER May be stored off-site
Sister Cities C+2 GC 34090
LEGISLATIVE HISTORY
004 Legislative Letters C+5
SUBJECT FILES
005
Files established pertaining to
various subjects, Project files,
Chronological Files
C+2 GC 34090
POLICIES AND PROCEDURES
006 Official copies of all City
Policies and procedures S
Each department should have a
current copy of the Policies &
Procedures
TRANSPORTATION
BICYCLES
016 a) Bike Boulevard PER GC 34090
Unique project, historical
significance, model for other
jurisdictions in and out of U.S.
Department Opinion
b) Bike Counts C+5 GC 34090
c) Bike Facilities,
Lockers/Racks
C+2 GC 34090
d) Bike Locker Rental Program C+2 GC 34090
e) Bike Operations
(signing/striping, signal
detection), paths, Routes and
Trails
C+2 GC 34090
f) Pedestrian and Bicycle
Advisory Committee
C+5 GC 34090
017
FUNDING-Fuel Efficient Traffic
Signal Management Program
(FETSIM) Applications, Prop
116 Applications, Surface
Transportation Program
(STDP)/Congestion Mitigation
and Air Quality
(CMAQ)Applications and
Transportation Development
Act (TDA) Article 3
Applications
PER
GC 34090
24 CFR
200.334
24 CFR
570.502
29 CFR
97.42 018 NEIGHBORHOOD STUDIES C+2 Department Opinion
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City of Palo Alto
Records Retention Schedule
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
PARKING
019 a) Assessment Districts PER Multiple Depts Opinion b) Carpool/Vanpool Program C+2 GC 34090
c) Facilities(garages/lots) PER GC 34090 Department Opinion d) Permit Policy/Management S+2 Department Opinion
e) Residential Permit Parking C+2
f) Structures PER Department Opinion
g) Surveys C+2
h) Zones C+2 Department Opinion
i) Congestion Pricing C+5 Department Opinion
020
PERMITS/TRAFFIC CONTROL-
Certificates of Insurance and
Traffic Control Plans
C+2 GC 34090
TRAFFIC REFERENCE
021
a) Bike-correspondence, other
jurisdiction bike plans,
safety/education
C+2 GC 34090
Department Opinion/Online
Reference
b) Demographic Data PER Department Opinion
c) Traffic Flow Maps C+5 GC 34090
022 REGIONAL AGENCIES C+2 GC 34090
023 SCHOOL SAFETY C+2 GC 34090
024 TRAFFIC STUDIES
C+5 GC 34090 Department Opinion
a) Traffic Calming
b) Traffic Signals
c) Other Traffic Studies
025
Traffic Operations Accidents
(high accident
location/accident data and
reports)
C+2 GC 34090
026 Plans PER H&S 19850
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City of Palo Alto
Records Retention Schedule
Community Services Department
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE SERVICES
1 Personnel – Current Employees Performance
Reviews & Work Schedules C+2
2 Security Documents, Work Orders,
Correspondence Inventories, Logs & Reports C+2 GC 34090 3 Policy – Policies, Procedures & Forms S CA Opinion
4 a) Stores Req
b)Purchase Orders
c)Contracts
TER+3
TER+3
TER+4
5 Volunteer Records C+2 GC 34090
6 Accounting – Sales Receipts, Deposits, Sales
Logs, Ledgers, Fees/Fines, Bills & Transit Books C+2 Community Services Opinion
ARTS & SCIENCES DIVISION
7 Art Loan Program C+2 GC 34090
8 Theatre Records – Costume & Prop Loans and
Booth Level Settings C+2 GC 34090
9 Art Collection C +2 Community
Services Opinion
10 Public Art Commission –
a) Action Agenda
a) Proof of Posting
b) Minutes of all meetings
c) General Correspondence
d) Proof of Agenda Posting
PER
C+2
PER
C+2
C+2
Community
Services Opinion
Agendas
Duplicates of
City Clerk
11 Exhibits – Junior Museum & Baylands
Interpretive Center PER Community
Services Opinion
12 Animal Permits – Junior Museum & Zoo TER+2
Fish & Game
Sections 3200,
3204
HUMAN SERVICES & CUBBERLEY DIVISION
Human Relations Commission –
a) Agendas and Packets
b) Proof of Publication
c) Minutes of all meetings
d) General Correspondence
e) Proof of Agenda Posting
PER
C+2
PER
C+2
C+2
GC 34090
Agendas
Duplicates of
City Clerk
RECREATION AND GOLF DIVISION
20 Use Permits – Fields, Parks, Courts, Certificates
of Insurance, Facilities Applications & Logs and
Group Agreements
C+2 GC 34090
21 Waivers, Cancellation/Transfer Forms C+2 GC 34090
22 Recreation Foundation – Minutes,
Correspondence & Financial Information C+2
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City of Palo Alto
Records Retention Schedule
Community Services Department
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Parks & Recreation Commission -
a) Action Agenda
a) Proof of Posting
b) Minutes of all meetings
c) General Correspondence
d) Proof of Agenda Posting
PER
C+2
PER
C+2
C+2
GC 34090
Agendas
Duplicate of
City Clerk
Fee Reduction Program C+2 Department
Opinion 2024
ANIMAL SERVICES
23 Veterinary Medical Records – all records
relating to animal inventory and care TER+3
BP 4081
FAC 32003€
PC 597.1(d)
Previously in
Police Dept.
retention
schedule.
Retained by
contractor
Pets in Need
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
1 DEPARTMENT
MANAGEMENT C+2 GC 34090
General Order, Special
Orders, Bulletins While Useful Department Opinion
Policies and
Procedures S+6 GC 34090
45 CFR Part 164.530
Memorandum of
Agreements TER+4 Duplicate of Human Resources
(HR)
General
Correspondence C+2 GC 34090
001(a) Code Books,
Ordinances PER GC 34090(e) California Fire Code, Ordinances duplicate of City Clerk
2 DEPARTMENT PLANS PER
Strategic Plans/Master
Planning Documents S+2
3 GENERAL
CORRESPONDENCE &
REPORTS
C+2 GC 34090
Correspondence,
memos, emails, press
releases
C+2 GC 34090
Committee reports,
minutes, public file
review requests
While Useful Duplicate of City Clerk
Special studies,
community relations While Useful
4 BIDS-UNACCEPTED While Useful Duplicate of Purchasing 5 OTHER DEPARTMENTS While Useful Duplicate of Other
Departments
Staffing roster,
timecards, leave
reports
While Useful Duplicate of Administrative
Services (ASD)
Contracts and
accounting reports,
purchase orders,
deposits, receipts
TER+4 CCP 337
CCP 337.15
Duplicate of ASD; Council
approved contracts duplicate of
City Clerk
Records retention
schedule S Duplicate of City Clerk
6 EMPLOYEE FILES
006(a) Training records,
certificates C+2 GC 34090 Duplicate of HR
006(b) Employee records While Useful Duplicate of HR 006(c) DMV Driver Tests and
records C+2 GC 34090 Duplicate of HR
7 EMPLOYEE
INJURY/EXPOSURE While Useful Duplicate of HR
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City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Employee accident and
exposure reports PER 29CFR1910.1020 Department Opinion Individual and
summary statistics PER
SUBJECT FILES
FIRE PREVENTION
8 FIRE PREVENTION:
Code Enforcement
actions
TERCL+5 CFC 104.6
Site Plans While Useful
Requests for service,
complaints. C+2
Sprinkler system & Fire
Alarm periodic testing
reports & inspections
C+6
Electronic 5 Year tests: Keep C+6
Stored by 3rd Party Vendor
008(a) FIRE INVESTIGATION
REPORTS & PHOTOS TER+6 CFC 104.6.2
PC 801
TER= for as long as the
structure or activity to which
such records relate remains in
existence
008(b)
FIRE/HOMICIDE
INVESTIGATION
REPORTS & PHOTOS
PER PC 799 C+6 onsite; PER offsite
008(c) ARSON /JUVENILE
FIRESETTER SUSPECTS C+6 CFC 104.6;
PC 801
Include interviews,
documentation and classroom
materials for junior firesetters
9 ANNUAL FIRE (CFC)
PERMITS C+2 GC 34090
10 STREET & NUMBER
ASSIGNMENT While Useful CFC 103.3.4
PAMC 16.36.030
Duplicate of Planning and
Development Services
11 FIRE INSPECTIONS
(Bureau and Engine
Company inspections)
TER+6 CFC 104.6.2 Department Opinion
Records of Inspection;
routine, special, new
construction & tenant
improvement-related.
PER CFC 104.6.2 Electronically stored in Accela
Pre-Citation Letters,
Notice of Violation
letters.
C+2
GC 34090
12 CERTIFICATIONS GC 34090
Flame Resistance PER Electronically stored in Accela
Use and Occupancy
Certificate PER Electronically stored in Accela
13 SPRINKLERS & FIRE
SUPPRESSION
SYSTEMS
Life of Building
(LoB) CFC 104.6
Pertains to real property. May
include blueprints, reports,
inspection results, permits.
Keep 2 years onsite, permanent
offsite
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Design, Flow,
Installation documents LoB
Plan review comments LoB
14 BUILDING PROJECTS LoB GC 34090(a)
Pertains to real property. May
include blueprints, reports,
inspection results, permits.
Keep 2 years onsite, permanent
offsite
New Construction &
Tenant Improvement
Projects, including
underground tank
installations and
repairs
PER
Electronic Electronically stored in Accela
Alternate means and
methods applications PER CFC 104.6.4 Electronically stored in Accela Plan review comments PER Electronically stored in Accela
SUPPRESSION
15 INCIDENTS (fire,
medical, hazmat, etc.) PER Electronically stored in RMS 015(a) Dispatch and daily logs C+2 GC 34090 Release to Union; do not destroy
015(b) Fire Incident Reports;
all except arson related PER CFC 104.6
PC 801 Electronically stored in RMS
015(c)
Fire Incident and other
Field Reports; arson
related
PER CFC 104.6
PC 801 Electronically stored in RMS
015(d)
Fire Incident and other
Field Reports; arson
with death involved
PER PC 799 Electronically stored in RMS
015(e) Pre-Hospital Care
Report (PCR) PER 45 CFR Part 164.530 Electronically stored in RMS 16 ENGINE/TRUCK
EQUIPMENT
016(a) Daily & Monthly logs C+2 GC 34090
016(c) Maintenance Program. C+2 GC 34090
HAZARDOUS MATERIALS
17 ANNUAL HAZARDOUS
MATERIALS STORAGE
PERMIT
TER+ 2 GC 34090
18 CALCULATIONS-
Seismic and secondary
containment
C+ 2 GC 34090
19 SITE CLEANUP Spill
Reports & facility
closure related
information; related
inspections. Does not
PER GC 34090(a)
Pertains to real property.
Electronically stored in
California Environmental
Reporting Service (CERS)
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City of Palo Alto
Records Retention Schedule
Fire Department
Series Description
Total Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
include reports for
activities regulated by
Calif. Regional Water
Resources Control
Board or Calif Dept of
Toxic Substances.
20 HAZARDOUS
MATERIALS &
UNDERGROUND TANK
INSPECTIONS, routine,
special, and
enforcement related
C+6 CCR 27, 15188
Department Opinion
C+5 Required. Keep additional
time for consistency with other
inspection records.
Electronically stored in CERS
21 HAZARDOUS
MATERIALS BUSINESS
PLANS
C+2 GC 34090 Electronically stored in CERS
UNDERGROUND TANKS
22(a)
UST closures and/or
removals and related
documentation. Does
not include reports for
activities regulated by
Calif. Regional Water
Resources Control
Board or Calif. Dept of
Toxic Substances.
PER GC 34090(a)
Pertains to real property. May
include blueprints, reports,
inspection results, permits
Electronically stored in CERS
022(b)
Periodic testing,
monitoring and special
reports
C+2 GC 34090 Electronically stored in CERS
PROGRAMS
23 SPECIAL PROGRAMS:
Strike teams and
mutual aid response
C+12 GC 34090
Existing Department Opinion is
C+12. Note that GC 34090
requires only C+2
23 (a)
Disaster Service
Worker:
All associated
documents
TER + 30 CCR 19, 2573.2
GC 3105, 6250 Required for injury Claims
24 PARAMEDICS: Training
and testing C+4 CCR 22, Div 9, sec
100101
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City of Palo Alto
Records Retention Schedule
Human Resources
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
1 GENERAL – Correspondence,
Timecards, Contracts, Subject
Files, Budgets, Projects
C+2 GC 34090
2 STANDARDS – Policies, Rules,
Bills, & Regulations C+2 GC 34090
EMPLOYMENT
4 RECRUITMENT – Applications,
Resumes, Alternate Lists,
Testing
C+3
42 USC Sections
2000e-8; 29 CFR
Section 1602.12 and
1602.14
Restricted Access
5 PERSONNEL FILES (a) Regular
Employees TER+15
29 CFR Section
1627.3
Labor Code Section
1174
Access may digitally store after
2 years and shred
Restricted Access
PERSONNEL FILES (b) Water
Quality Control Plant -- Senior
Chemist, Chemist, Laboratory
Tech, Senior Industrial Waste
Investigator, Industrial Waste
Investigator, Senior Mechanic,
Mechanic, Senior Operator,
WQC Plant Operators I/II,
Industrial Waste Inspectors,
Electricians, Supervisor, WQCP
Operations, Manager/Assistant
Manager, WQCP, and Manager,
TER+30
29 CFR
1910.1020;
Cal OSHA 8 Cal
Code Regs 3204
Access may digitally store after
2 years and shred
Restricted Access
*There may be other
employees in safety-sensitive
position in other locations with
same extended retention
schedule
5 PERSONNEL FILES (c) Hourly
Employees TER+5
29 CFR Section
1627.3
Labor Code Section
1174
Access may digitally store after
2 years and shred
Restricted access
6 RETIREMENT – Public Employee
Retirement System TER+4
29 USC Sections
1001 – 1381
29 CFR Section
1627.3
Restricted Access
7 CLASSIFICATION: Requests for
reclassification, PDQs, Job
Descriptions, Desk Audits
C+3 Labor Code Section
1197.5(e)
PDQ = Position Description
Questionnaire
BENEFITS
8 EMPLOYEE BENEFIT FILES -
DCAP), Deferred Comp, Dental,
EAP, Life, Medical, Vision/LTD
Claim Applications, Leave,
Domestic Partner
Reimbursement
C+4 29 CFR Section
1627.3
Restricted Access
DCAP = Dependent Care
Assistance Program
EAP = Employee Assistance
Program
LTD = Long Term Disability
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Human Resources
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
9 FPPC AGENCY FORMS
a) 804 New Positions -- Form
804
b) Consultants -- Form 805
C+4
C+4
FPPC 18734
FPPC 18734 Duplicate of City Clerk
RISK MANAGEMENT/WORKERS' COMP
10 WORKERS COMPENSATION
Claim Files PER
Labor Code Section
5410
8 CCR 3204(d)(1)
8 CCR 10102
GC 12946
Files are held at Administrator’s
Office, City only keeps working
file
Restricted Access
11 Authority for California Cities
Excess Liability (ACCEL) JPA
Agenda Files
C+3 Department Opinion
12 DMV Employer Pull Notice
Program Reports
C+4 (only
if
employee
has
violation
on record)
Department Opinion
Restricted Access
13 DRUG TESTING C+5
49 CFR Section 199
DOT 49 CFR Part 40
Subpart P Sect
40.333; 49 CFR
40.333 and Sect
40.25 Restricted Access
14 SAFETY REPORTS
a) Investigation Reports
b) Hearing Tests
PER
TER+5
C+4
8 CCR 3203(b)(1)-(2),
8 CCR 3203(c)(2),
Department Opinion
INSURANCE
(a) Insurance bond policies
(b) Insurance certificates
TER+10
PER
CCP 337.2; 343
GC 34090
INFECTIOUS DISEASE &
OCCUPATION EXPOSURE FILES PER
29CFR 1910.1030(h);
29 CFR 1910.1020;
8CCR3204(d)(1)(B)
OCCUPATIONAL MEDICAL TEST TER+5
FMLA 1993 US OSHA;
29 CFR
1910.1020; 29 CFR
1602.30-
1602.32; OSHA;
8CCR5100(d)(2)OSHA
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Human Resources
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
LE
AVE - DISABILITY TER+5
FMLA 1993 US OSHA;
29 CFR
1910.1020; 29 CFR
1602.30-
1602.32; OSHA
8CCR5100(d)(2)OSHA
Acci dent, Incident, and Injury
Reports PER 8 CCR 10102
G
C 12946
HUMAN RESOURCES DEVELOPMENT
16 TRAINING – Program Lists,
Instructor Lists, Class Rosters, &
Evaluations
C+2 49 CFR 199.17
49 CFR 199.227 Department Opinion
EMPLOYEE RELATIONS
17 NEGOTIATIONS – Notes,
Notebooks, Correspondence,
Contracts, & MOA
C+10 29 USC Sections 211
(c), 203 (m), 207 (g) Restricted Access
18 COMPENSATION – Mgmt.
Salary History Sheets, Job
Descriptions, Salary Surveys,
Compensation Plans
C+7 Department Opinion
19 GRIEVANCES – Arbitration,
Grievances Reports, SEIU
Window Period Requests,
Sexual Harassment &
Discrimination
C+7 29 CFR Section
1602.21 (h) Restricted Access
PERSONNEL MANAGEMENT
21 EMPLOYEE RIGHTS: Safety and
General Employees TER+5 GC 12946, 29 CFR
1602.12
23 CLASSIFICATION AND
COMPENSATION SURVEYS C+2
GC 12946, 34090; 29
CFR 516.6(2); 29 CFR
1602.14
25 LEAVE - MEDICAL TER+5
FMLA 1993 US OSHA;
29 CFR 1910.1020;
29 CFR 1602.30
27 SALARY INFORMATION - Salary
schedule, Salary resolutions PER GC 34090; GC 12946;
29 CFR 516.6(2)
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City of Palo Alto
Records Retention Schedule
Information Technology
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
001 Subject files, general
correspondence, C+2 GC 34090
SUBJECT FILES
002 Phone Log Files C+2 GC 34090 Call records
003 Service Desk Tickets C+2 GC 34090 IT Service Desk Tickets 004 Financial System Data
Backup C+7 GC
34090 SAP Database Backups
005
Contracts
a) Under $5000
b) $5000 and over
c) $85000 and over
TER+4
TER+4
TER+4
CCP 37.2
CCP 343
GC 34090
Duplicate of ASD
City Council approved contracts
duplicate of City Clerk
006 Hardware and software
inventories S+2 GC 34090
Running inventories of hardware
and software used to track
locations, to whom assigned,
and licensing information, as
needed
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Records Retention Schedule
Library
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
Department Administration
Work Schedules, Volunteer
Records, Budget Preparation,
Surveys, Statistics, Projects, Staff
Reports, Org Chart,
Memberships, Legal Opinion,
Staff Development and Training,
Community Relations, Benchmark
Data
C+2 GC 34090
Standards
Department Policies and
Procedures, Strategic Plan,
Safety/Security Manual, Disaster
Plan
S GC 34090
General Correspondence &
Reports
Correspondence, Memos, Emails,
Press Releases, Committee
Reports, Meeting Notes, Working
Files
C+2 GC 34090
Email messages related to
a current project or a
policy-making decision
should be retained along
with related records
Employee Files (Regular & Hourly)
PAFs, Appraisals, Work Injury, Job
Descriptions, Requests for
Reclassification, Recruitment --
applications, resumes
While useful Duplicate of HR
LEGISLATIVE HISTORY
Library Advisory Commission
a) Agenda
c) Minutes of Meetings
PER
PER
GC 34090
Library Advisory
Commission dissolved in
2020.
SUBJECT FILES
Library Databases
Customers, Circulation and
Inventory
Subscriptions and Licenses
S+2
GC 34090
Patron use and circulation
records are exempt from
Public Records Act under
certain conditions; GC
7927.105, GC7927.100
Grants & Donations
Applications
Awards
Non-monetary Donations
Reimbursements
C+5
GC 34090
24 CFR 200.334
24 CFR 570.502
29 CFR 97.42
Department Opinion
Capital Improvements
Project Files, Specifications,
Contracts, Agreements,
Equipment, Maintenance,
Licenses, Inventory
Life of
building
Duplicate of Public Works
City Council approved
contracts duplicate of City
Clerk
Item 2
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Library
Series Description Total
Retention
Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Publicity/Publications
Promotional Materials C+2 GC 34090
State Library
Public Library Survey
Reimbursements
C+2 GC 34090
Operational Reports
Daily Log, Cash Handling, Bank
Deposits, Debt Collection
Management
Incident Reports
C+2
C+5
GC 34090
Public Programming
Development and Administration
of Programs for the Public
(children, students, adults)
C+2 GC 34090
Collection Records
Records documenting the
selection and acquisition of new
materials for the Library's
collections and the physical
movement of materials between
the facilities and storage areas
C+2 GC 34090
Historical Reference
History of Palo Alto City Library PER GC 34090 Department Opinion
Item 2
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Office of Emergency Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
1 DEPARTMENT MANAGEMENT
General Order, Special Orders,
Bulletins, Policies and Procedures S GC 34090
Employment Memorandum of
Agreements
While
Useful GC 34090 Duplicate of Human Resources
2 DEPARTMENT PLANS PER Department Opinion
Strategic Plans/ Master Planning
Documents C+2 GC 34090
3 GENERAL CORRESPONDENCE &
REPORTS C+2 GC 34090
003c
Budgets, Purchase Orders Time
Keeping, Correspondence,
Surveys, Statistical Reports
C+5 GC 34090
004h Equipment Records TER+2 GC 34090
Retained until termination of
equipment's use; Manuals,
instructions, procedures, assignments,
maintenance
EMPLOYEE FILES
006(a) Training records, certificates C+2 GC 34090 Duplicate of HR (TER+3, 29 CFR 1627.3)
SPECIAL PROGRAMS
023(a)
Disaster Service Worker:
Emergency Services Volunteers
All associated documents
TER+30
CCR 19,
2573.2,
GC 3105,
6250
Required for injury claims
Item 2
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Records Retention
Schedule - Clean
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Pg.
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City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATION
001
OTHER DEPARTMENTS
Personnel Records, Purchase
Orders, Payment Claim
Vouchers, Legislation, Final
Budget, Correspondence with
Other Departments and
Records Requests
While
Useful GC 34090
Duplicate of Other Departments
002
DEPARTMENT
ADMINISTRATION
Department Procedures,
Equipment, Inventories,
Budget Preparation, and Final
Budget Correspondence,
General Correspondence
C+2 GC 34090
003
CONTRACTS
a) Contracts under 85,000 plus
all records associated
b) Full Cost Recovery Contracts
TER+4
TER+4
CCP 337
CCP 343
GC 34090
Department Opinion
004
ADMINISTRATIVE REFERENCE
Fee Schedules, Orgs, List,
Ordinance Binder, Planning
Ethics, Data Collection
S GC 34090 Department Opinion
LEGISLATIVE HISTORY
5 PLANNING COMMISSION,
ARCHITECTURAL REVIEW
BOARD, HISTORIC RESOURCES
BOARD AND DIRECTOR'S
HEARINGS
a) Minutes
b) Agendas and Packets
c) Correspondence with
Staff/Public - project based
d) Proof of Agenda Posting
PER
PE
R
C+2
C+2
GC 34090
Hard
copy format, Boards - Summary.
PTC – Verbatim
Agendas duplicates of City Clerk
SUBJECT FILES
6 COUNTY OF SANTA CLARA While
Useful GC 34090 Duplicate of Santa Clara County
7 BUILDING PLANS
a) Approved PER H&S 19850 Digital Format
b) Superseded C+2 H&S 19850 Hardcopies
Item 2
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
8 DISCRETIONARY PLANNING
ENTITLEMENTS
a) Applications
b) Maps - Zoning, Tentative
Subdivision, Preliminary Parcel,
Comp Plan Land Use, et al
c) Permit Extensions
(currently a 2-yr window with a
1-yr extension)
d) Record of Land Use Actions
e) CEQA determinations, EIR,
Negative Declarations
PER
PER
C+2
PER
PER
GC 34090
Department Opinion
Digital Format (stored offsite)
Digital Format
Saved Within Application files that
are scanned into GIS/DOXview
10 HISTORIC INVENTORY PER GC 34090 Digital Format--Currently updated via GIST
11 ZONING ORDINANCES PER GC 34090 Duplicate of City Clerk 12 COMPREHENSIVE PLAN AND
AMENDMENTS PER GC 34090
Duplicate stored offsite as vital copy
backup w/ Amendments
Resolutions Duplicate of City Clerk
13 COMMUNITY DEVELOPMENT
BLOCK GRANTS (CDBG)
a) Project Files TER+5
24 CFR Part
570
2 CFR
200.334
HCD CDBG Grants Management
Manual, Chapter 10
https://www.hcd.ca.gov/grants-and-
funding/programs-
active/community-development-
block-grant
b) Program Reference Forms,
Procedures and Brochures C+3
15 HOUSING
a) General Information and
References - Outside Materials
While
Useful Department Opinion
b) Housing Studies and
Programs C+3 GC 34090
c) HOME Funding-General (If
individual home loans keep
permanently)
TER+5
24 CFR Part
570
Federal regulation federally funded
programs and labor standard
compliance files
d) Below Market Rate (BMR)
Units, In Lieu Hosing Mitigation PER GC 34090 Department Opinion e) Below Market Rate
Administration C+2 GC 34090
DEVELOPMENT CENTER ADMINISTRATIVE RECORDS
1 OTHER DEPARTMENTS
Personnel Records, Safety
Files, Purchase Orders,
Payment Claim Vouchers, City
Manager’s Reports,
While Useful GC 34090 Duplicate of other Departments
Item 2
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Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
88 Packet Pg. 102 of 1138
City of Palo Alto
Records Retention Schedule
Planning and Development Services
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Legislation, Litigation, Final
Budget, Equipment and
Facility Maintenance, Time
Sheets, Correspondence with
Other Departments and
Retention Schedules
2 DEPARTMENT
ADMINISTRATION C+2 GC 34090
Daily Deposit Copies,
Department Procedures,
Equipment, Inventories,
Budget Preparation, and Final
Budget Correspondence
3 CONTRACTS
a) Contracts under $85,000
plus all records associated
b) Full Cost Recover Contracts
c) Contracts over $85,000 plus
all records associated
TER + 4
TER +4
TER +4
CCP 3
37 CCP 343
GC 34090
Duplicate of Administrative
Services
City Council approved contracts
duplicate of City Clerk
DEVELOPMENT CENTER SUBJECT FILES
4 PERMIT RECORDS
Address changes, Permit
applications, Building Use &
Occupancy applications and
certificates, Department
correspondence.
PER Electronically Stored in Geographic
Information System (GIS) or Accela
5 INSPECTION RECORDS
Survey letters, Special
inspection
– final inspection reports,
SB407 certificate of
compliance forms, Stop work
correspondence.
PER
6 Plans PER H&S 19850
7 CODE ENFORCEMENT
Complaints, inspections,
photographs, violations,
reports, notices, citations
TER+2
NOTE: Development Center Retention Schedule merged into Planning & Development Center Retention Schedule and transportation records merged into City Manager’s Office.
GC 34090
GC 34090
GC 34090
Item 2
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Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
89 Packet Pg. 103 of 1138
City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
3 (a) Personnel Training S GC 34090 Bulletins, training class certificates
3 (a)(1) Lesson Plans C+15 GC 34090 Scope, content, time period of courses
3 (b) P ersonnel TER+7 GC 34090
3 (b)(1) Ap plicant Fingerprint
Files TER+3 GC 34090
Includes paperwork
authorizing fingerprinting
and background checks for
City employment
applicants, all license and
permit applicants and
volunteer applicants.
3 (c) V olunteer Files TER+2 GC 34090 Volunteers’ identification, contact information
003b Policy, Forms, Brochures C+2 GC 34090
003c
Budgets, POs Time Keeping,
Correspondence, Surveys,
Statistical Reports, Contracts
TER+5 GC 34090
CCP 337
003e Alarm Records C +2 GC 34090
Alarm documents &
correspondence, alarm
permit
applications/permits, false
alarm notifications, false
alarm records
001q
Administrative/Internal Affairs
Investigations – Documents
relating to complaints or
investigations in response to
citizens’ complaints regarding
members of the Department.
a) Not sustained
b) Sustained
TER + 5
TER+15
PC 832.5(b),
EVC 1045,
PC 801.5,
PC 803(c),
VC 2547
GC 12946
Provided documents are
not evidence in any claim
filed or criminal
investigation, or part of any
pending records request or
litigation .
TER = conclusion of
investigation
001k News R elease C+2 GC 34090
Website 2 years; moved to
the Investigatory file if
applicable
001k Social Media Content C+2 GC 34090
001t Administrative Citations TER+2 GC 34090
Noise, Animal,
Parking/Traffic
TER = conclusion of
administrative review
hearing, if held.
001r PAPD Policy Manual S GC 34090 Living Document
ANIMAL SERVICES RECORDS
001p Nuisance Complaints, Animal
Bite Reports and Hearings, C+10 GC 34090 PAMC = Palo Alto Municipal Code
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
PAMC Violations and warnings
issued.
PAMC
6.28.030
FAC 32003(e),
31621 - 31626
10 Animal Licenses C+2 GC 34090 Dog – 3 years from
expiration
001n Animal Control Officer –
Activity records and logs C+2 GC 34090
COMMUNICATION RECORDS
1 (a) 91 1 Recordings
(b) Other Phone
Recordings, not on
911 lines
C+2 years and 1 day GC 34090.6
Exception: Recordings
flagged as evidence in a
criminal prosecution or
litigation hold request
received shall be preserved
for 100 days after
conclusion of the court
action, or as needed.
System programed to re-
write unless flagged
003f Mobile Audio Video Records
(MAV) C+2 GC 34090.6
PC 1054
Exception: Recordings
flagged as evidence in a
criminal prosecution or
litigation hold request
received shall be
preserved for 100 days
after conclusion of the
court action or as needed.
System programmed to re-
write unless flagged
DAR - Digital Audio Recordings
003g Interior Video Recordings
A
IB or ISD when initiated C2 GC 34090.6
PC 1054
Exception: Recordings
flagged as evidence in a
criminal prosecution or
litigation hold received
shall be preserved for 100
days after conclusion of the
court action, or as needed
003h Routine Perimeter Security
Video 100 Days GC 34090.6
INVESTIGATIVE RECORDS
001e Police Reports – ODI (Optical
Document Imaging) System
and supporting hard copy
Reports
C+100
GC 34090 Reports scanned into the
ODI system from 6-15-92 to
12-31-06. Unless report is a
Permanent Record or
ordered Sealed by Court
Order
PC 800
PC 801
PC 799
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Schedule - Clean
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Pg.
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City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
001e Traffic Collision Fatality Reports C +20 GC 34090 Regardless of the medium 001e
(1)Police Reports/PDF Scanned
– All Felonies, high
Misdemeanor cases.
C +100
PC 800
PC 801
PC 799
(Felony
Capital Crimes
punishable by
Death, Life
Imprisonment
)
PC 1054
Starting 2007 Hard Copies
will be kept in conjunction
with PDF
Prosecution for an offense
punishable by
imprisonment in state
prison for 8 years or more
must commence within 6
years after offense
commission.
Commencement of
prosecution defined in PC
804. *Exception: PC 803 –
Tolling/Extension of time
periods; Appeals process - -
.
001f
(1)Non Criminal Police
Reports/PDF Scanned –
Lost/Found Property, Injured
or sick persons; missing
persons where person has
returned; traffic collision
reports not used as the basis
for criminal charges etc.
C+10 GC 34090
Starting 2007 Reports will
be scanned to PDF.
Any CLETS entry must be
canceled prior to purge if
applicable.
12-1-2021 – all reports
scanned as PDF
001v
Arrest/Conviction HS Section
11 357 (b), (c), (d), (e) or H&S
Section 11360 (b) violations –
Occurring after January 1, 1996
Mandatory
destruction from
date of conviction or
date of arrest with
no conviction
HS 11361.5
Applicable to convictions
occurring after 1-1-1996 or
arrests not followed by a
conviction occurring after
1-1-1996; Exception: H&S
11357(e), the record shall
be retained until a juvenile
offender attains 18 years of
age – then destroyed
pursuant to 11361.5
001l FI Cards – Field interview Cards C+2 GC 34090 Includes photo if taken 001k (1) Daily Bulletins C+2 GC 34090
001e (2) Registrants – Sex, Arson,
Narcotics
TER or until S
DOJ
Guidelines
Fingerprint Card, Photo and
info forwarded to DOJ
001e
(3) Criminal Reports
(Misdemeanor low Felony) and
Domestic Violence Reports
C+15 FC 6228(d)
GC 34090
Remove property from
CLETS, no suspect or open
investigations pending.
MISC REPORTS AND DOCUMENTS
004a Court Board C+2 GC 34090 Court Notices
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Schedule - Clean
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Pg.
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City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
004b Court Liaison Tracking Systems C+ 5 GC 34090
Booking/Filing Lists and
Logs, Informal Discovery
requests and
Correspondence. Formal
Discovery scanned to
Investigatory File
004c Subpoenas (Duplicate) C +2 GC 34090
Subpoena Duces Tecum
(SDT) filed with case Report
once completed if
applicable
004d Statistical – C rime Analysis and
other reports C+2 GC 34090
Internally generated
information using activity
logs, citizen requests, .
Reports created for a
variety of purposes. Some
original reports sent to DOJ
& FBI
004f Sealed – Adult /Factual
Innocent
Mandatory
Destruction upon
and pursuant to
Court Order
PC 851.8
Unless sealed pursuant to
PC 851.91 and PC 851.92.
Does not include letter of
finding sent to the
defendant for
grants/denials
001j Restraining Orders C or until S
Destroy after law
enforcement actions
described in PC 273.5,
273.6, 646.9, 12028.5,
13700 and Family Code
Sections 6380-6383 are
fulfilled and effective date
of Restraining Order has
expired
001g Traffic Citations (copies) C+2 GC 34090
Original hard copy is
forwarded to court, citation
records are sent
electronically to the court.
Agency copy kept for
processing. Parking
Citations forwarded to
Revenue Collections
004h
Equipment Records – includes ,
PAS Records and Radar
Calibration Logs, Weapons
Records, ALPR Stats; Flock and
Star Chaser Forms
TER+2 GC 34090 f
004i License/Permits C+2 GC 34090
Parade, Noise Exemption,
Special Events, Block Party,
Taxi, Masseuse. No longer
interested forms to be sent
Item 2
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Records Retention
Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Police Department
Series Description Total Retention Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
to DOJ for applicant
expired applicant
information.
004j Warrants: Warrants attaining purge
date are sent to Santa Clara
Co DA’s office for review of
extension of warrant/
Active case or purge. All
CLETS/AWS systems must
be updated or cancelled.
(1) Felony Felony – C+ 10 GC 34090
(2) M isdemeanor Misdemeanor – C+7 PC 799
(3) I nfraction Infraction – C+7 PC 800/801
004l Records requests,
correspondence C+2 GC 34090
T
he destruction of felony, misdemeanor, and infraction Crime/Supplemental Reports is permitted providing:
(1) They do not relate to an unadjudicated arrest except for HS 11357 or HS 11360 violations; (2) They do not relate to unserved warrants;
(3) They do not involve identifiable items which have not been recovered; (4) The do not relate to PC 290, PC 457.1, or HS 11590 Registrants; (5) They do not relate to violations listed in PC Sections 799 and PC 800; (6) The cases are not presently involved in either a civil or criminal litigation.
Item 2
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Records Retention
Schedule - Clean
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Pg.
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City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATION
1 PERSONNEL
Confidential Documents
While
useful D uplicate of Human Resources
1 Contracts/purchase orders
awarded by PW Department,
except construction/capital
improvement
TER+4 CCP 337
CCP 343
AIRPORT
AGREEMENTS/CONTRACTS While
useful
TER+4
CCP 337
CCP 343
1 BUDGET
Budget Change Requests PER Duplicate of Office of Management & Budget
2 CAPITAL IMPROVEMENTS
a) Project Files, Work Orders,
Schedules, Bidders List,
Correspondence, Change Order
b) Spe
cifications, Reports Plans,
Contracts and Subdivisions
PER
H&S
19850
GC 4003
Life of Structure
2 GENERAL
Correspondence
Membership Information
Notice to Airmen (NOTAM)
C+2 GC 34090
GRANTS
Applications
Awards
PER 2 CFR
200.334 Department Opinion
OPERATIONAL REPORTS
Daily, Weekly, Monthly,
Quarterly, and Annually
C+4 GC 34090 Federal Aviation Administration
(FAA)
PERMITS PER
STAFF
Evaluations
Personnel Action Forms
S+5
Labor
Code
Section
5410
Duplicate of HR
TENANT FILES
Applications
Payments/Receipts Log
Leases
PER
ENGINEERING SERVICES
005
013
ASSESSMENT DISTRICT
Boundaries & Rolls PER GC 34090
006
020
BENCHMARK DATA
Horizontal, Vertical & Control PER GC 34090 Department Opinion - Need this data for historical reference material
007
011
CAPITAL IMPROVEMENTS
a) Project Files, Work O rders,
Schedules, Bidders List,
Correspondence,
Change Order
PER
H&S
19850
GC 4003
Life of Structure
Item 2
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Schedule - Clean
Item 2: Staff Report
Pg.
95 Packet Pg. 109 of 1138
City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
b) Specifications, Reports Plans,
Contracts and Subdivisions
c) Street Reports
8 CERTIFICATES OF COMPLIANCE PER GC 34090 Duplicate of City Clerk 9 CERTIFICATES OF INSURANCE S GC 34090
10 ENCROACHMENT PERMITS
a) Permanent Encroachments
b)
Temporary Encroachments
PER
C+2
GC 34090
11 FLOOD ZONE
Elevation Certificates & Letter
of Map Amendments
PER GC 34090
12 MAPS – Annexations, Park
Dedication, Tract, & Block S GC 34090 Keep current map version only 13 PERSONNEL
Evaluations
Personnel Action Forms
S D uplicate of HR
14 PRIVATE DEVELOPMENT
REVIEWS C+2 GC 34090
15 SOIL REPORTS PER Department Opinion - Need this
data for historical reference material
16 STREET WORK PERMITS PER GC 34090
17 SUBDIVISIONS
a) Agreements
b) Parcels and Subdivision Maps
PER
S+2
GC 34090 Keep current map version only
18 SURVEYS – Recording Data and
Maps PER GC 34090 Department Opinion - Need this
data for historical reference material
ENVIRONMENTAL SERVICES
19 ENVIRONMENTAL FILES PER Department Opinion
20 Discharger permits and permit
support documents
Permit
expiration
or facility
closure + 3
years
40 CFR Federal Pretreatment Regulations
Other Discharger data and
records C+12 40 CFR
141.91 Federal Pretreatment Regulations
WATER QUALITY CONTROL PLANT
35 FLOW
Discharge Data and Reports PER 40 CFR
122.41 Department Opinion
36 MAINTENANCE
Flow Strip charts, Instrument
Calibrations, Operations,
Maintenance & Laboratory
Records, & Crane Maintenance
and Certification, State
Certification
C+4 De partment Opinion
37 NPDES (National Pollution
Discharge Elimination System) –
Permits and Reports
PER 40 CFR
122.28 Department Opinion
Item 2
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
38 PERMITS
Pressurized Vessels, Air &
Industrial Waste
TER+4 GC 34090
39 SAFETY
Meetings and Training C+4 GC 34090
40 SEPTIC & RECLAIMED WATER
Permits, Fees, Billings C+4 GC 34090 Department Opinion 41 PERSONNEL
Accident report, accident
investigation, or other
personnel event resulting in
change of policy
TER+30 Department Opinion
Duplicate of HR
ZERO WASTE
Landfill Daily Log Operator
Assignments and Maintenance
Activities
C+5 GC 34090
Landfill Reports & Records PER GC 34090
Landfill tollbooth receipts C+5
Household Hazardous Waste
Manifest & Reports PER
SMaRT Station & Kirby contract
data C+10 Department Opinion
Waste Contractor data --
GreenWaste of Palo Alto C+10 Department Opinion
Recycling Programs S+2 GC 34090
SUSTAINABILITY
Climate Action Plan Reporting C+25 GC 34090 Department Opinion Sustainability Project
Documentation C+10 GC 34090 Department Opinion
Greenhouse Gas Inventory Data PER GC 34090 Department Opinion
EQUIPMENT MANAGEMENT
21 Transactions – Parts, Fuel, and
Gas Tags C+2 GC 34090
22 Vehicles – Registrations & DMV
Correspondence
Life of
Vehicle D MV Requirement
FACILITIES MANAGEMENT
23 BUILDING MAINTENANCE
Contracts
City Manager Reports
Specifications
Bidders List
Change Orders
Payment Files
TER+4
C
+2
GC 34090
CCP 337
CCP 343
24 CAPITAL IMPROVEMENTS
a) Project Files, Work Orders,
Schedules, Bidders List,
Correspondence, Change Order
PER
H&S
19850
GC 4003
CCP
337.15
Department Opinion
Item 2
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Records Retention
Schedule - Clean
Item 2: Staff Report
Pg.
97 Packet Pg. 111 of 1138
City of Palo Alto
Records Retention Schedule
Public Works
Series Description Total
Retention
Statutory
Reference
Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
b) Specifications, Reports Plans,
Contracts and Subdivisions
25 GENERAL - Correspondence
Forms C+2 GC 34090
26 PERSONNEL
Division Staff Schedules
Personnel Action Forms
Injury/Accident Reports
TER
Labor
Code
Section
5410
Originals to HR, copy kept in
individual’s file until employee
termination
27 REPORTS
Quarterly Summary of
maintenance labor and material
costs for Parking Lots
C+2 GC 34090
28 SUBJECT FILES C+2 GC 34090
29 WORK REQUESTS
Labor and Material Tracking
Key Requests
Service Calls
C+2 GC 34090
STREETS/SIDEWALKS/STORM DRAIN
30 26
32 25
DAILY REPORTS
Operator assignments &
equipment status
Storm Drain
Work Orders
C+5 GC 34090
33 Tree line clearing, landscaping
plans, pesticide spraying,
inventory & irrigation plans
C+2 GC 34090
34 WORK ORDERS
Streets, sidewalk, signs,
sweeping, trees
C+5 GC 34090
35 Urban Forestry C+2 GC 34090
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Schedule - Clean
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City of Palo Alto
Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
ADMINISTRATIVE RECORDS
001
Management books, CIP Budget,
Working Files, Operating &
Safety, Staff Meetings,
Correspondence, Budget Change
Requests, Journal Entries
Shipping Receipts, Depreciation,
Proof of Publication
C+2 GC 34090
Master Plans PER Department Opinion
WGW Ops Dailies
WGW Ops Stand-by/Call Out
Time Report
Shipping records Internal vs.
Outside Vendor
C+2
C+2
C+2
Department Opinion
SUBJECT FILES
002
Policies, Procedures, Processes,
Marking Requirements,
Engineering Standards, Electric
Service Requirements, Cable
Specs, Forms, Best Management
Practices
S+2 GC34090 Department Opinion
003 Drivers License Records While
Useful Duplicate of DMV
CONTRACTS
005 Construction &
Services/Products over $25,000
While
Useful CCP 337 Council approved contracts
duplicate of City Clerk
005 Services/Products under $25,000 TER+5 CCP 337 City Attorney Opinion Construction PER CCP 337.15 Council approved contracts
duplicate of City Clerk
005 Unaccepted Bids C+2 GC 34090
Electric and Gas Meter S+7
Purchase and Sales Agreements -
EEI & NAESB S+7 Department Opinion for
retention in Dept. files
Renewable Energy Certificate
Master Agreement S+7
Dept. Opinion for retention in
Dept. files
Master Agreement -- Transaction
and/or Confirmation Agreements
-- including supporting
documentation (deal sheet,
shopping sheet, authorization
etc.)
TER+7 CCP 337 Retained in Utilities Dept.
Bilateral Commodity and/or
related service agreements TER+7
If within City Manager
authority, then retained in
Utilities Dept. If Council
approved, retained in City
Clerk's Office
PROJECT FILES
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Schedule - Clean
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Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
006 Internal working files PER Department opinion
RATES
007 Rates – All Services PER Department opinion
REPORTS
009
Statistical, sales, annual
consumption analysis and
various spreadsheets
C+2 GC 34090
UTILITY ADVISORY COMMISSION
010
Agenda
Proof of Posting
Minutes of all meetings
General Correspondence
Proof of Agenda Posting
PER
C+2
C+2
Agendas Duplicate of City Clerk
TASK FORCE
011 City of Palo Alto and SCVWD
Meetings C+2 GC 34090
011 Any task force – internal and/or
external C+2 GC 34090
REGULATIONS
013
National Gas Act
Pipeline Safety Act
Natural Gas Policy Act
CVPIA
While
Useful
C+2
C+2
C+2
Duplicate of Other Agency
CVPIA = Central Valley Project
Improvement Act
013 Correspondence w/ Agency C+2 GC 34090
STUDIES - SURVEYS
014
Gas System Study
Distribution
Electro Magnetic Field Survey
and Energy Case Studies
Commodity Resource
C+2
C+2
C+2
GC 34090
CUSTOMER SERVICES
015 Customer Correspondence
Letters, faxes, emails C+2 Department Opinion
015
Service:
GC 34090 All listed will be scanned and
retained electronically
• Residential Service
Agreement C+3
• Residential Service
Application C+3
• Commercial Service
Agreement PER
• Commercial Service
Application PER
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Schedule - Clean
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Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
• Utilities Account Change C+3
• Make Change to Account C+3
• Account Closure Request C+3
• Close Utilities Account C+3
• Revert to Owner Request PER
• Revert to Owner Application PER
015
Demolition Request
Demolition Application
Temporary Power
Temporary Power Application
Hydrant Water Application
Hydrant Meter Application
C+3
C+3
C+2
C+2
C+2
C+2
Department Opinion
Department Opinion
015
Billing
• Consumption Adjustment
• Correct Misread and Billings
• Miscellaneous Adjustment
• Apply Credit or Debit
• Invoice Cancellation
• Cancel Rebill Invoice
• PV Statements
• Monthly PV Status
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
All are created and saved on
electronic templates
015
Credit & Collections
• Rate Assistance
• Annual Application Renewal
• Project Pledge
• One time Submission
• Bankruptcy
• LIHeap
• LIHeap send discs
C+2
C+2
PER
PER
C+3
C+2
C+2
Department Opinion
LIHeap = Low Income Home
Energy Assistance Program
015
Meter Reading
C+2
Department Opinion
• Customer Read Cards
• Reads Submitted by
Customers
• Customer Read Emails
• Electronic Read Submitted
by Customers
• On/and Off Orders
• Electronic in SAP
CONSTRUCTION
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Schedule - Clean
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Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
016
Acquisitions, Easement, Design,
Drawings, Specifications, Photos,
Permits, Soil Reports,
Correspondence, Quotes,
Payments & Schedules
PER GC 34090 Historical
CPAU Work Orders
As-Built Maps
Valve Cards
PER California Department of
Transportation
CPAU Work Orders of
Abandoned Pipe
As-Built Maps of Abandoned
Pipe
Valve Cards of Abandoned Valves
PER Department Opinion
ICOMMM Lateral Work Orders
ACP Forms
C+5
C+5 Department Opinion
REGULATORY AGENCIES
017 Reports to
• Federal Register
C+2 GC 34090
• U.S. Dept of Energy
• PG&E
• State Regulatory Agencies
(e.g. Public Utilities
Commission)
• California Energy
Commission
• California Air Resource
Board
REGULATORY RECORDS
Sanitary Sewer Overflow (SSO)
Reports
Sanitary Surveys
C+5
C+10
40 CFR 141.33
RWQCB
Statistics, reports,
correspondence
Water Discharge Form
Water Discharge Monitoring
C+5
C+5
40 CFR 122.41
Annual Report for Public Works
Storm Water Department
Water Connection Records,
Device Locations, and Water
Maps
PER GC 34090
Reports:
Compliance documentation
Average amount of pollution
discharged into waters
Compliance documentation
• Corrosion Control C+12 40 CFR 141.91
• Discharge Monitoring C+5 40 CR 141.91
• Drinking Water Corrections C+10 40 CFR 141.33
• Lead Service Line C+12 40 CFR 141.91
Water/Sewer Infrastructure Data
in GIS SUP GC 34090
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Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Underground Utility Locating C+6
CAGC Title 1 Division 5
Chapter 3.1 Article 2
Section 4216
Exception Collection Reviews,
Waste Logs C+2 GC 34090
Paradigm Data Sheets
Cathodic Work Orders
Cathodic Protection with Gas
Distribution Map
Exposed Pipe Reports
Steel Pipeline Tapping Coupon
Records
Annual Report to DOT
Emergency Response Plan
Operations and Maintenance
Manual
PER
PER
PER
PER
TER+5
C+5
C+5
C+5
California Department of
Transportation
EMPLOYEE TEST RECORDS
Gas Operator Qualification C+5 California Department of Transportation
Employee Water Distribution
Certification
Employee Water Treatment
Certification
Employee Backflow Certification
Employee Cross Connection
Certification
C+3
C+3
C+3
C+3
State
Welding Record (form 225A) PER California Department of Transportation
TESTS/INSPECTIONS/SURVEYS
Backflow Annual Certifications C+3 State
FSR Gas Leak Investigations
(818 Form)
FSR Stop Card Database
Gas Shop Stop Card
Water Shop Stop Card
C+7
PER
PER
PER
California Department of
Transportation
Gas Receiving Stations
Odorant and Oil Drip
Water Meter Test Results
Gas Meter Test Results
Meter Leak Tags
Abnormal Operating Conditions
(AOC)
PER
PER
PER
PER
PER
PER
California Department of
Transportation
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Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Water Quality-Water Sources:
• Testing
• Fluoride Summary
• Ground Water Elevation
• Bacteriologic Analysis
• Chemical Analysis
• Reservoirs, Wells & Rainfall
Gauge
Water Maintenance Records
C+10
C+5
Title 22 CCR
66261.24(a)(7)
40 CFR 141.33
State
CPAU Gas Pipeline Patrol
Program
CPAU WGW Operations Pre-
Tested Pipe Tag (Form 503)
CPAU WGW Operations Grade 1
Log Re-Checks
Gas Leakage Survey
C+5
PER
C+5
C+5
California Department of
Transportation
019 Equipment Records Life of
Equip + 2 GC 34090
019
General Information
Regulating
Specifications & Testing
Gas Leakage Survey
Meter Leak Tag
AOC
CPAU/WGW Operations Pre-
Tested Pipe Tag
Gas/Water Shop Stop Card
Odorant & Oil Dip
Valve Cards
Valve Cards of Abandoned Valve
Welding Record
Gas Receiving Station
PER
Form 503
Form 225A
ELECTRIC UTILITY
052
048
Electric--Circuit Map, Electric
Distribution, Street Light Block,
EV Charger Maps
C+2
GC 34090 Duplicate stored offsite as vital
copy backup
Maps: Electric Distribution, Pole
Test Block, Distribution Block,
Street Light Block, Hardware and
Coax
Current
while
active,+ 2
years off
site
053
049
Underground District:
Transmission Line Logs &
Correspondence
C+2 GC 34090
054
050 Work Orders: PER Department Opinion
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Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Pacific Bell, Cable Co-op, PG&E,
and Intents
055
051
Acquisitions, Design, Drawings,
Specs, Permits, Correspondence
quotes, Payments & Schedules
CIP/Construction
PER Department Opinion -
Historical
056 Electric Vehicles:
Power Delivery Records
Life of
Vehicle +2
off site
GC34090
057
Street Lights:
Lighting, Program Materials C+2 GC 34090
058 Joint Pole Applications TER+5 Department Opinion
Customer Services Projects
Applications, Plans, Invoices C+2
ELECTRIC OPERATIONS
059
Compliance/Inspections/Locating
• Field Switch/Man on Line
Logs
• Overhead/Underground
Compliance Records
• Underground Service Alert
Notices
a. Completed Tickets
b. Original Email Notices
PER
PER
C+6
C+2
C+1 on site
C+1 on site
Onsite
060 Customer Service – UCC
Dispatch Logs PER Electronic copy on S drive
061
Street Lights/Traffic Signal/Fiber
Notifications – SL & TS
Maintenance – WO - TS
C+6
Work transaction recorded in
SAP. Mark-up records
maintained on site
062
055
Substations
a) Equipment (transformers,
switches, breakers, capacitors,
relays)
• Specifications
• Inspection
• Inventory
• Replacement
• Disposal
Life of
Equip +2
Department Opinion
Duplicate stored offsite as vital
copy backup
062
055
Substations
b) Operations (troubleshooting,
line logs, load reports, power
factor, fences, cost data)
C+6
18 CFR Sections
125.3(23) & 125.3(26)
Inspection records and
equipment test records stored
electronically on F:drive
C+3 on site + 3 years off-site
064
055
Substations
c) Relay and fuse curves, fault
current, calculations, supervisory
control, automation and
C+2 GC 34090
Duplicate stored offsite as vital
backup copy
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Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
distribution automation (SCADA)
and Control Information
MARKETING SERVICES
Program Development PER Department Opinion
061
064
Customer Applications
Smart Energy Program
CAP
PV Partners Program
Solar Water Heating Program
Solar Water Heating Loan
Program 1970-1990
Palo Alto Green Program
Palo Alto Green Gas/New PA
Green
Fiber Program
Customer Applications
Rebate Application & agreement
Rebate Applications
Old Program -- files at The State
Signed Agreements
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
C+2
GC 34090
Department Opinion
Department Opinion
Department Opinion
Department Opinion
Council approved contracts
duplicate of City Clerk
062
066
Vendor contract invoices
3rd Pary Programs
Monthly/quarterly/annual
electronic records
TER+4 CCP 337 Department Opinion
063
066
Key Account Engineering Audit
Reports
BI Reports
Pcard receipts
C+2
C+2
C+2
GC 34090 Department Opinion
067
Public Outreach
Program marketing materials
Customer Workshops & Facility
Manager Meetings
C+6
C+2
Department Opinion
SUPPLY RESOURCE GROUP
070
Settlement Date
Commodity Invoices/payment
records
TER+2
PER
Department Opinion
Keep for two years past
contractual limitation of
invoice dispute
071
Regulatory Reference Materials
(e.g. – laws, ruling, orders, court
cases, settlements)
While
Useful Duplicate of Other Agency
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Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Risk Management
FO and BO Transaction oversight
Monthly BO reports
FO and BO Quarterly reports
FO Weekly Reports
C+6 Department Opinion
078
Rates Documents
Rates/Pricing
Cost of Service Studies
S+7
080
Resource Plans
Long-term Electric Acquisition
Plan, Gas Long-Term Plan, Water
Integrated Resources Plan
S+2
Department Opinion
Adopted plans duplicate of City
Manager
Electric Portfolio Models
Commodity Costs Protections &
Uncertainty Assessment
- load and resource balance
- supply costs
- transmission cost
- interconnection
- agency costs
- hydrology
- plant operation and
maintenance
- regulatory costs
C+7 for
annual
budget
models
Maintained in electronic
models
- overwritten as necessary
Electric Procurement Plan
Procurement Plans -- Needs
Analysis Load/Resource
Balance Targets
Authorizations
C+5 Department opinion
Voluntary Certification and
Verification
C+7
Department Opinion
§ Reports to certifying and
verifying agencies such as The
Climate Registry for GHG
Inventory and for Carbon Neutral
Plan (Electric Power Sector)
§ Reports from certifying and
verification agencies such as
audit reports
§ Risk Oversight Committee
§ New Models
§ Standards of Conduct
R&D Program
PET Projects related
documentation
C+6 Department Opinion
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Schedule - Clean
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Records Retention Schedule
Utilities
Series Description Total
Retention Statutory Reference Remarks
C = Current Year
PER = Permanent
TER = Termination
S = Supersede
Policies
Analysis of plans, programs, and
policies that become adopted by
Council
S+2 Department Opinion
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City Council
Staff Report
From: City Auditor
Report Type: CONSENT CALENDAR
Lead Department: City Auditor
Meeting Date: June 16, 2025
Report #:2506-4782
TITLE
Approval of Office of the City Auditor Emergency Preparedness: Wildfire Audit Report as Recommended by the Policy & Services Committee
RECOMMENDATION
Policy and Services Committee and the City Auditor recommend City Council approve the BakerTilly Emergency Preparedness: Wildfire Audit Report.
EXECUTIVE SUMMARY
Palo Alto, like many communities in California, faces increasing wildfire risks due to climate change, prolonged drought, and human activity in the wildland-urban interface (WUI), and this report is one item in a series of a series of public engagement and public meetings to raise awareness of local wildfire risks and the importance of wildfire preparedness. The Policy & Services Committee reviewed the attached report and discussed recent wildfire preparedness activities underway and new items such as the newly released wildfire maps released by the California Fire Marshal and transmits an audit on wildfire preparedness completed by BakerTilly, the City’s Auditor. The Committee on April 8, 2025 unanimously recommended Council approval of the audit. The audit conducted by BakerTilly reviewed the current wildfire protection plans implemented by the City and evaluated their effectiveness in mitigating wildfire risks and ensuring adequate emergency response. The audit identified areas for improvement in evacuation planning and enhancing community engagement.
BACKGROUND
Baker Tilly, in its capacity serving as the Office of the City Auditor (OCA), performed a citywide risk assessment that assessed a wide range of risk areas, including strategic, financial, operational, compliance, technological, and reputation risks. The purpose of the assessment was to identify and prioritize risks to develop the annual audit plan. Recognizing the need for an independent assessment of the City's wildfire preparedness, BakerTilly conducted an audit in alignment with its 2024 Risk Assessment and subsequent Council approved workplan.
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After the January 2025 southern California wildfires, the Policy & Services Committee agenda item was expanded to discuss two parts, 1) Wildfire Preparedness Activities and 2) Summary and Response to the Emergency Preparedness – Wildfire Audit (conducted in 2024, prior to the recent events). Recognizing the importance of communications, education, and preparation, in collaboration with the City Auditor, this expansion was in alignment with the launch of a series of items to raise awareness of local wildfire risks and the importance of wildfire preparedness.
ANALYSIS
The objective of the Emergency Preparedness – Wildfire Audit aimed to determine whether the City is adequately prepared to prevent and respond to wildfires as part of its overall emergency management plan. The attached BakerTilly Audit Report (Attachment A) provides a detailed analysis of the City's current practices and recommendations for improvement. The OCA interviewed staff, reviewed policies and procedures as well as FEMA and CAL FIRE standards and best practices to complete this audit work.
The BakerTilly Audit Report highlights two findings:
1. While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
2. Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning, training, after action report recommendation implementation, and communication efforts.
The attached report summarizes the analysis, audit findings, and recommendations. The audit identified areas for further improvement in evacuation planning and enhancing community engagement regarding these activities. Management has provided responses in the Appendix.
FISCAL/RESOURCE IMPACT
The timeline and resource needs for implementation of management’s corrective action plans are identified by management within the attached responses. Implementing activities such as hardening systems and undergrounding the electricity transmission line in the foothills are within existing capital improvement plans and funding. Acquisition of new equipment and technology is reviewed and evaluated as it arises in the context of the various plans, most currently as part of the Foothills Fire Management Plan/Community Wildfire Protection Plan (FFMP/CWPP) a multi-year plan transmitted to the City Council in parallel with this Audit on June 16, 2025. As noted in the information report, the City will also explore potential funding sources, such as grants from federal and state agencies, to offset the costs of implementing wildfire preparedness plans.
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STAKEHOLDER ENGAGEMENT
The Office of the City Auditor worked with and would like to thank several departments for their assistance in conducting this audit including: City Manager’s Office, Public Works, Fire Department, Office of Emergency Services, and Palo Alto Utilities.
ENVIRONMENTAL REVIEW
The Office of the City Auditor worked with and would like to thank several departments for their assistance in conducting this audit including: City Manager’s Office, Public Works, Fire Department, Office of Emergency Services, and Palo Alto Utilities.
ATTACHMENTS
Attachment A: Emergency Preparedness - Wildfire Audit Report Attachment B: Policy & Services April 8, 2025 Staff Report APPROVED BY:
Kate Murdock, City Auditor
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1 March 31, 2025
City of Palo Alto
Office of City Auditor
Emergency Preparedness - Wildfire Audit
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Emergency
Preparedness - Wildfire
Audit Report
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Contents
Baker Tilly Advisory Group, LP and Baker Tilly US, LLP, trading as Baker Tilly, operate under an alternative practice structure and are members of the global network of Baker Tilly International Ltd., the members of which are separate and independent legal entities. Baker Tilly US, LLP is a licensed CPA firm that provides assurance services to its clients. Baker Tilly Advisory Group, LP and its subsidiary entities provide tax and consul ting services to their clients and are not licensed CPA firms.
EXECUTIVE SUMMARY ................................................................................................. 1 INTRODUCTION ............................................................................................................. 4 DETAILED ANALYSIS ................................................................................................... 7 AUDIT RESULTS ............................................................................................................ 9 APPENDIX A MANAGEMENT RESPONSE MATRIX ......………………………………..25
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Audit Report
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1 Executive Summary
Purpose of the Audit
Baker Tilly Advisory Group, LP (Baker Tilly), in its capacity serving as the Office of the City Auditor (OCA) for the City of Palo Alto (the City), conducted an Emergency Preparedness – Wildfire Audit based on the approved Task Order 4.25. The objective of this audit was to determine whether the City is working to prevent wildfire and adequately prepared to respond to wildfire as part of the City’s emergency management plan.
Report Highlights
Finding 1:
(Page 13)
While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
• The City of Palo Alto Utilities Department (CPAU) has made significant investments to reduce wildfire risk
o Undergrounding distribution lines – the City is in the process of undergrounding its main distribution line in the Foothills high-risk area to reduce the potential for wildfire caused by damaged or downed lines. o Installing weather stations – to collect localized weather data to share with first responders.
o Public Power Shutoff Procedure – provides guidance for when to de- energize lines when needed to reduce wildfire risk and communicating information to the public.
o Formalizing Utility Infrastructure Maintenance Program – CPAU is in the process of formalizing its utility infrastructure maintenance program which will help guide and prioritize the utilities maintenance efforts o Use of FLIR cameras – to detect electrical hotspots and areas that may require maintenance
• The City has several programs to address vegetation management and improved tracking efforts may increase compliance
o Line Clearance Program – this program is managed by the Urban Forestry division of the Public Works Department in collaboration with CPAU and ensures vegetation is cleared from electrical equipment and utility lines. OCA noted areas to improve documentation of work scheduled and performed and overall program guidance
o Property inspections in the Wildland Urban Interface (WUI) help ensure properties in high-fire danger areas are cleared of vegetation that could potentially fuel a wildfire. OCA noted areas for improved tracking and follow-up for properties that are in violation of the City’s code. • While the City has partnered with CAL FIRE and is included in Santa Clara County’s Community Wildfire Protection Plan, community involvement could be enhanced with the establishment of Palo Alto as a Firewise Community, a Item 3
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Emergency
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Audit Report
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2 EXECUTIVE SUMMARY
program that offers a structured approach for communities to enhance their wildfire resilience and promotes collaboration between residents, fire departments and other stakeholders.
• Community education and outreach could be enhanced by policies and procedures to guide efforts and track and measure their effectiveness.
Key Recommendations
We recommend the City consider the following improvements to enhance its wildfire prevention efforts:
1. Continue efforts to underground Wildland Urban Interface (WUI) distribution infrastructure and prioritize, as appropriate, maintenance and possible replacement of the oldest utility poles should they remain in place.
2. Line Clearance policy documents should be established and or reviewed, updated and finalized (e.g. Draft Tree and Landscape Technical Manual
3. Continue efforts to better track and monitor property violations in the WUI to enhance enforcement.
4. Prioritize efforts to establish a Firewise Community including stakeholder engagement throughout the process
5. Formalize the contract with CAL FIRE to ensure service provision continues into the future.
6. Ensure wildfire education and outreach plans document coordination efforts between the Office of Emergency Services (OES), Fire and CPAU to ensure information is consistently and regularly provided to residents.
Finding 2:
(Page 15)
Overall, the City has a strong emergency response plan but should consider if improvements can be made to evacuation planning, after action report recommendation implementation, and communication efforts. • The City has a comprehensive set of emergency response and wildfire plans, but should consider if evacuation plans could be enhanced and some plans may require updating and review.
o Overall, OCA found that the City’s plans align with the majority of Federal Emergency Management Agency (FEMA) guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process to ensure that plans are regularly reviewed and updated. In addition, while the Foothills Fire Management Plan (FFMP) addresses evacuation routes and ensuring these routes remain clear for emergency personnel as well as residents for evacuation, we recommend the City consider additional planning activities based on the U.S. Department of Homeland Security’s, Planning Considerations: Evacuation and Shelter-in-Place; Guidance for State, Local, Tribal, and Territorial Partners, July 2019.
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Emergency
Preparedness - Wildfire
Audit Report
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3 EXECUTIVE SUMMARY
• The City monitors training requirements and compliance and recently implemented a new sign-in process to improve tracking.
• While the City conducts training and after-action reports (AAR) after critical incidents, efforts to track and implement resulting recommendations could be improved.
• The City is enhancing its wildfire detection capabilities through the use of gas monitoring sensors deployed in the Foothills area.
• The City employs several methods for communicating critical information to its residents during an emergency and should continue to explore methods to increase participation in the County’s emergency alerting system. o Based on the alert system sign-up data provided and Santa Clara County, 17% of Palo Alto residents were registered in the system in 2025.
• While the City has strong relationships with their mutual aid agreement partners1, the City does not maintain these agreements in a central repository for easy tracking and monitoring.
Key Recommendations
We recommend the City consider the following improvements to enhance its Wildfire response efforts:
1. The City’s emergency plans align with the majority of FEMA guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process. The City should also review its evacuation plans and consider if plans could be enhanced by reviewing best practices in other cities such as establishing evacuation locations and sheltering agreements with neighboring communities.
2. City management should more formally track and monitor findings and recommendations identified during training exercises and in AARs of emergency incidents to ensure needed improvements are made and issues are timely resolved.
3. Continue to explore ways to increase resident registration in the County’s emergency alerting system. Opportunities may include partnering with schools, homeowner associations, and local businesses to disseminate wildfire education materials and encourage participation in City programs and the County’s emergency alert system.
4. Determine an appropriate solution for staff to more easily access, track and monitor the status of all mutual aid agreements, including active dates, renewal deadlines, and responsible contacts for updates. For example, a centralized tracking system for mutual aid agreements would provide clarity on the status of each agreement, preventing lapses in mutual aid coverage and ensuring that expired agreements are addressed promptly.
1 Mutual aid partners include Los Altos Hills, Santa Clara County, Woodside, Mountain View, and the California Department of Forestry and Fire protection.
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4 Introduction
Objective The objective of this audit was to determine whether the City is working to prevent wildfire and adequately prepared to respond to wildfire as part of the City’s emergency management plan.
Background The rise in wildfires in California is fueled by a complex interplay of climate change, historical land management practices, human activities, and ecological shifts, all of which impact cities like Palo Alto that are situated near high-risk wildland-urban interface (WUI) zones. Climate change has intensified the state’s wildfire risk by driving higher temperatures, wind speeds, and drier conditions, which extend the fire season and increase the probability of fires. Historical land management practices, including the suppression of indigenous fire management techniques and aggressive fire suppression policies in the 20th century, have led to an accumulation of vegetative fuels. Additionally, logging practices have left denser forests prone to more intense fires. Human activities— ranging from infrastructure failures to recreational fires—are the primary sources of ignition, particularly as urban areas expand into WUI zones, increasing both the human and economic impact of fires.
In response to wildfire risks, the City of Palo Alto’s Office of Emergency Services (OES), Fire Department, and City of Palo Alto Utilities (CPAU) are all actively engaged in wildfire preparedness, prevention, and response efforts, coordinating resources and community education initiatives to address these risks. The City works closely with CAL FIRE, regional partners, and neighboring cities to implement and refine emergency response plans, ensure effective evacuation routes, and conduct community outreach on wildfire preparedness. Recognizing the need for a multifaceted approach to wildfire mitigation, the City supports initiatives that promote sustainable land management practices, encourages defensible space in WUI zones, and advocates for policies to reduce human- caused ignitions. By fostering partnerships and promoting proactive wildfire safety measures, Palo Alto is dedicated to enhancing the city’s resilience against the growing threat of wildfires in California.
The following table provides an overview of the City’s various planning documents related to wildfire preparedness and response, as well as their purpose and when they were last updated.
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5 INTRODUCTION
Table 1: City Emergency Preparedness Plans
Title Purpose Date
Emergency
Operations Plan
Basic Plan (EOP)
The EOP embraces the FEMA "whole community" approach. According to the EOP, the City has undergone multiple hazard analysis processes per the FEMA Comprehensive Preparedness Guide 201. The EOP also states the City actively manages training activities and allocates funding in relation to fluctuating needs, personnel turnover, and course availability.
January
2016*
Emergency
Operations Center
Manual (EOC)
The EOC wildland fire response is primarily addressed through the EOC activation, the plan's emphasis extends beyond immediate response to a broader, proactive strategy. According to the EOC the City prioritizes comprehensive hazard analysis and ongoing training aligned with state and national standards such as ICS, SEMS, and NIMS.
July
2021
Wildland Urban
Interface (WUI)
Fire Response
An annex to Palo Alto’s EOP, focusing on WUI fire response. It aligns with state and national emergency management systems (SEMS and NIMS). The primary goals are to guide initial response planning, support the development of incident plans, and ensure coordinated interagency actions.
August
2023
Local Hazard
Mitigation Plan
(LHMP)
The LHMP is part of the larger Santa Clara Operational Area Hazard Mitigation Plan and has a Palo Alto Annex. The LHMP details potential hazards for Palo Alto and provides recommended action on the hazards.
October
2024
Foothills Fire
Management Plan
(FFMP)
The FFMP focuses on mitigating wildfire risks in the Foothills area through targeted vegetation management and strategic planning. The document highlights accomplishments since the initial 2009 plan, including improved evacuation routes, prescribed burns, and reduced fire hazards near critical infrastructure. The update emphasizes ongoing efforts like annual maintenance of treated areas, collaboration with regional agencies, and leveraging funding opportunities. The plan includes post-treatment fire behavior analysis, showcasing how vegetation management efforts have improved emergency access and reduced the likelihood of wildfire spread.
January
2017
CPAU Wildfire
Mitigation Plan
The CPAU Wildfire Mitigation Plan focuses on minimizing the risk of wildfires caused by electric lines and infrastructure. Key strategies include undergrounding power lines in high-risk areas, such as the Foothills region, updating Public Safety Power Shutoff (PSPS) protocols, enhanced vegetation management, and the use of advanced technologies like non-expulsion fuses and remote deenergization switches. The plan emphasizes collaboration with other departments, such as Fire and Urban Forestry, to ensure comprehensive wildfire prevention efforts. Regular inspections, vegetation clearance exceeding regulatory standards, and continuous monitoring are highlighted as critical components. The plan includes performance metrics to track the effectiveness of mitigation efforts, ensuring proactive adjustments where needed.
June
2024
Santa Clara
County
Community
Wildfire Protection
Plan (CWPP)
The Santa Clara County CWPP aims to reduce wildfire risk by establishing cooperative relationships with federal, state and local stakeholders before an event occurs and developing pre-attack plans to enhance firefighter readiness and safety. The CWPP includes annexes which offer information and project recommendations specific to geographical planning areas. The City of Palo Alto is included as an annex. Communities are currently updating their annex plans.
August 2016
* The EOP is being updated and expected to be complete by Q4 Calendar Year 2025 per management.
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6 INTRODUCTION
2 Government auditing standards require an external peer review at least once every three (3) years. The last peer review of the Palo Alto Office of the City Auditor was conducted in 2017. The Palo Alto City Council approved a contract with Baker Tilly U.S., LLP for internal audit services for October 2020 through June 2022 with an extension through June 2025. City Council appointed Kate Murdock, Audit Manager in Baker Tilly’s Risk Advisory practice, as City Auditor in May 2024. As a result of transitions in the Audit Office and peer review delays due to the COVID pandemic, an external peer review is targeted for 2025. It should be noted that Baker Tilly’s most recent firmwide peer review was completed in October 2021 with a rating of “Pass”. The scope of that peer review includes projects completed under government auditing standards. A report on the next firmwide peer review should be available later in 2024.
Scope
The OCA evaluated the City’s plans and efforts related to wildfire prevention and preparedness by assessing related activities and internal controls from FY2023 through FY2024 in the OES, Fire Department, and CPAU.
Methodology To achieve the audit objectives, the OCA performed the following procedures:
• Interviewed the appropriate individuals to understand the roles and responsibilities, processes, and controls related to Emergency Preparedness (Wildfire) activities.
• Analyzed current policies and procedures (P&P) as well as FEMA and CAL FIRE standards and best practices.
• Evaluated relevant documents such as City of Palo Alto EOC Manual, CPAU Wildfire Mitigation Plan, FFMP, and various other plans • Gathered information and reports to assess if current City plans are sufficient in preventing and responding to wildfire risks.
• Inquired with OES departments for clarification and understanding of emergency plans.
• Completed audit report of findings, conclusions, and recommendations based on the supporting evidence gathered
Compliance
Statement
This audit activity was conducted from June 2024 to December 2024 in accordance with generally accepted government auditing standards, except for the requirement of an external peer review2. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
Organizational
Strengths
During this audit activity, we noted the expertise and the responsiveness demonstrated by the Emergency Preparedness team. We also observed their willingness to provide and receive feedback regarding the emergency preparedness process, which includes their receptiveness to process improvements.
The OCA greatly appreciates the support of the Fire Department, Office of Emergency Services, City Manager’s Office, and City of Palo Alto Utilities Department in conducting this audit.
Thank you!
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7 DETAILED ANALYSIS
Detailed Analysis
Best Practices:
Emergency
Preparedness &
Response
In its publication, Developing and Maintaining Emergency Operations Plans, FEMA highlights five key areas for communities to address related to Emergency Preparedness. These include:
• Prevention – reducing risk from human-caused incidents • Protection – reducing or eliminating the threat to people and critical infrastructure
• Response – actions taken in the immediate aftermath of an incident • Recovery – short-term and long-term efforts for rebuilding and revitalizing the affected community
• Mitigation – structural and non-structural approaches to eliminating or limiting the hazards presence
This audit report focuses on the first three areas as they relate to the audit objectives, but recognizes the City has efforts related to recovery and mitigation of wildfire risks too.
Shared Community Preparedness themes
Additional best practice information comes from the National Incident Management System (NIMS) and CAL FIRE. NIMS offers guidance on resource management, mutual aid, and communication during emergency events. CAL FIRE provides guidance and best practices for wildfire events specific to Fire Hazard Severity Zones (FHSZ), further described below. Guidance from FEMA, NIMS, and CAL FIRE all emphasize the importance of the following principles in preparing communities for emergencies including wildfires. Common themes include:
• Community Engagement: Public education and participation are key to ensuring communities are informed and involved.
• Response Coordination: Implementing reliable policies for consistent response across agencies and stakeholders is key to NIMS ICS framework and mutual aid strategies with FEMA’s planning and CAL FIRE’s interagency collaboration.
• Training and Communication: Regular drills and clear communication protocols are critical to ensure preparedness and efficiency during emergencies.
FEMA offers additional guidance related to wildfire emergency preparedness.
FEMA's best practices, as highlighted in their publication Developing and Maintaining Emergency Operations Plans. These best practices include:
• Risk Assessment and Planning: Conducting thorough risk assessments to identify potential wildfire hazards and developing comprehensive emergency plans that address these risks.
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8 DETAILED ANALYSIS
• Public Information and Warning: Ensuring that timely and accurate information is provided to the public about wildfire risks, evacuation orders, and safety measures.
NIMS offers important recommendations for departments handling wildfire emergencies. These best practices include:
• Communication and Information Management: Implementing reliable communication systems and protocols to ensure timely and accurate information sharing during wildfire emergencies.
• Incident Command System (ICS): Utilizing the ICS to coordinate response efforts and manage resources effectively during wildfires.
CAL FIRE offers comprehensive guidance related to wildfire emergency preparedness. CAL FIRE's best practices provide essential recommendations for departments handling wildfire emergencies. These best practices include:
• Fire Hazard Severity Zones (FHSZ): Identifying and mapping areas with varying degrees of fire hazard severity to prioritize resources and mitigation efforts.
• Evacuation Planning: Developing and regularly updating evacuation plans to ensure that residents can safely and efficiently evacuate in the event of wildfire.
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9 Audit Results
City Efforts to Prevent and Protect from Wildfire
Finding 1: While
the City has
made significant
investments in
and has strong
programs aimed
to prevent and
mitigate wildfire
risks; we noted
some areas for
improvement
including
enhancing
community
outreach and
engagement.
The City coordinates and collaborates across departments and with neighboring jurisdictions to prevent and protect the City and its residents from the risk of wildfire. These risk areas include utility infrastructure maintenance, vegetation management, and community outreach and education.
CPAU has made significant investments to reduce wildfire risk CPAU provides electricity to the entire Palo Alto service area including the Foothills/Wildland Urban Interface (WUI) Area and prepares and submits a Wildfire Mitigation Plan to the California Wildfire Safety Advisory Board each year. CPAU has invested in several projects to reduce wildfire risk including undergrounding distribution lines and installing weather stations. The Utility has also developed a Public Safety Power Shutoff (PSPS) procedure.
Undergrounding Distribution Lines
CPAU began the Foothills project to underground distribution lines in the Foothills high-risk area in 2021. This project, which will be completed in summer 2025, includes the undergrounding of approximately 49,200 feet of distribution lines. The project includes undergrounding the main 12470- voltage distribution line as well as fiber optic cable. Utility distribution lines pose a significant wildfire risk and undergrounding these lines largely eliminates this threat as lines cannot be damaged by trees or high winds which can spark fires by falling on vegetation below.
Based on information provided by CPAU, much of the overhead infrastructure within the Wildland Urban Interface (WUI), designated as the High Fire Threat Tier 2 zone, encompassing all city areas west of Highway 280, known as the "Foothills Area" will be undergrounded.
As part of City’s wildfire mitigation strategy, CPAU has prioritized the undergrounding of its overhead infrastructure in the WUI/Foothills Tier 2 area. The Foothill Fire Mitigation Project includes the following key activities:
• Substructure construction, including the installation of boxes and pad-mounted equipment
• Cable pulling and line energization
• Decommissioning of overhead poles and equipment
According to CPAU, the Foothill Fire Mitigation Project is estimated to underground 182 of the total of 203 poles and overhead lines in the high-risk area. The estimated 21 remaining poles require additional coordination with pole attachers, and customers prior to either undergrounding or implementation of additional fire hardening measures. As of March 2025, CPAU management reported it has completely de-energized and undergrounded electric lines for 69 of the 182 poles, significantly reducing the wildfire risk associated with overhead power lines in the area.
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10 3 Red Flag Warning
The table below shows the age of the remaining 21 poles that are not being removed as part of the initial Foothill Fire Mitigation Project.
Table 2: Age of Remaining Poles in WUI
*Analysis conducted by the OCA in March 2025
The OCA saw a range of estimates on how long utility poles can last, anywhere from 35 to 75+ years depending on conditions and maintenance, which suggests CPAU should prioritize maintenance and possible replacement of the oldest poles should they remain in place.
Additionally, CPAU is implementing a multi-year Grid Modernization initiative that will enhance grid resiliency and reliability of the electric distribution system by replacing poles, transformers, aerial wires, some cabinets and underground substructure. The initiative also includes upgrades to two of their substations, with a target completion by 2032.
Weather Station Installation
CPAU installed weather stations in the Foothills area and at the Utility Control Center to collect localized weather data which is shared with first- responder departments to determine if any actions are needed due to conditions. The Utility also monitors regional conditions and receives red flag warnings which signal when fire conditions are heightened3.
Public Safety Power Shutoff Procedure
CPAU has a Public Safety Power Shutoff procedure which provides guidance for deciding when lines may need to be de-energized to reduce Item 3
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11 4 California Public Resources Code Section 4293
wildfire risk and how best to communicate this information to the public.
Residents in the Foothills area are notified via email when de-energization is anticipated and are typically provided with dates and shutoff times.
Forward Looking Infrared (FLIR) Cameras
In addition to visual inspections, CPAU utilizes FLIR Cameras which are used to detect hotspots where electrical equipment could be overheating and treat areas before they become a problem. This use of technology helps enable the City to proactively address maintenance issues.
The City has several programs to address vegetation management and improved tracking of efforts may increase compliance
Wildfires and their spread are dependent on several conditions, such as fuel load or the accumulation of vegetation, as well as weather conditions which determine their severity. The City has several programs and resources dedicated to managing vegetation including resident assistance programs.
These programs include:
• Line Clearance Program
• Right Tree Right Place
• Property Inspections in the Wildland Urban Interface
• Santa Clara Fire Safe Council CAL FIRE
Line Clearance Program
The City’s Line Clearance Program ensures vegetation is cleared from electrical equipment and utility lines, patrol to ensure access roads to facilities remain clear, and right-of-way clearing. The Program, typically completed via a contract with the Fire Safe Council (FSC), is managed by the operations division of the Public Works Department in the absence of a contract with FSC and in collaboration with CPAU. The City’s aim is to maintain a 10-foot clearance from trees in the Foothills area which is in accordance with California law4 and the California Public Utilities Commission.
According to the City’s Tree Management Plan and interviews with staff, the entirety of the Foothills area is inspected and cleared each year in the Spring with a follow-up inspection conducted in the fall. Staff stated that they have not experienced any resource constraints and major tree trimming occurs every 3 to 4 years. Compliance is maintained in intervening years through the biannual inspections and subsequent tree trimming. Tree trimming activities are tracked using a software program called TreeKeeper.
Staff reported they do not currently track inspections but are working on how to capture them as a work record in TreeKeeper. The table below shows how many trees were trimmed in the Foothills area from 2021 to 2024.
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12 Table 3: Number of Trees Trimmed in the
Foothills Area from 2021 to 2024*
*Data analysis conducted by OCA in October 2024
Urban Forestry staff provided the OCA with two guiding documents: Urban Forest Master Plan and Draft Tree and Landscape Technical Manual. While the Urban Forest Master Plan provides overall guidance and includes information on the Line Clearance Program, the Draft Tree and Landscape Technical Manual provides information on what equipment and what environmental conditions to consider for conducting tree trimming to reduce the risk of ignition due to maintenance activities. Staff said that the Manual is intended as a supporting document to the City’s tree ordinance and its Fire- Safe Landscapes section provides residents with tree and landscaping guidance in support of creating a defensible space around one’s home against wildfire risk.
The OCA noted that this draft manual did not appear to be complete. For example, there were imbedded notes for staff to determine seasonal criteria for tree trimming. Overall, while these documents provide good information, they require updating, completion, and dissemination.
Right Tree Right Place Program
The Right Tree Right Place Program provides resources for residents with trees that conflict with power lines. The program includes removing trees at no cost, reimbursement for stump removal and reimbursement for replacing trees with appropriate tree alternatives.
Property Inspections in the Wildland Urban Interface
The City’s Fire Marshal oversees fire safety inspections of businesses and properties. These inspections ensure businesses and residents comply with California Fire Code and keep properties clear of fuel that could increase the risk of wildfire. When a property is found in violation of the Fire Code, they are issued a “Notice of Violation” and typically given a month to make corrections. If a property fails reinspection, the property may be referred to Item 3
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13 the Fire Prevention Bureau and potentially invoiced for any remediation or reinspection fees incurred by the City. The City also adopts a Weed Nuisance Abatement resolution annually and works in coordination with the County of Santa Clara to address properties with weeds that are deemed a nuisance and/or fire hazard.
Based on reports analyzed by the OCA, in 2023 there were 133 homes in Palo Alto’s Wildland Urban Interface (WUI). Inspections were conducted for 104 of these homes and 86 of these passed the first inspection. However, it appears that only 3 homes were reinspected and 26 homes had outstanding violations at year-end. Management stated that this report needs to be cleaned up and there may be less than 133 properties in the Palo Alto WUI.
In 2024, through the third quarter of the year, the City had performed 138 inspections in the WUI.
The City recently began using a new system to track fire inspections and management reported they are working with the City’s Information Technology Department to develop more robust reporting capabilities so the Fire Marshal can more easily track metrics on how many violations have been issued, how many have been corrected, how many referred to the fire prevention bureau, etc.
With improved data tracking and reporting capabilities, the City will be able to better and timelier follow-up with businesses and residents who are not in compliance with the Fire Code and ensure wildfire risk is reduced.
Santa Clara Fire Safe Council
The City has a short-term contract with Santa Clara Fire Safe Council to help with roadside clearance work, public education, and pursuing grant opportunities. Staff stated that the City has introduced the Firewise program in the past through the Fire Safe Council, but the program has not had much traction and Palo Alto does not currently have a Firewise Community, a program that must stem from the impacted residents. The Firewise USA® program offers a structured approach for communities to enhance their wildfire resilience and promotes collaboration between residents, fire departments and other stakeholders. Establishing a Firewise program is also recommended for Palo Alto in the Santa Clara County Community Wildfire Protection Plan.
A core principle in Community Wildfire Protection Plans is to include as many agency representatives and resident leaders in the planning process as possible. The first goal in FEMA’s Creating a Community Wildfire Protection Plan is to “Create fire-adapted communities” which includes pursuing Firewise site recognition, providing information to the community about fire safety, and reducing risks for home ignition. As stated in the CWPP, the City should strongly consider working with the local Foothills community to attain and maintain Firewise USA recognition.
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14 CAL FIRE
CAL FIRE has provided assistance to the City over the past couple of years in clearing out vegetation in the Foothills area and including some areas with Eucalyptus trees. The City does not currently have a formal contract with CAL FIRE for these services, however, this is something they should consider ensuring for service provision in the future.
Community Education and Outreach could be improved.
While the City has implemented various programs and trainings to promote the community's wildfire awareness and prevention efforts, there is room for improvement. Currently, there is no comprehensive policy or set of requirements established for the City's overall community outreach and education efforts to ensure sufficient information and education are provided to the residents for wildfire prevention and emergency preparedness. As a result, the City's overall community outreach and education efforts are not tracked to ensure goals are met.
Limited efforts to measure education and outreach effectiveness According to management, community outreach and education responsibilities are shared between Fire Prevention and OES and the citywide communications team. Staff said efforts were tracked in the past, but they lost the position responsible for this activity and there are currently no P&P in place to guide the provision or tracking of education and outreach efforts. Staff indicated that recent efforts have not been well attended by residents, making it difficult to assess how engaged and prepared the community is to prevent and respond to wildfires.
CPAU also performs community education and outreach activities and includes wildfire information as part of its regular communications with customers. CPAU employs several methods for communicating with customers including utility bill inserts, email newsletter, direct mail, social media, and the CPAU website. While staff provided several examples of wildfire education efforts, they indicated there is no policy or plan outlining expectations or responsibilities for outreach and education efforts, how often they should be performed and/or how to determine what information gets shared. In accordance with State law, the Utility Wildfire Management Plan is presented annually in a public meeting to the Utilities Advisory Commission. Developing a guiding document with appropriate goals and targets could help ensure the utility consistently communicates with residents and could aid in tracking the effectiveness of these efforts over time.
Some residents report a lack of wildfire preparedness education and a desire for more information related to City prevention efforts The City of Palo Alto’s Community Survey results from 2023 support the observations above that the City could improve outreach efforts to community members. When asked about the quality of Palo Alto’s fire prevention and education services, 37% of respondents in 2023 answered “don’t know”, 18% answered “fair” or “poor”, and 45% answered “good” or “excellent”. However, it should be acknowledged that this question is posed Item 3
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15 as broader “prevention” activities and does not specify wildfire prevention nor is the sample size specific to the WUI region.
In 2022, CPAU’s study of Key Account Customers found that 40% indicated being “very concerned” with future wildfires and a 2023 Residential Electric Customer Satisfaction Study reported that the second most desired topic of information (44%) is “what CPAU is doing to prepare for emergencies like wildfires and earthquakes.”
The City’s Fire Department conducts annual property inspections in the WUI to detect dangerous conditions that could contribute to or exacerbate wildfire risk. As noted above, our analysis of the fire inspection log from 2023 shows that 26 out of an approximate 133 homes in the WUI had outstanding violations and in 2024 more than 74 homes had violations. Annually doorhangers are provided to residents in this area. Additional measures such as education, outreach, and fines may help to reduce violations by informing residents of the dangers of excess vegetation and any maintenance or prevention related resources available to them. The Fire Department does maintain an online wildfire preparedness resource for community members:
https://www.cityofpaloalto.org/Departments/Fire/Prepare-For-Wildfire- READY-SET-GO.
Recommendation We recommend the City consider the following improvements to enhance its Wildfire prevention efforts:
1. Continue efforts to underground WUI distribution infrastructure and prioritize, as appropriate, maintenance and possible replacement of the oldest poles should they remain in place.
2. Line Clearance policy documents should be established and or reviewed, updated and finalized (e.g. Draft Tree and Landscape Technical Manual)
3. Continue efforts to better track and monitor property violations in the WUI to enhance enforcement.
4. Prioritize efforts to establish a Firewise Community including stakeholder engagement throughout the process
5. Formalize the contract with CAL FIRE to ensure service provision continues into the future.
6. Ensure wildfire education and outreach plans document coordination efforts between OES, Fire and CPAU to ensure information is consistently and regularly provided to residents.
Management
Response
Please see appendix for responses.
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16 City Wildfire Response Plans
Finding 2:
Overall, the City
has a strong
emergency
response plan
but should
consider if
improvements
could be made to
evacuation
planning, after
action report
recommendation
implementation,
and
communication
efforts.
The City takes a proactive and collaborative approach in responding to and mitigating wildfire risks by coordinating closely across its own departments— such as the OES, Fire Department, CPAU, and Public Works—and with neighboring jurisdictions. These risk areas include Planning, Training, Detection, Communication, and Resources.
The City has a comprehensive set of emergency response and wildfire plans, but the City should consider if evacuation plans could be enhanced and some plans may require updating and review
The City has several plans that all work in conjunction with each other to ensure the City is prepared to response to various disasters and hazardous conditions. In addition to internal plans, the City is part of Santa Clara County’s Community Wildfire Protection Plan. We discuss several of the plans guiding the City’s response approach, below.
The City has 6 plans related to wildfire.
• Overarching Emergency Operation Plans (EOP) which contains the annexes Emergency Operations Center Manual (EOC),
• Local Hazard Mitigation Plan (LHMP),
• Foothills Fire Management Plan (FFMP),
• Wildland Urban Interface Fire Response (WUI), and
• CPAU Wildfire Mitigation, which is a wildfire plan for the City Utilities Department.
•
The EOP adopted by city council on January 11, 2016, states that it follows FEMA's "whole community" approach. The EOP in general follows the format laid out by FEMA. The revision history and certification of biennial review on the EOP are blank both on the EOP provided to auditor and on the City website, indicating that the plan has not been updated or reviewed in 8 years. The distribution section of the EOP does not adhere to FEMA's recommended format, which specifies that this section should be presented as a list. Management has identified that the EOP is currently undergoing review and update in 2025.
In the EOC, wildland fire response is primarily addressed through the EOC activation, the plan's emphasis extends beyond immediate response to a broader, proactive strategy. According to the EOC, the City prioritizes comprehensive hazard analysis and ongoing training aligned with state and national standards such as ICS, SEMS, and NIMS.
The LHMP is part of the larger Santa Clara Operational Area Hazard Mitigation Plan and has a Palo Alto Annex. The LHMP details potential hazards for Palo Alto and provides recommended actions to prepare for these hazards. This plan was recently adopted by the City Council in October 2024.
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17 The FFMP for Palo Alto focuses on mitigating wildfire risks in the Foothills area through targeted vegetation management and strategic planning. The document highlights accomplishments since the initial 2009 plan, including improved evacuation routes, prescribed burns, and reduced fire hazards near critical infrastructure. The update emphasizes ongoing efforts like annual maintenance of treated areas, collaboration with regional agencies, and leveraging funding opportunities. The plan includes post-treatment fire behavior analysis, showcasing how vegetation management efforts have improved emergency access and reduced the likelihood of wildfire spread.
There is a monthly meeting with
OES, CSD Open Space Division, Fire
Marshal’s Office, Public Works Operations, and Utilities Engineering to address and discuss current issues within the FFMP. The City is currently in the process of updating this plan.
The WUI focuses on WUI fire response and provides a concept of operations in the development of an effective and coordinated response to a significant wildland urban interface (WUI) Fire. This provides direction for city departments, community groups, and allied stakeholders ensuring interagency coordination in accordance with the City’s EOP, the California Emergency Services Act, the Standardized Emergency Management System (SEMS), and the National Incident Management System (NIMS).
The CPAU Wildfire Mitigation plan focuses on minimizing the risk of wildfires caused by electric lines and infrastructure. Key strategies include undergrounding power lines in high-risk areas, such as the Foothills region, enhanced vegetation management, and the use of advanced technologies like non-expulsion fuses and remote deenergization switches. The plan emphasizes collaboration with other city departments, such as the Fire Department and Urban Forestry, to ensure comprehensive wildfire prevention efforts. Regular inspections, vegetation clearance exceeding regulatory standards, and continuous monitoring are highlighted as critical components. The plan also includes a performance metrics framework to track the effectiveness of these mitigation efforts, ensuring proactive adjustments where needed.
Areas for Improvement
Overall, OCA found that the City’s plans align with the majority of FEMA guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process to ensure that plans are regularly reviewed and updated. In addition, while the FFMP addresses evacuation routes and ensuring these routes remain clear for emergency personnel as well as residents for evacuation, we recommend the City consider the following enhancements based on Homeland Security’s, Planning Considerations: Evacuation and Shelter-in-Place; Guidance for State, Local, Tribal, and Territorial Partners, July 2019. This guidance highlights the following responsibilities for local jurisdictions:
• Setting clear expectations for whole community partners through education, training and information sessions,
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18 • Establishing and publishing clear evacuations routes and zones for the community,
• Identify evacuation shelters within the community and in other communities working with those neighboring communities to establish notification and operational procedures,
• Create pre-approved accessible messaging for rapid distribution regarding incident and shelter in place or evacuation instructions, • Have a continuity plan to help maintain response operations if interrupted, and
• Provide real-time mapping and navigation routing systems through Geographic Information System (GIS).
Homeland Security’s guide also highlights key lessons from past wildfire emergencies that occurred in Los Angeles County, CA and Larimer County, Colorado:
• Need for increased coordination for quicker incorporation of GIS data into analysis
• Identification of the safest evacuation routes combined with the use of multiple forms of communication to keep residents informed regarding timing and location of evacuated areas.
• Use of a tiered evacuation approach
o First, direct residents out of an immediate impact zone to an evacuation point, out of danger, where additional information is provided,
o Second, if the danger is prolonged, direct residents from the evacuation point to an evacuation center where water, food and power resources are available to charge mobile devices, and
o Third, if overnight or multi-day evacuation is necessary, direct residents to shelters in nearby communities.
Training
The City monitors training requirements and compliance and recently implemented a new sign-in process to improve tracking
Fire, OES, and Police all serve critical functions in emergency response with different training requirements depending on their roles and responsibilities.
In terms of wildfire response training, the Fire Department provides wildfire training through modules provided by Vector Solutions as part of an annual fire safety refresher course, RT-130 which is required per the National Wildfire Coordinating Group (NWCG) for designated positions for all personnel assigned with Fireline duties. The training is completed before the start of the Wildland season which typically runs from May to November but can vary from year to year. A new QR check-in system may have resulted in Item 3
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19 incomplete sign-ins and a battalion chief had not yet completed the training as of the writing of this report. There was a total of 77 employees signed up and as of August 29th, 2024, 71 had completed the required training. Out of the 6 who had not completed the training, five were due to workers’ comp or medical issues. Management was unable to provide an explanation of why the remaining employee’s training was not completed but noted that the individual received follow-up training to ensure understanding of training requirements and protocols. Management stated that a new check-in system is now in place and will help the City more easily track training compliance in the future.
The OES training primarily covers critical incident response, with minimal emphasis on wildfires. Finally, the Police Department does not have specific wildfire training. Instead, they focus on support roles during such incidents, including using police speakers for warnings, directing traffic, and ensuring clear roads.
After Action Reports (AAR)
According to The National Wildfire Coordinating Group (NWCG) AARs are essential for wildland firefighters to learn from mistakes and capitalize on successes. The objective of the AAR is to immediately identify these successes and failures. Once they have been recognized, further exploration allows the team to perfect its skills and be better prepared for future endeavors. NWCG is a partnership of federal, state, tribal, and local wildfire management agencies that work together to establish standardized practices for wildland fire operations in the United States, its primary goal is to enhance efficiency, safety, and effectiveness in wildland fire management and response. The NWCG develops training programs, operational guides, and policy frameworks to ensure consistent and coordinated wildfire management across jurisdictions. It also serves as a central resource for promoting best practices, improving interagency collaboration, and supporting the professional development of fire personnel.
While the City conducts training and AARs after critical incidents, efforts to track and implement resulting recommendations could be improved
All the departments come together to engage in tabletop exercises for training purposes. Departments also work together after critical emergency incidents to conduct AARs to report their successes and improvement opportunities. While some AAR recommendations have been implemented others have not and staff said they do not formally track and monitor the implementation of recommendations. Areas of improvement noted in training exercises and in AARs cover various areas such as communication, recovery and proper use of PPE.
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20 Training Exercises
2024 XSC Readiness Drill
A drill hosted by the County of Santa Clara to provide pre-incident training on bulldozer, hand crew, and helicopter operations during a wildfire. This event was attended by county-wide OES departments. Areas of improvement included:
• Creating clarity around the communications center and coordinating the process and flow of mutual aid initial attack orders.
Vulcan Forge Tabletop Exercise
The City of Palo Alto Vulcan Forge Tabletop Exercise was intended to discuss and validate existing procedures. The drill provided an opportunity for City staff to exercise their role and gain a greater understanding of the processes and procedures that will occur during wildfire response. Areas of improvement included:
• The WUI ConOps is lacking specific procedures to reach those with limited English proficiency or for people with disabilities, and others with access and functional needs (DAFN)
• Participants didn’t appear to know how best to alert residents who were experiencing power outages
• The WUI ConOps does not have a procedure for approving PIO to disseminate to the public
• Define terms such as “mass care” vs. “sheltering” to create clear understanding of evaluation points, centers, shelters, and the like • Establish evacuation center and sheltering operation criteria, P&P and train appropriate staff
• Current plans lack sufficient detail on recovery and relief efforts • OES needs to create P&P for re-entry and re-population
After Action Reports
PAFD AAR Dish Fire
A fire of unknown origin started near the Stanford Hiking Dish Trail and the PAFD responded to put out the fire. The fire was in an area of the dish hiking trail that’s nearest the intersection of lower Reservoir Road and the Stanford Hiking Dish Trail with the closest gate access being the Gerona Gate. Areas of improvement included:
• There was a delay in dispatching mutual aid and additional hands-on training was requested
• Proper PPE must always be worn when responding
OCA’s analysis of training exercise notes and AARs found areas of improvement are often identified with suggestions for process improvements. The OCA recommends the City more formally track and Item 3
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21 5 https://www.cityofpaloalto.org/Departments/Emergency-Services/Emergency-Preparedness 6 https://www.cityofpaloalto.org/Departments/Fire/Prepare-For-Wildfire-READY-SET-GO
monitor these findings and recommendations to better determine if they should be implemented, what resources may be needed, and to establish an appropriate timeline for implementation.
The City is enhancing its wildfire detection capabilities through the use of gas monitoring sensors deployed in the Foothills area
Detection is crucial in wildfire emergencies because it enables early response, reducing the spread and potential damage of fires by allowing for quicker containment efforts. Early detection systems, such as remote sensors and aerial surveillance, are vital for protecting communities and natural resources, as they help agencies mitigate risks before fires escalate to dangerous levels.
The City recently set up N5 Sensors which are an advanced gas monitoring system designed to provide early alerts in the event of a wildfire. In a collaborative program, the City is partnering with Stanford and Woodside, with Stanford purchasing 25 N5 sensors and receiving an additional 25 at no cost. Of these, Palo Alto will receive 12 sensors, while Woodside will receive
13. Each city will cover its own data expenses, estimated at $22,000 per city for the first two years. Palo Alto received a grant from the Department of Homeland Security to assist with the expenses. The Fire Safe Council will handle the sensor installation and program management. Although N5 Sensors will not provide complete coverage across all areas, they are strategically positioned to enhance early warning capabilities in high-risk zones. Additionally, the City has explored the use of drones for monitoring, but concerns over privacy, public perception, and restrictive municipal codes have made their approval challenging.
Communication
The City employs several methods for communicating critical information to its residents during an emergency and should continue to explore methods to increase participation in the County’s emergency alerting system
The City has established multiple communication channels such as the City’s website, news releases, social media, and radio announcements to remind residents of wildfire season and keep them informed of the City’s events and emergency notifications. City web pages dedicated to general emergency preparedness
5 and wildfire prevention include CAL FIRE’s
Ready-Set-Go6 video, Palo Alto Wildfire Planning Map, evacuation information, a link to sign up for Santa Clara County’s alerting system, and other resources.
Palo Alto utilizes Everbridge, the mass notification system used throughout Santa Clara County to communicate with residents in emergency situations.
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22 Under California’s emergency management structure, each county operates as an "Operational Area," giving it independent authority and responsibility for issuing alerts and warnings within its jurisdiction. Santa Clara County has been using Everbridge for several years, with trained personnel across jurisdictions, including staff from Palo Alto’s OES and Police dispatch.
Everbridge is Palo Alto’s primary tool for sending mass alerts in wildfire situations. There are two main response scenarios: First, if a fire breaks out within Palo Alto’s jurisdiction, OES will issue an immediate alert after assessing the fire's location and direction. Second, if a fire starts outside the area but moves toward Palo Alto, they monitor and notify residents as needed. Residents can "opt in" to receive these alerts by registering at alertscc.org. Additionally, Everbridge includes an "all records" list, which contains duplicates, and includes data from their reverse 911, purchased cell phone records, white and yellow pages, and data from the prior system, Blackboard. However, this “all records” list contains duplicates making it difficult to determine the total number of residents signed up for the service.
For example, an individual might have their information listed in all records noted above and each record lists them as a separate contact.
Based on the alert system sign-up data provided by Santa Clara County, the percentage of Palo Alto residents signed up for alerts increased from 15% in 2023 and 2024 to 17% in 2025. Participation among other Santa Clara County cities in 2025 ranges from 7% to 29%. Some cities may have more or less of their population occupying WUI areas which may account for some of the differences in emergency alert adoption.
The OCA recommends the City continue to explore ways to increase resident participation in this program since it is the City’s primary communication tool for reaching residents in an emergency.
Resources
The City has seven fire stations. Six fire stations are staffed full-time and the seventh station provides seasonal coverage in the foothills region during high-fire danger months. This seventh station is staffed through an interlocal agreement with Losa Altos Hills and Santa Clara County which specifies a rotational schedule to ensure coverage.
Mutual aid agreements are essential in wildfire management, enabling communities to combine resources, expertise, and personnel across jurisdictions for a more effective and rapid response to large-scale fires.
Wildfires spread quickly and can overwhelm local resources, making support from neighboring cities, counties, and state agencies critical for containment and suppression. These agreements establish protocols for communication, resource sharing, and logistical coordination, which helps reduce response times and enhances overall operational efficiency. FEMA and CAL FIRE emphasize that such partnerships strengthen resilience by ensuring that participating agencies are prepared to respond cohesively to the complex challenges of wildfire emergencies.
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23 Recommendation
While the City has strong relationships with their mutual aid agreement partners, the City does not maintain these agreements in a central repository for easy tracking and monitoring
Palo Alto has 5 mutual aid agreements for wildfire response, though some require updates for ongoing effectiveness. The Station 8 agreement remains active, providing 24/7 monitoring during wildfire season, while the Mutual Threat Zone operating plan with CAL FIRE establishes guidelines for resource usage and remains in force until a 30-day termination notice is issued. Additionally, the agreement among Palo Alto, Santa Clara County, and Los Altos Hills ensures the availability of nearby resources for emergencies, continuing unless ended by a 30-day notice. The agreement with Woodside, which expired sometime in 2019 had no specified end date, according to the Deputy Fire Chief negotiations for a new contract are currently underway. The mutual aid agreement with Mountain View is also expired, though still honored by both cities. The OCA noted that these agreements are not kept in a central repository which may make it difficult to track and monitor the status of the agreements.
We recommend the City consider the following improvements to enhance its Wildfire response efforts:
1. The City’s emergency plans align with the majority of FEMA guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process. The City should also review its evacuation plans and consider if plans could be enhanced by reviewing best practices in other cities such as establishing evacuation locations and sheltering agreements with neighboring communities.
2. City management should more formally track and monitor findings and recommendations identified during training exercises and in AARs of emergency incidents to ensure needed improvements are made and issues are timely resolved.
3. Continue to explore ways to increase resident registration in the County’s emergency alerting system. Opportunities may include partnering with schools, homeowner associations, and local businesses to disseminate wildfire education materials and encourage participation in City programs and the County’s emergency alert system.
4. Determine an appropriate solution for staff to more easily access, track and monitor the status of all mutual aid agreements, including active dates, renewal deadlines, and responsible contacts for updates. For example, a centralized tracking system for mutual aid agreements would provide clarity on the status of each agreement, preventing lapses in mutual aid coverage and ensuring that expired agreements are addressed promptly.
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24 7 CPAU contracts with a third-party vendor to conduct compliance inspections to ensure utility poles and equipment are well maintained. Visual inspections are conducted annually and a detailed inspection every five years. Every ten years, the vendor performs an “intrusive inspection” which can include drilling into the poles to determine their condition. Lines and poles are rated using a 3-point scale from P1 (most serious and needing immediate attention) to P3 (less urgent). Staff stated that poles rated with a P1 are remediated immediately, however, the OCA could not assess the timeliness of response based on the reports provided.
Management
Response
Please see appendix for responses.
Additional
Observation
The OCA noted that while the Utility has a regular Capital Improvement and electric Grid Modernization Project, it does not have a formal maintenance schedule that proactively anticipates and schedules maintenance as the infrastructure ages. Instead, maintenance issues are addressed on an as needed basis. Management stated that the Utility is currently behind schedule in addressing line and pole maintenance due to resource constraints but is on schedule to complete all Overhead and Underground facility inspections for 2024.
The OCA has performed a general assessment of CPAU’s line and pole maintenance program noting some areas for the City to consider. The OCA analyzed pole data from the Utility’s pole inspection report7 and noted that approximately half of the City’s poles are over 40 years old, with some poles dating back to the 1940’s. 545 of CPAU’s poles are 60 years old or older and may present age-related maintenance issues. It should be noted that many of these poles may be scheduled for replacement as part of the Grid Modernization project.
In addition to the Utility’s pole inspection report, the OCA asked for example inspection reports for individual pieces of equipment and poles. These reports are entered into the CPAU Electric Equipment & Maintenance Database. The audit team noted that for the example reports received, the previous inspection dates on the forms appeared to be more than 10 years ago. The OCA recommends the City consider implementing a formal infrastructure maintenance program as part of its Grid Modernization efforts to ensure ongoing timely inspection and maintenance in the future.
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25 Appendix A: Management Response Matrix
Finding 1: While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
1. Continue efforts to
underground WUI distribution
infrastructure and prioritize as
appropriate maintenance and
possible replacement of the
oldest poles should they remain
in place.
Agree Utilities Staff appreciates the CAO’s validation of this priority and agree that efforts should continue to underground and harden distribution infrastructure within the high fire danger area. The City’s Utilities Wildfire Mitigation Plan, updated and approved annually, prioritizes the undergrounding of the City’s overhead infrastructure in the high fire danger area on Arastradero Road. The first phase of the Foothill Fire Mitigation Project will move powerlines underground and remove approximately 182 of the total of 203 power poles and overhead powerlines in the high-risk area. The estimated 21 remaining poles and associated equipment require additional engineering and coordination prior to additional fire hardening measures.
The Foothill Fire Mitigation Project includes substructure construction, including the installation of boxes and pad-mounted equipment; Cable pulling and line energization; Decommissioning of overhead poles and equipment.
Q4 2025
2. Line Clearance policy
documents should be
established and or reviewed,
updated, and finalized (e.g.
Draft Tree and Landscape
Technical Manual)
Agree Public Works Staff is actively working to update the Draft Tree Landscape Technical Manual (TLTM), and the recent the public comment period on the proposed revisions closed March 2025. Comments are under review and a draft of the TLTM is scheduled for review with the Parks and Recreation Commission, with a final version expected this year. Staff agree and plan to establish a line clearing policy for trees and landscape (like the current line clearing policy for utilities operations).
Q4 2025
3. Continue efforts to better
track and monitor property
violations in the WUI to
enhance enforcement
Agree Fire The fire prevention bureau started utilizing Streamline software in 2024 and at the time of this report has now fully implemented this tool. This software, specifically designed for fire inspections, will improve inspection management, including tracking and monitoring of properties with violations that require re-inspections.
Q1 2025
4. Prioritize efforts to establish
a Firewise Community including
stakeholder engagement
throughout the process
Agree OES, Fire The Palo Alto Fire Department (PAFD) is working towards a long-term contract with the Fire Safe Council including cost estimates for roadside clearance and public education resources, i.e. Firewise Community.
PAFD is seeking partnership with Woodside Fire Protection District and Los Altos Hills Fire District to enhance our presence and efforts towards public education and will support residents in the pursuit of participation in the Firewise Communities program. Firewise is a grassroots program Q4 2025
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26 Finding 1: While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
that the impacted Community must initiate. As stated in the CWPP, staff will work with local Foothills community to attain and maintain Firewise USA recognition
5. Formalize the contract with
CAL FIRE to ensure service
provision continues into the
future.
Partially
Agree
Fire Staff agree that multiyear formal contracts would be a best practice and understand that operationally this may not be feasible since it would add administration obligations for an outside agency. The summer of 2025 will be the third year that CAL FIRE assists the City of Palo Alto with hazardous fuel removal. CAL FIRE provides similar services for multiple agencies in the county (San Jose, Morgan Hill) without a contract. Staff will seek this formalization to ensure stability and continuity, though it may be infeasible if CAL FIRE does not agree to a formal contract. CAL FIRE does not charge cities for the provision of these services.
Q4 2025
6. Ensure wildfire education
and outreach plans document
coordination efforts between
Office of Emergency Services
(OES), Fire and CPAU to
ensure information is
consistently and regularly
provided to residents.
Partially
Agree
OES, Fire,
Utilities, CMO
Staff partially agree as this work is already being coordinated among departments. Staff will look to update the City’s existing plans and hazard-specific annex documents ensuring communication of information is consistent and timely, reflecting the practices in place.
The existing EOP identifies communication protocols and responsibilities in the event of a disaster but could add details to formalize wildfire preparedness and outreach. The leadership team reviews all scheduled community events and engagement points on a monthly basis, including educational events for seasonal events such as floods and wildfires.
A unified wildfire preparedness effort among departments to build community awareness, offering tools and tips, and sharing online resources already includes the following: annual door hangers, utility bill inserts, general emergency services communications such as continued promotion of AlertSCC, the City’s emergency alert system, annual test of Alert SCC, and annual community presentations on wildfire preparedness all available on the ‘Ready, Set, Go!” web resource referenced in the report. Annually, OES and PAFD host public education forums for residents and businesses in the WUI.
Q2 2026
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27 Finding 2: Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning, training, after action report recommendation implementation, and communication efforts.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
1. The emergency plans align
with the majority of FEMA
guidance; however, they would
be strengthened by
incorporating a more
comprehensive revision history
and an enhanced review
process. The City should also
review its evacuation plans and
consider if plans could be
enhanced by reviewing best
practices in other cities such as
establishing evacuation
locations and sheltering
agreements with neighboring
communities.
Agree OES, Fire OES will institute management controls to ensure scheduled reviews of the City’s published emergency plans are timely completed with revision histories clearly documented, beginning with the current update of the EOP underway.
The City has evacuation maps available on the OES website and all public education materials and sessions advise residents of the location and content of the resources. PAFD and OES continue to utilize Genasys (formally Zonehaven) software that notifies residents in a particular zone of evacuation warnings and orders related to natural and human caused disasters: what is happening, where to evacuate, etc. which also includes pre-approved messaging in the platform.
Q4 2025
2. City management should
more formally track and monitor
findings and recommendations
identified during training
exercises and in emergency
incident AAR recommendations
to ensure needed
improvements are made and
issues are timely resolved
Agree OES Staff review AARs from training/tabletop exercises and real-world incidents, though the outcomes of these are tracked differently depending on the nature of the incident or training. For tabletop exercises, OES regularly conducts citywide AARs for training exercises and incidents. OES reviews and follows-up on necessary improvements identified in the AARs, however, to instill further rigor, OES will implement a post-AAR process review every six months until resolution of identified action items for final closure.
PAFD routinely conducts AARs following major incidents, which are then reviewed by executive command staff. Depending on any identified areas for improvement, such as further training or policy updates, the Deputy Chief over operations is responsible for ensuring completion of applicable follow-up steps including additional feedback to departments outside of the Fire Department.
Q3 2025
3. Continue to explore ways to
increase resident registration in
the County’s emergency
alerting system (AlertSCC).
Opportunities may include
Agree CMO, Utilities,
OES, Fire
The City uses many forms of communication to ensure community engagement, notification, and education activities and to increase AlertSCC sign ups. This is prominent on many pages of the City’s website, a recurring item in digital newsletters and printed outreach and always included in City emergency preparedness education programs Q1 2025
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28 Finding 2: Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning, training, after action report recommendation implementation, and communication efforts.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
partnering with schools,
homeowner associations, and
local businesses to disseminate
wildfire education materials and
encourage participation in City
programs and the County’s
emergency alert system.
regardless of the type of disaster being highlighted. It isa central message provided at community events through tabling. An annual AlertSCC test is scheduled citywide to encourage more registrations.
Staff agree that continuing to support participation in this program is important, and will continue to promote AlertSCC registrations in various City engagement efforts. Note that the City continues to be ahead when compared to the Countywide 10% opt-in level. Last year, as a result of communications efforts, over 7,000 City contacts opted into receive emergency alerts. Furthermore, staff agree and will continue to partner with schools, Palo Alto Neighborhoods, and local businesses to share educational materials.
4. Determine an appropriate
solution for staff to more easily
access, track and monitor the
status of all mutual aid
agreements, including active
dates, renewal deadlines, and
responsible contacts for
updates. For example, a
centralized tracking system for
mutual aid agreements would
provide clarity on the status of
each agreement, preventing
lapses in mutual aid coverage
and ensuring that expired
agreements are addressed
promptly.
Partially
Agree
OES, Fire The City’s EOP includes a section on mutual aid within the framework of the CA Master Mutual Aid Agreement. This includes a list of mutual aid response disciplines, coordinating agencies, and specific elements included, e.g. fire & rescue, search and rescue, emergency management, etc.
Although current mutual aid agreements for fire services are retained by the Fire Department in current operations, staff agree that a central repository of auto-aid agreements will be kept with emergency protocol documentation as an appendix/reference document, for broader and more ready accessibility in an emergency. A tracking system is not needed as all auto aid agreements within Santa Clara County agencies are current and have no expiration dates. Locally, the Santa Clara County XSC Mutual Aid Plan is reviewed and updated annually.
San Mateo County fire chiefs are looking at the details of the mutual aid agreements in the County to review operational impacts countywide. The auto aid agreements with Woodside Fire Protection District and Menlo Park Fire, both of which are in San Mateo County, do have end dates and are currently for freeway responses only.
Q3 2025
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Auditor
Meeting Date: April 8, 2025
Report #:2410-3635
TITLE
Receive Update on City of Palo Alto Emergency Preparedness for Wildfires and Recommend City Council Approval of the Emergency Preparedness: Wildfire Audit Report by the City Auditor – Late Packet Report
RECOMMENDATION
Staff recommend that the Policy & Services Committee: Receive an update regarding wildfire preparedness for City operations and receive and recommend City Council approve the BakerTilly Emergency Preparedness: Wildfire Audit Report.
EXECUTIVE SUMMARY
Palo Alto, like many communities in California, faces increasing wildfire risks due to climate change, prolonged drought, and human activity in the wildland-urban interface (WUI), and this report is one item in a series of a series of public engagement and public meetings to raise awareness of local wildfire risks and the importance of wildfire preparedness. This report provides a summary of recent wildfire preparedness activities underway and new items such as the newly released wildfire maps released by the California Fire Marshal and transmits an audit on wildfire preparedness completed by BakerTilly, the City’s Auditor. The findings of an independent audit conducted by BakerTilly reviewed the current wildfire protection plans implemented by the City and evaluated their effectiveness in mitigating wildfire risks and ensuring adequate emergency response. The audit identified areas for improvement in evacuation planning and enhancing community engagement. This report recommends that the Committee recommend the City Council approve the audit and recommendations within.
BACKGROUND
In response to increasing wildfire risks, the City has developed various wildfire protection plans and strategies and takes a regional approach to planning efforts. Coordination and alignment with County and State agencies is key to ensuring responsible agencies can work together in an emergency. Mutual aid agreements with neighboring jurisdictions to enhance firefighting Item 3
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capabilities during large-scale incidents are critical to incident response as no single agency has the resources to respond to a wildfire incident independently.
As noted in the Audit, the City has several planning documents from Utilities, Fire, and Office of Emergency Services to support planning and incident management of wildfire threats in the City of Palo Alto. The existing Emergency Operations Plan (EOP) is currently going through an update. The Wildland Urban Interface (WUI) Fire Response plan is part of the EOP planning cycle. The Utilities Wildfire Mitigation Plan is updated annually, and most recent updates were adopted in June 2024. Below is a comprehensive list of the City’s emergency plans relevant to wildfires:
•Emergency Operations Plan Basic Plan (EOP)
oEmergency Operations Center Manual (EOC)
•Wildland Urban Interface (WUI) Fire Response
•Local Hazard Mitigation Plan (LHMP)
•Foothills Fire Management Plan (FFMP)
•CPAU Wildfire Mitigation Plan
•Santa Clara County Community Wildfire Protection Plan (CWPP) A number of legislative initiatives are also being tracked as wildfire preparedness, response, and recovery are topics the state legislature is actively concerned with in the wake of the January 2025 wildfires in southern California.
ANALYSIS
After the January 2025 southern California wildfires, this agenda item was expanded to discuss two parts, 1) Wildfire Preparedness Activities and 2) Summary and Response to the Emergency Preparedness – Wildfire Audit (conducted in 2024, prior to the recent events). Recognizing the importance of communications, education, and preparation, in collaboration with the City Auditor, this expansion is in alignment with the launch of a series of items to raise awareness of local wildfire risks and the importance of wildfire preparedness.
Wildfire Preparedness Activities
Wildfire planning, a continued City Council priority objective, is a cross-cutting initiative within the City with key roles in: Fire, Utilities, Office of Emergency Services (OES), and Public Works Departments. As an example, the Foothills Fire Management Plan/Community Wildfire Protection Plan (FFMP/CWPP), a multi-year plan with OES, Fire Department, Public Works, Utilities, Community Services Department coordinated via the Foothills Fire Management Team (aka Foothills Wildfire Coordination Team), is a 2025 Council priority objective to be completed in summer 2025. The 2024 City Council priority objectives demonstrated this continual effort through Objectives 70 and 71: Approve updated Local Hazard Mitigation Plan and Update Item 3
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Foothills Fire Management Plan & Community Wildfire Protection Plan, respectively. Below outlines recent wildfire preparedness activities recently completed or under way organized by •preparation and planning,
•multijurisdictional initiatives, and
•mitigation and prevention efforts.
Emergency Preparedness & Planning:
Local Hazard Mitigation Plan (LHMP) & Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP): Office of Emergency Services (OES) with the County updated emergency plans, including the Palo Alto LHMP. The Santa Clara County MJHMP, Volume I and the associated Jurisdictional Annexes, Volume II, was approved by the State and by FEMA and City Council adopted Volume I and The Palo Alto Annex to Volume II on October 7, 2024 in alignment with the Council 2024 priority objective.
Emergency Operations Plan (EOP): The City’s Emergency Operations Plan (EOP) is currently undergoing a review and update process including community engagement and feedback. This process ensures the City has the planning, policies, and concept of operations to guide responsibilities for emergency preparedness, prevention, response, recovery, and mitigation for the City of Palo Alto.
Local Responsibility Area Hazard Severity Zone Maps: To better prepare for wildfires, the California Department of Forestry and Fire Protection (CAL FIRE) is required to classify the severity of fire hazard in areas throughout California. In response, the State is releasing Fire Hazard Severity Zone (FHSZ) maps in phases and released Palo Alto’s maps at the end of February. Portions of Palo Alto, generally west of Junipero Serra Blvd/Foothill Expressway have been identified as moderate, and areas in the Palo Alto Hills as high or very high Fire Hazard Severity Zones. The maps are like flood zone maps, noting factors such as fire history, existing and potential fuel (natural vegetation), terrain and weather patterns.
Our local fire agency does not control the creation of the map but is required to ensure the community can review and provide feedback within 30 days of the map's release, and within 120 days, the City Council is required to adopt the ordinance approving the map designations.
Public Comment period is now open through April 26, 20251, and the maps will tentatively be brought forward to the City Council for approval on June 2, 2025.
This map can affect land use planning, building codes, and wildfire mitigation strategies. The maps could also trigger additional inspections by the Palo Alto Fire Department and weed abatement requirements to increase wildfire protection and safety. They will also improve our hazard analysis as it pertains to the City’s Community Wildfire Protection Plan/Foothills Fire 1 State Fire Hazard Maps Released for Public Comment: https://www.cityofpaloalto.org/News-Articles/City- Manager/Palo-Alto-Begins-Wildfire-Preparedness-Public-Discussions Item 3
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Management Plan efforts, Local Hazard Mitigation planning, Comprehensive Plan programs and policies, and community education to reduce personal exposure and risk. The Electric Utility Engineering will be evaluating grid hardening measures in the expanded zones including the alternative to move the overhead electric lines undergrounding to mitigate wildfire risk.
Utilities Wildfire Mitigation Plan 2025 Update: Annually, staff work to review and update the Palo Alto Utilities Wildfire Mitigation Plan and present it to the Utilities Advisory Commission for approval, currently expected by the end of FY 2025. This plan, in compliance with Public Utilities Code section 8387, describes how the utility is to maintain and operate electrical lines and equipment to mitigate wildfire risk posed by electric lines and equipment. The City strives to ensure that its infrastructure is safe and resilient by taking proactive actions to maintain its equipment, refine the existing Public Safety Power Shutoff (PSPS) protocols as needed, and underground the electric lines in the only high fire threat area. As part of the Wildfire Mitigation Plan 2025 Update, Palo Alto Utilities will be expanding the Public Safety Power Shutoff Communications to customers that fall within the expanded State Fire Marshall’s Fire Hazard Severity Zones.
Multijurisdictional Approach:
When planning for an emergency event as significant as a wildfire, a multi-jurisdictional approach is critical, as no agency possesses the resources to successfully address an emergency event such as this independently. Staff is working on various efforts with other partner agencies and entities, which include not only emergency planning, but also early warning technology, and updating operational and procedural elements within the City organization to mitigate the risks associated with a fire in the foothills.
Regional Training: In June 2024, the Palo Alto Fire Department teamed up with Mountain View Fire, San Jose Fire, Santa Clara County Fire, and Alameda Fire agencies for an annual Wildland Safety Drill at Foothills Nature Preserve. This drill was all about sharpening skills in operational efficiency, communication, safety procedures, and resource familiarization, especially in the event where mutual aid is needed. This type of practice is vital to ensure that our teams are ready to seamlessly support each other. Efforts are already underway for a Santa Clara county- wide wildland training in May 2025.
Santa Clara County FireSafe Council: Staff is pursuing a service agreement to perform the schedule of required treatments each year in conjunction with some educational support. The Fire Department and OES are in the process of evaluating certain remote fire detection equipment in cooperation with the FireSafe Council and local partner agencies as well.
Tabletop Exercise: Staff are working to support efforts by the Santa Clara District - Division of Drinking Water of the State Water Resources Control Board (SWRCB) to perform a tabletop exercise of the water utility prior to the 2025 wildfire season.
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Prevention Efforts:
Fuel Reduction Activities: The City is contracting with the Santa Clara County FireSafe Council to perform fuel reduction along Page Mill Road and Arastradero Road in 2024 and pursuing a multi-year contract for broader fuel reduction work over a 3-5 year time horizon. Additionally, the Public Works department completed fuel reduction work prescribed in the FFMP for Los Trancos Road in May 2024 and the Community Services Department is performing the annual treatments2 in Arastradero and Foothills Nature Preserves. Staff expects to request additional capital funding in FY 2026 to continue to address eucalyptus tree fuel reduction.
Palo Alto Fire Department has completed their annual wildfire urban interface (WUI) residential inspections in 2024 and Utilities continues to prioritize vegetation management around power lines to prevent contact and potential ignitions.
Installed Sensor Technology: Twelve N5 Sensors3 were installed in the Foothills to detect the earliest stages of wildland fire, as well as track fire movement, smoke and monitor hazardous air quality. PAFD and OES are collaborating with the Santa Clara County FireSafe Council, Woodside Fire Protection District, Stanford University and the Department of Homeland Security to install a total of 50 sensors in the wildland urban interface areas in Palo Alto, Stanford and Woodside Fire District.
Utility Systems (electricity & water) Hardening & Backup: Hardening of the electric system in the WUI may include but is not limited to replacing overhead lines with underground cables and upgrading equipment to improve reliability. Both the significant investment in modernizing the electricity grid and undergrounding the electricity transmission line in the foothills are significant infrastructure adaptations to harden the system to wildfire risks. An easement for continuing to underground the transmission line in the foothills is expected to return to Council in June 2025 after approval by Mid-Peninsula Open Space Agency. Two new portable diesel backup generators were purchased in January 2025 for the Park and Dahl Foothill Booster Water Pump Stations ensuring there are now portable generators at all five Foothill Booster Water Pump Stations.
Summary and Response to the Emergency Preparedness – Wildfire Audit Baker Tilly, in its capacity serving as the Office of the City Auditor (OCA), performed a citywide risk assessment that assessed a wide range of risk areas, including strategic, financial, operational, compliance, technological, and reputation risks. The purpose of the assessment was to identify and prioritize risks to develop the annual audit plan. Recognizing the need for an 2 Treatments refers to reduction in fuel, or vegetation and other combustible materials, and the management of the fuel through strategies such as mowing, clearing, or even animal grazing to reduce the fuel available. 3 Wildfire Sensors: https://www.cityofpaloalto.org/Departments/Fire/Prepare-For-Wildfire-READY-SET- GO/Wildfire-Sensors
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independent assessment of the City's wildfire preparedness, BakerTilly conducted an audit in alignment with its 2024 Risk Assessment and subsequent Council approved workplan.
The objective of the Emergency Preparedness – Wildfire Audit aimed to determine whether the City is adequately prepared to prevent and respond to wildfires as part of its overall emergency management plan. The attached BakerTilly Audit Report (Attachment A) provides a detailed analysis of the City's current practices and recommendations for improvement. The OCA interviewed staff, reviewed policies and procedures as well as FEMA and CAL FIRE standards and best practices to complete this audit work.
The BakerTilly Audit Report highlights two findings:
1. While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
2. Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning, training, after action report recommendation implementation, and communication efforts.
The attached report summarizes the analysis, audit findings, and recommendations. The audit identified areas for further improvement in evacuation planning and enhancing community engagement regarding these activities. Management has provided responses in the Appendix.
NEXT STEPS
As noted in the summary, the City is preparing a series of engagements regarding wildfire preparedness and fire services. The calendar below provides a summary of engagements expected discussing fire services, wildfire activities, emergency services planning, and utilities activities.
Month Activity
March •California Fire Marshal updated wildfire risk maps for public comment (released on City webpage 3/26)
April •Finance Committee review Fire Department Staffing Options on April 1 4, continuing discussion from November 2024 exploring changes to enhance fire and ambulance service delivery.
•Policy & Services review of Emergency Preparedness - Wildfire Audit on April 8. •State Fire Hazard Map public comment period is now open through April 26. Council will consider adoption of an ordinance incorporating map designations tentatively on June 2.
May •Utilities Advisory Commission will review the 2025 Utilities Wildfire Mitigation Plan at their meeting in May or June.
4 Finance Committee, April 1, 2025, Agenda Item #3,
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•Finance Committee will review the preliminary Fiscal Year 2026 operating and capital budget recommendations on May 6 and 7, including fire staffing budget proposals, and capital funding to advance additional wildfire fuel reduction in the City’s Open Space Preserves.
June /
summer
•City Council will consider approval of an easement in the Palo Alto foothills to support continued undergrounding of the electric transmission line (upon approval by Mid- Peninsula Open Space District).
•The City’s Foothills Fire Management Plan updates and the Santa Clara County Community Wildfire Protection Plan, a combined effort, will be finalized. •City Council will hold annual hearing on properties assessed for Weed Abatement work.
Beyond •City Council adoption of the updated Emergency Operations Plan
FISCAL/RESOURCE IMPACT
Implementing activities such as hardening systems and undergrounding the electricity transmission line in the foothills are within existing capital improvement plans and funding.
Acquisition of new equipment and technology is reviewed and evaluated as it arises in the context of the various plans, most currently as part of the Foothills Fire Management Plan/Community Wildfire Protection Plan (FFMP/CWPP) a multi-year plan.
The City will also explore potential funding sources, such as grants from federal and state agencies, to offset the costs of implementing wildfire preparedness plans.
The timeline and resource needs for implementation of management’s corrective action plans are identified by management within the attached responses.
STAKEHOLDER ENGAGEMENT
The Office of the City Auditor worked with and would like to thank several departments for their assistance in conducting this audit including: City Manager’s Office, Public Works, Fire Department, Office of Emergency Services, and Palo Alto Utilities.
ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by CEQA because reviewing and approving audit findings is an organizational or administrative activity of government that will not result in direct or indirect physical changes in the environment. CEQA Guidelines section 15378(b)(5).
ATTACHMENTS
Attachment A: Emergency Preparedness - Wildfire Audit Report APPROVED BY:
Kate Murdock, City Auditor & Kiely Nose, Assistant City Manager Item 3
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: City Clerk
Meeting Date: June 16, 2025
Report #:2505-4751
TITLE
Recommendation that the City Council to Refer to the Policy and Services Committee an Update to the City of Palo Alto Advocacy Process Manual to Address Sponsorship of Legislation; CEQA – Not a Project
RECOMMENDATION
The Policy and Services Committee recommends that the City Council refer to the Policy and Services Committee an update to the City of Palo Alto Advocacy Process Manual to address sponsorship of legislation and any other recommended changes to the Advocacy Manual, and return to City Council for adoption.
BACKGROUND AND ANALYSIS
At the April 8, 2025 Policy and Services1 meeting, the Committee discussed legislation and also expressed an interest in reviewing the City’s advocacy process manual for edits, specifically as it relates to the process for legislation sponsorship. The Policy and Services Committee would review this topic with the following resources as a starting place:
Existing Legislative Guidelines: https://www.cityofpaloalto.org/files/assets/public/v/1/city- manager/legislation/2025-legislative-guidelines.pdf
Existing City Advocacy Manual:
https://www.paloalto.gov/files/assets/public/v/1/intergovernmental-affairs/advocacy-manual- updated-jan-2020.pdf
Most Recent Council Direction Regarding Strategic Weighing in on Legislation:
https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city- manager-reports-cmrs/year-archive/2021/id-12344.pdf
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The Committee is interested in updating the Advocacy Manual to be most reflective of current practices on advocacy and to also clarify the City’s process and timelines when deciding to pursue bill sponsorship. This discussion item can be taken concurrent with the update to the Legislative Guidelines or it can come before that, at the discretion of the Committee Chair. The Committee will bring the updated advocacy manual to the City Council for review and adoption.
FISCAL/RESOURCE IMPACT
There is no known resource impact to the committee discussing this topic. There could be resource impacts to existing staff depending on the extent of the proposed changes.
STAKEHOLDER ENGAGEMENT
There will be opportunity for public comment during the Policy and Services Committee meeting on this topic.
ENVIRONMENTAL REVIEW
Not a project.
APPROVED BY:
Ed Shikada, City Manager
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City Council
Staff Report
From: City Auditor
Report Type: CONSENT CALENDAR
Lead Department: City Auditor
Meeting Date: June 16, 2025
Report #:2505-4756
TITLE
Policy & Services Committee Recommends Approval to Amend the City Auditor Bakertilly FY2024 and FY2025 Budgets for Task Orders to Realign the Authorized Budgets with a Net Zero Impact; CEQA - Not a Project
RECOMMENDATION
The City Auditor and the Policy & Services Committee recommend City Council approve the amendment of the FY 2024 and FY2025 Task Orders to realign the authorized budgets with a net zero impact overall:
•FY 2025 Task 4.32: CSD Equipment and Materials Inventory Management reduced by $20,000
•FY 2024 Task 4.25: Emergency Preparedness – Wildfire increased by $5,000 •FY 2024 Task 4.28: Dispatch Center Assessment increased by $15,000
BACKGROUND
In accordance with our agreement with the City, Baker Tiily is required to conduct recurring activities each year. Task 4: Execute the Annual Audit Plan comprises the majority of our budget and time. Specific audit task orders are approved annually by the Council and executed by the Policy & Services Committee (P&S) Chair as the Project Manager for the Baker Tilly contract as stipulated in the contract terms.
ANALYSIS
The Office of the City Auditor (OCA) presented the recommended task order changes to the Policy & Services Committee on May 13, 2025. The Committee unanimously recommended that the City Council approve the amendments to the FY 2024 and FY 2025 Task Orders.
For FY 2024, two audit activities, Task Order 4.25: Emergency Preparedness (Wildfire) Audit and Task Order 4.28: Dispatch Center Assessment were included as part of the Annual Audit Plan.
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Both of these audits required a high degree of complexity in terms of research and analysis. The approved budgets for executing these task orders was not sufficient. The Office of the City Auditor wrote off some expenses for both of these projects. However, as these projects had extended reporting periods necessitating multiple management reviews and extending project work into 2025, the Office of the City Auditor is seeking to transfer unused funds from an FY 2025 Task Order, Task Order: 4.32 CSD Equipment & Materials Inventory Management Audit, to defray these additional costs. No change to the overall FY2025 budget is requested. •Task 4.25: Emergency Preparedness (Wildfire) – increase budget by $5,000 •Task 4.28: Dispatcher Center Assessment – increase budget by $15,000 •Task 4.32: CSD Equipment & Materials Inventory Management – reduce budget by $20,000
FISCAL/RESOURCE IMPACT
Work recommended in these tasks is within both the approved scope and compensation of the contract with Baker Tilly and funding levels in the FY2024 and FY2025 Operating Budgets for the Office of the City Auditor.
ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by CEQA because the audit activities do not involve any commitment to any specific project which may result in a potentially significant physical impact on the environment. CEQA Guidelines section 15378(b)(4).
ATTACHMENTS
Attachment A: Task Orders 4.25, 4.28, and 4.32
APPROVED BY:
Kate Murdock, City Auditor
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PROFESSIONAL SERVICES TASK ORDER
TASK ORDER FY24-4.25 Emergency Preparedness
Consultant shall perform the Services detailed below in accordance with all the terms and conditions of the Agreement referenced in Item 1A below. All exhibits referencedFY24 in Item 8 below are incorporated into this Task Order by this reference. The Consultant shall furnish the necessary facilities, professional, technical and supporting personnel required by this Task Order as described below.
CONTRACT NO. C21179340A
OR PURCHASE ORDER REQUISITION NO. (AS APPLICABLE)
1A.
1B.
MASTER AGREEMENT NO. (MAY BE SAME AS CONTRACT / P.O. NO. ABOVE): C21179340A TASK O RDER NO.: FY23-4.25
2. CONSULTANT NAME: Baker Tilly Advisory Group, LP
3. PERIOD OF PERFORMANCE: START: March 1, 2024 COMPLETION: December 31, 2024 4 TOTAL TASK ORDER PRICE: $73,110 $75,110.00 Increased by $2,000.00
BALANCE REMAINING IN MASTER AGREEMENT/CONTRACT TBD
5. BUDGET CODE_______________
COST CENTER________________
COST ELEMENT______________
WBS/CIP__________
PHASE__________
6. CITY PROJECT MANAGER’S NAME & DEPARTMENT:
Lydia Kou, Chair of the City Council’s Policy and Services Committee
7. DESCRIPTION OF SCOPE OF SERVICES (Attachment A)
MUST INCLUDE:
SERVICES AND DELIVERABLES TO BE PROVIDED
SCHEDULE OF PERFORMANCE
MAXIMUM COMPENSATION AMOUNT AND RATE SCHEDULE ( as applicable) REIMBURSABLE EXPENSES, if any (with “not to exceed” amount)
8. ATTACHMENTS: A: Task Order Scope of Services B (if any): N/A I hereby authorize the performance of the
work described in this Task Order.
APPROVED:
CITY OF PALO ALTO
BY:____________________________________
Name __________________________________
Title_ ___________________
Date ___________________________________
I hereby acknowledge receipt and acceptance of
this Task Order and warrant that I have
authority to sign on behalf of Consultant.
APPROVED:
COMPANY NAME: ______________________
BY:____________________________________
Name __________________________________
Title___________________________________
Date ___________________________________
Docusign Envelope ID: E008AC75-7AE6-49DD-B29E-91EE8C83AC25 Baker Tilly Advisory Group, LP
12/23/2024
Manager/ City Auditor
Kate Murdock
12/25/2024
Council Member
Council Member Lydia Kou
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Attachment A
DESCRIPTION OF SCOPE OF SERVICES
Introduction
Attachment A, the Description of Scope of Services, contains the following four (4) elements:
Services and Deliverables To Be Provided
Schedule of Performance
Maximum Compensation Amount and Rate Schedule (As Applicable) Reimbursable Expenses, if any (With “Not To Exceed” Amount) Services & Deliverables
Baker Tilly’s approach to conducting an internal audit of Emergency Preparedness involves three (3) primary steps:
Step 1: Audit Planning
Step 2: Control Review and Testing
Step 3: Reporting
Step 1 – Audit Planning
This step consists of the tasks performed to adequately plan the work necessary to address the overall audit objective and to solidify mutual understanding of the audit scope, objectives, audit process, and timing between stakeholders and auditors. Tasks include:
Gather information to understand the environment under review o Understand the organizational structure and objectives o Review the City code, regulations, and other standards and expectations o Review prior audit results, as applicable
o Review additional documentation and conduct interviews as necessary Assess the audit risk
Write an audit planning memo and audit program
o Refine audit objectives and scope
o Identify the audit procedures to be performed and the evidence to be obtained and examined
Announce the initiation of the audit and conduct kick-off meeting with key stakeholders
o Discuss audit objectives, scope, audit process, timing, resources, and expectations
o Discuss documentation and interview requests for the audit Docusign Envelope ID: E008AC75-7AE6-49DD-B29E-91EE8C83AC25 Item 5
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Step 2 – Control Review and Testing
This step involves executing the procedures in the audit program to gather information, interview individuals, and analyze the data and information to obtain sufficient evidence to address the audit objectives. The preliminary audit objective is to determine whether the City is working to prevent wildfire and adequately prepared to respond to wildfire as part of the City’s emergency management plan. Procedures include, but not limited to:
Interview the appropriate individuals in all relevant departments to gain an understanding of the organizational structure, processes, and controls related to wildfire prevention and response as well as the City’s overall emergency preparedness.
Review policies and procedures as well as the legislative and regulatory requirements to identify the criteria to be used for evaluation of control design and effectiveness. Review the existing emergency management plan and other related documents such as prevention activities, training and exercises, equipment, and service contracts. Compare the process and controls against the best practices.
Step 3 – Reporting
In Step 3, the project team will perform tasks necessary to finalize audit working papers, prepare and review a draft report with the stakeholders, and submit a final audit report. Tasks include:
Develop findings, conclusions, and recommendations based on the supporting evidence gathered
Validate findings with the appropriate individuals and discuss the root cause of the identified findings
Complete supervisory review of working papers and a draft audit report Distribute a draft audit report and conduct a closing meeting with key stakeholders o Discuss the audit results, finings, conclusions, and recommendations o Discuss management responses
Obtain written management responses and finalize a report Review report with members of City Council and/or the appropriate Council Committee
Deliverables:
The following deliverable will be prepared as part of this engagement:
Audit Report
Schedule of Performance
Anticipated Start Date: March 1, 2024
Anticipated End Date: December 31, 2024
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Maximum Compensation Amount and Rate Schedule
The not-to-exceed maximum, inclusive of reimbursable expenses (as summarized below) for this Task is $73,110. The not-to-exceed budget is based on an estimate of 385 total project hours, of which 25 are estimated to be completed by the City Auditor.
Reimbursable Expenses
We plan to complete all work remote including all interviews and documentation review.
However, during the planning and fieldwork phases of this audit, the City and Baker Tilly may mutually determine it will be beneficial to perform a portion of the work on-site. Given this possibility, Baker Tilly could incur reimbursable expenses for this Task.
The not-to-exceed maximum for reimbursable expenses for this Task is $6,500.
The following summarizes anticipated reimbursable expenses:
Round-trip Airfare – $2,000 (1 round trip flights x 2 auditors) Ground Transportation (car rental or Uber/taxi) - $800 Hotel accommodation - $3,000 (2 rooms x 4 nights)
Food and incidentals – $700
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PROFESSIONAL SERVICES TASK ORDER
TASK ORDER FY24-4.28 Dispatch Center Program
Consultant shall perform the Services detailed below in accordance with all the terms and conditions of the Agreement referenced in Item 1A below. All exhibits referenced in Item 8 below are incorporated into this Task Order by this reference. The Consultant shall furnish the necessary facilities, professional, technical and supporting personnel required by this Task Order as described below.
CONTRACT NO. C21179340A
OR PURCHASE ORDER REQUISITION NO. (AS APPLICABLE)
1A. MASTER AGREEMENT NO. (MAY BE SAME AS CONTRACT / P.O. NO. ABOVE): C21179340 1B. TASK O RDER NO.: FY24-4.28
2. CONSULTANT NAME: Baker Tilly Advisory Group, LP
3. PERIOD OF PERFORMANCE: START: August 15, 2024 COMPLETION: February 28, 2025
4. TOTAL TASK ORDER PRICE: $76,540 $79,040 Increased by $2,500.00
BALANCE REMAINING IN MASTER AGREEMENT/CONTRACT TBD
5. BUDGET CODE_______________
COST CENTER________________
COST ELEMENT______________
WBS/CIP__________
PHASE__________
6. CITY DEPARTMENT PROJECT MANAGER’S NAME & Lydia Kou, Chair of the City Council’s Policy and Services Committee
7. DESCRIPTION OF SCOPE OF SERVICES (Attachment A)
MUST INCLUDE:
SERVICES AND DELIVERABLES TO BE PROVIDED
SCHEDULE OF PERFORMANCE
MAXIMUM COMPENSATION AMOUNT AND RATE SCHEDULE (as applicable)
8. ATTACHMENT REIMBURSABLE EXPENSES, if a Task Order Scope any of Service “not to exceed” (with amount) B (if any): N/A
9. I hereby authorize the performance of the work
described in this Task Order.
APPROVED:
CITY OF PALO ALTO
BY:____________________________________
Name __________________________________
Title_ _____________________
Date __________________________
I hereby acknowledge receipt and acceptance of this
Task Order and warrant that I have authority to sign
on behalf of Consultant.
APPROVED:
COMPANY NAME: Baker Tilly Advisory Group, LP
BY:____________________________________
Name __________________________________
Title___________________________________
Date _ _________________________
Docusign Envelope ID: E008AC75-7AE6-49DD-B29E-91EE8C83AC25 Kate Murdock
Manager/ City Auditor
12/23/2024
Council Member
12/25/2024
Council Member Lydia Kou
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Attachment A
DESCRIPTION OF SCOPE OF SERVICES
Introduction
Attachment A, the Description of Scope of Services, contains the following four (4) elements:
Services and Deliverables To Be Provided
Schedule of Performance
Maximum Compensation Amount and Rate Schedule (As Applicable) Reimbursable Expenses, if any (With “Not To Exceed” Amount) Services & Deliverables
Baker Tilly’s approach to conducting an assessment of the Dispatch Center Program involves three (3) primary steps:
Step 1: Assessment Planning
Step 2: Control Review and Testing
Step 3: Reporting
Step 1 – Assessment Planning
This step consists of the tasks performed to adequately plan the work necessary to address the overall assessment objective and to solidify mutual understanding of the project scope, objectives, process, and timing between stakeholders and auditors. Tasks include:
Gather information to understand the environment under assessment o Understand the organizational structure and objectives o Review the City code, regulations, and other standards and expectations o Review prior audit and/or assessment results, as applicable o Review additional documentation and conduct interviews as necessary Write an assessment program
o Refine objectives and scope
o Identify the assessment procedures to be performed and the evidence to be obtained and examined Announce initiation of the assessment and conduct kick-off meeting with key stakeholders o Discuss objectives, scope, assessment process, timing, resources, and expectations o Discuss documentation and interview requests for the assessment Step 2 – Control Review and Testing
This step involves executing the procedures in the assessment program to gather information, interview individuals, and analyze the data and information to obtain sufficient evidence to address the audit objectives. The preliminary assessment objective is to: (1) Determine whether the City’s Dispatch Center Program is operating efficiently and effectively to meet community needs. Procedures include, but are not limited to:
Interview the appropriate individuals to gain an understanding of the organizational structure, processes, and controls related to the Dispatch Center Program.
Review policies and procedures as well as the legislative and regulatory requirements to identify the criteria to be used for evaluation of control program effectiveness. Review overall Dispatch Center Program performance, including selecting a sample of Dispatch Center Calls to test for efficiency and effectiveness of response and triage for services. Compare the performance, process, and controls against the best practices.
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Ste p 3 – Reporting
In Step 3, the project team will perform tasks necessary to finalize assessment working papers, prepare and review a draft report with the stakeholders, and submit a final report. Tasks include:
Develop findings, conclusions, and recommendations based on the supporting evidence gathered Validate findings with the appropriate individuals and discuss the root cause of the identified findings Complete supervisory review of working papers and a draft report Distribute a draft report and conduct a closing meeting with key stakeholders o o Discuss the results, finings, conclusions, and recommendations o Discuss management responses
Obtain written management responses and finalize a report Review report with members of City Council and/or the appropriate Council Committee Deliverables:
The following deliverable will be prepared as part of this engagement:
Report
Schedule of Performance
Anticipated Start Date: August 15, 2024
Anticipated End Date: February 28, 2025
Maximum Compensation Amount
The not-to exceed maximum, inclusive of reimbursable expenses (as summarized below) for this Task is $76,540. The not-to exceed budget is based on an estimate of 415 total project hours, of which 100 are estimated to be completed by the City Auditor.
Reimbursable Expenses
If circumstances allow, Baker Tilly anticipates planning one on-site fieldwork week. Given this possibility, Baker Tilly could incur reimbursable expenses for this Task.
The not-to-exceed maximum for reimbursable expenses for this Task is $8,500 The following summarizes anticipated reimbursable expenses (for three team members):
Round-trip Airfare - $2,000 (3 round trip flights)
Ground Transportation (car rental or Uber/taxi) - $1,500 Hotel Accommodation - $3,500 (12 nights)
Food and incidentals - $1,500
Confidential Information
1. In the performance of this Task Order, Baker Tilly (“AUDITOR”) may have access to CITY’s Confidential Information (defined below). AUDITOR will hold Confidential Information in strict confidence, not disclose it to any third party, and will use it only for the performance of its obligations to CITY under this Task Order and for no other purpose. AUD ITOR will maintain reasonable and appropriate administrative, technical and physical safeguards to ensure the security, confidentiality and integrity of the Confidential Information. This includes the use of encrypted, access- controlled storage for any Co nfidential Information stored in electronic form. Notwithstanding the foregoing, AUDITOR Docusign Envelope ID: E008AC75-7AE6-49DD-B29E-91EE8C83AC25 Item 5
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may disclose Confidential Information to its employees, agents and subcontractors, if any, only to the extent they have a need to know in order to perform AUDITOR’s obligations to CITY under this Task Order and for no other purpose, and provided that the AUDITOR informs them of, and requires them to follow, the confidentiality and security obligation s of this Task Order.
2. “Confidential Information” means all data, information, and materials of a non-public, proprietary or confidential nature, in any form or medium, tangible or intangible, provided or otherwise made available to AUDITOR by CITY, directly or indirectly, pursuant to this Task Order. For this Task Order, such Confidential Information may include dispatch calls, dispatch radio/phone traffic (including recordings, summaries, and transcripts of such traffic), dispatch logs and computer-aided dispatch (CAD) data, observations of the dispatch service (including recordings, summaries, notes, and transcripts of such observation), any information protected by law obtained by AUDITOR in conducting this Task Order (including but not limited to criminal background data, customer utility data, medical information, mental health conservatorship data, witness and victim identities protected by law, law enforcement intelligence, law enforcement investigations, law enforcement personnel file information protected by law, and “Personal Information” about a California resident as defined in Civil Code Section 1798 et seq., as amended from time to time) ). In addition to the Confidential Information itself, AUDITOR agrees that deliberations, conversations a nd discussions pertaining to the Confidential Information shall be kept confidential and shall not be disclosed without approval of CITY, and any required reporting incorporating Confidential Information will present findings in de-identified or summary formats as agreed by the Parties.
2.1. Exceptions: Confidential Information excludes information that AUDITOR can show by appropriate documentation: (i) was publicly known at the time it was provided or has subsequently become publicly known other than by a breach of this Agreement and is not otherwise protected from further sharing by law; (ii) was rightfully in AUDITOR’s possession free of any obligation of confidence prior to receipt of Confidential Information; (iii) is rightfu lly obtained by AUDITOR from a third party without breach of any confidentiality obligation; (iv) is independently developed by employees of AUDITOR without any use of or access to the Confidential Information; or (v) AUDITOR has written consent to disclose signed by an authorized representative of CITY.
2.2 Confidential Markings: As practicable, the Confidential Information shall be marked with the words “Confidential” or “Confidential Material” or with words of similar import. To the extent possible, t he disclosing party (whether CITY or AUDITOR) shall endeavor to mark any electronic document intended to be covered by the terms of these confidentiality provisions with the words “Confidential” or similar words, shall notify the receiving parties (for example, by cover e -mail transmitting the electronic document) that the electronic document is Confidential Information, and, for documents shared via encrypted cloud storage, shall file such Confidential Information in folders so labeled. The City’s failure, for whatever reason, to mark any material at the time it is produced to the AUDITOR, or to notify AUDITOR that oral or electronic material is Confidential Information at the time it is provided, shall not remove the material from the coverage of these confidentiality obligations, and the AUDITOR shall treat the material as Confidential Information once the CITY has notified it that the material is to be covered by these provisions.
3. Notwithstanding the foregoing, AUDITOR may disclose Confidential Infor mation to the extent required by order of a court of competent jurisdiction or governmental body, provided that AUDITOR will notify CITY in writing of such order immediately upon receipt and prior to any such disclosure (unless AUDITOR is prohibited by law from doing so), to give CITY an opportunity to oppose or otherwise respond to such order.
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4. AUDITOR will notify City promptly upon learning of any breach in the security of its systems or unauthorized disclosure of, or access to, Confidential Informati on in its possession or control, and if such Confidential Information consists of Personal Information, AUDITOR will provide information to CITY sufficient to meet the notice requirements of Civil Code Section 1798 et seq., as applicable, as amended from time to time.
5. Prior to or upon termination or expiration of this Task Order, AUDITOR will honor any request from the CITY to return or securely destroy all copies of Confidential Information. All Confidential Information is and will remain the property of the CITY and nothing contained in this Agreement grants or confers any rights to such Confidential Information on AUDITOR. Notwithstanding the return or destruction of tangible Confidential Information as contemplated by this subsection, AUDITOR and its representatives will continue to be bound by all obligations of confidentiality with respect to the CITY’s Confidential Information.
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16 PROFESSIONAL SERVICES TASK ORDER
TASK ORDER FY25-4.32 CSD Equipment and Materials Inventory Management Consultant shall perform the Services detailed below in accordance with all the terms and conditions of the Agreement referenced in Item 1A below. All exhibits referenced in Item 8 below are incorporated into this Task Order by this reference. The Consultant shall furnish the necessary facilities, professional, technical and supporting personnel required by this Task Order as described below.
CONTRACT NO. C21179340A
OR PURCHASE ORDER REQUISITION NO. (AS APPLICABLE)
1A. MASTER AGREEMENT NO. (MAY BE SAME AS CONTRACT / P.O. NO. ABOVE): C21179340A 1B. TASK ORDER NO.: FY25-4.32
2. CONSULTANT NAME: Baker Tilly Advisory Group, LP
3. PERIOD OF PERFORMANCE: START: January 1, 2025 COMPLETION: June 30, 2025
4. TOTAL TASK ORDER PRICE: $89,900
BALANCE REMAINING IN MASTER AGREEMENT/CONTRACT TBD
5. BUDGET CODE_______________ COST CENTER________________ COST ELEMENT______________ WBS/CIP__________ PHASE__________
6. CITY PROJECT MANAGER’S NAME & DEPARTMENT:
Lydia Kou, Chair of the City Council’s Policy and Services Committee
7. DESCRIPTION OF SCOPE OF SERVICES (Attachment A)
MUST INCLUDE:
SERVICES AND DELIVERABLES TO BE PROVIDED
SCHEDULE OF PERFORMANCE
MAXIMUM COMPENSATION AMOUNT AND RATE SCHEDULE (as applicable) REIMBURSABLE EXPENSES, if any (with “not to exceed” amount)
8. ATTACHMENTS: A: Task Order Scope of Services B (if any): N/A I hereby authorize the performance of the work
described in this Task Order.
APPROVED:
CITY OF PALO ALTO
BY:____________________________________
Name __________________________________
Title___________________________________
Date ___________________________________
I hereby acknowledge receipt and acceptance of
this Task Order and warrant that I have authority
to sign on behalf of Consultant.
APPROVED:
COMPANY NAME: Baker Tilly Advisory Group,
LP
BY:____________________________________
Name __________________________________
Title___________________________________
Date ___________________________________
Docusign Envelope ID: F60E09CC-400F-404E-8132-93318BE5ADE6 Kate Murdock
12/23/2024
Manager/ City Auditor
Council Member
Council Member Lydia Kou
12/25/2024
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17 Attachment A
DESCRIPTION OF SCOPE OF SERVICES
Introduction
Attachment A, the Description of Scope of Services, contains the following four (4) elements:
Services and Deliverables To Be Provided
Schedule of Performance
Maximum Compensation Amount and Rate Schedule (As Applicable) Reimbursable Expenses, if any (With “Not To Exceed” Amount) Services & Deliverables
Baker Tilly’s approach to conducting an internal audit of the Community Services Department Equipment and Materials Inventory Management three (3) primary steps:
Step 1: Audit Planning
Step 2: Fieldwork and Testing
Step 3: Reporting
Step 1 – Audit Planning
This step consists of the tasks performed to adequately plan the work necessary to address the overall audit objective and to solidify mutual understanding of the audit scope, objectives, audit process, and timing between stakeholders and auditors. Tasks include:
Gather information to understand the environment under review o Understand the environment under assessment
o Assess the City code, regulations, and other standards and expectations o Assess prior audit results, as applicable
o Assess additional documentation and conduct interviews as necessary Assess the audit risk
Prepare an audit planning memo and audit program
o Refine audit objectives and scope
o Identify the audit procedures to be performed and the evidence to be obtained and examined Announce the initiation of the audit and kick-off meeting with key stakeholders o Discuss audit objectives, scope, audit process, timing, resources, and expectations o Discuss documentation and interview requests for the audit Step 2 – Fieldwork and Testing
The step involves executing the procedures in the audit program to gather information, interview individuals, and analyze the data and information to obtain sufficient evidence to address the audit objectives The preliminary audit objective is to determine if the Community Services Department Equipment and Materials Inventory Management system is operating effectively and efficiently:
Interviewing the appropriate individuals to gain an understanding of the equipment and materials inventory management system
Analyze policies and procedures related to equipment and material management and procurement to identify the criteria to be used for evaluation of control design and effectiveness Compare processes and controls against best practices Docusign Envelope ID: F60E09CC-400F-404E-8132-93318BE5ADE6 Item 5
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18 Step 3 – Reporting
In Step 3, the project team will perform tasks necessary to finalize audit working papers, prepare and review a draft report with stakeholders, and submit a final report for management response. Tasks include:
Developing findings, conclusions, and recommendations based on the supporting evidence gathered
Validating findings with appropriate individuals and discuss the root cause of the identified findings
Complete supervisory review of working papers and a draft audit report Distribute a draft audit report and conduct a closing meeting with key stakeholders o Discuss the audit results, findings, conclusions, and recommendations o Discuss management responses
Obtain written management responses and finalize a report Review report with members of City Council and/or the appropriate Council Committee Deliverables:
The following deliverables will be prepared as part of this engagement:
Audit Report
Policy & Services Committee Audit Report Presentation Schedule of Performance
Anticipated Start Date: January 1, 2025
Anticipated End Date: June 30, 2025
Maximum Compensation Amount and Rate Schedule
The not-to-exceed maximum, inclusive of reimbursable expenses (as summarized below) for this Task is $89,900.
The not-to-exceed budget is based on an estimate of 500 total project hours, of which a minimum of 40 are estimated to be completed by the City Auditor.
Reimbursable Expenses
We plan to complete all work remote including all interviews and documentation review. However, during the planning and fieldwork phases of this audit, the City and Baker Tilly may mutually determine it will be beneficial to perform a portion of the work on-site. Given this possibility, Baker Tilly could incur expenses for this Task.
The not-to-exceed maximum for reimbursable expenses for this Task is $6,500.
The following summarizes anticipated reimbursable expenses:
Round-trip Airfare – $2,000 (1 round trip flight x 2 auditors) Ground transportation – $800 (car rental or Uber/taxi) Hotel accommodation – $3,000 (2 rooms x 4 nights)
Food & Incidentals – $2,100
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Human Resources
Meeting Date: June 16, 2025
Report #:2505-4650
TITLE
Approval of the Council Appointed Officers (CAO) Committee‘s Recommendation to Approve the CAO Annual Evaluation Process, Timeline, and Questions; and Approval of Professional Services Contract Number C25193915 with the Municipal Resources Group, LLC (MRG) in an Amount Not to Exceed $208,500 for Council Appointed Officer Performance Evaluation Services for a Period of Three Years. CEQA Status - Not A Project
RECOMMENDATION
The CAO Committee recommends approval of the CAO annual evaluation process timeline, the CAO self-evaluation questions and Council interview questions for the annual evaluation process (Attachment A), and staff recommends that the City Council approve and authorize the Mayor or designee to execute Contract Number C25193915 with MRG (Attachment B), to provide CAO performance evaluation services, for a three year term, and a total amount not to exceed $208,500, including $144,000 for basic services and $64,500 for additional services.
BACKGROUND
The City Manager, City Attorney, City Auditor and City Clerk are appointed directly by the City Council and, as such, are reviewed by the City Council on an annual basis in accordance with their individual employment agreements. The City Auditor is also appointed directly by the City Council however the City contracts for internal auditing services with Baker Tilly under the terms of the contract. Such review is necessary for Council members to ensure the efficiency of the appointed offices, to provide general feedback on their performance, to set goals for the coming year, and to identify areas of improvement. It is also necessary to review compensation to ensure that the positions are paid appropriately in comparison to the market and their performances. Given that a need exists for objectivity and facilitation as well as the time commitment in meeting with seven City Council members, the four CAO’s, and the CAO Committee, the use of an outside consultant increases efficiency.
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The Council Appointed Officers (CAO) Committee met on November 26, 20241 to review and debrief regarding the 2023-2024 CAO performance evaluation process, as well as to discuss the next steps for the CAO performance evaluation services contract. The CAO Committee strongly supported continuing with a facilitator and unanimously approved to request a proposal for services. The MRG proposal was reviewed by Mayor Lauing as well as the 2025 CAO Committee Chair, Greer Stone and the CAO Committee and was recommended for Council to approve services to be negotiated with MRG.
ANALYSIS
In June 2018, the Council approved a one-year contract (C18172268) with Municipal Resources Group (MRG) for CAO performance evaluation services for one-year term through June 20, 20192. This contract had the option to extend the term for up to two additional years through 2022. Council then approved a three-year contract extension (C22185281) with this current contract ending June 20, 2025 with a total annual cost of $51,200 and a not-to-exceed amount of $153,600.
On April 7, 20253, the CAO Committee recommended to the Council that the CAO Committee Chair negotiate a new professional services contract with MRG for the CAO performance evaluation services with the existing consultant and facilitator. The Council approved (passed 7- 0). The new professional services contract with MRG in an amount not to exceed $208,500 for a period of up to three years is attached (Attachment B) and was provided to the CAO Chair for final review.
Contract Overview
The contract engages MRG to facilitate the annual performance evaluation and compensation adjustment process for the City’s four CAOs.
Scope of Services:
•Preparation of Evaluation Tools: Development of customized questionnaires in coordination with the Council CAO Committee.
•Interview & Evaluation: Individual interviews with all seven Council Members and CAOs; preparation of a comprehensive written evaluation report; facilitation of evaluation discussions during closed sessions.
•Compensation Review: Recommendations to Council CAO Committee and assistance in compensation discussions and negotiations.
1 CAO Committee Meeting, November 26, 2024, Action Item #2, Special Meeting https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16465 2 City Council Meeting, June 25, 2018, Item #9148, https://www.paloalto.gov/files/assets/public/v/1/agendas- minutes-reports/reports/city-manager-reports-cmrs/year-archive/2018/id-9148.pdf 3 City Council, April 7, 2025, Agenda Item #14, SR #2503-4356, https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16024 Item 6
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•Optional Additional Services:
1.Executive Salary Analysis (compensation benchmarking from comparable jurisdictions)
2.Direct Reports Feedback (360-degree evaluation from senior staff using an online survey tool)
Following this, the CAO Committee met on May 12, 20254 to review and discuss the timeline for the annual evaluation process, to review the CAO self-evaluation questions and the Council interview questions and give direction to the evaluation process facilitator. The CAO Committee agreed with the timeline proposed and made suggestions to each of the CAO self-evaluation questions and Council interview questions as seen in Attachment A.
FISCAL/RESOURCE IMPACT
This contract is funded through the Council budget. There is no fiscal impact in FY 2026, as funds have already been allocated to cover costs for the first year of the contract. Costs for future years will be addressed through the City’s annual budget process.
STAKEHOLDER ENGAGEMENT
Public comment was made during the CAO Committee review on May 12, 2025 and opportunity was available when report was on the Council Consent agenda on April 7, 2025.
ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by CEQA because approval of and execution of a professional services contract for facilitating CAO performance evaluations is a continuing administrative activity. CEQA Guidelines section 15378(b)(2).
ATTACHMENTS
Attachment A: CAO Evaluation Timeline and Interview Materials Attachment B: Contract with Municipal Resources Group, LLC; Contract # C25193915 APPROVED BY:
Sandra Blanch, Human Resources Director
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Professional Services
Rev. Oct 16, 2024