Palo Alto City Council
October 6, 2025

300S 1st St. Suite 300A San Jose, CA 95113 | 650.830.0042 650.830.0042
TO: George Hoyt and David Chung, City of Palo Alto
FROM: Melanie Jacobson, Michelle Mann, and Leila Silver, ID360 CC: Jonathan Abendschein, Timothy Scott, Christine Luong, Evon Ballash, Julia Knight, City of Palo Alto
DATE: July 3, 2025
SUBJECT: Evaluation of CALGreen vs. LEED for Palo Alto Nonresidential Projects

BACKGROUND
At the request of the City of Palo Alto Staff Reach Code Team, ID360 conducted an evaluation comparing the performance and
requirements of nonresidential projects subject to the City’s Green Building Ordinance with the Leadership in Energy and Environmental Design Version 5 (LEED v5) rating system.

This memo evaluates three completed nonresidential construction projects in Palo Alto, examining how each aligns with LEED v5 criteria.

Each project received approval of the Building 101 Final Inspection during the current 2022 code cycle, which became effective January 1, 2023.

The goal of this study is to assess the extent to which current local building practices meet or exceed LEED standards and to identify opportunities for enhancing the City’s green building ordinance. For the 2025 building code update, staff is exploring the benefits and challenges of allowing LEED certification as an alternative compliance pathway to the City’s CALGreen Tier 1 and Tier 2 requirements. In the surrounding region, it is common for neighboring jurisdictions to require LEED certification for various building types.
1 The findings aim
to inform policy discussions and guide potential updates to strengthen environmental performance requirements for new and renovated commercial buildings.
1 Appendix C includes a comprehensive table of LEED certification requirements for 9 neighboring jurisdictions in the San Francisco Peninsula. 1 Item 10
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CALGreen Tiers and LEED Overview
Both CALGreen Tier standards and LEED certification systems establish mandatory baseline requirements (prerequisites) that each project must meet. In addition, they offer a flexible framework that allows project teams to select optional measures (electives or credits) that best align with the specific scope and goals of the project. While both systems aim to promote sustainable building practices, they differ significantly in terms of scope, intent, structure, category coverage, certification criteria, and verification processes.

It is important to note that a project that pursues LEED will have to comply with the mandatory requirements of the California Green Building Code (Title 24, Part 11), California Energy Code (Title 24, Part 6), and the City's local amendments (PAMC).

Scope and Intent
• CALGreen Tiers
o Part of California’s mandatory building code (Title 24, Part 11). o Focuses on minimum sustainability standards for energy efficiency, water conservation, material conservation, indoor air quality, and site development. o Tier 1 and Tier 2 are voluntary enhancements beyond the base CALGreen code:
2 § Tier 1 = moderate increase in performance.
§ Tier 2 = higher level of performance.
• LEED v5
o A voluntary national/international rating system administered by the U.S.

Green Building Council (USGBC).
o Broad scope that covers site selection, innovation, social equity, and operational performance.
o Offers certification levels (Certified, Silver, Gold, Platinum) based on point accumulation.

Structure and Flexibility
• CALGreen Tier 1 & Tier 2

2 The City of Palo Alto has continued to adopt CALGreen Tier 1 and Tier 2 standards for both residential and nonresidential construction projects. The level of CALGreen Tier depends on the project’s scope of work. 2 Item 10
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o Prescriptive and performance-based options but less flexible. o Limited ability to substitute measures (projects must choose specific number of electives from each category).
o Tier 1 and 2 require specific checklists and documentation for compliance. • LEED v5
o Prerequisite measures must be met based on project type. o Flexible credit-based system allowing project teams to choose how they earn points. Many options and paths available for each credit. o Encourages innovation and trade-offs across categories.

Mixed Occupancy Buildings
• CALGreen Tier 1 & Tier 2
o In a mixed occupancy building, each portion must follow the green building rules that apply to its specific use. (CALGreen Section 302.1). 3 • LEED v5
o The entire gross floor area of a LEED project must be certified under a single rating system and is subject to all prerequisites and attempted credits in that rating system, regardless of mixed construction or space usage type. o The “40/60” rule is used to determine which rating system and credits apply.

If 60% or more of the project’s gross floor area consists of a specific project type, the project must meet the requirements for that type.

Green Categories
Table 1 includes a brief summary of the general green building categories across CALGreen and the LEED v5 rating system. The LEED categories aim to drive high- performance, sustainable, and resilient buildings by addressing environmental and human health priorities. The newly released LEED v5 also emphasizes carbon tracking, equity, and climate resilience, which are not included in CALGreen. The 2022 CALGreen categories continue to focus on green building standards for sustainability, health, and resource efficiency.

3 For example, retail spaces on the first floor would comply with the nonresidential requirement of Chapter 5 and the residential dwelling units on the second and third floor would comply with the residential requirements of Chapter 4.
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Table 1: Green Building Categories
Green Category CALGreen Tiers LEED v5
Water Focuses on indoor/outdoor
efficiency, submetering
Comprehensive, including Water
Balance Table and lifecycle thinking
Materials Emphasizes VOC limits, recycled
content
Emphasizes embodied carbon, EPDs,
circularity
Indoor Air
Quality
Filtration, ventilation, low-emitting
materials
More comprehensive IAQ plans and
monitoring
Site/Location Minimal (stormwater, bike parking,
heat island)
Strong focus on location efficiency,
connectivity, resilience
Operations Cx, O&M, Not addressed post-
occupancy
Includes commissioning, metering,
ongoing performance

Certification and Verification
• CALGreen Tiers
o Verified by local code officials or third-party reviewers as part of the building permit and inspection process.
o The City of Palo Alto requires third-party Green Building Special Inspectors (GBSIs) to support the plan check and inspection compliance process for each green building project.
• LEED v5
o Third-party verified by GBCI (Green Business Certification Inc.), requiring rigorous documentation and sometimes additional modeling or commissioning.

METHODOLOGY
To conduct the evaluation, the project team analyzed existing building permit data to select three representative nonresidential projects that reflect a variety of building types and demonstrate different levels of compliance with the City’s current Green Building Ordinance. • Case Study 1: NR Tenant Improvement (Tier 1) - A nonresidential tenant improvement project subject to CALGreen Tier 1 requirements. The scope of work includes modifications of an existing 37,150 sq ft 2-story building with a one level basement, including expansion of an existing café, a new restroom block, reorganizing the existing large medium room into smaller meeting rooms, and finish updates.
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• Case Study 2: NR New Construction (Tier 2) - A two-story nonresidential core and shell construction project subject to CALGreen Tier 2 requirements. The scope of work includes a 21,933 sq ft office building over one level basement garage, site improvements, surface parking, outdoor landscape amenities, and plaza areas. The building is designed for a single tenant’s occupancy.
• Case Study 3: NR Mixed Use New Construction (Tier 2) - A three-story mixed-use new construction project subject to CALGreen Tier 2 requirements. The scope of work includes 6,995 sq ft commercial office, 19 residential dwelling units, and one level below grade parking. The project includes relevant site work, including excavation, grading, paving, landscaping, and utility connections.

Each project was evaluated using construction documents, permit records, and relevant compliance materials available in the City’s permitting software system, Accela. The team then conducted a comparative assessment of how each project would perform if it were evaluated using the LEED v5 rating system for Building Design and Construction (BD+C) or Interior Design and Construction (ID+C)
4, as appropriate.

The analysis focused on identifying which LEED prerequisites and credits would likely be met by each project based on documented compliance with the City's ordinance, and which would not. The comparison was used to assess both the stringency and the scope of the City’s green building requirements relative to LEED v5.

LEED Scorecard
As part of the evaluation of the CALGreen and LEED rating systems, the project team prepared LEED v5 Scorecards for each of the three projects included in this analysis. These scorecards reflect the most current published versions of the LEED v5 Building Design and Construction (BD+C) and Interior Design and Construction (ID+C) rating systems. The completed scorecards are provided in Appendix A for reference. Appendix B is also included for reference and outlines each prerequisite and elective measure the project

4 The U.S. Green Building Council (USGBC) launched the latest version, LEED v5, of the Leadership in Energy and Environmental Design (LEED) green building program on April 28, 2025. LEED v5 registration is now available for new construction, interior and existing commercial building projects through USGBC’s ARC platform.
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pursued to demonstrate compliance with CALGreen and the Palo Alto Municipal Code (PAMC).

The key sections of the LEED Scorecards used in the analysis are summarized below:
• LEED Credit Categories: The LEED rating system organizes the prerequisites and credits into eight categories: Integrative Process, Planning, and Assessments (IP), Location and Transportation (LT), Sustainable Sites (SS), Water Efficiency (WE), Energy and Atmosphere (EA), Materials and Resources (MR), Indoor Environmental Quality (EQ), and Project Priorities (PR).
• LEED Prerequisite/Credit: Each LEED prerequisite and credit for each credit category is listed on the scorecard.
• Yes, Maybe, No Columns: Each prerequisite and credit in the LEED Scorecards was labeled as “Yes” (Y), “Maybe” (M), or “No” (N) based on a review of the project’s approved plans, supporting documentation, GB-1 Sheet, and applicable CALGreen and Palo Alto Green Building/Energy Reach Code requirements. The assumptions informing these determinations are detailed in the “Assumptions” section of this memo.
• Notes: Brief notes have been included to provide additional context for each prerequisite and credit. Assumptions were necessary in some cases due to discrepancies between the LEED rating systems and the applicable code cycles. • Points: The scorecard summarizes the total number of “Yes” (Y), “Maybe” (M), and “No” (N) responses for each credit category. These totals are also provided at the bottom of the scorecard for overall reference. For the purpose of this evaluation, both “Yes” and “Maybe” points are counted toward estimating the project’s potential LEED certification level. LEED does not award points for prerequisites, which are mandatory for certification. However, the project team labeled prerequisites as “Yes” or “Maybe” based on information from the GB-1 Sheet and assumed compliance in alignment with LEED’s prerequisite requirements.

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ASSUMPTIONS
Several assumptions were made during the analysis in order to standardize comparisons and account for variations in project documentation and code cycles:
• Code Cycle Alignment: Two of the projects analyzed were originally permitted under earlier editions of the California Building Standards Code (Title 24, California Code of Regulations).
5 For the purpose of this study, the project team assumed these projects would comply with the most current applicable code requirements, including the 2022 Title 24 standards, CALGreen, and relevant local amendments to the Palo Alto Municipal Code (PAMC), to better align the analysis with the City’s current policy framework and regulatory environment.
• LEED Version: LEED v5 rating systems were applied based on project type:
o LEED v5 BD+C: New Construction for ground-up new buildings o LEED v5 ID+C: Commercial Interiors for tenant improvement projects Assumptions were made about standard compliance approaches (e.g., modeled performance for energy credits, prescriptive pathways for water and materials) where documentation was incomplete.
• Documentation and Credit Estimation: In cases where documentation did not explicitly demonstrate compliance with a specific LEED credit, credit achievement was estimated based on known building practices, required code compliance, or typical strategies used for similar project types.
• Standardized Interpretation: To ensure consistency across case studies, a standardized LEED v5 compliance checklist was developed and used for all three projects. The checklist reflects commonly used pathways and default thresholds unless project-specific evidence suggested otherwise.

5 Case Study 2 submitted under the 2019 building code cycle and was required to meet the City’s Green Building Ordinance 5485 and Energy Reach Code Ordinance 5481. Case Study 3 submitted under the 2016 code cycle and was required to meet the City’s Green Building Ordinance 5383 and Energy Reach Code Ordinance 5393. Case Study 1 is subject to the current 2022 code cycle and relevant local PAMC requirements.
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• Project Priorities Credit Category: At the time of this evaluation, the "Project Priorities” credit category was not yet made available to the public. Therefore, the ID360 team conservatively assumed each case study would earn 5 out the 9 credits available to each project. This assumption is based on our experience on similar projects in the region and the previous Regional Priority credit category.

These assumptions were necessary to provide a consistent and fair evaluation framework across all selected projects, especially given varying levels of documentation and the evolving nature of the City's green building requirements.

RESULTS
Case Study #1: Tenant Improvement (Tier 1)
Project Type: Nonresidential Tenant Improvement
Code Cycle: 2022
CALGreen Compliance Tier: Tier 1
LEED Rating System Used for Comparison: LEED v5 ID+C: Commercial Interiors

Scope of Work
Case Study 1 is a tenant improvement within an existing, single-tenant building. The scope includes demolition and reconstruction of non-load-bearing partitions, as well as updates to lighting and ceilings. On Level 1, the work expands the existing café, including the front-of- house seating area, back-of-house kitchen, and service line, and adds two manually operated sliding partitions. A new restroom block has also been added to meet the City of Palo Alto’s plumbing fixture requirements. On Level 2, the updates are limited to refreshing the existing pantry and converting a large meeting room into smaller ones, along with general finish upgrades throughout. The total area of work is 37,150 sq ft.

Key Findings
• Based on the submitted permit information, the project is anticipated to meet 8 of the 14 LEED prerequisites. The project would be required to pursue additional design and construction elements to meet the minimum standards which are not included in the local building code. Several of these prerequisite elements include owner-related policies and operational standards not typically associated with the building code.

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prerequisites are designated as “Maybe” (M), as they are either not required under the CALGreen code or would require the applicant to undertake additional efforts not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because all prerequisites must be met for LEED certification, none were marked as “No” (N) in the scorecard.
• The potential LEED rating for the project is based on the combined total of credits identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 27 points classified as “Yes” and 35 points classified as “Maybe.” For a conservative estimate, assuming the project achieves 75% of the “Maybe” credits, the projected total is 53 points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits are ultimately achieved (100%), the project is anticipated to earn approximately 62 points, aligning with a potential LEED Gold rating.
• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Water Efficiency (WE)
o Materials & Resources (MR)
o Indoor Environmental Quality (EQ)

• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Energy and Atmosphere (EA)
o Project Priorities & Innovation (PR)

Case Study #2: New Construction (Tier 2)
Project Type:

Nonresidential New Construction
Code Cycle: 2019
CALGreen Compliance Tier: Tier 2
LEED Rating System Used for Comparison: LEED v5 BD+C: Building Design & Construction

Scope of Work:

Case Study 2 is a 21,933 sq ft two-story office building over one level basement garage.

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amenity / plaza areas. Existing ground water extraction treatment facility toward rear of site to remain.

Key Findings:
• Based on the submitted permit information, the project is anticipated to meet 12 of the 16 LEED prerequisites. The project would be required to pursue additional design and construction elements to meet the minimum standards which are not included in the local building code. Several of these prerequisite elements include owner-related policies and operational standards not typically associated with the building code.

These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 4 prerequisites are designated as “Maybe” (M), as they are either not required under the CALGreen code or would require the applicant to undertake additional efforts not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because all prerequisites must be met for LEED certification, none were marked as “No” (N) in the scorecard.
• The potential LEED rating for the project is based on the combined total of credits identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 33 points classified as “Yes” and 28 points classified as “Maybe.” For a conservative estimate, assuming the project achieves 75% of the “Maybe” credits, the projected total is 54 points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits are ultimately achieved (100%), the project is anticipated to earn approximately 61 points, aligning with a potential LEED Gold rating.
• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Sustainable Sites (SS)
o Water Efficiency (WE)
o Energy and Atmosphere (EA)
o Materials and Resources (MR)

• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Indoor Environmental Quality (EQ)
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o Project Priorities & Innovation (PR)

Case Study #3: Mixed Use New Construction (Tier 2)
Project Type: Mixed-Use New Construction
Code Cycle: 2016
Compliance Tier: Tier 2
LEED Rating System Used for Comparison: LEED v5 BD+C: Building Design & Construction

Scope of Work:

Case Study 3 is a 47,074 sq ft three-story mixed-use building with one level of below-grade parking commercial office spaces on the first and second floor, as well as 19 residential dwelling units. The project includes relevant site work, including excavation, grading, paving, landscaping, a covered courtyard and utility connections.

Key Findings:
• Based on the submitted permit information, the project is anticipated to meet 11 of the 16 LEED prerequisites. The project would be required to pursue additional design and construction elements to meet the minimum standards which are not included in the local building code. Several of these prerequisite elements include owner-related policies and operational standards not typically associated with the building code.

These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 5 prerequisites are designated as “Maybe” (M), as they are either not required under the CALGreen code or would require the applicant to undertake additional efforts not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because all prerequisites must be met for LEED certification, none were marked as “No” (N) in the scorecard.
• The potential LEED rating for the project is based on the combined total of credits identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 39 points classified as “Yes” and 18 points classified as “Maybe.” For a conservative estimate, assuming the project achieves 75% of the “Maybe” credits, the projected total is 52 points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits are ultimately achieved (100%), the project is anticipated to earn approximately 57 points, aligning with a potential LEED Silver rating.
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• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Sustainable Sites (SS)
o Water Efficiency (WE)
o Energy and Atmosphere (EA)
o Materials and Resources (MR)

• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Indoor Environmental Quality (EQ)
o Project Priorities & Innovation (PR)

Notable Gaps, Risks and Opportunities:
• CALGreen Tier Prerequisites: To achieve CALGreen Tier 1 or Tier 2 status, a project must comply with all applicable prerequisite measures for the selected tier and select the required number of elective measures from each CALGreen division. Most CALGreen and Palo Alto Municipal Code (PAMC) prerequisites do not have direct equivalents in the LEED rating system.
6, 7 Notable CALGreen Tier prerequisites without
LEED prerequisite counterparts include:
o Designated parking for clean air vehicles
o Cool roof requirements to reduce the heat island effect o Minimum recycled content in building materials
o Enhanced construction waste reduction
o VOC limits for resilient flooring systems
o Formaldehyde limits for thermal insulation
o Electric vehicle charging infrastructure requirements

While these measures are not LEED prerequisites, projects may still earn LEED credits if they meet relevant criteria aligned with these CALGreen requirements.

6 See Appendix E for a comparison of the LEED v5 BD+C and CALGreen Tier 1 and Tier 2 prerequisites. 7 See Appendix F for a comparison of the LEED v5 ID+C and CALGreen Tier 1 and Tier 2 prerequisites. 12 Item 10
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• LEED Prerequisites: If a project elects to pursue LEED certification, all LEED prerequisites must be fully addressed and integrated into the project's design and construction phases. For the purpose of this evaluation, all measures referenced are assumed to comply with the mandatory LEED prerequisite requirements. New prerequisites and credits introduced in LEED v5 are not required by CALGreen and go further than the statewide requirements. Most of these prerequisites and credits are tied to decarbonization strategies, embodied carbon of building materials, health, comfort and community impact.
8 • Embodied Carbon: The City’s ordinance does not currently address whole building embodied carbon or life-cycle impact reductions, which are encouraged in LEED v5.

CALGreen Embodied Carbon requirements currently impact new nonresidential buildings 100,000 sq ft or more.
9 • Commissioning: Enhanced commissioning and performance verification practices go beyond the City’s current Tier 1 requirements. These additional measures may require substantial effort, particularly for nonresidential tenant improvement projects or smaller nonresidential alterations. The California Energy Code (Title 24, Part 6, Section 120.8) mandates building commissioning for new nonresidential buildings (excluding healthcare facilities) with conditioned floor areas of 10,000 sq ft or more.

CALGreen (Section 5.410.2) adopts the same 10,000 sq ft threshold for full-scope commissioning. For new buildings under 10,000 sq ft or new systems serving additions or alterations, CALGreen requires system testing and adjusting, similar to the Energy Code.
10 However, these requirements are less rigorous than full building commissioning, which state code requires for new construction only.

8 In particular, a climate resilience assessment (IPp1), human impact assessment (IPp2), and an embodied carbon assessment (IPp3), are now prerequisites for all projects pursuing LEED certification. 9 The threshold for triggering the CALGreen Embodied Carbon requirements will lower to 50,000 sq ft in the 2025 code cycle, effective January 1, 2026.
10 Energy-related systems including heating, ventilation, air conditioning (HVAC) systems and controls, indoor lighting system and controls, as well as water heating systems and controls, refer to California Energy Code Section 120.8 for commissioning requirements and Sections 120.5, 120.6, 130.4, and 140.9(b)3 for additional testing requirements of specific systems. CALGreen requires a written plan for testing and adjusting of renewable energy systems, landscape irrigation systems, and water reuse systems if applicable to the project (Section 5.410.4).
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• LEED Platinum: A new standard for LEED Platinum Certification was introduced in LEED v5. In addition to achieving 80 or more points, projects will also need to demonstrate compliance with additional performance benchmarks, such as zero operational emissions, full electrification, and a comprehensive embodied carbon analysis. Although setting LEED Platinum as an alternative compliance route is likely to not conflict with federal law, through the evaluation, the ID360 team is not recommending setting LEED Platinum as the alternative compliance threshold.

However, it is worth noting the significant level of effort and commitment this level of LEED certification would reflect of a project if achieved. • CPAU Carbon-Free: Since 2013, City of Palo Alto Utilities (CPAU) provides 100% carbon-neutral electricity and since 2017 offers 100% carbon-neutral gas services.

CPAU is also a certified Green‑e® Energy participant as of 2023 and was the first Green‑e Climate certified gas offset program offered by a municipal utility. 11 Due to
this, projects that receive off-site renewable energy and fuels are eligible for points under LEED’s Tier 3 Renewable Energy (EAc3) pathway. For the purposes of this evaluation, the project team assumes the project meets these criteria. • Regional Alignment: Jurisdictions across California—including those neighboring the City of Palo Alto—require LEED certification or LEED equivalency for certain project types, particularly larger commercial, institutional, and municipal developments.

There is an opportunity for Palo Alto to align with these regional standards, which would provide a more consistent permitting experience for applicants already pursuing LEED in nearby cities. This alignment would reduce duplication of effort, support sustainability objectives, and reinforce Palo Alto’s commitment to high- performance building practices. Appendix C provides a summary of LEED requirements adopted by neighboring jurisdictions.
• Noncompliance and Noncertified Results: One risk of pursuing the LEED Certification Compliance pathway is that a project may ultimately fail to achieve formal LEED certification, despite choosing that route. This could lead to delays in obtaining the final certificate of occupancy, depending on the City’s enforcement

11 CRS 2024 Green-e Verification Report. https://resource-solutions.org/g2024/ and City of Palo Alto Utilities. https://www.paloalto.gov/Departments/Utilities/Customer-Service/About-CPAU/Carbon-Neutral-Electricity-and- Natural-Gas/FAQs. Accessed June 25, 2025.
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mechanisms. Additionally, the project applicant may incur LEED design review and construction fees without receiving certification. A potential way to mitigate this risk is to adopt a model like San Francisco’s, where building permit closeout is contingent upon obtaining the LEED certificate.
• Third-Party Review Limitations: If a project fails to achieve LEED certification and no mitigating measures are in place, the City has no control over the outcome, as certification is solely at the discretion of GBCI.

RECOMMENDATION
Based on the ID360 team’s analysis, the findings support allowing permit applicants to use LEED certification as an alternative compliance pathway for CALGreen Tier 1 and Tier 2 requirements. The team recommends establishing LEED Silver as the minimum acceptable level for this alternative, with LEED Gold as the maximum. Additionally, the team suggests considering a tiered approach aligned with project scope—requiring LEED Silver for CALGreen Tier 1 projects and LEED Gold for Tier 2 projects.

The CALGreen Tiers and the LEED v5 rating systems are both green building standards that support the design and construction of high-performance buildings, but the standards differ significantly in scope, stringency, flexibility, and intent. 12 In certain areas, LEED v5 includes
more stringent and additional requirements, particularly in the areas of commissioning, carbon tracking, equity, and climate resilience strategies. In other ways, the CALGreen Tiers require certain prerequisites that can typically be claimed under optional credits in the LEED rating system. A summary table of the potential options outlined below is provided in Appendix D.

Potential Options for Palo Alto
• Option 1 – LEED Certification as a Standalone Compliance Pathway: Allow LEED Gold Certification to serve as an alternative compliance pathway for nonresidential projects in lieu of CALGreen Tier 1 and Tier 2 requirements, provided the project

12 See Appendix E for a comparison of CALGreen Tier prerequisite requirements against the LEED v5 BD+C rating system and Appendix F for a comparison of CALGreen Tier prerequisite requirements against the LEED v5 ID+C rating system. The CALGreen Tiers and LEED Overview section of this memo highlights and compares the intent, scope, structure, and green building categories between CALGreen and LEED v5. 15 Item 10
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complies with all CALGreen Mandatory Measures (Chapter 5) and applicable local amendments (e.g., energy reach codes, low-carbon concrete requirements). o Reasoning: This option streamlines the compliance process for project teams already pursuing LEED certification by removing the additional burden of Tier 1 and Tier 2 prerequisites and electives. It leverages a well-established third- party certification system—administered by Green Business Certification Inc. (GBCI)—to verify sustainability outcomes, while ensuring that local baseline standards remain enforced.
o Benefits:
§ Simplified Compliance: Removes additional CALGreen requirements for projects already pursuing LEED Gold, reducing administrative burden and additional design/construction considerations. § Third-Party Verification: Relies on GBCI’s established review process to assess and verify sustainability performance.
§ Voluntary LEED Compliance: Discussions with City staff highlighted that many projects that pursue LEED Certification on their own are typically driven by owner sustainability goals, design team strategies, and marketability of the building as LEED certified.
o Considerations:
§ Exemption from Tier Prerequisites: Projects utilizing this pathway would not be required to meet CALGreen Tier 1 or Tier 2 prerequisite measures.
§ Third-Party Oversight: Certification and compliance would be determined by GBCI, outside of City control.
§ City Verification Mechanism: A system for confirming LEED certification must be established. Options used by other jurisdictions include:
• Temporary Certificate of Occupancy: Conditional occupancy granted pending verification of LEED certification (e.g., San Francisco).
• LEED AP Verification Letters: Require pre-permit and pre- occupancy letters from a LEED Accredited Professional
confirming compliance (e.g., Mountain View).
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• Green Building Refundable Deposit: Require a deposit at permit issuance, refunded upon verification of certification achievement (e.g., San José).

• Option 2 – LEED Certification with CALGreen Tier Prerequisites: Allow LEED Gold Certification to serve as an alternative compliance pathway for nonresidential projects subject to CALGreen Tier 1 or Tier 2 requirements, with the stipulation that all applicable CALGreen Tier prerequisite measures must still be incorporated into the project’s design and construction.
o Reasoning: This approach maintains alignment with the City’s environmental goals by ensuring that projects meet the baseline CALGreen mandatory requirements and integrate the minimum sustainability measures required under Tier 1 or Tier 2. It offers project teams greater flexibility, particularly those already pursuing LEED certification, while preserving the integrity of the CALGreen tiered framework.
o Benefits:
§ Consistency and Accountability: Ensures all projects meet the City’s and CALGreen’s identified mandatory sustainability standards, regardless of the compliance pathway.
§ Efficiency and Synergy: Many CALGreen Tier prerequisites support specific LEED credits, creating an opportunity for streamlined documentation and reduced duplication of effort.
§ Incentivizes High Performance: By recognizing LEED Gold as a valid compliance route, the City can encourage broader adoption of third- party verified green building practices.
§ Flexibility for Project Teams: Provides an alternate route for compliance that may align better with the project’s sustainability strategy or certification goals.
o Considerations:
§ Documentation: Documentation must clearly demonstrate that all applicable CALGreen Tier 1 or Tier 2 prerequisites are met within the LEED-certified project.
§ City Verification Mechanism: Project teams must submit some form of documentation (e.g., GB-1 Sheet, compliance form) showing how 17 Item 10
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CALGreen prerequisites are satisfied under the LEED framework and incorporated into the design. Additionally, a system for confirming LEED certification must be established as mentioned under Option 1 (e.g., TCO, green building deposit, verification letter). § Evaluation of Requirements: Periodic review of LEED equivalency should be conducted to ensure continued alignment with evolving CALGreen standards.

• Option 3 – Tiered LEED Standards Differentiated by Project Scope: Permit LEED Gold Certification as an alternative compliance option for nonresidential CALGreen Tier 2 projects involving new construction or substantial remodels. For CALGreen Tier 1 projects, City staff would determine one of the following pathways: 1) Require LEED Silver Certification as the minimum standard; or 2) Exclude CALGreen Tier 1 projects from the LEED alternative compliance pathway entirely.
o Reasoning: This tiered approach provides flexibility for larger-scope projects (Tier 2) to leverage LEED Gold certification while maintaining oversight of Tier 1 projects or providing a lower threshold for smaller projects. By establishing differentiated requirements, the City can ensure that sustainability outcomes remain robust and consistent with the intent of the CALGreen tiers. o Benefits:
§ Flexible Compliance for Tier 2: Supports streamlined compliance for complex projects already pursuing LEED Gold.
§ City Control over Tier 1 Approach: Allows the City to decide whether to permit LEED Silver as a sufficient alternative or to require full CALGreen Tier 1 adherence in lieu of an alternative pathway. § Aligns Effort with Project Scope: Differentiates between the scale and impact of Tier 1 and Tier 2 projects, applying more rigorous certification standards to larger or more intensive developments. o Considerations:
§ City Decision Point: City staff must select the preferred approach for Tier 1 (LEED Silver or no alternative pathway).
§ Documentation and Verification: LEED-certified projects must still demonstrate compliance with all applicable CALGreen Mandatory Measures and relevant local code amendments.
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§ Enforcement Mechanism: The City should implement a verification process to confirm that LEED certification is achieved, consistent with practices used in other jurisdictions (e.g., deposits, third-party confirmation, temporary occupancy permits).
§ Tier 1 Project Scopes: Under PAMC, nonresidential Tier 1 projects are defined as alterations or tenant improvements (TIs) over 5,000 sq ft that include the replacement of at least two systems— HVAC, building envelope, hot water, or lighting. For smaller TIs, the limited scope may make it difficult to meet LEED prerequisites or earn enough credits, particularly for requirements like commissioning. The cost of LEED registration, the design and construction review fees may deter project teams from selecting LEED as a viable alternative.

Recommended Next Steps
If the City chooses to move forward with offering LEED Certification as an alternative compliance pathway, the project team recommends the following next steps.

Policy Development Next Steps

1. Select preferred policy option based on City priorities, administrative capacity, and staff feedback.

2. Present to the community and City Council to gather feedback and ensure alignment with broader sustainability goals and priorities.

Post-Policy Adoption Next Steps

1. Choose verification mechanism(s) aligned with existing permitting processes.

2. Develop implementation timeline and staff training, community training, and GBSI training requirements.

3. Establish periodic review process for policy effectiveness and LEED-CALGreen alignment during each building code cycle or new cycle of the LEED Rating System. 13 4. Coordinate with Planning and Building Division staff on permitting workflow integration, procedures, and implementation of enforcement requirements.

13 The LEED program has recently moved to a five-year development cycle starting with the 2025 release of the balloted LEED v5 rating systems. https://www.usgbc.org/leed/v5. Accessed June 23, 2025. 19 Item 10
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Appendix A
This page is left intentionally blank.

See next page for Appendix details.
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LEED ID+C® v5.0 SCORECARD
PROJECT: DATE:6/20/25 LEED for Interior Design and Construction INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP) 1 / 1 Points Possible Y M N PTS Prerequistie/Credit
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
1 0 0 1
LOCATION AND TRANSPORTATION (LT) 5 / 14 Points Possible Y M N PTS Prerequistie/Credit
4 4 8 Credit Public Transportation/Walkable Location
1 3 4 Credit
2 2 Credit EV parking shown on plans, not in scope
5 7 2 14
WATER EFFICIENCY (WE) 2 / 10 Points Possible

Y M N PTS
0 0 Prerequisite
1 1 2 Credit Permanent water meters/submeters
1 7 8 Credit 25% reduction fixture and fittings
2 0 8 10
ENERGY AND ATMOSPHERE (EA) 3 / 31 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite Meet Title 24 Energy Code
0 0 Prerequisite Fundamental Commissioning
0 0 Prerequisite Energy Metering and Reporting
0 0 Prerequisite Fundamental Refrigerant Management
5 5 Credit Electrification
4 8 12 Credit Enhanced Energy Efficiency
2 3 5 Credit Renewable Energy
4 4 Credit Enhanced Commissioning
1 2 3 Credit Grid Interactive
2 2 Credit
3 4 24 31
MATERIALS & RESOURCES (MR) 9 / 26 Points Possible

Y M N PTS
0 0 Prerequisite Planning for Zero Waste Operations
0 0 Prerequisite Quantify and Assess Embodied Carbon
1 4 4 Credit Interior Materials Reuse
1 3 4 Credit Reduce Embodied Carbon
2 2 4 Credit Low-Emitting Materials
2 8 10 Credit Building Product Selection and Procurement No project specifications included 3 4 Credit Construction and Demolition Waste Diversion
9 17 0 26
INDOOR ENVIRONMENTAL QUALITY (EQ) 1 / 18 Points Possible

Y M N PTS
0 0 Prerequisite Construction Management
Initial project analysis by applicant
Initial project analysis by applicant
Initial project analysis by applicant
Meeting early in design
Case Study 1
Tier 1 TI
Minimum Energy Efficiency
D
D/C
D
D
D
D
D/C
D/C
Climate Resilience Assessment
Human Impact Assessment
Carbon Assessment
Integrative Design Process
Minimum Water Efficiency
Des/Con Notes
D
D/C
D
Existing building reuse, recycled content
Low emitting flooring, insulation, base code
80% diversion rate / CWM
Enhanced Refrigerant Management
Reduce harmful refrigerants
C
Requires enhanced refrigerant calcs.

Construction plan for air quality
No indication of enhanced cs efforts
D/C
D/C
D
D/C
D/C
D
C
Initial project analysis by applicant
Initial project analysis by applicant
D
Des/Con
D
D/C
CALGreen low flow and flush fixtures
D
D/C
D/C
Water Metering and Leak Detection
lighting contol system / controlled receptacles DR
Advanced lighting, HVAC
No solar PV; Carbon Free CPAU
Estimated Energy Use/Operational Carbon Projection D
D/C
D
D
Compact and Connected Development
Transportation Demand Management
Electric Vehicles
Enhanced Water Efficiency
Installed meters and reports
Initial project analysis by applicant
Meet Title 24 Energy Commissioning
Reuse of existing buildings
Mixed fuel building
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0 0 Prerequisite Fundamental Air Quality
0 0 Prerequisite No Smoking
1 1 2 Credit Enhanced Air Quality
1 6 7 Credit Occupant Experience
1 1 2 Credit Accessibility and Inclusion
3 3 Credit Resilient Spaces
4 4 Credit Air Quality Testing and Monitoring
1 3 14 18
PROJECT PRIORITIES & INNOVATION (PR) 6 / 10 Points Possible

Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED AP
6 4 0 10
LEED Rating System Point Requirements
N
48 110
C
Y M
C
D/C
D
D

POSSIBLE POINTS
D 1 project team must be LEED AP w/ specialty
D
27 35
D
CALGreen equivalent
No smoking signs & policy
Mech ventilation complies w/ CEC
Possible for windows or lighting or acoustics
Complies with CBC Chp 11B ADA
No indication of testing and monitoring
D
Multiple pathways for points
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
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LEED BD+C® v5.0 SCORECARD
PROJECT: DATE: 6/27/25 LEED for Building Design + Construction INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP) 1 / 1 Points Possible Y M N PTS Prerequistie/Credit
0 0 Prerequisite Climate Resilience Assessment
0 0 Prerequisite Human Impact Assessment
0 0 Prerequisite Carbon Assessment
1 1 Credit Integrative Design Process Meeting early in design 1 0 0 1
LOCATION AND TRANSPORTATION (LT) 5 / 15 Points Possible Y M N PTS Prerequistie/Credit
1 1 Credit Sensitive Land Protection Infill site
1 2 Credit Equitable Development
1 6 Credit Compact and Connected Development
2 2 4 Credit Transportation Demand Management Bicycle network/storage/shower 2 2 Credit Electric Vehicles 4 EVSE, 6 EV Ready
5 2 2 15
SUSTAINABLE SITES (SS) 5 / 11 Points Possible

Y M N PTS
0 0 Prerequisite
2 2 Credit Project restoring disturbed areas
1 1 Credit Landscape/outdoor area not 30%
2 1 3 Credit 85th percentile rainwater management
1 1 2 Credit
2 2 Credit SRI included for 2 roof products
1 1 Credit BUG ratings per Tier 2 prerequisite
5 1 5 11
WATER EFFICIENCY (WE) 2 / 9 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
2 6 8 Credit 31% indoor water use reduction; app.
2 0 7 9
ENERGY AND ATMOSPHERE (EA) 9 / 33 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite Meet Title 24 Energy Code
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
5 5 Credit
1 4 5 Credit Reduce Peak Thermal Loads
1 9 10 Credit
3 2 5 Credit
4 4 Credit FPT: BMS, HVAC, plumbing, electrical
2 2 Credit No DR or BAS in plans
Case Study 2
Tier 2 New Construction
D
D/C
D
D/C
D/C
Installed meters and reports
Reduce harmful refrigerants
Permanent water meter on site
Solar ready area/ CPAU Green-e Certified
Accessible Outdoor Space
Rainwater Management
Enhanced Resilient Site Design Climate/natural hazard design Meter only, not included for all uses
CALGreen low flow and flush fixtures
D/C
D
D
D
D
Initial project analysis by applicant
Initial project analysis by applicant
Initial project analysis by applicant
All-electric building design
Meet Title 24 Energy Commissioning
Energy Recovery Ventilator (ERV)
Core and shell, all-electric building
No on-site combustion
D
D
D
D/C
D
D/C
Electrification
Enhanced Energy Efficiency
Renewable Energy
Enhanced Commissioning
Grid Interactive
D/C
D/C
D/C
D
Light Pollution Reduction
Water Metering and Reporting
Minimum Water Efficiency
Water Metering and Leak Detection
Carbon Projection and Decarbonization Plan
Minimum Energy Efficiency
Fundamental Commissioning
Energy Metering and Reporting
Fundamental Refrigerant Management
Des/Con
D
D
Erosion control/site assessmentD/C
D
Des/Con
D
D/C
D
D/C
D
Heat Island Reduction
Enhanced Water Efficiency
D
D/C
Minimize Site Disturbance
Biodiverse Habitat
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2 2 Credit
9 9 15 33
MATERIALS & RESOURCES (MR) 5 / 18 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
3 3 Credit
6 6 Credit
1 1 2 Credit
2 3 5 Credit Choice materials CALGreen elective
2 2 Credit 80% C&D diversion
5 3 10 18
INDOOR ENVIRONMENTAL QUALITY (EQ) 0 / 13 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
7 7 Credit
1 1 Credit
2 2 Credit
2 2 Credit
0 9 4 13
PROJECT PRIORITIES & INNOVATION (PR) 6 / 10 Points Possible

Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED Accredited Professional
6 4 0 10
LEED Rating System Point Requirements
Initial project analysis by applicant
New construction
No WBLCA, EPD, or carbon tracking
1 pt for C/S, CALGreen categories
D
Requires enhanced refrigerant calcs.

Recyclables & ZW Operations Plan
D Enhanced Refrigerant Management
D 1 project team must be LEED AP w/ specialty
C
Construction and Demolition Waste Diversion
Construction Management
Fundamental Air Quality
Planning for Zero Waste Operations
Quantify and Assess Embodied Carbon
Building and Materials Reuse
Reduce Embodied Carbon
Low-Emitting Materials
Building Product Selection and Procurement
D
D/C
C
D/C
D
D
D/C
D
No Smoking or Vehicle Idling
Enhanced Air Quality
Occupant Experience
Accessibility and Inclusion
Resilient Spaces
D/C
C
C
Multiple pathways for points
No IAQ testing indicated
Project team develop CM practices
ASHRAE 62.1, MERV 13
CALGreen tabacco requirements/ No idle
Increased outdoor air rates or IAQ limits
Project analysis by team required
Additional accessibility strategies
No operable windows or passive technique

Y M N POSSIBLE POINTS
33 28 43 110
D
Air Quality Testing and Monitoring
D
D
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
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LEED BD+C® v5.0 SCORECARD
PROJECT: DATE: 6/27/25 LEED for Building Design + Construction INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP) 1 / 1 Points Possible Y M N PTS Prerequistie/Credit
0 0 Prerequisite Climate Resilience Assessment
0 0 Prerequisite Human Impact Assessment
0 0 Prerequisite Carbon Assessment
1 1 Credit Integrative Design Process
1 0 0 1
LOCATION AND TRANSPORTATION (LT) 8 / 15 Points Possible Y M N PTS Prerequistie/Credit
1 1 Credit Sensitive Land Protection
2 2 Credit Equitable Development
3 6 Credit Compact and Connected Development
1 3 4 Credit Transportation Demand Management
3 2 Credit Electric Vehicles
8 0 5 15
SUSTAINABLE SITES (SS) 9 / 11 Points Possible

Y M N PTS
0 0 Prerequisite
2 2 Credit Biodiverse Habitat
1 1 Credit Accessible Outdoor Space
2 1 3 Credit Rainwater Management
2 2 Credit Enhanced Resilient Site Design
1 1 2 Credit Heat Island Reduction
1 1 Credit Light Pollution Reduction
9 0 2 11
WATER EFFICIENCY (WE) 2 / 9 Points Possible

Y M N PTS
0 0 Prerequisite Water Metering and Reporting
0 0 Prerequisite Minimum Water Efficiency
1 1 Credit Water Metering and Leak Detection
1 2 8 Credit
2 2 0 9
ENERGY AND ATMOSPHERE (EA) 6 / 33 Points Possible

Y M N PTS
0 0 Prerequisite Carbon Projection and Decarbonization Plan 0 0 Prerequisite Minimum Energy Efficiency
0 0 Prerequisite Fundamental Commissioning
0 0 Prerequisite Energy Metering and Reporting
0 0 Prerequisite Fundamental Refrigerant Management
5 5 Credit Electrification
2 2 5 Credit Reduce Peak Thermal Loads
3 10 Credit Enhanced Energy Efficiency
3 2 5 Credit Renewable Energy
Enhanced Water Efficiency
Des/Con
D
D
Erosion control/site assessmentD/C
D
Des/Con
D
D/C
D
D/C
D/C
D
D
D/C
D
D
D
D
D
D
D/C
D
Minimize Site Disturbance
D/C
D/C
D/C
D
Indoor plumbing, irrigation systems
D/C
1 point for 30% reduction
Initial project analysis by applicant
Meet Title 24 Energy Code
Cx not requied per CALGreen/CEC
Installed meters and reports
Reduce harmful refrigerants
Project includes on site combustion.

Permanent water meter on site
CALGreen low flow and flush fixtures
ASHRAE 90.1 Building Envelope
Initial project analysis by applicant
Solar Ready only, CPAU Green-e certified
Case Study 3
Tier 2 Mixed Use
D
D/C
D
Assessment provided by applicant.

Assessment provided by applicant.

Assessment provided by applicant.

Meeting early in design
Infill site
Area with developmental challenges
Walk Score is 92
Bicycle network and storage
CPA EV requirements > LEED requirements
D
Project restoring disturbed areas
30% Open/Outdoor Space
LID - 85th percentile rainfall
Climate/natural hazard design
SRI 78 required in specs 07 54 23
Met through compliance with CALGreen
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4 4 Credit Enhanced Commissioning
2 2 Credit Grid Interactive
1 2 Credit Enhanced Refrigerant Management
6 7 11 33
MATERIALS & RESOURCES (MR) 4 / 18 Points Possible

Y M N PTS
0 0 Prerequisite Planning for Zero Waste Operations
0 0 Prerequisite Quantify and Assess Embodied Carbon
3 3 Credit Building and Materials Reuse
6 6 Credit Reduce Embodied Carbon
2 2 Credit Low-Emitting Materials
2 3 5 Credit Building Product Selection and Procurement 2 2 Credit Construction and Demolition Waste Diversion
4 2 12 18
INDOOR ENVIRONMENTAL QUALITY (EQ) 3 / 13 Points Possible

Y M N PTS
0 0 Prerequisite Construction Management
0 0 Prerequisite Fundamental Air Quality
0 0 Prerequisite No Smoking or Vehicle Idling
1 1 Credit Enhanced Air Quality
2 5 7 Credit Occupant Experience
1 1 Credit Accessibility and Inclusion
1 1 2 Credit
2 2 Credit
3 3 7 13
PROJECT PRIORITIES & INNOVATION (PR) 6 / 10 Points Possible

Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED Accredited Professional
6 4 0 10
LEED Rating System Point Requirements
Resilient Spaces
D/C
D
D

Y M N POSSIBLE POINTS
39 18 37 110
D/C
C
C
D
D/C
C
D
D/C
D
D
D
C
1 project team must be LEED AP w/ specialty
Air Quality Testing and Monitoring
D
D
D
D/C
No WBLCA, EPD, or carbon tracking
D/C
No IAQ testing indicated
Project team develop CM practices
ASHRAE 62.1, MERV 13
CALGreen tabacco requirements/ No idle
Increased outdoor air rates or IAQ limits
Additional accessibility strategies
Quality Views 75%
Operable windows included
Multiple pathways for points
No Commissioning in plans
No DR or BAS in plans
Requires enhanced refrigerant calcs.

Recyclables & ZW Operations Plan
Initial project analysis by applicant
New construction
CALGreen VOC limits
Choice materials CALGreen (2022)
80% C&D diversion
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
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Appendix B

1 CALGreen Tier Prerequisite and Elective Measures by Project The following is a list of the prerequisite and elective measures marked “Yes” (Y) on the project’s approved GB-1 Sheet.

Case Study #1: Tenant Improvement (Tier 1)
Planning & Design
A5.105.1.1 Existing Buildings Structure (75%)
A5.105.1.2 Existing non-Structure elements (50%)
Water Efficiency & Conservation

5.303.1.2 Excess consumption (submeters for additions that consume over 1,00 gal/day) A5.303.2.3.1 Water reduction - 12% (Table A5.303.2.3.1)

5.303.3.1 Indoor Water Use: Water closets (1.28 gpf)

5.303.2.1 Indoor Water Use: Wall mounted Urinals 0.125 gpf

5.303.3.4.1 Indoor Water Use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)

5.303.4.2 Indoor Water Use: Kitchen faucets (1.8 gpm at 60 psi)

5.303.4 Commercial kitchen equipment

5.303.4.1 Food waste disposers

5.303.5 Indoor water use: areas of addition or alteration

5.303.6 Indoor water use: Standards for plumbing fixtures and fittings (2022 CA Plumbing Code) A5.303.2.3.3 Water reduction - 25%
A5.303.3 Appliances and fixtures for commercial application Material Conservation & Resource Efficiency

5.408.1 Construction waste management

5.408.1.1 Construction waste management plan

5.408.1.2 Waste management company

5.408.1.3 Waste stream reduction alternative

5.408.1.4 Documentation - CWM, Waste management company, waste stream reduction alternative

5.408.2 Universal Waste [AA]

5.408.3 Excavated soil and land clearing debris (100% reuse or recycle) PAMC 16.14.410/
A5.408.3.1
Enhanced construction waste reduction (80% diversion w/ job valuation >$25,000)

5.410.1 Recycle by occupants (with exceptions)

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Appendix B

2 5.410.4.3 Testing and adjusting: Procedures

5.410.4.3.1 Testing and adjusting: HVAC balancing

5.410.4.4 Testing, adjusting and balancing: Reporting for HVAC balancing

5.410.4.5 Operation and maintenance (O&M) Manual

5.410.4.5.1 Inspection and reports
PAMC 16.14.360/

5.410.4.6
ENERGY STAR Portfolio Manager profile setup (for projects >$100,000 in value) PAMC 16.14.370/

5.4.10.4.7 Performance Review. - Energy (For projects over 10,000 SF) PAMC 16.14.070 &

16.14.080/ A5.405.4
Recycled content of the total material cost: 10%
A5.405.3 Reused materials (5% of total value)
Environmental Quality

5.504.1 Temporary ventilation (MERV 8)

5.504.3 Covering of duct openings and protection of mechanical equipment during construction

5.504.4.4.1 Adhesives, sealants, caulks: Comply with VOC limits (Table 5.504.4.1 & 5.504.4.2 for VOC limits)

5.504.4.4.3 Paints and Coatings: Comply with VOC Limits (Table 5.504.4.3)

5.504.4.4.1 Carpet systems: carpet cushion

5.504.4.4.2 Carpet systems: carpet adhesive (Table 5.504.4.1 for VOC Limits)

5.504.4.5 Composite wood products: Formaldehyde limits (Table 5.504.4.5)

5.504.4.5.3 Composite wood products: Documentation

5.504.4.6.1 Verification of compliance, for resilient flooring systems PAMC 16.16.070/

16.14.080/ A5.504.4.7
Resilient flooring system - 90%
PAMC 16.16.070 /

16.14.808 / A5.504.4.8
Thermal insulation - Tier 1 requirement

5.504.5.3 Filters: Labeling (MERV 13, with exceptions)

5.504.7 Environmental tobacco smoke (ETS) control

5.505.1 Indoor moisture control

5.506.1 Outside air delivery (For Indoor Air Quality)

5.506.2 Carbon dioxide (CO2) monitoring (For Indoor Air Quality) PAMC 16.14.390/

5.506
Indoor Air Quality Management Plan (locally amended)

5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413) 28 Item 10
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Appendix B

3 5.507.4.3 Interior sound transmission (with note)

5.508.1 Ozone depletion and greenhouse gas reductions

5.508.2 Supermarket refrigerant leak reduction

5.508.2.1 Refrigerant piping

5.508.2.2 Refrigerant piping valves

5.508.2.2.2 Refrigerant piping access valves

5.508.2.3 Refrigerated service cases

5.508.2.4 Refrigerant receivers

5.508.2.5 Pressure testing

5.508.2.6 Evacuation after pressure testing
A5.504.4.9 Entryway systems
A5.507.1.2 Lighting and thermal comfort controls: Multi-occupant spaces A5.601.2.4 Acoustic ceiling/ Panels

Case Study #2: New Construction (Tier 2)
Planning & Design
PAMC 16.14.209/

5.106.1
Storm water pollution prevention for projects that disturb < 1 acre of land PAMC 16.14.2090/

5.106.1.1
Local storm water pollution prevention

5.106.1.2 Best management practices

5.106.4.1.1 Short term bicycle parking

5.106.4.1.2 Long term bicycle parking

5.106.5.2.1 Parking stall markings
A5.106.5.1.2 Designated parking - 12% of parking capacity PAMC

16.14.430/A5.106.5.3
EV Charging for Nonresidential Structures - New Construction - Provide Conduit Only, EVSE-Ready Outlet or EVSE Installed for 25% of parking spaces, 5% shall be 5% EVSE Installed PAMC 16.14.295/

5.106.8
Light Pollution Reduction

5.106.10 Grading and paving
A5.106.11.2 Cool roof for reduction of heat island effect A5.103.2 Brownfield or greyfield site redevelopment or infill area development A5.106.2 Storm water design
A5.106.3 Low Impact Development (LID)
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Appendix B

4 A5.106.4.3 Changing rooms
A5.106.6 Parking capacity
Energy Reach Code
PAMC 16.17.080 All-electric design
PAMC 16.14.380/

5.410.4.6
Energy STAR Portfolio manager
PAMC 16.14.390/

5.410.4.7
Performance review - for projects over 10,000 SF
PAMC 16.14.400/

5.410.4.8
Performance review (For sites > 1 acre)
Water Efficiency & Conservation

5.303.1 Meters, separate submeters or metering devices
A5.303.2.3.2 Water Reduction - 20%

5.303.1 Indoor water use: Water closets (not exceed 1.28 gpf)

5.303.3.2.1 Indoor water use: Wall-mounted urinals (0.125 gpf)

5.303.3.2.2 Indoor water use: Floor-mounted urinals (0.5 gpf)

5.303.3.3.1 Indoor water use: Single showerhead (1.8 gpm at 80 psi)

5.303.3.4.1 Indoor water use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)

5.303.3.4.2 Indoor water use: kitchen faucets (1.8 gpm at 60 psi)

5.303.3.4.4 Indoor water use: Metering faucets (0.2 gallons/cycle)

5.303.6 Indoor water use: standards for plumbing fixtures and fittings

5.304.1 Outdoor potable water use in landscape areas (MWELO) PAMC 16.12.030 Recycled water supply systems
PAMC 16.14.360/

5.304.2
Invasive species prohibited
A5.303.2.3.3 Indoor water use: 25% reduction
A5.304.6 Outdoor water use: Restoration of areas disturbed by construction A5.305.2 Irrigation system: Recycled water
Material Conservation & Resource Efficiency
A5.405.4 Recycled content: 15%

5.407.1 Weather protection

5.407.2.1 Moisture control: sprinklers

5.407.2.2 Moisture control: Entries + Openings
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Appendix B

5 5.407.2.2.1 Moisture control: Exterior door protection

5.407.2.2.2 Moisture control: Flashing

5.408.1 Construction waste management

5.408.1.1 Construction waste management plan

5.408.1.2 Waste management company

5.408.1.4 Documentation: Construction WMP, waste management company, waste stream reduction alternative

5.408.3 Excavated soil and land clearing debris (100% reuse or recycle) PAMC 16.14.370/
A5.408.3.1.1
Enhanced construction waste reduction (80% diversion)

5.410.1 Recycling by occupants

5.410.2 Commissioning (≥ 10,000 SF)

5.410.2.3 Commissioning plan

5.410.2.4 Functional Performance Testing

5.410.2.5.1 Documentation and Training: Systems manual

5.410.2.5.2 Documentation and Training: Systems operations training

5.410.2.6 Commissioning Report

5.410.4 Testing and adjusting for [N] buildings < 10,000 SF or new systems serving addition or alterations

5.410.4.2 Testing and adjusting for systems: renewable energy, landscape irrigation, water reuse

5.410.4.3 Testing and adjusting procedures

5.410.4.3.1 Testing and adjusting: HVAC balancing

5.410.4.4 Testing, adjusting, and balancing: Reporting for HVAC balancing

5.410.4.5 Operation and maintenance (O&M) manual
PAMC 16.14.400/

5.410.4.8
Performance reviews. - water (sites > 1 acre)

5.410.4.5.1 Inspection and reports [AA} + [N] < 10,000 SF A5.405.2.1 Bio-based materials: certified wood
A5.406.1.1 Choice of materials: Service life
A5.406.1.2 Choice of materials: Reduced maintenance
A5.406.1.3 Choice of materials: Recyclability
Environmental Quality

5.504.1 Temporary ventilation (MERV 8)
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Appendix B

6 5.504.3 Covering of duct openings and protection of mechanical equipment during construction

5.504.4.1 Adhesives, sealants and caulks: Comply with VOC Limits (Table 5.504.4.1 and 5.504.4.2 for VOC limits)

5.504.4.3 Paints and coatings: comply with VOC limits (Table 5.504.4.3)

5.504.4.3.1 Aerosol paints and coatings

5.504.4.3.2 Verification for paints and coatings

5.504.4.5 Composite wood products: Formaldehyde limits (Table 5.504.4.5)

5.504.4.5.3 Composite wood products: Documentation
PAMC 16.14.070/
A5.504.4.7.1
Resilient Flooring system, 100%
A5.504.4.8.1 Thermal insulation: No added formaldehyde

5.504.7 Environmental tobacco smoke (ETS) control

5.506.1 Outside air delivery (For Indoor Air Quality)
PAMC 16.14.410 Indoor Air Quality Management Plan

5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413)

5.507.4.1 Exterior noise transmission, prescriptive method (with exceptions)

5.507.4.1.1 Noise exposure where noise contours are not readily available

5.507.4.2 Exterior noise transmission, performance method

5.507.4.2.1 Site features

5.507.4.2.2 Documentation of compliance

5.507.4.3 Interior sound transmission (with note)

5.508.1 Ozone depletion and greenhouse gas reductions

5.508.1.1 Chlorofluorocarbons (CFCs)

5.508.1.2 Halons
A5.504.1.2 Indoor Air Quality during construction: Additional IAQ measures A5.504.5.1 Entryway systems (to control pollutants)
A5.504.5.2 Isolation of pollutant sources (to control pollutants) A5.508.1.3 Hydro-chlorofluorocarbons (HCFCs) (for HVAC and refrigeration equipment)

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Appendix B

7 Case Study #3: Mixed Use New Construction (Tier 2)
Planning & Design
PAMC 16.14.290/

5.106.1
Stormwater pollution prevention for projects that disturb < 1 acre of land PAMC 16.14.290/

5.106.1.1
Local storm water pollution prevention

5.106.1.2 Best management practices (BMP's)
PAMC 18.54.060/

5.106.4
Bicycle parking for additions or change of use that results in increased parking PAMC 18.54.060/

5.106.4.1.1
Short term bicycle parking (exception for additions or alterations which add nine or less visitor vehicular parking spaces)
PAMC 18.54.060/

5.106.4.1.2
Long term bicycle parking
PAMC

16.14.295/5.106.8
Light pollution reduction

5.106.10 Grading and paving (exception for additions and alterations not altering the drainage path) PAMC 16.16.070 &

16.14.080/ A5.106.11.2
Cool roof for reduction of heat island effect
A5.103.1 Community connectivity
A5.106.3 Low impact development (LID)
A5.106.6 Parking capacity
Energy Reach Code
PAMC 16.17.050 Mixed-fuel design 10%
PAMC 16.14.3980/

5.410.4.6
Energy STAR Portfolio Manager
Water Efficiency & Conservation

5.303.1 Meters, separate submeters or metering devices installed as follows:

5.303.1.1 New buildings or additions in excess of 50,000 square feet

5.303.1.2 Excess consumption (Submeters for additions that consume over 1,000 gal/ day) A5.303.2.3.2 Indoor Water Use Reduction- 20% savings over the "water use baseline" Table A5.303.2.3.1

5.303.3.1 Indoor Water Use: Water closets (shall not exceed 1.28 gallons per flush)

5.303.3.2.1 Indoor Water Use: Wall-mounted urinals (0.125gpf)

5.303.3.2.2 Indoor Water Use: Floor-mounted urinals (0.5 gpf)

5.303.3.3.1 Indoor Water Use: Single showerhead (1.8 gpm at 80 psi)

5.303.3.3.2 Indoor Water Use: Multiple showerheads serving one shower (flow rate of 1.8 gpm at 80 psi)

5.303.3.4.1 Indoor Water Use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)

5.303.3.4.2 Indoor Water Use: Kitchen faucets (1.8 gpm at 60 psi) 33 Item 10
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8 5.303.3.4.3 Indoor Water Use: Wash fountains (1.8 gpm at 60 psi)

5.303.3.4.4 Indoor Water Use: Metering faucets (0.2 gallons/ cycle)

5.303.3.4.5 Indoor Water Use: Metering faucets for wash fountains (0.2 gallons/ cycle)

5.303.4 Commercial kitchen equipment

5.303.4.1 Food waste disposers

5.303.5 Indoor water use: Areas of addition or alteration [AA] PAMC 16.12.035 Dual plumbing (locally amended)

5.303.6 Indoor Water Use: Standards for plumbing fixtures and fittings (2022 California Plumbing Code)

5.304.1 Outdoor potable water use in landscape areas (MWELO) PAMC 16.12.030 Recycled water supply systems
PAMC 16.14.330
Section 5.304.2
Invasive species prohibited
PAMC 16.14.340
Section 5.306
Non-residential enhanced water budget required when use > 1,000 gal/day PAMC 16.14.350
Section 5.307
Cooling Tower Water Use (locally amended)
A5.303.2.3.3 Indoor water use: 25% reduction
A5.303.2.3.4 Nonpotable water systems for indoor water use A5.303.3 Appliances and fixtures for commercial application A5.303.4.1 Nonwater supplied urinals
A5.304.6 Outdoor Water Use: Restoration of areas disturbed by construction A5.304.7 Outdoor Water Use: Previously developed sites: restore or protect 50 % of site area A5.304.8 Outdoor Water Use: Graywater irrigation system A5.305.1 Nonpotable water systems
A5.305.2 Irrigation system: Recycled water
Material Conservation & Resource Efficiency
A5.405.4 Recycled content: 15% of materials based on estimated total cost or use two products from Table A5.405.4 for at least 75% by cost

5.407.1 Weather protection

5.407.2.1 Moisture control: Sprinklers

5.407.2.2 Moisture control: Entries + Openings

5.407.2.2.1 Moisture control: Exterior door protection
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Appendix B

9 5.407.2.2.2 Moisture control: Flashing

5.408.1 Construction waste management

5.408.1.1 Construction waste management plan

5.408.1.2 Waste management company

5.408.1.3 Waste stream reduction alternative

5.408.1.4 Documentation: Construction waste management plan, waste management company, waste stream reduction alternative

5.408.2 Universal Waste [AA]

5.408.3 Excavated soil and land clearing debris (100% reuse or recycle)

5.409.2 Whole building life cycle assessment

5.409.3 Product GWP compliance—prescriptive path
PAMC 16.14.430/
A5.408.3.1.1
Enhanced construction waste reduction
(80% Diversion w/ job valuation >$25,000, less than $25,000 must meet state standards of 65%)

5.410.1 Recycling by occupants (with exceptions)

5.410.2 Commissioning (≥ 10,000 SF) [N]

5.410.2.3 Commissioning plan [N]

5.410.2.4 Functional performance testing [N]
PAMC 16.14.360 /

5.410.4.6
ENERGY STAR Portfolio Manager profile setup (for projects exceeding $100,000 in value) PAMC 16.14.370 /

5.410.4.7
Performance Review- For projects over 10,000 SF
PAMC 16.14.380/

5.410.4.8
Performance Review (For sites > 1 acre)

5.410.2.5.1 Documentation and Training: Systems manual

5.410.2.5.2 Documentation and Training: Systems operations training [N]

5.410.2.6 Commissioning report [N]

5.410.4 Testing and adjusting for new buildings < 10,000 SF or new systems that serve additions or alterations [N] [AA]

5.410.4.2 Testing and adjusting for systems: Renewable energy, landscape irrigation, and water reuse

5.410.4.3 Testing and adjusting: Procedures

5.410.4.3.1 Testing and adjusting: HVAC balancing

5.410.4.4 Testing, adjusting and balancing: Reporting for HVAC balancing

5.410.4.5 Operation and maintenance (O&M) manual
PAMC 16.14.380/ Sect

5.410.4.8
Performance reviews- Water (sites > 1 acre)
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Appendix B

10 5.410.4.5.1 Inspection and reports (new buildings / additions and alterations < 10,000 SF) [AA] + [N] A5.404.1.1 Wood Framing: Structural or fire-resistance integrity A5.404.1.2 Wood Framing: Framing specifications
A5.406.1.3 Choice of materials: Recyclability
Environmental Quality

5.504.1 Temporary ventilation (MERV 8)

5.504.3 Covering of duct openings and protection of mechanical equipment during construction

5.504.4.1 Adhesives, sealants and caulks: Comply with VOC limits (Table 5.504.4.1 and 5.504.4.2 for VOC limits)

5.504.4.3 Paints and Coatings: Comply with VOC Limits (Table 5.504.4.3)

5.504.4.3.1 Aerosol paints and coatings

5.504.4.3.2 Verification, for paints and coatings
PAMC 16.16.070 &

16.14.080/ A5.504.4.8.1
Thermal Insulation: No added formaldehyde

5.504.5.3 Filters: Labelling (MERV 13, with exceptions)

5.504.7 Environmental tobacco smoke (ETS) control

5.506.2 Carbon dioxide (CO2) monitoring (For Indoor Air Quality) PAMC 16.14.390 Indoor Air Quality Management Plan

5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413)

5.507.4.2 Exterior noise transmission, performance method

5.507.4.3 Interior sound transmission (with note)
A5.504.1.1 Indoor air quality (IAQ) during constructions: Temporary ventilation A5.504.1.2 Indoor air quality (IAQ) during constructions: Additional IAQ measures A5.507.3.1 Views: Direct line of sign to outdoors: interior office spaces

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Appendix C
1 LEED Certification Requirements by California Jurisdiction Jurisdiction Trigger
Belmont • Residential alteration projects adding less than 400 SF with a construction valuation of 0 to $50,000: One Build It Green (BIG) Green Building Practice from the Existing Home Checklist • Residential alteration projects adding less than 400 SF with a construction valuation of $50,001.00 to $99,999: Three BIG Green Building Practices from the Existing Home Checklist • Residential alteration projects adding less than 400 SF with a construction valuation of $100,000.00: 25 BIG points Elements or 50 BIG points Whole House • New residences and residential alteration projects adding 400 SF or greater: 70 BIG points Whole House
• Tenant improvement or new construction commercial projects 10,000 SF or greater: LEED Silver Certification
Cupertino • New SF and MF (greater than 9 homes): GPR Certified at min. 50 points or LEED Silver or Alternate Reference Standard
• NR Mid-size (25,000-50,000 SF): LEED Certified or Alternate Reference Standard • NR Large (> 50,000 SF): LEED Silver or Alternate Reference Standard • MF Renovations/Additions (w/ FAR increase 50% and at least 35,000 SF and replace or substantially alter the HVAC system and at least two systems - building envelope, hot water system, and lighting system): GPR min. 50 pts, LEED Certified or LEED EBOM Certified, or Alternative Reference Standard
• NR Renovations/Additions (35,000 SF or more and replace or substantially alter the HVAC system and two systems - building envelope, hot water system, and lighting system): LEED Certified (applicable only to the area of renovation/addition), LEED EBOM Certified, or Alternative Reference Standard
Menlo Park • LEED: Project applicants will have the option to select whether they wish to pursue LEED certification or demonstrate LEED-equivalent performance through the LEED performance program (LPP).
• New NR 10,000 sq. ft.—25,000 sq. ft: Designed to meet LEED Silver BD+C • New NR 25,001 sq. ft.—100,000 sq. ft.: Designed to meet LEED Silver BD+C • New NR 100,001 sq. ft. and above: Designed to meet LEED Gold BD+C1 • NR Additions/Alterations 10,000 sq. ft.—25,000 sq. ft. of conditioned area, volume or size:

Designed to meet LEED Silver ID+C1 or update core and shell of entire building to current California Energy Code and meet Section 16.43.140 (Local GB and Energy Standards) • NR Additions/Alterations 25,001 sq. ft. and above of conditioned area, volume or size:

Designed to meet LEED Gold ID+C1 or update core and shell of entire building to current California Energy Code2 and meet Section 16.43.140 (Local GB and Energy Standards) Mountain
View
• The MVGBC does not require formal certification from a third-party organization. Instead, projects will be required to be designed and constructed to “meet the intent” of a third-party rating system.
• New Multi-Family 3 Units +: Meet the intent of LEED Gold • New Mixed Use: Meet the Intent of LEED Gold
• New Hotel: Meet the Intent of LEED Gold
• New Commercial: Meet the Intent of LEED Gold

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Appendix C
2 LEED Certification Requirements by California Jurisdiction Jurisdiction Trigger
San
Francisco
• New Large Commercial ≥ 25,000 SF: LEED v4 Gold
• New Res All Sizes: GreenPoint Rated or LEED v4 Silver • Major Res Alterations ≥ 25,000 SF AND significant structural upgrade AND mechanical, electrical, or plumbing: GreenPoint Rated or LEED v4 Silver • Large First-Time Commercial Interiors ≥ 25,000 SF: LEED v4 Gold • Major Nonres Alterations ≥ 25,000 SF: LEED v4 Gold
• Municipal New Construction, Additions/Alterations ≥10,000 square feet, including leasehold improvements: LEED v4 Gold
San José • Municipal projects 10,000 SF or more: LEED Gold certification • Large commercial industrial building or a large residential project or high-rise MF: Green building refundable deposit.
• Municipal buildings 15,000 SF or more and Privately-owned Residential or Nonresidential Buildings 20,000 SF or more: Energy and Water Building Performance Ordinance.

Commercial/Industrial - Tier 1 < 25,000 square feet: LEED Applicable NC Checklist Commercial/Industrial - Tier 2 ≥ 25,000 square feet: LEED Silver • Residential < 10 units Tier 1: GreenPoint or LEED Checklist • Residential ≥ 10 units Tier 2: GreenPoint Rated 50 points or LEED Certified • High Rise Residential (75' or higher): LEED Certified
Saratoga • Public buildings 5,000 SF or more: LEED Silver and City maintains LEED AP list Foster City • LEED Silver for individual projects (Gilead Sciences, Pilgrim Triton Master Plan and Chess/Hatch Offices)
Sunnyvale • Bonus and Max FAR for Nonresidential Development: LEED BD+C Platinum and whole building life cycle assessment
• New NR and Initial TIs > 5,000 sq. ft. 30,000 sq. ft. CALGreen Mandatory Measures and LEED Gold Level with verification by a LEED AP
• New NR and Initial TIs > 30,000 sq. ft. CALGreen Mandatory Measures and LEED Gold Level with USGBC Certification, including Design Phase Credits reviewed and approved by USGBC:
• All Major Alterations CALGreen Mandatory Measures and LEED Silver with verification by a

LEED AP
• New Public Facility ≤ 5,000 sq. ft.: CALGreen Mandatory Measures as applicable to the scope of work. Reviewed by City staff.
• New Public Facility > 5,000 sq. ft.: CALGreen Mandatory Measures and LEED Gold Level with verification by a LEED AP --
• All Major Alterations: CALGreen Mandatory Measures and LEED Silver with verification by a

LEED AP

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Appendix D
LEED Certification Alternative Compliance Policy Options Summary Table Policy Option Scope LEED Level CALGreen Requirements Key Benefits Implementation Considerations Option 1:

Standalone
LEED
Pathway
Allow LEED Gold
Certification as a
complete alternative
to CALGreen Tier 1
and Tier 2
requirements. Projects
still must comply with
CALGreen Mandatory
and local PAMC code
amendments.

LEED Gold
Certification
• Mandatory Measures
(Chapter 5)
• Local amendments
• Tier prerequisites/electives
do not apply
• Simplified compliance for
LEED projects
• Third-party verification via
GBCI
• Reduced administrative
burden
• Industry alignment
• Third-party oversight outside
City control
• Requires City verification
mechanism
• No Tier prerequisite
compliance
Option 2:

LEED + Tier
Prerequisites
Allow LEED Gold
Certification as an
alternative pathway
only if all CALGreen
Tier 1 or Tier 2
prerequisite measures
are still incorporated
into the project design
and construction.

LEED Gold
Certification
• Mandatory Measures
(Chapter 5)
• Local amendments
• All applicable Tier 1 or
Tier 2 prerequisites apply
• Maintains CALGreen
baseline standards
• Leverages LEED-
CALGreen synergies
• Preserves City
environmental goals
• Flexible compliance
pathway
• Requires documentation of
Tier prerequisite compliance
• More complex verification
process
• Need for periodic LEED-
CALGreen alignment review
Option 3:

Differentiate
by Project
Scope
Allow LEED Gold
Certification as an
alternative only for
Tier 2 projects. For Tier
1, the City selects one
of the following: 1)
Require LEED Silver, or
2) Exclude from LEED
option.

Tier 2:

LEED Gold

Tier 1:

LEED Silver
OR no
alternative
pathway
• Mandatory Measures
(Chapter 5)
• Local amendments
• Tier requirements as
applicable and
determined by City staff
• Tailored approach by
project complexity
• City control over Tier 1
pathway
• Aligns certification level
with project scope
• Requires City decision on Tier
1 approach
• Differentiated enforcement
mechanisms
• More complex policy
framework

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Appendix E

This page is left intentionally blank.

See next page for Appendix details.
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CALGreen / LEED BD+C v5 Comparison: Nonresidential Projects CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 35% (CALGreen A5.106.5.1.1)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV Readiness (or min. 10 spaces) for 1pt. LEED does not enhance this PAMC requirement. Projects would be subject to local amendments and Tier 1 requirements.
• Cool roof for reduction of heat island
effect - Tier 1 standards (CALGreen
A5.106.11.2)
No LEED eBD+C equivalent prerequisite. LEED credit Heat Island Reduction (SSc5) includes Option 1 Nonroof and Roof strategies, Option 2 100% Parking under cover, Option 3: Tree Equity. For roof areas, CALGreen Tier 1 requires an aged SRI value of 75 for low-sloped roofs (≤ 2:12), and 16 for steep-sloped roofs (> 2:12), and LEED requires an aged SRI value of 64 for low-sloped roofs (≤ 2:12), and 32 for steep-sloped roofs (> 2:12).

Tier 1 Water
Prerequisites
• Indoor water use reduction - 12%
(CALGreen A5.303.2.3.1)
LEED BD+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and no irrigation for outdoor water use or 30% reduction from the baseline.

CALGreen: Tier 1 only requires 12% reduction in indoor water use. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen Tier 2 and LEED requires 20% indoor water use reduction on all applicable water use fixtures compared to base case water consumption calculations as a prerequisite. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates. • Recycled content: 10% of materials
(CALGreen A5.405.4)
No LEED BD+C equivalent prerequisite. CALGreen Tier 1 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 10% by cost.

LEED does not have a requirement for installing products or using building materials with recycled content. Recycled content can be a strategy used for the Quantify and Assess Embodied Carbon (MRp2) and Building Product Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC

16.14.410/CALGreen A5.408.3.1)
No LEED BD+C equivalent prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 50% diversion and at least 10% of diverted materials must be salvaged or source-separated or 2pts for 75% diversion and at least 25% salvaged or source-separated. Projects would be subject to locally amended C&D diversion rate.
• Resilient flooring system - 90%
(CALGreen A5.504.4.7)
No LEED BD+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories).

LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED BD+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose under Path 2. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments.

CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 50% (CALGreen A5.106.5.1.1)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV Readiness (or min. 10 spaces) for 1pt. LEED does not enhance this PAMC requirement. Projects would be subject to local amendments and Tier 1 requirements.

Tier 2 Site
Prerequisites
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
Tier 1 Site
Prerequisites
Tier 1
Material
Prerequisites
Tier 1
Environmental
Quality
Prerequisites
Tier 2 CALGreen/ PAMC Requirements
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CALGreen / LEED BD+C v5 Comparison: Nonresidential Projects Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
• EV Charing Infrastructure
º parking areas 10-20 spaces - 20%
EVSE or 20% EV Capable or EVSE Ready
º parking areas ≥ 20 spaces - 15%
EVSE and 15% EV Capable or EVSE
Ready (PAMC 16.14.400/ CALGreen
A4.106.5.3)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV Readiness (or min. 10 spaces) for 1pt. PAMC currently requires 20% EV Capable or EV Ready, 20% EVSE Installed (10-20 parking spaces) and 15% EV Capable or EV Ready and 15% EVSE Installed (over 20 parking spaces).

CALGreen requires 10% for existing when electrical/lighting or panel upgrade is included in scope, PV added, or alterations trigger CALGreen.

LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Cool roof for reduction of heat island
effect Tier 2 standards (CALGreen
A5.106.11.2)
No LEED BD+C equivalent prerequisite. LEED credit Heat Island Reduction (SSc5) includes Option 1 Nonroof and Roof strategies, Option 2 100% Parking under cover, Option 3: Tree Equity. For roof areas, CALGreen Tier 2 requires an aged SRI value of 82 for low-sloped roofs (≤ 2:12), and 27 for steep-sloped roofs (> 2:12) and LEED requires an aged SRI value of 64 for low-sloped roofs (≤ 2:12), and 32 for steep-sloped roofs (> 2:12).

Tier 2 Water
Prerequisites
• Indoor water use reductions - 20%
(CALGreen A5.303.2.3.1)
LEED BD+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and no irrigation for outdoor water use or 30% reduction from the baseline.

CALGreen: 20% reduction required for Tier 2. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen and LEED require 20% water use reduction on all applicable water use fixtures compared to base case water consumption calculations. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates.
• Recycled content: 15% of materials
(CALGreen A5.405.4)
No LEED BD+C equivalent prerequisite. CALGreen Tier 2 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 15% by cost.

LEED does not have a requirement for installing products or using building materials with recycled content. Recycled content can be a strategy used for the Quantify and Assess Embodied Carbon (MRp2) and Building Product Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC

16.14.410/CALGreen A5.408.3.1)
No equivalent LEED BD+C prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 50% diversion and at least 10% of diverted materials must be salvaged or source-separated or 2pts for 75% diversion and at least 25% salvaged or source-separated. Projects would be subject to locally amended C&D diversion rate.
• Resilient flooring system - 100%
(CALGreen A5.504.4.7)
No LEED equivalent BD+C prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories).

LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED equivalent BD+C prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose under Path 2. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments.
1 Projects that pursue LEED Certification would still be subject to CALGreen Mandatory requirements (Chapter 4 for residential and Chapter 5 for nonresidential), as well as any applicable locally amended building requirements in PAMC 16.14 (CALGreen) and PAMC 16.17 (Energy Code). 3 LEED v5 BD+C includes the following prerequisites: IPp1 Climate Resilience Assessment, IPp2 Human Impact Assessment, IPp3 Carbon Assessment, IPp4 Tenant Guidelines (C&S), SSp1 Minimized Site Disturbance, WEp1 Water Metering and Reporting, WEp2 Minimum Water Efficiency, EAp1 Operational Carbon Projection and Decarbonization Plan, EAp2 Minimum Energy Efficiency, EAp3 Fundamental Commissioning, EAp4 Energy Metering and Reporting, EAp5 Fundamental Refrigerant Management, MRp1 Planning for Zero Waste Operations, MRp2 Quantify and Assess Embodied Carbon, EQp1 Construction Management, EQp2 Fundamental Air Quality, EQp3 No Smoking or Vehicle Idling.

Tier 2 Site
Prerequisites
Tier 2
Material
Prerequisites
2 CALGreen Divisions A4.6 and A5.6 outline the Tier 1/Tier 2 prerequisites a project must meet to achieve CALGreen tier status. In addition the divisions specify the number of electives from each CALGreen Division Category a project must choose. PAMC does not require Tier 1 and Tier 2 projects to comply with the CALGreen Energy Efficiency Tier requirements due to the local Energy Reach Code requirements.

Tier 2
Environmental
Quality
Prerequisites
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Appendix F

This page is left intentionally blank.

See next page for Appendix details.
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CALGreen / LEED ID+C v5 Comparison: Nonresidential Projects CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 35% (CALGreen A5.106.5.1.1)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc3) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments and Tier 1 requirements. • Cool roof for reduction of heat island
effect - Tier 1 standards (CALGreen
A5.106.11.2)
No LEED ID+C equivalent prerequisite. There is no LEED v5 ID+C cool roof requirement.

Tier 1 Water
Prerequisites
• Indoor water use reduction - 12%
(CALGreen A5.303.2.3.1)
LEED ID+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and newly installed appliances must meet additional water use requirements.

CALGreen: Tier 1 only requires 12% reduction in indoor water use. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen Tier 2 and LEED requires 20% indoor water use reduction on all applicable water use fixtures compared to base case water consumption calculations as a prerequisite. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates.
• Recycled content: 10% of materials
(CALGreen A5.405.4)
No LEED ID+C equivalent prerequisite. CALGreen Tier 1 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 10% by cost.

LEED does not have a requirement for installing products or using building materials with recycled content. Recycled content can be a strategy used for the Quantify and Assess Embodied Carbon (MRp2) and Building Product Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC

16.14.410/CALGreen A5.408.3.1)
No LEED ID+C equivalent prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 35% diversion and at least 10% of diverted materials must be salvaged or source-separated, 2 points for 50% diversion and at least 20% of diverted materials must be salvaged or source-separated, 3 points for 65% diversion and at least 30% of diverted materials must be salvaged or source-separated.

Additionally, 1 point may be achieved if the project exceeds 10% of all salvaged or source separated and recycled clean gypsum, carpet, ceiling and furniture.

Projects would be subject to locally amended C&D diversion rate. • Resilient flooring system - 90%
(CALGreen A5.504.4.7)
No LEED ID+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories). LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED ID+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose. LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.

CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 50% (CALGreen A5.106.5.1.1)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc3) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments and Tier 1 requirements.

Tier 2 Site
Prerequisites
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
Tier 1 Site
Prerequisites
Tier 1 Material
Prerequisites
Tier 1
Environmental
Quality
Prerequisites
Tier 2 CALGreen/ PAMC Requirements
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CALGreen / LEED ID+C v5 Comparison: Nonresidential Projects Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
• EV Charing Infrastructure
º parking areas 10-20 spaces - 20%
EVSE or 20% EV Capable or EVSE Ready
º parking areas ≥ 20 spaces - 15%
EVSE and 15% EV Capable or EVSE
Ready (PAMC 16.14.400/ CALGreen
A4.106.5.3)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. PAMC currently requires 20% EV Capable or EV Ready, 20% EVSE Installed (10-20 parking spaces) and 15% EV Capable or EV Ready and 15% EVSE Installed (over 20 parking spaces). CALGreen requires 10% for existing when electrical/lighting or panel upgrade is included in scope, PV added, or alterations trigger CALGreen.

LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Cool roof for reduction of heat island
effect Tier 2 standards (CALGreen
A5.106.11.2)
No LEED ID+C equivalent prerequisite. There is no LEED v5 ID+C cool roof requirement.

Tier 2 Water
Prerequisites
• Indoor water use reductions - 20%
(CALGreen A5.303.2.3.1)
LEED ID+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and and newly installed appliances must meet additional water use requirements.

CALGreen: 20% reduction required for Tier 2. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen and LEED require 20% water use reduction on all applicable water use fixtures compared to base case water consumption calculations. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates.
• Recycled content: 15% of materials
(CALGreen A5.405.4)
No LEED ID+C equivalent prerequisite. CALGreen Tier 2 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 15% by cost.

LEED does not have a requirement for installing products or using building materials with recycled content. Recycled content can be a strategy used for the Quantify and Assess Embodied Carbon (MRp2) and Building Product Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC

16.14.410/CALGreen A5.408.3.1)
No equivalent LEED ID+C prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 35% diversion and at least 10% of diverted materials must be salvaged or source-separated, 2 points for 50% diversion and at least 20% of diverted materials must be salvaged or source-separated, 3 points for 65% diversion and at least 30% of diverted materials must be salvaged or source-separated.

Additionally, 1 point may be achieved if the project exceeds 10% of all salvaged or source separated and recycled clean gypsum, carpet, ceiling and furniture.

Projects would be subject to locally amended C&D diversion rate. • Resilient flooring system - 100%
(CALGreen A5.504.4.7)
No LEED ID+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories). LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED ID+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose under Path 2. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments.
1 Projects that pursue LEED Certification would still be subject to CALGreen Mandatory requirements (Chapter 4 for residential and Chapter 5 for nonresidential), as well as any applicable locally amended building requirements in PAMC 16.14 (CALGreen) and PAMC 16.17 (Energy Code). 3 LEED v5 ID+C includes the following prerequisites: IPp1 Climate Resilience Assessment, IPp2 Human Impact Assessment, IPp3 Carbon Assessment, WEp1 Minimum Water Efficiency, EAp1 Estimated Energy Use and Operational Carbon Projection, EAp2 Minimum Energy Efficiency, EAp3 Fundamental Commissioning, EAp4 Energy Metering and Reporting, EAp5 Fundamental Refrigerant Management, MRp1 Planning for Zero Waste Operations, MRp2 Quantify and Assess Embodied Carbon, EQp1 Construction Management, EQp2 Fundamental Air Quality, EQp3 No Smoking.

Tier 2 Site
Prerequisites
Tier 2 Material
Prerequisites
2 CALGreen Divisions A4.6 and A5.6 outline the Tier 1/Tier 2 prerequisites a project must meet to achieve CALGreen tier status. In addition the divisions specify the number of electives from each CALGreen Division Category a project must choose. PAMC does not require Tier 1 and Tier 2 projects to comply with the CALGreen Energy Efficiency Tier requirements due to the local Energy Reach Code requirements.

Tier 2
Environmental
Quality
Prerequisites
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City Council
Staff Report
From: City Manager and City Clerk
Report Type: ACTION ITEMS
Lead Department: City Manager
Meeting Date: October 6, 2025
Report #:2508-5072
TITLE
Review of State and Local Ballot Measures Appearing on the November 4, 2025 Ballot and Consideration of Possible City Council Positions

RECOMMENDATION
Staff recommends that the City Council review state and local (City, County, and Regional) ballot measures presented to Palo Alto voters at the November 4, 2025 election and consider adoption of positions if desired by the City Council.

BACKGROUND
The City Council routinely reviews and considers adopting positions on state or local ballot measures appearing before Palo Alto voters in election years. This agenda item is intended to provide information to voters to consider when voting and provide a forum for City Council discussion and consideration of positions of the measures based on impacts to Palo Alto.1 This report notes when a ballot measure aligns with the City Council-approved Legislative Guidelines.2 Alignment with the Guidelines does not obligate the City Council to take a position.

The City Council may opt not to take positions on some or all of the measures.

There is a statewide special election on November 4, 2025. The Santa Clara County Registrar of Voters will begin mailing out ballots on October 6. Ballots may be returned by mail, at a drop-off location, County elections office, or a Vote Center. Vote Center locations in Palo Alto as of the 1 California law allows local legislative bodies, acting as a body, to take a position on behalf of the city on ballot measures. This is a limited exception, recognized by California courts, to the general rule prohibiting use of public resources for political activity. The Council’s decision should be made during a regular Council meeting that is open to the public and where members of the public may express their views. League of Women Voters v. Countywide Crim. Just. Coordination Com., 203 Cal. App. 3d 529, 560 (Ct. App. 1988); Vargas v. City of Salinas, 46 Cal. 4th 1, 36 (2009).
2 City of Palo Alto’s 2025 Federal and State Legislative Guidelines:
https://www.paloalto.gov/files/assets/public/v/1/city-manager/legislation/2025-legislative-guidelines.pdf Item 11
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publication of this report are below. These locations are subject to change, and residents are encouraged to check the County’s website for up-to-date information5. Ventura Community Center – Activity Center, 3990 Ventura Ct. Open October 25 – November 3 from 9:00am – 5:00pm. Open November 4 from 7:00am – 8:00pm Mitchell Park Community Center – El Palo Alto Room, 3700 Middlefield Rd. Open November 1 – November 3 from 9:00am – 5:00pm. Open November 4 from 7:00am – 8:00pm
Palo Alto Buddhist Temple – Issei Hall, 2751 Louis Rd. Open November 1 – November 3 from 9:00am – 5:00pm. Open November 4 from 7:00am – 8:00pm

ANALYSIS
The November 4, 2025 election includes one statewide ballot measure and one Santa Clara County ballot measure. There are no measures from other relevant local jurisdictions (such as the City, Palo Alto Unified School District, or regional bodies such as the Valley Transportation Authority (VTA)). The information below summarizes the two ballot measures on the November 2025 ballot.

Proposition 50
Prop 50 language as it will appear on the ballot is below. Arguments for and against the measure and rebuttal arguments are available in the California Secretary of State Official Voter Information Guide6.

AUTHORIZES TEMPORARY CHANGES TO CONGRESSIONAL DISTRICT MAPS IN RESPONSE TO TEXAS’ PARTISAN REDISTRICTING. LEGISLATIVE CONSTITUTIONAL AMENDMENT.

Requires temporary use of new congressional district maps through 2030. Directs independent Citizens Redistricting Commission to resume enacting congressional district maps in 2031. Establishes policy supporting nonpartisan redistricting commission nationwide. Fiscal Impact: One-time costs to counties of up to a few million dollars statewide to update election materials to reflect new congressional district maps.

Relevant Local Legislative Guideline(s): None. There are no legislative guidelines relating to redistricting.
5 Santa Clara County Registrar of Voters November 4, 2025, Statewide Special Election https://vote.santaclaracounty.gov/elections/november-4-2025-statewide-special-election 6 California Secretary of State Official Voter Information Guide https://voterguide.sos.ca.gov/ Item 11
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Measure A
Measure A is a local measure placed on the ballot by Santa Clara County. Measure A language as it will appear on the ballot is below. Arguments for and against the measure, rebuttal arguments, and an impartial analysis are available on the Santa Clara County Registrar of Voters’ website.9 To help our community address severe federal cuts enacted by the President and Congress; support critical local services such as trauma, emergency room, mental health, and public safety; and reduce the risk of hospital closures at Santa Clara Valley Healthcare and other service cuts – shall the County of Santa Clara adopt a five-eights cent (0.625%) general sales tax for 5 years, providing $330 million annually that is not available to the federal governments and is subject to independent audits/oversight?
Supporters: Daniel Nelson, MD; Emiko Rivera, RN; Sara Cody, Health Dir Ret; Otto Lee, Brd Pres; Douglas Sporleder, Fire Chf Ret
Opponents: None submitted.

Relevant Local Legislative Guideline(s): None. There are no legislative guidelines relating to City administration of healthcare services.

In previous years, the City Council has been interested in positions taken by statewide organizations. As of the writing of this report, the League of California Cities has not taken a position on Proposition 50. The League of Women Voters of California has chosen not to take a position on Proposition 50.

FISCAL/RESOURCE IMPACT/ATTACHMENTS
None.

STAKEHOLDER ENGAGEMENT
The City Council is expected to hold a study session at its September 29, 2025 meeting with Santa Clara County staff regarding Measure A.

ENVIRONMENTAL REVIEW
The Council’s consideration of positions on state and local ballot measures is not a project under section 15378(b)(25) of the California Environmental Quality Act Guidelines (administrative activities that will not result in direct or indirect physical change in the environment).

APPROVED BY:

Ed Shikada, City Manager & Mahealani Ah Yun, City Clerk 9 Santa Clara County Registrar of Voters List of Local Measures: https://vote.santaclaracounty.gov/list-local- measures-2
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City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Public Works
Meeting Date: October 6, 2025
Report #:2504-4477
TITLE
2024 Annual Airport Noise Report and 2025 Noise Program Initiatives

RECOMMENDATION
This is an Informational Report. No Council action is required.

BACKGROUND
The objective of the Palo Alto Airport (PAO) Annual Aircraft Noise Report is to analyze noise patterns in the vicinity and assess adherence to established voluntary noise abatement procedures. The 2024 Annual Aircraft Noise Report (Attachment A) was compiled by Airport Division staff of the Public Works Department, utilizing data from aircraft noise complaints received throughout the 2024 calendar year. This report is generated on an annual basis and posted on the Airport’s webpage.

PAO receives noise complaints via email at [email protected] and a designated hotline at (650) 329-2405. Staff reviews and responds timely to all complaints, ascertaining from complainants their contact information and the date, time, and description of the offending occurrence. Staff reviews and compiles the data to determine flying activity trends. Staff contacts pilots when violations are observed or reported, advising them of established procedures, requesting compliance, and reminding them about the City’s strong commitment to limiting the community impacts from airport noise.

ANALYSIS
PAO continues to be one of the busiest general aviation airports in the Bay Area, averaging over 150,000 annual operations since 2015. In calendar year 2024, the Airport totaled 150,123 operations, representing a slight increase compared to 2023.

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In 2024, the Airport received a total of 110 noise complaints from 51 individual households. The majority of complaints originated from residents in the City of Palo Alto, with the second highest volume of complaints coming from East Palo Alto.

The Airport’s location within the region’s complex and congested airspace – bounded by San Francisco Class B, San Jose Class C, and Moffett Field airspace – continues to influence aircraft routing and limits operational flexibility. Despite these constraints, Airport staff remain committed to promoting voluntary noise abatement procedures and continue to engage with Airport users to minimize noise impacts on surrounding communities.

To support these efforts, Airport staff began conducting monthly coordination meetings with Airport users and FAA Air Traffic Control personnel. These meetings allow for the discussion of noise abatement procedures and identify effective strategies for communicating with both based and transient1 pilots. As a result of the ongoing meetings, the Airport’s noise abatement flyer was revised and updated to more clearly communicate procedures and improve pilot awareness.

Additionally, PAO staff have participated in regional Bay Area Airport Managers meetings to explore a centralized website to consolidate noise abatement procedures throughout the Bay Area. The goal of this initiative is to improve pilot access to noise-related information and promote greater awareness of recommended procedures across the region. This effort remains an ongoing project and collaboration will continue with participating airports.

To enhance noise monitoring, staff entered into a contract with 1200.Aero and is currently testing a new web-based software system implemented in March 2024. Initial testing is focused on Runway 31, which comprises approximately 90% of operations, with geofencing in place to identify potential deviations from the Airport’s noise abatement procedures over East Palo Alto. The geofenced area over East Palo Alto was set up to monitor for straight out departures and early left turns which do not conform to the noise abatement procedures. Additional geofencing will be applied over Palo Alto and Menlo Park as testing progresses to ensure comprehensive monitoring.

This system enables real-time monitoring and tracking of aircraft operations, providing staff with a proactive method of reviewing flights for adherence to the Airport’s noise abatement procedures. An example of a notification can be seen below. The Airport’s noise abatement procedures request that pilots make a 10 degree turn to the north and avoid turning left until the Dumbarton Auto Bridge. In the example flight, the aircraft made an early left turn, entering into the geofenced area over East Palo Alto and triggering a notification. This software reduces the dependency on community complaints and allows for a more proactive review of flights for potential violations. It should be noted that Air Traffic Control directions supersede noise 1 Transient pilots are pilots whose aircraft are based at other airports.

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abatement procedures, and the below operations would not be considered a deviation if directed by Air Traffic Control.

With 1200. Aero, staff can geofence specific areas and monitor operations within those zones.

Whenever an aircraft enters a geofenced area, staff receives automatic notifications. Staff can then promptly review flight data and assess whether a deviation from procedures occurred and determine whether the operation was a result of Air Traffic Control instruction or other justifiable circumstances. Staff then follows up with pilots to provide education and promote awareness of recommended procedures. It is important to note that not every generated notification constitutes a violation of the noise abatement procedures. Staff continue to work closely with 1200. Aero to refine the system’s parameters and improve the accuracy of notifications.
1200. Aero began collecting data in April, and between April 3, 2025, and June 30, 2025 the system identified 705 incursions into the airspace above East Palo Alto. After review, staff determined that 560 of these were actual deviations from recommended noise abatement procedures. The remaining flights included arrivals entering the airspace at approximately 1,000 feet which is consistent with noise abatement procedures, aircraft transitioning through the area without operating at PAO, or flights directed by Air Traffic Control for spacing or safety reasons. Staff attempts to contact pilots who do not follow the recommended procedures; however, outreach to transient pilots can be challenging. Airport Operations has been able to follow up on approximately 50% of deviations, as contact information is not available for the remainder. In June, the Airport implemented transient billing software that requests pilots Item A
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check in upon landing, which has provided email contacts for many transient pilots and expanded outreach opportunities. Since June, the percentage of deviations responded to has increased, and will continue to rise as contact information is logged. In addition, staff coordinates with neighboring airports to request that they notify pilots based at those airports and reciprocates when other airports request the same.

Additionally, 1200. Aero relies on publicly available ADS-B data and registration information, which is subject to potential changes in FAA policy. The FAA has proposed rules that could restrict access to registration and ADS-B information. In response, the City submitted formal comments on June 4, 2025, emphasizing the critical importance of maintaining access to this data to support the Airport’s noise monitoring and abatement programs.3

FISCAL/RESOURCE IMPACT
There is no direct fiscal impact associated with this informational report.

STAKEHOLDER ENGAGEMENT
The Airport has consistently engaged stakeholders of the Airport and will continue to collaborate with them regarding noise concerns and complaints. Airport staff attends monthly meetings with the Palo Alto Airport Association, representing a diverse array of Airport users including flight schools, charter flight operators, corporate pilots, and private users. Trends in noise abatement are a common topic of discussion during those meetings.

Additionally, staff actively participates in educational and informational conferences, such as the University of California at Davis Noise & Emissions Symposium Conference, to stay abreast of the latest industry trends and innovations pertaining to noise and emissions at the Airport.

ENVIRONMENTAL REVIEW
This item is informational in nature and does not constitute a project under the California Environmental Quality Act (CEQA).

ATTACHMENTS
Attachment A: 2024 Annual Palo Alto Airport Noise Report APPROVED BY:

Brad Eggleston, Director Public Works/City Engineer
3 Comment on FAA Proposal To Withhold Certain Aircraft Registration Information From Public Dissemination (Docket No. FAA-2025-0638); https://www.paloalto.gov/files/assets/public/v/1/public-works/palo-alto- airport/airplane-noise/june-4-2025-comment-on-faa-proposal-to-withhold-certain-aircraft-registration- information-from-public-disemination.pdf
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PALO ALTO

AIRPORT

PUBLIC WORKS DEPARTMENT
2024

ANNUAL NOISE REPORT
(January 2024 to
December 2024)
Vision: Palo Alto Airport strives to balance the
interests of pilots to fly with the interests of
neighbors in a peaceful living environment. This
document is a report of the noise complaints
received by the airport in 2024. Airport staff uses
this information to identify trends within Palo Alto
and neighboring communities. These trends inform
communications between airport staff and pilots on
the issue of noise.

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Introduction:

The following is a report on noise-related operations and complaints received by Palo Alto Airport (PAO) in 2024. The Federal Aviation Administration (FAA) defines air travel routes and procedures, including defining separation distances between aircraft, determining hazards to aviation and all other safety criteria for aircraft, and is responsible for directing and enforcing the movement of aircraft in flight.

Although organizations can petition the FAA regarding flight procedures, the FAA has the final say in what is safe and acceptable. The Airport Noise and Capacity Act (ANCA) of 1990 federally prohibits public-use airports from restricting airspace.

The FAA measures noise based on the Yearly Day and Night Average Sound Level (DNL) and the Community Noise Equivalent Level (CNEL). While both are essentially the same, airports in California use the CNEL method to measure noise. CNEL is a method of averaging single event aircraft noise into a weighted 24-hour average. The system adds penalties to all events occurring during the evening (7pm – 10pm) and the night (10pm – 7am). The Santa Clara County Airport Land Use Commission (SCC ALUC) performed a noise study for the Palo Alto Airport using the CNEL to determine the noise contours for 55, 60, 65, and 70 decibels. The contour map is included as Attachment A.

Regarding safety and altitude, the FAA has in place Federal Aviation Regulations (FARs) that establish Minimum Safe Altitudes (MSAs) for aircraft. For fixed wing aircraft, the MSA is 1,000 feet above ground when over congested areas and 500 feet when not over congested areas. These MSAs apply to all fixed wing aircraft except when necessary for landing and takeoff operations. Helicopters are exempt from these altitude restrictions due to the nature of their flight. These minimum altitudes are enforced by the FAA Flight Standards District Office in San Jose, not by Palo Alto Airport. Palo Alto Airport cannot tell pilots when or where to fly; the Airport, however, does have voluntary noise abatement procedures that Palo Alto Airport recommends that pilots follow. (See the Noise Abatement Procedures section below.) The Airport receives noise complaints via email at [email protected] and a noise complaint hotline 650-329-2405. Airport staff review and timely respond to all complaints, ascertaining information from complainants including contact information, date, time, and description of the occurrence. Various flight trackers can be used to help identify the aircraft involved and verify if FAA regulations or Palo Alto Airport procedures were violated. The Airport staff reviews and compiles all data to determine trends with flying activities.

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Purpose:

The purpose of the Palo Alto Airport Annual
Noise Report is to identify noise trends in the
surrounding areas and determine compliance
with established voluntary noise abatement
procedures.

Airspace:

The Palo Alto Airport airspace is unique. The
congested Bay Area airspace is dominated by
SFO Class Bravo airspace, which encompasses
a 30 nautical mile radius around SFO.

Underneath the Class Bravo airspace lies the
Class Charlie airspace of Oakland and San Jose
International Airports. Finally, Moffett Airfield lies approximately 4 nautical miles to the southeast of Palo Alto Airport.

As a result, Palo Alto Airport airspace ends only 1.5 nautical miles southeast of the Palo Alto Airport’s single runway (Runway 13/31). To land at Palo Alto Airport, aircraft must turn before entering Moffett’s airspace, resulting in aircraft having to space themselves in traffic patterns over the peninsula when takeoff/landing volumes peak. The FAA’s Air Traffic Control Tower (ATCT) at Palo Alto Airport has a letter of agreement with Moffett’s ATCT providing Palo Alto Airport aircraft with extensions into Moffett airspace when Moffett airfield is not in use. The additional airspace is a useful mitigation tool during busy times.

Further restrictions in Palo Alto Airport airspace come from San Jose Class C airspace, starting at 1,500 feet Mean Sea Level, just southeast of Palo Alto Airport and SFO Class B airspace, starting at 2,500 feet Mean Sea Level, just northeast of the Palo Alto Airport. Both are identified on the Palo Alto Airport Sectional Map: San Jose Class C is shown with thick magenta lines and SFO Class B is shown with thick blue lines. These restrictions play a vital role in aircraft departures, in turn influencing noise abatement procedures for the Palo Alto Airport.

Noise Abatement Procedures:

Noise abatement procedures are voluntary procedures that the Airport asks pilots to follow. The Airport is prohibited from restricting airspace. Palo Alto Airport staff will speak with individual pilots and educate them about the voluntary noise abatement procedures. The Palo Alto Airport cannot levy fines on pilots that violate the voluntary noise procedures. For illustrated noise abatement procedures reference Palo Alto Airport Pilots Handout included as Attachment B.

The noise abatement procedures depend on the runway that is in use at the time. Depending on weather patterns, aircraft can depart on Runway 31 to the northwest or Runway 13 to the southeast.

Approximately 90% of the time, weather conditions require the use of Runway 31. Pilots are asked to not make a left crosswind departure from Runway 31, but instead make a “Left Dumbarton Departure” (fly to the Dumbarton Auto Bridge before making a left turn and flying over East Palo Alto) or a right 270 degree turn before departing to the south or west. When aircraft are using Runway 13, pilots are asked Palo Alto Airport Sectional Map
Palo Alto Airport in Green
PAO Airspace highlighted in Red
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to make a left 270-degree turn. In addition to these procedures, pilots are asked to climb to 1,500 feet or above ground before crossing Highway 101 and reduce power when safely able.

For arrivals, it is standard practice and necessary for pilots to descend to pattern altitude before entering the traffic pattern around PAO, sometimes requiring aircraft to descend below the 1,500 feet minimum of departing aircraft over Palo Alto. As these aircraft are descending to land the engines are generally powered back and quieter than ascending aircraft.

Airport staff continuously engage with tenants and pilots about the voluntary noise abatement procedures, always noting that safety always supersedes noise.

Findings:

The Palo Alto Airport remains one of the busiest general aviation Airports in the Bay Area with an average of 150546.8 operations per year since 2015. Airport Operations for the calendar year of 2024 increased .17% compared to the calendar year 2023. An operation is defined as either a takeoff or a landing and a touch-and-go procedure will account for two operations.

Table 1. Airport Operations for Palo Alto Airport
Year Air Taxi Military Total Year
Air
Taxi Military Total
2005 2397 28 184821 2015 1082 118 172132
2006 1932 17 176570 2016 708 52 153238
2007 1440 318 181883 2017 872 146 148769
2008 1697 280 174332 2018 760 133 146181
2009 1650 301 155556 2019 920 63 150266
2010 2077 6 158217 2020 620 45 112712
2011 1572 8 170389 2021 566 23 158568
2012 1700 16 176564 2022 636 37 163620
2013 1628 14 172653 2023 763 21 149859
2014 1518 22 179900 2024 666 29 150123
AVG 1761.1 101 173088.5 AVG 759.3 66.7 150546.8
During the 2024 Calendar year, the Airport logged 110 total noise complaints from 51 households. While the quarterly household counts add up to 60, the actual total unique households for 2024 are 51. This difference occurs because some households submitted complaints in multiple quarters, but they are only counted once in the yearly total. Table 2 shows the number of complaints by quarter and includes the totals from 2023.

Table 2. Complaints Received
Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total 2024 Total 2023 Complaints 20 24 37 29 110 256
Households 11 13 16 20 51 23
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Table 3 sorts the complaints logged into three sections. The first one is PAO which includes all complaints that involve aircraft that performed an operation at the Airport. The next section is General, which includes complaints that did not include a specific aircraft or incident of noise. These complaints may or may not involve aircraft from PAO. The last section is non-PAO, which include aircraft that are not based or did not operate at the Airport. These flights may include California Highway Patrol, Coast Guard, Air Taxis, Pipe Surveys, Stanford Life Flight, Angel Flights, and banner towing operations. Also included in Table 3 are the totals for 2023.

Table 3. Aircraft Association
Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total 2024 Total 2023 PAO 16 18 32 22 88 236
General 2 3 1 5 11 4
Non-PAO 2 3 4 2 11 16
Table 4 below provides a detailed breakdown of the 110 complaints by City. Most complaints came from the City of Palo Alto, with 54 complaints logged from 12 households.

Table 4. PAO Noise Complaints by City
Quarter
1 Quarter 2 Quarter 3 Quarter 4 Total
2024 Total 2023
City C H C H C H C H C H C H
Cupertino 1 1
East Palo Alto 5 3 3 2 6 5 2 2 16 10 4 4
Half Moon Bay 2 1 6 2 8 2
Ladera 3 3 3 3
Livermore 1 1 1 1
Los Altos 4 1
Menlo Park 12 2
Mountain View 1 1 1 1 1 1
Newark 2 2 3 3 2 2 7 7 1 1
Palo Alto 7 3 14 5 25 6 8 4 54 15 227 8
Pleasanton 1 1 1 1 2 1
Portola Valley 2 1 2 1 4 1 1 1
San Jose 3 1 1 1 4 1
Stanford 1 1 1 1 2 2
Sunnyvale 2 1 3 3 5 3 1 1
Union City 1 1 1 1
Unknown 1 1 1 1 2 2 1 1
Woodside 1 1 1 1 1 1
Total 21 12 24 13 37 16 29 20 110 51 256 23
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Table 5 below shows the general type of aircraft identified as causing noise complaints at the Airport.

There are 2 types of engines for aircraft utilizing PAO. The first is reciprocating which is similar to an automobile engine, and the second is turboprop which is a turbine engine with a propeller that produces thrust. Aircraft are further differentiated by “multi” and “single” which denotes the number of engines for the aircraft. As Table 5, shows single reciprocating aircraft produced the largest portion of noise complaints. This class of aircraft represents most of the fleet at PAO and usually consists of Cessna, Piper, and Cirrus aircraft.

Table 5. Aircraft Type
Helicopter Multi-
Reciprocating
Multi-
Turboprop
Single-
Reciprocating
Single-
Turboprop Unknown Drone
2024 Complaints 7 2 5 68 10 6
2023 Complaints 1 3 4 127 7 101 9
Table 6 below shows the number of violations of the established noise abatement procedures. Airport staff makes every effort to talk to all pilots that violate these procedures, but it is difficult to talk to all transient pilots about noise abatement procedures. It is not the role of the FAA Air Traffic Control Tower to advise pilots of the noise abatement procedures, however, the City has developed a working relationship with the Air Traffic Control Tower (ATCT) and Air Traffic Controllers do advise pilots of the noise abatement procedures when they have the ability to do so.

Table 6. Observed Violations of Noise Abatement Procedures Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total
Tenant 2 6 7 4 19
Transient 1 4 7 2 14
Unknown 1 1 2
Total 3 10 15 7 35
Complaints 20 24 37 29 110
Operations 33,061 40,904 41,267 34,891 150123
% Compliance 99.94% 99.94% 99.91% 99.91% 99.93%
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Attachment A
PAO Noise Contour Map

Following is a noise contour map for PAO, adopted by the Santa Clara County Airport Land Use Commission (SCC ALUC) in their 2008 Comprehensive Land Use Plan, reflecting the forecasted noise contours for Palo Alto Airport in 2022.

SCC ALUC used the Integrated Noise Model which considers airport altitude, mean temperature, runway configuration, aircraft flight track definition, aircraft departure and approach profiles, aircraft traffic volume and fleet mix, and flight track utilization by aircraft types. All data is entered into the CNEL formula to prepare the noise contours for Palo Alto Airport.

The 65 decibel (dB) noise level of the Airport extends beyond the airport boundaries, but is only over Palo Alto Golf Course, Palo Alto Baylands Nature Preserve, and the salt marshes in San Mateo County.

Refer to https://stgenpln.blob.core.windows.net/document/ALUC_PAO_CLUP.pdf, for a more detailed description of how the SCC ALUC prepared this map.

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2022 Forecasted Palo Alto Airport Noise Contour Map
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Attachment B
PAO Pilot Handout
Santa Clara County created a Pilot Handout for Palo Alto Airport that described the noise abatement procedures. When the City of Palo Alto assumed control of the Airport, the existing noise abatement procedures were adopted, with one exception, “pilots must maintain 1,500 feet or above across Highway 101” was replaced with “Aircraft are asked to climb to and maintain at least 1,500 feet before crossing Highway 101.” The change is consistent with the voluntary nature of noise abatement procedures as Airports are Federally prohibited from instructing pilots how to fly. In 2024, Airport staff worked with airport users and FAA Air Traffic Controllers to update the handout to better illustrate the Airports Voluntary Noise Abatement Procedures.

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Attachment C
Map of Palo Alto Households
39 1
39 1
1 1
1 2
39 1
There were 7 complaints
from 7 households that
did not provide
addresses.

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City Council
Staff Report
From: CAO Committee
Report Type: CONSENT CALENDAR
Lead Department: Human Resources
Meeting Date: October 6, 2025
Report #:2509-5249
TITLE
Approve the selection of Teri Black & Company as the executive recruitment firm for the recruitment of the City Attorney and Approve the Recruitment General Timeline as Recommended by the Council Appointed Officers (CAO) Committee. CEQA status – not a project.

RECOMMENDATION
The Council Appointed Officers Committee (CAO) recommends that Council approve:

1. Teri Black & Co. as the executive recruitment firm for the recruitment of the next City Attorney

2. Approve the general timeline and process for recruitment as outlined and delegate approval of interview process details to the CAO Committee Chair.

BACKGROUND
The City Attorney is one of four Council Appointed Officer positions defined in Article IV of the City Charter and further defined in the Palo Alto Municipal Code, section 2.08.120 which states that the City Attorney is accountable to the City Council. On September 9, 20251, the CAO Committee reviewed initial proposals from three highly qualified executive recruitment firms in order to select a firm for the purpose of recruiting the City’s next City Attorney. Based on review of the proposals and need to ask follow-up questions, the CAO Committee determined it prudent to conduct interviews. The Committee also asked staff to begin drafting the content for the recruitment brochure and gain input from the current City Attorney.

The CAO committee met again on September 22, 20252 to conduct interviews, review draft content for a brochure, and make final selections and provide recommendations to 1 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=17948 2 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=18033 Item AA1
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Council. The CAO committee interviewed Bob Murray and Associates and Teri Black & Company. Peckham and McKenney did not make a representative available for interviews.

The CAO committee through these deliberations selected Teri Black & Co. executive recruitment firm to conduct the recruitment process for the selection of the City’s next City Attorney. Furthermore, the committee provided the following guidance on process and advertising preferences:
Council interviews to occur after stakeholder and subject matter expert interviews; and To the extent feasible hold Council interviews, panel stakeholder interviews and final round interviews on back-to-back days.

The CAO committee unanimously approved this recommendation to the full Council.

ANALYSIS
The CAO Committee selected Teri Black & Co. (TB&C) to conduct the executive recruitment for the City Attorney as this firm has an extensive understanding of the Palo Alto organization as well as the region. Most recently, TB&C, has successfully recruited placements for City Attorney/Deputy/Assistant City Attorney searches for the Cities of Burlingame, Cupertino, Fremont, Milpitas, Mountain View, Palo Alto, Santa Clara and the Town of Los Gatos. The proposal submitted by TB&C for this recruitment is attached.

Process and Timeline

RECRUITMENT
STAGES  TIMELINE  ACTION ITEMS
Recruitment Pre-
Planning
August 2025 -
September 2025
Review of executive firms recommended
Review and affirm recruitment process steps and
timeline
Interviews and selection of executive firm
Recruitment
Planning
September 2025 –
October 2025
TB&C to conduct stakeholder meetings on
candidate characteristics (Council Members,
Current City Attorney and other CAOs)
CAO Committee Chair approval of marketing and
advertising materials
CAO Chair approves final strategy and process
refinement (panel dates, structure, and
sequencing) (TB&C/HR)
Posting and Active
Recruitment
October 2025 –
November 2025
Marketing and advertising launch (TB&C)
Targeted and active sourcing begins (TB&C)
Initial reviews occur on an ongoing basis as
applications received (TB&C)
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RECRUITMENT
STAGES  TIMELINE  ACTION ITEMS
Candidate
Screening
November 2025 –
December 2025
Candidate assessments (TB&C)
Supplemental questionnaires and interviews (TB&C)
Presentation of recommended top candidates to
Council in closed session (Council will confirm top
candidates invited to interviews) (TB&C/HR)
Continued and ongoing candidate
engagement (TB&C)
Finalist selection
and negotiation
December 2025 –
January 2026
Panel interviews: Stakeholder/subject matter
expert panel(s), followed by City Council panel
Background and reference checks (TB&C)
Final Interview(s) with Council & authority for
conditional offer (TB&C/HR)
Conditional offer letter/compensation negotiations
(TB&C/HR)
Onboarding January 2026 –
February 2026
Appointment by Council
City onboarding process (HR)

FISCAL/RESOURCE IMPACT
The City Attorney position is fully funded in the existing FY 2026 Adopted Operating Budget and while the negotiation with a successor over compensation is unknown it is deemed unlikely to impact or increase FY 2026 or FY 2027 costs. One-time costs of up to $37,000 for recruitment services are generally paid for out of department salary savings, however with the City Attorney’s office being fully staffed during this period, staff will monitor mid-year and FY 2026 closing department balances to determine if a budget adjustment to allocate additional funding would be needed to cover these costs or if use of centralized recruiting funds is deemed necessary. Should additional resources be required, staff will bring forward a budget action for the City Council’s review.

STAKEHOLDER ENGAGEMENT
Public comment was made during the CAO Committee review on September 9, 2025 and September 22, 2025. Opportunity will also be available when report is on the Council Consent agenda on October 6, 2025.

ATTACHMENTS
Attachment A: Executive Recruitment Proposal from Teri Black and Co.

APPROVED BY:

Sandra Blanch, Human Resources Director
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Stellar Talent
Premier Service
Powerful Results
TERI BLACK & co., LLC

LETTER OF TRANSMITTAL
August 21, 2025
Mayor Ed Lauing
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Dear Mayor Lauing:

Teri Black & Company (TBC) is pleased to present this proposal to the City of Palo Alto to assist in the successful recruitment of a new City Attorney. We have enjoyed a productive partnership with the City, having conducted numerous recruitments over the years, including the current search for the City's new Fire Chief. We would be honored to represent the City Council in this important endeavor.

Founded in 2006, TBC is known for delivering the most personalized executive search services to clients and candidates in our industry. The firm's business goals are to provide high-quality results and foster long-term relationships with our customers. Personalized service and inclusivity have never been more important in our industry, as outstanding candidates often have many options when considering a job change.

The attention we devote to ensuring an exceptional candidate experience is reflected in our consistent success with diverse placements. In fact, in 2024, 52 percent of our placements were from underrepresented populations, and an equal percentage were female.

With our extensive network and incomparable approach to client and candidate care, our consultants consistently produce outstanding results. The trust and credibility that my team and I have earned over the past two decades are proudly reflected in these results.

TBC is not driven by volume, which sets us apart from our competitors. We are committed to providing customized and flexible service to our clients and will only take on a select number of recruitments at any given time. Headquartered in Los Angeles, TBC is the most established female-founded and owned executive search firm serving local government in the United States.

If retained, you have my personal commitment that Palo Alto will receive the highest level of attention. Detailed information about the firm and our clients is available on our website at www.tbcrecruiting.com. Please do not hesitate to contact us if you have any questions or require further information about our services or qualifications.

Sincerest regards,
Teri Black
President
teri@t crecruitingcom
424.285.1548 (dire
tel 424.296.3111 www.tbcrecruiting.com
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Executive Search Services
for the

CITY OF PALO ALTO
to recruit a

CITY ATTORNEY
August 2025
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Ill.
lv.
v.

VI.

VII.

TABLE OF CONTENTS

SECTION

CREDENTIALS, QUALIFICATIONS & COMMITMENT

RECRUITMENT STRATEGY & TIMELINE

PROFESSIONAL REFERENCES

PROFESSIONAL FEES & GUARANTEE

RECRUITERS & STAFF PROFILES

COMPANY CONTACT INFORMATION

COMPREHENSIVE LIST OF CLIENTS
PAGE
2 6
7 8
11 12
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l. CREDENTIALS, QUALIFICATIONS & COMMITMENT
Teri Black & Company (TBC), a woman-owned California Limited Liability Company (LLC) established in 2006, has a solid reputation for providing exemplary service to its clients and has enjoyed great success in recruiting impressive local government professionals for our clients throughout the Western United States. Our reputation for managing successful and inclusive recruitment is unparalleled.

We have a dominant presence throughout the Bay Area, especially on the San Francisco Peninsula. In addition to serving the City of Palo Alto, our municipal client base includes the Cities of Redwood City, Burlingame, San Mateo, San Carlos, Mountain View, Sunnyvale, Santa Clara, Cupertino, San Bruno, South San Francisco, San Jose, Milpitas, Pacifica, Brisbane, San Leandro, Fremont, Novato, Pleasanton, Walnut Creek, Albany, and Piedmont, as well as the Towns of Los Gatos, Colma, Woodside, and Hillsborough, among numerous others. As evidence of our clients' high satisfaction levels, nearly 90% of our projects are generated through repeat business and client referrals.

Our completed City Attorney/Deputy/Assistant City Attorney searches include the Cities of Mountain View, Fremont, San Mateo, Cupertino, Burlingame, Santa Clara, Milpitas, Oxnard (partial), and the Town of Los Gatos.

Because we are driven by a concern for quality results rather than volume, we limit the number of recruitments the firm handles at any given time. We are careful to only partner with clients who appreciate the value of highly personalized services and the importance of finding qualified candidates who are a good fit, rather than simply attracting individuals who meet minimum qualification criteria. This has been a significant corporate value since the firm's inception.

Palo Alto will also find that our commitment to candidate care is incomparable. From initial conversations during the active recruiting period to personalized coaching as candidates prepare for final interviews, all the way to professional development debriefings at the end of the process, no other firm invests the amount of time and level of attention in candidates that we do. Our treatment of applicants is a direct reflection of our customers' values, and we consistently receive feedback that our service is simply unmatched.

The attention we devote to ensuring an exceptional candidate experience is another key factor that sets us apart from our competitors. It is also reflected in our consistent success with diverse placements. In fact, in the last two years, 52 percent of our placements were from underrepresented populations, and an equal percentage were female. The trust and credibility Teri and her team have earned over the course of two decades are proudly reflected in these results.

Teri Black will co-lead this search with Senior Recruiter Suzanne Mason and will be closely supported by the entire TBC support team. Our recruiters maintain a strong network throughout various local government disciplines through their involvement and membership with numerous professional associations.

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II. RECRUITMENT STRATEGY & TIMELINE
The executive search strategy that follows describes four complete phases of a comprehensive recruitment for a Council-appointed position.

PHASE I
Client Feedback & Involvement
The recruiters will work closely with the City Council and City Manager to design a customized candidate profile, recruitment strategy, and timeline in accordance with the Client's desires and expectations. It is our goal to gain a complete understanding of the experience, knowledge, expertise, and strengths the City Council is seeking in a new City Attorney, as well as learn more about the City's priorities, current and upcoming challenges, fiscal health, organizational culture, and composition of the management team.

In order for TBC to represent the opportunity with conviction and credibility, we prefer to get as much information and feedback as possible before the recruitment is officially launched.

Because our clients know their organizations best, we rely on their guidance to determine the best sources of information upon launching each assignment.

Strategy Refinement
Following the gathering of feedback, TBC will develop a detailed timeline for the project along with a proposed methodology for attracting the best possible candidates. The timeline and overall strategy will be reviewed and approved by the Council prior to execution.

Material Development & Production
Immediately following the client feedback activities, the recruiters will draft advertising and recruitment brochure text for the Client's review. This information (description of community, culture, organization, ideal candidate profile, compensation/benefits, etc.) should accurately summarize what was learned from the feedback sources.

PHASE II
Advertising & Marketing
Once the recruiters develop a clear understanding of what the Client is seeking, we will create aggressive advertising, marketing, and social media campaigns for the recruitment. Both the traditional and electronic campaigns will be interrelated to ensure the position has a powerful presence in the marketplace.

Once the advertising is executed, TBC will distribute the recruitment brochure with a personalized cover letter to our national network of professional contacts in our database. Both e-mail and traditional mail are utilized in our marketing efforts. The job will also be promoted through the firm's social media presence via LinkedIn and Facebook.

Linked
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Personalized Outreach
As an intensive follow-up to the direct mail campaign, the recruiters will personally contact the individuals targeted and generate new contacts through referrals made by respected sources.

The most impressive candidates are usually found this way, and it frequently requires several persuasive conversations to attract them into a recruitment if they are content and successful in their current position. Most highly qualified candidates will not necessarily respond to an advertisement; therefore, extensive proactive outreach is required.

Our clients pay for results, and that's exactly what we deliver. Unlike many other recruiting firms serving the public sector, TBC invests whatever time is necessary to generate a number of outstanding candidates from which the Client can make a selection. We invest more time and resources in finding undiscovered superstars across the country as well as within the state. While most of our competitors charge additional consulting fees beyond a specific threshold, we do not limit the number of consulting hours, travel, or meetings dedicated to any given project.

PHASE Ill
Resume Assessment
While the recruiters review resumes as they are received, a final detailed review of each submission will be conducted immediately following the closing date of the recruitment. Those candidates deemed the most highly qualified will be selected for screening interviews.

The TBC online application system was introduced to the market over a decade ago and was the first in the public sector executive search industry. Leveraging the power, reach, and accessibility of the internet, TBC pioneered a modern digital experience for both candidates and clients. Since then, some of our competitors have followed suit. However, TBC continues to set the bar with enhanced website and online application security features, strong passwords, and secure candidate database storage to keep candidate information safe and confidential.

Screening Interviews
TBC does not restrict the number of candidates to be screened. Rather, we interview every candidate who meets our Client's criteria. As a rule, this group frequently amounts to 6-12 candidates. The number of candidates screened ranges from just a handful of professionals for highly specialized positions to more than 20 for highly coveted opportunities. The screening interviews are typically conducted by video or phone.

Recruitment Report
Following the completion of the screening interviews, the lead recruiter will develop a written report that includes: a master list of all the applicants, resumes and cover letters for each candidate interviewed, a one-page profile summarizing each candidate's professional history, plus an overview of the recruiter's initial assessment of each individual based on their experience and the results of their screening interview. This information will be presented to the Client in a closed-session meeting, where the recruiters will review the results of the overall recruitment, discuss each candidate screened, and plan for the final stage of the selection process.
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Candidate Communications & Care
Throughout the entire recruitment process, TBC will take responsibility for communicating with the candidates during each stage of the search. In addition, the Client should feel free to refer any inquiries from potential or existing candidates directly to the recruiters at any time during the engagement. We handle all administrative aspects of the assignment.

TBC is extremely attentive to internal candidates. Our recruiters ensure they understand the process and are kept informed at every juncture, as they may have never worked with a recruiter before. We strive to exceed the expectations of candidates throughout our engagements, as it is critical that all participants, regardless of whether they are selected, have a positive experience and leave the process with a favorable impression of the City of Palo Alto.

PHASE
Selection Process & Confidentiality
TBC will design and administer an appropriate final selection process in partnership with the Client. Most traditional selection processes entail at least one or two interviews with the City Council, followed by the appointing authority spending time with the highest-ranked candidates. Our team will prepare the materials for the interviews, arrange follow-up interviews with the Council, and coordinate all logistics with the candidates. We tailor the process to best meet the Client's needs and will assist the decision makers with deliberations. Lastly, it is critical that candidates' confidentiality be respected and maintained to the greatest degree possible to maintain the integrity of the process.

Negotiations
Once the Council reviews and is comfortable with the findings in the reports, the lead recruiter will facilitate negotiations on compensation, benefits, start date, and other transition details to ensure both parties are satisfied.

Background & References
Following the final process and the guidance of the Council's selection of its top candidate, TBC will conduct thorough background and in-depth reference checks. Our background checks are conducted by a licensed private investigator and include credit, driving record, civil, criminal, and academic credential checks. Court records checks include county, state, and federal systems. Media, internet, and social networking checks are also included.

A TBC consultant conducts reference checks, which are supplemented by comments generated from contacts that do not appear on the candidate's reference list. Extensive written reports are provided to the Client for review and recordkeeping. 4 Item AA1
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Project Timeline
An executive-level recruitment can typically be completed within 100-120 days of the initial meeting with the Client depending on time of year and necessary launch preparation work. A visual representation of a projected timeline is shown below and assumes the recruitment will be launched in September. The actual recruitment schedule can be adjusted in accordance with the Client's goals.

City of Palo Alto
City Attorney
JAN FEB I MAR : JUN
,
JUL@AUG I: SEP OCT NOV IDEC
Phase I
Phase II
Phase
Phase IV
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PROFESSIONAL REFERENCES
Client:

Contact:

Email:

Searches:

Client:

Contact:

Email:

Searches:

Client:

Contact:

Email:

Searches:

Client:

Contact:

Email:

Searches:

City of Mountain View Tel: 650.903.6300 ext. 5
Ellen Kamei
— Mayor (Councilmember during engagement)
[email protected]
City Attorney, City Manager, Assistant City Manager, Fire Chief, Deputy Fire Chief, Battalion Chief, Fire Marshal, Fire Protection Engineer, Police Captain (Internal Process), Human Resources Director, Risk Manager, Finance & Administrative Services Director, Chief Sustainability & Resiliency Officer, Economic Development Strategists, Public Works Director, Assistant Public Works Director
-
Transportation & Business Services, Assistant Public Works Director —
Public Services, Community Development Director, Assistant Community Development Director, Housing & Neighborhood Services Manager, Chief Building Official, Deputy Building Officials, Zoning Administrator, Deputy Zoning Administrator, Risk Manager, Economic Vitality Manager, Planning Manager (current)
City of Santa Clara Tel: 408.615.2161
Aracely Azevedo
—
Assistant City Manager
[email protected]
Assistant City Attorney - General, Assistant City Attorney —
HRILabor,
Deputy City Attorney, Fire Chief, Director of Human Resources, City Librarian, Director of Finance, Assistant Finance Director, Risk Manager, Accounting Division Manager, Economic Development Officer, Assistant Director of Community Development, City Planner, Planning Manager, Housing & Community Services Manager, Director of Water & Sewer Utilities, Assistant Director of Water & Sewer utilities
City of San Mateo Tel: 650-522-7522 ext. 6266
Rob Newsom, Jr. — Mayor (was a Council Member during engagement) [email protected]
City Attorney, City Manager (2023 & 2018), Police Chief, Public Works Director, Deputy Public Works Director, Community Development Director, Deputy Community Development Director, Planning Manager, Parks & Recreation Director, Deputy City Librarian
City of Burlingame Tel: 650.558.7206
Maria Saguisag-Sid
—
Human Resources Director
[email protected]
Assistant City Attorney, Chief of Police, Chief Building Official, Finance Director, Human Resources Director, Community Development Director, Public Works Director (current)
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lv. PROFESSIONAL FEES & GUARANTEE
The professional fee for this assignment is $23,000 for the Scope of Work articulated in this proposal. Services include onsite meetings and/or conference calls/Zoom meetings for the purpose of gathering stakeholder feedback on the candidate profile, briefing the client on the results of the recruitment, facilitating up to two days of Council/panel interviews, assisting the Client with selection deliberations, and conducting background and reference checks.

REIMBURSABLE EXPENSES EXCEED)
Advertising
Recruitment Brochure design & mailing
Administrative support
Shipping & FedEx
Background & records checks
Consultant Travel (mileage/airfare, lodging & ground
transportation
—
up to 3 trips)
Project expenses (NTE)
$3,200
$1 ,400
$5,000
$ 400
$ 500
$3,500
$14,000
Professional fees and expenses are billed in phases as work progresses and expenses are incurred.

Placement Guarantee
If a candidate selected and appointed by the City of Palo Alto is terminated before the completion of the first year of service due to a comprehensive TBC recruitment, the firm will provide Palo Alto with the necessary consulting services required to secure a replacement.

Professional consulting services will be provided at a discounted rate of 25% -
75% of the
original fee. Expenses will be covered by the Client.

Fee for Additional Placements & Discounts
Because of the challenging market for top talent, our clients are increasingly taking advantage of selecting more than one outstanding candidate from a single recruitment that will benefit the organization in a different capacity. In these instances, a $5,000 placement fee per additional candidate placed will apply and will include completion of background check records review as well as reference checking.
1 Reimbursable Expenses by Category are an estimation. Invoices may reflect actual expense amounts in any given category that are above or below the estimated amount, however, total expenses billed during the project shall not exceed the total "Project Expenses (NTE)" amount as stated.
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V. RECRUITERS & STAFF PROFILES
Teri Black, President
Following a distinguished career in local and federal government, Teri has been dedicated to executive search since 1999. Serving communities with populations in the millions to as small as 1,500 for over 20 years, she has built a substantial base of clients across the Western United States that continually rely on her personalized service and recruitment expertise. In addition to cities and counties, Teri's clients also include special districts and utility agencies.

She has managed hundreds of high-profile and sensitive recruitments over the years. Prior to starting her own firm in 2006, Teri was affiliated with Shannon Executive Search/CPS Human Resource Services and The Oldani Group.

Before entering the executive search profession, Teri served as the first Chief of Staff in the U.S. Department of Justice/Office of Community-Oriented Policing Services (COPS) during the Clinton Administration, where she helped oversee an annual budget of nearly $2 billion and more than 300 employees. Her local government experience includes management positions in the Cities of Santa Ana, Lakewood, and Oakland, California. As a consultant, clients find her prior government experience to be of tremendous value, often commenting, "She has walked in our shoes and understands our business.' Teri earned her Master's degree in Public Administration from the University of Southern California and holds a bachelor's degree in Criminal Justice from California State University, Fullerton. She is a graduate of the UCLA Anderson School of Management's invitational certificate program for entrepreneurs and a founding member of Cal-ICMA's Preparing the Next Generation (PNG) committee. In addition to holding memberships in relevant professional organizations, Teri is a Fellow of the Future Policing Institute, which is dedicated to advancing future policing that is effective, empathetic, and just.

Suzanne Mason, Senior Recruiter
Following a distinguished career in local government spanning over 30 years, Suzanne Mason has served as a Senior Recruiter with TBC since 2018. Along with her dedication to executive search, she has deep expertise in human resources. Suzanne's experience working with cities and counties in California as a local government administrator and human resources professional was largely focused on business process improvement, change management and improved human resource practices.

While in government, Suzanne worked to modernize and improve public sector recruitment and hiring practices throughout her career in serving the Cities of Long Beach and Palo Alto, Napa County, and the City and County of San Francisco. With these jurisdictions, she has served as Deputy City Manager, Assistant City Manager, Director of Human Resources, and Director of Employee Relations, in addition to various departmental assignments. Suzanne has extensive experience in organizational change management, community and employee engagement, budgeting, as well as all areas of human resources management.

Suzanne earned a Master's degree in Public Administration from the University of Southern California, and her Bachelor's degree in History from the University of California at Santa Barbara. She also holds a certificate from the Senior Executives in State and Local 8 Item AA1
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Government Program at Harvard University's John F. Kennedy School of Government.

Suzanne has served as a member of Cal-ICMA's Preparing the Next Generation Committee since its inception and was part of the team that transitioned the effort to the ICMA Talent Initiative. Suzanne also serves as a Civil Service Commissioner for the City of Napa.

Tina White, Chief Operating Officer/Senior Recruiter
Tina White retired as City Manager of Poway, California in May 2019 and joined the firm in early 2020. She has a long-term passion for recruiting the best talent possible and has been a powerful addition to the TBC team, assisting our clients in both Southern and Northern California. Tina attributes her success in recruitments to ensuring that she understands the needs of the position and the organization, looking beyond the job description. Consistent with our recipe for success, she ensures that the selected candidates not only possess the necessary skills and abilities, but also that they are the right "match" for our clients.

Under Tina's leadership, the City of Poway consistently ranked as one of California's safest cities and among the best California cities in which to raise a family. As City Manager, she oversaw an operating budget of $90 million, a workforce of more than 200 full-time employees, and capital improvement projects totaling $34 million in fiscal year 2017-18. Prior to being appointed City Manager, she served as Poway's Assistant City Manager for more than six years.

Tina's career in local government spans nearly 30 years, with experience working for the cities of El Cajon and Poway, as well as for Helix Water District. Moving up through the ranks, she was responsible for human resources, finance, information technology, customer services, and a water conservation team. She also worked for five years as a municipal law paralegal and legal administrator for a law firm that represented several cities and special districts. Tina holds a Bachelor's degree in Public Administration from San Diego State University.

Tracey Carlson, Director of Client & Candidate Care
Tracey is responsible for managing the numerous administrative activities and logistical coordination associated with TBC recruitments and special projects. Her 15 years of project management experience benefit the company in many ways. From overseeing our massive database to ensuring contractual requirements are met, and from interacting with candidates to coordinating background checks, she is involved in all aspects of the search process.

Tracey is also responsible for the most challenging task in the practice —
managing Teri's
calendar. In addition, she serves as an outstanding resource for candidates and sets a high bar for the firm's commitment to five-star quality service. Concisely, she serves as Teri's invaluable "right hand" in ensuring that all client and candidate needs are met.

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Lucia Vo, Recruiting Assistant
Lucia interfaces extensively with our candidates and works alongside Tracey to help ensure our clients and candidates receive the proper care and support. A great deal of her time is spent handling incoming calls, researching candidates and new clients, monitoring our online application system, responding to e-mails, and assisting candidates with their submissions.

Lucia has worked in various administrative capacities in the private sector throughout Europe and the United States. She graduated from Technic University Kosice in Slovakia majoring in Business Administration.

Monica Irons, Special Projects Manager
With over 36 years of experience in both the private and public sectors, Monica provides technical and strategic support to Senior Recruiters, conducting reference checks and additional due diligence on candidates. She served as the Director of Human Resources for the City of San Luis Obispo for nearly two decades and offers incredible experience in recruiting, hiring and retaining talent as well as training and organizational development.

Monica has a Bachelor's degree in Business Administration from Cal Poly San Luis Obispo and is a graduate of the Senior Executive Institute at the University of Virginia.

Cindi Maudlin, Special Projects Manager
Serving as Special Projects Manager & Assistant to the President and CEO, Cindi is charged with overseeing special projects for the firm, such as implementing new software, designing our approach to social media, and keeping our operations as green as possible -
all things
related to keeping us on our toes when it comes to efficiency and accountability. She also manages the firm's community philanthropic efforts.

Cindi holds a Bachelor's degree in English from Loyola Marymount University and has been with the firm since 2007.
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COMPANY CONTACT INFORMATION
Business address:

Telephone:

Web site:

Federal Tax ID:

Primary Contact:

Company Officers:
25500 Hawthorne Blvd., Suite 1158
Torrance, CA 90505
424.296.3111
www.tbcrecruiting.com
13-4346458
Teri Black
[email protected]
Office: 424.296.3111
Teri Black, President
Joseph E. Brann, CEO
Mobile: 310.781.0878
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VII. COMPREHENSIVE LIST OF CLIENTS
Cities
Agoura Hills
Alameda
Alhambra
Aliso Viejo
American Canyon
Antioch
Anaheim
Arlington, TX
Arroyo Grande
Ashland, OR
Beaumont
Belmont
Berkeley
Beverly Hills
Brisbane
Buena Park
Burbank
Burlingame
Campbell
Cannon Beach, OR
Carlsbad
Carmel-by-the-Sea
Carpinteria
Chandler, AZ
Chino
Colma, Town of
Colorado Springs, CO
Concord
Costa Mesa
Cupertino
Cypress
Daly City
Davis
Del Mar
Denver, CO
Dublin
East Palo Alto
El Cajon
El Segundo
Emeryville
Escondido
Eugene, OR
Fairfield
Fort Worth, TX
Fremont
Fresno
Fullerton
Glendale
Glendora
Goleta
Half Moon Bay
Hayward
Healdsburg
Hermiston, OR
Hermosa Beach
Hillsborough
Huntington Beach
Imperial Beach
• Indian Wells
Indio
Irvine
Laguna Niguel
La Habra
La Mesa
La Palma
La Quinta
Lakewood, CO
Livermore
Lomita
Lompoc
Long Beach
Los Alamitos
Los Altos
Los Banos
Los Gatos, Town of
Lynwood
Malibu
Manhattan Beach
Marina
Manteca
Menlo Park
Milpitas
Modesto
Moreno Valley
Morgan Hill
Mountain View
Murrieta
Napa
National City
Newport Beach
Novato
Oakland
Ontario
Oxnard
Pacifica
Palo Alto
Pasadena
Petaluma
Piedmont
Pismo Beach
Pittsburg
Pleasanton
Prescott Valley, AZ
Pomona
Poway
Provo City, UT
Rancho Cordova
Redlands
Redwood City
Rohnert Park
Riverside
Roseville
San Bruno
San Carlos
San Diego
San José
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San Juan Capistrano
San Leandro
San Luis Obispo
San Mateo
Santa Ana
Santa Barbara
Santa Clara
Santa Clarita
Santa Cruz
Santa Monica
Santa Paula
Santa Rosa
Seaside
Sierra Vista, AZ
Signal Hill
South Pasadena
South San Francisco
Counties
Alameda
Contra Costa
Denver, CO (City/County)
Lane, OR
Los Angeles
Marin
Merced
Monterey
Napa
San Diego
Santa Barbara
Special Districts/Authorities/Non-profits
•
Ashland, OR Parks Commission
Beach Cities Health District
Calleguas Municipal Water District
Castaic Lake Water Agency
Central County Fire Department
Contra Costa Water District
Dublin San Ramon Services District
East Bay Regional Park District
Glendale Water & Power
Goleta Water District
Hi-Desert Water District
Indio Water Authority
Menlo Park Fire Protection District
Mesa Consolidated Water District
Metropolitan Water District of Southern California
Municipal Water District of Orange County
Pasadena Water & Power
Sacramento Metropolitan Fire District
San Ramon Valley Fire Protection District
Santa Clara Silicon Valley Power
South Bay Regional Public Communications Authority
Southern California Association of Governments
Southern California Library Cooperative
The Annenberg Foundation Trust at Sunnylands
West Basin Municipal Water District
Sunnyvale
Surprise, AZ
Torrance
Tracy
Truckee, Town of
Turlock
Tustin
Vallejo
Ventura
Vista
Walnut Creek
West Hollywood
Westminster
West Sacramento
Woodside, Town of
Yucca Valley, Town of
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