Palo Alto City Council
October 20, 2025

Dispatch Center Assessment 2025:

Management Response
The City of Palo Alto thanks Baker Tilly for their assessment of the City’s Dispatch Center. This report provides valuable insights into how our Public Safety Answering Point (PSAP) is performing and where we can improve to better serve our community.

The assessment highlights strengths of our Dispatch Center:
• Rapid 9-1-1 Call Response: Over 99% of emergency calls are answered within 10 seconds—well above national standards.
• Professional and Knowledgeable Staff: Stakeholders consistently praised the professionalism and local knowledge of our dispatchers.
• Commitment to Training: All dispatchers are certified and in compliance with required continuing education standards.

At the same time, the report identifies areas where we can do better. The assessment identified several future state considerations, focused on staffing, call processing, emergency medical dispatch (EMD), and training. Management has reviewed these items and responds as follows:

Staffing
While staffing levels are consistent with industry benchmarks, the PSAP continues to operate with vacancies, impacting capacity for training and quality assurance while managing peak demand. Staff will continue efforts to recruit and retain qualified dispatchers. Staff is open to a future assessment of staffing utilization to ensure a strong understanding of dispatcher workload and exploration of any opportunities for efficiency especially in non-emergency activities of the unit, to be completed as time and resources allow. In the immediate, dispatch management will maintain monthly meetings with stakeholders to continue to identify and monitor areas for improvement.

Quality Assurance Review of General Call Processing
Current staffing levels are inadequate to implement a formal quality assurance process for general call processing for all calls at the level and depth recommended in the assessment. In order to meet this, staff would need to add at least 1.0 additional FTE. Although there are agencies that do that in some form with the necessary resources in place for this, staff believe it can meet the intention of quality assurance through focusing review in the areas of concern identified in the assessment, specifically Emergency Medical Dispatch (EMD). Dispatch management will explore the feasibility of doing a broader quality assurance process in the future as resources and time allows.

Lead dispatchers will continue to monitor calls in real-time, as workload allows, and provide correction and feedback as appropriate. The dispatch center historically tracked its compliance with National Emergency Number A (NENA) call answering standards, a nationwide standard for call answering. Staff commit to working with PSAP partners to identify a call processing standard that is right sized to our Item 12
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Management Response to
Dispatch Assessment

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Attachment B
Dispatch Center Assessment: Management Response

operation and call type. Although adoption of National Fire Protection Association (NFPA) as a call processing standard (not to be confused with call answering standards) for dispatch times is referenced, less than half of the US dispatch centers meet this. Staff recommend tracking call processing performance against this benchmark for information on daily performance; staff will establish a call processing compliance standard with PSAP partners.

Emergency Medical Dispatch
Dispatch management is committed to continuous improvement in performance, training, and process.

Staff recognize the criticality of EMD, especially considering the ongoing work to implement a single role service delivery model for medical response and the increased opportunity for improved patient outcomes. The City has enlisted an outside vendor to assess 25 EMD calls per week and provide detailed feedback. The dispatch center conducts its own internal EMD-Q’s monthly review of NOEMD and N/A calls as well. Next, staff are working to expand internal reviews to include all medical calls, not just those coded as EMD.

Staff have formalized EMD procedures in the EMD Policy, a policy within the Dispatch Policy Manual, to ensure consistent call processing and documentation of call types and dispatcher actions. This will serve as part of the training and accountability discussed below. Staff will continue to review these results monthly across all stakeholders to progress towards greater compliance with the EMD procedures.

Training
The existing dispatch training program incorporates daily assessment of trainee performance, coupled with timely feedback and remedial instruction. All dispatchers are compliant with continuing professional training requirements and receive formal feedback as part of the annual performance review process.

In parallel to this assessment, staff have been actively reviewing and have substantially revised the dispatch policy manual. The recent revisions address the observations noted in the BakerTilly Assessment. The manual now expressly provides for formal feedback, employee acknowledgement of that feedback, and a formal process for addressing performance deficiencies; this will enable supervisors to track follow-up actions and take progressive steps if improvement is not seen or maintained. Next, as noted above, staff commit to working with PSAP partners to identify a call processing compliance standard that is right sized to our operation and applied to appropriate call types.

Looking Ahead
We appreciate the work our dispatchers do every day to keep Palo Alto safe. This assessment gives us focus areas to build on that foundation and continuously improve our Dispatch Center. Staff will continue to work collaboratively across departments to implement the items discussed to strengthen the Dispatch Center’s operations for the benefit of our community.

From: City Manager’s Office, Police Department, & Fire Department Item 12
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Management Response to
Dispatch Assessment

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Baker Tilly Advisory Group, LP and Baker Tilly US, LLP, trading as Baker Tilly, are members of the global network of Baker Tilly International Ltd., the members of which are separate and independent legal entities. Baker Tilly US, LLP is a licensed CPA firm that provides assurance services to its clients. Baker Tilly Advisory Group, LP and its subsidiary entities provide tax and consulting services to their clients and are not licensed CPA firms.

City of Palo Alto
Office of the City Auditor (OCA)
Policy & Services Committee Meeting
Dispatch Center Assessment
September 9, 2025
Presenter: Kate Murdock, City Auditor, Senior Manager, Baker Tilly Item 12
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2 Assessment Objectives
Gather general information about the
Center’s performance in the following
areas:
• Staffing
• Call processing
• Emergency Medical Dispatching (EMD)
• Training
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3 Background
The City’s Dispatch Center or Public Safety Answering Point (PSAP) üOperates a 24-hour dispatch center housed in the Police Department’s Communications Division
üReceives and dispatches calls for Police, Fire, Utilities, Public Works, Animal Control, and 24-hour non-emergency line
üServes as Stanford’s call center dispatching police and fire services üPart of Tri-City Consortium with Mountain View and Los Altos Item 12
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4 Staffing

DISPATCH CENTER
• Budgeted staffing levels in line with industry
standards
• Overall stakeholder feedback on service is
positive with some noted areas for
improvement
• Center was not fully staffed at the time of the
assessment
• Consider conducting a staffing utilization
assessment
• Areas for improvement:
• Greater detail in dispatcher notes and
communication
• Assist in eliminating duplicate incidents during
emergency events
• Obtain officer approval before closing out
incidents in the system to ensure records are
accurate and complete
Current State Observations Future State Considerations
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5 Call Processing

DISPATCH CENTER
• Exceeding NENA standards
• 99.53% of 9-1-1 calls answered ≤ 10 seconds
• Underperform on NFPA standards
• 68% of calls dispatched ≤ 90 seconds
• Dispatch Center lacks a formal QA process for
general call processing
• Consider a formal QA process for general
calls received to ensure on going coaching
and performance feedback
Current State Observations Future State Considerations
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6 Emergency Medical Dispatch (EMD)

DISPATCH CENTER
• Compliant with many EMD standards but not
formalized
• OCA analysis of EMD calls found
• Sampled EMD coded calls had correct coding
• 6% of sampled NOEMD calls should have been
coded EMD
• 70% of sampled N/A calls should have been
coded NOEMD
• 20% of sampled N/A calls should have been EMD
• No formal follow-up on performance reports
• Quality Assurance vendor determined overall
agency performance meets standards
• Formalize process related to EMD Call
Processing Standards
• Formal feedback mechanism for dispatchers
• Establish center and individual performance
goals
Current State Observations Future State Considerations
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7 Training

DISPATCH CENTER
• Comprehensive training manual
• Formally evaluates EMD calls
• Does not have a formal process for evaluating
performance on other calls
• All dispatchers in compliance with Continuing
Professional Training requirements
• Consider developing and incorporating formal
feedback procedures into the Communications
Training Manual
Current State Observations Future State Considerations
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Questions?
Baker Tilly Advisory Group, LP and Baker Tilly US, LLP, trading as Baker Tilly, operate under an alternative practice structure and are members of the global network of Baker Tilly International Ltd., the members of which are separate and independent legal entities. Baker Tilly US, LLP is a licensed CPA firm that provides assurance services to its clients. Baker Tilly Advisory Group, LP and its subsidiary entities provide tax and consulting services to their clients and are not licensed CPA firms. The name Baker Tilly and its associated logo is used under license from Baker Tilly International limited. The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. © 2024 Baker Tilly Advisory Group, LP Item 12
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Community Services
Meeting Date: October 20, 2025
Report #:2508-5068
TITLE
Approval of Professional Services Contract Number C26194598 with Thomas Sarsfield in the Amount Not to Exceed $660,000 for Providing Tennis Instruction Services for Seasonal Classes and Summer Camp Sessions for a Period of Five Years; CEQA Status - Not a Project.

RECOMMENDATION
Staff recommends that City Council approve and authorize the City Manager or their designee to execute Contract No. C26194598 (Attachment A), with Thomas Sarsfield to provide instruction for tennis classes and summer camps for a term of five years and a total amount not-to-exceed $660,000.

BACKGROUND
The Community Services Department (CSD) provides recreational programs to youth and adults each year. CSD strives to offer a variety of programs that are high quality, exciting, dynamic, and inclusive to all. These recreational classes are available to the Palo Alto community and to non-residents. The classes are marketed through the City's ENJOY! Catalog, as well as on the City's website. CSD contracts with a tennis organization to instruct classes for adults and youth, as well as summer camps for youth. CSD coordinators work closely with the contractor to ensure that the correct program information, descriptions, dates, and times are provided in a timely manner and that courts are reserved properly. The current vendor, Thomas Sarsfield, has a contracted agreement for a total not-to-exceed amount of $395,000 for three years and will expire December 31, 2025. A formal solicitation was conducted, and Thomas Sarsfield was selected by the committee. The recommended new contract C26194598 will begin on January 1, 2026.

ANALYSIS
The City of Palo Alto retains qualified instructors to provide tennis classes and camps for its recreational programming. To accomplish this, staff conduct a competitive solicitation process.

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Solicitation Process
A Request for Proposals (RFP) for the project was posted on the OpenGov Procurement, the City's eProcurement platform on July 9, 2025. The solicitation period was open for 15 days, closing on July 23, 2025. Two proposals were received, with one proposal disqualified due to an incomplete response submitted.

Table 1: Summary of Request for Proposal
Proposal Description Tennis Class and Camp Instruction for Adults and Youth - REBID (RFP 194598A)
Proposed Length of Project 5-years term
Number of Vendors Notified 3604
Number of Proposal Packages Downloaded 8
Total Days to Respond to Proposal 15 Days
Pre-Proposal Meeting Yes; Non-Mandatory
Pre-Proposal Meeting Date July 14, 2025
Number of Proposals Received 2 proposals received. Disqualified 1 of the 2 proposals Proposal Price Range $660,000 (one proposal)
Public Link to Solicitation https://procurement.opengov.com/portal/palo-alto- ca/projects/181878
The remaining proposal was evaluated and determined to be responsive to the criteria identified in the RFP. Thomas Sarsfield proposed maintaining the same revenue split as we currently apply, which specifies him retaining 65% of total revenues and 35% of total revenues going to the City for the five-year term of the agreement with a not-to-exceed amount of $660,000. Although one proposal was received, the evaluation committee felt that Thomas Sarsfield's written proposal demonstrated he has extensive experience, knowledge, and the background desired for the work. Thomas Sarsfield and his instructors have consistently been dependable with their programs for youth and adults. Each season there are multiple offerings of class types and classes are not overcrowded, providing a quality program for participants involved.

FISCAL/RESOURCE IMPACT
The fiscal impact of the new contract is not-to-exceed $660,000 in the 5-year term, or $132,000 annually. This annual cost is similar to the previous 3-year contract term expiring on December 31, 2025, which has a not-to-exceed amount of $395,000, or $131,600 annually. Funding is budgeted in the FY 2026 Adopted Operating Budget of the Community Services Department and costs are offset by registration fees. Based on current enrollment projections, the City anticipates receiving approximately $184,000 in registration fees each year. Per the revenue share terms, the city will retain approximately $64,000 (35%) and pay the contractor (including their team of eight instructors) about $120,000 (65%). The additional contract authority above $120,000 provides flexibility for additional classes or potential future rate increases. This Item 13
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program has a relatively high cost recovery among contracted classes as it is a revenue contract with little direct expense to the City.

Additionally, the City will receive a minimum of $15,000 each year in revenue for court rental fees for private lessons scheduled directly through the consultant.

STAKEHOLDER ENGAGEMENT
The variety of age and skill level classes and camps offered by Thomas Sarsfield over the length of the previous contract have been well attended with satisfied community members. Multiple classes and camps fill quickly at the start of each registration period, with many of them accruing a waiting list. During the term of the existing contract, 2,950 tennis players were surveyed with 178 responses returned. The average response was 4.90 out of 5 when answering the question, “Overall, how satisfied were you with the program? (5 being the highest).”

ENVIRONMENTAL REVIEW
The recommendation in this report does not constitute a project requiring review under the California Environmental Quality Act (CEQA).

ATTACHMENTS
Attachment A: Thomas Sarsfield Contract; C26194598
APPROVED BY:

Kristen O'Kane, Community Services Director
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Professional Services
Rev. Oct 16, 2024

CITY OF PALO ALTO CONTRACT NO. C26194598

AGREEMENT FOR PROFESSIONAL SERVICES

BETWEEN THE CITY OF PALO ALTO AND THOMAS SARSFIELD

This Agreement for Professional Services (this “Agreement”) is entered into as of the 1st day of January, 2026 (the “Effective Date”), by and between the CITY OF PALO ALTO, a California chartered municipal corporation (“CITY”), and THOMAS SARSFIELD, a sole proprietor, located at P.O. Box 60534, Palo Alto, CA, 94306 (“CONSULTANT”).

The following recitals are a substantive portion of this Agreement and are fully incorporated herein by this reference:

RECITALS

A. CITY intends to implement tennis classes and camps for its Recreational Program (the “Project”) and desires to engage a consultant to provide Tennis Instruction services for seasonal classes and summer Camps sessions in connection with the Project ( the “Services”, as detailed more fully in Exhibit A).

B. CONSULTANT represents that it, its employees and subconsultants, if any, possess the necessary professional expertise, qualifications, and capability, and all required licenses and/or certifications to provide the Services.

C. CITY, in reliance on these representations , desires to engage CONSULTANT to provide the Services as more fully described in Exhibit A, entitled “SCOPE OF SERVICES”.

NOW, THEREFORE, in consideration of the recitals, covenants, terms, and conditions, in this Agreement, the parties agree as follows:

SECTION 1. SCOPE OF SERVICES. CONSULTANT shall perform the Services described in Exhibit A in accordance with the terms and conditions contained in this Agreement. The performance of all Services shall be to the reasonable satisfaction of CITY.

SECTION 2. TERM.

The term of this Agreement shall be from the date of its full execution through December 31, 2030 unless terminated earlier pursuant to Section 19 (Termination) of this Agreement.

SECTION 3. SCHEDULE OF PERFORMANCE. Time is of the essence in the performance of Services under this Agreement. CONSULTANT shall complete the Services within the term of this Agreement and in accordance with the schedule set forth in Exhibit B, entitled “SCHEDULE OF PERFORMANCE”. Any Services for which times for performance are not specified in this Agreement shall be commenced and completed by CONSULTANT in a reasonably prompt and Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
Attachment A - Thomas
Sarsfield Contract;
C26194598

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timely manner based upon the circumstances and direction communicated to the CONSULTANT.

CITY’s agreement to extend the term or the schedule for performance shall not preclude recovery of damages for delay if the extension is required due to the fault of CONSULTANT.

SECTION 4. NOT TO EXCEED COMPENSATION . The compensation to be paid to CONSULTANT for performance of the Services shall be based on the compensation structure detailed in Exhibit C, entitled “COMPENSATION,” including any reimbursable expenses specified therein, and the maximum total compensation shall not exceed Six Hundred Sixty Thousand Dollars ($660,000). The hourly schedule of rates, if applicable, is set out in Exhibit C-1, entitled “ SCHEDULE OF RATES.” Any work performed or expenses incurred for which payment would result in a total exceeding the maximum compensation set forth in this Section 4 shall be at no cost to the CITY.

SECTION 5. INVOICES. In order to request payment, CONSULTANT shall submit monthly invoices to the CITY describing the Services performed and the applicable charges (including , if applicable, an identification of personnel who performed the Services, hours worked, hourly rates, and reimbursable expenses), based upon Exhibit C or, as applicable, CONSULTANT’s schedule of rates set forth in Exhibit C-1. If applicable, the invoice shall also describe the percentage of completion of each task. The information in CONSULTANT’s invoices shall be subject to verification by CITY. CONSULTANT shall send all invoices to CITY’s Project Manager at the address specified in Section 1 3 (Project Management) below. CITY will generally process and pay invoices within thirty (30) days of receipt of an acceptable invoice.

SECTION 6. QUALIFICATIONS/STANDARD OF CARE. All Services shall be performed by CONSULTANT or under CONSULTANT’s supervision. CONSULTANT represents that it , its employees and subcontractors, if any, possess the professional and technical personnel necessary to perform the Services required by this Agreement and that the personnel have sufficient skill and experience to perform the Services assigned to them. CONSULTANT represents that it, its employees and subcontractors, if any, have and shall maintain during the term of this Agreement all licenses, permits, qualifications, insurance and approvals of whatever nature that are legally required to perform the Services. All Services to be furnished by CONSULTANT under this Agreement shall meet the professional standard and quality that prevail among professionals in the same discipline and of similar knowledge and skill engaged in related work throughout California under the same or similar circumstances.

SECTION 7. COMPLIANCE WITH LAWS . CONSULTANT shall keep itself informed of and in compliance with all federal, state and local laws, ordinances, regulations, and orders that may affect in any manner the Project or the performance of the Services or those engaged to perform Services under this Agreement, as amended from time to time . CONSULTANT shall procure all permits and licenses, pay all charges and fees, and give all notices required by law in the performance of the Services.

SECTION 8. ERRORS/OMISSIONS. CONSULTANT is solely responsible for costs, including, but not limited to, increases in the cost of Services , arising from or caused by CONSULTANT’s errors and omissions, including, but not limited to, the costs of corrections such errors and omissions, any change order markup costs, or costs arising from delay caused by the Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
Attachment A - Thomas
Sarsfield Contract;
C26194598

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errors and omissions or unreasonable delay in correcting the errors and omissions.

SECTION 9. COST ESTIMATES. If this Agreement pertains to the design of a public works project, CONSULTANT shall submit estimates of probable construction costs at each phase of design submittal. If the total estimated construction cost at any submittal exceeds the CITY’s stated construction budget by ten percent (10%) or more , CONSULTANT shall make recommendations to CITY for aligning the P roject design with the budget, incorporate CITY approved recommendations, and revise the design to meet the Project budget, at no additional cost to CITY.

SECTION 10. INDEPENDENT CONTRACTOR. CONSULTANT acknowledges and agrees that CONSULTANT and any agent or employee of CONSULTANT will act as and shall be deemed at all times to be an independent contractor and shall be wholly responsible for the manner in which CONSULTANT performs the Services requested by CITY under this Agreement.

CONSULTANT and any agent or employee of CONSULTANT will not have employee status with CITY, nor be entitled to participate in any plans, arrangements, or distributions by CITY pertaining to or in connection with any retirement, health or other benefits that CITY may offer its employees. CONSULTANT wi ll be responsible for all obligations and payments, whether imposed by federal, state or local law, including, but not limited to, FICA, income tax withholdings, workers’ compensation, unemployment compensation, insurance, and other similar responsibilities re lated to CONSULTANT’s performance of the Services, or any agent or employee of CONSULTANT providing same. Nothing in this Agreement shall be construed as creating an employment or agency relationship between CITY and CONSULTANT or any agent or employee of CONSULTANT. Any terms in this Agreement referring to direction from CITY shall be construed as providing for direction as to policy and the result of CONSULTANT’s provision of the Services only, and not as to the means by which such a result is obtained.

SECTION 11. ASSIGNMENT . The parties agree that the expertise and experience of CONSULTANT are material considerations for this Agreement. CONSULTANT shall not assign or transfer any interest in this Agreement nor the performance of any of CONSULTANT’s obligations hereunder wit hout the prior written approval of the City Manager. Any purported assignment made without the prior written approval of the City Manager will be void and without effect. Subject to the foregoing, the covenants, terms, conditions and provisions of this Agreement will apply to, and will bind, the heirs, succes sors, executors, administrators and assignees of the parties.

SECTION 12. SUBCONTRACTING.

Option A : No Subcontractor: CONSULTANT shall not subcontract any portion of the Services to be performed under this Agreement without the prior written authorization of the City Manager or designee. In the event CONSULTANT does subcontract any portion of the work to be performed under this Agreement, CONSULTANT shall be fully responsible for all acts and omissions of subcontractors.

Option B: Subcontracts Authorized: Notwithstanding Section 11 (Assignment) above, CITY agrees that subcontractors may be used to complete the Services. The subcon tractors authorized Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
Attachment A - Thomas
Sarsfield Contract;
C26194598

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by CITY to perform work on this Project are:

a. John Whitlinger, former Stanford Head Coach, Stanford Hall of Famer, RSPA Elite Pro, consultant
P.O. Box 60534, Palo Alto, CA 94306
650 380-4009 [email protected]

b. Neil Da Silva, USPTA Teaching Pro with over 20 years of experience with us, teaches Individual lessons and Junior Intermediate Tennis Camps at Mitchell Park 408 398-5543 [email protected]

c. Hung Nguyen, USPTA Teaching Pro with over 30 years of experience with us, teaches Individual lessons at Mitchell Park
408 499-2433 [email protected]

d. John Chan, USPTA Teaching Pro with over 30 years of experience with us, teaches Classes & Individual lessons at Mitchell Park
650 637-8809 [email protected]

e. d. Megan Bryan, PTR Teaching Pro, 8th year with us, teaches Individual Tennis lessons at Rinconada Park.
650 759-8433 [email protected]

f. James Knofler, 13th year with us, teaches Classes/ Camps and Individual Tennis lessons at Rinconada Park.
408 410-0434 [email protected]

g. Sujan Bajracharya , 5th year with us, teaches Classes & Individual Tennis lessons at Rinconada Park.
650 787-7906 [email protected]

h. Lisa Sarsfield, 7th year with us, teaches Classes & Individual Tennis lessons at Mitchell Park.
408 745-6171 [email protected]

CONSULTANT shall be responsible for directing the work of any subcon tractors and for any compensation due to subcon tractors. CITY assumes no responsibility whatsoever concerning compensation of subcontractors. CONSULTANT shall be fully responsible to CITY for all acts and omissions of subcon tractors. CONSULTANT shall change or add subcon tractors only with the prior written approval of the City Manager or designee.

SECTION 13. PROJECT MANAGEMENT. CONSULTANT will assign Thomas Sarsfield, Managing Director, Telephone: (408) 431 -3177, Email: [email protected] as the CONSULTANT’s Project Manager to have supervisory responsibility for the performance, progress, and execution of the Services and represent CONSULTANT during the day -to-day performance of the Services. If circumstances cause the substitution of the CONSULTANT’s Project Manager or any other of CONSULTANT’s key personnel for any reason, the appointment of a substitute Project Manager and the assignment of any key new or replacement personnel will Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
Attachment A - Thomas
Sarsfield Contract;
C26194598

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be subject to the prior written approval of the CITY’s Project Manager. CONSULTANT, at CITY’s request, shall promptly remove CONSULTANT personnel who CITY finds do not perform the Services in an acceptable manner, are uncooperative, or present a threat to the adequate or timely completion of the Services or a threat to the safety of persons or property.

CITY’s Project Manager is Margie Cain, Community Service Department, Recreation Program Division, Lucie Stern Community Center, 1305 Middlefield Road, Palo Alto, CA , 94301, Telephone: (650) 463-4919, Email: [email protected]. CITY’s Project Manager will be CONSULTANT’s point of contact with respect to performance, progress and execution of the Services. CITY may designate an alternate Project Manager from time to time.

SECTION 1 4. OWNERSHIP OF MATERIALS . All work product, including without limitation, all writings, drawings, studies, sketches, photographs, plans, reports, specifications, computations, models, recordings, data, documents, and other materials and copyright interests developed under this Agreement, in any form or media, shall be and remain the exclusive property of CITY without restriction or limitation upon their use. CONSULTANT agrees that all copyrights which arise from creation of the work product pursuant to this Agreement are vested in CITY, and CONSULTANT hereby waives and relinquishes all claims to copyright or other intellectual property rights in favor of CITY. Neither CONSULTANT nor its subcontractors, if any, shall make any of such work product available to any individual or organization without the prior written approval of the City Manager or designee. CONSULTANT makes no representation of the suitability of the work product for use in or application to circumstances not contemplated by the Scope of Services.

SECTION 15. AUDITS . CONSULTANT agrees to permit CITY and its authorized representatives to audit, at any reasonable time during the term of this Agreement and for four (4) years from the date of final payment, CONSULTANT’s records pertaining to matters covered by this Agreement, including without limitation records demonstrating compliance with the requirements of Section 10 (Independent Contractor). CONSULTANT further agrees to maintain and retain accurate books and records in accordance with generally accepted accounting principles for at least four (4) years after the expiration or earlier termination of this Agreement or the completion of any audit hereunder, whichever is later.

SECTION 16. INDEMNITY.

16.1. To the fullest extent permitted by law, CONSULTANT shall indemnify, defend and hold harmless CITY, its Council members, officers, employees and agents (each an “Indemnified Party”) from and against any and all demands, claims, or liability of any nature, including death or injury to any person, property damage or any other loss, including all costs and expenses of whatever nature including attorney’s fees, experts fees, court costs and disbursements (“Claims”) resulting from, arising out of or in any manner related to performance or nonperformance by CONSULTANT, its officers, employees, agents or contractors under this Agreement, regardless of whether or not it is caused in part by an Indemnified Party.

16.2. Notwithstanding the above, nothing in this Section 16 shall be construed to require CONSULTANT to indemnify an Indemnified Party from a Claim arising from the active Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
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Sarsfield Contract;
C26194598

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negligence or willful misconduct of an Indemnified Party that is not contributed to by any act of, or by any omission to perform a duty imposed by law or agreement by, CONSULTANT, its officers, employees, agents or contractors under this Agreement.

16.3. The acceptance of CONSULTANT’s Services and duties by CITY shall not operate as a waiver of the right of indemnification. The provisions of this Section 16 shall survive the expiration or early termination of this Agreement.

SECTION 17. WAIVERS. No waiver of a condition or nonperformance of an obligation under this Agreement is effective unless it is in writing in accordance with Section 2 9.4 of this Agreement. No delay or failure to require performance of any provision of this Agreement shall constitute a waiver of that provision as to that or any other instance. Any waiver granted shall apply solely to the specific instance expressly stated. No single or parti al exercise of any right or remedy will preclude any other or further exercise of any right or remedy.

SECTION 18. INSURANCE.

18.1. CONSULTANT, at its sole cost and expense, shall obtain and maintain, in full force and effect during the term of this Agreement, the insurance coverage described in Exhibit D, entitled “INSURANCE REQUIREMENTS”. CONSULTANT and its contractors, if any, shall obtain a policy endorsement naming CITY as an additional insured under any general liability or automobile policy or policies.

18.2. All insurance coverage required hereunder shall be provided through carriers with AM Best’s Key Rating Guide ratings of A -:VII or higher which are licensed or authorized to transact insurance business in the State of California. Any and all contractors of CONSULTANT retained to perform Services under this Agreement will obtain and maintain, in full force and effect during the term of this Agreement, identical insurance coverage, naming CITY as an additional insured under such policies as required above.

18.3. Certificates evidencing such insurance shall be filed with CITY concurrently with the execution of this Agreement. The certificates will be subject to the approval of CITY’s Risk Manager and will contain an endorsement stating that the insurance is primary coverage and will not be canceled, or materially reduced in coverage or limits, by the insurer except after filing with the Purchasing Manager thirty (30) days ’ prior written notice of the cancellation or modification. If the insurer cancels or modifies the insurance and provides less than thirty (30) days’ notice to CONSULTANT, CONSULTANT shall provide the Purchasing Manager written notice of the cancellation or modification within two (2) business days of the CONSULTANT’s receipt of such notice. CONSULTANT shall be responsible for ensuring that current certificates evidencing the insurance are provided to CITY’s Chief Procurement Officer during the entire term of this Agreement.

18.4. The procuring of such required policy or policies of insurance will not be construed to limit CONSULTANT ’s liability hereunder nor to fulfill the indemnification provisions of this Agreement. Notwithstanding the policy or policies of insurance, CONSULTANT will be obligated for the full and total amount of any damage, injury, or loss Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
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caused by or directly arising as a result of the Services performed under this Agreement, including such damage, injury, or loss arising after the Agreement is terminated or the term has expired.

SECTION 19. TERMINATION OR SUSPENSION OF AGREEMENT OR SERVICES.

19.1. The City Manager may suspend the performance of the Services, in whole or in part, or terminate this Agreement, with or without cause, by giving ten (10) days prior written notice thereof to CONSULTANT. If CONSULTANT fails to perform any of its material obligations under this Agreement, in addition to all other remedies provided under this Agreement or at law, the City Manager may terminate this Agreement sooner upon written notice of termination. Upon receipt of any notice of suspension or termination, CONSULTANT will discontinue its performance of the Services on the effective date in the notice of suspension or termination.

19.2. In event of suspension or termination, CONSULTANT will deliver to the City Manager on or before the effective date in the notice of suspension or termination, any and all work product, as detailed in Section 14 (Ownership of Materials), whether or not completed, prepared by CONSULTANT or its contractors, if any, in the performance of this Agreement. Such work product is the property of CITY, as detailed in Section 14 (Ownership of Materials).

19.3. In event of suspension or termination, CONSULTANT will be paid for the Services rendered and work products delivered to CITY in accordance with the Scope of Services up to the effective date in the notice of suspension or termination; provided, however, if this Agreement is suspended or terminated on account of a default by CONSULTANT, CITY will be obligated to compensate CONSULTANT only for that portion of CONSULTANT’s Services provided in material conformity with this Agreement as such determination is made by the City Manager acting in the reasonable exercise of his/her discretion . The following Sections will survive any expiration or termination of this Agreement: 14, 15, 16, 17, 19.2, 19.3, 19.4, 20, 25, 27, 28, 29 and 30.

19.4. No payment, partial payment, acceptance, or partial acceptance by CITY will operate as a waiver on the part of CITY of any of its rights under this Agreement, unless made in accordance with Section 17 (Waivers).

SECTION 20. NOTICES.

All notices hereunder will be given in writing and mailed, postage prepaid, by certified mail, addressed as follows:

To CITY: Office of the City Clerk
City of Palo Alto
Post Office Box 10250
Palo Alto, CA 94303

With a copy to the Purchasing Manager

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To CONSULTANT: Attention of the Project Manager at the address of CONSULTANT recited on the first page of this Agreement.

CONSULTANT shall provide written notice to CITY of any change of address.

SECTION 21. CONFLICT OF INTEREST.

21.1. In executing this Agreement, CONSULTANT covenants that it presently has no interest, and will not acquire any interest, direct or indirect, financial or otherwise, which would conflict in any manner or degree with the performance of the Services.

21.2. CONSULTANT further covenants that, in the performance of this Agreement, it will not employ subcontractors or other persons or parties having such an interest.

CONSULTANT certifies that no person who has or will have any financial interest under this Agreement is an officer or employee of CITY; this provision will be interpreted in accordance with the applicable provisions of the Palo Al to Municipal Code and the Government Code of the State of California, as amended from time to time . CONSULTANT agrees to notify CITY if any conflict arises.

21.3. If the CONSULTANT meets the definition of a “Consultant” as defined by the Regulations of the Fair Political Practices Commission, CONSULTANT will file the appropriate financial disclosure documents required by the Palo Alto Municipal Code and the Political Reform Act of 1974, as amended from time to time.

SECTION 22. NONDISCRIMINATION; COMPLIANCE WITH ADA.

22.1. As set forth in Palo Alto Municipal Code Section 2.30.510, as amended from time to time, CONSULTANT certifies that in the performance of this Agreement, it shall not discriminate in the employment of any person due to that person’s race, skin color, gender, gender identity, age, religion, disability, national origin, ancestry, sexual orientation, pregnancy, genetic information or condition, housing status, marital status, familial status, weight or height of such person. CONSULTANT acknowledges that it has read and understands the provisions of Section

2.30.510 of the Palo Alto Municipal Code relating to Nondiscrimination Requirements and the penalties for violation thereof, and agrees to meet all requirements of Section 2.30.510 pertaining to nondiscrimination in employment.

22.2. CONSULTANT understands and agrees that pursuant to the Americans Disabilities Act (“ADA”), programs, services and other activities provided by a public entity to the public, whether directly or through a contractor or subcontractor, are required to be accessible to the disabled public. CONSULTANT will provide the Services specified in this Agreement in a manner that complies with the ADA and any other applicable federal, state and local disability rights laws and regulations, as amended from time to time. CONSULTANT will not discriminate against persons with disabilities in the provision of services, benefits or activities provided under this Agreement.

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SECTION 23. ENVIRONMENTALLY PREFERRED PURCHASING AND ZERO WASTE REQUIREMENTS. CONSULTANT shall comply with the CITY’s Environmentally Preferred Purchasing policies which are available at CITY’s Purchasing Department , hereby incorporated by reference and as amended from time to time. CONSULTANT shall comply with waste reduction, reuse, recycling and disposal requirements of CITY’s Zero Waste Program. Zero Waste best practices include , first, minimizing and reducing waste; second, reusing waste ; and, third, recycling or composting waste. In particular, C ONSULTANT shall comply with the following Zero Waste requirements:
(a) All printed materials provided by CONSULTANT to C ITY generated from a personal computer and printer including but not limited to, proposals, quotes, invoices, reports, and public education materials, shall be double-sided and printed on a minimum of 30% or greater post-consumer content paper, unless otherwi se approved by CITY’s Project Manager. Any submitted materials printed by a professional printing company shall be a minimum of 30% or greater post-consumer material and printed with vegetable-based inks. (b) Goods purchased by C ONSULTANT on behalf of CITY shall be purchased in accordance with CITY’s Environmental Purchasing Policy including but not limited to Extended Producer Responsibility requirements for products and packaging. A copy of this policy is on file at the Purchasing Department’s office.
(c) Reusable/returnable pallets shall be taken back by CONSULTANT, at no additional cost to CITY, for reuse or recycling. CONSULTANT shall provide documentation from the facility accepting the pallets to verify that pallets are not being disposed.

SECTION 24. COMPLIANCE WITH PALO ALTO MINIMUM WAGE ORDINANCE .

CONSULTANT shall comply with all requirements of the Palo Alto Municipal Code Chapter 4.62 (Citywide Minimum Wage), as amended from time to time. In particular, for any employee otherwise entitled to the State minimum wage, who performs at least two (2) h ours of work in a calendar week within the geographic boundaries of the City, CONSULTANT shall pay such employees no less than the minimum wage set forth in Palo Alto Municipal Code Section 4.62.030 for each hour worked within the geographic boundaries of the City of Palo Alto. In addition, CONSULTANT shall post notices regarding the Palo Alto Minimum Wage Ordinance in accordance with Palo Alto Municipal Code Section 4.62.060.

SECTION 25. NON-APPROPRIATION. This Agreement is subject to the fiscal provisions of the Charter of the City of Palo Alto and the Palo Alto Municipal Code , as amended from time to time. This Agreement will terminate without any penalty (a) at the end of any fiscal year in the event that funds are not appropriated for the following fiscal year, or (b) at any time within a fiscal year in the event that funds are only appropriated for a portion of the fiscal year and funds for this Agreement are no longer available. This Section shall take precedence in the event of a conflict with any other covenant, term, condition, or provision of this Agreement.

SECTION 2 6. PREVAILING WAGES AND DIR REGISTRATION FOR PUBLIC WORKS CONTRACTS.

26.1. This Project is not subject to prevailing wages and related requirements. CONSULTANT is not required to pay prevailing wages and meet related requirements under the California Labor Code and California Code of Regulations in the Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
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performance and implementation of the Project if the contract:
(1) is not a public works contract;
(2) is for a public works construction project of $25,000 or less, per California Labor Code Sections 1782(d)(1), 1725.5(f) and 1773.3(j); or (3) is for a public works alteration, demolition, repair, or maintenance project of $15,000 or less, per California Labor Code Sections 1782(d)(1), 1725.5(f) and 1773.3(j).

SECTION 27. CLAIMS PROCEDURE FOR “9204 PUBLIC WORKS PROJECTS” . For purposes of this Section 27, a “9204 Public Works Project” means the erection, construction, alteration, repair, or improvement of any public structure, building, road, or other public improvement of any kind. (Cal. Pub. Cont. Code § 9204.) Per California Public Contract Code Section 9204, for Public Works Projects , certain claims procedures shall apply , as set forth in Exhibit F, entitled “Claims for Public Contract Code Section 9204 Public Works Projects”.

This Project is not a 9204 Public Works Project.

SECTION 28. CONFIDENTIAL INFORMATION.

28.1. In the performance of this Agreement, CONSULTANT may have access to CITY’s Confidential Information (defined below). CONSULTANT will hold Confidential Information in strict confidence, not disclose it to any third party, and will use it only for the performance of its obligations to CITY under this Agreement and for no other purpose.

CONSULTANT will maintain reasonable and appropriate administrative, technical and physical safeguards to ensure the security, confidentiality and integrity of the Confidential Information.

Notwithstanding the foregoing, CONSULTANT may disclose Confidential Information to its employees, agents and subcontractors, if any, to the extent they have a need to know in order to perform CONSULTANT’s obligations to CITY under this Agreeme nt and for no other purpose, provided that the CONSULTANT informs them of, and requires them to follow, the confidentiality and security obligations of this Agreement.

28.2. “Confidential Information” means all data, information (including without limitation “Personal Information” about a California resident as defined in Civil Code Section 1798 et seq., as amended from time to time) and materials, in any form or media, tangible or intangible, provided or otherwise made available to CONSULTANT by CITY, directly or indirectly, pursuant to this Agreement. Confidential Information excludes information that CONSULTANT can show by appropriate documentation: (i) was publicly known at the time it was provided or has subsequently become publicly known other than by a breach of this Agreement; (ii) was rightfully in CONSULTANT’s possession free of any obligation of confidence prior to receipt of Confidential Information; (iii) is rightfully obtained by CONSULTANT from a third party without breach of any confidentiality obligation; (iv) is independently developed by employees of CONSULTANT without any use of or access to the Confidential Information; or (v) CONSULTANT has written consent to disclose signed by an authorized representative of CITY.

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Information to the extent required by order of a court of competent jurisdiction or governmental body, provided that CONSULTANT will notify CITY in writing of such order immediately upon receipt and prior to any such disclosure (unless CONSULTANT is prohib ited by law from doing so), to give CITY an opportunity to oppose or otherwise respond to such order.

28.4. CONSULTANT will notify City promptly upon learning of any breach in the security of its systems or unauthorized disclosure of, or access to, Confidential Information in its possession or control, and if such Confidential Information consists of Personal In formation, CONSULTANT will provide information to CITY sufficient to meet the notice requirements of Civil Code Section 1798 et seq., as applicable, as amended from time to time.

28.5. Prior to or upon termination or expiration of this Agreement, CONSULTANT will honor any request from the CITY to return or securely destroy all copies of Confidential Information. All Confidential Information is and will remain the property of the CITY and nothing contained in this Agreement grants or confers any rights to such Confidential Information on CONSULTANT.

28.6. If selected in Section 30 (Exhibits), this Agreement is also subject to the terms and conditions of the Information Privacy Policy and Cybersecurity Terms and Conditions.

SECTION 29. MISCELLANEOUS PROVISIONS.

29.1. This Agreement will be governed by California law, without regard to its conflict of law provisions.

29.2. In the event that an action is brought, the parties agree that trial of such action will be vested exclusively in the state courts of California in the County of Santa Clara, State of California.

29.3. The prevailing party in any action brought to enforce the provisions of this Agreement may recover its reasonable costs and attorneys’ fees expended in connection with that action. The prevailing party shall be entitled to recover an amount equal to the fair market value of legal services provided by attorneys employed by it as well as any attorneys’ fees paid to third parties.

29.4. This Agreement, including all exhibits, constitutes the entire and integrated agreement between the parties with respect to the subject matter of this Agreement, and supersedes all prior agreements, negotiations, representations, statements and undertakings, either oral or written. This Agreement may be amended only by a written instrument, which is signed by the authorized representatives of the parties and approved as required under Palo Alto Municipal Code, as amended from time to time.

29.5. If a court of competent jurisdiction finds or rules that any provision of this Agreement is void or unenforceable, the unaffected provisions of this Agreement will remain in full force and effect.

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29.6. In the event of a conflict between the terms of this Agreement and the exhibits hereto (per Section 30) or CONSULTANT’s proposal (if any), the Agreement shall control. In the event of a conflict between the exhibits hereto and CONSULTANT’s proposal (if any), the exhibits shall control.

29.7. The provisions of all checked boxes in this Agreement shall apply to this Agreement; the provisions of any unchecked boxes shall not apply to this Agreement.

29.8. All section headings contained in this Agreement are for convenience and reference only and are not intended to define or limit the scope of any provision of this Agreement.

29.9. This Agreement may be signed in multiple counterparts, which, when executed by the authorized representatives of the parties, shall together constitute a single binding agreement.

SECTION 30. EXHIBITS. Each of the following exhibits, if the check box for such exhibit is selected below, is hereby attached and incorporated into this Agreement by reference as though fully set forth herein:

EXHIBIT A: SCOPE OF SERVICES
EXHIBIT B: SCHEDULE OF PERFORMANCE
EXHIBIT C: COMPENSATION
EXHIBIT C-1: SCHEDULE OF RATES
EXHIBIT D: INSURANCE REQUIREMENTS

THIS AGREEMENT IS NOT COMPLETE UNLESS ALL SELECTED EXHIBITS ARE ATTACHED.

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CONTRACT No. C26194598 SIGNATURE PAGE

IN WITNESS WHEREOF, the parties hereto have by their duly authorized representatives executed this Agreement as of the date first above written.

CITY OF PALO ALTO

____________________________
City Manager

APPROVED AS TO FORM:

__________________________
City Attorney or Designee

THOMAS SARSFIELD

By:

Name:

Title:

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EXHIBIT A

SCOPE OF SERVICES

CONSULTANT shall provide the Services detailed in this Exh ibit A, entitled “SCOPE OF SERVICES”. Notwithstanding any provision herein to the contrary, CONSULTANT’s duties and services described in this Scope of Services shall not include preparing or assisting CITY with any portion of CITY’s preparation of a request for proposals, request for qualific ations, or any other solicitation regarding a subsequent or additional contract with CITY. CITY shall at all times retain responsibility for public contracting, including with respect to any subsequent phase of this project.

CONSULTANT’s participation in t he planning, discussions, or drawing of project plans or specifications shall be limited to conceptual, preliminary, or initial plans or specifications.

CONSULTANT shall cooperate with CITY to ensure that all bidders for a subsequent contract on any subsequent phase of this project have access to the same information, including all conceptual, preliminary, or initial plans or specifications prepared by CONSULTANT pursuant to this Scope of Services.

TENNIS INSTRUCTION SERVICES

CONSULTANT will provide tennis instructor services for tennis classes and camps for its Recreational Program . CONSULTANT’s year-round tennis classes and summer camps will include a curriculum for youths and adults at all skill levels.

REQUIREMENTS

CONSULTANT must have a team of experience d coaches to instruct tennis to both youth and adults. Youth classes will be offered to students from 5 years - 15 years of age. Youth classes will run all four seasons of the year and summer camps will be during the month of June through August. Adult classes instruction will run all 4 seasons and provide private class instruction that will be offered to all during the year from January through December.

CONSULTANT (Instructor) will perform the services to comply with the following:

1. COURSE CONTENT:
• Be responsible for curriculum and course content.
• Unless otherwise expressly provided in this Agreement, City shall not be responsible for providing course materials.
• Provide a teacher that will teach the whole session, with as little substitution as possible. • Conduct the program in a safe manner.
• City shall have the right to observe Consultant instruct in order to determine whether Consultant is in compliance with the terms and conditions of this Agreement.

2. QUALITY OF PROGRAM:

Maintain a quality program which includes, but is not limited to:

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• Consultants are knowledgeable and experienced in the subject being taught and with the age group.
• Consultants are reliable and punctual.
• Consultants are organized and prepared to teach at the start of each class. • Consultants can establish and maintain working relationships with City staff and customers.
• Consultants provide good customer service.
• Consultants and their employees can effectively resolve issues. • Consultants make their best effort to make their programs inclusive and accessible.

3. SET UP & CLEAN UP:
• Be responsible for all set up and cleanup of the room and equipment. • All set up must be completed prior to the start of class.

4. COACHES:
• Provide coaches who are at least 18 years old.
• Consultant, as well as its coaches (whether they are contractors, employees, and/or volunteers), must complete and pass LiveScan/Fingerprint/Background checks and must provide proof of passing such checks prior to providing services, provide negative TB test result within the last two years (for another working with minors) and provide proof of auto insurance in accordance with City guidelines (for anyone driving to the City of Palo Alto facility). All are strongly recommended to obtain certification of CPR/First Aid.

5. PUBLICITY:
• May not publicize Consultant's business to class participant during class hours without prior authorization from Department Director.
• Must obtain prior approval from Recreation Coordinator or designee for publicity containing City classes.
• Must clarify to customers that any personal information sought by Consultant (name, phone number, address, etc.) from customers is voluntary, and strictly for the use of the Consultant and not requested by the City
• Submit quarterly class proposals for creation of the Enjoy catalog. Note: Classes included in proposal are not guaranteed to be offered.
• Consultant will create a marketing plan to help promote camps and classes and encourage enrollment.

6. PUNCTUALITY:
• Consultant and their employees shall arrive at least 15 minutes prior to the starting time of the class
• Ensures that all classes start and end on time
• Notifies center prior to the class if Consultant is running late for unable to attend • If a class is missed, a makeup class is required to be provided by Consultant.

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7. RECORD KEEPING:
• Must take attendance at each class. All attendance records shall be submitted at the end of each session.

8. COMMUNICATION:
• Maintain on-going communication
• Immediately communicate problems and issues with the class(es) or customers • Inform City staff of participant injuries and complete necessary accident reports within 24 hours.

9. ADHERENCE TO CITY POLICY:
• Responsible for knowing the City’s policies and procedures with regard to special interest classes (i.e. waiting lists, cancellation, refund, satisfaction, etc.) • Responsible for verifying that only registered participants with a signed City liability form on file with the City are permitted to participate in City’s special interest classes. • Consultant shall submit the following prior to the commencement of this contract. If the following items are not submitted prior to the start of the contract, it shall automatically terminate:
- General Liability and Automobile Insurance in accordance with City guidelines. - LiveScan/Fingerprints
- TB Test

10. PRIVACY:
• Agrees that any personal information that Consultant receives regarding customers may not be used for other than City business.
• Ensures that customer information will be stored in a secure location.

City will support by:

• Processing all registrations for classes (Consultants not allowed to register participants) • Providing Consultant with attendance sheets or online access to run their own. • Providing facility for scheduled classes, which includes reservation of outdoor spaces (i.e. sports fields, tennis courts, etc.)
• Including Consultant classes in publicity materials

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SEASONAL CLASSES AND SUMMER CAMPS SCHEDULE

CONSULTANT will collaborate with the CITY to provide a recreational program for tennis for “Seasonal Classes” that will occur every quarter over the Fall, Winter, Spring and Summer sessions. “Summer Camps” shall occur over the summer seasonal session(s). The classes and camps will be facilitated at City’s tennis courts at the following site:

▪ Rinconada Park – 777 Embarcadero Rd, Palo Alto, CA 94303; and ▪ Mitchell Park – 3800 Middlefield Rd, Palo Alto, CA 94306

SEASONAL CLASSES

Fall, Winter, Spring, and Summer Seasonal Classes are typically made up of 2 -day classes per week or 1 -day class per week through the annual seasons for various skill -level group sessions.

Each class will be up to a maximum of 6 students with the exception of Advanced Players Tennis, which has a maximum of 12 students. CONSULTANT will annually collaborate with the CITY/Recreational Coordinator to determine the amount of class sessions to publish a schedule with actual dates/times/locations, which is subject to a mutual agreement of City/Recreational Coordinator and CONSULTANT.

CONSULTANT shall coordinate Seasonal tennis classes by instructing lessons for various skill - level groups of the following:

Children Tennis Classes

a. Tiny Tennis Class Instruction
- Children: 5-7 years of age
- Class Length: 40 minutes (each session meets 6 times, max 6 students) - Estimate Session(s): 11 Class Sessions Per Quarter
- Skill Level: Lessons are designed to enhance their athletic and skill development in a success-oriented environment.

b. QuickStart Tennis
- Children: 8-10 years of age
- Class Length: 60 minutes
- Estimate Session(s): 5 Class Sessions Per Quarter
- Skill Level: Learn simple and efficient techniques on the “60 ft. court” with low compression tennis balls. Emphasis on control, consistency, sportsmanship, and fun.

c. QuickStart Advantage Tennis
- Children: 8-10 years of age
- Class Length: 60 minutes
- Estimate Session(s): 3 Class Sessions Per Quarter
- Skill Level: Review and develop techniques on the “60 ft. court” with low compression tennis balls. More emphasis on depth, direction, and spin. Players should have prior Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
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Quickstart experience and/or instructor’s approval.

Junior Tennis Classes

a. Junior Novice Tennis Classes
- Junior: 11-14 years of age
- Class Length: 60 minutes
- Estimate Session(s): 2 Class Sessions Per Quarter
- Skill Level: Develop the essential techniques with emphasis on control, depth, and direction on the “78 ft. court” with regulation tennis balls. Lessons will also incorporate rules, sportsmanship, and basic doubles play. Ten year -olds may participate with instructors’ approval.

b. Junior Low Intermediate Tennis
- Junior: 11-14 years of age
- Class Length: 60 minutes
- Estimate Session(s): 3 Class Sessions Per Quarter
- Skill Level: For players who are consistent on a slow pace rally but need to develop better depth, directional control and use of spin. Review and strengthen stroke techniques with more emphasis on basic strategy and tactics. Ten year -olds may participate with instructors’ approval.

c. Junior Intermediate Tennis
- Junior: 11-15 years of age
- Class Length: 60 minutes
- Estimate Session(s): 1 Class Sessions Per Quarter
- Skill Level: For players who are consistent on a medium pace rally but need to develop more spin, power, and/or variety. Refine stroke techniques, strategy, and tactics with performance enhancing drills.

Adult Tennis Classes

a. Adult Novice Tennis
- Adult: 15+ years of age
- Class Length: 60 minutes
- Estimate Session(s): 4 Class Sessions Per Quarter
- Skill Level: Develop the essential techniques with emphasis on control, depth, and direction. Lessons will also incorporate rules, sportsmanship, and basic doubles play.

b. Adult Low Intermediate Tennis
- Adult: 15+ years of age
- Class Length: 60 minutes
- Estimate Session(s): 6 Class Sessions Per Quarter
- Skill Level: For players who are consistent on a slow pace rally but need to develop better depth, directional control and use of spin. Review and strengthen stroke techniques with more emphasis on basic strategy and tactics.

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c. Adult Intermediate Tennis
- Adult, 15+ years of age
- Class Length: 60 minutes
- Estimate Session(s): 5 Class Sessions Per Quarter)
- Skill Level: For players (NTRP 3.0) who are consistent on a medium pace rally but need to develop more spin, power, and/or variety. Develop stroke techniques, strategy, and tactics with performance enhancing drills.

d. Advanced Players Tennis
- Adult, 15+ years of age
- Class Length: 90 minutes
- Estimate Session(s): 1 Class Sessions Per Quarter
- Skill Level: A Stanford/USPTA Pro will personally teach this dynamic clinic for Advanced Players (NTRP 3.5-4.5). Players will enhance their tactical and strategic play with competitive situational drills. Refine stroke techniques with Ball Machine and Serving target drills. Only 3-6 players per Pro/court.

SUMMER CAMPS

Summer Camps are for 1 week session(s). Each class will be up to a maximum of 12 students.

CONSULTANT will annually collaborate with the CITY/Recreational Coordinator to determine amount of camp sessions to publish a schedule with actual dates/times/locations, which is subject to a mutual agreement of City/Recreational Coordinator and CONSULTANT.

CONSULTANT will coordinate Tennis Summer Camp by instructing lessons for various skill - level groups of the following:

Children Summer Camps

a. QuickStart Tennis Camps
- Children, 8-10 years of age
- Class Length: 90 minutes
- Estimate Session(s): 9 camp Sessions Per Summer
- Skill Level: Learn simple and efficient techniques on the “60 ft. court” with low compression tennis balls. Emphasis on control, consistency, sportsmanship, and fun. In general, we recommend the 25” racket. Three courts grouped by age and/or ability.

Junior Summer Camps

b. Junior Novice Tennis Camp
- Junior, 11-14 years of age
- Class Length: 90 minutes
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- Estimate Session(s): 5 Camp Sessions Per Summer
- Skill Level: Develop the essential techniques with emphasis on control, depth, and direction. Camps will also incorporate rules, sportsmanship, and basic play. In general, we recommend the 26” -27” racket. Three courts grouped by age and/or ability.

c. Junior Low Intermediate Tennis Camp
- Junior,11-14 years of age
- Class Length: 90 minutes
- Estimate Session(s): 4 Camp Sessions Per Summer
- Skill Level: For players who are consistent on a slow pace rally but need better depth, directional control, and use of spin. Review and strengthen stroke techniques with more emphasis on basic strategy and tactics. In general, we recommend the 26”-27" racket. Three courts grouped by age and/or ability.

d. Junior Intermediate Tennis Camp
- Junior,10-15 years of age
- Class Length: 90 minutes
- Estimate Session(s): 4 Camp Sessions Per Summer
- Skill Level: This class provides excellent instruction, extensive practice, and exciting match play for juniors (10 -15 years old) at the INTERMEDIATE and HIGH INTERMEDIATE level. These camps are not for Novice players. Practices are designed to refine players’ technique and enhance their knowledge of strategy and tactics with competitive drills. Four courts grouped by age and/or ability.

PRIVATE LESSONS

*Court Rental for Private Lessons:

CONSULTANT will reimburse the City of Palo Alto for the use of 4 tennis courts to teach individual Private and Semi Private lessons (Rinconada Park Cts. #5-6 and Mitchell Park Cts. #1- 2). There will be 4 quarterly scheduled payments per year. CONSULTANT will prioritize Seasonal Classes and Summer Camps over private lessons. CONSULTANT will develop a plan to advertise private lessons based on availability. Quarterly payments will be pai d to the City in accordance with Exhibit C-1, Schedule of Rates of Section E.

CONSULTANT will provide the CITY a quarterly report of all private lessons completed. Based on the quarterly report, the private lessons court rental rates may increase upon mutual agreement.

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EXHIBIT B

SCHEDULE OF PERFORMANCE

CONSULTANT shall perform the Services so as to complete each milestone within the number of days/weeks specified below. The time to complete each milestone may be increased or decreased by mutual written agreement of the Project Managers for CONSULTANT and CITY so long as all work is completed within the term of the Agreement. CONSULTANT shall provide a detailed schedule of work consistent with the schedule below within 2 weeks of receipt of the notice to proceed (“NTP”) from the CITY.

Milestones
Completion
Number of Days/Weeks (as specified below)
from NTP

1. Tennis Instruction Services – Seasonal
Classes (Per Year)
Upon mutual agreement detailed in Exhibit A
within term of Agreement.

2. Tennis Instruction Services – Summer
Camps (Per Year)
Upon mutual agreement detailed in Exhibit A
within term of Agreement.

3. Tennis Instruction Services – Private
Lessons (Per Year)
Upon mutual agreement detailed in Exhibit A
within term of Agreement.

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EXHIBIT C

COMPENSATION

CITY agrees to compensate CONSULTANT for the Services performed in accordance with the terms and conditions of this Agreement, including Services, any specified reimbursable expenses, and Additional Services (if any, per Section 4 of the Agreement ), based on the rate schedule attached as Exhibit C-1.

The compensation to be paid to CONSULTANT under this Agreement for all Services, any specified reimbursable expenses, and Additional Services (if any, per Section 4), shall not exceed the amount(s) stated in Section 4 of this Agreement . CONSULTANT agrees to complete all Services, any specified reimbursable expenses, and Additional Services (if any, per Section 4) , within this/these amount(s). Any work performed or expenses incurred for which payment would result in a total exceeding the maximum amount of compensation set forth in this Agreement shall be at no cost to the CITY.

REIMBURSABLE EXPENSES

CONSULTANT’S ordinary business expenses , such as administrative, overhead, administrative support time/overtime, information systems, software and hardware, photocopying, telecommunications (telephone, internet), in-house printing, insurance and other ordinary business expenses, are included within the scope of payment for Services and are not reimbursable expenses hereunder.

Reimbursable expenses, if any are specified as reimburs able under this section , will be reimbursed at actual cost. The expenses (by type, e.g. travel) for which CONSULTANT will be reimbursed are: NONE up to the not-to-exceed amount of: $0.00.

A. Travel outside the San Francisco Bay Area, including transportation and meals , if specified as reimbursable, will be reimbursed at actual cost subject to the City of Palo Alto’s policy for reimbursement of travel and meal expenses.

B. Long distance telephone service charges, cellular phone service charges, facsimile transmission and postage charges, if specified as reimbursable, will be reimbursed at actual cost.

All requests for reimbursement of expenses, if any are specified as reimbursable under this section, shall be accompanied by appropriate backup documentation and information.

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EXHIBIT C-1

SCHEDULE OF RATES

CONSULTANT’s schedule of rates is as follows:

A. RATE
For the classes taught for all sessions during the term of this Agreement, CITY shall pay CONSULTANT at the rate for Sixty Five percent (65%) of the resident rate. CONSULTANT will not be compensated for classes offered and canceled – without a make -up session.

CONSULTANT will be compensated for only registered participants listed on the attendance records. CITY and CONSULTANT shall mutually agree upon the date an d time and number of courses offered by CONSULTANT pursuant to this Agreement, provided that the total compensation payable to CONSULTANT shall not exceed the amount set forth in Section 4 of this Agreement

B. PAYMENT
For registration-based classes, at the conclusion of each session, CONSULTANT will invoice the CITY for payment and shall comply with the requirements of Section 5 (invoices of this Agreement). In addition, the CONSULTANT’S invoice must include class name , class number, number of registered participants, rate of pay, total amount due for each class and grand total of all classes included on invoice.

For drop-in based classes, CONSULTANT will invoice the CITY for payment at least monthly.

Invoices must include attendance sheets, rate of pay, total amount due for each class and grand total of all classes.

C. MISSED CLASSES (Excluding weather-related cancellations, if applicable) If CONSULTANT gives 24 hours or less cancellation notice of class(es) starting time and subject to the prior approval of CITY, CONSULTANT will be compensated at 50% of compensation rate for day of the make up session provided CONSULTANT conducts a make-up session at a mutually agreeable time and location.

If CONSULTANT misses two consecutive weeks/meetings of the same class(es) and subject to the prior approval of CITY, CONSULTANT will be compensated at 25% of compensation rate for each of the make-up days provided CONSULTANT conducts a make-up session at a mutually agreeable time and location. Nothing herein limits the CITY’S right to terminate this Agreement for CONSULTANT’S failure to conduct any class at the specified time and place.

D. LATE CLASSES

1. If CONSULTATNT is late at least twice to same class in the same session (or same month for drop-in classes) and subject to the prior approval of CITY, CONSULTANT will be compensated at 100% of compensation rate for the first time the CONSULTANT was late.

For the second time the CONSULTANT is late, CONSULTANT will be compensated at 50% of compensation rate.

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2. If CONSULTANT is late at three or more times to same class in the same session (or same month for drop-in classes) and subject to the prior approval of CITY, CONSULTANT will be compensated at 25% of compensation rate. Nothing herein limits the CITY’S righ t to terminate this Agreement for CONSULTANT’S failure to conduct any class at the specified time and place.

E. PAYMENT FOR – USE OF FACILITY FOR APPROVED AND NON-APPROVED USES

CONSULTANT will reimburse the CITY for the use of 4 tennis courts to teach individual Private and Semi Private lessons (Rinconada Park Cts. #5-6 and Mitchell Park Cts. #1-2). There will be 4 scheduled payments per year.

Annual Amounts:

Private Lessons

Annual Fee
Year One $15,000
Year Two $16,000
Year Three $17,000
Year Four $18,000
Year Five $19,000

If the CONSULTANT uses CITY’S facility for any purpose other than a mutually agreed upon and scheduled class under this agreement, then the CONSULTANT shall pay all fees and charges - as specified in the CITY’S Municipal Fee Schedule.

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EXHIBIT D

INSURANCE REQUIREMENTS

CONSULTANTS TO THE CITY OF PALO ALTO (CITY), AT THEIR SOLE EXPENSE, SHALL FOR THE TERM OF THE

CONTRACT OBTAIN AND MAINTAIN INSURANCE IN THE AMOUNTS FOR THE COVERAGE SPECIFIED BELOW, AFFORDED BY COMPANIES WITH AM BEST’S KEY RATING OF A -:VII, OR HIGHER, LICENSED OR AUTHORIZED TO TRANSACT INSURANCE BUSINESS IN THE STATE OF CALIFORNIA.

AWARD IS CONTINGENT ON COMPLIANCE WITH CITY’S INSURANCE REQUIREMENTS AS SPECIFIED HEREIN.

REQUIRED TYPE OF COVERAGE REQUIREMENT

MINIMUM LIMITS
EACH

OCCURRENCE AGGREGATE
NO (for sole proprietor)
NO (for sole proprietor)
WORKER’S COMPENSATION
EMPLOYER’S LIABILITY

STATUTORY

STATUTORY STATUTORY STATUTORY
YES

GENERAL LIABILITY,

INCLUDING PERSONAL

INJURY, BROAD FORM

PROPERTY DAMAGE

BLANKET CONTRACTUAL,

AND FIRE LEGAL LIABILITY

BODILY INJURY

PROPERTY DAMAGE

BODILY INJURY & PROPERTY
DAMAGE COMBINED.
$1,000,000

$1,000,000

$1,000,000

$1,000,000

$1,000,000

$1,000,000

YES

AUTOMOBILE LIABILITY,

INCLUDING ALL OWNED,

HIRED, NON-OWNED

BODILY INJURY
- EACH PERSON
- EACH OCCURRENCE

PROPERTY DAMAGE

BODILY INJURY AND PROPERTY

DAMAGE, COMBINED
$1,000,000
$1,000,000
$1,000,000

$1,000,000

$1,000,000

$1,000,000
$1,000,000
$1,000,000

$1,000,000

$1,000,000

NO

PROFESSIONAL LIABILITY,

INCLUDING, ERRORS AND

OMISSIONS, MALPRACTICE
(WHEN APPLICABLE), AND

NEGLIGENT PERFORMANCE
ALL DAMAGES $1,000,000
YES

THE CITY OF PALO ALTO IS TO BE NAMED AS AN ADDITIONAL INSURED : CONSULTANT, AT ITS

SOLE COST AND EXPENSE, SHALL OBTAIN AND MAINTAIN, IN FULL FORCE AND EFFECT THROUGHOUT

THE ENTIRE TERM OF ANY RESULTANT AGREEMENT, THE INSURANCE COVERAGE HEREIN

DESCRIBED, INSURING NOT ONLY CONSULTANT AND ITS SUBCONSULTANTS, IF ANY, BUT ALSO, WITH THE EXCEPTION OF WORKERS’ COMPENSATION, EMPLOYER’S LIABILITY AND PROFESSIONAL

INSURANCE, NAMING AS ADDITIONAL INSUREDS CITY, ITS COUNCIL MEMBERS, OFFICERS, AGENTS, AND EMPLOYEES.

I. INSURANCE COVERAGE MUST INCLUDE:

A. A CONTRACTUAL LIABILITY ENDORSEMENT PROVIDING INSURANCE COVERAGE FOR CONSULTANT’S AGREEMENT TO INDEMNIFY CITY.

II. THE CONSULTANT MUST SUBMIT CERTIFICATES(S) OF INSURANCE EVIDENCING REQUIRED COVERAGE TO THE FOLLOWING EMAIL: [email protected]

III. ENDORSEMENT PROVISIONS WITH RESPECT TO THE INSURANCE AFFORDED TO ADDITIONAL INSUREDS:

A. PRIMARY COVERAGE

WITH RESPECT TO CLAIMS ARISING OUT OF THE OPERATIONS OF THE NAMED INSURED,

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CONTRIBUTING WITH ANY OTHER INSURANCE CARRIED BY OR FOR THE BENEFIT OF THE ADDITIONAL INSUREDS.

B. CROSS LIABILITY

THE NAMING OF MORE THAN ONE PERSON, FIRM, OR CORPORATION AS INSUREDS UNDER

THE POLICY SHALL NOT, FOR THAT REASON ALONE, EXTINGUISH ANY RIGHTS OF THE

INSURED AGAINST ANOTHER, BUT THIS ENDORSEMENT, AND THE NAMING OF MULTIPLE

INSUREDS, SHALL NOT INCREASE THE TOTAL LIABILITY OF THE COMPANY UNDER THIS POLICY.

C. NOTICE OF CANCELLATION

1. IF THE POLICY IS CANCELED BEFORE ITS EXPIRATION DATE FOR ANY REASON

OTHER THAN THE NON-PAYMENT OF PREMIUM, THE CONSULTANT SHALL PROVIDE CITY AT LEAST A THIRTY (30) DAY WRITTEN NOTICE BEFORE THE EFFECTIVE DATE OF CANCELLATION.

2. IF THE POLICY IS CANCELED BEFORE ITS EXPIRATION DATE FOR THE NON-PAYMENT OF PREMIUM, THE CONSULTANT SHALL PROVIDE CITY AT LEAST A TEN (10) DAY WRITTEN NOTICE BEFORE THE EFFECTIVE DATE OF CANCELLATION.

EVIDENCE OF INSURANCE AND OTHER RELATED NOTICES ARE REQUIRED TO BE FILED WITH THE CITY OF PALO ALTO TO THE FOLLOWING EMAIL: [email protected] Docusign Envelope ID: 942584A5-15F3-47FA-B882-7DF2C868371B Item 13
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Utilities
Meeting Date: October 20, 2025
Report #:2505-4735
TITLE
Approval of Contract Number C25194217 with Veteran Pipeline Construction in the Amount of $8,962,204 for the Gas Main Replacement Project 25 (GS-15000) in the Duveneck/St. Francis, Leland Manor, Midtown, and Palo Verde neighborhoods; Authorization for the City Manager to Negotiate and Execute Related Change Orders Not-to-Exceed of $896,221 for a Total Not-to- Exceed Amount of $9,858,425; NEPA status - B5.4 categorical exclusion; CEQA status — Exempt under CEQA Guidelines 15302 (Replacement or Reconstruction of Existing Facilities).

RECOMMENDATION
Staff recommends that the Council:

1. Approve and authorize the City Manager or their designee to execute contract C251942171 with Veteran Pipeline Construction in an amount not-to-exceed $8,962,204 for the Gas Main Replacement 25 project (GS-15000) in the Duveneck/St. Francis, Leland Manor, Midtown, and Palo Verde neighborhoods.

2. Approve and authorize the City Manager or their designee to negotiate and execute one or more changes to the contract with Veteran Pipeline Construction for related additional but unforeseen work, which may develop during the project, the total value of which shall not exceed $896,221 or 10% of the contract amount.

The total authorized not-to-exceed expenditure amount is $9,858,425 which includes the contract base amount of $8,962,204 and a 10% contingency amount of $896,221. This Project was selected for Federal grant funding.

EXECUTIVE SUMMARY
The Gas Main Replacement (GMR) 25 project (GS-15000) is part of the Council-approved Capital Improvement Program (CIP) designed to ensure reliable gas service for the City of Palo 1 Veteran Pipeline Construction, Gas Main Replacement Project 25 Contract No. C25194217 https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/agendas-minutes/city-council- agendas-minutes/2025/october-20/veteran-pipeline-construction-gas-main-replacement-project-25-contract-no.- c25194217.pdf
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Alto residents and customers. The project targets the replacement of polyvinyl chloride (PVC) and black-wrapped steel pipe (BWP) distribution main and service pipes that are near or past their operational life expectancy with polyethylene (PE) pipelines. Work will be done in the Duveneck/St. Francis, Leland Manor, Midtown, and Palo Verde neighborhoods. The City anticipates starting construction in January 2026 and completing construction in August 2027.

The Gas Main Replacement 25 project (GS-15000) project was selected by the Department of Transportation (DOT) for the Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) Federal Grant Program. The Federal grant program was established to help community-owned utilities improve the safety and reliability of their natural gas pipeline systems. The grant is a reimbursable grant at 100% of approved project cost.

BACKGROUND
Over time, PVC pipe material becomes embrittled and is susceptible to cracking during excavation and earth movements, which result in gas leaking from the pipelines. Steel pipe material has an increased chance of becoming corroded and eventually leaking when isolated from the cathodic protection system or receiving low cathodic protection current. Repairs on PVC and steel pipelines require specialized tooling and can be very time-consuming, disruptive, and difficult. PVC and steel pipelines are typically replaced with polyethylene (PE) pipelines, which have greater elastic properties and do not require cathodic protection.

Replacing the gas distribution system with PE will enhance the reliability of the gas distribution system, make the system more resilient against corrosion and earth movements, eliminate potential leaks, reduce maintenance costs, and extend the useful life of the gas distribution system. In addition, unlike PVC gas main and services, the new PE pipelines will be installed with a metallic tracer wire, which increases the pipeline locating accuracy and reduces pipe damage during excavation.

There are six active Grade 3 gas leaks in the Project Area, four along Ross Road and two on Northampton Drive. Grade 3 leaks are non-hazardous at the time of detection and can be monitored until repaired. The replacement of pipelines on this project will eliminate these gas leaks. Replacement of PVC and corroded steel distribution main and services is required to maintain the City's planned CIP replacement schedule and minimize greenhouse gas emissions from leaking or damaged PVC and steel pipelines, having a positive impact on the environment.

ANALYSIS
Project Description
The work to be performed under this contract C25194217 is to replace approximately 25,500 linear feet of natural gas mains and services with polyethylene (PE) pipe in the Duveneck/St.

Francis, Leland Manor, Midtown, and Palo Verde neighborhoods (see Attachment B). The main sizes being installed are 2-inch, 4-inch, and 6-inch in diameter and the associated installation of services and reconnects are 1-inch and 2- inch in diameter. The PVC gas facilities were Item 14
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installed in the mid 1970’s and the steel gas facilities were installed in the 1920’s through the early 1950’s. These sections of main were prioritized to further the replacement of PVC pipelines and address leak prone steel pipelines in the gas system. Portions of this project replace mains installed on major streets and take a proactive approach to minimize impacts to the community in the event of a leak.

Notifications and Work Restrictions
The city anticipates starting construction in January 2026. The construction hours for this project are 8:00 AM to 4:00 PM, Monday through Friday. Streets with non-standard construction hours start at 9:00 AM and end at 4:00 PM, which applies to a small section of work on Middlefield Road.

Contractor must schedule work to avoid working on City-specified school routes during the first week of school in August of 2026 and 2027. The Contractor will coordinate with the property owners, apartment managers, and businesses throughout the project scope to facilitate the installation of the new gas pipelines and minimize disruption to businesses. Prior to construction, there will be coordination and delivery of project notices and maps to each resident and business a minimum of 30 days prior to beginning the project. Project information will be maintained on the City’s website too.

Bid Process
On June 26, 2025, the City posted a notice inviting formal bids (IFB) for the GMR 25 project on the City's electronic procurement system, OpenGov. Bids were due July 31, 2025. This included an additional week at the request of the contractors, to allow sufficient time to review the project bid documents and federal grant requirements, the City agreed.

Bid Name/Number Gas Main Replacement Project 25
(GS-15000)
Proposed Length of Project 386 working days
Number of Venders notified through OpenGov 3,555
Number of Builder’s Exchanges notified through OpenGov 4 Number of Bid Packages Downloaded by Venders 51
Total Days to Respond to Bid 35
Pre-Bid Meeting? Yes (Mandatory)
Number of Venders at Pre-Bid Meeting 16
Number of Bids Received: 4
Bid Price Range From a low of $8,962,203 to a
high of $15,165,184
*Bid summary provided (see Attachment C).

Staff reviewed the submitted bids, and all four bids were responsible and responsive. Staff recommend Veteran Pipeline Construction be awarded the contract as the low bidder listed Item 14
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in the attached Bid Summary (see Attachment A). The contingency amount of $896,221, which equals 10% of the total contract, is requested for additional unforeseen work that may develop during the project. Additional work is common with construction projects because during construction there may be previously unknown obstructions and ground conditions that require changes in how construction will proceed, leading to change orders that may create additional costs.

Staff confirmed with the Contractor's State License Board that Veteran Pipeline Construction and their listed subcontractors have active licenses on file. Veteran Pipeline Construction has never worked on a city project, but Staff checked their references for previous work performed and found no significant complaints. Staff also confirmed that Veteran Pipeline Construction and their listed subcontractors are registered and in good standing with the Department of Industrial Relations (DIR). After issuing the Notice of Intent to Award the City held a preliminary kickoff meeting on August 27, 2025, with Veteran Pipeline to discuss City’s process, staff roles, and Veteran Pipeline Construction approach to the project.

FISCAL/RESOURCE IMPACT
Funding is available in the Gas Main Replacement 25 project (GS-15000) as part of the Fiscal Year 2026 Adopted Gas Fund Capital Budget.

Staff applied for a Department of Transportation (DOT); Pipeline and Hazardous Materials Safety Administration (PHMSA) grant in FY2023 for GS-15000 (GMR25) and was selected to receive a portion of funding in the Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) Federal Grant Program. The grant is a reimbursable grant at 100% of approved project cost beginning July 2, 2024 (PHMSA’s pre-award letter – see Attachment D).

Summary of Project Costs for GMR 25 Project (GS-15000)
Pre-Design/Design Costs prior to the Pre-award (July 2nd, 2024) $17,632 Pre-Design/Design Costs after the Pre-award (July 2nd, 2024) to signed Grant award (July 31st, 2025)
$199,993
Material (gas regulators and gas meters)) $213,317
Construction Costs (Veteran Pipeline Construction Bid) $8,962,204 10% Contingency $896,221
Staff Time (Includes Engineering, Operations, & Inspection) $1,739,662 Trench Cut Fees $970,000
Soil Compaction Testing $20,000
Total Project Cost $13,019,029
PHMSA Approved Grant Funding $16,519,8793
Anticipated Remaining Grant Funding After Total Project Cost $3,500,850 GS-15000 Budget Available $16,728,324
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The size of this project significantly exceeds the City's in-house construction resources, making it necessary to contract out the work.

During the grant application process, Staff estimated that the total cost of the GMR25 construction project would be $16,474,416 and the cost to purchase methane reducing equipment would be $45,463 for a total estimate of $16,519,879. PHMSA reviewed the application and supporting documentation and approved the total grant amount. The construction portion of the grant required a National Environmental Policy Act (NEPA) review and PHMSA issued a Tier 2 Environmental Assessment pre-award authorization (see Attachment D) of $240,768 on July 2 nd, 2025 for staff time dedicated for work related to the National Environmental Policy Act (NEPA) application. This amount was authorized to be charged against the grant prior to the execution of the grant agreement between the City and PHMSA. The grant agreement5 was executed on April 30, 2025 and all costs incurred from this date forward will be charged against the grant.

The selected lowest bidder, Veteran Pipeline Construction (VPC), submitted a bid of $8,962,204 which is $3,699,168 lower than the City’s engineering estimate of $12,661,372.

An amount of $12,661,372 has been allotted from the NGDISM grant fund to Gas Main Replacement 25, reflecting the City’s engineering estimate. The difference of $3,699,168 between Veteran Pipeline Construction’s bid and the City’s engineering estimate reflects VPC’s accelerated schedule of project completion and the efficient approach to construction compared to the past Gas Main Replacement Projects. The anticipated remaining $3,699,168 in grant funding cannot be used to increase the project size, as the GMR25 project has already been processed through a NEPA categorical exclusion. Therefore, these funds are not available for additional pipeline replacement projects.

The City will submit a request, for approval by PHMSA, to purchase additional methane reducing equipment.

STAKEHOLDER ENGAGEMENT
Utilities infrastructure work has been coordinated with Public Works street paving activities to comply with City’s pavement moratorium and to avoid cutting into streets that have been paved within past 5 years. Staff’s GMR25 project communications will include project notifications mailed to residents and business within the vicinity of the three project areas, in the Duveneck/St. Francis, Leland Manor, Midtown, and Palo Verde neighborhoods at least 30 days prior to the commencement of work. Veteran Pipeline Construction will distribute project notifications to each property a minimum of 15 days and again 24 hours prior to beginning work. No Parking signs will be posted a minimum of 72 hours prior to any construction activities. A link to the city website for the GMR 25 project will be included in the mailed project notifications. Additional communications will be distributed to the subscribers through the city online social media accounts using Twitter, Facebook, Instagram, and 5 PHMSA Grant Agreement https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/agendas- minutes/city-council-agendas-minutes/2025/october-20/phmsa-grant.pdf Item 14
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Nextdoor. The construction is expected to commence in January 2026 and be completed by August 2027.

ENVIRONMENTAL REVIEW
The project received a National Environmental Policy Act (NEPA) Categorial Exclusion B5.4 7 for repair or replacement of pipelines and is categorically exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15302, replacement or reconstruction of existing utility systems or facilities.

ATTACHMENTS
Attachment A: GMR25 Project Map
Attachment B: GMR25 Bid Summary
Attachment C: GMR25 Tier-2 EA Pre-Award Authorization
APPROVED BY:

Alan Kurotori, Utilities Director
Staff: Kim Rasay, Associate Engineer
7 NEPA Categorial Exclusion B5.4 https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-12/PHMSA-Final-CE- Palo-Alto-Ver4-approved.pdf
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Bid Date: 07/31/2025 Project Title: Gas Main Replacement Project 25 IFB# 25194217 CIP# GS-15000
Bid No. Quantity Unit Description Unit Price Extended Price Unit Price Extended Price Unit Price Extended Price Unit Price Extended Price Unit Price Extended Price 001 15836 Linear Feet Install 2" gas MDPE pipe by horizontal directional drilling
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 177.49 2,810,748.42 $ $ 117.51 1,860,888.36 $ 159.40$ 2,524,258.40 285.00 4,513,260.00 200.27 3,171,475.72 002 2827 Linear Feet Install 2" gas MDPE pipe by open trench excavation
_______________________________________
$ $ $ $ $ $ 339.42 959,546.86 $ 133.78$ 378,196.06 $ 385.65$ 1,090,232.55 365.00 1,031,855.00 495.46 1,400,665.42 003 4985 Linear Feet Install 4" gas MDPE pipe by horizontal directional drilling
_______________________________________
$ $ $ $ $ $ 268.61 1,339,028.37 $ $ 230.16 1,147,347.60 $ 246.00$ 1,226,310.00 405.00 2,018,925.00 403.57 2,011,796.45 004 1476 Linear Feet Install 4" gas MDPE pipe by open trench excavation
_______________________________________
$ $ $ $ $ $ 731.58 1,079,818.26 194.40$ $ 286,934.40 $ 695.15 1,026,041.40$ 505.00 745,380.00 712.16 1,051,148.16 005 663 Linear Feet Install 6" gas MDPE pipe by horizontal directional drilling
_______________________________________
$ $ $ $ $ $ 277.35 183,880.96 276.23$ $ 183,140.49 262.50 $ $ 174,037.50 490.00 324,870.00 654.55 433,966.65 006 160 Linear Feet Install 6" gas MDPE pipe by open trench excavation
_______________________________________
$ $ $ $ $ $ 740.32 118,451.12 631.81$ $ 101,089.60 $ 706.95 $ 113,112.00 590.00 94,400.00 1,258.40 201,344.00 007 37 Each Install anode box / test station
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 529.58 19,594.45913.27 $ $ 33,790.99 500.00 $ $ 18,500.00 500.00 18,500.00 781.17 28,903.29 008 320 Each Install 1" PE gas service line including EFV and 1" riser with OR without a bypass at the EXISTING
gas meter location by horizontal directional
drilling OR open trench excavation
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 11,328.64 3,625,163.44 9,020.62 $ $ 2,886,598.40 11,250.00 $ $ 3,600,000.00 5,750.00 1,840,000.00 7,311.40 2,339,648.00 009 246 Each Install 1" PE gas service stub and EFV for the city to reconnect the EXISTING 1" PE gas service to
new main by horizontal directional drilling OR
open trench excavation
_______________________________________
$ $ $ $ $ $ 5,186.60 1,275,904.66 5,833.17 $ $ 1,434,959.82 5,300.00 $ $ 1,303,800.00 4,750.00 1,168,500.00 6,190.62 1,522,892.52 010 3 Each Install 2" PE gas service line including 2" PE ball valve and/or EFV and 2" Riser with a 1-1/4" or 2"
bypass at EXISTING gas meter location by
horizontal directional drilling OR open trench
excavation
_______________________________________
$ $ $ $ $ 12,966.78 $ 21,226.06 $ 38,900.35 $ 63,678.18 35,975.00 $ 107,925.00 $ 6,000.00 18,000.0032,231.08 96,693.24 011 2 Each Install 2" PE gas service stub with 2" PE ball valve and/or EFV for the city to reconnect the
EXISTING 2" PE gas service to new main by
horizontal directional drilling OR open trench
excavation
_______________________________________
$ $ $ $ $ 7,097.46 $ 8,686.25 $ 14,194.92 $ 17,372.50 $ 6,700.00 $ 13,400.00 5,000.00 10,000.0015,584.44 31,168.88 Base Bid Summary
BASE BID SUMMARY ENGINEER'S ESTIMATE Veteran Pipeline Construction Daleo Inc. Ranger Pipeline ARB Inc.

Item 14
Attachment B - GMR25 Bid
Summary

Item 14: Staff Report
Pg.
8 Packet Pg. 356 of 607

012 95 Excavate and expose existing non-standard (1/2"
PE inserted or 3/4") riser location for City to
replace EXISTING riser with new 1" anodeless
riser to existing 1" PE service.
_______________________________________
$ $ $ $ $ 4,149.28 $ 394,181.93$ 331.31 $ 31,474.45 2,530.00 $ $ 240,350.00 2,000.00 190,000.00 2,494.81 237,006.95 013 82 Each Install a 2" residential steel pipe bollard, filled with concrete, at gas meter location per
Standard Detail WGW-05A
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 709.75 58,199.16719.88 $ $ 59,030.16 750.00 $ $ 61,500.00 500.00 41,000.00 457.74 37,534.68 014 9 Each Install a 4" commercial steel pipe bollard, filled with concrete, at gas meter location per
Standard Detail WGW-05B
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 928.13 1,074.22 $ 8,353.16 $ 9,667.98 950.00$ $ 8,550.00 600.00 5,400.00 469.76 4,227.84 015 45 Each Excavate tie-in/abandonment pits for gas
main(s) (≤5-ft in depth, up to 25 S.F.)
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 7,425.03 $ $ 4,286.34 334,126.51 $ 192,885.30 $ 7,000.00 $ 315,000.00 15,000.00 675,000.00 31,170.93 1,402,691.85 016 15 Each Excavate tie-in/abandonment pits for gas
main(s) (≤5-ft in depth, up to 50 S.F.)
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 11,028.36 $ $ 4,286.12 165,425.38 $ 64,291.80 10,500.00 $ $ 157,500.00 24,000.00 360,000.00 32,557.90 488,368.50 017 75 Each Abandon existing anode/valve box
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 436.77 32,757.50711.45 $ $ 53,358.75 450.00 $ $ 33,750.00 500.00 37,500.00 535.70 40,177.50 018 5 Each Abandon existing anode/valve box
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 6,005.54 $ 6,295.72 30,027.71 $ 31,478.60 $ 5,500.00 $ $ 27,500.00 800.00 8,164.994,000.00 40,824.95 019 5 Each Investigation and removal/relocation of sewer lateral obstructions by open-cut excavation in
paved area
_______________________________________
$ $ $ $ $ 4,913.63 $ 3,333.02 $ 24,568.13 $ 16,665.10 4,500.00 $ $ 22,500.00 6,000.00 30,000.00 7,756.78 38,783.90 020 1 Each Perform GPS survey
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 148,500.67 $ 109,354.90 $ 148,500.67 $ 109,354.90210,000.00 $ $ 210,000.00 25,000.00 585,865.89 25,000.00 585,865.89 $ $ 8,962,203.44 12,274,266.85 $ 15,165,184.39 Ranger
Pipeline
Total Base
Bid:
$ 13,151,590.00 ARB Inc.

Total Base Bid:$ 12,661,371.96
Veteran
Pipeline
Construction
Total Base Bid:

Base Bid Total (items 001 through 020) Engineering
Estimate:

Daleo Inc.

Total Base Bid:

Item 14
Attachment B - GMR25 Bid
Summary

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9 Packet Pg. 357 of 607

Bid No. Quantity Unit Description Unit Price Extended Price Unit Price Extended Price Unit Price Extended Price Unit Price Extended Price Unit Price Extended Price 021 1 Each Installation of sewer lateral cleanout by open- cut excavation in paved area
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 6,005.54 $ 4,353.70 $ 6,005.54 $ 6,500.004,353.70$ $ 2,000.00 6,500.00 8,716.722,000.00 8,716.72 022 1 Each Installation of sewer lateral cleanout by open- cut excavation in unpaved area
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 4,913.63 $ 3,589.89 $ 4,913.63 $ 5,500.003,589.89$ $ 1,500.00 5,500.00 7,802.981,500.00 7,802.98 023 10 Cubic Yard Recycle asphalt containing petro mat
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 436.77 $ $ 325.74 4,367.67 $ 3,257.40 30.00 $ $ 100.00 300.00 1,000.00 66.37 663.70 024 1,500 Inch/SF Install additional base (concrete base) _______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 4.91 7,370.44 2.45$ $ 3,675.00 $ 3.00 4,500.00 2.00 3,000.00 19.52 29,280.00$ 025 2,000 Inch/SF Install additional base (Class II aggregate base) _______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 4.37 8,735.33 3.31$ 6,620.00$ 2.00$ 4,000.00 $ 0.15 300.00 0.10 200.00 026 5,000 Inch/SF Install additional finished pavement (concrete thickness)
_______________________________________
$ $ $ $ $ $ 2.18 10,919.17 30.73 153,650.00$ $ $ 2.00 $ 10,000.00 4.00 20,000.00 17.08 85,400.00 027 5,000 Inch/SF Install additional finished pavement (asphalt concrete thickness)
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 2.18 10,919.17 22.96 114,800.00$ $ 2.00 $ $ 10,000.00 3.00 15,000.00 5.98 29,900.00 028 500 Linear Feet Perform additional saw cutting
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 4.64 2,320.32 8.00$ $ 4,000.00 3.50$ 1,750.00 3.00 1,500.00 4.58 2,290.00$ 029 250 Linear Feet Install additional curb
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 32.76 $ 80.75 8,189.38 $ 20,187.50 $ 30.00 $ 7,500.00 125.00 31,250.00 176.91 44,227.50 030 250 Linear Feet Install additional gutter
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 32.76 $ 46.38 8,189.38 $ 11,595.00 $ 30.00 $ 7,500.00 125.00 31,250.00 176.91 44,227.50 031 500 Square Foot Install additional sidewalk
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 30.57 15,286.83 58.19 $ $ 29,095.00 27.00 $ $ 13,500.00 25.00 12,500.00 34.16 17,080.00 032 10,000 Inch/LF Sawcut additional pavement (thickness) _______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 1.36 13,648.96 4.95 $ 49,500.00$ 1.25$ $ 12,500.00 0.50 5,000.00 1.22 12,200.00 033 1 Each Remove meter box
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 545.96 $ 728.42$ 545.96 $ $ 728.42500.00 $ 500.00 500.00 1,924.17 500.00 1,924.17 034 10 Ton Disposal of excavated soils at Class 1 landfill _______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 764.34 $ 208.89 7,643.42 $ 2,088.90 500.00 $ 5,000.00 $ 250.00 2,500.00 45.41 454.10 Supplemental Unit Pricing Summary
Supplemental Unit Pricing ENGINEER'S ESTIMATE Veteran Pipeline Construction Daleo Inc. Ranger Pipeline ARB Inc.

Item 14
Attachment B - GMR25 Bid
Summary

Item 14: Staff Report
Pg.
10 Packet Pg. 358 of 607

035 10 Ton Disposal of excavated soils at Class 2 landfill _______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 655.15 $ 36.33 6,551.50 $ $ 363.30700.00 $ 7,000.00 150.00 1,622.731,500.00 16,227.30 036 20 Each Additional pothole
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ $ 709.75 $ 14,194.92729.24 $ 14,584.80 $ 650.00 $ 13,000.00 2,000.00 40,000.00 4,512.27 90,245.40 037 1 Each Install/Replace existing gas meter box and lid with Armorcast Polymer Concrete Utility Box
(30" x 60" x 36") with extensions and one-piece
cover per Standard Detail GD-22
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 6,005.54 $ $ 985.64 6,005.54 $ 1,500.00$ 985.64 $ 5,000.00 1,500.00 3,848.335,000.00 3,848.33 038 45 Each Relocation of customer gas houseline (>2 ft to ≤5 ft) for gas meter relocation on the same side
of property.
_______________________________________
$ $ $ $ $ 4,913.63 $ 1,255.56 221,113.13 $ $ 56,500.20 3,500.00 $ $ 157,500.00 3,000.00 135,000.00 3,996.23 179,830.35 039 10 Each Relocation of customer gas houseline (>5 ft to ≤10 ft) for gas meter relocation on the same
side of property.
_______________________________________
$ $ $ $ $ 4,968.22 $ 1,255.56 $ 49,682.21 $ 12,555.60 4,300.00 $ $ 43,000.00 6,000.00 60,000.00 4,050.43 40,504.30 040 5 Each Relocation of customer gas houseline (>10 ft to ≤15 ft) for gas meter relocation on the same
side of property.
_______________________________________
$ $ $ $ $ 5,022.82 $ 2,283.98 $ 25,114.08 $ 11,419.90 4,875.00 $ $ 24,375.00 9,000.00 45,000.00 4,172.39 20,861.95 041 1 Each Install/Replace existing gas meter box and lid with Armorcast Polymer Concrete Utility Box
(24" x 36" x 18") with extensions and one-piece
cover per Standard Detail GD-21
_______________________________________
(Unit Price, in Words)
$ $ $ $ $ 5,241.20 $ $ 339.60 5,241.20 $ 1,400.00$ 339.60 $ 2,000.00 1,400.00 1,923.382,000.00 1,923.38 $ 13,092,324.18
ARB Inc.
$ 8,962,203.44
$ 503,889.85
$ 9,466,093.29
$ 12,274,266.85
$ 336,825.00
$ 12,611,091.85
$ 13,151,590.00
$ 415,800.00
$ 13,567,390.00
$ 15,165,184.39
$ 637,807.68
$ 15,802,992.07
Veteran Pipeline Construction Daleo Inc.
$ 415,800.00 ARB Inc.

Total SUP Bid: $ 637,807.68
Veteran
Pipeline
Construction
Total SUP Bid:
$ 503,889.85 Daleo Inc.

Total SUP Bid: $ 336,825.00
Ranger
Pipeline
Total SUP Bid:

Engineer's Estimate Ranger Pipeline
$ 12,661,371.96
$ 430,952.22

GRAND TOTAL
Engineering
Estimate: Supplemental Unit Pricing Total (items 022 through 041) Bid Summary
(Base Bid + Supplemental)
)02 0ghuor ht10 0semital (toeB Bas Tid
Supplemental Unit Pricing Total (items 022 through 041) $ 430,952.22
Item 14
Attachment B - GMR25 Bid
Summary

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U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration

July 2, 2024

Via E-mail: [email protected]

Edmar David, Engineer
City of Palo Alto Utilities Department
1007 Elwell Court
Palo Alto, CA 94301

RE: Request for NGDISM Grant Pre-Award Materials Costs

Dear
City of Palo Alto:

This letter serves as official notification that the pre-award costs requested have been approved for the costs listed below that are associated with the FY 2023 Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) grant program. Please note that, notwithstanding this approval, the Pipeline and Hazardous Materials Safety Administration (PHMSA) cannot reimburse costs prior to the full execution of the grant agreement; if, for any reason, a grant agreement is not executed, then the provisional awardee will be liable for all pre- award costs incurred. Reimbursement of costs as a Recipient of federal funds is contingent upon your compliance with the cost principles in 2 CFR Part 200, Subpart E (including allocability and documentation requirements) and any funding restrictions in the FY 2023 Notice of Funding Opportunity (NOFO).

When requesting reimbursement of actual costs incurred, the Recipient shall include a breakout of all costs incurred, including direct labor, indirect costs, and other direct costs. If PHMSA determines that the reimbursement request does not include or is not supported by sufficient detail, PHMSA may deny the request or withhold processing the request until the Recipient provides sufficient detail. You may not incur any costs that were not identified in your application unless you have received prior approval to amend your scope of work.

1200 New Jersey Avenue, SE
Washington, DC 20590
Item 14
Attachment C - GMR25 Tier-
2 EA Pre-Award
Authorization

Item 14: Staff Report
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12 Packet Pg. 360 of 607

Edmar David
City of Palo Alto

The approved pre-award costs are outlined below and may not include costs for expenses that were not included in your submitted and/or updated budget and project narratives.

Item Cost ($)
Tier 2 Environmental Assessment $182,400.00
Specification Documents $29,184.00
Contract Documents $29,184.00
Total $240,768.00

Please note the Recipient’s requests for materials must provide specific details and the request must address whether it complies with the Build America, Buy America (BABA) requirements.

These requests will be reviewed on a case-by-case basis by the grant program’s Environmental Protection Specialist (EPS) to ensure that the materials will not impact any Tier 2 mitigation efforts.

The pre-award authority extended in this letter is limited to costs incurred after PHMSA’s FY 2023 announcement on April 3, 2024.

If you have any questions or concerns, please contact your grant management specialist, Jasmine Carr, via email at [email protected] and cc: [email protected].

Sincerely,

Shakira N. Mack
Director, NGDISM Grant Program
Pipeline and Hazardous Materials Safety Administration
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
Item 14
Attachment C - GMR25 Tier-
2 EA Pre-Award
Authorization

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City Council
Staff Report
Report Type: CONSENT CALENDAR
Lead Department: City Clerk
Meeting Date: October 20, 2025
Report #:2510-5301
TITLE
SECOND READING: Adoption of Eight Ordinances Amending Various Sections of the Palo Alto Municipal Code (PAMC) Related to the 2025 California Building Standards Code (CA Code of Regulations Title 24) Update, including: (1) Chapter 16.04 Incorporating the 2025 CA Building Code With Local Amendments; (2) Chapter 16.05 Incorporating the 2025 CA Mechanical Code With Local Amendments; (3) Chapter 16.06 Incorporating the 2025 CA Residential Code With Local Amendments; (4) Chapter 16.08 Incorporating the 2025 CA Plumbing Code With Local Amendments; (5) Chapter 16.14 Incorporating the 2025 CA Green Building Standards Code with Local Amendments; (6) Chapter 16.16 Incorporating the 2022 CA Electrical Code With Local Amendments; (7) Chapter 16.18 Incorporating the 2024 International Swimming Pool and Spa Code With Local Amendments; (8) Chapter 16.17 Incorporating the 2025 CA Energy Code With Local Amendments; CEQA Status: Exempt Under CEQA Guidelines Sections 15061(b)(3) and 15308. (FIRST READING: October 6, 2025, PASSED: 6-0-1, Lauing absent)

BACKGROUND
The City Council heard this item on October 6, 2025 for a first reading and approved it on a 6-0- 1, Lauing absent vote. No changes were made to the ordinances, and they are now before the City Council for a second reading.

ATTACHMENTS
Attachment A - Chapter 16.04, California Building Code and Chapter 16.19, California Historical Building Code
Attachment B - Chapter 16.05 California Mechanical Code Attachment C - Chapter 16.06 California Residential Code Attachment D - Chapter 16.08 California Plumbing Code
Attachment E - Chapter 16.14 California Green Building Standards Attachment F - Chapter 16.16 California Electrical Code Item 15
Item 15 Staff Report

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Attachment G - Chapter 16.18 International Swimming Pool and Spa Code Attachment H - Chapter 16.17 California Energy Code
APPROVED BY:

Mahealani Ah Yun, City Clerk
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Item 15 Staff Report

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1 0290186_20250923_ms29
Ordinance No.

Ordinance of the Council of the City of Palo Alto Repealing Chapter 16.04 and Chapter 16.19 of the Palo Alto Municipal Code and Adopting a New Chapter 16.04, California Building Code, and a New Chapter 16.19, California Historical Building Code and California Existing Building Code, 2025 Editions, and Local Amendments and Related Findings

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Chapter 16.04 of the Palo Alto Municipal Code is hereby amended by repealing it in its entirety and adopting a new Chapter 16.04 to read as follows:

CHAPTER 16.04

CALIFORNIA BUILDING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 2, VOLUMES 1 & 2

Sections

16.04.010 2025 California Building Code, Title 24, Part 2, Volumes 1 & 2 adopted and amended.

16.04.020 Cross - References to California Building Code.

16.04.030 Local Amendments.

16.04.040 Adoption of 2025 California Building Code Chapter 1, Division II – Scope and Administration, Part 1 – Scope and Application and Part 2 – Administration and Enforcement.

16.04.050 Section 101.1 Title.

16.04.060 Section 101.2.1 Appendices.

16.04.070 Section 101.4 Referenced codes.

16.04.080 Section 103 Code Compliance Agency.

16.04.090 Section 104.2.4.1 Flood hazard area.

16.04.100 Section 104.3.1 Determination of substantially improved or substantially damaged existing buildings and structures in flood hazard areas.

16.04.110 Section 105.2 Work exempt from permit.

16.04.120 Section 105.3.2 Time limitation of application.

16.04.130 Section 105.5 Expiration.

16.04.140 Section 106.1 Live loads posted.

16.04.150 Section 109.6 Refunds.

16.04.160 Section 109.7 Re-Inspection fees.

Item 15
Attachment A - Chapter

16.04, California Building
Code and Chapter 16.19,
California Historical Building
Code

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16.04.170 Section 110.2.1 Preliminary accessibility compliance inspection.

16.04.180 Section 110.3.3 Lowest floor elevation.

16.04.190 Section 111.1 Use and occupancy.

16.04.200 Section 111.3 Temporary occupancy.

16.04.210 Section 111.5 Posting.

16.04.220 Section 113 Means of Appeals.

16.04.225 Section 114 Violations.

16.04.230 Section 115 Stop Work Order.

16.04.235 Section 202 Definitions.

16.04.240 Section 502.1 Address identification.

16.04.250 Reserved

16.04.260 Section 903.2 Automatic sprinkler systems, where required.

16.04.270 Section 903.3.1.1 NFPA 13 sprinkler systems.

16.04.280 Section 903.3.1.2 NFPA 13R sprinkler systems.

16.04.290 Section 903.3.1.3 NFPA 13D sprinkler systems.

16.04.300 Section 903.3.1.3.1 Increase in fire sprinkler design criteria.

16.04.310 Section 903.4.4 Floor control valves.

16.04.320 Section 905.3.1 Height.

16.04.330 Section 907.2.11.2.4 Smoke alarms.

16.04.340 Section 909.20.7 Smoke control systems schedule.

16.04.345 Section 915.6 Maintenance.

16.04.350 Section 1008.3 Illumination required by an emergency electrical system.

16.04.360 Section 1031.2 Where required.

16.04.370 Reserved.

16.04.380 Section 1205.3.4 Roof guards at courts.

16.04.390 Section 1208.6 Dwelling unit and congregate residence superficial floor area.

16.04.400 Section 1503.2.1 Locations.

16.04.410 Section 1612.1.1 Palo Alto Flood Hazard Regulations.

16.04.420 Section 1613.8 Suspended ceilings.

16.04.430 Reserved

16.04.440 Section 1705.3 Concrete construction.

16.04.450 Section 1803.2 Investigations required.

16.04.460 Section 1803.5.11 Seismic design categories C through F.

16.04.470 Section 1809.7 Prescriptive footings for light-frame construction.

16.04.480 Section 1809.8 Plain concrete footings.

16.04.490 Section 1901.2 Plain and reinforced concrete.

Item 15
Attachment A - Chapter

16.04, California Building
Code and Chapter 16.19,
California Historical Building
Code

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16.04.500 Section 1905.6.2 Seismic Design C, D, E and F.

16.04.510 SECTION 1906 FOOTINGS FOR LIGHT-FRAME CONSTRUCTION

16.04.520 Section 1906.1 Plain concrete footings.

16.04.530 Section 1907.1 Structural slabs-on-ground

16.04.535 Section 1907.2 Nonstructural slabs-on-ground

16.04.540 Reserved

16.04.550 Reserved

16.04.560 Section 2308.10.4 Braced wall panel construction.

16.04.570 Section 2308.10.5 Alternative bracing.

16.04.580 TABLE 2308.10.1 WALL BRACING REQUIREMENTS.

16.04.590 TABLE 2308.10.3(1) BRACING METHODS.

16.04.600 Section 2308.10.9 Attachment of sheathing.

16.04.610 SECTION 2505 SHEAR WALL CONSTRUCTION.

16.04.620 Reserved

16.04.630 Chapter 31B Public Pools.

16.04.640 Section 3304.1 Excavation and fill.

16.04.010 2025 California Building Code, Title 24, Part 2, Volumes 1 & 2 adopted and amended.

The California Building Code, 2025 Edition, Title 24, Part 2, Volumes 1 & 2 of the California Code of Regulations, together with those omissions, amendments, exceptions, and additions thereto, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and regulations to the chapters and sections of any former iteration of the California Code of Regulations, Title 24, shall be construed to apply to the corresponding provisions contained within the California Code of Regulations, Title 24, 2025. Ordinance No. 5564 and No. 5664 of the City of Palo Alto and all other ordinances or parts of ordinances in conflict herewith are hereby expressly repealed.

Wherever the phrases “California Building Code” or “Building Code” are used in this code or any ordinance of the City, such phrases shall be deemed and construed to refer and apply to the California Building Code, 2025 Edition, Title 24, Part 2 of the California Code of Regulations, as adopted by this chapter.

One (1) copy of the California Building Code, 2025 Edition, has been filed for use and examination of the public in the Office of the Chief Building Official of the City of Palo Alto.

16.04.020 Cross - References to California Building Code.

Item 15
Attachment A - Chapter

16.04, California Building
Code and Chapter 16.19,
California Historical Building
Code

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4 0290186_20250923_ms29
The provisions of this Chapter contain cross-references to the provisions of the California Building Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.

16.04.030 Local Amendments.

The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of the California Building Code, 2025 Edition, and shall be deemed to replace the cross-referenced sections of said Code with the respective provisions set forth in this Chapter. Where used in this Chapter 16.04, ellipses shall indicate text of the California Building Code, 2025 Edition, that has been adopted without amendment but is omitted for brevity.

16.04.040 Adoption of 2025 California Building Code Chapter 1, Division II – Scope and Administration, Part 1 – Scope and Application and Part 2 – Administration and Enforcement Chapter 1, Division II, Parts 1 – Scope and Application and Part 2 – Administration and Enforcement of the 2025 California Building Code are adopted in their entirety, as amended herein.

16.04.050 Section 101.1 Title.

Section 101.1 of the California Building Code is amended to read:

101.1 Title. These regulations shall be known as the Building Code of City of Palo Alto, hereinafter referred to as “this code”.

16.04.060 Section 101.2.1 Appendices.

Section 101.2.1 of the California Building Code is amended to read:

The following Appendix chapters and sections of the California Building Code, 2025 Edition, are adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein:

A. Appendix I – Patio Covers (Sections I101 through I105) B. Appendix J – Grading (Section J109.4 Drainage across property lines) C. Appendix Q – Emergency Housing (Sections Q101 through Q110)

16.04.070 101.4 Referenced codes.

Section 101.4 of the California Building Code is amended to add subdivisions 101.4.9 through 101.4.13, as follows:
101.4 Referenced codes. The other codes listed in Section 101.4.1 through 101.4.13 and referenced elsewhere in this code shall be considered part of the Item 15
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requirements of this code to the prescribed extent of each such reference.

[. . .]
101.4.9 Historical Buildings. The provisions of the California Historical Code shall apply to the alteration, addition, and relocation to qualified historical buildings or properties.

101.4.10 Electrical. The provisions of the California Electrical Code shall apply to the installation of electrical systems, including alterations, repairs, replacement, equipment, appliances, fixtures, fittings and appurtenances thereto. 101.4.11 Residential Buildings. The provisions of the California Residential Code shall apply to all matters governing the design and construction of detached, one- and two-family dwellings, townhouses not more than three stories and separate means of egress, and structural accessory thereto.

101.4.12 Green Building Standards. The provisions of the California Green Building Standards Code shall apply to all matters governing the "green building" related planning, design construction, operation, use and occupancy of newly constructed and altered buildings. 101.4.13 International Swimming and Spa Code. The provisions of the 2024 International Swimming and Spa Code shall apply to the installation of private swimming pools and spa facilities.

16.04.080 Section 103 Code Compliance Agency.

Section 103 of the California Building Code is amended to read:

103.1 Creation of enforcement agency. The Planning and Development Services Department is hereby created and the official in charge thereof shall be known as the chief building official, also referred to as building official or code official. The function of the department shall be the implementation, administration, and enforcement of the provisions of this code. 103.2 Appointment. The building official shall be appointed by the chief appointing authority of the jurisdiction.
103.3 Deputies. In accordance with the prescribed procedures of this jurisdiction and with the concurrence of the appointing authority, the building official shall Item 15
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have the authority to appoint assistant chief building officials, manager supervisors, and other technical officers, inspectors, and other employees. Such employees shall have powers as delegated by the building official.

16.04.090 Section 104.2.4.1 Flood hazard area.

Section 104.2.4.1 of the California Building Code is amended to read:
104.2.4.1 Flood hazard areas. The city engineer or designee shall not grant modifications to any provision required in flood hazard areas as established by Section 1612.3 unless a determination has been made that:

1. A showing of good and sufficient cause that the unique characteristics of the size, configuration or topography of the site render the elevation standards of Section 1612 inappropriate.

2. A determination that failure to grant the variance would result in exceptional hardship by rendering the lot undevelopable.

3. A determination that the granting of a variance will not result in increased flood heights, additional threats to public safety, extraordinary public expense, cause fraud on or victimization of the public, or conflict with existing laws or ordinances.

4. A determination that the variance is the minimum necessary to afford relief, considering the flood hazard.

5. Submission to the applicant of written notice specifying the difference between the design flood elevation and the elevation to which the building is to be built, stating that the cost of flood insurance will be commensurate with the increased risk resulting from the reduced floor elevation, and stating that construction below the design flood elevation increases risks to life a property.

16.04.100 Section 104.3.1 Determination of substantially improved or substantially damaged existing buildings and structures in flood hazard areas.

Section 104.3.1 of the California Building Code is amended to read:
104.3.1 Determination of substantially improved or substantially damaged existing buildings and structures in flood hazard areas. For applications for reconstruction, rehabilitation, repair, alteration, addition or other improvement of existing buildings or structures located in flood hazard areas, the city engineer or designee shall determine if the proposed work constitutes substantial improvement or repair of substantial damage. Where the city engineer or designee determines that the proposed work constitutes substantial improvement or repair of substantial damage, and where required by this code, the city engineer or designee shall require the building to meet the requirements Item 15
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of Section 1612 of the California Building Code, Section R306 of the California Residential Code as amended, or Palo Alto Municipal Code 16.52 Flood Hazard Regulations, whichever is more stringent.

16.04.110 Section 105.2 Work exempt from permit.

Section 105.2 of the California Building Code is amended to read:

105.2 Work exempt from permit. Exemptions from permit requirements of this code shall not be deemed to grant authorization for any work to be done in any manner in violation of the provisions of this code or any other laws or ordinances of this jurisdiction. Permits shall not be required for the following:

Building:

1. One-story detached accessory structures used as tool and storage sheds, playhouses and similar uses, provided that the floor area does not exceed 120 square feet (11.15 m2). It is permissible that these structures still be regulated by Section 710A, despite exemption from permit.

2. Wood fences, other than swimming pool barriers, not over 7 feet (2134 mm) high or concrete or masonry wall not over 4 feet (1219 mm) high when not subject to specific city of Palo Alto Planning and Zoning regulations.

3. Retaining walls that are not over 4 feet (1219 mm) in height measured from the bottom of the footing to the top of the wall, unless supporting a surcharge or impounding Class I, II or IIIA liquids.

4. Oil derricks.

5. Water tanks supported directly on grade if the capacity is not greater than 5,000 gallons (18 925 L) and the ratio of height to diameter or width is not greater than 2:1.

6. Sidewalks and driveways not more than 30 inches (762 mm) above adjacent grade and not over any basement or story below and are not part of an accessible route, accessible parking spaces, or required exits.

7. Wood decks not over 30 inches above surrounding grade or finishes, not attached to a structure, or serving any part of the means of egress.

8. Painting, papering, tiling, carpeting, cabinets, counter tops and similar finish work.

9. Temporary motion picture, television and theater stage sets and scenery.

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10. Prefabricated swimming pools accessory to a Group R-3 occupancy that are less than 24 inches deep, do not exceed 5,000 gallons and are installed entirely above ground.

11. Shade cloth structures constructed for nursery or agricultural purposes, not including service systems.

12. Swings and other playground equipment accessory to detached one- and two- family dwellings and not considered a public playground.

13. Window awnings supported by an exterior wall that do not project more than 54 inches (1,372 mm) from the exterior wall and do not require additional support of Group R-3 and U occupancies.

14. Nonfixed and movable fixtures, cases, racks, counters and partitions not over 5 feet 9 inches (1753 mm) in height.

Electrical:

1. Repairs and maintenance: Minor repair work, including the replacement of lamps or the connection of approved portable electrical equipment to approved permanently installed receptacles.

2. Radio and television transmitting stations: The provisions of this code shall not apply to electrical equipment used for radio and television transmissions, but do apply to equipment and wiring for a power supply and the installations of towers and antennas.

3. Temporary testing systems: A permit shall not be required for the installation of any temporary system required for the testing or servicing of electrical equipment or apparatus.

4. Temporary decorative lighting: Exterior listed plug-in decorative lighting plugged into a waterproof GFCI receptacle outlet.

5. Replacement of overcurrent devices: Replacement of any overcurrent device less than 1,200 amps of the same capacity in the same location.

6. Wiring for temporary theatre, motion picture or television stage sets.

7. Electrical wiring, devices, appliances, apparatus, or equipment operating at less than 25 volts and not capable of supplying more than 50 watts of energy.

Gas:

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1. Portable heating appliance.

2. Replacement of any minor part that does not alter approval of equipment or make such equipment unsafe.

Mechanical:

1. Portable heating appliance.

2. Portable ventilation equipment.

3. Portable cooling unit.

4. Steam, hot or chilled water piping within any heating or cooling equipment regulated by this code.

5. Replacement of any part that does not alter its listing/approval or make it unsafe.

6. Portable evaporative cooler.

7. Self-contained refrigeration system containing 10 pounds (4.54 kg) or less of refrigerant and actuated by motors of 1 horsepower (0.75 kW) or less.

Plumbing:

1. The stopping of leaks in drains, water, soil, waste or vent pipe, provided however, that if any concealed trap, drain pipe, water, soil, waste or vent pipe becomes defective and it becomes necessary to remove and replace the same with new material, such work shall be considered as new work and a permit shall be obtained and inspection made as provided in this code.

2. The clearing of stoppages or the repairing of leaks in pipes, valves or fixtures and the removal and reinstallation of water closets, provided that such repairs do not involve or require the replacement or rearrangement of valves, pipes or fixtures.

[. . .]

16.04.120 Section 105.3.2 Time limitation of application.

Section 105.3.2 of Chapter 1 of the California Building Code is amended to read:

105.3.2 Time limitation of application. An accepted application for a permit for any proposed work shall be deemed to have been abandoned twelve (12) months after the date of filing, unless such application has been pursued in good faith or a permit has been issued; except that the building official is authorized to grant one or more extensions and/or reactivations for additional periods not exceeding ninety (90) days each. The extension shall be required in writing and Item 15
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justifiable cause demonstrated.

16.04.130 Section 105.5 Expiration.

Section 105.5 of Chapter 1 of the California Building Code is amended to read:

105.5 Expiration. Every permit issued shall become invalid unless the work on the site authorized by such permit is commenced within twelve (12) months after its issuance, or if the work authorized on the site by such permit is suspended or abandoned for a period of twelve (12) months after the time the work is commenced. For the purpose of this section, failure to progress a project to the next level of required inspection, as determined by the chief building official, shall be deemed to be suspension of the work.

The chief building official or designee is authorized to grant, in writing, no more than three extensions and reactivations of permits that would otherwise expire or reactivations of expired permits, for periods not more than 180 days each and may require:

1. that construction documents be revised to partially or fully to comply with current codes and ordinances; and

2. payment of fees; and

3. payment of a penalty pursuant to Chapter 16.62 of the Palo Alto Municipal Code.

Extensions and reactivations shall be requested in writing and justifiable cause demonstrated. Additional extensions or reactivations beyond three may only be granted with the approval of the City Council.
105.5.1 Term limit for permits. All work associated with a building permit must be completed, and final inspection issued, within forty-eight (48) months of permit issuance. Once a term limit has been exhausted without obtaining an approved final inspection the permit will automatically become void. The chief building official or designee is authorized to allow a new permit application to be applied for the original scope of work and may require:

1. that construction documents be revised to partially or fully to comply with current codes and ordinances; and

2. payment of partial or all plan review and permit fees; and

3. payment of a penalty pursuant to Chapter 16.62 of the Palo Alto Municipal Code.

16.04.140 Section 106.1 Live loads posted.

Section 106.1 of the California Building Code is amended to read:

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106.1 Live Loads Posted. In commercial, institutional or industrial buildings, for each floor or portion thereof designed for live loads exceeding 50 psf (2.40 kN/m2), such design live loads shall be conspicuously posted by the owner or the owner's authorized agent in that part of each story in which they apply, using durable signs. It shall be unlawful to remove or deface such notices.

16.04.150 Section 109.6 Refunds.

Section 109.6 of Chapter 1 of the California Building Code is amended to read:

109.6 Refunds. The building official or designee may authorize the refund of any fee paid hereunder which was erroneously paid or collected. The building official or designee may authorize the refund of not more than eighty percent (80%) of the Permit Fee paid when no work has occurred under a permit issued pursuant to this Chapter. The building official or designee may authorize the refund of not more than eighty percent (80%) of the Plan Review Fee paid when a permit application is withdrawn or canceled before any plan review work has started.

16.04.160 Section 109.7 Re-Inspection fees.

Section 109.7 of Chapter 1 of the California Building Code is added to read:

109.7 Re-Inspection Fees. A re-inspection fee may be assessed/authorized by the building official or designee for each occurrence as itemized below:

1. inspection record card is not posted or otherwise available on the work site; or

2. approved plans are not readily available for the inspector at the time of inspection; or

3. inspector is unable to access the work at the time of inspection; or

4. when work has substantially deviated from the approved plans without the prior approval of required revision; or

5. when work for which an inspection is requested is not ready for inspection; or

6. when required corrections noted during prior inspections have not been completed.

When a re-inspection fee is assessed, additional inspection of the work will not be performed until the fee has been paid.

16.04.170 Section 110.2.1 Preliminary accessibility compliance inspection.

Section 110.2.1 of Chapter 1 of the California Building Code is added to read:

110.2.1 Preliminary accessibility compliance inspection. Before issuing a permit, the building official or designee is authorized to examine or cause to be examined Item 15
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the pre- construction accessibility compliance conditions of the buildings, structures, and sites for which an application has been filed.

16.04.180 Section 110.3.3 Lowest floor elevation.

Section 110.3.3 of Chapter 1 of the California Building Code is amended to read:

110.3.3 Lowest floor elevation. In flood hazard areas, upon placement of the lowest floor, including the basement, and prior to further vertical construction, the elevation certification shall be submitted to City Public Works Engineering for inspection approval prior to foundation inspection by City Building Inspection staff.

16.04.190 Section 111.1 Use and occupancy.

Section 111.1 of Chapter 1 of the California Building Code is amended to read:

111.1 Use and occupancy. A building or structure shall not be used or occupied, and a change in the existing occupancy of a building or structure or portion thereof shall not be made, until the chief building official has issued a certificate of occupancy therefor as provided herein. Issuance of a certificate of occupancy shall not be construed as an approval of a violation of the provisions of this code or of other ordinances of the jurisdiction.

Exception: Certificates of occupancy are not required or issued for:

1. Work exempted from permits under Section 105.2

2. Group R – Division 3 and Group U occupancies located on a single-family residential/agricultural lot.

3. Non-residential “core and shell” or similar construction (exterior envelope and structural framework) without finalized tenant improvement(s).

4. Site development without a building or buildings as defined in section 202.

111.1.1 Change of occupancy or tenancy. Each change of occupancy, official name or tenancy of any building, structure, or portion thereof, shall require a new certificate of occupancy, whether or not any alterations to the building are required by this code.

Before any application for a new certificate of occupancy is accepted, a fee shall be paid by the applicant to cover the cost of the inspection of the building required by the change of occupancy or tenancy.

When application is made for a new certificate of occupancy under this section, the building official and fire chief shall cause an inspection of the Item 15
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building to be made. The inspector(s) shall inform the applicant of those alterations necessary, or if none are necessary, and shall submit a report of compliance to the building official.

If a portion of any building does not conform to the requirements of this code for a proposed occupancy, that portion shall be made to conform. The building official may issue a new certificate of occupancy without requiring compliance with all such requirements if it is determined that the change in occupancy or tenancy will result in no increased hazard to life or limb, health, property, or public welfare.

16.04.200 Section 111.3 Temporary occupancy.

Section 111.3 of Chapter 1 of the California Building Code is amended to read:
111.3 Temporary occupancy. The building official or designee is authorized to issue a temporary certificate of occupancy before the completion of the entire work covered by the permit, or as otherwise required, provided that such portion or portions shall be occupied safely. The building official or designee shall set a time period during which the temporary certificate of occupancy is valid.

16.04.210 Section 111.5 Posting.

Section 111.5 of Chapter 1 of the California Building Code is added to read:

111.5 Posting. The temporary certificate of occupancy or certificate of occupancy shall be posted in a conspicuous, readily accessible place in the building or portion of building to be occupied and shall not be removed except when authorized by the building official.

16.04.220 Section 113 Means of Appeals.

Section 113 of Chapter 1 of the California Building Code is amended to read:

SECTION 113 MEANS OF APPEALS

113.1 Appeals. A person requesting an order, decision, or determination made by the building official relative to the California Building Code (as amended) may appeal such order,
decision or determination by completing a request for hearing form and returning it to the City within thirty calendar days from the date of the decision, together with all applicable fees authorized by the City’s Municipal Fee Schedule.

A request for hearing shall be based on a claim that the true intent of the California Building Code (as amended) or the rules legally adopted thereunder have been incorrectly interpreted, the provisions of this code do not fully apply or an equivalent or better form of construction is proposed.

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(a) The person requesting the hearing shall be notified of the time and place set for the hearing at least ten days prior to the date of the hearing. (b) If the building official submits an additional written report concerning the decision to hearing officer for consideration at the hearing, then a copy of this report shall also be served on the person requesting the hearing at least five days prior to the date of the hearing.
(c) The appeal procedure set out in this Section 113.1 et seq. does not apply to:
(1) decisions by the building official or any other City official related to administrative enforcement actions taken under Chapter 1.12 or Chapter 1.16 of the Palo Alto Municipal Code; (2) decisions by the City to enforce the California Building Code under any provision of criminal law; or (3) any other action taken by the City that specifies its own appeal procedure.

113.2 Hearing Officer. The building official shall designate a hearing officer for the appeal hearing. The hearing officer may consist of one person or a body of people. The hearing officer shall not be the building official or any directly subordinate employees.
(a) The hearing officer does not have authority to waive requirements of the California Building Code (as amended) or interpret the administration of the Code.
(b) The hearing officer does not have authority to issue an order, decision, or determination on his or her own authority. This includes the issuance or amendment of building permits.
(c) The hearing officer shall be qualified by experience and training to pass on matters pertaining to building construction.
113.3 Hearing procedures.
(a) No appeal hearing before a hearing officer shall be noticed unless the applicable fee(s) been paid in advance in accordance with Section 113.1. (b) A hearing before the hearing officer shall be set for a date that is not less than fifteen days and not more than sixty days from the date that the request for hearing is filed in accordance with the provisions of this chapter. The party requesting the hearing may request one continuance for any reason, provided that the hearing officer is given the request for continuance at least forty-eight hours in advance of the scheduled hearing and that the deferred hearing shall not be deferred more than ninety days after the request for hearing was made.

A request for continuance made less than forty-eight hours before the scheduled hearing may be granted by the hearing officer based upon exigency only. The parties may stipulate to an alternative hearing date schedule outside of these rules upon a finding of good cause and approval from the hearing officer. (c) At the hearing, the appellant shall be given the opportunity to testify and to Item 15
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present evidence and cross-examine witnesses concerning the appeal. The appellant may appear personally or through a representative. Prehearing discovery is not authorized, but subpoena of witnesses and documents shall be permitted as authorized by law. The hearing officer may conduct the hearing informally, both as to rules of procedure and admission of evidence, in any manner which will provide a fair hearing.
(d) The failure of the appellant to appear at the hearing or, in the alternative, to present written or demonstrative evidence shall constitute the dismissal of the appeal with prejudice.
(e) The administrative record and any additional report submitted by the building official shall constitute presumptive evidence of the respective facts contained in those documents. The building official shall have the same rights as the appellant to testify, present evidence, and cross-examine witnesses concerning the appeal.
(f) The hearing officer may continue the hearing and request additional information from the building official or appellant prior to issuing a written decision.

113.4 Hearing Officer’s decision.
(a) After considering all the testimony and evidence submitted at the hearing, the hearing officer shall issue a written decision to uphold or amend the building official’s order, decision or determination, and the reasons for that decision. The decision of the hearing officer shall be issued within thirty days following completion of the hearing. The decision of the hearing officer shall be final upon service on the appellant, subject only to judicial review as allowed by law. (b) The hearing officer shall consider any written or oral evidence submitted at the hearing consistent with ascertainment of the facts regarding the issues of the appeal.
(c) If the hearing officer determines that the building official’s order, decision, or determination should not be upheld as originally given, then the hearing officer shall direct the building official to make any amendments or changes necessary to implement the hearing officer’s decision. The hearing officer shall also give the building official a reasonable deadline to complete such actions. (d) The appellant shall be served with a copy of the hearing officer's written decision within ten calendar days following its issuance.

16.04.225 Section 114 Violations.

Section 114 of Chapter 1 of the California Building Code is amended to read:

SECTION 114 VIOLATIONS
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114.1 Unlawful acts. It is unlawful for any person to violate any provision or to fail to comply with any of the requirements of this Chapter or any permits, conditions, or variances granted under this Chapter. Violators shall be subject to any penalty or penalties authorized by law, including but not limited to: administrative enforcement pursuant to Chapters 1.12, 1.16 and 16.62 of the Palo Alto Municipal Code; and criminal enforcement pursuant to Chapter 1.08 of the Palo Alto Municipal Code. Each separate day or any portion thereof during which any violation of this Chapter occurs or continues shall be deemed to constitute a separate offense.

When the chief building official determines that a violation of this Chapter has occurred, the chief building official may, in his or her sole discretion, record a notice of pendency of code violation with the Office of the County Recorder stating the address and owner of the property involved. When the violation has been corrected, the chief building official shall issue and record a release of the notice of pendency of code violation.

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114.5 Criminal enforcement authority. The employee positions designated in this section are authorized to exercise the authority provided in California Penal Code section 836.5 for violations of this Chapter. The designated employee positions are: (1) chief building official, (2) assistant chief building official, (3) building inspection manager, (4) Building Inspector or Building Inspector Specialist as designated by the chief building official and
(5) code enforcement officer.

16.04.230 Section 115 Stop Work Order.

Section 115 of Chapter 1 of the California Building Code is amended to read:

SECTION 115 STOP WORK ORDER

115.1 Authority. Whenever the building official finds any work regulated by this code being performed in a manner that is contrary to the provisions of this code, without a permit, beyond the scope of the issued permit, in violation of the Palo Alto Municipal Code or Zoning Ordinance, or dangerous or unsafe, the building official is authorized to issue a stop work order.
115.2 Issuance. The stop work order shall be in writing and shall be posted in a visible location near the location where the work is being conducted. If the owner or owner’s agent is not on site at the time of posting, a notice advising the reasons for the stop work order issuance shall be hand delivered or mailed first- class to the owner of the property involved, or to the owner’s agent, or to the person doing the work. Upon issuance of a stop work order, the cited work shall immediately cease. The stop work order shall state the reason for the order, the conditions under which the cited work will be permitted to resume, and the Item 15
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name and contact information of the official or agency issuing the order. 115.3 Emergencies. Where an emergency exists, the building official shall not be required to give a written notice prior to stopping the work. 115.4 Unlawful continuance. Any person who continues to engage in any work after having been served with a stop work order, except such work as that person is directed to perform to remove a violation or unsafe condition, shall be guilty of a misdemeanor.
115.5 Removal of posted stop work order. Any person who removes a posted stop work order without written consent of the Building Official shall be guilty of a misdemeanor.
115.6 Response required. Violators receiving a stop work order are required to respond to Planning and Development Services within five (5) business days of the issued notice to receive instructions on how to rescind the order. 115.7 Permit application required. A building permit application with construction or demolition plans and supporting (structural calculations, energy calculations, accessible access) documents must be submitted for approval within twenty (20) working days following response to Planning and Development Services. Plans will be reviewed and correction letters issued or permit application approved by Planning and Development Services. A response to any correction letter must be submitted within fifteen (15) working days of the date of the correction letter. Ten (10) working days will be required to review this second submission and a permit approved for issuance. Permits ready for issuance must be issued within five (5) working days thereafter. All construction must be inspected as work progresses and signed off by all (affected) departments within the permit term limits outlined in Section 105.5.1 or as determined by the building official.
115.8 Stop work order penalty. The Building Official may impose Stop Work Order Penalties in accordance with Section 1.14.050 of this code and/or other applicable law.

16.04.235 Section 202 Definitions.

Section 202 of Chapter 2 of the California Building Code is amended to read:

[…]

FLOOR AREA, GROSS. The floor area within the inside perimeter of the exterior walls of the building under consideration, exclusive of vent shafts and courts, without deduction for corridors, stairways, ramps, closets, the thickness of interior walls, columns or other features. The floor area of a building, or portion thereof, not provided with surrounding exterior walls shall be the usable area under the horizontal projection of the roof or floor Item 15
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above. The gross floor area shall not include shafts with no openings or interior courts. For the purposes of Title 18 (Zoning), the definition of “gross floor area” in Section 18.04.030 shall apply.

[…]

FLOOR AREA, NET. The actual occupied area not including unoccupied accessory areas such as corridors, stairways, ramps, toilet rooms, mechanical rooms and closets. For the purposes of Title 18 (Zoning), the definition of “net floor area” in Section 18.04.030 shall apply.

[…]

16.04.240 Section 502.1 Address identification.

Section 502.1 of Chapter 5 of the California Building Code is amended to read:

502.1 Address identification. New and existing buildings shall be provided with approved address identification. The address identification shall be legible and placed in a position that is visible from the street or road fronting the property. Address identification characters shall contrast with their background. Address numbers shall be Arabic numbers or alphabetical letters. Numbers shall not be spelled out. Each character shall be not less than 4 inches (102 mm) high with a minimum stroke width of ½ inch (12.7 mm) unless required to be larger by Section 502.1.2. When required by the fire code official, address identification shall be provided in additional approved locations to facilitate emergency response. Where access is by means of a private road and the building address cannot be viewed from the public way, a monument, pole or other approved sign or means shall be used to identify the structure. Address numbers shall be maintained.

502.1.1 Address illumination. Address identification required by Section 502.1 shall be illuminated.

502.1.2 Address identification size. Address numbers and letters shall be sized as follows:

1. When the structure is between thirty-six (36) and fifty (50) feet from the road or other emergency means of access, a minimum of one-half inch (0.5") stroke by six inches (6") high is required.

2. When the structure is fifty (50) or more feet from the road or other emergency means of access, a minimum of one inch (1") stroke by nine inches (9") high is required.

16.04.250 Reserved.

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16.04.260 Section 903.2 Automatic sprinkler systems, where required.

Section 903.2 of Chapter 9 the California Building Code is amended to read:

903.2 Automatic sprinkler systems, where required. Approved automatic sprinkler systems in new buildings and structures and in existing modified buildings and structures, shall be provided in the locations described in this section. Automatic fire sprinklers shall be installed per the requirements set forth in Sections 903.2.1 through 903.2.18 and as follows, whichever is the more restrictive:

1. An automatic sprinkler system shall be provided throughout all new buildings and structures.

Exception: New non-residential occupancies, buildings or structures that do not exceed 350 square feet of building area and contain no plumbing fixtures.

2. An automatic sprinkler system shall be provided throughout all existing buildings when modifications are made that create conditions described in Sections 903.2.1 through 903.2.18, or that create an increase in fire area to more than 3600 square feet or when the addition is equal or greater than 50% of the existing building square footage whichever is more restrictive.

3. An automatic sprinkler system is required in basements when any of the following occur:
a. New basements used for storage, utility, occupancy or habitable space regardless of size.
b. Existing basements that are altered for the use of storage, utility, occupancy, or habitable space regardless of size.
c. Existing basements that are expanded by more than 50%. If the addition or alteration is only the basement, then only the basement is required to be fire sprinkler protected.

4. An automatic sprinkler system shall be installed throughout when either the roof structure and/or exterior wall structure have been removed, altered, and/or replaced by at least 50% of the existing structure.

5. An automatic sprinkler system shall be installed throughout when any change in use or occupancy creates a more hazardous fire/life-safety condition, as determined by the fire code official.

6. All new trash enclosures regardless of size require installation of fire sprinklers (nonresidential only).

Exception: A fire extinguishing system will not apply when all of the Item 15
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following conditions are met:
a. The trash enclosure including the door(s) and roof are constructed of noncombustible materials.
b. The trash enclosure is a stand-alone structure, be a minimum of 20 feet away from adjacent buildings and 10-feet away from property line(s); and
c. The enclosure is used exclusively for waste garbage, recyclables, and organize waste/composting contained within the approved trash bins/containers. No outdoor storage is permitted within the trash enclosure.

7. Phone booths and pods when installed in a building equipped with a fire sprinkler system (nonresidential only).

8. Fume hoods when installed in a building equipped with a fire sprinkler system (nonresidential only).

Exception: Spaces or areas in telecommunications buildings used exclusively for telecommunications equipment, associated electrical power distribution equipment, batteries and standby engines, provided that those spaces or areas are equipped throughout with an automatic smoke detection system in accordance with Section 907.2 and are separated from the remainder of the building by not less than 1-hour fire barriers constructed in accordance with Section 707 or not less than 2-hour horizontal assemblies constructed in accordance with Section 711, or both.

16.04.270 Section 903.3.1.1 NFPA 13 sprinkler systems.

Section 903.3.1.1 of Chapter 9 of the California Building Code is amended to read:
903.3.1.1 NFPA 13 sprinkler systems. Where the provisions of this code require that a building or portion thereof be equipped throughout with an automatic sprinkler system in accordance with this section, sprinklers shall be installed throughout in accordance with NFPA 13 and State and local requirements except as provided in Section 903.3.1.1.

1. For new buildings having no designated use or tenant, the minimum sprinkler design density shall be Ordinary Hazard Group II/1500 square feet.

2. Where future use or tenant is determined to require a higher density, the sprinkler system shall be augmented to meet the higher density.

3. Light hazard occupancy shall be hydraulically designed to a 1500 square feet most remote area or as required by the fire code official Item 15
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4. Laboratory areas within buildings shall be hydraulically designed to Ordinary Hazard II density.

5. Parking areas where mechanical vehicle storage equipment is used shall be hydraulically designed to Extra Hazard II density.

6. In multi-residential apartments, townhomes, and condominiums.

7. In new commercial buildings that will have power micro mobility devices, the fire sprinkler system shall be designed to Ordinary Hazard II.

8. Energy Storage Systems in nonresidential buildings shall comply with one of the following:
a. ESS units with a maximum stored energy capacity of 50 kWh, as described in Section 1207.5.1 shall be designed with a minimum density of 0.40 gpm/ft2 (1.14 L/min) based over the area of the room or 2,500 square-foot design area, whichever is smaller. b. ESS units (groups) exceeding 50 kWh shall use a density based on large- scale fire testing complying with Section 1207.1.7.

16.04.280 Section 903.3.1.2 NFPA 13R sprinkler systems.

Section 903.3.1.2 of Chapter 9 of the California Building Code is amended to read:

903.3.1.2 NFPA 13R sprinkler systems. Where allowed in buildings of Group R Occupancies, automatic sprinkler systems shall be installed throughout in accordance with NFPA 13 and State and local standards.

16.04.290 Section 903.3.1.3 NFPA 13D sprinkler systems.

Section 903.3.1.3 of Chapter 9 of the California Building Code is amended to read:

903.3.1.3 NFPA 13D sprinkler systems. Where allowed, automatic sprinkler systems installed in one-and two-family detached dwellings shall be installed throughout in accordance with NFPA 13D and State and local standards. Fire sprinkler protection is required under rear covered patios extending 4 feet perpendicular from the exterior of the structure.

16.04.300 Section 903.3.1.3.1 Increase in fire sprinkler design criteria.

Section 903.3.1.3.1 of Chapter 9 of the California Building Code is added to read:

903.3.1.3.2 Increase in fire sprinkler design criteria. Structures determined by the fire code official to have higher firefighting hazardous conditions or located in the Wildland- Urban Interface Fire Area shall have an increase in fire sprinkler design criteria as determined by the fire code official.

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16.04.310 Section 903.4.4 Floor control valves.

Section 903.4.4 of Chapter 9 of the California Building Code is amended to read:

903.4.4 Floor control valves. Automatic sprinkler systems serving buildings two (2) or more stories in height shall have valves installed so as to control the system independently on each floor including basements.

16.04.320 Section 905.3.1 Height.

Section 905.3.1 of the California Building Code is amended to read:
905.3.1 Height. A Class I standpipe system shall be installed in buildings where the roof edge/parapet is greater than 27 feet above the lowest level of fire apparatus access roadway and in below grade levels.

16.04.330 Section 907.2.11.2.4 Smoke alarms.

Section 907.2.11.2.4 of the California Building Code is amended to read:
907.2.11.2.4 Smoke alarms. Smoke alarms shall be tested and maintained in accordance with the manufacturer's instructions. Smoke alarms that no longer function or are 10 years or older from the date of installation shall be replaced.

16.04.340 Section 909.20.7 Smoke control systems schedule.

Section 909.20.7 is added to the California Building Code to read as follows:

909.20.7 Smoke control systems schedule. A routine maintenance and operational testing program shall be initiated immediately after the smoke control system has passed the acceptance tests. A written schedule for routine maintenance and operational testing shall be established and both shall occur at least annually.

16.04.345 Section 915.6 Maintenance
Section 915.6 of the California Building Code is amended to read:

915.6 Maintenance. Carbon monoxide alarms and carbon monoxide detection systems shall be maintained in accordance with NFPA 72. Carbon monoxide alarms and carbon monoxide detectors that become inoperable or begin producing end-of-life signals or are 10 years or older shall be replaced.

16.04.350 Section 1008.3 Illumination required by an emergency electrical system.

Section 1008.3 of the California Building Code is amended to read as follows:

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1008.3 Illumination required by an emergency electrical system. In the event of power supply failure, an emergency electrical system shall automatically illuminate all of the following areas:

1. In rooms or spaces that require two or more exits or access to exits:

1.1 Aisles.

1.2 Corridors.

1.3 Exit access stairways and ramps.

2. In buildings that require two or more exits or access to exits:

2.1 Interior exit access stairways and ramps.

2.2 Interior and exterior exit stairways and ramps.

2.3 Exit passageways.

2.4 Vestibules and areas on the level of discharge used for exit discharge in accordance with Section 1028.2.

2.5 Exterior landings as required by Section 1010.1.5 for exit doorways that lead directly to the exit discharge.

2.6 Group I-2 exit discharge stairways, ramps, aisles, walkways and escalators leading to a public way or to a safe dispersal area in accordance with Section 1028.5.

3. In other rooms and spaces:

3.1. Electrical equipment rooms.

3.2. Fire command centers.

3.3. Fire pump rooms.

3.4. Generator rooms.

3.5. Public restrooms.

16.04.360 Section 1031.2 Where required.

Section 1031.2 of Chapter 10 of the California Building Code is amended to read:

1031.2 Where required. In addition to the means of egress required by this chapter, emergency escape and rescue openings shall be provided in Group R occupancies.

Basements and sleeping rooms below the fourth story above grade plane shall have not fewer than one emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, an emergency escape and rescue opening shall be required in each sleeping room but shall not be required in adjoining areas of the basement. Such openings shall open directly into a public way or to a yard or court that opens to a public way or to an egress balcony that leads to a public way.

Exceptions:

1. In Group R-1 and R-2 occupancies constructed of Type I, Type IIA, Type IIIA or Type IV construction equipped throughout with an approved automatic sprinkler system in accordance with Section 903.3.1.1.

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2. Group R-2.1 occupancies meeting the requirements for delayed egress in accordance with Section 1010.2.13 may have operable windows that are breakable in sleeping rooms permanently restricted to a maximum of 4-inch open position.

3. Emergency escape and rescue openings are not required from basements or sleeping rooms that have an exit door or exit access door that opens directly into a public way or to a yard, court or exterior egress balcony that leads to a public way.

4. Storm shelters and basements used only to house mechanical equipment not exceeding a total floor area of 200 square feet (18.58 m2)

16.04.370 Reserved.

16.04.380 Section 1205.3.4 Roof guards at courts.

Section 1205.3.4 of Chapter 12 of the California Building Code is added to read:
1205.3.4 Roof guards at courts. Roof openings into courts where not bounded on all sides by walls shall be protected with guardrails. The top of the guards shall not be less than 42 inches in height. Required guards shall not have openings that allow passage of a sphere twelve inches (12) in diameter from the walking surface to the required guard height.

Exception: Where the roof opening is greater than 600 square feet in area.

16.04.390 Section 1208.6 Dwelling unit and congregate residence superficial floor area.

Section 1208.6 of Chapter 12 of the California Building Code is added to read:

1208.6 Dwelling unit and congregate residence superficial floor area. Every dwelling unit and congregate residence shall have at least one room which shall have not less than 120 square feet of superficial floor area. Every room which is used for both cooking and living or both living and sleeping purposes shall have not less than 144 square feet of superficial floor area. Every room used for sleeping purposes shall have not less than 70 square feet of superficial floor area.

When more than two persons occupy a room used for sleeping purposes the required superficial floor area shall be increased at the rate of 50 square feet for each occupant in excess of two. Guest rooms with cooking shall contain the combined required superficial areas of a sleeping and a kitchen, but not less than 144 square feet. Other habitable rooms shall be not less than 70 square feet.

Notwithstanding any provision of this Section, children under the age of six shall not be counted for purposes of determining whether a family with minor children Item 15
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complies with the provisions of this Code.

For the purposes of this section, "superficial floor area" means the net floor area within the enclosing walls of the room in which the ceiling height is not less than seven feet six inches, excluding built-in equipment such as wardrobes, cabinets, kitchen units, or fixtures which are not readily removable.

16.04.400 Section 1503.2.1 Locations.

Section 1503.2.1 of Chapter 15 of the California Building Code is amended to read:
1503.2.1 Locations. Flashing shall be installed at wall and roof intersections, gutters, wherever there is a change in roof slope or direction, and around roof openings. Where flashing is of metal, the metal shall be corrosion resistant with a thickness of not less than 0.019 inches (0.483 mm) (e.g. no. 26 galvanized sheet) and shall be primed and painted.

16.04.410 Section 1612.1.1 Palo Alto Flood Hazard Regulations.

Section 1612.1.1 of Chapter 16 of the California Building Code is added to read:
1612.1.1 Palo Alto Flood Hazard Regulations. Notwithstanding the provisions of Section 1612.1, all construction or development within a flood hazard area(areas depicted as a Special Flood Hazard Area on Flood Insurance Rate Maps published by the Federal Emergency Management Agency) shall comply with the City of Palo Alto Flood Hazard Regulations (Palo Alto Municipal Code Chapter 16.52).

Where discrepancies exist between the requirements of this code and said regulations, the more stringent requirements shall apply.

16.04.420 Section 1613.8 Suspended ceilings.

Section 1613.8 of Chapter 16 of the California Building Code is added to read:

1613.8 Suspended ceilings. Minimum design and installation standards for suspended ceilings shall be determined in accordance with the requirements of Section 2506.2.1 of this Code and this section.
1613.8.1 Scope. This part contains special requirements for suspended ceilings and lighting systems. Provisions of Section 13.5.6 of ASCE 7 shall apply except as modified herein.
1613.8.2 General. The suspended ceilings and lighting systems shall be limited to 6 feet (1828 mm) below the structural deck unless the lateral bracing is designed by a licensed engineer or architect.
1613.8.3 Sprinkler heads. All sprinkler heads (drops) except fire-resistance-rated Item 15
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floor/ceiling or roof/ceiling assemblies, shall be designed to allow for free movement of the sprinkler pipes with oversize rings, sleeves, or adaptors through the ceiling tile. Sprinkler heads and other penetrations shall have a 2-inch (50mm) oversize ring, sleeve, or adapter through the ceiling tile to allow for free movement of at least 1 inch (25mm) in all horizontal directions. Alternatively, a swing joint that can accommodate 1 inch (25 mm) of ceiling movement in all horizontal directions is permitted to be provided at the top of the sprinkler head extension. Sprinkler heads penetrating fire-resistance-rated floor/ceiling or roof/ceiling assemblies shall comply with Section 714 of this Code. 1613.8.4 Special requirements for means of egress. Suspended ceiling assemblies located along means of egress serving an occupant load of 30 or more and at lobbies accessory to Group A Occupancies shall comply with the following provisions.
1613.8.4.1 General. Ceiling suspension systems shall be connected and braced with vertical hangers attached directly to the structural deck along the means of egress serving an occupant load of 30 or more and at lobbies accessory to Group A Occupancies. Spacing of vertical hangers shall not exceed 2 feet (610 mm) on center along the entire length of the suspended ceiling assembly located along the means of egress or at the lobby.

1613.8.4.2 Assembly device. All lay-in panels shall be secured to the suspension ceiling assembly with two hold-down clips minimum for each tile within a 4-foot (1219 mm) radius of the exit lights and exit signs.
1613.8.4.3 Emergency systems. Independent supports and braces shall be provided for light fixtures required for exit illumination. Power supply for exit illumination shall comply with the requirements of Section 1008.3 of this Code. 1613.8.4.4 Supports for appendage. Separate support from the structural deck shall be provided for all appendages such as light fixtures, air diffusers, exit signs, and similar elements.

16.04.430 Reserved

16.04.440 Section 1705.3 Concrete construction.

Section 1705.3 of Chapter 17 of the California Building Code is amended to read:

1705.3 Concrete construction. The special inspections and tests of concrete construction shall be as required by this section and Table 1705.3.

Exceptions: Special inspections and tests shall not be required for:

1. Isolated spread concrete footings of buildings three stories or less Item 15
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above grade plane that are fully supported on earth or rock, where the structural design of the footing is based on a specified compressive strength, f’c, no greater than 2,500 pound per square inch (psi) (17.2 MPa).

2. Continuous concrete footings supporting walls of buildings three stories or less above grade plane that are fully supported on earth or rock where:

2.1. The footings support walls of light-frame construction;

2.2. The footings are designed in accordance with Table 1809.7; or

2.3. The structural design of the footing is based on a specified compressive strength, f ′c, no greater than 2,500 pounds per square inch (psi) (17.2 MPa), regardless of the compressive strength specified in the construction documents or used in the footing construction.

3. Nonstructural concrete slabs supported directly on the ground, including pre- stressed slabs on grade, where the effective pre-stress in the concrete is less than 150 psi (1.03 MPa).

4. Concrete foundation walls constructed in accordance with Table 1807.1.6.2.

5. Concrete patios, driveways and sidewalks, on grade.

16.04.450 Section 1803.2 Investigations required.

Section 1803.2 of Chapter 18 of the California Building Code is amended to read:
1803.2 Investigations required. Geotechnical investigations shall be conducted in accordance with Sections 1803.3 through 1803.5
Exceptions:

1. The building official or designee shall be permitted to waive the requirement for a geotechnical investigation where satisfactory data from adjacent areas is available that demonstrates an investigation is not necessary for any of the conditions in Sections 1803.5.1 through 1803.5.6 and Sections 1803.5.10 and 1803.5.11.

2. Light-frame construction building utilizing the prescriptive continuous footings per Table 1809.7 amended in section 16.04.470. For addition, the engineer of record shall certify in writing that the existing foundation system matches the proposed foundation system.

3. Accessories and minor additions may be exempted by the Building Official or designee.

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16.04.460 Section 1803.5.11 Seismic design categories C through F.

Section 1803.5.11 of Chapter 18 of the California Building Code is amended to read:

Section 1803.5.11 Seismic design categories C through F. For structures assigned to Seismic Design Category C, D, E or F, a geotechnical investigation shall be conducted, and shall include an evaluation of all of the following potential geologic and seismic hazards:

1. Slope instability.

2. Liquefaction.

3. Total and differential settlement.

4. Surface displacement due to faulting or seismically induced lateral spreading or lateral flow.

Exception: Refer to section 1803.2 exception.

16.04.470 Section 1809.7 Prescriptive footings for light-frame construction.

Section 1809.7 of Chapter 18 of the California Building Code is amended to read:

1809.7 Prescriptive footings for light-frame construction. Where a specific design is not provided, concrete or masonry-unit footings supporting walls of light-frame construction shall be permitted to be designed in accordance with Table 1809.7. TABLE 1809.7 Prescriptive Footings Supporting Walls of Light-Frame Constructionabcd

Number of Floors
Supported by the
Footing e
Thickness of
Foundation Wall
(inches)
Width of Footing
(inches)
Thickness of
Footing
(inches)
Depth of
Foundation Below
Natural Surface of
Ground or Finish
Grade (inches)
1 & 2 8 15 8 20
3 8 18 8 30
Group U Occupancies 8 12 8 12
ADU Conversionsf 8 12 8 12

a. Ground under the floor shall be permitted to be excavated to elevation of footing. b. Interior stud-bearing walls shall be permitted to be supported by isolated footings.

Footing width and length shall be twice the width shown in this table, and footings shall be spaced not more than 6 feet on center.
c. See Section 1905 for additional requirements for concrete footings of Item 15
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structures assigned to Seismic Design Category C, D, E or F. d. All foundations as required in the above Table shall be continuous and have a minimum of three #4 bars of reinforcing steel, except for one story, detached accessory buildings of Group U occupancy where two bars are required. e. Footings shall be permitted to support a roof in addition to the stipulated number of floors. Footings supporting roof only shall be as required for supporting one floor. f. If existing detached accessory building is being converted to an Accessory Dwelling Unit (ADU) and the existing foundation is being utilized, then a designer, architect or engineer shall provide a letter that the existing foundation complies with the conditions above and is deemed structurally sound.

16.04.480 Section 1809.8 Plain concrete footings.

Section 1809.8 of Chapter 18 of the California Building Code is deleted.

16.04.490 Section 1901.2 Plain and reinforced concrete.

Section 1901.2 of Chapter 19 of the California Building Code is amended to read:

1901.2 Plain and reinforced concrete. Structural concrete shall be designed and constructed in accordance with the requirements of this chapter and ACI 318 as amended in section 1905 of this code and PAMC 16.14.240. Except for the provisions of Sections 1904 and 1907, the design and construction of slabs on grade shall not be governed by this chapter unless they transmit vertical loads or lateral forces from other parts of the structure to the soil.

16.04.500 Section 1905.6.2 Seismic Design Categories C, D, E and F.

Section 1905.6.2 of Chapter 19 of the California Building Code is amended to read:
1905.6.2 Seismic Design Categories C, D, E and F.

Structures assigned to Seismic Design Category C, D, E or F shall not have elements of structural plain concrete, except as follows:

1. Left intentionally blank.

2. Isolated footings of plain concrete supporting pedestals or columns are permitted, provided the projection of the footing beyond the face of the supported member does not exceed the footing thickness.

3. Plain concrete footings supporting walls are permitted, provided the footings have at least three continuous longitudinal reinforcing bars not smaller than No. 4, with a total area of not less than 0.002 times the gross cross-sectional area of the footing except for one story, detached accessory buildings of Group U occupancy where Item 15
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two bars are required. A minimum of one bar shall be provided at the top and bottom of the footing. Continuity of reinforcement shall be provided at corners and intersections.

16.04.510 SECTION 1906 FOOTINGS FOR LIGHT-FRAME CONSTRUCTION Section 1906 of Chapter 19 of the California Building Code is deleted.

16.04.520 Section 1906.1 Plain concrete footings.

Section 1906.1 of Chapter 19 of the California Building Code is deleted.

16.04.530 Section 1907.1 Structural slabs-on-ground.

Section 1907.1 of Chapter 19 of the California Building Code is amended to read:
1907.1 Structural slabs-on-ground. Structural concrete slabs-on-ground shall comply with all applicable provisions of this chapter. Slabs-on-ground shall be considered structural concrete where required by ACI 318 or where designed to transmit either of the following:

1. Vertical loads or lateral forces from other parts of the structure to the soil.

2. Vertical loads or lateral forces from other parts of the structure to foundations.

3. Structural slabs-on-ground shall have 6x6-10/10 wire mesh or equal at mid- height.

16.04.535 Section 1907.2 Nonstructural slabs-on-ground.

Section 1907.2 of Chapter 19 of the California Building Code is amended to read:
1907.2 Nonstructural slabs-on-ground. Nonstructural slabs-on-ground shall be required to comply with Sections 1904.2, 1907.3 and 1907.4. Portions of the nonstructural slabs-on-ground used to resist uplift forces or overturning shall be designed in accordance with accepted engineering practice throughout the entire portion designated as dead load to resist uplift forces or overturning.

Nonstructural slabs-on-ground shall have 6x6-10/10 wire mesh or equal at mid- height.

16.04.540 Reserved

16.04.550 Reserved
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16.04.560 Section 2308.10.4 Braced wall panel construction.

Section 2308.10.4 of Chapter 23 of the California Building Code is amended to read:

2308.10.4 Braced wall panel construction. For Methods DWB, WSP, SFB, PBS, PCP and HPS, each panel must be not less than 48 inches (1219 mm) in length, covering three stud spaces where studs are spaced 16 inches (406 mm) on center and covering two stud spaces where studs are spaces 24 inches (610 mm) on center. Braced wall panels less than 48 inches (1219 mm) in length shall not contribute toward the amount of required bracing. Braced wall panels that are longer than the required length shall be credited for their actual length.

Vertical joints of panel sheathing shall occur over studs and adjacent panel joints shall be nailed to common framing members. Horizontal joints shall occur over blocking or other framing equal in size to the studs except where waived by the installation requirements for the specific sheathing materials. Sole plates shall be nailed to the floor framing in accordance with Section 2308.10.7 and top plates shall be connected to the framing above in accordance with Section 2308.10.7.2.

Where joists are perpendicular to braced wall lines above, blocking shall be provided under and in line with the braced wall panels.

16.04.570 Section 2308.10.5 Alternative bracing.

Section 2308.10.5 of Chapter 23 of the California Building Code is amended to read:
2308.10.5 Alternative bracing. An alternate braced wall (ABW) or a portal frame with hold-downs (PFH) described in this section is permitted to substitute for a 48-inch (1219 mm) braced wall panel of Method DWB, WSP, SFB, PCP or HPS.

16.04.580 TABLE 2308.10.1 WALL BRACING REQUIREMENTS.

Footnote “b” of TABLE 2308.10.1 of Chapter 23 of the California Building Code is amended to read:
b. See section 2308.10.3 for full description of bracing methods. Method GB is prohibited in Seismic Design Categories D & E.

16.04.590 TABLE 2308.10.3(1) BRACING METHODS.

TABLE 2308.10.3(1) Bracing Methods of Chapter 23 of the California Building Code is amended by adding footnote “b” and footnote “b” superscript to METHODS, MATERIAL column title as follows:

TABLE 2308.10.3(1) BRACING METHODS

METHODS,
MATERIAL b

MINIMUM

THICKNESS FIGURE
a

CONNECTION CRITERIA
Fasteners Spacing
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b. Method GB is prohibited in Seismic Design Categories D & E.

16.04.600 Section 2308.10.9 Attachment of sheathing.

Section 2308.10.9 of Chapter 23 of the California Building Code is amended to read:
2308.10.9 Attachment of sheathing. Fastening of braced wall panel sheathing shall not be less than that prescribed in Table 2308.10.1 or 2304.10.2. Wall sheathing shall not be attached to framing members by adhesives. Staple fasteners in Table 2304.10.2 shall not be used to resist or transfer seismic forces in structures assigned to Seismic Design Category D, E, or F unless the allowable shear values are substantiated by cyclic testing and approved by the Building Official or designee.

All braced wall panels shall extend to the roof sheathing and shall be attached to parallel roof rafters or blocking above with framing clips (18 gauge minimum) spaced at maximum 24 inches on center with four 8d nails per leg (total eight- 8d nails per clip). Braced wall panels shall be laterally braced at each top corner and at maximum 24-inch intervals along the top plate of discontinuous vertical framing.

16.04.610 SECTION 2505 SHEAR WALL CONSTRUCTION.

Section 2505 Chapter 25 of the California Building Code is deleted in its entirety including its subsections.

16.04.620 Reserved

16.04.630 Chapter 31B Public Pools.

Chapter 31B of the California Building Code has been adopted in its entirety.

16.04.640 Section 3304.1 Excavation and fill.

Section 3304.1 of Chapter 33 of the California Building Code is amended to read:

3304.1 Excavation and fill. Excavation and fill for buildings and structures shall be constructed or protected so as not to endanger life or property. Stumps and roots shall be removed from the soil to a depth of not less than 12 inches (305mm) below the surface of the ground in the area to be occupied by the building. Wood forms that have been used in placing concrete, if within the ground or between foundation sills and the ground, shall be removed before a building is occupied or used for any purpose. Wooden stakes shall not be embedded in concrete. Before completion, loose or casual wood shall be removed from direct contact with the ground under the building.

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SECTION 2. Chapter 16.19, California Historical Building Code and Existing Building Code, of Title 16 (Building Regulations) of the Palo Alto Municipal Code is repealed in its entirety and readopted to read as follows:

CHAPTER 16.19

CALIFORNIA HISTORICAL BUILDING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 8
and

CALIFORNIA EXISTING BUILDING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 10

Sections

16.19.010 2025 California Historical Building Code, Title 24, Part 8 adopted.

16.19.020 2025 California Existing Building Code, Title 24, Part 10 adopted and amended.

16.19.030 Cross - References to California Existing Building Code.

16.19.040 Local Amendments.

16.19.050 101.2.1 Appendices.

16.19.060 Administration & Enforcement of 2025 California Existing Building Code

16.19.070 Adoption of 2025 California Existing Building Code Chapter 1, Division II – Scope and Administration

16.19.080 Section 101.1 Title.

16.19.090 Section 324 Dwelling unit and congregate residence superficial floor area.

16.19.100 Section 503.21 Suspended ceiling systems.

16.19.110 Section 503.22 Mechanical and electrical equipment in seismic design categories D, E or F.

16.19.120 Section 405.2.3.1 Seismic evaluation and design procedures for repairs.

16.19.010

2025 California Historical Building Code, Title 24, Part 8 adopted.

The California Historical Building Code, 2025 Edition, Title 24, Part 8 (authorized by Health and Safety Code Sections 18950 through 18961), which provides alternative building regulations for the rehabilitation, preservation, restoration, or relocation of designated historic buildings, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

One copy of the California Historical Building Code, 2025 Edition, has been filed for use and examination of the public in the Office of the Chief Building Official of the City of Palo Alto.

16.19.020 2025 California Existing Building Code, Title 24, Part 10 adopted and amended.

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The California Existing Building Code, 2025 Edition, Title 24, Part 10 of the California Code of Regulations, which provides alternative building regulations for the rehabilitation, preservation restoration or relocation of existing buildings, together with those omissions, amendments, exceptions, and additions thereto, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

One copy of the California Existing Building Code, 2025 Edition, has been filed for use and examination of the public in the Office of the Chief Building Official of the City of Palo Alto.

16.19.030 Cross - References to California Existing Building Code.

The provisions of this Chapter contain cross-references to the provisions of the California Existing Building Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.

16.19.040 Local Amendments.

The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of the California Existing Building Code, 2025 Edition, and shall be deemed to replace the cross- referenced sections of said Code with the respective provisions set forth in this Chapter.

16.19.050 101.2.1 Appendices.

Section 101.2.1 of Chapter 1 of the California Existing Building Code is amended to read:

2025 California Existing Building Code and International Existing Building Code Appendix Chapters Adopted.

The following Appendix Chapters of the California Existing Building Code (CEBC), 2025 Edition, and International Existing Building Code (IEBC), 2024 Edition, are adopted and hereby incorporated in this Chapter be reference and made a part hereof the same as if fully set forth herein:

A . CEBC Appendix A1 – Seismic Strengthening Provisions for Unreinforced Masonry Bearing Wall Buildings
B . CEBC Appendix Chapter A2 – Earthquake Hazard Reduction in Existing Reinforced Concrete and Reinforced Masonry Wall Buildings with Flexible Diaphragms
C . CEBC Appendix A3 – Prescriptive Provisions for Seismic Strengthening of Cripple Walls and Sill Plate Anchorage of Light, Wood-Frame Residential Buildings
D. CEBC Appendix A4 – Earthquake Risk Reduction in Wood-Frame Residential Buildings with Soft, Weak or Open Front Walls Item 15
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E . CEBC Appendix A5 – Referenced Standards

16.19.060 Administration & Enforcement of 2025 California Existing Building Code Administration and enforcement of this code shall be governed by Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04.

16.19.070 Adoption of 2025 California Existing Building Code Chapter 1, Division II – Scope and Administration
Chapter 1, Division II, Parts 1 and 2 of the 2025 California Existing Building Code is adopted by the City of Palo Alto to supplement, to the extent it does not conflict with, Chapter 1, Division II of the 2025 California Building Code, as amended.

16.19.080 Section 101.1 Title.

Section 101.1 of Chapter 1 of the California Existing Building Code is amended to read:
101.1 Title. These regulations shall be known as the Existing Building Code of City of Palo Alto, hereinafter referred to as “this code.”

16.19.090 Section 324 Dwelling unit and congregate residence superficial floor area.

Section 324 of Chapter 3 of the California Existing Building Code is added to read:
324 Dwelling unit and congregate residence superficial floor area. Every dwelling unit and congregate residence shall have at least one room which shall have not less than 120 square feet of superficial floor area. Every room which is used for both cooking and living or both living and sleeping purposes shall have not less than 144 square feet of superficial floor area. Every room used for sleeping purposes shall have not less than 70 square feet of superficial floor area.

When more than two persons occupy a room used for sleeping purposes the required superficial floor area shall be increased at the rate of 50 square feet for each occupant in excess of two. Guest rooms with cooking shall contain the combined required superficial areas of a
sleeping and a kitchen, but not less than 144 square feet. Other habitable rooms shall be not less than 70 square feet.

Notwithstanding any provision of this Section, children under the age of six shall not be counted for purposes of determining whether a family with minor children complies with the provisions of this Code.

For the purposes of this section, "superficial floor area" means the net floor area within the enclosing walls of the room in which the ceiling height is not less than seven feet six inches, excluding built-in equipment such as wardrobes, cabinets, Item 15
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kitchen units, or fixtures which are not readily removable.

16.19.100 Section 503.21 Suspended ceiling systems.

Section 503.21 of Chapter 5 the California Existing Building Code is added to read:
503.21 Suspended ceiling systems. In existing buildings or structures, when a permit is issued for alterations or repairs, the existing suspended ceiling system within the area of the alterations or repairs shall comply with ASCE 7-22 Section

13.5.6. 16.19.110 Section 503.22 Mechanical and electrical equipment in seismic design categories D, E or F.

Section 503.22 of Chapter 5 of the California Existing Building Code is added to read:

503.22 Mechanical and electrical equipment in seismic design categories D, E or F. In existing buildings or structures, when a permit is issued for alteration or repairs, the existing mechanical and electrical equipment on the area of the roof shall comply with ASCE 7-22 Section 13.4 Nonstructural Component Anchorage.

16.19.120 Section 405.2.3.1 Seismic evaluation and design procedures for repairs.

Section 405.2.3.1 of Chapter 5 of the California Existing Building Code is amended to read:

405.2.3.1 Evaluation and design procedures. The building shall be evaluated by a registered design professional, and the evaluation findings shall be submitted to the code official. The evaluation shall establish whether the damaged building, if repaired to its pre-damage state, would comply with the provisions of the California Building Code for load combinations that include wind or earthquake effects, except that the seismic forces shall be reduced seismic forces. Evaluation for earthquake loads shall be required if the substantial structural damage was caused by or related to earthquake effects or if the building is in Seismic Design Category C, D, E or F. The seismic evaluation and design shall be based on the procedures specified in the building code, ASCE 41 Seismic Evaluation and Upgrade of Existing Buildings. The procedures contained in Appendix A of the International Existing Building Code (IEBC) shall be permitted to be used as specified in Section 405.2.3.1. Wind loads for this evaluation shall be those prescribed in Section 1609.

405.2.3.1.1 CEBC level seismic forces. When seismic forces are required to meet the building code level, they shall be one of the following:

1. One hundred percent of the values in the building code. The R factor used for analysis in accordance with Chapter 16 of the building code shall be the R factor specified for structural systems classified as Item 15
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"Ordinary" unless it can be demonstrated that the structural system satisfies the proportioning and detailing requirements for systems classified as "intermediate" or "special".

2. Forces corresponding to BSE-1 and BSE-2 Earthquake Hazard Levels defined in ASCE 41. Where ASCE 41 is used, the corresponding performance levels shall be those shown in Table 405.2.3.1.

3. Forces corresponding to BSE-1 and BSE-2 Earthquake Hazard Levels defined in ASCE 41. Where ASCE 41 is used, the corresponding performance levels shall be those shown in Table 405.2.3.1.

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TABLE 405.2.3.1
ASCE 41 PERFORMANCE LEVELS

RISK CATEGORY (BASED
ON CBC TABLE 1604.5)

PERFORMANCE LEVEL FOR USE WITH
ASCE 41 BSE-1 EARTHQUAKE HAZARD
LEVEL

PERFORMANCE LEVEL FOR USE
WITH ASCE 41 BSE-2
EARTHQUAKE HAZARD LEVEL *
I Life Safety (LS) Collapse Prevention (CP)
II Life Safety (LS) Collapse Prevention (CP)
III Damage Control Limited Safety
IV Immediate Occupancy (IO) Life Safety (LS)
* Only applicable when Tier 3 procedure is used.

405.2.3.1.2 Reduced CEBC level seismic forces. When seismic forces are permitted to meet reduced building code levels, they shall be one of the following:

1. Seventy-five percent of the forces prescribed in the building code. The R factor used for analysis in accordance with Chapter 16 of the building code shall be the R factor as specified in Section 405.2.3.1.1.

2. In accordance with the California Existing Building Code and applicable chapters in Appendix A of the International Existing Building Code, as specified in Items (a.) through (e.) below. Structures or portions of structures that comply with the requirements of the applicable chapter in Appendix A shall be deemed to comply with the requirements for reduced building code force levels.
a. The seismic evaluation and design of unreinforced masonry bearing wall buildings in Risk Category I or II are permitted to be based on the procedures specified in CEBC Appendix ChapterA1. b. Seismic evaluation and design of the wall anchorage system in reinforced concrete and reinforced masonry wall buildings with flexible diaphragms in Risk Category I or II are permitted to be based on the procedures specified in IEBC Appendix Chapter A2. c. Seismic evaluation and design of cripple walls and sill plate anchorage in residential buildings of light-frame wood
construction in Risk Category I or II are permitted to be based on the procedures specified in CEBC Appendix Chapter A3
d. Seismic evaluation and design of soft, weak, or open-front wall conditions in multi-unit residential buildings of wood construction in Risk Category I or II are permitted to be based on the procedures specified in CEBC Appendix Chapter A4.

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e. Seismic evaluation and design of concrete buildings and concrete with masonry infill buildings in all risk categories are permitted to be based on the procedures specified in IEBC Appendix Chapter A5.

Those associated with the BSE-1 Earthquake Hazard Level defined in ASCE 41 and the performance level as shown in Table 405.2.3.1. Where ASCE 41 is used, the design spectral response acceleration parameters SXS and SX1 shall not be taken less than seventy-five percent of the respective design spectral response acceleration parameters SDS and SD1 defined by the California Building Code and its reference standards.

SECTION 3. The Council adopts the findings for local amendments to the California Building Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.

SECTION 4. The Council adopts the findings for local amendments to the California Existing Building Code, 2025 Edition, attached hereto as Exhibit “B” and incorporated herein by reference.

SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it would have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

SECTION 4. The Council finds that to the extent they affect residential units, the changes or modifications to the California Building Code (Title 24, Part 2) and the California Existing Building Code (Title 24, Part 10) adopted by this ordinance are substantially equivalent to changes or modifications that were previously filed by the governing body of the City and were in effect as of September 30, 2025, and are therefore exempt from the moratorium on new residential building standards imposed by Assembly Bill 130 (2025).

SECTION 5. The Council finds that this ordinance is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the amendments herein adopted will have a significant effect on the environment. //

//

//

//

//
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SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

____________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

____________________________ ____________________________ City Attorney or Designee City Manager

____________________________
Director of Planning and
Development Services

____________________________
Director of Administrative Services

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Exhibit A

FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA BUILDING CODE, TITLE 24, PART 2, VOLUMES 1 AND 2

Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Building Code, Title 24, Part 2, Volumes 1 and 2 Chapter(s),
Section(s),
Table(s),
Appendices
Title Added Amended Deleted Justification
(See below
for keys)
Ch. 1, Div. II SCOPE OF ADMINISTRATION  A
Part 1 Scope of Application   A
Part 2 Administration and Enforcement   A
101.1 Title  A
101.2.1 Appendices  A
101.4 Referenced codes  A
101.4.9 Historical Buildings  A
101.4.10 Electrical  A
101.4.11 Residential Buildings  A
101.4.12 Green Building Standards  A
101.4.13 International Swimming and Spa Code  A
103.1 Creation of enforcement agency  A
103.2 Appointment  A
103.3 Deputies  A
104.2.4.1 Flood hazard area  C, G, T
104.3.1 Determination of substantially improved
or substantially damaged existing buildings
and structures in flood hazard zones
 C, G, T
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105.2 Work exempt from permit  A, G, T
105.3.2 Time limitation of applications  A
105.5 Expiration  A
105.5.1 Term limits for permits  A
106.1 Live load posted  G , T
109.6 Refunds  A
109.7 Re-Inspection fees   A
110.2.1 Preliminary accessibility compliance
inspection
 A
110.3.3 Lowest floor elevation   A
111.1 Use and occupancy  A
111.1.1 Change of occupancy or tenancy   A
111.3 Temporary occupancy   A
111.5 Posting   A
113 Means of Appeals   A
114.1 Unlawful acts  A
114.5 Criminal enforcement authority  A
115.1 Authority  A
115.2 Issuance  A
115.3 Unlawful continuance  A
115.4 Removal of posted stop work order  A
115.5 Response required   A
115.6 Permit application required  A
115.7 Stop work order penalty  A
202 Definitions   A
502.1 Address identification  T
502.1.1 Address illumination   T
502.1.2 Address identification size  T
903.2 Automatic sprinkler system, where
required
   G, T
903.3.1.1 NFPA 13 sprinkler systems  G, T
903.3.1.2 NFPA 13R sprinkler systems  G, T
903.3.1.3 NFPA 13D sprinkler systems  G, T
903.3.1.3.1 Increase in fire sprinkler design criteria   G, T Item 15
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903.4.4 Floor control valves   G, T
905.3.1 Height   G, T
907.2.11.2.4 Smoke Alarms -  
G, T
909.20.7 Smoke control systems   G, T
915.6 Maintenance  
T
1008.3 Illumination required by an emergency
electrical system
  G, T
1031.2 Where required   G, T
1205.3.4 Roof guards at courts   G
1208.6 Dwelling unit and congregate residence
superficial floor area
  A, G
1503.2.1 Locations   C
1612.1.1 Palo Alto Flood Hazard Regulations   C, T
1613.8 Suspended ceilings   G
1613.8.1 Scope   G
1613.8.2 General   G
1613.8.3 Sprinkler heads   G
1613.8.4 Special requirements for means of egress   G 1613.8.4.1 General   G
1613.8.4.2 Assembly device   G
1613.8.4.3 Emergency systems   G
1613.8.4.4 Supports for appendage   G
1705.3 Concrete construction   G
1803.2 Investigations required   G
1803.5.11 Seismic design categories C through F   G, T 1809.7 Prescriptive footings for light-frame
construction
  G, T
Tbl. 1809.7 Prescriptive footings for light-frame
construction
  G, T
1809.8 Plain concrete footings    G, T
1901.2 Plain and reinforced concrete    G, T
1905.6.2 Seismic Design Categories C, D, E and F    G, T 1906 FOOTINGS FOR LIGHT-FRAME

CONSTRUCTION
   G, T
1906.1 Plain concrete footings    G, T
1907.1 Structural slab-on-ground    G, T
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1907.2 Nonstructural slabs-on-ground    G, T
2308.10.4 Braced wall panel construction    G, T
2308.10.5 Alternative bracing    G, T
Tbl.
2308.10.1
Wall Bracing Requirements.

Footnote “b”
   G, T
Tbl.
2308.10.3(1
)
Bracing Methods
Footnote “b”
   G, T
2308.10.9 Attachment of sheathing    G, T
2505 SHEAR WALL CONSTRUCTION    G, T
Ch. 31B Public Pools    G, T
3304.1 Excavation and fill    G, T
Appx. I Patio Covers    A, G
Appx. J Grading (Section J109.4 Drainage across
property lines)
   G, T
Appx. P Emergency Housing    A, C, G, T
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Exhibit B

FINDINGS FOR LOCAL AMENDMENTS TO CALIORNIA EXISTING BUILDING CODE, Title 24, Part 10

Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Existing Building Code, Title, 24, Part 10 Chapter(s),
Section(s),
Table(s),
Appendices
Title Added Amended Replaced Justification
(See below
for keys)
101.2.1 Appendices  A, G, T
Ch. 1, Div. II Scope and Administration  A
101.1 Title  A
324 Dwelling unit and congregate
residence superficial floor
area.
 A, G
503.21 Suspended ceiling system  G
503.22 Mechanical and
electrical equipment in
seismic design
categories D, E or F
 G
405.2.3.1 405.2.3.1 Seismic evaluation
and
design procedures for repairs
 G
405.2.3.1.1 CEBC level seismic forces  G
Tbl.
405.2.3.1
ASCE 41 PERFORMANCE LEVELS  G
405.2.3.1.2 Reduced CEBC level seismic
forces
 G
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Appx. A1 Seismic Strengthening
Provisions
for Unreinforced Masonry
Bearing Wall
Buildings
 G, T
Appx. A2 Earthquake Hazard Reduction
in Existing Reinforced Concrete
and Reinforced Masonry Wall
Buildings with Flexible
Diaphragms
 G, T
Appx. A3 Prescriptive Provisions for
Seismic Strengthening of
Cripple Walls and Sill Plate
Anchorage of Light, Wood-
Frame Residential Buildings
 G, T
Appx. A4 Earthquake Risk Reduction in
Wood- Frame Residential
Buildings with Soft, Weak or
Open Front Walls
 G, T
Appx. A5 Referenced Standards  G, T
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Key to Justification for Amendments to Title 24 of the California Code of Regulations A This is an administrative amendment to clarify and establish civil and administrative procedures, regulations, or rules to enforce and administer the activities by the Palo Alto Building Inspection Department. These administrative amendments do not need to meet HSC 18941.5/17958/13869 per HSC 18909(c).

C This amendment is justified based on a local climatic condition. The seasonal climatic conditions during the late summer and fall create severe fire hazards to the public health and welfare in the City. The hot, dry weather frequently results in wild land fires on the brush covered slopes west of Interstate 280. The aforementioned conditions combined with the geological characteristics of the hills within the City create hazardous conditions for which departure from California Building Standards Code is required. Natural gas combustion and gas appliances emit a wide range of air pollutants, such as carbon monoxide (CO), nitrogen oxides (NOx, including nitrogen dioxide (NO2)), particulate matter (PM), and formaldehyde, which according to a UCLA Study, have been linked to various acute and chronic health effects, and additionally exceed levels set by national and California-based ambient air quality standards.

The burning of fossil fuels used in the generation of electric power and heating of buildings contributes to climate change, which could result in rises in sea level, including in San Francisco Bay, that could put at risk Palo Alto homes and businesses, public facilities, and Highway 101 (Bayshore Freeway), particularly the mapped Flood Hazard areas of the City. Energy efficiency is a key component in reducing GHG emissions, and construction of more energy efficient buildings can help Palo Alto reduce its share of the GHG emissions that contribute to climate change. All-electric new buildings benefit the health, safety, and welfare, of Palo Alto and its residents. Requiring all-electric construction, without gas infrastructure will reduce the amount of greenhouse gas produced in Palo Alto and will contribute to reducing the impact of climate change and the associated risks. Due to decrease in annual rain fall, Palo Alto experiences the effect of drought and water saving more than some other communities in California. Embodied carbon of concrete is a significant contributor to greenhouse gas emissions and climate change, and this amendment includes a requirement to use low-carbon concrete.

G This amendment is justified based on a local geological condition. The City of Palo Alto is subject to earthquake hazard caused by its proximity to San Andreas fault. This fault runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel Rock. This is the approximate location of the epicenter of the 1906 San Francisco earthquake. The other fault is Hayward Fault. This fault is about 74 mi long, situated mainly along the western base of the hills on the east side of San Francisco Bay. Both faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area which includes these earthquake faults, the modifications and changes cited herein are designed to better limit property damage as a result of seismic activity and to establish criteria for repair of damaged properties following a local emergency.

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16.04, California Building
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Code

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T The City of Palo Alto topography includes hillsides with narrow and winding access, which makes timely response by fire suppression and emergency response vehicles difficult. Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater run-off. Also, the City of Palo Alto is located in an area that is potentially susceptible to liquefaction during a major earthquake. The surface condition consists mostly of stiff to dense sandy clay, which is highly plastic and expansive in nature. The aforementioned conditions within the City create hazardous conditions for which departure from California Building Standards Code is warranted.

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California Historical Building
Code

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Ordinance No.

Ordinance of the Council of the City of Palo Alto Repealing Chapter

16.05 of the Palo Alto Municipal Code and Amending Title 16 to Adopt a New Chapter 16.05, California Mechanical Code, 2025 Edition, and Local Amendments and Related Findings

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Chapter 16.05 of the Palo Alto Municipal Code is hereby amended by repealing in its entirety 16.05 and adopting a new Chapter 16.05 to read as follows:

CHAPTER 16.05

CALIFORNIA MECHANICAL CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 4
Sections

16.05.010 2025 California Mechanical Code, Title 24, Part 4 adopted and amended.

16.05.020 Cross - References to California Mechanical Code.

16.05.030 Local Amendments.

16.05.040 Administration & Enforcement of 2025 California Mechanical Code.

16.05.045 Adoption of Chapter 1, Division II Administration.

16.05.050 Section 102.8 Appendices.

16.05.060 Section 104.2 Exempt from this code.

16.05.070 Section 510.7 Interior installations.

16.05.010 2025 California Mechanical Code, Title 24, Part 4 adopted and amended.

The California Mechanical Code, 2025 Edition, Title 24, Part 4 of the California Code of Regulations together with those omissions, amendments, exceptions and additions thereto, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and regulations to the chapters and sections of the former editions of the California Code of Regulations, Title 24 shall be construed to apply to the corresponding provisions contained within the California Code of Regulations, Title 24, 2025. Ordinance No. 5565 of the City of Palo Alto and all other ordinances or parts of ordinances in conflict herewith are hereby suspended and expressly repealed.

Wherever the phrases "California Mechanical Code" or "Mechanical Code" are used in this code or any ordinance of the City, such phrases shall be deemed and construed to refer and apply to the California Mechanical Code, 2025 Edition, Title 24, Part 4 of the California Code of Regulations, as adopted by this Chapter.

One copy of the California Mechanical Code, 2025 edition, has been filed for use and examination of the public in the Office of the Building Official of the City of Palo Alto.

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16.05.020 Cross - References to California Mechanical Code.

The provisions of this Chapter contain cross-references to the provisions of the California Mechanical Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.

16.05.030 Local Amendments.

The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of the California Mechanical Code, 2025 Edition, and shall be deemed to replace the cross- referenced sections of said Code with the respective provisions set forth in this Chapter.

16.05.040 Administration & Enforcement of 2025 California Mechanical Code.

Administration and enforcement of this code shall be governed by Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04.

16.05.045 Adoption of Chapter 1, Division II Administration.

Chapter 1, Division II Administration of the 2025 California Mechanical Code is adopted by the City of Palo Alto to supplement, to the extent it does not conflict with, Chapter 1, Division II of the 2025 California Building Code, as amended.

16.05.050 Section 102.8 Appendices.

The following Appendix Chapters of the California Mechanical Code, 2025 Edition, are adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein:

A. Appendix B – Procedures to be followed to place gas equipment in operation B. Appendix C – Installation and testing of oil (liquid) fuel-fired equipment

16.05.060 Section 104.2 Exempt from this code.

Subdivision (6) of Section 104.2 of Chapter 1 of the California Mechanical Code is added to read:
(6) ADDITIONAL EXCEPTIONS: Reference Mechanical Section under PAMC 16.04.110 Section 105.2 Work exempt from permit.

16.05.070 Section 510.7 Interior installations.

Section 510.7 of Chapter 5 of the California Mechanical Code is amended to read:

Section 510.7 Interior installations. In all buildings, the ducts shall be enclosed in a continuous enclosure extending from the lowest fire-rated ceiling or floor above the hood, through any concealed spaces, to or through the roof so as to maintain the Item 15
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integrity of the fire separations required by the applicable building code provisions. The enclosure shall be sealed around the duct at the point of penetration of the lowest fire-rated ceiling or floor above the hood in order to maintain the fire resistance rating of the enclosure and shall be vented to the exterior of the building through weather-protected openings. [NFPA 96:7.7.1.2 – 7.7.1.4] SECTION 2. The Council adopts the findings for local amendments to the California Mechanical Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.

SECTION 3. The Council finds that the changes or modifications to the California Mechanical Code adopted by this ordinance are substantially equivalent to changes or modifications that were previously filed by the governing body of the City and were in effect as of September 30, 2025, and are therefore exempt from the moratorium on new residential building standards imposed by Assembly Bill 130 (2025).

SECTION 4. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the amendments herein adopted will have a significant effect on the environment.

SECTION 5. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

//

//

//

//

//

//

//

//

//
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SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

City Attorney or Designee City Manager

Director of Planning and Development Services

Director of Administrative Services
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Exhibit A

FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA MECHANICAL CODE, TITLE 24, PART 4
Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Mechanical Code, Title, 24, Part 4
Chapter(s),
Sections(s),
Appendices
Title Added Amended Replaced Justification
(See below
for keys)
Ch. 1, Div. II ADMINSTRATION  A
102.8 Appendices  A
Administration and Enforcement  A
104.2 Exempt from this code  A
510.7 Interior installations  G
Appx. B Procedures to be followed to place gas
equipment in operation
 A
Appx. C Installation and testing of oil (liquid) fuel-
fired equipment
 A
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Key to Justification for Amendments to Title 24 of the California Code of Regulations A This is an administrative amendment to clarify and establish civil and administrative procedures, regulations, or rules to enforce and administer the activities by the Palo Alto Building Inspection Department. These administrative amendments do not need to meet HSC 18941.5/17958/13869 per HSC 18909(c).

C This amendment is justified based on a local climatic condition. The seasonal climatic conditions during the late summer and fall create severe fire hazards to the public health and welfare in the City. The hot, dry weather frequently results in wild land fires on the brush covered slopes west of Interstate 280. The aforementioned conditions combined with the geological characteristics of the hills within the City create hazardous conditions for which departure from California Building Standards Code is required.

G This amendment is justified based on a local geological condition. The City of Palo Alto is subject to earthquake hazard caused by its proximity to San Andreas fault. This fault runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel Rock. This is the approximate location of the epicenter of the 1906 San Francisco earthquake. The other fault is Hayward Fault. This fault is about 74 mi long, situated mainly along the western base of the hills on the east side of San Francisco Bay. Both faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area which includes these earthquake faults, the modifications and changes cited herein are designed to better limit property damage as a result of seismic activity and to establish criteria for repair of damaged properties following a local emergency.

T The City of Palo Alto topography includes hillsides with narrow and winding access, which makes timely response by fire suppression and emergency response vehicles difficult. Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater run-off. Also, the City of Palo Alto is located in an area that is potentially susceptible to liquefaction during a major earthquake. The surface condition consists mostly of stiff to dense sandy clay, which is highly plastic and expansive in nature. The aforementioned conditions within the City create hazardous conditions for which departure from California Building Standards Code is warranted.

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Ordinance No.

Ordinance of the Council of the City of Palo Alto Repealing Chapter 16.06 of the Palo Alto Municipal Code and Adopting a New Chapter 16.06, California Residential Code, 2025 Edition, and Local Amendments and Related Findings

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Chapter 16.06 of Palo Alto Municipal Code is hereby amended by repealing the Chapter in its entirety and adopting a new Chapter 16.06 to read as follows:

CHAPTER 16.06
2025 California Residential Code,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 2.5
Sections

16.06.010 2025 California Residential Code adopted and amended.

16.06.015 Local Amendments.

16.06.020 2025 California Residential Code Appendix Chapters adopted.

16.06.030 Cross - References to California Residential Code.

16.06.040 Administration of California Residential Code.

16.06.050 Section R202 Definitions.

16.06.060 Table 301.2 Climatic and Geographic Design Criteria.

16.06.070 Section R301.2.2.6 Irregular buildings.

16.06.075 Section R304.5 Dwelling unit and congregate residence superficial floor area.

16.06.080 Section R319.1 Emergency escape and rescue openings.

16.06.090 Section R319.4.2.3 Window well fall protection.

16.06.100 Section R319.4.5 Security bars.

16.06.110 Section R309.1.1 Design and installation.

16.06.120 Section R309.2 One- and two-family dwellings automatic fire sprinkler systems.

16.04.130 Section R309.2.1 Design and installation.

16.04.140 Section R309.2.2 NFPA 13D sprinkler systems increase in design requirements.

16.04.150 Section R309.3 Dwelling unit fire sprinkler systems.

16.06.160 Section R310.1 Smoke detection and notification.

16.06.170 Section R310.1.3 Smoke alarms or detector end of life replacement

16.06.180 Section R311.7.5. Carbon Monoxide alarms
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16.06.190 Section R308 Address Identification

16.06.200 Section R306.1 General (Palo Alto Flood Hazard Regulations).

16.06.210 Reserved

16.06.220 Section R401 GENERAL

16.06.225 Section R402.2.1 Materials for concrete

16.06.230 Section R403 FOUNDATION.

16.06.240 Section R404.1.3 Concrete foundation walls.

16.06.250 Section R504.3.1 Projections exposed to weather

16.06.260 Section R506.1 General

16.06.270 Section R602.10.4.5 Limits on methods GB and PCP

16.06.280 Table R602.10.3(3) Bracing requirements based on seismic design category

16.06.290 Section R608.5 Materials

16.06.300 Section R703.8.5.1 Locations.

16.06.310 Reserved

16.06.320 Section R1003.9.2.1 Repairs, replacements, and alterations

16.06.330 Section BO109 Preliminary Meeting

16.06.010

2025 California Residential Code adopted and amended.

The California Residential Code, 2025 Edition, Title 24, Part 2.5 of the California Code of Regulations, together with those omissions, amendments, exceptions and additions thereto, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and regulations to the chapters and sections of the former California Code of Regulations, Title 24, 2019, shall be construed to apply to the corresponding provisions contained within the California Code of Regulations, Title 24, 2025. Ordinance No. 5566 of the City of Palo Alto and all other ordinances or parts of ordinances in conflict herewith are hereby suspended and expressly repealed.

Wherever the phrases "California Residential Code" or "Residential Code" are used in this code or any ordinance of the city, such phrases shall be deemed and construed to refer and apply to the California Residential Code, 2025 Edition, Title 24, Part 2.5 of the California Code of Regulations, as adopted by this Chapter.

One copy of the California Residential Code, 2025 Edition, has been filed for use and examination of the public in the Office of the Building Official of the City of Palo Alto.

16.06.015 Local Amendments.

The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of the California Residential Code, 2025 Edition, and shall be deemed to replace the cross-referenced sections of said Code with the respective provisions set forth in this Chapter.

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Where used in this Chapter 16.06, ellipses shall indicate text of the California Residential Code, 2025 Edition, that has been adopted without amendment but is omitted for brevity.

16.06.020 2025 California Residential Code Appendix Chapters adopted.

The following Appendix Chapters of the California Residential Code, 2025 Edition, are adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein:

A. Appendix BF – Patio Covers
B. Appendix BO – Existing Building and Structures
C. Appendix BG – Sound Transmission
D. Appendix CI – Swimming Pool Safety Act

16.06.030 Cross - References to California Residential Code.

The provisions of this Chapter contain cross-references to the provisions of the California Residential Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.

16.06.040 Administration of California Residential Code Chapter 1, Division II of the 2025 California Residential Code is replaced in its entirety by Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04.

16.06.050 Section R202 Definitions.

Section R202 of the California Residential Code is amended to include the following definitions:

SUPERFICIAL FLOOR AREA. "Superficial floor area" is the net floor area within the enclosing walls of the room in which the ceiling height is not less than seven feet six inches, excluding built-in equipment such as wardrobes, cabinets, kitchen units, or fixtures which are not readily removable.

16.06.060 Table 301.2 Climatic and Geographic Design Criteria.

Table 301.2 of the California Residential Code is amended to read:

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TABLE R301.2

CLIMATIC AND GEOGRAPHIC DESIGN CRITERIA

GROUND WIND DESIGN SEISMIC SUBJECT TO DAMAGE FROM
SNOW LOAD Speed
(mph)
Topographic
effects
DESIGN

CATEGORY
Weathering Frost
line
depth
Termite
0 92 No D0 thru E Negligible 5” Very High

WINTER
DESIGN
TEMP.
(OF)

ICE BARRIER

UNDERLAYEMENT

REQUIRED
FLOOD

HAZARDS
AIR

FREEZING
INDEX
MEAN
ANNUAL
TEMP.
(OF)
40 No See
Footnotes
p thru r
0 55
p The City of Palo Alto entered National Flood Insurance Program in 1979. q The effective date of the current Flood Insurance Study and Flood Insurance Rate Map is May 18, 2009.
r The panel numbers and dates of all currently effective FIRMs and FBFMs:
06085CIND0A, 06085C0010H, 06085C0015H through 06085C0019H, 06085C0030H, 06085C0036H , 06085C0038H , 06085C0180H ,06085C0185H (May 18, 2009 for all)

16.06.070 Section R301.2.2.6 Irregular buildings.

Section R301.2.2.6 of the California Residential Code is amended as follows:

The seismic provisions of this code shall not be used for structures, or portions thereof, located in Seismic Design Categories C, D0, D1 and D2 and considered to be irregular in accordance with this section. A building or portion of a building shall be considered to be irregular where one or more of the conditions defined in Items 1 through 8 occur. Irregular structures, or irregular portions of structures, shall be designed in accordance with accepted engineering practice to the extent the irregular features affect the performance of the remaining structural system. Where the forces associated with the irregularity are resisted by a structural system designed in accordance with accepted engineering practice, the remainder of the building shall be permitted to be designed using the provisions of this code.

1. Shear wall or braced wall offsets out of plane. Conditions where exterior shear wall lines or braced wall panels are not in one plane vertically from the foundation to the uppermost story in which they are required.

2. Lateral Support of roofs and floors. Conditions where a section of floor or roof is not laterally supported by shear walls or braced wall lines on all edges.

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Exception: Portions of floors that do not support shear walls, braced wall panels above, or roofs shall be permitted to extend not more than 6 feet (1829 mm) beyond a shear wall or braced wall line.

3. Shear wall or braced wall offsets in plane. Conditions where the end of a braced wall panel occurs over an opening in the wall below.

4. Floor and roof opening. Conditions where an opening in a floor or roof exceeds the lesser of 12 feet (3658 mm) or 50 percent of the least floor or roof dimension.

5. Floor level offset. Conditions where portions of a floor level are vertically offset.

6. Perpendicular shear wall and wall bracing. Conditions where shear walls and braced wall lines do not occur in two perpendicular directions.

7. Wall bracing in stories containing masonry or concrete construction. Conditions where stories above grade plane are partially or completely braced by wood wall framing in accordance with Section R602 or cold-formed steel wall framing in accordance with Section R603 include masonry or concrete construction. Where this irregularity applies, the entire story shall be designed in accordance with accepted engineering practice.

Exceptions: Fireplaces, chimneys and masonry veneer in accordance with this code.

8. Hillside light-frame construction. Conditions in which all of the following apply:

8.1 The grade slope exceeds 1 unit vertical in 5 units horizontal where averaged across the full length of any side of the dwelling.

8.2 The tallest cripple wall clear height exceeds 7 feet (2134 mm), or where a post and beam system occurs at the dwelling perimeter, the post and beam system tallest post clear height exceeds 7 feet (2134 mm).

8.3 Of the total plan area below the lowest framed floor, whether open or enclosed, less than 50 percent is living space having interior wall finishes conforming to Section R702.

Where Item 8 is applicable, design in accordance with accepted engineering practice shall be provided for the floor immediately above the cripple walls or post and beam system and all structural elements and connections from this diaphragm down to and including connections to the foundation and design of the foundation to transfer lateral loads from the framing above.

Exception: Light-frame construction in which the lowest framed floor is supported directly on concrete or masonry walls over the full length of all sides except the downhill side of the dwelling need not be considered an irregular dwelling under Item 15
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Item 8.

16.06.75 Section R304.5 Dwelling unit and congregate residence superficial floor area.

Section R304.5 of the California Residential Code is added to read:

R304.5 Dwelling unit and congregate residence superficial floor area.

Every dwelling unit and congregate residence shall have at least one room which shall have not less than 120 square feet of superficial floor area. Every room which is used for both cooking and living or both living and sleeping purposes shall have not less than 144 square feet of superficial floor area. Every room used for sleeping purposes shall have not less than 70 square feet of superficial floor area. When more than two persons occupy a room used for sleeping purposes the required superficial floor area shall be increased at the rate of 50 square feet for each occupant in excess of two. Guest rooms with cooking shall contain the combined required superficial areas of a sleeping and a kitchen, but not less than 144 square feet. Other habitable rooms shall be not less than 70 square feet.

Notwithstanding any provision of this Section, children under the age of six shall not be counted for purposes of determining whether a family with minor children complies with the provisions of this Code.

For the purposes of this section, "superficial floor area" means the net floor area within the enclosing walls of the room in which the ceiling height is not less than seven feet six inches, excluding built-in equipment such as wardrobes, cabinets, kitchen units, or fixtures which are not readily removable.

16.06.080 Section R319.1 Emergency escape and rescue openings.

Section R319.1 of the California Residential Code is amended to read:

R319.1 Emergency escape and rescue opening required. Basements, habitable attics and every sleeping room shall have not less than one operable emergency escape and rescue opening. Where basements contain one or more sleeping rooms, an emergency escape and rescue opening shall be required in each sleeping room. Emergency escape and rescue openings shall open directly into a public way, or to a yard or court that opens to a public way.

Exceptions:

1. Storm shelters and basements used only to house
mechanical equipment not exceeding a total floor area of 200 square feet (18.58 m2)
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16.06.090 Section R319.4.2.3 Window well fall protection.

Section R319.4.2.3 of the California Residential Code is added to read:

R319.4.2.3 Window well fall protection. Window wells with a vertical depth greater than 30 inches shall have guards on all sides. The guards shall be provided in accordance with Section R321.1. Openings shall comply with Section R321.1.3. Access ladder shall comply with Section R319.4.2.1 and shall extend from the bottom of the well to the top of the guard. Grates or similar barriers shall not be installed over the window well.

16.06.100 Section R319.4.5 Security bars.

Section R319.4.5 of the California Residential Code is added to read:

R319.4.5 Security bars. Fire Department plan check review and approval of all security bar submittals shall be required prior to the issuance of a Building Permit.

16.06.110 Section R309.1.1 Design and installation.

Section 309.1.1 of the California Residential Code is amended to read:

R309.1.1 Design and installation. Where allowed, automatic sprinkler systems installed in townhouses shall be installed throughout in accordance with NFPA 13 and State and local standards.

16.06.120 Section R309.2 One and two-family dwellings automatic fire sprinkler systems.

Section R309.2 of the California Residential Code is amended to read:

R309.2 One and two-family dwellings automatic fire sprinkler systems.

Approved automatic sprinkler systems in new buildings and structures and in existing modified buildings and structures, shall be provided in the locations described in this section. Automatic fire sprinklers shall be installed per the requirements set forth in Sections
903.2.1 through 903.2.18 of the California Building Code and as follows, whichever is the more restrictive:

1. An automatic sprinkler system shall be provided throughout all new buildings and structures.

Exception: New residential occupancies, buildings or
structures that do not exceed 350 square feet of building area and contain no interior plumbing fixtures.

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2. An automatic sprinkler system shall be provided throughout all existing buildings when modifications are made that create an increase in fire area to more than 3600 square feet or when the addition is equal to or greater than 50% of the existing building square footage, whichever is more restrictive.

3. An automatic fire sprinkler system is required in basements when any of the following occurs:
a) New basements used for storage, utility, occupancy, or habitable space regardless of size.
b) Existing basements that are altered for the use of storage, utility, occupancy, or habitable space regardless of size.
c) Existing basements expanded by 50% or more.

If the addition or alteration is only the basement, then only the basement is required to be protected by fire sprinklers.

4. An automatic fire sprinkler system is required when either the roof structure, exterior walls, or combination of both has been removed, altered and/or replaced in at least 50% of the existing structure.

5. An automatic sprinkler system shall be installed throughout when any change in use or occupancy creating a more hazardous fire/life safety condition, as determined by the Fire Chief.

16.04.130 Section R309.2.1 Design and installation.

Section R309.2.1 of the California Residential Code is amended to read as follows:

R309.2.1 Design and installation. R309.2.1 Design and installation.

Where allowed, automatic sprinkler systems installed in one-and two- family detached dwellings shall be installed throughout in accordance with NFPA 13D and State and local standards. Fire sprinkler protection is required under rear covered patios extending over 4 feet perpendicular from the exterior of the structure.

16.04.140 Section R309.2.2 NFPA 13D sprinkler systems
increase in design requirements.

Section R309.2.2 of the California Residential Code is added to read as follows:

R309.2.2 Section R309.2.2 NFPA 13D sprinkler systems increase in design requirements. In a higher fire fighting hazardous conditions a four head fire sprinkler calculation and coverage in all closets, bathrooms and attics will be required in Residential and Group U Occupancies as determined by the Fire Code Official in the following conditions:

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1. Structures located in the High Hazardous Fire Areas.

2. Structures where the combined fire area is 3600 sq ft or larger.

3. Structures located 150 ft or greater from the Fire Department access roadways.

4. Basements and below grade structures.

16.04.150 Section R309.3 Dwelling unit fire sprinkler systems.

Section R309.3 of the California Residential Code is deleted in its entirety and amended as follows:

R309.3 Dwelling unit fire sprinkler systems. Fire sprinkler systems shall be designed and installed in accordance with NFPA 13D, State and local standards.

16.06.160 Section R310.1 Smoke detection and notification.

Section R310.1 of the California Residential Code is amended to read:

R310.1 Smoke detection and notification. Listed single- and multiple- station smoke alarms complying with UL 217 shall be installed in accordance with the California Fire Code Sections 907.2.11.1 through 907.2.11.5 and manufacturer’s installation and use instructions.

Smoke alarms and smoke detectors shall be in compliance with this code or subject to the provisions of the Health and Safety Code, they shall also be listed and approved for rapid response to smoldering synthetic materials. All smoke alarms or detectors shall be of the photoelectric type or shall have equivalent detection capabilities in compliance with UL 217.

Exception: A photoelectric smoke alarm or detector shall be installed if located within 20 feet to a kitchen, fireplace or woodburning stove or within 5 feet of a bathroom.

16.06.170 Section R310.1.3 Smoke alarms or detector end of life replacement.

Section R310.1.3 of the California Residential Code is added to read:

R310.1.3 Smoke alarms or detector end of life replacement. Smoke alarms or detectors shall be replaced every 10 years or according to the manufacture guidelines, whichever is more restrictive.

16.06.180 Section R311.7.5. Carbon Monoxide alarms.

Section R311.7.5 of the California Residential Code is added to read:

R311.7.5 Carbon Monoxide alarms or detectors end of life replacement.

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or according to the manufacture guidelines, whichever is more restrictive.

16.06.190 Section R308 - Site Address.

Section R308 of the California Residential Code is amended to read:

R308.1 Address Identification. Buildings shall be provided with approved address identification. The address identification shall be legible and placed in a position that is visible from the street or road fronting the property. Address identification characters shall contrast with their background. Address numbers shall be Arabic numbers or alphabetical letters. Numbers shall not be spelled out. Each character shall be not less than 4 inches (102 mm) in height with a stroke width of not less than 0.5 inch (12.7 mm). Where required by the fire code official, address identification shall be provided in additional approved locations to facilitate emergency response. Where access is by means of a private road and the building address cannot be viewed from the public way, a monument, pole or other sign or means shall be used to identify the structure. Address identification shall be maintained.

R308.1.1 Address illumination. Address identification required by Section R308.1 shall be illuminated.

R308.1.2 Address identification size. Address numbers and letters shall be sized as follows:

1. When the structure is between thirty-six (36) and fifty (50) feet from the road or other emergency means of access, a minimum of one-half inch (0.5") stroke by six inches (6") high is required.

2. When the structure is fifty (50) or more feet from the road or other emergency means of access, a minimum of one inch (1") stroke by nine inches (9") high is required.

16.06.200 Section R306.1 – General (Palo Alto Flood Hazard Regulations).

The following paragraph is added to Section R306.1 of the California Residential Code:

Palo Alto Flood Hazard Regulations. Notwithstanding the provisions of this section R306, all construction or development within a flood hazard area (areas depicted as a Special Flood Hazard Area on Flood Insurance Rate Maps published by the Federal Emergency Management Agency) shall comply with the City of Palo Alto Flood Hazard Regulations (Palo Alto Municipal Code Chapter 16.52). Where discrepancies exist between the requirements of this code and said regulations, the more stringent requirements shall apply.

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16.06.210 Reserved.

16.06.220 Section R401 GENERAL.

Section R401 of the California Residential Code is amended to read:

R401.1 – R401.3 {CRC text not modified}
R401.4 Soils tests. Exception is added at end of the CRC text as follows: Exception: Refer to PAMC 16.04.450
R401.4.1 Geotechnical evaluation. When permitted by the building official or designee, in lieu of a complete geotechnical evaluation, the load bearing values in T401.4.1(1) shall be assumed.

T401.4.1(2), R401.4.1.1 – R401.4.2 {CRC text not modified}

16.06.225 Section R402.2.1 Materials for concrete.

Section 402.2.1 of the California Residential Code is amended to read:

R402.2.1 Materials for concrete. Materials for concrete shall comply with the requirements of Section R608.5.1, as amended by PAMC 16.14.240.

16.06.230 Section R403 FOUNDATION.

Section R403 of the California Residential Code is amended as follows:

R403.1 – R403.1.1 {CRC text not modified}
R403.1.2 Continuous footing in Seismic Design Categories D0, D1, and D2.

Exterior walls of buildings located in Seismic Design Categories D0, D1 and D2 shall be supported by continuous solid or fully grouted masonry or concrete footings. All required interior braced wall panels in buildings located in Seismic Design Categories D0, D1 and D2 shall be supported on continuous foundations.

R403.1.3 Footing and stem wall reinforcing in Seismic Design Categories D0, D1, and D2. Concrete footings located in Seismic Design Categories D0, D1 and D2, as established in Table R301.2(1), shall have not fewer than three No. 4 horizontal bars. One No. 4 horizontal bar shall be installed within 12 inches (305 mm) of the top of the stem wall and two No. 4 horizontal bars shall be located 3 to 4 inches (76 mm to 102 mm) from the bottom of the footing.

R403.1.3.1 Concrete stem walls with concrete footings. In Seismic Design Categories D0, D1 and D2 where a construction joint is created between a concrete footing and a stem wall, not fewer than one No. 4 vertical bar shall be installed at not more than 4 feet (1219 mm) on center. The vertical Item 15
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bar shall have a standard hook and extend to the bottom of the footing and shall have support and cover as specified in Section R403.1.3.5.3 and extend not less than 14 inches (357 mm) into the stem wall. Standard hooks shall comply with Section R608.5.4.5. Not fewer than one No. 4 horizontal bar shall be installed within 12 inches (305 mm) of the top of the stem wall and two No. 4 horizontal bars shall be located 3 to 4 inches (76 mm to 102 mm) from the bottom of the footing.

R403.1.3.2 Masonry stem walls with concrete footings. In Seismic Design Categories D0, D1 and D2 where a grouted masonry stem wall is supported on a concrete footing, not fewer than one No. 4 vertical bar shall be installed at not more than 4 feet (1219 mm) on center. The vertical bar shall have a standard hook and extend to the bottom of the footing and have support and cover as specified in Section R403.1.3.5.3 and extend not less than 14 inches (357 mm) into the stem wall. Standard hooks shall comply with Section R608.5.4.5. Not fewer than one No. 4 horizontal bar shall be installed within 12 inches (305 mm) of the top of the wall and two No. 4 horizontal bars shall be located 3 to 4 inches (76 mm to 102 mm) from the bottom of the footing. Masonry stem walls shall be solid grouted.

In Seismic Design Categories D0, D1 and D2 masonry stem walls without solid grout and vertical reinforcing are not permitted.

R403.1.3.3 – R403.1.7.4 {CRC text not modified}
R403.1.8 Foundations on expansive soils. Foundations and floor slabs for buildings located on expansive soils shall be designed in accordance with Section 1808.6 or Table 1809.7 of the California Building Code as amended in Municipal Code Section 16.04.470.

R403.1.8.1 {CRC text not modified}

16.06.240 Section R404.1.3 Concrete foundation walls.

Section 404.1.3 of the California Residential Code is amended to read:

R404.1.3 Concrete Foundation Walls. Concrete foundation walls that support light- frame walls shall be designed and constructed in accordance with the provisions of this section, ACI 318, ACI 332, or PCA 100, as amended by PAMC Section 16.14.240. Concrete foundation walls that support above-grade concrete walls that are within the applicability limits of Section R608.2 shall be designed and constructed in accordance with the provisions of this section, ACI 318, ACI 332, or PCA 100, as amended by PAMC Section 16.14.240. Concrete foundation walls that support above- grade concrete walls that are not within the applicability limits of Section R608.2 shall be designed and constructed in accordance with the provisions of ACI 318, ACI 332, or PCA 100, as amended by PAMC Section

16.14.240. When ACI 318, ACI 332, PCA 100 or the provisions of this section, as amended by PAMC Section 16.14.240 are used to design Item 15
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concrete foundation walls, project drawings, typical details and specifications are not required to bear the seal of the architect or engineer responsible for design, unless otherwise required by the state law of the jurisdiction having authority.

16.06.250 Section R504.3.1 Projections exposed to weather.

Section R504.3.1 of the California Residential Code is added to read:

R504.3.1 Projections exposed to weather. Floor projections exposed to the weather and sealed underneath, including but not limited to balconies, landings, decks, and stairs shall be constructed of naturally durable wood, preservative-treated wood, corrosion-resistant (e.g. galvanized) steel, or similar approved materials.

16.06.260 Section R506.1 General.

Section R506.1 of the California Residential Code is amended to read:

R506.1 General. Concrete slab-on-ground floors shall be designed and constructed in accordance with the provisions of this section of ACI 332, as amended by PAMC Section 16.14.240. Floors shall be a minimum 3 1/2 inches (89mm) thick (for expansive soils, see Section R403.1.8). The specified compressive strength of concrete shall be as set forth in Section R402.2.

16.06.270 Section R602.10.4.5 Limits on methods GB and PCP.

Section R602.10.4.5 of the California Residential Code is added to read:

R602.10.4.5 Limits on methods GB and PCP. In Seismic Design Categories D0, D1, and D2, Method GB is not permitted for use as an intermittent braced wall panels, but gypsum board is permitted to be installed when required by this Section to be placed on the opposite side of the studs form other types of braced wall panel sheathing. In Seismic Design Categories D0, D1, and D2, the use of Method PCP is limited to one-story single family dwelling and accessory structures.

16.06.280 Table R602.10.3(3) Bracing requirements based on seismic design category.

Footnote e to Table R602.10.3(3) is amended to read as follows:

e. In Seismic Design Categories D0, D1 and D2, Method GB is not permitted and PCP is limited to one-story dwellings and accessory structures.

16.06.290 Section R608.5 Materials.

Section R608.5 of the California Residential Code is amended to read:

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R608.5 Materials. Materials used in the construction of concrete walls shall comply with this section, as amended by PAMC Chapter 16.14.240.

16.06.300 Section R703.8.5.1 Locations.

Section R703.8.5.1 of the California Residential Code is added to read:

R703.8.5.1 Locations. Flashing shall be installed at wall and roof intersections, gutters, wherever there is a change in roof slope or direction, and around roof openings. Where flashing is of metal, the metal shall be corrosion resistant with a thickness of not less than

0.019 inches (0.483 mm) (e.g. no. 26 galvanized sheet) and shall be primed and painted.

16.06.310 Reserved.

16.06.320 Section R1003.9.2.1 Repairs, replacements and alterations.

Section R1003.9.2.1 is added to the California Residential Code to read:

R1003.9.2.1 Repairs, replacements and alterations. When any repair, replacement or alteration to the roof of an existing structure is performed, a spark arrester shall be installed on the existing chimney in accordance with Section R1003.9.2.

16.06.330 Section BO109 Preliminary Meeting.

Section BO109 of Appendix BO of the California Residential Code is added to read:

Section BO109.1 General. If a building permit is required at the request of the prospective permit applicant, the building official or his or her designee may meet with the prospective applicant to discuss plans for any proposed work under these provisions prior to the application for the permit. The purpose of this preliminary meeting is for the building official to gain an understanding of the prospective applicant’s intentions for the proposed work, and to determine, together with the prospective applicant, the specific applicability of these provisions.

SECTION 2. The Council adopts the findings for local amendments to the California Residential Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.

SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it would have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof Item 15
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irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

SECTION 4. The Council finds that the changes or modifications to the California Residential Code adopted by this ordinance are substantially equivalent to changes or modifications that were previously filed by the governing body of the City and were in effect as of September 30, 2025, and are therefore exempt from the moratorium on new residential building standards imposed by Assembly Bill 130 (2025).

SECTION 5. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the amendments herein adopted will have a significant effect on the environment.

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SECTION 6. This ordinance shall be effective on the thirty-first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

____________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

____________________________ ____________________________ City Attorney or Designee City Manager

____________________________
Director of Planning and
Development Services

____________________________
Director of Administrative Services

____________________________
Director of Public Works
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Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA RESIDENTIAL CODE, TITLE 24, PART 2.5

Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Residential Code, Title 24, Part 2.5
Chapter(s),
Section(s),
Table(s),
Appendices
Title Add Deleted Amended Justification
(See below
for keys)
R202 Superficial floor area  A, G
Table R301.2 Climatic and
Geographic Design
Criteria
 C, G, T
R301.2.2.6 Irregular Buildings  G
R304.5 Dwelling unit and
congregate residence
 A, G
R319.1 Emergency Escape
and Rescue Openings
 C, T
R319.4.2.3 Window Well Fall Protection  T
R 319.4.5 Security Bars  T
R309.1.1 Design and installation  T
R 309.2 One and Two Family
Dwellings
Automatic Spr. Syst.
 T
R309.2.1 Design and installation  T
R309.2.2 NFPA 13D sprinkler increase
in design requirements
 T
R309.3 Dwelling unit fire sprinkler
systems
 T
R 310.1 Smoke Detection and
Notification  C, T
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R310.1.3 Smoke alarms or detector
end of life replacement
  T
311.7.5 Carbon monoxide alarms
or detectors end of life
replacement
  T
R 308 Address identification  T
R 306.1 Flood Hazard Regulations   T
R401 General  T, G
R402.2.1 Materials for concrete  C
R403,
R403.1.2,
R403.1.3,
R403.1.3.1,
R403.1.3.2
Foundation  G, T
R 403.1.8 Foundation on
expansive Soils
 G, T
R404.1.3 Concrete foundation
walls
 C
R 504.3.1 Projections exposed to
weather
  G, T
R506.1 Concrete Floors on
ground
  C
CR602.10.

4.5 Limits on methods GB
and PCP
  G
Table
R602.10.3(3
)
Bracing Requirements Based
on
Seismic Design Category
  G
R608.5 Materials   C
R703.8.5.
1 Flashing Locations   T
R1003.9.2
.1
Repairs, Replacements and
Alterations
  T
Appendix
BF
Patio Covers   C
Appendix
BO
Existing Building and
Structures
  C, T
Appendix
BG
Sound Transmission   C
Appendix
CI
Swimming Pool Safety Act   C, G
BO109 Preliminary Meeting,
General
  A, C, G

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Key to Justification for Amendments to Title 24 of the California Code of Regulations

A This is an administrative amendment to clarify and establish civil and administrative procedures, regulations, or rules to enforce and administer the activities by the Palo Alto Building Inspection Department. These administrative amendments do not need to meet HSC 18941.5/17958/13869 per HSC 18909(c).

C This amendment is justified based on a local climatic condition. The seasonal climatic conditions during the late summer and fall create severe fire hazards to the public health and welfare in the City. The hot, dry weather frequently results in wild land fires on the brush covered slopes west of Interstate 280. The aforementioned conditions combined with the geological characteristics of the hills within the City create hazardous conditions for which departure from California Building Standards Code is required. Natural gas combustion and gas appliances emit a wide range of air pollutants, such as carbon monoxide (CO), nitrogen oxides (NOx, including nitrogen dioxide (NO2)), particulate matter (PM), and formaldehyde, which according to a UCLA Study, have been linked to various acute and chronic health effects, and additionally exceed levels set by national and California-based ambient air quality standards. The burning of fossil fuels used in the generation of electric power and heating of buildings contributes to climate change, which could result in rises in sea level, including in San Francisco Bay, that could put at risk Palo Alto homes and businesses, public facilities, and Highway 101 (Bayshore Freeway), particularly the mapped Flood Hazard areas of the City. Energy efficiency is a key component in reducing GHG emissions, and construction of more energy efficient buildings can help Palo Alto reduce its share of the GHG emissions that contribute to climate change. All-electric new buildings benefit the health, safety, and welfare, of Palo Alto and its residents. Requiring all-electric construction, without gas infrastructure will reduce the amount of greenhouse gas produced in Palo Alto and will contribute to reducing the impact of climate change and the associated risks. Due to decrease in annual rain fall, Palo Alto experiences the effect of drought and water saving more than some other communities in California. Embodied carbon of concrete is a significant contributor to greenhouse gas emissions and climate change, and this amendment includes a requirement to use low-carbon concrete.

G This amendment is justified based on a local geological condition. The City of Palo Alto is subject to earthquake hazard caused by its proximity to San Andreas fault. This fault runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel Rock. This is the approximate location of the epicenter of the 1906 San Francisco earthquake. The other fault is Hayward Fault. This fault is about 74 mi long, situated mainly along the western base of the hills on the east side of San Francisco Bay. Both faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area which includes these earthquake faults, the modifications and changes cited herein are designed to better limit property damage as a result of seismic activity and to establish criteria for repair of damaged properties following a local emergency.

T The City of Palo Alto topography includes hillsides with narrow and winding access, which makes timely response by fire suppression and emergency response vehicles difficult. Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater run-off. Also, the City of Palo Alto is located in an area that is potentially susceptible to liquefaction during a major earthquake. The surface condition consists mostly of stiff to dense sandy clay, which is highly plastic and expansive in nature. The aforementioned conditions within the City create hazardous conditions for which departure from California Building Standards Code is warranted.

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Ordinance No.

Ordinance of the Council of the City of Palo Alto Repealing Chapter 16.08 of the Palo Alto Municipal Code and Amending Title 16 to Adopt a New Chapter 16.08, California Plumbing Code, 2025 Edition, and Local Amendments and Related Findings

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Chapter 16.08 of the Palo Alto Municipal Code is hereby amended by repealing in its entirety 16.08 and adopting a new Chapter 16.08 to read as follows:

CHAPTER 16.08

CALIFORNIA PLUMBING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 5

Sections

16.08.010 2025 California Plumbing Code, Title 24, Part 5 adopted and amended.

16.08.020 Cross - References to California Plumbing Code.

16.08.030 Local Amendments.

16.08.040 Administration & Enforcement of 2025 California Plumbing Code.

16.08.050 Adoption of Chapter 1, Division II Administration.

16.08.060 Section 102.8 Appendices.

16.08.070 Section 306.3 Palo Alto sewer use.

16.08.080 Section 701.2, (4) Drainage piping.

16.08.090 Section 719.7 Cleanouts.

16.08.100 Section 808.2 Single pass cooling water systems prohibited.

16.08.110 Section 1014.1 Grease Interceptors - General.

16.08.115 Section 1014.2.1.1 Grease Capacity

16.08.120 Section 1101.4 Material use.

16.08.130 Section 1101.4.1 Copper and copper alloys.

16.08.140 Section 1101.4.2 Conductors.

16.08.150 Section 1101.4.3 Leaders.

16.08.160 Section 1102.1 Applications.

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16.08.010 2025 California Plumbing Code, Title 24, Part 5 adopted and amended.

The California Plumbing Code, 2025 Edition, Title 24, Part 5 of the California Code of Regulations together with those omissions, amendments, exceptions and additions thereto, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and regulations to the chapters and sections of the former editions of the California Code of Regulations, Title 24, shall be construed to apply to the corresponding provisions contained within the California Code of Regulations, Title 24, 2025. Ordinance No. 5567 of the City of Palo Alto and all other ordinances or parts of ordinances in conflict herewith are hereby suspended and expressly repealed.

Wherever the phrases "California Plumbing Code" or "Plumbing Code" are used in this code or any ordinance of the City, such phrases shall be deemed and construed to refer and apply to the California Plumbing Code, 2025 Edition, Title 24, Part 4 of the California Code of Regulations, as adopted by this Chapter.

One copy of the California Plumbing Code, 2025 edition, has been filed for use and examination of the public in the Office of the Building Official of the City of Palo Alto.

16.08.020 Cross - References to California Plumbing Code.

The provisions of this Chapter contain cross-references to the provisions of the California Plumbing Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.

16.08.030 Local Amendments.

The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of the California Plumbing Code, 2025 Edition, and shall be deemed to replace the cross- referenced sections of said Code with the respective provisions set forth in this Chapter.

Where used in this Chapter 16.08, ellipses shall indicate text of the California Plumbing Code, 2025 Edition, that has been adopted without amendment but is omitted for brevity.

16.08.040 Administration & Enforcement of 2025 California Plumbing Code.

Administration and enforcement of this code shall be governed by Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04.

16.08.050 Adoption of Chapter 1, Division II Administration.

Chapter 1, Division II Administration of the 2025 California Plumbing Code is adopted by the City of Palo Alto to supplement, to the extent it does not conflict with, Chapter 1, Division II of the 2025 California Building Code as amended.

16.08.060 Section 102.8 Appendices.

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The following Appendix Chapters of the California Plumbing Code, 2025 Edition, are adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein:

A. Appendix A – Recommended rules for sizing the water supply system B. Appendix D – Sizing storm water drainage systems

16.08.070 Section 306.3 Palo Alto sewer use.

Section 306.3 of Chapter 3 of the California Plumbing Code is added to read:
306.3 Palo Alto sewer use. All non-domestic waste shall comply with the City of Palo Alto Sewer Use Ordinance (Palo Alto Municipal Code Chapter 16.09). Where discrepancies exist between the requirements of this code and said ordinance, the provisions of said ordinance shall apply.

16.08.080 Section 701.2, (4) Drainage piping.

Subdivsion (4) of Section 701.2 of Chapter 7 of the California Plumbing Code is amended to read:
701.2 Drainage Piping
Materials for drainage piping shall be in accordance with one of the referenced standards in Table 701.2 except that:
[. . .]

(4) Copper, copper alloys, lead and lead alloys, including brass, shall not be used for building sanitary drainage lines, connectors or seals coming in contact with sewage except for domestic waste sink traps and short lengths of associated connecting pipes where alternate materials are impracticable.

Where permitted by the building official or their designee, copper tube for drainage piping shall have a weight of not less than that of copper drainage tube type DWV.

[. . .]

16.08.090 Section 719.7 Cleanouts.

Section 719.7 of Chapter 7 of the California Plumbing Code is added to read:

719.7 Cleanouts. A cleanout shall be provided at the point of connection between the building sewer and the city lateral and an approved fitting shall be used to bring the cleanout riser to grade. Where sewer cleanouts are to be connected to existing city laterals, such connections shall be accomplished by use of a City of Palo Alto Utility approved fitting.

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16.08.100 Section 808.2 Single pass cooling water systems prohibited.

Section 808.2 of Chapter 8 of the California Plumbing Code is added to read:

808.2 Single pass cooling water systems prohibited. Clean running water used exclusively as a cooling medium in an appliance, device, or apparatus is prohibited.

Refer to PAMC 16.14.350 for additional CALGreen measures.

16.08.110 Section 1014.1 Grease Interceptors - General
Section 1014.1 of Chapter 10 of the California Plumbing Code is amended to read as follows (additions to the 2025 California Plumbing code are underlined, deletions are struck through):
1014.1 General. Where it is determined by the Authority Having Jurisdiction that waste pretreatment is required, an approved type of grease interceptor(s) shall comply with ASME A112.14.3, ASME A112.14.4, CSA B481, ANSI/CAN/IAPMO Z1001, PDI G-101, or PDI G-102, and sized in accordance with Sections 1014.2.1 and 1014.2.1.1 or Section 1014.3.6, shall be installed in accordance with the manufacturer’s installation instructions to receive the drainage from fixtures or equipment that produce grease-laden waste. Grease-laden waste fixtures shall include, but not be limited to, sinks and drains, such as floor drains, floor sinks, and other fixtures or equipment in serving establishments, such as restaurants, cafes, lunch counters, cafeterias, bars and clubs, hotels, hospitals, sanitariums, factory or school kitchens, or other establishments where grease is introduced into the drainage or sewage system in quantities that can effect line stoppage or hinder sewage treatment or private sewage disposal systems. A combination of hydromechanical, gravity grease interceptors and engineered systems shall be allowed to meet this code and other applicable requirements of the Authority Having Jurisdiction where space or existing physical constraints of existing buildings necessitate such installations. A grease interceptor shall not be required for individual dwelling units or private living quarters. Water closets, urinals, and other plumbing fixtures conveying human waste shall not drain into or through the grease interceptor. […]
1014.1.2 Maintenance. Grease interceptors shall be maintained in efficient operating condition by periodic removal of the accumulated grease and latent material. No such collected grease shall be introduced into drainage piping or a public or private sewer.

Where the Authority Having Jurisdiction determines that a grease interceptor is not being properly cleaned or maintained, the Authority Having Jurisdiction shall have the authority to mandate the installation of additional equipment or devices. The Authority Having Jurisdiction shall have the authority and to mandate a maintenance program for grease interceptors.
1014.1.3 Food Waste Disposers and Dishwashers.

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Unless specifically required or permitted by the Authority Having Jurisdiction, no No food waste disposer or dishwasher shall be connected to or discharge into a grease interceptor. Commercial food waste disposers shall be permitted to discharge directly into the building’s drainage system. Commercial Food Waste Disposal Units are prohibited.

Exception: Food waste disposers shall be permitted to discharge to grease interceptors that are designed to receive the discharge of food waste. 1014.1.4 Wastewater Discharge through Grease Interceptors. Wastewater Discharge through grease interceptors shall be by means of gravity only. Unless otherwise approved by the Authority Having Jurisdiction, mechanical pumping of wastewater through a grease interceptor shall not be allowed. Pumps and/or other mechanical pumping equipment to convey wastewater shall only be installed to convey wastewater after the wastewater has passed through the grease interceptor. 1014.1.5 Two-Way Lateral Cleanouts. Two-way Lateral cleanouts shall be installed on the inlet and outlet sides of grease interceptors for ease of maintenance and flushing of the lateral line(s).
1014.1.6 Acceptable Materials. Grease interceptors made of the following materials shall not be installed in the City: materials susceptible to corrosion in low pH environments, concrete, metal, and acid-resistant enamel or epoxy (A.R.E.) coatings.

Examples of acceptable materials of construction include thermoplastic (low or high- density polyethylene) or similar non-corrosive materials. 1014.1.7 Sharing of Grease Interceptors Prohibited. Unless specifically required or permitted by the Authority Having Jurisdiction, a grease interceptor may be used by only one food facility. Sharing grease interceptors between multiple food facilities is prohibited.

16.08.115 Section 1014.2.1.1 Grease Capacity
Section 1014.2.1.1 of Chapter 10 of the California Plumbing Code is added to read:
1014.2.1.1 Grease Capacity. In addition to the sizing criteria based on flow rate specified in Section 1014.2.1, hydromechanical grease interceptors shall meet the sizing criteria based on grease capacity outlined in the “Palo Alto Regulations for Food Facilities Related to Water Pollution Prevention and Management of Fats, Oils, and Grease.” The correctly sized grease interceptor will have both the minimum flow rate determined according to Section 1014.2.1 and the minimum grease storage capacity determined according to this section.

16.08.120 Section 1101.4 Material use.

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Section 1101.4 of Chapter 11 of the California Plumbing Code is amended to read:

1101.4 Material use. Pipe, tube, and fittings conveying rainwater shall be of such materials and design as to perform their intended function to the satisfaction of the Authority Having Jurisdiction. Conductors within a vent or shaft shall be of cast- iron, galvanized steel, wrought iron, Schedule 40 ABS DWV, Schedule 40 PVC DWV, stainless steel 304 or 316L [stainless steel 304 pipe and fittings shall not be installed underground and shall be kept not less than 6 inches (152 mm) aboveground], or other approved materials, and changes in direction shall be in accordance with the requirements of Section 706.0. ABS and PVC DWV piping installations shall be installed in accordance with applicable standards referenced in Chapter 17 and the firestop protection requirements in the California Building Code.

Except for individual single- family dwelling units, materials exposed within ducts or plenums shall have a flame- spread index of not more than 25 and a smoke-developed index of not more than 50, where tested in accordance with ASTM E84 or UL 723.

Plastic piping installed in plenums shall be tested in accordance with all requirements of ASTM E84 or UL 723. Mounting methods, supports and sample sizes of materials for testing that are not specified in ASTM E84 or UL 723 shall be prohibited. [HCD 1 & HCD 2] ABS or PVC installations are limited to not more than two stories of areas of residential accommodation.
[OSHPD 1, 2, 3 & 4] ABS and PVC installations are not allowed.

16.08.130 Section 1101.4.1 Copper and copper alloys.

Section 1101.4.1 of Chapter 11 of the California Plumbing Code is amended to read:
1101.4.1 Copper and copper alloys. Joints and connections in copper and copper alloy pipe and tube is prohibited.

16.08.140 Section 1101.4.2 Conductors.

Section 1101.4.2 of Chapter 11 of the California Plumbing Code is amended to read:
1101.4.2 Conductors. Conductors installed aboveground in buildings shall comply with the applicable standards referenced in Table 701.2 for aboveground drain, waste, and vent pipe. Conductors installed aboveground level shall be of Schedule 40 copper pipe or Schedule 40 copper alloy pipe; service weight cast-iron soil pipe or hubless cast-iron soil pipe; standard weight galvanized steel pipe; stainless steel 304 or 316L [stainless steel 304 pipe and fittings shall not be installed underground and shall be kept not less than 6 inches (152 mm) aboveground], or Schedule 40 ABS or Schedule 40 PVC plastic pipe.

16.08.150 Section 1101.4.3 Leaders.

Section 1101.4.3 of Chapter 11 of the California Plumbing Code is amended to read:

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1101.4.3 Leaders. Leaders installed outside shall be in accordance with the applicable standards referenced in Table 701.2 for aboveground drain, waste, and vent pipe; aluminum sheet metal; or galvanized steel sheet metal.

16.08.160 Section 1102.1 Applications.

Section 1102.1 of Chapter 11 of the California Plumbing Code is amended to read:
1102.1 Applications. Roof drains shall be constructed of aluminum, cast-iron, stainless steel, ABS, PVC, polypropylene, polyethylene, or nylon and shall comply with ASME A112.3.1 or ASME A112.6.4.

SECTION 2. The Council adopts the findings for local amendments to the California Plumbing Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.

SECTION 3. The Council finds that, with the exception of the changes codified at PAMC Section 16.08.110 and 16.08.115, the changes or modifications to the California Plumbing Code adopted by this ordinance are substantially equivalent to changes or modifications that were previously filed by the governing body of the City and were in effect as of September 30, 2025, and are therefore exempt from the moratorium on new residential building standards imposed by Assembly Bill (AB) 130 (2025). The changes codified at PAMC Section 16.08.110 and

16.08.115 do not affect residential units and are therefore not subject to the AB 130 moratorium.

SECTION 4. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”) pursuant to Section 15308 of the CEQA Guidelines, because it is an action by the City as a regulatory body for the protection of the environment, and Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the amendments herein adopted will have a significant effect on the environment.

SECTION 5. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.
//
//
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SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

____________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

____________________________ ____________________________ City Attorney or Designee City Manager

____________________________
Director of Planning and
Development Services

____________________________
Director of Administrative Services

____________________________
Director of Public Works

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Exhibit A

FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA PLUMBING CODE, TITLE 24, PART 5
Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Plumbing Code, Title, 24, Part 5
Chapter(s),
Sections(s),
Appendices
Title Added Amended Replaced Justification
(See below
for keys)
Ch. 1, Div. II ADMINSTRATION  A
Administration and Enforcement  A
306.3 Palo Alto sewer use  C
701.2 (4) Drainage piping  C
719.7 Cleanouts  C
808.2 Single pass cooling water systems
prohibited
 C
1014.1 Grease Interceptors - General  C, T
1014.2.1.1 Grease Capacity   C, T
1101.4 Material use  C
1101.4.1 Copper and copper alloys  C
1101.4.2 Conductors  C
1101.4.3 Leaders  C
1102.1 Applications  C
Appx. A Recommended rules for sizing the water
supply system
 A, C, T
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Appx. D Sizing storm water drainage systems  A, C, T Item 15
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Key to Justification for Amendments to Title 24 of the California Code of Regulations A This is an administrative amendment to clarify and establish civil and administrative procedures, regulations, or rules to enforce and administer the activities by the Palo Alto Building Inspection Department. These administrative amendments do not need to meet HSC 18941.5/17958/13869 per HSC 18909(c).

C This amendment is justified based on a local climatic condition. The seasonal climatic conditions during the late summer and fall create severe fire hazards to the public health and welfare in the City. The hot, dry weather frequently results in wild land fires on the brush covered slopes west of Interstate 280. The aforementioned conditions combined with the geological characteristics of the hills within the City create hazardous conditions for which departure from California Building Standards Code is required. In addition, Palo Alto’s local climatic conditions create unique challenges for grease management in the sewer system. Heavy winter rains contribute to infiltration and inflow, increasing flows that reduce the system’s tolerance for blockages and making effective grease control devices (GCDs) critical to preventing backups and overflows. Seasonal temperature variations further exacerbate the risk: hot summer conditions can liquefy grease, allowing it to migrate through pipes, while cooler winter conditions cause grease to solidify, increasing the likelihood of blockages. Bay-influenced humidity and saline air accelerate corrosion of interceptor components and piping, making it necessary to prohibit materials susceptible to corrosion in low-pH environments to ensure long-term reliability of GCDs.

G This amendment is justified based on a local geological condition. The City of Palo Alto is subject to earthquake hazard caused by its proximity to San Andreas fault. This fault runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel Rock. This is the approximate location of the epicenter of the 1906 San Francisco earthquake. The other fault is Hayward Fault. This fault is about 74 mi long, situated mainly along the western base of the hills on the east side of San Francisco Bay. Both faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area which includes these earthquake faults, the modifications and changes cited herein are designed to better limit property damage as a result of seismic activity and to establish criteria for repair of damaged properties following a local emergency.

T The City of Palo Alto topography includes hillsides with narrow and winding access, which makes timely response by fire suppression and emergency response vehicles difficult. Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater run-off. Also, the City of Palo Alto is located in an area that is potentially susceptible to liquefaction during a major earthquake. The surface condition consists mostly of stiff to dense sandy clay, which is highly plastic and expansive in nature. The aforementioned conditions within the City create hazardous conditions for which departure from California Building Standards Code is warranted. In addition, much of Palo Alto has very low slope gradients. In flatter areas, sanitary sewer lines experience reduced flow velocity. This condition increases the risk of grease Item 15
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accumulation and blockages in the system, making the use of appropriately sized grease interceptors more critical.

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Ordinance No. ____
Ordinance of the Council of the City of Palo Alto Amending Chapter 16.14 (California Green Building Standards, California Code of Regulations, Title 24, Part 11) of the Palo Alto Municipal Code to Adopt the 2025 Green Building Standards Code, Along With Local Amendments

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Findings and Declarations.

A. The City of Palo Alto adopted a Sustainability and Climate Action Plan, or S/CAP, to meet the City's stated goal of "80 x 30": reducing greenhouse gas emissions 80% below 1990 levels by 2030.

B. The S/CAP outlines goals and key actions in eight areas, one of which is energy and more specifically, energy efficiency and electrification. The goals for the energy area of the S/CAP are to reduce GHG emissions from the direct use of natural gas in Palo Alto’s building sector by at least 60% below 1990 levels (116,400 MT CO2e reduction) and to modernize the electric grid to support increased electric demand to accommodate state‐ of‐the‐art technology.

C. One key action the City is taking to accomplish those goals is to use codes and ordinances ‐ such as the energy reach code, green building ordinance, zoning code, or other mandates ‐ to facilitate electrification in both existing buildings and new construction projects where feasible.

D. The purpose of this ordinance is to formally adopt California Code of Regulations, Title 24, Part 11, 2025 California Green Building Standards Code, with local amendments in furtherance of the City of Palo Alto’s S/CAP goals and other sustainability‐related goals included in the City’s 2030 Comprehensive Plan. The amendments adopted herein are more restrictive than the building standards in Title 24, Part 11.

E. Recent legislation, Assembly Bill (AB) 130 (2025), limits local jurisdictions’ authority to amend the California Building Standards Code beginning October 1, 2025, and ending June 1, 2031. The Council finds that, with the exception of the changes codified at PAMC Sections 16.14.070, 16.14.080, 16.14.285, 16.14.355, and 16.14.400, the changes or modifications to the California Green Building Standards Code adopted by this ordinance are substantially equivalent to changes or modifications that were previously filed by the governing body of the City and were in effect as of September 30, 2025, and are therefore exempt from the moratorium on new residential building standards Item 15
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imposed by Assembly Bill (AB) 130 (2025). The changes codified at the PAMC Sections listed above, to the extent that they are not substantially equivalent to changes in effect as of September 30, 2025, do not affect residential units and are therefore not subject to the AB 130 moratorium.

F. California Health and Safety Code sections 17958.5 and 17958.7 requires that the City, in order to make changes or modifications in the requirements contained in the California Green Building Standards on the basis of local conditions, make express finding that such modifications or changes are reasonably necessary because of local climatic, geological or topographical conditions.

G. The required findings are attached to this ordinance as Exhibit A.

SECTION 2. Chapter 16.14 (California Green Building Standards, California Code of Regulations, Title 24, Part 11) of the Palo Alto Municipal Code is hereby amended by repealing in its entirety existing 16.14 and adopting a new Chapter 16.14 to read as follows:

CHAPTER 16.14

CALIFORNIA GREEN BUILDING STANDARDS CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 11
Sections
Part 1 – General

16.14.010 2025 California Green Building Standards Code, Title 24, Part 11 adopted and amended.

16.14.020 Cross ‐ References to California Green Building Standards Code.

16.14.030 Local Amendments.

Part 2 – Local Modifications to CHAPTER 1 – ADMINISTRATION

16.14.040 Administration & Enforcement of 2025 California Green Building Standards Code.

16.14.050 Adoption of Chapter 1 Administration.

16.14.060 Section 101.4 Appendices.

Part 3 – Local Modifications to CHAPTER 2 – DEFINITIONS

16.14.070 Section 202 Definitions.

Part 4 – Local Modifications to CHAPTER 3 – GREEN BUILDING Item 15
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16.14.080 Section 301 – Voluntary Tiers Added.

Part 5 – Local Modifications to CHAPTER 4 – RESIDENTIAL

MANDATORY MEASURES

16.14.090 Section 4.106.5 Full Electrification

16.14.100 Section 4.306 Swimming Pool and Spa Covers.

16.14.110 Reserved
Part 6 – Local Modifications to CHAPTER 7 – INSTALLER AND

SPECIAL INSPECTOR QUALIFICATIONS

16.14.120 Section 702.2 Special Inspection.

Part 7 – Local Modifications to APPENDIX A4 – RESIDENTIAL

VOLUNTARY MEASURES

16.14.130 Residential Projects. Appendix A4 Preface: Green Building Measures for Project Type and Scope.

16.14.140 Section A4.104 Site Preservation.

16.14.150 Section A4.105 Deconstruction and Reuse of Existing Materials.

16.14.160 Section A4.106.8 Electric Vehicle (EV) Charging for New Construction.

16.14.170 Section A4.106.9 Bicycle Parking.

16.14.180 Section A4.106.10 Light Pollution Reduction.

16.14.190 Section A4.203.1 Performance Approach for Newly Constructed Buildings.

16.14.200 Section A4.304.3 Irrigation Metering Device.

16.14.210 Section A4.305 Water Reuse Systems.

16.14.220 A4.305.4 Additions and Alterations.

16.14.230 Section A4.403.1 Frost Protection Foundation Systems.

16.14.240 Section A4.403.2 Reduction in Cement Use.

16.14.250 Section A4.408.1 Enhanced Construction Waste Reduction.

16.14.260 Section A4.504.1 Compliance with formaldehyde limits.

16.14.270 Section A4.504.3 Thermal Insulation.

Part 8 – Local Modifications to CHAPTER 5 – NONRESIDENTIAL

MANDATORY MEASURES

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16.14.280 Nonresidential Projects: Chapter 5 Preface Green Building Requirements Project Type and Scope.

16.14.285 Section 5.105.1 Scoping

16.14.290 Section 5.106.1.1 Local Storm Water Pollution Prevention.

16.14.295 Section 5.106.8 Light Pollution Reduction.

16.14.300 Section 5.106 Full Electrification.

16.14.310 Reserved

16.14.320 Reserved

16.14.330 Section 5.304.2 Invasive Species Prohibited.

16.14.340 Section 5.306 Nonresidential Enhanced Water Budget.

16.14.350 Section 5.307 Cooling Tower Water Use.

16.14.355 Section 5.409 Life Cycle Assessment

16.14.360 Section 5.410.4.6 Energy STAR Portfolio Manager.

16.14.370 Section 5.410.4.7 Performance Reviews – Energy.

16.14.380 Section 5.410.4.8 Performance Reviews – Water.

16.14.390 Section 5.506 Indoor Air Quality.

Part 9 – Local Modifications to APPENDIX A5 – NONRESIDENTIAL

VOLUNTARY

MEASURES

16.14.400 Section A5.106.5.3 Electric Vehicle (EV) Charging for New Construction.

16.14.410 Section A5.203.1 Performance Approach for Newly Constructed Buildings.

16.14.420 Section A5.405.5 Cement and Concrete.

16.14.430 Section A5.408 Construction Waste Reduction, Disposal and Recycling.

Part 1 – General

16.14.010 2025 California Green Building Standards Code, Title 24, Part 11 adopted and amended.

The California Green Building Standards Code, 2025 Edition, Title 24, Part 11 of the California Code of Regulations, together with those omissions, amendments, exceptions and additions thereto, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

Unless superseded and expressly repealed, references in City of Palo Alto forms, Item 15
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documents and regulations to the chapters and sections of the former California Code of Regulations, Title 24, shall be construed to apply to the corresponding provisions contained within the California Code of Regulations, Title 24, 2025.

Ordinance No. 5626 of the City of Palo Alto and all other ordinances or parts of ordinances in conflict herewith are hereby suspended and expressly repealed.

Wherever the phrases “California Green Building Standards Code” or “CALGreen” are used in this code or any ordinance of the City, such phrases shall be deemed and construed to refer and apply to the California Green Building Standards Code, 2025 Edition, as adopted and amended by this chapter.

One copy of the California Green Building Standards Code, 2025 Edition, has been filed for use and examination of the public in the Office of the Chief Building Official of the City of Palo Alto.

16.14.020 Cross ‐ References to California Green Building Standards Code.

The provisions of this Chapter contain cross‐references to the provisions of the California Green Building Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.

16.14.030 Local Amendments.

The provisions of this Chapter shall constitute local amendments to the cross‐ referenced provisions of the California Green Building Standards Code, 2025 Edition, and shall be deemed to replace the cross‐referenced sections of said Code with the respective provisions set forth in this Chapter.

Part 2 – Local Modifications to CHAPTER 1 – ADMINISTRATION

16.14.040 Administration & Enforcement of 2025 California Green Building Standards Code.

Administration and enforcement of this code shall be governed by Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04.

16.14.050 Adoption of Chapter 1 Administration.

Chapter 1 Administration of the 2025 California Green Building Code is adopted by the City of Palo Alto to supplement, to the extent it does not conflict with, Chapter 1, Division II of the 2025 California Building Code, as amended.

16.14.060 Section 101.4 Appendices.

The following Appendix Chapters of the California Green Building Standards Code, 2025 Edition, are adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein:

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A. Appendix A4 ‐ Residential Voluntary Measures (Tier 1 and Tier2) B. Appendix A5 ‐ Nonresidential Voluntary Measures (Tier 1 and Tier 2)

Part 3 – Local Modifications to CHAPTER 2 – DEFINITIONS

16.14.070 Section 202 Definitions.

Section 202 of Chapter 2 of the California Green Building Standards Code is amended to include the following definitions:

ALL‐ELECTRIC BUILDING / SITE. A building or parcel of land whose sole source of energy is electricity and contains no combustion equipment or plumbing for combustion equipment.

CPAU. City of Palo Alto Utilities Department.

CALGREEN INSPECTOR is a person certified as a CALGreen Inspector/Plans Examiner through the International Code Council (ICC), demonstrating knowledge and application of Green Building concepts during plan review and inspection. For projects that require a CALGreen Inspector/Plans Examiner verification, the Inspector must be contracted directly with the owner and may not be a contractor or employee of the design or construction firm.

CERTIFIED ENERGY ANALYST is a person registered as a Certified Energy Analyst with the California Association of Building Energy Consultants as of the date of submission of a Certificate of Compliance as required under section 10‐103 of Building Energy Efficiency Standards for residential and nonresidential buildings.

GREEN BUSINESS CERTIFICATION INC. (GBCI™). Green Business Certification Inc. (GBCI™) is an independent third‐party organization that provides certification, credentialing, and verification services for green building and sustainability programs, including serving as the official certification body for LEED projects and professional credentials.

LEADERSHIP IN ENERGY AND ENVIRONMENTAL DESIGN (LEED®). The Leadership in Energy and Environmental Design (LEED®) is a green building certification program developed by the U.S. Green Building Council that provides a framework for green buildings through a point‐based rating system that evaluates building performance across multiple sustainability categories. Projects shall follow the U.S. Green Building Council’s standards for selecting the appropriate LEED® rating system.

LEED AP WITH SPECIALTY. An advanced professional credential signifying Item 15
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expertise in green building and a LEED rating system. To earn a LEED AP with specialty, candidates must first pass the LEED Green Associate exam.

The exams measure knowledge about green building, a specific LEED rating system and the certification process and are ideal for individuals who are actively working on green building and LEED projects.

MODEL WATER EFFICIENT LANDSCAPE ORDINANCE. The California Department of Water Resources Model Water Efficient Landscape Ordinance.

SALVAGE. Salvage means the controlled removal of items and material from a building, construction, or demolition site for the purpose of on‐ or off‐site reuse, or storage for later reuse. Examples include air conditioning and heating systems, columns, balustrades, fountains, gazebos, molding, mantels, pavers, planters, quoins, stair treads, trim, wall caps, bath tubs, bricks, cabinetry, carpet, doors, ceiling fans, lighting fixtures, electrical panel boxes, fencing, fireplaces, flooring materials of wood, marble, stone or tile, furnaces, plate glass, wall mirrors, door knobs, door brackets, door hinges, marble, iron work, metal balconies, structural steel, plumbing fixtures, refrigerators, rock, roofing materials, siding materials, sinks, stairs, stone, stoves, toilets, windows, wood fencing, lumber and plywood.

SUBSTANTIAL REMODEL (or “50‐50‐50” RULE). Any project that affects the removal or replacement of 50% or more of the linear length of the existing exterior walls of the building, 50% or more of the linear length of the existing exterior wall where the plate height is raised, or 50% or more of the existing roof framing area is removed or replaced, over a 3‐year period is considered a substantial remodel. (Refer to Section 301.1.2).

SQUARE FOOTAGE. For application of green building requirements, “square footage” refers to all new or altered square footage, including basement areas (7 feet or greater in height), as calculated based on outer boundary of proposed construction area, including exterior walls.

U.S. Green Building Council (USGBC). The U.S. Green Building Council (USGBC) is a nonprofit organization that promotes sustainability in building design, construction, and operation through market transformation initiatives and the development of green building standards, most notably the Leadership in Energy and Environmental Design (LEED®) certification program.

Part 4 – Local Modifications to CHAPTER 3 – GREEN BUILDING

16.14.080 SECTION 301 ‐ Voluntary Tiers Added.

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SECTION 301 of Chapter 3 of the California Green Building Standards Code is amended to read:

SECTION 301 GENERAL
301.1 Scope. Buildings shall be designed to include the green building measures specified as mandatory in the application checklists contained in this code and any applicable local amendments. In addition, the City requires the use of Voluntary Tiers, as provided in Appendices A4 and A5, for certain residential and nonresidential new construction, additions, and alterations.

Projects that only trigger Mandatory measures are not required to fulfill Tier 1 or Tier 2 measures in Appendix A4 and A5.

To achieve Tier 1 status, a project must comply with measures identified in Appendix A4, Division A4.6, Section A4.601.4 for residential projects and Appendix A5, Division A5.6, Section A5.601.2 for nonresidential projects. Projects subject to Tier 1 must fulfill all mandatory measures, all Tier 1 prerequisite measures and a defined number of Tier 1 elective measures.

To achieve Tier 2 status, a project must comply with requirements identified in Appendix A4, Division A4.6, Section A4.601.5 for residential projects and Appendix A5, Division A5.6, Section A5.601.3 for nonresidential projects. Projects subject to Tier 2 must fulfill all mandatory measures, all Tier 2 prerequisite measures and a defined number of Tier 2 elective measures.

301.1.1 Residential additions and alterations. [HCD] The Mandatory provisions of Chapter 4 shall be applied to additions and/or alterations of existing residential buildings where the addition and/or alteration increases the building's conditioned area, volume, or size. The requirements shall apply only to and/or within the specific area of the addition or alteration. Tier 1 adopted (Residential). All residential building additions and/or alterations exceeding 1000 square feet must meet CALGreen Mandatory plus the Tier 1 measures, as amended by this Chapter and as applicable to the scope of work.

For Tier 1 projects, the area of alterations will include any construction or renovation to an existing structure other than repair or addition. Alterations include raising the plate height, historic restoration, changes or rearrangements of the structural parts or elements, and changes or rearrangement of bearing walls and full height partitions.

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Normal maintenance, reroofing, painting or wall papering, floor finishes, replacement‐in‐kind of mechanical, plumbing and electrical systems, or replacing or adding new kitchen counter and similar furniture, plumbing fixture to the building are excluded for the purposes of establishing scope of Tier 1 projects.

The area of alteration should be limited to the footprint of element(s) being altered.

This does not exclude mandatory CALGreen measures. The sum of the footprint of the elements being altered with respect to Tier 1, shall be calculated using the following methodology:

1. Raising the plate height: The calculation with respect to raising of the plate height will be based on the area of the footprint in which the plate height is being increased. Plate height means the vertical distance measured from the top of the finished floor to the top of the plates.

2. Historic restoration: The calculation with respect to historic restoration will be based on the area of work covered in the California Historical Building Code (Title 24, Part 8).

3. Structural parts or elements: The calculation with respect to changes or rearrangements of the structural parts or
elements will be based on the sum of the individual footprints of each structural change or rearrangement. The footprint shall be calculated based on the proposed design and inclusive of any demolished structural parts or elements.

4. Bearing walls and full height partition: The calculation with respect to changes or rearrangement of walls and full height partitions will be based on the footprint of any demolished wall or full height partition and any new wall or new full height partition.

Exception: Attached and detached Accessory Dwelling Units, ADU conversions of existing structures shall meet the California Green Building Standards Code Mandatory measures only.
301.1.2 Substantial Remodel (50‐50‐50 rule). Any project that affects the removal or replacement of 50% or more linear length of the existing exterior walls of the building, 50% or more linear length of the existing exterior wall where the plate height is raised, or 50% or more of the existing roof framing area is removed or replaced, over a 3‐year period is considered a substantial remodel.

Any permit(s) applied for will trigger a review of a 3‐year history of the project.

This review will result in determining if a substantial remodel has occurred.

The Chief Building Official or designee shall make the final determination Item 15
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regarding the application if a conflict occurs.

[…]
301.2 Low‐rise and high‐rise residential buildings. [HCD] The provisions of individual sections of CALGreen may apply to either low‐rise residential buildings, high‐rise residential buildings, or both. Individual sections will be designated by banners to indicate where the section applies specifically to low‐rise only (LR) or high‐rise only (HR). When the section applies to both low‐rise and high‐rise buildings, no banner will be used.

301.2.1 Low‐Rise residential new construction – Tier 2 adopted. All new constructed or substantial remodel projects must meet CALGreen Mandatory plus Tier 2 measures, as amended by this ordinance and as applicable to the scope of work.
301.3 Nonresidential additions and alterations. [BSC‐CG] The provisions of individual sections of Chapter 5 apply to building nonresidential additions of 1,000 square feet or greater, and/or building alterations with a permit valuation of $200,000 or above (for occupancies within the authority of California Building Standards Commission). Code sections relevant to additions and alterations shall only apply to the portions of the building being added or altered within the scope of the permitted work.

A code section will be designated by a banner to indicate where the code section only applies to newly constructed buildings [N] or to additions and alterations [A]. When the code section applies to both, no banner will be used.

Tier 1 adopted. Nonresidential alterations (including tenant improvements or renovations) of 5,000 square feet that include replacement of at least two of the following: HVAC system, building envelope, hot water system, or lighting system, must comply with CALGreen Mandatory plus Tier 1 measures, as amended by this Chapter and as applicable to the scope of work.

Tier 1 alternative compliance path. Nonresidential alterations projects that would otherwise be subject to CALGreen Mandatory plus Tier 1 measures may elect an alternative compliance pathway by achieving LEED® Silver certification or higher from the U.S. Green Building Council. The Green Business Certification Inc. (GBCI™) shall serve as the independent third‐party certification body responsible for reviewing project documentation, conducting compliance verification, and issuing official LEED® certification. Projects electing this pathway are exempt from all individual Tier 1 CALGreen prerequisite and Item 15
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elective requirements with exception of the following:

PAMC 16.14.430 Section A5.408 Construction Waste
Reduction, Disposal and Recycling.

Projects must maintain compliance with all applicable base CALGreen mandatory measures and building code requirements.

Tier 2 adopted. Nonresidential additions of 1000 square feet or greater must comply with CALGreen Mandatory plus Tier 2 measures, as amended by this Chapter and as applicable to the scope of work.

Tier 2 alternative compliance path. Nonresidential additions of 1000 square feet or greater that would otherwise be subject to CALGreen Mandatory plus Tier 2 measures may elect an alternative compliance pathway by achieving LEED® Gold certification or higher from the U.S. Green Building Council. The Green Business Certification Inc. (GBCI™) shall serve as the independent third‐party certification body responsible for reviewing project documentation, conducting compliance verification, and issuing official LEED® certification.

Projects electing this pathway are exempt from all individual Tier 2 CALGreen prerequisite and elective requirements with exception of the following:

PAMC 16.14.430 Section A5.408 Construction Waste
Reduction, Disposal and Recycling.

Projects must maintain compliance with all applicable base CALGreen mandatory measures and building code
requirements.

301.3.1 ‐ 301.3.2 Unmodified

301.3.3 Nonresidential new construction – Tier 2 adopted. All new nonresidential construction must meet CALGreen Mandatory plus Tier 2 measures (including initial occupancy tenant improvements), as amended by this ordinance and as applicable to the scope of work.

Tier 2 alternative compliance path. All new nonresidential construction that would otherwise be subject to CALGreen Mandatory plus Tier 2 measures may elect an alternative compliance pathway by achieving LEED® Gold certification or higher from the U.S. Green Building Council. The Green Business Certification Inc. (GBCI™) shall serve as the independent third‐party certification body responsible for Item 15
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reviewing project documentation, conducting compliance verification, and issuing official LEED® certification. Projects electing this pathway are exempt from all individual Tier 2 CALGreen prerequisite and elective requirements with exception of the following:

PAMC 16.14.430 Section A5.408 Construction Waste
Reduction, Disposal and Recycling.

PAMC 16.14.400 Section A5.106.5.3 Electric Vehicle (EV) Charging for New Construction.

Projects must maintain compliance with all applicable base CALGreen mandatory measures and building code requirements.
301.6 Special inspector requirements. Residential and nonresidential project owners subject to CALGreen Mandatory, CALGreen Mandatory plus Tier 1, or CALGreen Mandatory plus Tier 2 measures shall contract a City‐approved Green Special Inspector (GBSI) in accordance with section 702.2 of CALGreen, as amended.

A City‐approved GBSI is required to verify compliance with CALGreen mandatory measures when the project elects to use the alternative LEED compliance pathway per section 301.3 and 301.3.3 of this Chapter. A LEED Accredited Professional with applicable specialty (LEED AP) shall certify that the project has been designed to meet the requirements for LEED Silver or LEED Gold certification, as applicable. The LEED AP shall provide two letters to certify the alternative compliance pathway:

1. At Building Permit Application – A letter confirming that said project has been registered with the U.S. Green Building Council (USGBC) and is anticipated to achieve the required number of points for the specified certification level.

2. Prior to any Approved Occupancy ‐ A letter based on the actual construction confirming that the project has been built in accordance with the approved plans and is expected to be eligible for certification at the approved LEED level. This letter must also state whether, and when, the final submittal certification documents will be submitted to the USGBC.

Provide proof of LEED Silver/Gold Certification to the Building Department within two years of initial occupancy as part of the project record.

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301.7 Low‐carbon concrete requirements for Tier 1 and Tier 2 projects.

Plain and reinforced concrete installed as part of any project subject to the application of this code shall demonstrate compliance with the requirements of PAMC 16.14.240.

Part 5 – Local Modifications to CHAPTER 4 – RESIDENTIAL MANDATORY

MEASURES
Division 4.1 – PLANNING AND DESIGN

16.14.090 Section 4.106.5 Full Electrification
Section 4.106 of Chapter 4 of the California Green Building Standards Code is amended to add new subsection, 4.106.5 as follows:

4.106.5 Full electrification. Full electrification is recommended for new buildings, substantial remodels, and new outdoor appliances/equipment such as fireplaces, firepits, heaters for swimming pool/spa, and similar equipment. Full electrification is required for outdoor grills, stoves, and barbecues. This subsection does not prohibit freestanding and/or portable grills, stoves, or barbecues whose sole source of energy is self‐contained fuel canisters.

Division 4.3 – WATER EFFICIENCY AND CONSERVATION

16.14.100 Section 4.306 Swimming Pool and Spa Covers
Section 4.306 of Chapter 4 of the California Green Building Standards Code is added to read:

4.306 Swimming pool and spa covers. Swimming pools and spas shall be provided with a vapor retardant cover.

Part 6 – Local Modifications to CHAPTER 7 – INSTALLER AND SPECIAL INSPECTOR

QUALIFICATIONS

16.14.120 Section 702.2 Special Inspection.

Section 702.2 of Chapter 7 of the California Green Building Standards Code is amended to read:
702.2 Green building special inspection. When required by the enforcing agency, the owner or responsible entity acting as the owner’s agent shall employ one or more Green Building Special Inspectors to provide inspection or other duties necessary to substantiate compliance with this Item 15
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code. Green Building Special Inspectors shall demonstrate competence to the satisfaction of the enforcing agency for the particular type of inspection or task to be performed. In addition to other certifications or qualifications acceptable to the enforcing agency, the following certifications or education may be considered by the enforcing agency when evaluating the qualifications of a Special Inspector. The City shall maintain a list of pre‐approved Special Inspectors in accordance with this section. The owner shall contract a Special Inspector from the pre‐ approved list meeting one of the following:

1. Certification by a national or regional green building program:

ICC Certified CALGreen Inspector/Plans Examiner

2. Other programs acceptable to the enforcing agency.

Note: Special Inspectors shall be independent entities with no financial interest in the materials or the project they are inspecting for compliance with this code.

Part 7– Local Modifications to APPENDIX A4 – RESIDENTIAL VOLUNTARY

MEASURES
Division A4.1 – PLANNING AND DESIGN

16.14.130 Residential Projects. Appendix A4 Preface: Green Building Measures for Project Type and Scope.

A preface is added to Chapter A4 of the California Green Building Standards Code to read:

Preface ‐ Green Building Requirements for Project Type and Scope. For design and construction of residential projects, the City of Palo Alto requires compliance with the mandatory measures of Chapter 4, in addition to use of Tier 1 and Tier 2 as specified in Palo Alto Municipal Code Chapter 16.14. See Section 202 for definitions on CALGreen Mandatory, Tier 1 Prerequisites and Electives, and Tier 2 Prerequisites and Electives.

All elective measures are adopted as written under Appendix A4 unless otherwise indicated in this Section.

16.14.140 Section A4.104 SITE PRESERVATION.

Section A4.104.1 of Appendix A4 of the California Green Building Standards Code is adopted as a Tier 1 and Tier 2 elective measure and is amended to read:

A4.104.1 Supervision and education by a special inspector. Individuals with oversight authority on the project, as defined in section 16.14.120 of this code, who have been trained in areas related to environmentally Item 15
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friendly development, shall teach green concepts to other members of the builder’s staff and ensure training and written instruction has been provided to all parties associated with the development of the project.

Prior to the beginning of the construction activities, the builder shall receive a written guideline and instruction specifying the green goals of the project.

Note: Lack of adequate supervision and dissemination of the project goals can result in negative effects on green building projects. If the theme of green building is not carried through the project, the overall benefit can be substantially reduced by the lack of knowledge and information provided to the various entities involved with the construction of the project.

16.14.150 Section A4.105 Deconstruction and Reuse of Existing Materials.

Section A4.105 of Appendix A4 of the California Green Building Standards Code is not adopted as an elective measure and is amended to read:

Section A4.105.1 Chapter 5.24 of Title 5 of the Municipal Code. See Chapter 5.24 of the Municipal Code for the local deconstruction requirements.

Section A4.105.2 is adopted as a Tier 1 and Tier 2 elective measure.

A4.105.2 Reuse of materials. Nonhazardous materials which can be easily reused include but are not limited to the following:

1. Light fixtures

2. Plumbing fixtures

3. Doors and trim

4. Masonry

5. Electrical devices

6. Appliances

7. Foundations or portions of foundations
Note: Reused material must be installed to comply the appropriate Title 24 provisions.

16.14.160 Section A4.106.8 Electric Vehicle (EV) Charging for New Construction.

Sections A4.106.8 – A4.106.8.2.2 of the California Green Building Standards Code are deleted in its entirety, adopted as mandatory measures and is Item 15
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amended to read:

A4.106.8 Electric vehicle (EV) charging for residential structures. Newly constructed single‐family and multi‐family residential structures, including residential structures constructed as part of a mixed‐use development, shall comply with the following requirements for electric vehicle supply equipment (EVSE). All parking space calculations under this section shall be rounded up to the next full space. The requirements stated in this section are in addition to those contained in Section 4.106.4 of the California Green Building Standards Code. In the event of a conflict between this section and Section 4.106.4 of the California Green Building Standards Code, the more robust EV Charging requirements shall prevail.

A4.106.8.1 New single‐family, duplex and townhouse dwellings. The following standards apply to newly constructed detached and attached single‐family, duplex and townhouse residences.
( a ) In general. The property owner shall provide One (1) Level 2 electrical vehicle supply equipment (EVSE) or one (1) EV ready space for each residence (except for accessory dwelling unit (ADU)).
( b ) Location. The proposed location of a charging station may be internal or external to the dwelling and shall be in close proximity to an on‐site parking space consistent with city regulations.

A4.106.8.2 New multi‐family dwellings. In addition to the applicable standards in the 2025 California Green Building Standards Code, the following standards apply to newly constructed residences in a multi‐ family residential structure.
(a) Resident parking. The property owner shall provide at least one (1) Level 2 electrical vehicle supply equipment (EVSE) or one (1) Level 2 EV Ready space for each residential unit in the structure . (b) Location. The EVSE, receptacles, and/or raceway required by this section shall be placed in locations allowing convenient installation of and access to EVSE. In addition, if parking is deed‐restricted to individual residential units, the EVSE or receptacles required by subsection (a) shall be located such that each unit has access to its own EVSE or receptacle. Location of EVSE or receptacles shall be consistent with all city regulations.

A4.106.8.3 New hotels and motels. The following standards apply to newly constructed hotels.

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(a) In general. The property owner shall comply with Section

4.106.4.2.6 of the California Green Building Standards Code. (b) Location. The EVSE and/or receptacles, required by this section shall be placed in locations allowing convenient installation of and access to EVSE. Location of EVSE or receptacles shall be consistent with all City guidelines, rules, and regulations.

16.14.170 Section A4.106.9 Bicycle Parking.

Section A4.106.9 of Appendix A4 of the California Green Building Standards Code is not adopted as a Tier 1 and Tier 2 elective measure. Projects must comply with the bicycle parking requirements in the Palo Alto Municipal Code.

16.14.180 Section A4.106.10 Light Pollution Reduction.

Section A4.106.10 is added and adopted as a Tier 1 and Tier 2 elective measure for all covered projects and is amended to read:

A4.106.10 Light pollution reduction. Outdoor lighting systems shall be designed and installed to comply with the following:

1. The minimum requirements in the California Energy Code for Lighting Zones 1‐4 as defined in Chapter 10 of the California Administrative Code; and

2. Backlight, Up light and Glare (BUG) ratings as defined in IES TM‐15‐11; and

3. Allowable BUG ratings not exceeding those shown in TABLE 5.106.8 [N]; or
Comply with a local ordinance lawfully enacted pursuant to Section 101.7 of this code, whichever is more stringent.

Projects may use an approved equal reference standard for light fixtures where BUG ratings are unavailable.

Exceptions:

1. Luminaires that qualify as exceptions to the California Energy Code.

2. Emergency lighting.

3. One‐ and two‐family dwellings.

Note: The International Dark‐Sky Association (IDA) and the Illuminating Engineering Society of North America (IESNA) have developed a Model Lighting Ordinance (MLO). The MLO was designed to help municipalities develop outdoor lighting standards that reduce glare, light trespass, and skyglow. The model ordinance and user guides for the ordinance may be accessed at the International Dark‐Sky Association web site.

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Division A4.2 – ENERGY EFFICIENCY

16.14.190 Section A4.203.1 Performance Approach for Newly Constructed Buildings.

Section A4.203.1 of Appendix A4 of the California Green Building Standards Code is not adopted as a Tier 1 and Tier 2 elective measure. Projects shall comply with Chapter 16.17 of the Palo Alto Municipal Code (California Energy Code).

Division A4.3 – WATER EFFICIENCY AND CONSERVATION

16.14.200 Section A4.304.3 Irrigation Metering Device.

Section A4.304.3 of Appendix A4 of the California Green Building Standards Code is adopted as a Tier 1 and Tier 2 elective measure and is amended to read:

A4.304.3 Irrigation metering device. Dedicated irrigation meters from CPAU are to be installed in all new construction and rehabilitated landscapes when the landscape is greater than 1,000 square feet.

16.14.210 Section A4.305 Water Reuse Systems.

Sections A4.305.1, A4.305.2, and A4.305.3 of Appendix A4 of the California Green Building Standards Code are adopted as Tier 1 and Tier 2 elective measures and are amended to read:

A4.305.1 Graywater. Alternative plumbing piping is installed to permit the discharge from the clothes washer and other fixtures (except toilets and kitchen sinks) to be used for an irrigation system in compliance with the California Plumbing Code. In the event that the whole house graywater system is installed in compliance with the California Plumbing Code, then this measure shall count as 3 electives.

A4.305.2 Recycled water piping. Based on projected availability, dual water piping is installed for future use of recycled water at the following locations:

1. Interior piping for the use of recycled water is installed to serve all water closets, urinals, and floor drains.

2. Exterior piping is installed to transport recycled water from the point of connection to the structure. Recycled water systems shall be designed and installed in accordance with the California Plumbing Code.

A4.305.3 Recycled water for landscape irrigation. Recycled water piping is used for landscape irrigation.

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16.14.220 A4.305.4 Additions and Alterations.

Section A4.305.4 is added as Tier 1 and Tier 2 prerequisite to read:

A4.305.4 Additions and alterations. All multi‐family residential additions and alterations must install recycled water infrastructure for irrigation when the landscape area exceeds 1,000 square feet.

Division A4.4 – MATERIAL CONSERVATION AND RESOUCE EFFICIENCY

16.14.230 Section A4.403.1 Frost Protection Foundation Systems.

Sections A4.403.1 is not adopted as a Tier 1 and Tier 2 elective measure.

16.14.240 Section A4.403.2 Reduction in cement use.

Section A4.403.2 of Appendix A4 of the California Green Building Standards Code is adopted as a Mandatory measure for all Tier 1 and Tier 2 projects and is amended to read:

A4.403.2 Low carbon concrete requirements.

A4.403.2.1 Purpose. The purpose of this chapter is to provide practical standards and requirements for the composition of concrete, as defined herein, that maintains adequate strength and durability for the intended application and at the same time reduces greenhouse gas emissions associated with concrete composition. This code includes pathways for compliance with either reduced cement levels or lower‐emission supplementary cementitious materials.

A4.403.2.2 Definitions. For the application of this section the following definitions shall apply:

Concrete. Concrete is any approved combination of mineral aggregates bound together into a hardened conglomerate in accordance with the requirements of this code.

Environmental product declaration (EPD). EPDs present quantified environmental information on the life cycle of a product to enable comparisons between products fulfilling the same function. EPDs must conform to ISO 14025, and EN 15804 or ISO 21930, and have at least a "cradle to gate" scope (which covers product life cycle from resource extraction to the factory).

Upfront embodied carbon (embodied carbon). The greenhouse gasses emitted in material extraction, transportation and manufacturing of a material corresponding to life cycle stages A1 (extraction and upstream Item 15
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production), A2 (transportation), and A3 (manufacturing). Definition is as noted in ISO 21930 and as defined in V2.3 Product Category Rule for Concrete by NSF dated November 2023.
https://d2evkimvhatqav.cloudfront.net/documents/PCR‐Product‐Category‐Rules/PCR‐ Concrete‐2023‐deviation.pdf https://d2evkimvhatqav.cloudfront.net/documents/PCR‐Product‐ Category‐Rules/PCR‐Concrete‐2023‐deviation.pdf?v=1701797590

A4.403.2.3 Compliance. Compliance with the requirements of this chapter shall be demonstrated through any of the compliance options in Sections A4.403.2.3.2 through A4.403.2.3.5:

TABLE A4.403.2.3 Cement and Embodied Carbon Limit
Pathways

A4.403.2.3.1 Allowable increases.
(1) Cement and Embodied Carbon Limit Allowances. Cement or Embodied Carbon limits shown in Table A4.403.2.3 can be increased by 30% for concretes demonstrated to the Building Official as requiring high early strength. Such concretes could include, but are not limited to, precast, prestressed concrete; beams and slabs above grade; and shotcrete (2) Approved Cements. The maximum cement content may be increased proportionately above the tabulated value when using an approved cement, or blended cement, demonstrated by approved EPD to have a plant‐specific EPD lower than 1040 kg CO2e/metric ton. The increase in allowable cement content would be (1040 / plant=specific EPD) %.

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A4.403.2.3.2 Cement limit method — mix. Cement content of a concrete mix using this method shall not exceed the value shown in the Table A4.403.2.3. Use of this method is limited to concrete with specified compressive strength not exceeding 5,000 psi.

A4.403.2.3.3 Cement limit method — project. Total cement content shall be based on total cement usage of all concrete mix designs within the same project. Total cement content for a project shall not exceed the value calculated according to Equation A4.403.2.3.3.

Equation A4.403.2.3.3:

Cem proj < Cem allowed
where
Cem proj = ΣCem n v n and Cem allowed = ΣCem lim v n
and
n = the total number of concrete mixtures for
the project Cem n = the cement content for
mixture n , kg/m 3 or lb/yd 3
Cem lim = the maximum cement content for mixture n per Table A4.403.2.3, kg/m 3 or lb/yd 3
v n = the volume of mixture n concrete to be placed, yd 3 or m 3 Applicant can use yd 3 or m 3 for calculation, but must keep same units throughout
A4.403.2.3.4. Embodied carbon method — mix. Embodied carbon of a concrete mix, based on an approved environmental product declaration (EPD), shall not exceed the value given in Table A4.403.2.3.

A4.403.2.3.5. Embodied carbon method — project. Total embodied carbon (EC proj ) of all concrete mix designs within the same project shall not exceed the project limit (EC allowed ) determined using Table A4.403.2.3 and Equation A4.403.2.3.5.

Equation A4.403.2.3.5:

EC proj < EC allowed
where
EC proj = ΣEC n v n and EC allowed = ΣEC lim v n
and
n = the total number of concrete mixtures for the project Item 15
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EC n = the embodied carbon potential for mixture n per mixture EPD, kg/m 3 EC lim = the embodied carbon potential limit for mixture n per Table A4.403.2.3, kg/m3 v n = the volume of mixture n concrete to be placed, yd 3 or m 3
Applicant can use yd 3 or m 3 for calculation, but must keep same units throughout.

A4.403.2.3.6. Enforcement.

As a condition prior to the issuance of every building permit involving placement of concrete, the permit applicant shall be required to submit a completed low‐carbon concrete compliance form or other acceptable methods that shall be provided by and reviewed for compliance by the building department prior to issuing the permit.

As a condition of such building permits, and prior to approving construction inspections following placement of concrete, the permit applicant shall be required to submit batch certificates and/or EPDs provided by the concrete provider that demonstrate compliance with the low‐carbon concrete compliance form on file with the building permit. The batch certificates and/or EPDs shall be reviewed for compliance by the building department prior to approving any further inspections.

When deviations from compliance with this section occur, the chief building official or his designee is authorized to require evidence of equivalent carbon reductions from the portions of remaining construction of the project to demonstrate alternative compliance with the intent of this chapter.

For projects involving placement of concrete by, or on behalf of, a public works, parks, or similar department the director of such department, or his/her assignee, shall maintain accurate records of the total volume (in cubic yards) of all concrete placed, as well as the total compliant volume (in cubic yards) of all concrete placed, and shall report this data annually to the governing body in a form expressing an annual compliance percentage derived from the quotient of total compliant concrete volume placed divided by total concrete volume placed.

A4.403.2.3.7. Exemptions.
(a) Hardship or infeasibility exemption. If an applicant for a project subject to this chapter believes that circumstances exist that make it a hardship or infeasible to meet the requirements of this chapter, the applicant may request an exemption as set forth below. In applying for an exemption, the burden is on the applicant to show hardship or infeasibility. The applicant shall identify in writing the specific requirements of the standards for compliance that the project is unable to achieve and the circumstances that Item 15
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make it a hardship or infeasible for the project to comply with this chapter.

Circumstances that constitute hardship or infeasibility may include, but are not limited to the following:
(1) There is a lack of commercially available material necessary to comply with this chapter;
(2) The cost of achieving compliance is disproportionate to the overall cost of the project;
(3) Compliance with certain requirements would impair the historic integrity of buildings listed on a local, state or federal list or register of historic structures as regulated by the California Historic Building Code (Title 24, Part 8).
(b) Granting of exemption. If the chief building official determines that it is a hardship or infeasible for the applicant to fully meet the requirements of this chapter and that granting the requested exemption will not cause the building to fail to comply with the California Building Standards Code, the chief building official shall determine the maximum feasible threshold of compliance reasonably achievable for the project. In making this determination, the chief building official shall consider whether alternate, practical means of achieving the objectives of this chapter can be satisfied.

If an exemption is granted, the applicant shall be required to comply with this chapter in all other respects and shall be required to achieve the threshold of compliance determined to be achievable by the chief building official.
(c) Denial of exception. If the chief building official determines that it is reasonably possible for the applicant to fully meet the requirements of this chapter, the request shall be denied and the applicant shall be notified of the decision in writing. The project and compliance documentation shall be modified to comply with the standards for compliance.

16.14.250 Section A4.408.1 Enhanced Construction Waste Reduction.

Section A4.408.1 of Appendix A4 of the California Green Building Standards Code is adopted as a mandatory measure and is amended to read:

A4.408.1 Enhanced construction waste reduction. Nonhazardous construction and demolition debris generated at the site is diverted to recycle or salvage in compliance with the following:

Projects with a given valuation of $25,000 or more must have at least an 80‐percent reduction. Any mixed recyclables that are sent to mixed‐waste recycling facilities shall include a qualified third party verified facility average diversion rate. Verification of diversion rates shall meet minimum certification eligibility guidelines, acceptable to the local enforcing agency.

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Exceptions:

1. Residential stand‐alone mechanical, electrical or plumbing permits.

2. Commercial stand‐alone mechanical, electrical or plumbing permits.

A4.408.1.1 Documentation. Documentation shall be provided to the enforcing agency which demonstrates compliance with all construction and demolition waste reduction requirements.

Division A4.5 – ENVIRONMENTAL QUALITY

16.14.260 Section A4.504.1 Compliance with Formaldehyde Limits.

Section A4.504.1 of Appendix A5 of the California Green Building Standards Code is adopted as a Tier 1 and Tier 2 elective measure.

16.14.270 Section A4.504.3 Thermal Insulation.

Section A4.504.3 of Appendix A5 of the California Green Building Standards Code is not adopted as a Tier 1 and Tier 2 prerequisite. Section A4.504.3 is adopted as a Tier 1 and Tier 2 elective measure.

Part 8 – Local Modifications to CHAPTER 5 – NONRESIDENTIAL MANDATORY

MEASURES
Division 5.1 – PLANNING AND DESIGN

16.14.280 Nonresidential Projects: Chapter 5 Preface Green Building Requirements for Project Type and Scope.

A Preface is added to Chapter 5 of the California Green Building Standards Code to read:

Preface – Green Building Requirements for Project Type and Scope. For design and
construction of nonresidential projects, the City requires compliance with the mandatory measures of Chapter 5, in addition to use of Tier 1 and Tier 2 as specified in Palo Alto Municipal Code Chapter 16.14. See Section 202 for definitions on CALGreen MANDATORY, Tier 1 prerequisites and electives, and Tier 2 prerequisites and electives. All elective measures are adopted as written under Appendix A5 unless otherwise indicated in this Section.

16.14.285 Section 5.105.1 Scoping
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Section 5.105.1 of Chapter 5 of the California Green Building Standards Code is amended to read:

5.105.1 Scope. [BSC‐CG] Effective July 1, 2024, alteration(s) to existing building(s) where the combined altered floor area is 100,000 square feet or greater shall comply with either Section 5.105.2, 5.409.2, or 5.409.3.

Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 100,000 square feet or greater shall comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3.

Effective January 1, 2026, the combined floor area shall be 25,000 square feet or greater.

Exception [BSC‐CG, DSA‐SS]: Combined addition(s) to existing building(s) of two times the area or more of the existing building(s) is not eligible to meet compliance with Section 5.105.2.

16.14.290 Section 5.106.1.1 Local ordinance.

Section 5.106.1.1 of Chapter 5 of the California Green Building Standards Code is amended to read:

5.106.1.1 Local ordinance. Newly constructed projects and additions shall comply with additional City of Palo Alto stormwater runoff management and pollution prevention measures as applicable, and as may be amended from time to time.

16.14.295 Section 5.106.8 Light Pollution Reduction.

Section 5.106.8 of Chapter 5 of the California Green Building Standards Code is amended to read:

5.106.8 Light pollution reduction. Outdoor lighting systems shall be designed and installed to comply with the following:

1. The minimum requirements in the California Energy Code for Lighting Zones 0‐4 as defined in Chapter 10, Section 10‐114 of the California Administrative Code; and

2. Backlight (B) ratings as defined in IES TM‐15‐11 (shown in Table A‐1 in Chapter 8);

3. Uplight and Glare ratings as defined in California Energy Code (shown in Tables 130.2‐A and 130.2‐B in Chapter 8); and

4. Allowable BUG ratings not exceeding those shown in Table 5.106.8 [N]; or Comply with a local ordinance lawfully enacted pursuant to Item 15
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Section 101.7, whichever is more stringent.

Projects may use an approved equal reference standard for light fixtures where BUG ratings are unavailable.

Exceptions:

1. Luminaires that qualify as exceptions in Section 103.2(b) and 140.7 of the California Energy Code.

2. Emergency lighting.

3. Building facade meeting the requirements in Table 140.7‐B of the California Energy Code, Part 6.

4. Custom lighting features as allowed by the local enforcing agency, as permitted by Section 101.8 Alternate materials, designs and methods of construction.

5. Luminaires with less than 6,200 initial luminaire lumens.

16.14.300 Section 5.106.13 Full Electrification.

Section 5.106 of Chapter 4 of the California Green Building Standards Code is amended to add new subsection, 5.106.13 as follows:

5.106.13 Full electrification. Full electrification is recommended for new buildings, substantial remodels, and new outdoor appliances/equipment such as fireplaces, firepits, heaters for swimming pool/spa, and similar equipment. Full electrification is required for outdoor grills, stoves, and barbecues. This subsection does not prohibit freestanding and/or portable grills, stoves, and barbecues whose source of energy is self‐contained fuel canisters.

16.14.310 Reserved

16.14.320 Reserved
Division 5.3 – WATER EFFICIENCY AND CONSERVATION

16.14.330 Section 5.304.2 Invasive Species Prohibited.

Section 5.304.2 of Chapter 5 of the California Green Building Standards Code is added as mandatory measure to read:

5.304.2 Invasive species prohibited. All nonresidential new construction, additions, and alterations shall not install invasive species in a landscape area of any size.

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16.14.340 Section 5.306 Nonresidential Enhanced Water Budget.

Section 5.306 of Chapter 5 of the California Green Building Standards Code is added as mandatory measure to read:

5.306 Nonresidential enhanced water budget. Nonresidential buildings anticipated to use more than 1,000 gallons of water a day shall complete an Enhanced Water Budget Calculator as established by the Chief Building Official or designee.

16.14.350 Section 5.307 Cooling Tower Water Use.

Section 5.307 Cooling Tower Water Use is added as mandatory to read:

5.307 COOLING TOWER WATER USE

5.307.1. Cooling tower water use in high rise residential or nonresidential buildings.

Cooling tower water use must meet the conditions as follows and as outlined in Palo Alto
Municipal Code Section 16.08.100. Projects are required to perform a potable water analysis at the site to meet the maximum concentration of parameters noted in Table 5.307.1

TABLE 5.307.1
Ca (as CaCO3) 600 ppm
Total alkalinity 500 ppm
SiO2 150 ppm
Cr 300 ppm
Conductivity 3300 Us/cm

Calculate maximum number of cycles that can be achieved with these levels of concentration shall be included in the plumbing design plans.

Division 5.4 – MATERIAL CONSERVATION AND RESOUCE EFFICIENCY

16.14.355 Section 5.409 Life Cycle Assessment
Section 5.409 of Chapter 5 of the California Green Building Standards Code is amended to read:

5.409.1 Scope. [BSC‐CG] Effective July 1, 2024, nonresidential projects consisting of newly constructed building(s) with a combined floor area of 100,000 square Item 15
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feet or greater shall comply with either Section 5.409.2 or Section 5.409.3.

Alteration(s) to existing building(s) where the combined altered floor area is 100,000 square feet or greater shall comply with either Section 5.105.2, 5.409.2, or 5.409.3. Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 100,000 square feet or greater shall comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3. Effective January 1, 2026, the combined floor area shall be 25,000 square feet or greater.

16.14.360 Section 5.410.4.6 Energy STAR Portfolio Manager.

Section 5.410.4.6 of Chapter 5 of the California Green Building Standards is added as mandatory measure to read:

5.410.4.6 Energy STAR portfolio manager. All nonresidential projects exceeding $100,000 valuation must provide evidence of an Energy STAR Portfolio Manager project profile for both water and energy use prior to Permit Issuance, acquire an Energy STAR Portfolio Manager Rating, and submit the rating to the City of Palo Alto once the project has been occupied after 12 months.

16.14.370 Section 5.410.4.7 Performance Reviews – Energy.

Section 5.410.4.7 of Chapter 5 of the California Green Building Standards is added to read:

5.410.4.7 Performance reviews – energy. All projects over 10,000 square feet. The City reserves the right to conduct a performance review, no more frequently than once every five years unless a project fails review, to evaluate the building's energy use to ensure that resources used at the building and/or site do not exceed the maximum allowance set forth in the rehabilitation or new construction design. Following the findings and recommendations of the review, the City may require adjustments to the energy usage or energy‐using equipment or systems if the building is no longer compliant with the original design. Renovation or rehabilitation resulting from such audit activity shall be considered a project and shall be subject to applicable documentation submittal requirements of the City. This section is effective only for those projects for which a building permit was issued after January 1, 2009.

16.14.380 Section 5.410.4.8 Performance Reviews – Water.

Section 5.410.4.8 of Chapter 5 of the California Green Building Standards is added to read:

5.410.4.8 Performance reviews – water. All sites greater than one acre:

The City reserves the right to conduct performance reviews, no more Item 15
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frequently than once every five years unless a project fails review, to evaluate water use to ensure that resources used at the building and/or site do not exceed a maximum allowance set forth in the rehabilitation or new construction design. Water use reviews may be initiated by CPAU, or as a coordinated effort between the CPAU and the Santa Clara Valley Water District (SCVWD), or as part of SCVWD's established water conservation programs. Following the findings and recommendations of the review, the City may require adjustments to irrigation usage, irrigation hardware, and/or landscape materials to reduce consumption and improve efficiency. Renovation or rehabilitation resulting from such audit activity shall be considered a project and shall be subject to applicable documentation submittal requirements of the City.

16.14.390 Section 5.506 Indoor Air Quality.

Section 5.506.4 of Chapter 5 of the California Green Building Standards is added as mandatory measure to read:

Section 5.506.4 Indoor air quality management plan. All commercial and multi‐ family projects must submit an Indoor Air Quality Management Plan (IAQ) with building permit application in accordance with the Sheet Metal and Air Conditioning Contractors National Association (SMACNA IAQ) Guidelines for Occupied Buildings Under Construction, 2nd edition ANSI/SMACNA 008‐2008.

Part 9 – Local Modifications to APPENDIX A5 – NONRESIDENTIAL VOLUNTARY

MEASURES
Division A5.1 – PLANNING AND DESIGN

16.14.400 Section A5.106.5.3 Electric Vehicle (EV) Charging for New Construction.

Section A5.106.5.3 – A5.106.5.3.4 of the California Green Building Standards Code are adopted as mandatory measures and amended to read:

A5.106.5.3 Electric vehicle (EV) charging for nonresidential structures.

New non‐ residential structures shall comply with the following requirements for electric vehicle supply equipment (EVSE). All parking space calculations under this section shall be rounded up to the next full space. The requirements stated in this section are in addition to those contained in Section 5.106.5.3 of the California Green Building Standards Code.

A5.106.5.3.1 Nonresidential structures other than hotels. The following standards apply to newly constructed nonresidential structures other than Item 15
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hotels.

Comply with Section 5.106.5.3.1 EV capable spaces, Section 5.106.5.3.2 Electric vehicle charging stations and associated Table A5.106.5.3.3, or Section A5.106.5.3.4 Electric vehicle charging stations (EVCS)—power allocation method and associated Table A5.106.5.3.4.

Refer to Section 5.106.5.3.2 for the permitted use of Level 2 or Direct Current Fast Charger (DCFC) to create EVCS. Refer to Section

5.106.3.2.1 for the allowed use of DCFC to comply with both EV capable spaces and Level 2 EVSE. Refer to Section 5.106.5.3.3 for the allowed use of Automatic Load Management System (ALMS).

Table A5.106.5.3.3—Tier 2 EV Capable Spaces and EVCS
Total Number of Actual
Parking Spaces
Number of
Required EV Capable
Spaces

Other than Office and
Retail
Number of Required EVCS
2, 3

Office and Retail
Number of Required EVCS
2, 3
1–9 3 2 2
10–25 8 4 6
26–50 17 9 13
51–75 28 14 21
76–100 40 20 30
101–150 57 29 43
151–200 79 40 59
201 and over 45 percent of actual
parking spaces1
50 percent of EV capable
spaces1
75 percent of EV capable
spaces1

1. Calculation for spaces shall be rounded up to the nearest whole number.

2. Each EVCS shall reduce the number of required EV capable spaces by the same number.

3. At least one Level 2 EVSE shall be provided.

Table A5.106.5.3.4—Tier 2 EVCS – Power Allocation Method Total Number of Actual
Parking Spaces
Minimum Total kVA
@ 6.6 kVA
Other than Office and
Retail
Total kVA Required
in any Combination of EV
Capable3,4, Low Power
Level 2
Level 21, 2, or DCFC
Office and Retail
Total kVA Required
in any Combination of EV
Capable3,4, Low Power
Level 2
Level 21, 2, or DCFC
1–9 19.8 19.8 19.8
10–25 52.8 52.8 52.8
26–50 112.2 112.2 112.2
51–75 184.8 184.8 184.8
76–100 264.0 264 264
101–150 376.2 376.2 376.2
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151–200 521.4 521.4 521.4
201 and over

45 percent of
actual parking spaces x

6.6 Total required kVA = P x
.45 x 6.6
Where P = Parking
spaces in facility

Total required kVA = P x
.45 x 6.6
Where P = Parking
spaces in facility

1. Level 2 EVSE @ 6.6 kVA minimum.

2. At least one Level 2 EVSE shall be provided.

3. Maximum allowed kVA to be utilized for EV capable spaces is 75 percent.

4. If EV capable spaces are utilized, they shall meet the requirements of Section 5.106.5.3.1 EV capable spaces.

5. For office and retail buildings the maximum allowed kVA to be utilized for EV capable spaces is 25 percent.

Location. The EVSE, receptacles, and/or raceway required by this section shall be placed in locations allowing convenient installation of and access to EVSE. Location of EVSE or receptacles shall be consistent with all city regulations.

Division A5.4 – ENERGY EFFICIENCY

16.14.410 Section A5.203.1 Performance Approach for Newly Constructed Buildings.

Section A5.203.1 of Appendix A5 of the California Green Building Standards Code is not adopted as a Tier 1 and Tier 2 elective measure. Projects shall comply with Chapter 16.17 of the Palo Alto Municipal Code (California Energy Code).

Division A5.4 – MATERIAL CONSERVATION AND RESOUCE EFFICIENCY

16.14.420 Section A5.405.5 Cement and Concrete.

Section A5.405.5 of Appendix A5 of the California Green Building Standards Code is adopted as a Mandatory measure for Tier 1 and Tier 2 projects and is amended to read:

A5.405.5 Cement and concrete. Use cement and concrete made with recycled products and complying with the following sections and requirements per PAMC Chapter 16.14.240.

16.14.430 Section A5.408 Construction Waste Reduction, Disposal and Recycling.

Section A5.408 of Appendix A5 of the California Green Building Standards Code is adopted as a Mandatory measure for Tier 2 projects and is amended to read:

A5.408.3.1 Waste enhanced construction waste reduction. (80% construction waste reduction) as a mandatory requirement for all nonresidential construction, including new construction, additions, and Item 15
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alterations, as long as the construction has a valuation of $25,000 or more. Nonresidential projects with a lower valuation shall remain subject to
California Green Building Standards Code Chapter 5 mandatory measures.

Exceptions:

1. Residential stand‐alone mechanical, electrical or plumbing permits.

2. Commercial stand‐alone mechanical, electrical or plumbing permits.

A5.408.3.1.1 ‐ Deleted

A5.408.3.1.2 Documentation. Documentation shall be provided to the enforcing agency which demonstrates compliance with all construction and demolition waste reduction requirements.

SECTION 3. The Council adopts the findings for local amendments to the California Green Building Standards Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.

SECTION 4. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

SECTION 5. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the amendments herein adopted will have a significant effect on the environment and Section 15308, because the amendments herein adopted is an action taken by the City to assure the maintenance, restoration, enhancement, or protection of the environment.

//

//

//

//

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SECTION 6. This Ordinance shall be effective on the thirty‐first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

City Clerk Mayor
APPROVED AS TO FORM: APPROVED:

City Attorney or Designee City Manager

Director of Planning and
Development Services

Director of Administrative Services
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Exhibit A

FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA GREEN BUILDING STANDARD CODE TITLE 24, PART 11

Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Green Building Standard Code, Title 24, Part 11 Chapter(s),
Sections(s),
Appendices
Title Add Deleted Amended Justification
(See below of keys)
101.4 Appendices  A, C, E
202 Definitions   A
301 Voluntary Tiers Added  C, E
301.1 Scope  C, E
301.1.1 Residential additions and alterations  C, E 301.1.2 Substantial Remodel (50‐50‐50 rule)  C, E
301.2 Low‐rise and high‐rise residential buildings  C, E 301.2.1 Low‐Rise residential new construction –
Tier 2 adopted
 C, E
301.3 Nonresidential additions and alterations  C, E 301.3.3 No‐residential new construction – Tier 2  C, E 301.6 Special inspector requirements  C, E
301.7 Low‐carbon concrete requirements for Tier
1 and Tier 2 projects
 C, E

4.106.5 Full Electrification 

C, E

4.306 Swimming pool and spa covers  C, E
702.2 Green building special inspection  C, E
A4.104.1 Supervision and education by a special
inspector
 C, E
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A4.105.1 Chapter 5.24 of Title 5 of the Municipal
Code
 C, E
A4.105.2 Reuse of materials  C, E
A4.106.8 Electric vehicle (EV) charging for
residential structures
 C, E
A4.106.8.1 New single‐family, duplex and townhouse
dwellings
 C, E
A4.106.8.2 New multi‐family dwellings.  C, E
A4.106.8.3 New hotels and motels  C, E
A4.106.9 Bicycle Parking  C, E
A4.106.10 Light pollution reduction  C, E
A4.203.1 Performance Approach for Newly
Constructed Buildings
 C, E
A4.304.3 Irrigation metering device  C, E
A4.305.1 Graywater  C, E
A4.305.2 Recycled water piping  C, E
A4.305.3 Recycled water for landscape irrigation  C, E A4.305.4 Additions and alterations   C, E
A4.403.1 Frost Protection Foundation Systems    C
A4.403.2 Reduction in cement use    C, E
A4.403.2.1 Purpose    C, E
A4.403.2.2 Definitions    C, E
A4.403.2.3 Compliance    C, E
Table
A4.403.2.3
Cement and Embodied Carbon Limit
Pathways
   C, E
A4.403.2.3.1 Allowable increases    C, E
A4.403.2.3.2 Cement limit method ‐ mix    C, E
A4.403.2.3.3 Cement limit method ‐ project    C, E
A4.403.2.3.4 Embodied carbon method ‐ mix    C, E
A4.403.2.3.5 Embodied carbon method ‐ project    C, E A4.403.2.3.6 Enforcement    A
A4.403.2.3.7 Exemptions    A
A4.408.1 Enhanced construction waste reduction    C, E A4.408.1.1 Documentation    A
A4.504.1 Compliance with Formaldehyde Limits    C, E A4.504.3 Thermal Insulation    C, E

5.105.1 Scoping    C, E

5.106.1.1 Local ordinance    C, E

5.106.8 Light pollution reduction    C, E

5.106.3 Full Electrification    C, E
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5.304.2 Invasive species prohibited    C

5.306 Nonresidential enhanced water
budget
   C, E

5.307.1 Cooling tower water use in high‐rise
residential or nonresidential buildings
   C, E

5.409.1 Scope     C, E

5.410.4.6 Energy STAR portfolio manager    C, E

5.410.4.7 Performance reviews – energy    C, E

5.410.4.8 Performance reviews – water    C, E

5.506.4 Indoor air quality management plan    E
A5.106.5.3 Electric vehicle (EV) charging for
nonresidential structures
   C, E
A5.106.5.3.1 Nonresidential structures other than hotels    C, E A5.203.1 Performance Approach for Newly
Constructed Buildings
   C, E
A5.405.5 Cement and concrete    C, E
A5.408.3.1 Waste enhanced construction waste
reduction
   C, E
A5.408.3.1.1 Enhanced construction waste reduction –
Tier 2
   A
A5.408.3.1.2 Documentation    A
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Key to Justification for Amendments to Title 24 of the California Code of Regulations

A This is an administrative amendment to clarify and establish civil and administrative procedures, regulations, or rules to enforce and administer the activities by the Palo Alto Building Inspection Department. These administrative amendments do not need to meet HSC 18941.5/17958/13869 per HSC 18909(c).

C This amendment is justified on the basis of a local climatic condition. The seasonal climatic conditions during the late summer and fall create severe fire hazards to the public health and welfare in the City. The hot, dry weather frequently results in wild land fires on the brush covered slopes west of Interstate 280. The aforementioned conditions combined with the geological characteristics of the hills within the City create hazardous conditions for which departure from California Building Standards Code is required. Natural gas combustion and gas appliances emit a wide range of air pollutants, such as carbon monoxide (CO), nitrogen oxides (NOx, including nitrogen dioxide (NO2)), particulate matter (PM), and formaldehyde, which according to a UCLA Study, have been linked to various acute and chronic health effects, and additionally exceed levels set by national and California‐based ambient air quality standards. The burning of fossil fuels used in the generation of electric power and heating of buildings contributes to climate change, which could result in rises in sea level, including in San Francisco Bay, that could put at risk Palo Alto homes and businesses, public facilities, and Highway 101 (Bayshore Freeway), particularly the mapped Flood Hazard areas of the City. Energy efficiency is a key component in reducing GHG emissions, and construction of more energy efficient buildings can help Palo Alto reduce its share of the GHG emissions that contribute to climate change. All‐electric new buildings benefit the health, safety, and welfare, of Palo Alto and its residents. Requiring all‐electric construction, without gas infrastructure will reduce the amount of greenhouse gas produced in Palo Alto and will contribute to reducing the impact of climate change and the associated risks. Due to decrease in annual rain fall, Palo Alto experiences the effect of drought and water saving more than some other communities in California. Embodied carbon of concrete is a significant contributor to greenhouse gas emissions and climate change, and this amendment includes a requirement to use low‐carbon concrete. Providing additional capacity for electric vehicle use reduces use of gasoline which is a major contributor to climate change.

E Green building enhances the public health and welfare by promoting the environmental and economic health of the City through the design, construction, maintenance, operation and deconstruction of buildings and sites by incorporating green practices into all development. The green provisions in this Chapter are designed to achieve the following goals:
(a) Increase energy efficiency in buildings;
(b) Reduce the use of natural gas in buildings which improves indoor environmental quality and health;
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(c) Reduce the use of natural gas which will reduce the natural gas infrastructure and fire risk over time;
(d) Reduce the embodied carbon of concrete which reduces greenhouse gas emissions;
(e) Increase water and resource conservation;
(f) Reduce waste generated by construction and demolition projects; (g) Provide durable buildings that are efficient and economical to own and operate; (h) Promote the health and productivity of residents, workers, and visitors to the city; (i) Recognize and conserve the energy embodied in existing buildings; (j) Increase capacity for use of electric vehicles which reduces greenhouse gas emissions and improves air quality;
(k) Encourage alternative transportation; and
(l) Reduce disturbance of natural ecosystems.

G This amendment is justified on the basis of a local geological condition. The City of Palo Alto is subject to earthquake hazard caused by its proximity to San Andreas fault. This fault runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel Rock. This is the approximate location of the epicenter of the 1906 San Francisco earthquake. The other fault is Hayward Fault. This fault is about 74 mi long, situated mainly along the western base of the hills on the east side of San Francisco Bay. Both of these faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area which includes these earthquake faults, the modifications and changes cited herein are designed to better limit property damage as a result of seismic activity and to establish criteria for repair of damaged properties following a local emergency. Reduction or eliminating of natural gas infrastructure over time will reduce maintenance costs and fire risk in difficult geological conditions.

T The City of Palo Alto topography includes hillsides with narrow and winding access, which makes timely response by fire suppression vehicles difficult. Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and waste water run‐off.

Also, the City of Palo Alto is located in an area that is potentially susceptible to liquefaction during a major earthquake. The surface condition consists mostly of stiff to dense sandy clay, which is highly plastic and expansive in nature. The aforementioned conditions within the City create hazardous conditions for which departure from California Building Standards Code is warranted. In addition, the reduction or elimination of natural gas infrastructure reduces the likelihood of fire or environmental damage should they become disrupted due to challenging topographic conditions during construction or repair.

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Ordinance No.

Ordinance of the Council of the City of Palo Alto Repealing Chapter

16.16 of the Palo Alto Municipal Code and Amending Title 16 to Adopt a New Chapter 16.16, California Electrical Code, 2025 Edition, and Local Amendments and Related Findings

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Chapter 16.16 of the Palo Alto Municipal Code is hereby amended by repealing in its entirety 16.16 and adopting a new Chapter 16.16 to read as follows:

CHAPTER 16.16

CALIFORNIA ELECTRICAL CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 3

Sections

16.16.010 2025 California Electrical Code, Title 24, Part 3 adopted and amended.

16.16.020 Cross - References to California Electrical Code.

16.16.030 Local Amendments.

16.16.040 Adoption of SECTION 89.101 GENERAL.

16.16.050 Article 89.101.3.3 Exempted from This Code.

16.16.060 Article 89.101.4 2025 California Electrical Code Annexes adopted.

16.16.070 Administration & Enforcement of 2025 California Electrical Code.

16.16.080 Article 110.13 Mounting and Cooling of Equipment.

16.16.010 2025 California Electrical Code, Cal. Code of Regs., Title 24, Part 3 adopted and amended.

The California Electrical Code, 2025 Edition, Title 24, Part 3 of the California Code of Regulations together with those omissions, amendments, exceptions and additions thereto, is adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein.

Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and regulations to the chapters and sections of the former California Code of Regulations, Title 24, 2022, shall be construed to apply to the corresponding provisions contained within the California Code of Regulations, Title 24, 2025. Ordinance No. 5568 of the City of Palo Alto and all other ordinances or parts of ordinances in conflict herewith are hereby suspended and expressly repealed.

Wherever the phrases "California Electrical Code" or "Electrical Code" are used in this code or any ordinance of the City, such phrases shall be deemed and construed to refer and apply to the California Item 15
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Electrical Code, 2025 Edition, as adopted by this Chapter.

One copy of the California Electrical Code, 2025 edition, has been filed for use and examination of the public in the Office of the Chief Building Official of the City of Palo Alto.

16.16.020 Cross - References to California Electrical Code.

The provisions of this Chapter contain cross-references to the provisions of the California Electrical Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.

16.16.030 Local Amendments.

The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of the California Electrical Code, 2025 Edition, and shall be deemed to replace the cross-referenced sections of said Code with the respective provisions set forth in this Chapter.

16.16.040 Adoption of SECTION 89.101 GENERAL.

SECTION 89.101 GENERAL of the 2025 California Electrical Code is adopted by the City of Palo Alto as amended herein.

16.16.050 Article 89.101.3.3 Exempted from This Code.

Section 89.101.3.3 is amended as follows (additions underlined; sections omitted without change noted by [. . .]):

89.101.3.3 Exempted from This Code.

This code does not cover:

1. Installations in ships, watercraft other than floating dwelling units, railway rolling stock, aircraft, automotive vehicles, commercial coaches, mobile homes, and recreational vehicles.
[. . .]

7. ADDITIONAL EXEMPTIONS: Electrical work that is exempt from permits pursuant to Palo Alto Municipal Code Section 16.04.110, Section 105.2 Work exempt from permit.

16.16.060 Article 89.101.4 2025 California Electrical Code Annexes adopted.

The following Annexes of the California Electrical Code, 2025 Edition, are adopted and hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set forth herein:

A. Annex B – Application Information for Ampacity Calculations B. Annex C – Conduit, Tubing, and Cable Tray Fill Tables for Conductors and Fixture Wires of the Same Size
C. Annex I – Unit Recommended Tightening Torque Tables from UL Standard 486A - 486B Item 15
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16.16.070 Administration & Enforcement of 2025 California Electrical Code Administration and enforcement of this code shall be governed by Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04.

16.16.080 Article 110.13 Mounting and Cooling of Equipment.

Article 110.13 (A) (1) of Article 110 of the California Electrical Code is added to read:
110.13 (A) (1) Concrete Slab Supporting Electrical Equipment. When electrical equipment is to be placed on a concrete substrate, a 4-inch concrete housekeeping pad shall be installed to elevate and protect the equipment.

SECTION 2. The Council adopts the findings for local amendments to the California Electrical Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.

SECTION 3. The Council finds that the changes or modifications to the California Electrical Code adopted by this ordinance are substantially equivalent to changes or modifications that were previously filed by the governing body of the City and were in effect as of September 30, 2025, and are therefore exempt from the moratorium on new residential building standards imposed by Assembly Bill 130 (2025).

SECTION 4. The Council finds that this ordinance is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the amendments herein adopted will have a significant effect on the environment.

SECTION 5. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

//

//

//

//

//

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SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

____________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

____________________________ ____________________________ City Attorney or Designee City Manager

____________________________
Director of Planning and
Development Services

____________________________
Director of Administrative Services
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Exhibit A

FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA ELECTRICAL CODE, TITLE 24, PART 3

Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Electrical Code, Title, 24, Part 3
Section(s)
or Article(s)
Title Added Amended Deleted Justification
(See below
for keys)

89.101 GENERAL  A

89.101.3.3 Exempt from This Code  A
110.13 (A) (1) Mounting and Cooling of Equipment  C
Annex B Application Information for
Ampacity Calculations
 G
Annex C Conduit, Tubing, and Cable Tray Fill Tables
for Conductors and Fixture Wires of the
Same Size
 A
Annex I Unit Recommended Tightening Torque
Tables
from UL Standard 486A - 486B
 A
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Key to Justification for Amendments to Title 24 of the California Code of Regulations

A This is an administrative amendment to clarify and establish civil and administrative procedures, regulations, or rules to enforce and administer the activities by the Palo Alto Building Inspection Department. These administrative amendments do not need to meet HSC 18941.5/17958/13869 per HSC 18909(c).

C This amendment is justified based on a local climatic condition. The seasonal climatic conditions during the late summer and fall create severe fire hazards to the public health and welfare in the City. The hot, dry weather frequently results in wild land fires on the brush covered slopes west of Interstate 280. The aforementioned conditions combined with the geological characteristics of the hills within the City create hazardous conditions for which departure from California Building Standards Code is required.

G This amendment is justified based on a local geological condition. The City of Palo Alto is subject to earthquake hazard caused by its proximity to San Andreas fault. This fault runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel Rock. This is the approximate location of the epicenter of the 1906 San Francisco earthquake. The other fault is Hayward Fault. This fault is about 74 mi long, situated mainly along the western base of the hills on the east side of San Francisco Bay. Both faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area which includes these earthquake faults, the modifications and changes cited herein are designed to better limit property damage as a result of seismic activity and to establish criteria for repair of damaged properties following a local emergency.

T The City of Palo Alto topography includes hillsides with narrow and winding access, which makes timely response by fire suppression and emergency response vehicles difficult.

Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater run-off. Also, the City of Palo Alto is located in an area that is potentially susceptible to liquefaction during a major earthquake. The surface condition consists mostly of stiff to dense sandy clay, which is highly plastic and expansive in nature.

The aforementioned conditions within the City create hazardous conditions for which departure from California Building Standards Code is warranted

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Ordinance No.

Ordinance of the Council of the City of Palo Alto Repealing Chapter 16.18 of the Palo Alto Municipal Code and Adopting a New Chapter 16.18, International Swimming Pool and Spa Code, With Local Amendments

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Chapter 16.18 of the Palo Alto Municipal Code is hereby amended by repealing it in its entirety and adopting a new Chapter 16.18 to read as follows:

CHAPTER 16.18
2024 International Swimming Pool and Spa Code (ISPSC)
Sections

16.18.010 2024 International Swimming Pool and Spa Code (ISPSC) adopted in part and amended.

16.18.020 Violations -- Penalties.

16.18.030 Enforcement -- Criminal Enforcement Authority.

16.18.040 References to California Building Codes.

16.18.050 Precedence of California Building Codes.

16.18.060 Administration & Enforcement of 2024 International Swimming Pool and Spa Code (ISPSC)

16.18.070 Section 101.1 Title.

16.08.080 Section 105.1.1 Agreements to build; notice of provisions.

16.18.090 Section 110.17 Final approval.

16.18.100 Section 301.1.2 Conflicts.

16.18.110 Section 303.3.1 Operating time.

16.18.120 Section 303.1.3 Covers.

16.18.130 Section 305.2 Outdoor swimming pools and spas.

16.18.140 Section 305.9 Private swimming pools.

16.18.150 Section 305.10 Enclosure.

16.18.160 Section 311.2 Construction requirements for building a pool or spa.

16.18.170 Section 317.2.1 Certification and installation.

16.18.180 Section 504.1 Emergency shutoff switch.

16.18.190 Section 903 to 908.

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Code

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16.18.010 2024 International Swimming Pool and Spa Code (ISPSC) adopted in part and amended.

Chapters 1 through 3 and chapters 7 through 11 of the International Swimming Pool and Spa Code, 2024 Edition, are adopted and hereby incorporated into this Chapter by reference and made a part hereof as if fully set forth herein. The provisions of this Chapter shall constitute local amendments to the referenced provisions of the International Swimming Pool and Spa Code, 2024 Edition.

One copy of the International Swimming Pool and Spa Code, 2024 Edition, has been filed for use and examination by the public in the Office of the Chief Building Official of the City of Palo Alto.

16.18.020 Violations -- Penalties.

It is unlawful for any person to violate any provision or to fail to comply with any of the requirements of this Chapter or any permits, conditions, or variances granted under this Chapter. Violators shall be subject to any penalty or penalties authorized by law, including but not limited to: administrative enforcement pursuant to Chapters 1.12 and 1.16 of the Palo Alto Municipal Code; and criminal enforcement pursuant to Chapter 1.08 of the Palo Alto Municipal Code. Each separate day or any portion thereof during which any violation of this Chapter occurs or continues shall be deemed to constitute a separate offense.

When the chief building official determines that a violation of this Chapter has occurred, the chief building official may record a notice of pendency of code violation with the Office of the County Recorder stating the address and owner of the property involved. When the violation has been corrected, the chief building official shall issue and record a release of the notice of pendency of code violation.

16.18.030 Enforcement -- Criminal Enforcement Authority.

The employee positions designated in this section are authorized to exercise the authority provided in California Penal Code section 836.5 for violations of this Chapter. The designated employee positions are: (1) chief building official, (2) assistant chief building official, (3) building inspection manager, and (4) code enforcement officer.

16.18.040 References to California Building Codes.

The International Swimming Pool and Spa Code, 2024 Edition, is hereby amended to refer to those building regulations adopted by the California Building Standards Commission in Title 24 of the California Code of Regulations, as follows:

1. Where the term “International Building Code” is used it shall be replaced with the term “California Building Code (CBC).”

2. Where the term “International Residential Code” is used it shall be replaced with the term “California Residential Code.”

3. Where the term “International Plumbing Code” is used it shall be replaced with the term “California Plumbing Code.”
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Code

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4. Where the term “International Energy Conservation Code” is used it shall be replaced with the term “California Energy Code.”

5. Where the term “International Fire Code” is used it shall be replaced with the term “California Fire Code.”

6. Where the term “International Fuel Gas Code” is used it shall be replaced with the term “California Plumbing Code.”

7. Where the term “International Mechanical Code” is used it shall be replaced with the term “California Mechanical Code.”

8. Where the term “NFPA 70” is used it shall be replaced with the term “California Electrical Code.”

16.18.050 Precedence of California Building Codes.

In the event of any conflict between this Chapter and provisions of the California Health and Safety Code or the building regulations adopted by the California Building Standards Commission in Title 24 of the California Code of Regulations, the provisions of the Health and Safety Code and Title 24 shall prevail.

16.18.060 Administration & Enforcement of 2024 International Swimming Pool and Spa Code (ISPSC)
Administration and enforcement of this code shall be governed by Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04, and any sections of the 2024 International Swimming Pool and Spa Code that are adopted by the City of Palo Alto in this Chapter 16.18.

16.18.070 Section 101.1 Title.

Section 101.1 of the International Swimming Pool and Spa Code is hereby amended to read:
101.1 Title. These regulations shall be known as the International Swimming Pool and Spa Code of the City of Palo Alto, hereinafter referred to as “this code.”

16.08.080 Section 105.1.1 Agreements to build; notice of provisions.

Section 105.1.1 of the International Swimming Pool and Spa Code is hereby added to read:

105.1.1 Agreements to build; notice of provisions. Any person entering into an agreement to build a swimming pool or spa, or to engage in permitted work on a pool or spa covered by this article, shall give the consumer notice of the requirements of this code.

Pursuant to existing law, the California Department of Health Services shall have available on the department's web site, commencing January 1, 2007, approved pool safety information available for consumers to download. Pool contractors are encouraged to share this information with consumers regarding the potential dangers a pool or spa poses toddlers. Additionally, pool contractors may provide the consumer Item 15
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16.18 International
Swimming Pool and Spa
Code

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with swimming pool safety materials produced from organizations such as the United States Consumer Product Safety Commission, Drowning Prevention Foundation, California Coalition for Children's Safety & Health, Safe Kids Worldwide, Association of Pool and Spa Professionals, or the American Academy of Pediatrics. [CBC 3109.1, 115924]

16.18.090 Section 111.17 Final approval.

Section 110.17 of the International Swimming Pool and Spa Code is hereby added to read:

111.17 Final Approval. Prior to the issuance of any final approval for the completion of permitted construction or remodeling work, the code official shall inspect the drowning safety prevention devices required and if no violations are found, shall give final approval. [CBC 3109.1, 15922(b)]

16.18.100 Section 301.1.2 Conflicts.

Section 301.1.2 of the International Swimming Pool and Spa Code is hereby added to read:

301.1.2 Conflicts. In the event of a conflict between the provisions of the Swimming Pool Safety Act, the International Swimming Pool and Spa Code, 2024 Edition, the 2025 California Building Code, or the 2025 California Residential Code, the Building Official shall implement the most restrictive measures cited.

16.18.110 Section 303.3.1 Operating time.

Section 303.3.1 of the International Swimming Pool and Spa Code is hereby added to read:

303.3.1 Operating time. The time switch or other control mechanism shall be installed as part of a pool water circulation control system that will allow all pumps to be set or programmed to run only during off-peak electric demand period, and for the minimum time necessary to maintain the water in the condition required by applicable public health standards. [California Energy Code (CEnC) 110.4(b)4ii]

16.18.120 Section 303.1.3 Covers.

Section 303.1.3 of the International Swimming Pool and Spa Code is hereby amended to read:

303.1.3 Covers. Outdoor pools and outdoor spas shall be provided with a vapor retardant cover.

16.18.130 Section 305.2 Outdoor swimming pools and spas.

Section 305.2 of the International Swimming Pool and Spa Code is hereby amended to read:

305.2 Outdoor swimming pools and spas. All outdoor pools and spas and indoor swimming pools shall be surrounded by a barrier that complies with Sections 305.2.1 through 305.7. [CBC 3109.1, 115922]. Refer to 305.9 for additional drowning Item 15
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prevention safety features.

16.18.140 Section 305.9 Private swimming pools.

Section 305.9 of the International Swimming Pool and Spa Code is hereby added to read:
305.9 Private swimming pools. Whenever a building permit is issued for construction of a new swimming pool or spa, or any building permit is issued for remodeling of an existing pool or spa, at a private, single-family home, it shall be equipped with at least two of the following seven drowning prevention safety features:

1. The pool/spa shall be isolated from access to a home by an enclosure that meets the requirements of Section 305.10.

2. The pool shall incorporate removable mesh pool fencing that meets ASTM F2286 in conjunction with a gate that is self-closing and self-latching and can accommodate a key lockable device.

3. The pool shall be equipped with an approved safety pool cover that meets all requirements of the ASTM F 1346-23 standards.

4. The residence shall be equipped with exit alarms on those doors and windows providing direct access to the pool and spa without any intervening enclosure.

Whenever any door or window is opened or left ajar, exit alarms shall make either an audible, continuous alarm sound or a repeating verbal warning, such as a repeating notification that “the door to the pool is open.”

5. All doors providing direct access from the home to the swimming pool or spa shall be equipped with a self-closing, self-latching device with a release mechanism placed no lower than 54 inches (1372 mm) above the floor.

6. An alarm that, when placed in a swimming pool or spa, will sound upon detection of accidental or unauthorized entrance into the water. The alarm shall meet and be independently certified to the ASTM Standard F2208 “Standard Safety Specification for Residential Pool Alarms,” which includes surface motion, pressure, sonar, laser, and infrared type alarms. A swimming protection alarm feature designed for individual use, including an alarm attached to a child that sounds when the child exceeds a certain distance or becomes submerged in water, is not a qualifying drowning prevention safety feature.

7. Other means of protection, if the degree of protection afforded is equal to or greater than that afforded by any of the devices set forth in items 1 - 4 and have been independently verified by an approved testing laboratory as meeting standards for those devices established by the ASTM or ASME.

Exceptions:

1. Public swimming pools.

2. Hot tubs or spas with locking safety covers that comply with the ASTM ES 13-89. b)]

3. An apartment complex, or any residential setting other than a single- Item 15
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family home.

16.18.150 Section 305.10 Enclosure.

Section 305.10 of the International Swimming Pool and Spa Code is hereby added to read:
305.10 Enclosure. The enclosure for private swimming pools shall have all of the following characteristics:

1. Any access gates through the enclosure open away from the swimming pool and are self-closing with a self-latching device placed no lower than 60 inches (1524 mm) above the ground.

2. A minimum height of 60 inches (1524 mm).

3. A maximum vertical clearance from the ground to the bottom of the enclosure of 2 inches (51 mm).

4. Gaps or voids, if any, do not allow passage of a sphere equal to or greater than 4 inches (102 mm) in diameter.

5. An outside surface free of protrusions, cavities or other physical characteristics that would serve as handholds or footholds that could enable a child below the age of five years to climb over.

16.18.160 Section 311.2 Construction requirements for building a pool or spa.

Section 311.2 of the International Swimming Pool and Spa Code is hereby added to read:
311.2 Construction requirements for building a pool or spa. Whenever a building permit is issued for the construction of a new private swimming pool or spa, the pool or spa shall meet all of the following requirements:
(a) (1) The suction outlets of the pool or spa for which the permit is issued shall be equipped to provide circulation throughout the pool or spa as prescribed in paragraphs (2) and (3).
(2) The swimming pool or spa shall either have at least two circulation suction outlets per pump that shall be hydraulically balanced and symmetrically plumbed through one or more “T” fittings, and that are separated by a distance of at least three feet in any dimension between the suction outlets, or be designed to use alternatives to suction outlets, including, but not limited to, skimmers or perimeter overflow systems to conduct water to the recirculation pump.
(3)The circulation system shall have the capacity to provide a complete turnover of pool water, as specified in Section 3124B of Chapter 31B of the California Building Code (Title 24 of the California Code of Regulations).

Suction outlets shall be covered with anti-entrapment grates, as specified in the ANSI/APSP-16 performance standard or successor standard designated by the federal Consumer Product Safety Commission, that cannot be removed except Item 15
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with the use of tools. Slots or openings in the grates or similar protective devices shall be of a shape, area, and arrangement that would prevent physical entrapment and would not pose any suction hazard to bathers. (b) Any backup safety system that an owner of a new swimming pool or spa may choose to install in addition to the requirements set forth in subdivisions (a) and (b) shall meet the standards as published in the document, “Guidelines for Entrapment Hazards: Making Pools and Spas Safer,” Publication Number 363, March 2005, United States Consumer Product Safety Commission.

16.18.170 Section 317.2.1 Certification and installation.

Section 317.2.1 of the International Swimming Pool and Spa Code is hereby added to read:

317.2.1 Certification and installation.
( a ) Certification by manufacturers. Heating systems and equipment shall be certified by the manufacturer that the heating system and equipment complies with the following:

1. Efficiency. A thermal efficiency that complies with the Appliance Efficiency Regulations in Title 20, Division 2, Chapter 4, Article 4 of the California Code of Regulations; and [CEnC 110.4(a)1]

2. On-off switch. A readily accessible on-off switch, mounted on the outside of the heater that allows shutting off the heater without adjusting the thermostat setting; and [CEnC 110.4(a) 2]

3. Instructions. A permanent, easily readable and weatherproof plate or card that gives instruction for the energy efficient operation of the pool or spa heater and for the proper care of pool or spa water when a cover is used; and [CEnC 110.4(a)3]
( b ) Installation. Any pool or spa system or equipment shall be installed with all of the following:

1. Heating equipment: Equipment installed to heat water for pools and/or spas shall be selected from equipment meeting the standards shown in Table 110.4-A. [CEnC 110.4(b)1]

Table 110.4-A Heating Equipment Standards
Heating Energy Source Standard
Electric Resistance UL 1261
Gas-fired ANSI Z21.56/CSA 4.7a
Heat Pump AHRI 1161 and one of the
following: CSA C22.2 No. 236,
UL1995, or UL/CSA 60335-2-40
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Solar ICC/APSP902/SRCC400 for solar
pool heaters, ICC 901/SRCC100 for
solar collectors

2. Piping. At least 18 inches of horizontal or vertical pipe shall be installed between the filter and the heater or dedicated suction and return lines, or built-in or built-up connections shall be installed to allow for the future addition of solar heating equipment. [CEnC 110.4(b)2]

3. Covers. A cover for outdoors pools or outdoor spas.

4. Directional inlets. The swimming pool shall have directional inlets that adequately mix the pool water. [CEnC 110.4(b)4i]

16.18.180 Section 504.1 Emergency shutoff switch.

Section 504.1 of the International Swimming Pool and Spa Code is hereby amended to read:
504.1 Emergency shutoff switch. One emergency shutoff switch shall be provided to disconnect power to circulation and jet system pumps and air blowers. Emergency shutoff switches shall be clearly labeled, accessible, located within sight of the spa and shall be located not less than 5 feet (1524 mm) but not greater than 10 feet (3048 mm) horizontally from the inside walls of the spa. [California Electrical Code (CEC), 680.41]

16.18.190 Section 903 to 908.

Sections 903 to 908 of the International Swimming Pool and Spa Code are added as follows:

SECTION 903

MATERIALS
903.1 Pumps and motors. Pumps and motors shall be listed and labeled for use in spas.

SECTION 904

STRUCTURE AND
DESIGN
904.1 Water depth. The maximum water depth for spas shall be 4 feet (1219 mm) measured from the design waterline except for spas that are designed for special purposes and approved by the authority having jurisdiction. The water depth for exercise spas shall not exceed 6 feet 6 inches (1981 mm) measured from the design waterline. 904.2 Multilevel seating. Where multilevel seating is provided, the maximum water depth of any seat or sitting bench shall be 28 inches (711 mm) measured from the design waterline to the lowest measurable point.
904.3 Floor slope. The slope of the floor shall not exceed 1 unit vertical in 12 units Item 15
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horizontal (8.3-percent slope). Where multilevel floors are provided, the change in depth shall be indicated.

SECTION 905

PUMPS AND MOTORS
905.1 Emergency shutoff switch. One emergency shutoff switch shall be provided to disconnect power to circulation and jet system pumps and air blowers. Emergency shutoff switches shall be accessible, located within sight of the spa and shall be located not less than 5 feet (1524 mm) but not greater than 10 feet (3048 mm) horizontally from the inside walls of the spa.

Timer. The operation of the hydrotherapy jets shall be limited by a cycle timer having a maximum setting of 10 minutes. The cycle timer shall be located not less than 5 feet (1524 mm) away, adjacent to, and within sight of the spa.

SECTION 906

RETURN AND SUCTION FITTINGS
906.1 Return fittings. Return fittings shall be provided and arranged to facilitate a uniform circulation of water and maintain a uniform sanitizer residual throughout the entire spa or exercise spa.
906.2 Suction fittings. Suction fittings shall be in accordance with Sections 505.2.1 through 505.2.4.
906.2.1 Testing and certification. Suction fittings shall be listed and labeled in accordance with APSP 16.
906.2.2 Installation. Suction fittings shall be sized and installed in accordance with the manufacturer’s specifications. Spas and exercise spas shall not be used or operated if the suction outlet cover is missing, damaged, broken or loose. 906.2.3 Outlets per pump. Suction fittings shall be provided in accordance with Section 311.
906.2.4 Submerged vacuum fittings. Submerged vacuum fittings shall be in accordance with Section 311.

SECTION 907

HEATER AND TEMPERATURE REQUIREMENTS

907.1 General. This section pertains to fuel-fired and electric appliances used for heating spa or exercise spa water.
907.2 Water temperature controls. Components provided for water temperature controls shall be suitable for the intended application.
907.2.1 Water temperature regulating controls.

Water temperature regulating controls shall comply with UL 873 or UL 372. A means Item 15
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shall be provided to indicate the water temperature in the spa.

Exception: Water temperature regulating controls that are integral to the heating appliance and listed in accordance with the applicable end use appliance standard. 907.2.2 Water temperature limiting controls. Water temperature limiting controls shall comply with UL 873 or UL 372. Water temperature at the heater return outlet shall not exceed 140°F (60°C).

SECTION 908

WATER SUPPLY

908.1Water temperature.

The temperature of the incoming makeup water shall not exceed 104°F (40°C).

SECTION 2. The Council finds that adoption of this code and its local amendments is not a change or modification to the California Building Standards Code pursuant to Health and Safety Code Section 17958.5. The California Building Standards Commission does not require that an ordinance adopting and amending the International Swimming Pool and Spa Code be filed with the Commission or supported by local conditions SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

SECTION 4. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the amendments herein adopted will have a significant effect on the environment.

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SECTION 5. This Ordinance shall be effective on the thirty-first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

____________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

____________________________ ____________________________ City Attorney or Designee City Manager

____________________________
Director of Planning and
Development Services

____________________________
Director of Administrative Services

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Ordinance No. ____
Ordinance of the Council of the City of Palo Alto Amending Chapter 16.17 (California Energy Code, California Code of Regulations, Title 24, Part 6) of the Palo Alto Municipal Code to Adopt the 2025 California Energy Code, Along with Local Amendments Thereto

The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Findings and Declarations.

A. The City of Palo Alto adopted a Sustainability and Climate AcƟon Plan, or S/CAP , to meet the City's stated goal of "80 x 30": reducing greenhouse gas emissions 80% below 1990 levels by 2030.

B. The S/CAP outlines goals and key acƟons in eight areas, one of which is energy and more specifically, energy efficiency and electrificaƟon. The goals for the energy area of the S/CAP are to reduce GHG emissions from the direct use of natural gas in Palo Alto’s building sector by at least 60% below 1990 levels (116,400 MT CO2e reducƟon) and to modernize the electric grid to support increased electric demand to accommodate state- of-the-art technology.

C. One key acƟon the City is taking to accomplish those goals is to use codes and ordinances - such as the energy reach code, green building ordinance, zoning code, or other mandates - to facilitate electrificaƟon in both exisƟng buildings and new construcƟon projects where feasible.

D. The purpose of this ordinance is to formally adopt California Code of RegulaƟons, Title 24, Part 6, 2025 California Energy Code, with local amendments in furtherance of the City of Palo Alto’s S/CAP goals and other sustainability-related goals included in the City’s 2030 Comprehensive Plan. The amendments adopted herein are more restricƟve than the building standards in Title 24, Part 6.

E. This ordinance is intended to supplement, not to supersede, Ordinance 5565, which was passed by the Council on September 8, 2025 and which adopted the 2025 California Energy Code along with local amendments related to FlexPath and Air CondiƟoner Time- of-Replacement Requirements.

F. Recent legislaƟon, Assembly Bill (AB) 130 (2025), limits local jurisdicƟons’ authority to amend the California Building Standards Code beginning October 1, 2025, and ending June 1, 2031. The Council finds that to the extent they affect residenƟal units, the Item 15
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changes or modificaƟons to the California Energy Code (Title 24, Part 6) adopted by this ordinance are substanƟally equivalent to changes or modificaƟons that were previously filed by the governing body of the City and were in effect as of September 30, 2025, and are therefore exempt from the moratorium on new residenƟal building standards imposed by AB 130.

G. AddiƟonally, the Council finds that these changes or modificaƟons to the California Energy Code are necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10, 2025, and that permits mixed- fuel residenƟal construcƟon consistent with federal law while also incenƟvizing all- electric construcƟon as part of an adopted greenhouse gas emissions reducƟon strategy.

The City of Palo Alto’s Comprehensive Plan was adopted on November 13, 2017, and amended on December 19, 2022. The relevant policies and goals in the Comprehensive Plan include, but are not limited to: Goal N-7 (“A clean, efficient energy supply that makes use of cost-effecƟve renewable resources”) and Goal N-8 (“AcƟvely support regional efforts to reduce our contribuƟon to climate change while adapƟng to the effects of climate change on land uses and city services”) and associated policies and programs. These include Policy N-7.4 (“Maximize the conservaƟon and efficient use of energy in new and exisƟng residences and other buildings in Palo Alto”), Program N-

7.4.1 (“ConƟnue Ɵmely incorporaƟon of State and federal energy efficiency standards and policies in relevant City codes, regulaƟons and procedures and higher local efficiency standards that are cost-effecƟve”), Policy N-7.7: (“Explore a variety of cost- effecƟve ways to reduce natural gas usage in exisƟng and new buildings in Palo Alto in order to reduce associated greenhouse gas emissions”), and especially Policy N-8.2 (“With guidance from the City’s Sustainability and Climate AcƟon Plan (S/CAP) and its subsequent updates and other future planning efforts, reduce greenhouse gas emissions from City operaƟons and from the community”). The amendments herein promote building electrificaƟon by imposing broader electric readiness requirements than the California Energy Code.

H. California Health and Safety Code secƟons 17958.5 and 17958.7 require that the City, in order to make changes or modificaƟons in the requirements contained in the California Building Standards Code on the basis of local condiƟons, make express finding that such modificaƟons or changes are reasonably necessary because of local climaƟc, geological or topographical condiƟons. The required findings are aƩached to this ordinance as Exhibit A.

SECTION 2. SecƟon 16.17.070 of the Palo Alto Municipal Code is hereby amended to read as follows:

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16.17.070 Section 110.10 MANDATORY REQUIREMENTS FOR SOLAR READY BUILDINGS Section 110.10 of Subchapter 2 of the California Energy Code is amended by adding Section 110.10 (f) to read:
(f) Existing tree canopies. In the event of a conflict between the provisions of this Code, the Solar Shade Act of 2009, and the Palo Alto Tree Ordinance (Chapter 8.10), the most protective of existing tree canopies shall prevail.

SECTION 3. SecƟon 16.17.080 of the Palo Alto Municipal Code is hereby amended to read as follows:

16.17.080 SUBCHAPTER 3 NONRESIDENTIAL, HOTEL/MOTEL OCCUPANCIES, AND COVERED PROCESSES—MANDATORY REQUIREMENTS

SECTION 120.0 NONRESIDENTIAL, HOTEL/MOTEL OCCUPANCIES, AND COVERED PROCESSES—MANDATORY REQUIREMENTS – GENERAL.

Section 120.0 of Subchapter 3 of the California Energy Code is amended to read:

Sections 120.1 through 120.10 establish requirements for the design and installation of building envelopes, ventilation, space-conditioning and service water-heating systems and equipment in nonresidential and hotel/motel buildings as well as covered processes that are within the scope of Section 100.0(a).

Note: The requirements of Sections 120.1 through 120.10 apply to newly constructed buildings. Section 141.0 specifies which requirements of Sections 120.1 through 120.10 also apply to additions or alterations to existing buildings.

The electric readiness requirements specified in Section 120.6 (k) and Section 120.6 (l) apply to substantial remodels.

SECTION 4. SecƟon 16.17.090 of the Palo Alto Municipal Code is hereby amended to read as follows:

16.17.090 SECTION 120.6(l) ELECTRIC READINESS REQUIREMENTS FOR SYSTEMS USING GAS

OR PROPANE
Subchapter 3 of the California Energy Code is amended to add Section 120.6(l) to be numbered, entitled, and to read:
120.6(l) ELECTRIC READINESS REQUIREMENTS FOR SYSTEMS USING GAS OR PROPANE Item 15
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Where nonresidential systems using gas or propane are installed, the construction drawings shall indicate electrical infrastructure and physical space accommodating the future installation of an electric appliance in the following ways, as certified by a registered design professional or licensed electrical contractor.
a) Branch circuit wiring, electrically isolated and designed to serve all electric heating appliances in accordance with manufacturer requirements and the California Electrical Code, including the appropriate voltage, phase, minimum amperage, and an electrical receptacle or junction box within five feet of the appliance that is accessible with no obstructions.

Appropriately sized conduit may be installed in lieu of conductors; and b) Labeling of both ends of the unused conductors or conduit shall be with “For Future Electrical Appliance”; and
c) Reserved circuit breakers in the electrical panel for each branch circuit, appropriately labeled (e.g. “Reserved for Future Electrical Appliance”), and positioned on the opposite end of the panel supply conductor connection; and
d) Connected subpanels, panelboards, switchboards, busbars, and transformers shall be sized to serve the future electric heating appliances.

The electrical capacity requirements shall be adjusted for demand factors in accordance with the California Electrical Code; and
e) Physical space for future electric appliances, including equipment footprint, and if needed a pathway reserved for routing of ductwork to heat pump evaporator(s), shall be depicted on the construction drawings. The footprint necessary for future electric appliances may overlap with non- structural partitions and with the location of currently designed combustion equipment.

SECTION 5. SecƟon 16.17.150 of the Palo Alto Municipal Code is hereby amended to read as follows:

16.17.150 SECTION 160.9 MANDATORY REQUIREMENTS FOR ELECTRIC READY BUILDINGS

Section 160.9 of Subchapter 10 of the California Energy Code is amended to read:

Mandatory requirements for electric-ready buildings apply to newly constructed buildings and substantial remodels.

Section 160.9 Sections (a) – (f) are adopted without amendments.

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SECTION 6. The Council adopts the findings for local amendments to the California Energy Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.

SECTION 7. If any secƟon, subsecƟon, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining porƟon or secƟons of the Ordinance. The Council hereby declares that it would have adopted the Ordinance and each secƟon, subsecƟon, sentence, clause or phrase thereof irrespecƟve of the fact that any one or more secƟons, subsecƟons, sentences, clauses or phrases be declared invalid.

SECTION 8. The Council finds that this ordinance is exempt from the provisions of the California Environmental Quality Act (“CEQA”), under Section 15308 of the CEQA Guidelines, because it is a regulatory action for the protection of the environment, and under Section 15061(b)(3) on the grounds that the proposed standards are more stringent than the State energy standards, there are no reasonably foreseeable adverse environmental impacts and there is no possibility that the activity in question may have a significant effect on the environment.

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SECTION 9. This Ordinance shall be effective on the thirty-first day after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:
____________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

____________________________ ____________________________ City Attorney or Designee City Manager

____________________________
Director of Planning and
Development Services

____________________________
Director of Administrative Services

____________________________
Director of Public Works

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Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA ENERGY CODE, 2025 EDITION TITLE 24, PART 6
Section 17958 of the California Health and Safety Code provides that the City may make changes to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the Health and Safety Code require that for each proposed local change to those provisions of the California Building Standards Code which regulate buildings used for human habitation, the City Council must make findings supporting its determination that each such local change is reasonably necessary because of local climatic, geological, or topographical conditions.

Regarding the Energy Code, local jurisdictions have the authority to adopt local energy efficiency ordinances—or reach codes—that exceed the minimum standards defined by Title 24 (as established by Public Resources Code Section 25402.1(h)2 and Section 10-106 of the Building Energy Efficiency Standards), provided the City Council finds that the requirements of the proposed ordinance are cost-effective and do not result in buildings consuming more energy than is permitted by Title 24.

Local building regulations having the effect of amending the uniform codes, which were adopted by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958, 17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform codes which were adopted by the City Council prior to November 23, 1970 and have been carried through from year to year without significant change, need no required findings. Also, amendments to provisions not regulating buildings used for human habitation do not require findings.

Code: California Energy Code, Title 24, Part 6
Chapter(s),
Sections(s),
Appendices
Title Add Deleted Amended Justification
(See below of keys)
110.10 (f) Existing tree canopies  C & E
120.0 Nonresidential, Hotel/Motel
Occupancies, and Covered
Processes—Mandatory
Requirements
 C & E
120.6(l) Electric Readiness Requirements
for Systems Using Gas or Propane
 C & E
160.9 Mandatory Requirements for
Electric Ready Buildings
 C & E

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Key to Justification for Amendments to Title 24 of the California Code of Regulations

A This is an administrative amendment to clarify and establish civil and administrative procedures, regulations, or rules to enforce and administer the activities by the Palo Alto Building Inspection Department. These administrative amendments do not need to meet HSC
18941.5/17958/13869 per HSC 18909(c).

C This amendment is justified on the basis of a local climatic condition. The seasonal climatic conditions during the late summer and fall create severe fire hazards to the public health and welfare in the City. The hot, dry weather frequently results in wild land fires on the brush covered slopes west of Interstate 280. The aforementioned conditions combined with the geological characteristics of the hills within the City create hazardous conditions for which departure from California Energy Code is required.

Failure to address and significantly reduce greenhouse gas (GHG) emissions could result in rises in sea level, including in San Francisco Bay, that could put at risk Palo Alto homes and businesses, public facilities, and Highway 101 (Bayshore Freeway), particularly the mapped Flood Hazard areas of the City. Energy efficiency is a key component in reducing GHG emissions, and the construction of more energy efficient buildings can help Palo Alto reduce its share of the GHG emissions that contribute to climate change. The burning of fossil fuels used in the generation of electric power and heating of buildings contributes to climate change, which could result in rises in sea level, including in San Francisco Bay, that could put at risk Palo Alto homes and businesses 1 public facilities, and Highway 101. Due to a decrease in annual rainfall, Palo Alto experiences the effect of drought and water saving more than some other communities in California.

E Energy efficiency enhances the public health and welfare by promoting the environmental and economic health of the City through the design, construction, maintenance, operation, and deconstruction of buildings and sites by incorporating green practices into all development. The provisions in this Chapter are designed to achieve the following goals:
(a) Increase energy efficiency in buildings;
(b) Increase resource conservation;
(c) Provide durable buildings that are efficient and economical to own and operate;
(d) Promote the health and productivity of residents, workers, and visitors to the city;
(e) Recognize and conserve the energy embodied in existing buildings; and (f) Reduce disturbance of natural ecosystems.

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G This amendment is justified on the basis of a local geological condition.

The City of Palo Alto is subject to earthquake hazards caused by its proximity to San Andreas fault. This fault runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel Rock. This is the approximate location of the epicenter of the 1906 San Francisco earthquake. The other fault is the Hayward Fault. This fault is about 74 mi long, situated mainly along the western base of the hills on the east side of San Francisco Bay. Both of these faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area that includes these earthquake faults, the modifications and changes cited herein are designed to better limit property damage as a result of seismic activity and to establish criteria for repair of damaged properties following a local emergency.

T The City of Palo Alto topography includes hillsides with narrow and winding access, which makes timely response by fire suppression vehicles difficult. Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and waste water run-off. Also the City of Palo Alto is located in an area that is potentially susceptible to liquefaction during a major earthquake. The surface condition consists mostly of stiff to dense sandy clay, which is highly plastic and expansive in nature. The aforementioned conditions within the City create hazardous conditions for which departure from California Building Standards Codes is warranted.

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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Manager
Meeting Date: October 20, 2025
Report #:2509-5183
TITLE
Policy and Services Committee Recommendation to the City Council to Approve a Phased Approach to Address Oversized Vehicle (Including Recreational Vehicle) Impacts, Particularly Relating to Individuals Living in Vehicles and Approve Budget Amendments in various funds; CEQA status – categorically exempt.

RECOMMENDATION
Staff recommends the City Council Approve the Policy and Services Committee recommendation to:

1. Approve the phased approach (described below) to addressing oversized vehicle (including recreational vehicle) impacts, particularly relating to individuals living in vehicles; and

2. Approve amendments to the Fiscal Year 2026 Budget Appropriation (requires a 2/3 vote) to resource aspects of the phased approach in the:
a. General Fund by:
i. Increasing the contractual services appropriation for the City Manager’s Office by $157,000 for resources to support program implementation; ii. Decreasing the Reserve: Business Tax Revenue for Housing Affordability by $157,000;
iii. Increasing the contractual services appropriation for the Office of Transportation by $150,000 for engineering services;
iv. Increasing the contractual services appropriation in the Public Works Department by $60,000 for street clean-up services;
v. Increasing the contractual services appropriation in the Police Department by $95,000 for marking and enforcement of vehicles; vi. Decreasing the Budget Stabilization Reserve by $305,000; b. Refuse Fund by:
i. Increasing the contractual services appropriation by $245,000 for new permanent and temporary street cleaning signage; and
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ii. Decreasing the Ending Fund Balance by $245,000.

EXECUTIVE SUMMARY
This report updates information presented to the Policy and Services Committee at its August 25, 2025 meeting as well as reflecting the Committee’s recommendation to the full Council.

This recommendation follows the 2025 Council Priority Objective to present options for addressing impacts associated with oversized vehicles (OSVs), particularly individuals living in vehicles. Following the initial report outlining a range of possible strategies, the Policy and Services Committee (the Committee) reviewed the options, amended the staff proposal, and is recommending a phased approach for full Council consideration.

The recommended approach reflects a balanced approach to addressing public health, safety, and neighborhood concerns while also recognizing the complex needs of those living in vehicles. The proposed phasing begins with Phase 1 enacting regulatory measures and enhanced street cleanups and sweeping, including coordination with service providers such as LifeMoves, and appropriating $707,000 in FY 2026 across several funds. This would be followed by Phase 2, a small-scale pilot of enhanced services, such as mobile pump-outs and increased outreach. The approach also sets the stage for expanding safe parking on private and congregation-based lots and, over time, developing a program to limit OSV parking to designated streets. The Committee was split on limiting OSV parking to designated streets. In a 2-1 vote, the Committee recommended that Phase 2 begin exploring limiting OSV parking to certain streets, including direction to evenly distribute OSV permitted parking citywide, tie the OSV permitted parking to the Point in Time (PIT)1 count, explore an OSV permitting program, and clearly mark where OSV parking is permitted. Subsequent phases include approving items developed in earlier phases, implementation, and enforcement. Additional one-time and ongoing resources will be needed in future years to administer all phases of this program and will be brought forward as part of the annual budget process to allocate funding.

BACKGROUND
Homelessness continues to be one of the most complex and pressing societal issues affecting communities across California and the nation. In response, the City of Palo Alto has aligned its local efforts with the Santa Clara County Community Plan to End Homelessness 2020–2025, which the City formally endorsed in August 2021.2 Since that time, the City has advanced a 1 The PIT Count is a count of sheltered and unsheltered people experiencing homelessness at a specific point in time and occurs every other year in January.
2 Santa Clara County Community Plan to End Homelessness 2020-2025:
https://housingtoolkit.sccgov.org/sites/g/files/exjcpb501/files/CommunityPlan_2020.pdf ; Council Staff Report, April 5, 2021 https://www.cityofpaloalto.org/files/assets/public/v/1/agendasminutesreports/reports/citymanager- reports-cmrs/year-archive/2021/id-12133.pdf ; Council Action Minutes, August 9, 2021 https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=3354&compileOutputType= 1 Item 16
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range of initiatives to promote housing stability and reduce the impacts of homelessness, including:
•Strengthening renter protections,
•Enabling and supporting safe parking programs,
•Permitting and beginning construction of the Homekey interim shelter, and •Supporting affordable housing developments such as Wilton Court Apartments, 231 Grant Avenue, Mitchell Park Place, and projects on city-owned sites like Lot T downtown and 340 Portage Avenue.

The City also continues to respond to resident and business concerns regarding the visible impacts of homelessness, focusing both on service referrals and enforcement of existing laws.

Recognizing the need for a deeper understanding of local needs and service gaps, the City Council established a 2024 Council Priority Objective to conduct a gap analysis of local housing and homelessness services.3 That analysis was presented as an informational item on December 9, 2024, and discussed at a Council Study Session on February 10, 2025.4 The session also included updates on service coordination and enforcement efforts. As a result of that discussion, Council referred follow-up work to the Policy and Services Committee, and adopted two related 2025 Council Priority Objectives, asking staff to return as soon as feasible to Council to determine further action and to bypass extended stakeholder engagement at that time. The Council Priority Objectives are:5
•Present options to address homelessness impacts, particularly for individuals living in vehicles, to Policy and Services Committee for prioritization. •Organize an initial review of sources and methods to raise funding to support new affordable housing production for future evaluation.

Following the February Study Session, staff shared the gap analysis with the Human Relations Commission (HRC) on June 12, 2025, gathering input on housing and services for the unhoused.6 While no formal action was taken, individual Commissioners supported a wide 3 Council Meeting, December 4, 2023 https://www.youtube.com/watch?v=A-2CuhXvs84 4 Council Staff Report, December 9, 2024
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=6549&meetingTemplateType=2&comp iledMeetingDocumentId=12534; Council Staff Report, February 10, 2025 https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=6751&meetingTemplateType=2&comp iledMeetingDocumentId=13091
5This item responds to the first of the two objectives, the second will be referred to Finance Committee, once staff has identified and evaluated sources and methods. Council Staff Report, May 5, 2025, https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=7767&meetingTemplateType=2&comp iledMeetingDocumentId=14271
6 Human Relations Commission Staff Report, June 12, 2025 https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=8147&meetingTemplateType=2&comp iledMeetingDocumentId=14739
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range of ideas, including expanded safe parking, particularly for RVs; incentives and streamlined processes for below-market-rate housing, addressing family homelessness (e.g., via hotel vouchers or tiny homes), shelter improvements, continued renter protections, and stronger partnerships with the tech industry to improve communications access (e.g., phones, Wi-Fi).

Most recently, on August 25, 2025, the Policy and Services Committee took up the Council Priority Objective—addressing impacts related to oversized vehicles (OSVs), including recreational vehicles (RVs).7 After discussion, the Committee voted on a split motion to recommend a phased approach. The full Committee agreed on Phases 1, 3 and 4. In a 2-1 vote, with Councilmember Veenker voting no, the Committee recommended to, in Phase 2, begin exploring limiting OSV parking to certain streets, including direction to evenly distribute OSV permitted parking citywide, tie the OSV permitted parking to the Point in Time count, explore an OSV permitting program, and clearly mark where OSV parking is permitted. The full motion text and vote is shown in full on the next page. The full staff report is included as Attachment B. 7 Council Staff Report, August 25, 2025,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=8615&meetingTemplateType=2&comp iledMeetingDocumentId=15516
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1. Discussion and recommendation to Council on prioritization of potential approaches to address oversized vehicle (including recreational vehicle) impacts, particularly relating to individuals living in vehicles

MOTION SPLIT FOR PURPOSES OF VOTING
MOTION: Councilmember Stone moved, seconded by Councilmember Lu, to recommend the City Council:

Phase 2:

Begin exploration of the “limiting OSV parking to certain streets” approach, including determining a process and criteria for designating streets where OSV parking might be permitted, with appropriate community engagement
oIdentify non-residential and non-residential adjacent streets where OSV parking would be permitted, and to the extent possible, evenly distribute those streets across the city oTie the number of OSV permitted parking to the Point in Time count oExplore the possibility of a permitting program for OSV oEvenly disburse permissible OSV parking spots across the identified streets to avoid overconcentration and clearly mark on those streets where OSV parking is permitted MOTION PASSED: 2-1, Veenker no
MOTION: Councilmember Stone moved, seconded by Councilmember Lu, to recommend the City Council:

Phase 1: Upon Council approval, staff would:

1. Develop an ordinance to prohibit parking of detached/inoperable vehicles on public streets,

2. Develop an ordinance to prohibit the renting of public parking spaces (“vanlording”),

3. Refine the scope and begin implementation of additional street cleanups and sweeping,

4. Return to Council for approvals of ordinances and contract amendments (e.g., street sweeping) as soon as possible, estimated to require up to four (4) months, and

5. Implementation and enforcement of these actions would follow.

6. Work with LifeMoves to consider options, such as a buyback or parking program, to accept RV residents quickly at the Homekey site or other housing options

7. Return to Council for direction for expanded safe parking on privately-owned and congregation- based parking lots, excepting any safe parking site that requires undedicating parkland Phase 2: Concurrent of Phase 1 implementation, staff would initiate work on:

1. Design a small-scale enhanced services pilot (e.g., mobile pump outs, additional outreach workers/hours, garbage pickup, etc.),
Phase 3: Following the completion of related components in Phase 2, Council would:

1. Approve pilot and any related contracts and agreements for small-scale enhanced services pilot,

2. Approve a preferred option for expanded safe parking on privately-owned and congregation- based parking lots,

3. Identify streets where OSV parking will be allowed and develop necessary ordinances and program design for “limiting OSV parking to certain streets” approach, and

4. Implementation of these actions would follow.

Phase 4: Following the completion of related components in Phase 3, staff would:

1. Evaluate the enhanced services pilot,

2. Pursue implementation of expanded safe parking, and

3. Obtain related Council approvals for “limiting OSV parking to certain streets” and begin enforcing new approach.

MOTION PASSED: 3-0
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ANALYSIS
The recently received 2025 PIT count data shows 418 people experiencing homelessness in Palo Alto, compared to 206 people in 2023. The City continues to have a higher percentage of its unsheltered population living in vehicles compared to the County as a whole. Of those unsheltered in Palo Alto, 73 percent were in vehicles, while 37 percent were in vehicles countywide. There were 168 vehicles (29 cars, 120 RVs, and 19 vans) counted, 35 of which were in safe parking.8
As noted at the August Committee meeting, the growing number of people living in vehicles on public streets poses a health and safety challenge, reducing the on-street parking availability for other uses (e.g., residents, business employees and visitors), and necessitating outreach services, street cleaning, and waste disposal. The City has been receiving increased concerns from residents and the business community about long-term parking of oversized vehicles, debris and personal belongings obstructing streets and sidewalks, and improper disposal of human waste. The City Manager’s Office has seen a notable rise in these complaints beginning in Spring 2025. Other neighboring cities are also seeking a variety of ways to address inhabited OSVs, as summarized in Attachment A.

This report outlines the phased approach recommended by the Committee, beginning with some contextual information on state law. Then more detailed information is provided on the various actions proposed in the phased approach to: (1) reduce the impacts of accommodating OSV parking demand, (2) strengthen regulations in areas where impacts are occurring while preventing the impacts elsewhere, and (3) organize activities into phases that account for implementation timelines and the complexity of the issue.

Please note that one of the Committee actions was to move safe parking expansion from Phase 2 to Phase 1. To reflect the Committee intent of moving safe parking expansion up in the timeline, staff also moved associated safe parking expansion activities from Phases 3 and 49 to Phase 1; associated resource implications are also identified. Additionally, upon review of the motion, staff noted that the amended Phase 2 to “identify non-residential and non-residential adjacent streets where OSV parking would be permitted” is a revision of Phase 3 item 3 "identify streets where OSV parking will be allowed....” Since this was part of the split motion, if the full Council chooses to adopt the proposed amended language in Phase 2, staff would interpret the Phase 3 item 3 language as being the continuation and finalization of the work begun in Phase 2.

The many items in Phase 1 will trigger the immediate need for staff resources to handle coordination, administration, and implementation. Procurement, contracting, and/or 8 The County used a new survey methodology in 2025, so comparing to prior years is fundamentally not the same.

The full 2025 PIT Count report is available here: https://osh.santaclaracounty.gov/data-and-reports/point-time- count.
9 In the Policy and Services Motion this is Phase 3, item 2, but is now considered incorporated under/as part of Phase 1.

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recruitment and hiring for this will likely take several months and may impact the rollout time for Phase 1.

State Law and Local Parking Regulations Relating to Oversized Vehicles In California, the state legislature holds preemptive authority over vehicle movement and parking regulations. Cities—including charter cities—may adopt local parking laws only as permitted by state law, and such laws must also comply with the U.S. Constitution.

In general, parking is allowed in the public right-of-way when: (a) it is not explicitly prohibited, and (b) the vehicle does not block an active lane of traffic, fire hydrants, driveways, or other areas restricted by state law. These rules apply equally to oversized vehicles (OSVs), unless a local jurisdiction adopts specific restrictions for OSVs, which the California Vehicle Code generally allows.

Palo Alto’s Municipal Code includes one provision regulating OSV parking: it prohibits OSVs from parking on the street in residential and public facility zones between 2:00 a.m. and 6:00 a.m. Although the Code states this rule is enforceable regardless of signage, state law prohibits enforcement without proper signage to notify drivers. (Practically speaking, OSVs rarely attempt to park in residential zones.)
State law also authorizes local jurisdictions to regulate parking in specific ways, such as with the “72-hour” rule. This allows cities to adopt ordinances permitting removal of a vehicle parked in the same spot for more than 72 hours. Palo Alto has a 72-hour ordinance, which also, to satisfy federal due process requirements, requires that City staff must post a notice on a vehicle stating it will be towed10 after 72 hours unless the vehicle travels at least five-tenths of a mile.

However, nothing in state or local law prevents a vehicle from moving and re-parking in the same location. Prior to towing a vehicle believed to be used for shelter, Police Department personnel and the City’s homeless outreach team collaboratively engage in outreach efforts to attempt to connect occupants with alternative housing or safe parking options. The Police Department has primarily focused on abandoned and non-operational OSVs. The Police Department has successfully collaborated with the City’s homeless outreach team and has not towed an occupied OSV.

Parking regulations are typically enforced through citations and fines. In certain situations, as defined by state law, vehicles may also be towed. Because towing is a form of property seizure, it triggers Fourth Amendment protections. Courts have ruled that a judicial warrant is generally required to tow a vehicle unless the action falls under the judicially-defined “community caretaking doctrine.” This doctrine authorizes towing vehicles that jeopardize public safety and the efficient movement of vehicular traffic or to keep the vehicle from being a target for 10 The City's ability to tow OSVs is constrained by the limited number of tow companies operating the specialized equipment necessary for towing OSVs, and by limited local tow yard capacity to store OSVs.

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vandalism or theft. In most cases, towing also requires notice and an opportunity to correct the violation.

Signage and Enforcement Considerations
Parking restrictions, including the increased street sweeping parking restrictions and the proposed ordinance banning unattached trailer parking, require installing signage to be enforceable.11 Implementing signage for these items could include use of temporary signs and focused sign installation in areas of high activity.

The cost of signage could be substantial. For comparison, Mountain View spent about $980,00012 in 2020 to implement signage relating to its oversized vehicle parking ordinances. In Palo Alto, estimated costs are $1,900 per block for sign installation by a contractor. As a hypothetical maximum, with approximately 2,200 blocks and two signs per side of the block, this equates to roughly 8,800 signs at an estimated cost of $4.2 million if signs needed to be posted on every block on every street.13 (However, to enforce the recommended ordinance to prohibit unattached trailers, signage would not be required on every block in the City and installation could focus on particular areas. On the other hand, state law requires block-level signage, at minimum, for street sweeping parking restrictions). In addition to costs for installation, engineering is required for sign and pole placement field verification, and work order preparation for new street signs and poles (if needed) in public rights of way. For a Citywide signage program, an additional FTE limited duration equivalent to $244,000-$269,000 per year would be needed. There may also be an impact to the work of existing engineering staff on items such as development-related traffic control plan review, routine sign upgrades, traffic signal adjustments, traffic signal upgrades, traffic calming and traffic control device plan review, and complete streets projects engineering design). For reference, Mountain View’s implementation required over two traffic engineers working full-time for 9 to 12 months.

There would also be added work for Utility Locators to check for conflicts at each site, and ongoing maintenance after installation, likely requiring additional Public Works staffing.

Consistent with current practice,14 staff would also lead with outreach workers ahead of implementing increased street sweeping or any changes to enforcement. Dedicating the 11 In some cases, California cities adopting regulatory actions relating to OSV parking have been sued by advocates for the unhoused, resulting in legal costs.
12 Number not adjusted for inflation nor construction cost increases over time. https://mountainview.legistar.com/LegislationDetail.aspx?ID=4712008&GUID=B91F5618-049D-44E7-9BA9- 966071A60D1C&Options=&Search=
13 This estimate assumes the cost for one sign to be posted throughout the City - approximately 2,200 blocks in the City and 2 signs per side per block. If signage will be installed throughout the City it would equate to approximately 8,800 signs. Installation of signs and posts by a contractor is estimated at $4.2 million (8,800 x $475). However, not every new parking restriction may require signage to this extent. 14 Currently, Police and Public Works coordinate closely with the outreach team during a weekly huddle and as- needed.

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outreach team to this work would likely impact their ability to rotate effectively throughout the city for contact with other unhoused people not living in these areas.

In terms of enforcement, a citywide parking regulation, inclusive of all the options presented in this report, would significantly increase parking enforcement workload, triggering the need for an additional 1 police officer and 1 parking enforcement officer. The approximate additional annual cost for either in-house FTEs or contracted services would be $400,000. The additional towing associated with a new citywide parking regulation could add approximately $40,000 in towing costs annually.15
Phased Approach – Actions to Accommodate Some Demand
Expanding Safe Parking on Privately-Owned and Congregation-Based Lots The City could expand safe parking options by pursuing partnerships with privately-owned commercial properties and building on its existing congregation-based safe parking program.

Allowing safe parking on private commercial property would require amending the zoning code and conducting site-specific environmental reviews under CEQA. Then the City could lease the property from interested owners and develop the site for safe parking use. Developing a zoning code amendment to allow safe parking on privately-owned sites is on the Planning and Development Services Department’s long-term work plan but is currently un-resourced.

Moreover, as currently scoped, this effort does not include identification of interested property owners, potential sites or funding sources. Progress would depend on a property owner coming forward, which has not happened so far. If that occurs, staff would need to adjust priorities to move this forward.16
15 The exact staffing and associated cost would depend on the specific regulation(s) adopted.

16 Additional Information on Resources for Safe Parking: Implementation of an expanded safe parking program on privately-owned lots, including commercial and congregation-based sites, would require substantial staff work.

This includes outreach to congregations, commercial property owners, and surrounding neighborhoods to gauge interest, identify concerns, and assess willingness to participate; evaluation of potential sites for suitability, including space requirements for RVs, circulation, access, lighting, sanitation, and safety standards; coordination with the Human Relations Commission and the Planning and Transportation Commission; and development of policy options for Council consideration; for example, it could be establishing a pilot program with willing partners or preparing a draft ordinance with defined conditions for private sites.

This scope of work is currently un-resourced. If Council directs staff to proceed, resources would need to be shifted from other Council priority projects, which would result in de-prioritizing or delaying work related to several initiatives including: stream corridor, bird-safe glass, wireless, and lighting/dark skies ordinance implementation and limit the number of Council priorities that could be implemented in calendar year 2026 while staff capacity is redirected to this effort.

Prior staff work on this issue in previous years noted several concerns from commercial property owners about participating in a safe parking program. Liability issues and increased insurance premiums were identified as significant barriers. Elected officials, partnered with staff in direct discussions with potential partners may be more Item 16
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One idea proposed at Policy and Services Committee was to consider safe parking or perhaps OSV storage on airport vacant land, including places leased to car dealerships. Residential use, including temporary or short-term occupancy, is prohibited on the airport under Section 2.3.1.2 of the Federal Aviation Administration’s Advisory Circular 150/5190-4B. The two staging areas on airport land total approximately 75,000 square feet over 2 sites and are currently leased for $0.86/square foot, generating roughly $774,000 annually. If used for unoccupied vehicle storage, federal grant assurances require that the Airport Enterprise Fund be compensated at this rate. The Runway Protection Zone overlays one of the sites and both sites are affected by the Runway 31 approach.

For congregation-based lots, existing City law allows up to eight vehicles to park overnight at approved sites.17 Staff could explore expanding this to allow 24-hour parking and possibly accommodate some oversized vehicles (OSVs). While OSVs aren’t currently prohibited, the program operator notes these vehicles are hard to manage with the daily movement required under current hours. Expanding to include OSVs or longer hours would require outreach to congregations to gauge interest and address neighbor concerns.

Resource Impacts
Exploring these expansion options would require staff time and reprioritizing other work. Costs depend on the level of expansion and site conditions, especially existing amenities. Additional funding would be needed for program management and might be needed for leases and infrastructure. For context, a recent safe parking expansion with existing facilities cost about $270,000 annually to accommodate 10 additional RV spaces.

Consider Options for Buyback or Parking Program
As mentioned elsewhere (see “Expanding Safe Parking...” above and “Enhanced Services...” following), both, a buyback program and pursuing storage or temporary parking of OSVs while occupants are participating in an interim shelter (e.g., Homekey) or housing program is a novel approach for the City. A couple of jurisdictions recently pursued buyback and at least one is leveraging a local storage facility to pursue storage. The efficacy, effort required, and costs for this approach are largely unknown at this time. A buyback program in Berkeley disbursed a total of $150,000 for 21 OSVs. The storage cost for OSVs would likely vary significantly based on location, security involved, and insurance costs. There are no existing OSV storage lots in Palo Alto. The nearest that staff is aware of is in the City of San Mateo and, at the time of this report, staff does not have the per vehicle per month rates charged. Staff estimates that exploring this option would take a couple months to research and analyze and that approvals, agreements, and implementation would require several additional months. Without additional staffing in the effective than developing a broad pilot program or ordinance, which tends to be more passive and resource intensive. If a partner is identified the city could negotiate a site-specific regulatory agreement to advance the City’s interests in this topic.
17 Safe parking at churches and other religious institutions is regulated at PAMC section 18.42.160.

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near term, an ambitious target would be returning to Council with a recommended path forward and funding request for the Fiscal Year 2027 budget.

Increased Cleaning and Street Sweeping on Selected Streets The City could focus increased cleaning and sweeping on streets where clusters of OSVs are parked. Streets impacted by OSVs require more frequent and thorough cleaning and maintenance than other areas to address refuse, biohazards, and debris. The City can use parking restrictions to support thorough street sweeping by prohibiting parking on designated streets during sweeping hours. Staff would propose to sweep each side of the designated streets twice per month on alternating weeks. For instance, one side could be swept the first and third Wednesday, while the other side was swept the second and fourth Wednesday.

Streets currently or recently affected by high concentrations of OSVs include Embarcadero Way, Embarcadero Road east of Highway 101, Faber Place, Elwell Court, Corporation Way, East Meadow Circle, Fabian Way, Park Boulevard, Sheridan Avenue, Portage Avenue, Ash Street, Commercial Street, Transport Street, Industrial Avenue, the 1000 block of Colorado, the 900 block of San Antonio, Lambert, and Sheridan (east of Park).18 The street sweeping parking restrictions may encourage OSV owners to relocate, potentially shifting impacts to more sensitive areas like retail or residential neighborhoods.

To reduce storm drain contamination, the City could install filter fabric at storm drain locations to block larger debris, sediment, and soil particles from entering the storm drain system.

Additionally, specialized cleanup crews and equipment are necessary to address any biohazardous debris.

Resource Impacts
Costs for signage, increased street sweeping, and specialized cleanup services would need to be addressed. Installing street sweeping signage on the above-mentioned streets where the highest concentration of OSVs commonly park is estimated at about $100,000 in addition to staff time and deferral of other priorities in order to engineer the installation of the signs.

Posting temporary No Parking signs for the above-mentioned streets to enable expedited street cleaning work, before permanent signs are installed, is estimated at $143,000. Cleanup after OSVs move on—often involving fluid spills, biohazards, and abandoned items—requires dedicated crews working 4 to 8 hours per instance, costing between $2,000-$4,000 plus debris disposal fees. Increasing street sweeping to weekly schedule year-round on these streets would add roughly $12,000 annually. If street sweeping for these abovementioned street segments is changed from the current schedule of weekly sweeping during Leaf Season and bi-weekly 18 This list has been updated and amended since the Policy and Services Committee meeting to add portions of Colorado, San Antonio, Lambert, Olive, and Sheridan. Cost for in-house signage along these streets would be approximately $80,000 and take a minimum of 6 months with in-house staff operating on mandatory overtime.

The cost for the increased frequency of street sweeping would be $12,000 for weekly, year round sweeping of these streets. If the increase were to be one side of the street each week, year round there would be no net increase cost for the sweeping.

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sweeping during non-Leaf Season, to sweeping only one side of the street twice per month year-round, alternating sides each week, then staff anticipates there will be no net increase in street sweeping cost.

Enforcement would increase the workload for Police Department parking enforcement staff, as well as increase towing expenses. First-year cost assumes this program would begin with temporary signage. Temporary signage must be maintained and properly noticed to be legally enforceable. At a minimum, staff are required to check temporary signage three days before the scheduled sweeping day when enforcement occurs prior to actual sweeping. If a vehicle is towed, staff time requires the presence of a parking officer and a sworn police officer. At inception, this program will require significant outreach by the police staff and the homeless outreach team. As compliance with the sweeping program increases, enforcement staff time and the number of tows is anticipated to decrease. The FY26 cost of this effort is estimated at $95,000, inclusive of staff time and enforcement towing - depending on vendor capacity to accept these vehicles. Ongoing costs would be a 0.5 FTE at $70,000 - $80,000 annually and some ongoing towing funding is already in the Police Department’s operating budget.

Enhanced Services Relating to Inhabited OSVs
The City could further address the impacts of inhabited OSVs with enhanced services, including outreach to people living in vehicles, mobile sanitation support (e.g., garbage collection, pump- out), and potentially explore new strategies like an OSV “buyback” program. These could complement expanded street sweeping and stormwater protection efforts already under consideration. Outreach is a key first step. People living in vehicles often take longer to engage with service providers and may be hesitant to leave the perceived independence and security of their vehicles for shelter options. The City currently has under contract two outreach workers who have recently updated their schedules so that one primarily operates weekday daytime shifts, while the other worker covers weekends and some evenings. Further expanding evening and weekend coverage could improve engagement and trust-building, as anecdotally, this population tends to be working during daytime and weekend hours.

To encourage voluntary participation in shelter programs, the City could consider piloting a vehicle buyback program, as seen in Berkeley and San Francisco, where modest cash incentives were offered in exchange for relinquishing vehicles and moving into interim housing. While promising, this remains a relatively new and untested strategy.

For sanitation, the City could designate a waste drop-off site for OSV occupants or use existing facilities with capacity for increased disposal. Staff does not recommend installing new public waste bins due to concerns about illegal dumping. However, another option could be to issue RV dwellers their own solid waste containers to be placed out for collection on assigned collection days and serviced by GreenWaste of Palo Alto. Some jurisdictions have piloted pump- out programs for RVs with mixed results. For example, Portland’s program served over 4,000 OSVs in a few years using a combination of scheduled routes and on-demand service, while Item 16
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other cities, like Long Beach, saw limited participation. Staff can further explore during Phase 2 how to help OSV occupants appropriately dispose of both their solid waste and liquid waste.

Resource Impacts
The City currently spends approximately $256,000 annually on its contracted outreach program, which includes two full-time outreach workers and a part-time manager.19 A potential OSV buyback program’s cost would depend on the scale of implementation. For reference, the City of Berkeley allocated $150,000 to a pilot program, which showed early success—20 out of 21 OSV occupants accepted a cash offer in exchange for moving into interim housing and relinquishing their vehicles.

Residential curbside refuse collection services provided by GreenWaste of Palo Alto, the City’s contracted hauler, are $50.07 per month for the standard size 32-gallon size container.

Extrapolating from the estimated number of 133 vehicles,20 the estimated projected additional annual expense for such service is about $80,000. Providing a larger container for each block, such as a two cubic yard bin, is another option but would come at a significantly higher cost.

Mobile pump-out services would require additional research to determine local costs, but available examples provide useful context. Portland spent roughly $805,000 over four years (about $22,000 per month), while Mountain View’s three-month pilot cost was $29,000 (about $7,250 per month), with a per-service cost of $391, not including staff time. These two programs had different service models.

Phased Approach – Actions to Increase Regulation
Prohibit Storage of Detached Trailers/Non-motorized Vehicles on Public Streets A common concern from the community is the presence of detached trailers and other non- motorized vehicles that are clearly not able to move under their own power and taking up public parking spaces. The City could adopt an ordinance banning the parking of non-motorized vehicles, such as camper shells and trailers, on public streets when not attached to a motor vehicle capable of legally moving them. Staff recommend a prohibition that applies throughout the City, at all hours. Alternatively, parking could be limited to a set duration, like 1-2 hours.

This would help free up parking spaces currently being used for storage of stationary vehicles unable to move under their own power to comply with the 72-hour parking limit.21 19 Currently, the program is funded through a combination of State Permanent Local Housing Allocation (PLHA) entitlement funds, City General Fund contributions, and financial support from Stanford University. 20 This number considers all vehicles not in safe parking (168 vehicles – 35 in safe parking). The estimate was calculated at 133 vehicles for $50.07/month each, totaling $6,659, or $79,912 annual cost. 21 The zoning code (Title 18) includes a prohibition on storing or parking non-operable conveyances on private property, except where screened from neighbors. This provision is enforced by Code Enforcement through issuance of warnings, administrative citations, and fines. For non-motorized conveyances on public streets, staff recommends adoption of a new ordinance specifically addressing use of public parking spaces, enforceable by the Police Department or Office of Transportation.

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The ordinance would apply to all such conveyances, whether inhabited or not. At the Policy and Services Committee meeting, a Councilmember expressed concern for contractor trailers retaining the ability to park in public parking spaces. However, a ban on detached trailers will not impact trailers used by construction crews which already require a City permit for parking.

The prohibition could also include exceptions for loading/unloading and emergency repairs.

Signage would be necessary to enforce this rule, with priorities likely starting in areas most impacted by detached trailers.

The prohibition would be enforceable as a parking citation and by towing.

If directed to return on the Consent calendar with an ordinance as described in this section, staff could bring an ordinance for a first reading as early as December 2025 or January 2026.

Resource Impacts
Sign installation for enforcement would require some costs for the additional signage22 and staff from both the Office of Transportation and Public Works Department, similar to other parking restriction projects.

While enforcement, in the short term, is expected to moderately increase the workload for existing parking enforcement officers and increase towing costs, implementing multiple measures, to include clean sweeping enforcement and this strategy, may require an additional

0.5 full-time equivalent (FTE) staff, at a cost of about $70,000-$80,000 annually. Towing would likely be done using the current operating budget and is dependent on towing company capacity. Enforcement for Detached Trailers/Non-motorized Vehicles and street sweeping would share resources.

Prohibit Renting of Public Parking Spaces (“Vanlording”) Staff identified that some occupied OSVs parked on city streets are being rented out by so- called “vanlords” who profit from leasing public parking spaces for habitation. To address this, the City could adopt an ordinance prohibiting the rental of vehicles for living purposes on public streets or the sale of space in the public right-of-way. The goal would be to prevent private profit-taking from a public resource and protect vulnerable renters who often pay for substandard, unregulated living conditions.

The ordinance would target the vanlord—not the renter—and could include escalating daily fines for violations. Other cities are beginning to take similar action. San José recently passed a vanlord-specific ordinance, and Los Angeles is considering one. While San Francisco doesn’t directly regulate vanlords, it does ban leasing public streets or sidewalks, with fines of up to $300 per violation.23
22 Staff believes that this signage would be less extensive and should cost a lower amount. 23 San Jose’s vanlording ordinance is available here:
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Enforcement may be difficult, as identifying vanlords often depends on information from renters, who may be reluctant to cooperate if the practice is banned. As a result, enforcement would rely on staff investigations.

If Council directed staff to return on the Consent calendar with an ordinance prohibiting vanlording as described in this report, staff could bring an ordinance for a first reading as early as December 2025 or January 2026.

Resource Impacts
Implementing a vanlord ban would require staff resources, primarily from the Police Department and City Attorney’s Office. Staff would need to gather evidence—both online and in the field—identify the vanlord, and issue warnings or fines. If a vehicle is occupied, the City would also assess what support services could be offered to the residents. While it is still too early to determine impact to workloads for Police, to be effective with investigating illegal renting, Police staff expect one more police officer would need to be resourced – by either diverting away from other investigations, which is not recommended, or add 1.0 FTE during the FY 27 budget cycle at approximately $280,000 ongoing.

Limit OSV Parking to Certain Streets with Focused Regulations The City could manage OSV parking by designating specific streets for OSV parking and prohibiting it elsewhere. This strategy, similar to Mountain View’s approach under the term of a legal settlement,24 would help mitigate public health, sanitation, and parking impacts while providing clearer guidelines for both enforcement and services. These designated streets would likely be in commercial or industrial areas where residential or school-adjacent impacts are minimized.25 This targeted approach, paired with the above-mentioned increased services— regular street sweeping, trash/waste collection/removal, and safety measures—on streets where OSVs are allowed. Localized parking regulations like red curbs and intersections clearances could also be implemented to maintain safety and access.

Preliminary analysis suggests that street segments where OSVs are currently clustered could accommodate an estimated 200 OSVs,26 though this would reduce the availability for other users and pose ongoing localized challenges arising from habitation on public rights of way not 24 At Policy and Services, a Councilmember asked what the change in number of OSVs was in Mountain View since it began enforcing its oversized vehicle restrictions in October 2022. Mountain View counted 208 vehicles in August 2022 (138 RVs, 35 passenger vehicles, 35 other), 151 vehicles in January 2023 (115 RVs, 21 passenger vehicles, 15 other vehicles), 148 vehicles in August 2023 (99 RVs, 11 passenger vehicles, 38 other), and 223 vehicles in July 2024 (143 RVs, 31 passenger vehicles, 49 other). Mountain View had not published its 2025 vehicle count at the time this report was written.
25 The municipal code already prohibits OSV parking between the hours of 2:00 and 6:00 am on streets located within residential and public facilities zones. However, to enforce the provision, state law requires local jurisdictions to install signs adequately informing parkers of the restriction. Moreover, any attempt to formally designate a subset of non-residential streets on which OSVs may park (i.e., prohibiting OSV parking on all other streets) would require amending the municipal code.
26 Per the 2025 PIT Count, there were 170 vehicles counted: 29 cars, 122 RVs, and 19 vans.

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designed to support the ongoing activities of living.27 In consideration of these localized challenges, two of three Committee members voted to identify non-residential and “non- residential-adjacent”28 streets where OSV parking would be permitted, with the goal of distributing these locations as evenly as possible through the city to avoid overconcentration.29 The number of OSVs allowed to park could be tied to the City’s Point-in-Time (PIT) count, ensuring that capacity remains responsive to actual need. The Committee also raised the possibility of a permitting program to help regulate and monitor OSV parking. In addition, all designated streets could be clearly marked to communicate where OSV parking is allowed, further supporting enforcement and public understanding.

To ensure this is fair and manageable, the City would need a detailed plan identifying where OSVs may or may not park, rather than adopting piecemeal restrictions. Ongoing enforcement of the 72-hour parking rule would continue, and a process would be needed to periodically review and update designated streets.

Resource Impacts
As mentioned in the “Signage and Enforcement Considerations” subsection earlier in this Analysis section, any citywide parking regulation would require significant signage and enforcement-related resources. The resource burden is somewhat ameliorated by the phased nature of the overall recommendation.

Summary of Phased Approach
The table below summarizes the costs referenced about each of the programs.

PHASE ACTION

ESTIMATED

DURATION/

COMPLETION

ESTIMATED COST/

BUDGET TIMING

IMPLICATIONS
All Support program implementation 2 years $314,000 (total over 2 years); some costs can
be prorated
Phase 1

1.1 Develop ordinance to prohibit detached/inoperable
vehicle parking on public streets
3 months –
January 2026
Staff time only
27 Analysis assumptions include OSV length of 30’, 5’ distance between vehicles, driveway clearance of 10’, intersection clearance of 20’, hydrant clearance of 15’ and 300’ hydrant spacing. The estimate analyzed the 14 streets where high concentrations of OSVs are currently clustered, focusing on the segments of those streets where OSVs park. Given those parameters, the combined street length is approximately 12,000 linear feet and assuming one sign per 150 feet and $300/sign.
28 The municipal code restricts overnight parking of OSVs on streets where the property on at least one side carries a residential or public facilities zoning designation, but it does not prohibit OSV parking on “residential-adjacent” streets or include a definition of that term. If Council wants to expand the restriction, it would need to formulate a definition of “residential-adjacent.”
29 The Councilmember voting against the motion that included this idea was advocating to explore all other options before pursuing limiting OSV parking to certain streets.

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PHASE ACTION

ESTIMATED

DURATION/

COMPLETION

ESTIMATED COST/

BUDGET TIMING

IMPLICATIONS

1.2 Develop an ordinance to prohibit renting public
parking spaces
3 months –
January 2026
Staff time only

1.3 Refine scope & begin implementation of additional
street cleanups and sweeping
3 months – Jan
2026
$548K for FY26; plus an
additional $269K in FY27
for engineering; some
costs can be prorated[1]

1.4 Begin adoption of ordinance(s) (i.e., vanlord,
inoperable vehicles) and contract(s) approval (i.e.,
for street sweeping) on consent calendar
3 months – Jan
2026
Staff time only

1.5.1 Implement & enforce detached/inoperable vehicles
prohibition
Apr/May 2026 Unknown amount for
signage/FY26
enforcement included in

1.3; FY27 additional
$80K/yr

1.5.2 Implement & enforce vanlord (public parking space rental) prohibition
Apr/May 2026 FY26 enforcement
included in 1.3 and 1.5.2;
FY27 additional $280K/yr
for 1.3 thru 1.5.2; CAO
time dependent on
volume

1.6 Work with LifeMoves [and Santa Clara County] to
consider options (buyback, storage) and to accept
RV residents quickly at Homekey or other housing
6 months –
Apr/May 2026
Unknown - $150,000[2]
for buyback program/
FY27 Budget

1.7 Return to Council for direction on expanding safe
parking on privately-owned and congregational
based lots
If no site
identified, then
9+ months –
August 2026[3]
Staff time only
Phase 2

2.1 Develop small scale enhanced services pilot 5 months - Oct 2026
Staff time only

2.2[4] Begin exploration of limiting OSV parking to certain streets, including process/criteria for designating
streets, with community engagement
6+ months –
Nov/Dec 2026
Staff time only

2.2.1 Identify non-residential & non-residential adjacent streets
6+ months –
Nov/Dec 2026
Staff time only

2.2.2 Tie the number of OSV permitted parking to the PIT count
<1 month Staff time only

2.2.3 Explore possibility of OSV permitting program 3+ months – Aug/Sept 2026
Staff time only

2.2.4 Evenly disburse permissible OSV parking across
identified streets to avoid overconcentration and
mark clearly on those streets where permitted
6+ months –
Nov/Dec 2026
Staff time only
Phase 3
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PHASE ACTION

ESTIMATED

DURATION/

COMPLETION

ESTIMATED COST/

BUDGET TIMING

IMPLICATIONS

3.1 Council approval of enhanced services pilot and
related contracts/agreements
Nov/Dec 2026 $400,000+ one-time
FY 2027 Budget

3.2 Council approval of preferred expanded safe
parking option(s)
Aug/Sept 2026 Staff time only

3.3 Council identification of streets where OSV parking permitted & develop ordinances and program
design
6+ months –
Nov/Dec 2026
Staff time only

3.4.1 Implement enhanced services pilot Jan/Feb 2027 Staff time only

3.4.2 Approve preferred option for expanded safe
parking[5]
Late 2026 &
onward
Staff time only
Phase 4

4.1 Evaluate enhanced services pilot Jan/Feb 2028 Staff time only

4.2 Pursue implementation of expanded safe parking.[6] Late 2026 & onward
$270,000+
annually/Midyear 2026-
2027 Budget

4.3 Council approvals relating to limiting OSV parking
to certain streets.

Jan/Feb 2027 $4.2 million one-time for
citywide signage
FY 2027 Budget
$400,000+ annually
thereafter (this includes
$80K for enforcement for

1.3-4.3)

4.3.1 Implement “limiting OSV parking to certain streets” and begin enforcement.
3-6 months -
May/Aug 2027
Staff time only
[1] This amount includes $100,000 for new permanent signage, $143,000 for temporary signage if the City wants to start implementing street cleaning immediately, plus $60,000 for the estimated cost of deep cleaning of the 18 street segments (where OSVs are currently clustered) after the OSVs leave each area for the initial cleaning. Staff anticipates phasing in this work, starting with a few blocks each week over several months. This allows time for workers to install signs along nearly 40,000 linear feet of roadway. The sweeping and cleaning work can follow behind as signs are installed. Additionally, this amount includes $150,000 for engineering analysis, plans, work orders and inspection related to signage, striping and curb paint throughout the City. It also includes $95,000 for enforcement support rolled out as PW works through the progressions. [2] A buyback program in Berkeley applied $150,000 for 21 OSVs. The storage cost for OSVs would likely vary significantly based on location, security involved, and insurance costs. There are no extant OSV storage lots in Palo Alto. The nearest that staff is aware of is in the City of San Mateo and the per month vehicle costs were not available at the time of this report publishing.
[3] Note: this timeframe does not align with the P&S Committee recommendation. The motion called for Safe Parking expansion to be moved to Phase 1; however, with no specific site identified to date, this effort is currently not resourced as noted in footnote 16 earlier in this report. [4] This particular action was part of a split motion that indicated it would be in Phase 2. As parts of this action also appear in the unanimous motion, where those appear, they are also italicized. [5] Since expanded safe parking implementation is also part of Phase 4, staff is considering this the initial implementation steps. Since both proposed expansion options require a willing non-city partner, implementation will begin with outreach and, if successful, result in permitting (e.g., congregation-based) and/or leasing (e.g., Item 16
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privately owned).
[6] See note above.

FISCAL/RESOURCE IMPACT
The recommended phased approach would require City funding as outlined in the table below and ongoing staff allocation for the foreseeable future. Although funding sources for the majority of this work have not yet been identified, a significant General Fund allocation is likely.

Staff will also research and evaluate other funding sources (e.g., grant funding and/or entitlement opportunities, and Business Tax Revenue for Affordable Housing and Unhoused Services). The budget appropriations reflected in the recommendations on the first page of this report are intended to provide the up-front resources required to move forward on immediate actions, with the expectation that additional appropriations and funding sources will be identified at the mid-year budget report in early 2026.

In the near term, the significant front-loading of items into Phase 1 will require reallocating staff resources, will impact other Council priorities, and will require appropriation of a total of $707,000 in FY 2026: (1) $157,000 to the City Manager’s Office for resources to support program implementation (2) $305,000 to Public Works for additional street cleaning on currently impacted street segments and related signage, (3) $150,000 to the Office of Transportation (pro-rated) for engineering analysis, plans, work orders, and inspections, and (4) $95,000 to the Police Department for enforcement and towing services. These costs will be funded by: (1) $157,000 from the Business Tax Revenue for Housing Affordability, (2) $245,000 from the Refuse Fund, and (3) $305,000 from the General Fund Budget Stabilization Reserve.

The ongoing costs for these services would impact the General Fund by approximately $0.7 to $0.8 million ongoing annually. In addition, funding for signage in the Capital Improvement Fund may need additional support from the General Fund depending on resources available in the Infrastructure Reserve for capital improvements.

This report focuses on immediate steps to ameliorate the impacts of vehicle dwelling in Palo Alto. In light of the increasing PIT numbers, however, addressing homelessness in a lasting way will ultimately require additional housing for the people being helped. Although not covered in this report, this longer-term effort is important to keep in mind.

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Action Funding
Source FY 2026 FY 2027 FY 2028 &
Ongoing
Street Sweeping Signage Refuse Fund $245,000 $0 $0
Clean-up Services General Fund $60,000 $0 $0
Engineering General Fund $150,000 $269,000* $0
Enforcement/Towing General Fund $95,000 $440,000 $440,000 Expanded Safe Parking General Fund $0 $135,000 $270,000 Signage for Additional Parking
Restrictions
Capital Fund $0 $4,200,000* $0
Administration/Implementation Business Tax $157,000 $157,000 $0 Buyback/Storage Program Business Tax $0 $150,000 $0
Enhanced Services Pilot Business Tax $0 $400,000 $0
Total $707,000 $5,751,000 $710,000
General Fund Impact * $305,000 $844,000 $710,000
Business Tax Revenue Support $157,000 $707,000 $0
*Parking Signage work in the Capital Fund may require additional funds to be transferred from the General Fund depending on resources available in the Infrastructure Reserve. The $4.2 million for signage and $269,000 for engineering is the estimated maximum cost to sign Citywide; see discussion in the Analysis section under the Signage and Enforcement Considerations item of this memo. The cost will ultimately vary depending on such factors as: the number of new parking regulations adopted (and therefore the number of new signs), the geographic scope of a new parking restriction, and the availability of existing poles/infrastructure for new signs.

STAKEHOLDER ENGAGEMENT
Staff has made some preliminary efforts to gather feedback from the community on the Committee’s recommendation. This included seeking input from the “RV Dwellers Group” of service providers, a representative of Stanford University, members of the faith-based community, City staff, a City Councilmember, and a Human Relations Commission member, at its regular meeting in September 2025. Attendees discussed how to address and balance needs and concerns, including:
•Considering extending safe parking near Geng Road site, •Understanding how many people living in vehicles work in Palo Alto, how many are van lifers, and noting that there is distrust and fear in this community, •Concern about people who would not qualify for housing and/or services based on immigration status, and
•Concern about the health and safety of people living in “vanlord” vehicles.

ENVIRONMENTAL REVIEW
Council action on Phase 1 provisions about enhanced cleaning, street sweeping, parking signs, and parking enforcement are categorically exempt under CEQA regulations 15301 (existing Item 16
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facilities) and 15321 (enforcement actions). Other items in Phase 1 and in later phases require further Council input and/or approval and CEQA will be addressed as those are approved.

ATTACHMENTS
Attachment A: Neighboring Cities’ OSV Parking Approaches Attachment B: Policy and Services Committee August 25, 2025 Staff Report APPROVED BY:

Ed Shikada, City Manager
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Attachment A: Neighboring Cities’ OSV Parking Regulations The following is a non-exhaustive list of the approaches some of our neighbor cities have taken to managing the impacts of inhabited Oversized Vehicles (OSVs).

San Jose
•“Oversized and Lived-In Vehicle Enforcement” (OLIVE) pilot program 1:
oThe program, funded by a $1.5 million budget addendum, is intended to help address the environmental and safety issues caused by oversized vehicles, including lived-in vehicles, parked on city streets. It directs City staff to:
▪Identify areas impacted by the parking of oversized and lived-in vehicles on city streets
▪Establish temporary tow-away zones to allow cleanup of impacted areas and encourage vehicles to relocate
▪Analyze the feasibility of installing permanent parking restrictions at select locations
o30 sites were identified in FY 2025 and up to 50 will be identified in FY 2026 for temporary tow-away parking restrictions (approximately one month in duration) to help facilitate the cleanup and street sweeping of the area and encourage people to move their vehicles out of the restricted zone. Vehicles that are not voluntarily moved from tow away zones will be subject to towing and impound. Based on the success of the temporary restrictions, up to 10 sites will be considered for permanent parking restrictions.
•Designated “no overnight parking” and “no large vehicle parking” zones. Towing authorized for violations.2
•Ban on vanlording and on living in vehicles, which went into effect in July 2025. 3 Services including safe parking, vehicle buy-back program, biowaste removal, and trash pickups for lived-in vehicles.4
San Mateo
•Prohibits parking oversize vehicles and detached trailers on residential streets throughout the city. 5
•Prohibits living in vehicles. 6 The City had not been enforcing this ordinance, which was originally passed in the 1990s, but recently began enforcing it again after a dedicated outreach period.7 Menlo Park
•Effective April 2025, OSVs may not park overnight (2-5 am) on any public street in the city. 8 •The City also recently updated its 72-hour ordinance and adopted ordinance language to implement AB 413 (state law that prohibits parking within defined distance of intersections).9 Fremont
•In late 2024, the Fremont City Council approved municipal code amendments that would:
oProhibit parking an OSV on any public street within 100 feet of a residential property line.10
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oAmend the City’s 72-hour ordinance to clarify that “Any vehicle that has been parked or left standing in the same location or parking spot for seventy-two (72) consecutive hours must be moved at least one thousand (1,000) feet (approximately two-tenths (2/10) of a mile) from its current location and may not return to the same parking spot for at least twenty-four (24) hours after its departure.”11 oThe associated staff report 12 acknowledged that enforcement would be largely complaint-based. Staff estimated that substantially expanding parking enforcement beyond their current model would require several additional FTEs at a total ongoing expense of about $1.2 million plus additional one-time expenses for equipment and material.

Sunnyvale
•Sunnyvale plans to expand safe parking. At the end of 2024, the Council passed an ordinance 13 that would govern safe parking programs in the city. It also directed staff to pursue implementing a safe parking pilot program on public land and a general fund grant for nonprofit or faith-based organizations to provide safe parking on private land.14 San Francisco
•San Francisco recently imposed a citywide two-hour limit on OSV parking. Vehicles that have applied for and received a “refuge permit” are exempt from enforcement.15 To be eligible for a permit, applicants must:
oHave been living in a large vehicle in SF as of May 2025 (verified by City staff count) oBe actively engaging with City services for the unhoused oAgree to adhere to a “good neighbor policy”
oAllow Public Works to clear debris around the vehicle
oAgree to relinquish the vehicle (via City-run buy-back program or otherwise) and enter permanent housing or non-congregate interim housing if offered. •The City has budgeted $13 million for the program over two years. Enforcement is set to start November 1, 2025.

Cupertino
•City recently passed a first reading 16 of an ordinance that would ban overnight OSV parking throughout the city. Housed city residents would be eligible to apply for up to 20 permits a year that would allow them to park their OSVs on the street for up to 72 hours at a time. •The ordinance also bans renting out a vehicle for living or sleeping quarters in the public right of way.
•At the time this report was written, the ordinance had not yet taken effect. 1 https://www.sanjoseca.gov/your-government/departments-offices/transportation/parking/vehicle- abatement/oversized-and-lived-in-vehicle-enforcement
2 https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:eab8cf93-9cc5-4caf-a89a-0358319167f0 3 https://library.municode.com/ca/san_jose/ordinances/code_of_ordinances?nodeId=1363727 4 https://www.sanjoseca.gov/residents/homelessness-hub/homelessness-hub-faqs 5 https://www.cityofsanmateo.org/2407/Oversized-Vehicle-Parking Item 16
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6 https://law.cityofsanmateo.org/us/ca/cities/san-mateo/code/10.04.140#(a) 7 https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:9f595393-eae3-4d52-b18d- 88cb77eef4f0?viewer%21megaVerb=group-discover
8 https://www.codepublishing.com/CA/MenloPark/html/MenloPark11/MenloPark1124.html#11.24.075 9 https://www.menlopark.gov/files/sharedassets/public/v/1/agendas-and-minutes/city-council/2024- meetings/agendas/20241112/l1-20241112-cc-oversized-vehicle-and-parking-ord.pdf 10 https://www.codepublishing.com/CA/Fremont/#!/Fremont10/Fremont1005.html#10.05.555 11 https://www.codepublishing.com/CA/Fremont/#!/Fremont10/Fremont1005.html#10.05.550 12 https://fremontcityca.iqm2.com/Citizens/Detail_LegiFile.aspx?Frame=&MeetingID=1980&MediaPosition=&ID=5 285&CssClass=
13 https://ecode360.com/46385883
14 https://sunnyvaleca.legistar.com/LegislationDetail.aspx?ID=7014182&GUID=1ED10C32-1325-4891-ABED- 959D528361C5&G=FA76FAAA-7A74-41EA-9143-F2DB1947F9A5&Options=&Search=&FullText=1 15 https://www.sf.gov/large-vehicle-refuge-permit-program 16 https://cupertino.legistar.com/LegislationDetail.aspx?ID=7640446&GUID=AA6B4AEF-0865-48BB-ADEB- 056F131B83A5
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CITY OF PALO ALTO
Policy & Services Committee
Special Meeting
Monday, August 25, 2025
6:00 PM

Agenda Item

1. Discussion and recommendation to Council on prioritization of potential approaches to address oversized vehicle (including recreational vehicle) impacts, particularly relating to individuals living in vehicles
Presentation
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Manager
Meeting Date: August 25, 2025
Report #:2506-4783
TITLE
Discussion and recommendation to Council on prioritization of potential approaches to address oversized vehicle (including recreational vehicle) impacts, particularly relating to individuals living in vehicles

RECOMMENDATION
Staff recommends that the Policy & Services Committee discuss and recommend Council approval of a phased approach to addressing oversized vehicle impacts.

EXECUTIVE SUMMARY
This item responds to the Council Priority Objective to present possible approaches to Policy & Services Committee to address oversized vehicle (OSV) impacts, particularly relating to individuals living in vehicles, anecdotal reports of significant increases in people living in OSVs on City streets, and recent increases in calls and complaints relating to OSV long-term parking and associated health and safety concerns. This report summarizes a variety of approaches to accommodate some demand for OSV parking and related services while also increasing regulation of OSVs. These options enable a phased approach that balances the need to accommodate those living in vehicles with the need to manage public health, safety, and neighborhood impacts, while also considering available resources. Potential phasing could begin with additional regulations, street maintenance measures, and an enhanced services pilot (e.g., mobile pump-out, garbage pick-up, and additional outreach), leading toward expanded safe parking options and limited OSV parking on certain streets with focused regulations.

At the time of this report, the 2025 Point in Time count numbers at the city level is not yet available by Santa Clara County. However, the 2023 Point in Time count observed 206 people experiencing homelessness in Palo Alto, with 88% living in approximately 102 vehicles. Given the anecdotal increases in vehicle dwellers, this report assumes a doubling of the 2023 vehicle count.

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Potential approaches for addressing homelessness impacts outlined in this report, offer potential actions and reflect experience gained from other cities’ experiences with this challenge. The preliminary list of ideas presented are to gain initial feedback from the Committee. Based on the Committee and Council discussion and direction, stakeholder engagement plans will be developed and additional fiscal analysis completed.

BACKGROUND
Homelessness is clearly one of, if not the most, vexing societal problems of our time and impacting communities across California and the nation. The City of Palo Alto aligned its homelessness response with the Santa Clara County Community Plan to End Homelessness 2020-2025, which the City endorsed in August 2021.1 Since then, the City has pursued a variety of initiatives to better support housing stability including: strengthening renter protections, enabling safe parking programs, permitting and beginning construction of the interim Homekey shelter, and supporting affordable housing developments such as Wilton Court Apartments, 231 Grant Ave, Mitchell Park Place, and development on City-owned properties such as Lot T downtown and 340 Portage Ave. On an ongoing basis, the City also responds to resident and business concerns associated with the impacts of homelessness throughout Palo Alto, with a focus on service referrals and enforcement of existing laws.

By late 2023, Council prioritized a deeper insight into the unhoused situation locally, resulting in a 2024 Council Priority Objective to conduct a gap analysis of local housing and homelessness services.2 The analysis, shared as an information item to Council on December 9, 2024, was followed by a study session on February 10, 2025.3 That session included updates on service coordination and enforcement efforts; a review of the gap analysis; an overview of suggested community engagement next steps, including involving the Human Relations Commission; and a Council discussion on housing production, homelessness prevention, support services, and enforcement efforts related to health and safety, referring follow-up discussion to the Policy and Services Committee.
1 Santa Clara County Community Plan to End Homelessness 2020-2025:
https://housingtoolkit.sccgov.org/sites/g/files/exjcpb501/files/CommunityPlan_2020.pdf ; Council Staff Report, April 5, 2021 https://www.cityofpaloalto.org/files/assets/public/v/1/agendasminutesreports/reports/city- manager-reports-cmrs/year-archive/2021/id-12133.pdf ; Council Action Minutes, August 9, 2021 https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=3354&compileOutputType= 1 2 Council Meeting, December 4, 2023 https://www.youtube.com/watch?v=A-2CuhXvs84; Council Staff Report, December 9, 2024
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=6549&meetingTemplateType=2&comp iledMeetingDocumentId=12534
3 Council Staff Report, February 10, 2025
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=6751&meetingTemplateType=2&comp iledMeetingDocumentId=13091
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Through the discussion, Council referred follow up on this topic to the Policy & Services Committee with focus on a few key areas from the February Council study session discussion.

The discussion also informed two 2025 Council Priority Objectives:7 Present options to address homelessness impacts, particularly relating to individuals living in vehicles, to Policy & Services Committee for prioritization. Identify feasible (1) regulatory approaches to manage the use of public space and (2) policy solutions to expand RV safe parking. Present options to Policy & Services for consideration and prioritization.
Organize an initial review of sources and methods to raise funding to support new affordable housing production for future evaluation. Conduct research to identify and evaluate sources and methods. Work with the Finance Committee to develop recommendations for City Council.

This staff report responds to the first Council Priority Objective. The second Objective, once staff has identified and evaluated sources and methods, will be referred to Finance Committee.

Following the study session and adoption of the 2025 Council Priority Objectives, staff presented the gap analysis on June 12, 20258 to the Human Relations Commission for discussion and input relating to housing and services for the unhoused. Two commissioners called for more housing in general and more senior housing, specifically. Individual commissioners (this was not an action item) supported a variety of ideas, including:
Adding safe parking, particularly for RVs;
Increasing incentives for below market rate (BMR) housing; Making it easier to build (e.g., streamlining the process); Addressing family homelessness, perhaps through hotel vouchers or building tiny homes;
Improving the quality of shelters;
Continuing progress with renter protections; and
More aggressively pursuing partnerships with the tech industry for a variety of things including providing communications access to people experiencing homeless (e.g., cell phones, wi-fi, etc.).
7 Council Staff Report, May 5, 2025
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=7767&meetingTemplateType=2&comp iledMeetingDocumentId=14271
8 Human Relations Commission Staff Report, June 12, 2025 https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=8147&meetingTemplateType=2&comp iledMeetingDocumentId=14739
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ANALYSIS
The 2023 Point in Time (PIT)11 count observed 206 people experiencing homelessness in Palo Alto, with 88% living in a vehicle (those individuals lived within 102 vehicles). This differs from the 32% countywide unhoused population living in vehicles. More recently, service providers and City staff have reported a significant increase in people living in vehicles in Palo Alto. At the time of this report, the 2025 PIT count numbers at the city level were not yet available. The County has indicated they will be sharing the city level 2025 PIT numbers in late summer. Given the anecdotal increases in vehicle dwellers, this report assumes a doubling of the 2023 vehicle count.

The increasing numbers of people living in vehicles on public streets presents a health and safety challenge which leads to an increased demand for off-street safe parking, outreach services, street cleaning, and waste disposal. The City received calls and complaints relating to the long-term parking of oversized vehicles (OSVs), personal property obstructing the streets and sidewalks, and improper disposal of human waste. The City Manager’s Office has noted a sharp increase in these complaints beginning in Spring 2025.

The remainder of this report provides a discussion of potential approaches for addressing homelessness impacts, looking at potential actions to (1) mitigate impacts of accommodating some demand, (2) increase regulation where impacts occur and avoiding impacts elsewhere, and (3) combine options into a potential phased approach that recognizes implementation timelines and the complexity of this issue. These options reflect experience gained from other cities’ experiences with this challenge, and a summary of some other cities’ experiences are provided in Attachment A. Please note, this is a preliminary list of ideas for the Committee’s discussion and feedback. Staff has not yet conducted outreach to community stakeholders on these ideas.

State Law and Local Parking Regulations Relating to Oversized Vehicles

In California, the state legislature has exerted preemptive authority over vehicle movement and parking regulations. Cities, including charter cities, are permitted to adopt local laws regulating parking only to the extent authorized by state law. City regulations must also comply with requirements arising from the U.S. Constitution.

In general, vehicle parking is available in the public right of way where: (a) parking is not prohibited; and (b) vehicles can be parked without blocking an active lane of traffic, fire-safety hydrants, driveways, and for other reasons set forth in state law. These general rules apply equally to parking of oversized vehicles, unless a local jurisdiction adopts parking restrictions for OSVs, which the state Vehicle Code allows.

11 The PIT count is conducted every two years in Santa Clara County.

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The Palo Alto Municipal Code includes one provision regulating OSV parking: a prohibition on parking of OSVs in residential and public facility zones between 2am and 6am. However, while the Code states this regulation is enforceable regardless of signage, preemptive state law bars enforcement without adequate signage to inform parkers of the restrictions. (Note: as a practical matter, to date, it is not common that OSVs attempt to park in residential zones.)

State law authorizes local jurisdictions to regulate parking in a variety of specific ways. One area of interest is the “72-hour” rule. State law allows cities to adopt a local ordinance authorizing removal of a vehicle that has been parked in the same place for more than 72 hours. Palo Alto has adopted such an ordinance. Prior to removing a vehicle, the ordinance requires City staff to affix a notice to the vehicle advising that the vehicle will be removed for violation of the ordinance after 72 hours unless it is moved at least five tenths of a mile. (This notice procedure satisfies federal due process requirements.) If the vehicle is moved, there is nothing in state or local law that prevents the owner from re-parking in the same location.

In general, parking regulations are enforced through citations and fines. In some circumstances defined in state law, vehicles are also subject to being towed, but towing is a seizure of property, which implicates the Fourth Amendment of the U.S. Constitution. Courts have ruled that a judicial warrant is required to tow a vehicle unless the tow is justified under the judicially-defined “community caretaking doctrine.” That doctrine authorizes towing vehicles that jeopardize public safety and the efficient movement of vehicular traffic or to keep the vehicle from being a target for vandalism or theft. In many cases, towing also requires individualized notice and an opportunity to remedy the violation.

Potential Actions to Accommodate Some Demand
A. Expand Safe Parking at Baylands Athletic Center (or Other Dedicated Parkland) The Baylands Athletic Center and surrounding area is currently dedicated parkland. Providing additional safe parking near the City’s current Geng Road site would require “undedication” of space that is currently dedicated parkland. Potential spaces to consider for undedication would be the (A) the batting cage area, or (B) the land facing the current safe parking site on the other side of Geng Road, or (C) the baseball field, as shown in Figure 1 below. Undedicating any of these areas would require a vote of the electorate. This change would provide additional spaces for safe parking, facilitate the provision of services to those living in their vehicles, and reduce the number of vehicles parked on public streets. It would, however, only accommodate a fraction of the oversized vehicles currently occupying public streets around the city.

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Figure 1, Baylands Athletic Field space, showing (A) batting cages, (B) land facing current safe parking, and (C) baseball field.

Implementation Considerations
This change would require analysis under the California Environmental Quality Act (CEQA), as well as the work needed to convert the space to a safe parking site (e.g., grading, plumbing, electrical, etc.). The land facing the current safe parking site (area B in Figure 1), would need to be surveyed for sensitive species and habitat.

Converting the athletic field to a safe parking site could impact other uses of area C such as baseball field use and staging and space for events held at the site (e.g., the annual Moonlight Run). Converting and running the site would require both City funding and support from Santa Clara County and non-profit partners. Any of the proposed portions in or around the Baylands Athletic Center could likely support 10-20 safe parking spaces. Use of any of this area for safe parking could limit future opportunities for habitat restoration or recreational uses.

C
A
B
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Resource Impact
Resources required include the cost of putting an item on the ballot, plus site preparation and operational costs. For the 2026 ballot, costs are forecast to be approximately $100,000 for a single ballot measure (e.g., base charges, printing, legal publication/notice, analysis). The recent safe parking expansion, adding 10 RV spaces, cost roughly $270,000 annually, covering staffing (e.g., facilities management, case management, outreach), utilities, portable restrooms and sinks, and administrative costs. Assuming approximately 14,000 square feet of space needed to accommodate 10 additional oversized vehicles (OSVs), site prep costs for clearing vegetation, grading, paving, and striping would be approximately $600,000.13 With federal funding cuts for housing and homelessness, the County does not have additional resources to contribute.

Overall, staff estimates that the minimum cost would be $1,000,000 in the first year, which would include election costs, site preparation, and operations. Ongoing, the annual cost is estimated to be similar to the recent safe parking expansion amount of $270,000 annually.

B. Safe Parking on Privately-Owned Commercial Lots
The City could allow safe parking sites on privately-owned commercial property. Allowing this use of commercial property would likely require an amendment to the City’s zoning code. It would require analysis under CEQA, with issues that will be site-specific. The City could then enter into a lease with the property owner for safe parking operations.

Implementation Considerations
This approach is in the Planning and Development Services Department long-term workplan (forecasted for 2026) but is not currently resourced given no currently identified site. It would require a private property owner willing to lease land to the City for this purpose, and to date no property owner has come forward. Should a willing property owner come forward, staff would need to reprioritize other work to advance this option.

Resource Impact
The impact would vary depending on the existing onsite amenities (e.g., utilities, buildings, restrooms, etc.), versus anything that would need to be brought in. As mentioned above, the recent safe parking expansion cost roughly $270,000 annually for 10 additional RV spaces at a site with existing amenities (i.e., onsite showers, restrooms, kitchen, fencing, office space, etc.).

The cost of a lease with a property owner is unknown.
13 The expansion area for 2000 Geng Road Safe Parking measures approximately 113 feet by 118 feet or 13,334 square feet and can accommodate 10 oversize vehicles, together with sufficient portable toilets, sink, and trash receptacles. The cost estimate is preliminary and includes paving costs and contingencies for design, testing and stormwater treatment as the area is over the 5,000 square foot requirement.

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C. Expand Congregation-Based Safe Parking Program
In January 2024, Council made permanent the City’s Congregation-Based Safe Parking Program,15 including regulations allowing for up to eight (8) vehicles overnight. Staff could explore feasibility of and interest in expanding the congregation-based program to allow vehicles to stay 24 hours and/or to consider allowing some number of OSVs.

Implementation Considerations
While the City does not prohibit OSVs from the existing congregation-based program, the safe parking program operator has noted these sites are not ideal for OSVs because the daily movement required with the existing operation hours would be difficult for OSVs. An exploration of adding OSVs to these sites and extending the program from overnight to 24-hour parking would involve outreach to congregations and neighbors.

Resource Impact
Researching and developing this policy change would require staff time and reprioritizing other work.

D. Increased Cleaning and Street Sweeping on Selected Streets Streets impacted by OSVs often need more frequent and thorough cleaning and maintenance than other streets. This could include streets where OSVs are currently observed, including:

Embarcadero Way, Embarcadero Road east of Highway 101, Faber Place, Elwell Court, Corporation Way, East Meadow Circle, Fabian Way, Park Boulevard, Sheridan Avenue, Portage Avenue, Ash Street, Commercial Street, Transport Street, and Industrial Avenue. Regular street sweeping can mitigate some of the impacts associated with long-term inhabited OSV parking on streets (e.g., refuse in the storm drain system).

The Vehicle Code authorizes cities to establish and enforce parking restrictions to facilitate thorough street sweeping.

Implementation Considerations
Parking restrictions to support street sweeping would prohibit all parking on the designated streets during sweeping hours, and as such street sweeping regulations may incentivize OSV owners to park elsewhere. This could include areas more sensitive to associated impacts, such as retail districts or residential neighborhoods.
15 City Council Staff Report, January 16, 2024,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=3827&meetingTemplateType=2&comp iledMeetingDocumentId=8890
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To mitigate storm drain impacts, the City could install filter fabric17 at each storm drain location to deter biohazards from entering storm drains. After OSVs relocate or move, staff have observed large amounts of debris left behind, including fluid spills and biohazards. This requires not only street sweeping, but a team and special equipment to address the biohazard elements of the cleanup.

Resource Impact
The City would incur the cost of signage and increased sweeping and any required road cleanup. Staff estimates signage would cost approximately $70,000 if installed along the aforementioned segments of the 14 streets where OSVs are currently clustered.18 When OSVs have been parking in a particular area for an extended period, it often requires additional cleanup of abandoned items, spilled liquids, biohazards, etc. This type of street cleanup would require the dispatch of workers for 4-8 hours from each worker, depending on the situation, at a cost between $2,000 - $4,000 (4 or 8 hours, at $100/hour), plus a debris dumping fee. To increase roadway sweeping to remove debris with a street sweeper would not trigger by itself a significant cost increase.19 As an example, if street sweeping increased to weekly, year-round only on the street segments where OSVs are currently clustered (i.e., Embarcadero Way, Embarcadero Road east of Highway 101, Faber Place, Elwell Court, Corporation Way, East Meadow Circle, Fabian Way, Park Boulevard, Sheridan Avenue, Portage Avenue, Ash Street, Commercial Street, Transport Street, and Industrial Avenue), the annual cost increase would be approximately $11,000. Enforcement of this regulation is anticipated to create a minimal workload increase for existing Police Department parking enforcement personnel and a minimal increase in annual towing expenses. However, if Council adopts multiple measures requiring additional parking enforcement, cumulatively, that would require an additional 0.5 FTE at an approximate cost of $50,000-$75,000 in parking enforcement, and additional towing 17 Filter fabric would not prevent liquids from entering the system and can cause local ponding and flooding if not removed before rains.
18 This estimate assumes signs along the 14 aforementioned street segments where OSVs are currently clustered and approximately 1 sign/150 feet.
19 The City’s current street sweeping contractor sweeps residential streets once a week during Leaf Season (October – February), and once every two weeks during non-Leaf Season (February – October). If the City increased sweeping frequency, such as changing the “once every two weeks during non-Leaf Season” to once a week so that all residential streets are swept weekly year-round, then there will be an ongoing additional cost of approximately $85 per curb mile.

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expenses of approximately $50,000-$100,000. Overall, this strategy is estimated to cost $165,000-250,000 the first year.23
E. Enhance Services Relating to Inhabited OSVs
The ongoing presence of inhabited OSVs generates impacts that the City may wish to further address with enhanced services, such as conducting outreach to people experiencing homelessness, particularly those inhabiting OSVs, providing garbage pick-up and mobile pump- outs to OSVs combined with the expanded street sweeping and storm drain maintenance described above. Other concepts such as setting up an OSV “buy back” program could also be explored. This could help increase the effectiveness of outreach and mitigate some of the impacts associated with long-term inhabited OSV parking (e.g., personal property obstructing the street, debris buildup in storm drains, improper human waste disposal).

Allocating additional resources to outreach and cleanup services could help mitigate the impacts of inhabited OSVs without requiring significant additional regulatory action or could be paired with additional regulation to mitigate impacts from OSV parking. This approach could be combined with an increase in enforcement of existing regulations, such as prohibitions on illegal dumping.

Implementation Considerations
Vehicle dwellers are often harder to contact, take longer to establish trust with service providers, and are frequently reticent to “give up” the flexibility, autonomy, and perceived security of a private vehicle for the commitment to program rules and reduced privacy associated with shelters. Currently, the City has a contract for two (2) outreach workers, with some flex scheduling available, primarily operating Monday through Friday during the daytime.

Having enough outreach workers to cover weekends, evenings, and early mornings will increase the likelihood of successful contact, which is the first step towards establishing trust.

To address the reluctance of leaving a vehicle for a shelter, the City could follow the example of other Bay Area cities (i.e., Berkeley and San Francisco) in offering a small stipend for those willing to accept shelter and relinquish their OSVs. However, buyback programs are an untested novel approach and their efficacy and full costs are not yet known. Overall, it will be difficult to identify funding for additional resources given fiscal constraints.

To provide garbage pick-up, the City could identify a dedicated location for disposing of OSV waste or an existing facility with a refuse enclosure and container capacity for additional 23 Since it is likely initial efforts will require the additional street cleanup in a more intensive manner and decrease as street sweeping assumes a regular rhythm, this estimate assumes $2,000/$4,000 cleanup (minimum/maximum) on each of 14 streets 3 times ($81,000/$168,000) plus $70,000 in signage costs and $11,000 for weekly street sweeping.

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disposal volume. Staff does not recommend placing additional public waste containers because of the potential to encourage illegal dumping.

A handful of jurisdictions in the west have attempted to provide pump-out services to OSVs, with varying degrees of success. Two recent examples are Long Beach, CA and Portland, OR.

Long Beach provided a pump-out location during weekdays and had very little uptake or use.

Portland started with a regular route on a weekly basis and then added some “by-request” responses and served more than 4,000 OSVs in the first several years of the program. Mountain View also piloted a three-week pump-out program in 2018, at two locations and two times, one afternoon/evening on Tuesdays, the other midday on Saturdays, which served 18 OSVs a total of 33 times.25
Resource Impact
Currently, the City pays approximately $66/hour (per outreach worker) for 2 FTEs and $99/hour for a 0.1 FTE manager, operating on a Monday – Friday day shift schedule, totaling $256,000 annually. Funding for the outreach pilot is provided through a combination of State Permanent Local Housing Allocation (PLHA) entitlement funds, City General Fund contributions and financial support from Stanford University.

In terms of the cost of a buyback program, the City of Berkeley allocated $150,000 towards a buyback pilot, with early results indicating 20 of 21 OSV occupants accepting a cash offer for their OSV in exchange for moving into interim housing.26 As mentioned above, additional street sweeping and cleanup has a range of costs from an as- needed basis at several thousand dollars an instance to weekly, street sweeping, which would cost approximately $165,000-250,000 the first year, assuming the 14 street segments where OSVs are currently clustered.

In terms of pump out costs, this would require more research for accurate, up-to-date estimates. At the time of this report, staff was able to learn the cost of both the Portland program at $805,000 for July 2021 through June 2025 (approximately $22,361/month), and the Mountain View pilot at $29,000 for January through April 2018 (approximately $7,250/month).

For Mountain View, the per service cost, exclusive of staff costs, was $391. 25 Mountain View City Council Report, May 15, 2018
https://mountainview.legistar.com/LegislationDetail.aspx?ID=3501450&GUID=FEBF512E-C985-4BD6-B35F- 302756729DC5
26 https://berkeleyca.gov/sites/default/files/documents/2025-04- 15%20Item%2004%20%20Contract%20University%20of%20California.pdf Item 16
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Potential Actions to Increase Regulation29
Some of the potential actions listed below involve new parking regulations. Most parking regulations require signage. In general, comprehensive citywide regulations typically require signage throughout the City. In some cases, however, it may be possible for the City to use temporary signage or individualized notices. Also, depending on the strategy selected, it may be possible to install signage in targeted areas or to approach a comprehensive signage program through a phased approach. For the Committee’s understanding, full implementation of a citywide parking regulation would require significant resources for signage as well as enforcement. More details are below.

Signage Cost Considerations (relevant for any citywide regulation approaches) The estimated cost to install new signs for a new citywide regulation would be hundreds of thousands of dollars. For context, in 2020, the City of Mountain View spent $980,00030 one- time cost on signage to implement their OSV parking ordinances.

For Palo Alto, costs would vary but at minimum, assuming two signs and posts per side, per block it would cost $1,200 per block in-house ($800 labor, $400 materials) and $1,900 per block if contracted out. If signage is required on all Palo Alto blocks, the City would need to add 2.0 FTE in Public Works working full-time on this work for approximately five (5) years.31 Additionally, if deploying signage on all city blocks, this would require significant staff time from the Office of Transportation including an additional 1.0 FTE or the re-allocation of traffic engineering staff from other duties (such as signal timing and capital projects) to design and direct field staff for sign installations citywide for the duration of the implementation time period. The costs associated with traffic review and permitting for a more narrowly defined approach could be on the order of $300,000 and/or equivalent opportunity costs associated with diversion from other City projects and essential City services. For context, in 2020, the City of Mountain View dedicated 9 to 12 months of work for more than two (2) traffic engineers who reviewed, permitted and issued work orders to implement their OSV parking ordinance. 29 In some cases, California cities that have adopted one or more of the listed regulatory actions have been sued by advocates for the unhoused, resulting in legal costs. Potential legal fees and costs are not included in the resource impact sections that follow.
30 Number not adjusted for inflation nor construction cost increases over time. https://mountainview.legistar.com/LegislationDetail.aspx?ID=4712008&GUID=B91F5618-049D-44E7-9BA9- 966071A60D1C&Options=&Search=
31This estimate assumes approximately 2,200 blocks in the City and 2 signs per side per block. For in-house staff, fabrication and installation of signs and posts at each location, would be approximately $800 per block for field staff labor plus $400 for materials, or $2.65 million for the approximately 2,200 blocks in the City and take over 20 years to complete. If signage will be installed throughout the City it would equate to approximately 8,800 signs. To install this signage, the City would need an additional 2 FTE, working full time, for approximately five years. If the work is outsourced to a contractor, the work would cost approximately $4 million31. To install both signs and posts would costs $4 million (8,800 x $475).

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Staff also anticipates an impact on Utility Locators during the implementation period for the Locators to verify each sign location for utility conflicts. Once all the signs have been installed throughout the City, ongoing maintenance requiring 2.0 FTE to fabricate and replace signs will be needed. The maintenance timeframe begins soon after installation.

Parking Enforcement Cost Considerations
Enforcement of a citywide parking regulation likely would create a significant parking enforcement workload increase, requiring an additional 1-2 FTE parking enforcement officers.

The approximate annual cost of 1-2 FTE parking enforcement officers (in house or contracted enforcement services) is $125,000-$250,000. Beyond enforcement personnel, any citywide parking regulation that results in additional towing expenses, could add costs ranging from approximately $50,000-$100,000 annually.

The cost information above is relevant to some of the approaches described below.

F. Prohibit Renting of Public Parking Spaces
Staff have determined that some of the occupied OSVs parked on city streets are owned by “vanlords” purporting to rent vehicles for habitation. Staff could develop an ordinance prohibiting the renting of vehicles for habitation on public streets or otherwise purporting to rent space in the public right of way. Such a prohibition would prohibit private profit-taking from use of a public resource (on-street parking spaces) and discourage vanlords who take advantage of vulnerable populations by charging rent while failing to provide the infrastructure necessary for human habitation. This prohibition would be enforced against the vanlord, not the renter, and penalties could include a fine assessed per day of violation.

Other cities are seeing vanlording proliferate and are working to crack down on the practice.

While San Francisco does not have any laws regulating vanlords specifically, the municipal police code does forbid leases, rental agreements, or contracts of any kind for the use of any sidewalk or street enforceable by citations up to $300 per violation. Los Angeles is currently considering an ordinance aimed specifically at vanlords, and San José recently adopted one.35 Implementation Considerations
Identifying a vanlord can be challenging. In the past, the City has relied on information from the RV renters, but renters will be disincentivized from helping the City identify their vanlords if the City starts enforcing a ban on the practice. Enforcement will likely rely on complaints. 35 San Jose’s vanlording ordinance is available here:
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Resource Impact
Enforcement of a vanlord ban would require minimal staff resources, primarily in the Police Department and City Attorney’s Office. Enforcement would involve collecting evidence that a violation is occurring, both online and in the field. Once staff determine a violation is likely occurring, the City would need to locate the vanlord, issue a warning or fine, and then collect on the fine. If the vehicle is inhabited, staff would determine what resources can be offered to those living there.

G. Prohibit Storage of Detached Trailers/Inoperable Vehicles on Public Streets A frequently cited source of concern from community members are detached trailers, that are clearly unable to move therefore essentially being stored or stationary on city streets. The City could adopt an ordinance prohibiting placement of nonmotorized or inoperable conveyances (such as camper shells and trailers) on the public right-of-way, or limiting parking to a maximum duration such as 1-2 hours. This would reduce the use of public parking spaces for storage of non-vehicles that are unable to move under their own power (e.g., to comply with the 72-hour parking limit).37
Implementation Considerations
A prohibition on parking non-motorized or inoperable conveyances would apply equally to all such conveyances, whether inhabited or not. Signage is required for enforcement as discussed earlier, and installation priorities will need to be established likely starting with areas impacted by detached trailer parking.

Resource Impact
Sign installation will require Transportation and Public Works staff resources similar to other options discussed. Enforcing this prohibition is anticipated to create a minimal increase in workload for existing police department parking enforcement personnel and a minimal increase in annual towing expenses; however, if multiple measures requiring additional parking enforcement are adopted, they are expected to, cumulatively, require an additional 0.5 FTE at an approximate cost of $50,000-$75,000, and additional towing expenses of approximately $50,000-$100,000.
37 The zoning code (Title 18) includes a prohibition on storing or parking non-operable conveyances on private property, except where screened from neighbors. This provision is enforced by Code Enforcement through issuance of warnings, administrative citations, and fines. For non-operable conveyances on public streets, staff recommends adoption of a new ordinance specifically addressing use of public parking spaces, enforceable by the Police Department or Office of Transportation.

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H. Limit Oversized Vehicle Parking to Certain Streets with Focused Regulations The City could consider limiting OSV parking to certain designated streets by prohibiting or limiting it on all other streets (for example, through an overnight parking ban) similar to Mountain View. This would effectively formalize locations where OSVs are allowed to park by limiting OSV parking on other streets, such as commercial zones where not already restricted.39 Designating streets where inhabited OSVs are allowed could facilitate effective management of the associated public health and sanitation impacts. This approach could be coupled with increased services (i.e., street sweeping, trash pickup, other safety measures) for the streets on which OSV parking is allowed. Focused parking regulation such as street sweeping and red curbs at intersections and driveways could also be included.

City staff has observed that there are current OSV clusters on particular streets including:

Embarcadero Way, Embarcadero Road east of Highway 101, Faber Place, Elwell Court, Corporation Way, East Meadow Circle, Fabian Way, Park Boulevard, Sheridan Avenue, Portage Avenue, Ash Street, Commercial Street, Transport Street, and Industrial Avenue. These street segments are not adjacent to residential or schools; however, the City has received complaints regarding impacts to adjacent businesses. The City would need to conduct a process to identify the streets where OSV would be allowed if this approach is pursued.

As an example for illustration, preliminary analysis indicates that the existing streets with OSV clusters have enough capacity for the on-street parking of the estimated 200 OSVs currently in Palo Alto, albeit with impacts to the availability of on-street parking for other users and other localized impacts arising from habitation on public right of ways that are not designed to support ongoing activities of living.40
Implementation Considerations
This approach would require a comprehensive plan identifying areas where OSVs may and may not park, not an ad hoc street-by-street ban. On streets where OSV parking is permitted, to maintain cleanliness, the City could institute weekly street sweeping and, to ensure that vehicles are not stored or abandoned and to maintain equitable access to public parking spaces, the City could continue enforcement of the 72-hour parking rule. The City may also establish a process for adding or removing streets from the list in the future.

Resource Impact
As mentioned in the note at the beginning of this section, any citywide parking regulation would require significant resources for signage and enforcement, although a targeted or 39 The municipal code already prohibits OSV parking in residential and public facilities zones. However, to enforce the provision, state law requires local jurisdictions to install signs adequately informing parkers of the restriction. 40 Analysis assumptions include OSV length of 30’, 5’ distance between vehicles, driveway clearance of 10’, intersection clearance of 20’, hydrant clearance of 15’ and 300’ hydrant spacing.

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phased approach may be available. Resources required for services (e.g., street sweeping, outreach, etc.) as described earlier.

I. Prohibit Oversized Vehicles on Specific Streets
The City could consider banning oversized vehicles on streets that meet certain conditions (e.g., highly impacted blocks, narrow widths, etc.) on a street-by-street basis.

Implementation Considerations
This approach would likely create a cycle of escalating restrictions and is therefore not recommended unless accompanied by designating other streets as previously described. Street- by-street prohibitions alone would have the unintended consequence of relocating OSV parking to other streets. This would likely trigger a cycle of requests for bans on other streets.

Resource Impact
Depending on the number of streets marked for no OSV parking, this approach would require resources for signage and enforcement. At this time, to add signage to the existing streets where OSVs tend to park, staff estimates it would cost approximately $70,000.43 J. Prohibit Oversized Vehicle Parking Throughout the City The Vehicle Code authorizes local jurisdictions to adopt restrictions on OSV parking, which could, in theory, include a comprehensive prohibition on parking OSVs throughout the City. In some cases, cities that have passed comprehensive parking regulations that are perceived to restrict the ability of the unhoused to remain in the jurisdiction, or that have the practical effect of doing so, have drawn lawsuits from advocates supporting the unhoused. Most of these jurisdictions have lost or settled these suits. Those cities include Mountain View, Pacifica, San Diego, and others. Other cities, including Berkeley and Sebastopol, are currently defending ongoing lawsuits from the vehicularly housed and their advocates. Typically, these lawsuits begin with a temporary injunction or agreement to toll enforcement, both of which put enforcement of the challenged ordinances on hold while litigation is underway. Where advocates prevail in court or where settlements were agreed to, regulations were either wholly invalidated or significantly modified. Attachment A provides additional information on specific cities’ experiences.
43 The estimate analyzed the 14 streets where OSVs are currently clustered, focusing on the segments of those streets where OSVs park. Given those parameters, the combined street length is approximately 12,000 linear feet and assuming one sign per 150 feet and $300/sign.

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Recommended Phased Approach
Staff compiled information on a variety of approaches which are summarized in the previous subsections. Given the range of possible approaches, staff has put together a sequence of actions for the Committee’s consideration to accommodate some OSV parking demand while increasing regulation to manage impacts. This sequence considers current resources, effectiveness, scalability, and the estimated timing needed for some of the approaches. Of note, the sequence below does not include further exploration of the citywide OSV ban nor the ‘prohibit OSVs on specific streets’ approach given the considerations shared in those subsections above.

It should also be noted that this sequence would require redeploying staff from other work, impacting other Council priorities.

Phase 1: Upon Council approval, staff would:
- Develop an ordinance to prohibit parking of detached/inoperable vehicles on public streets,
- Develop an ordinance to prohibit the renting of public parking spaces (“vanlording”), - Refine the scope and begin implementation of additional street cleanups and sweeping, - Return to Council for approvals of ordinances and contract amendments (e.g., street sweeping) as soon as possible, estimated to require up to four (4) months, and - Implementation and enforcement of these actions would follow.

Phase 2: Concurrent of Phase 1 implementation, staff would initiate work on:
- Design a small-scale enhanced services pilot (e.g., mobile pump outs, additional outreach workers/hours, garbage pickup, etc.),
- Return to Council for direction on a preferred option for expanded safe parking, and - Begin exploration of the “limiting OSV parking to certain streets” approach, including determining a process and criteria for designating streets where OSV parking might be permitted, with appropriate community engagement.

Phase 3: Following the completion of related components in Phase 2, Council would:
- Approve pilot and any related contracts and agreements for small-scale enhanced services pilot,
- Approve a preferred option for expanded safe parking, -Identify streets where OSV parking will be allowed and develop necessary ordinances and program design for “limiting OSV parking to certain streets” approach, and - Implementation of these actions would follow.

Phase 4: Following the completion of related components in Phase 3, staff would:
- Evaluate the enhanced services pilot,
- Pursue implementation of expanded safe parking, and
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- Obtain related Council approvals for “limiting OSV parking to certain streets” and begin enforcing new approach.

Implementation Considerations
The phasing would require ongoing, significant work over the course of several years, the near- term addition of at least 1 FTE staff position at an approximate cost of $104,000-$156,000 to assist in the associated complex funding, administration, and reporting needs, and likely require reprioritizing of some other assignments. However, this begins with the easier to implement actions and gradually progresses to the more complex and expensive, employing actions to both accommodate demand and regulate parking. In this way it is also responsive to the varied community perspectives (e.g., the needs of unhoused neighbors, the needs of housed neighbors, the shared use of public space, etc.).

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Table 1

POTENTIAL APPROACH IMPLEMENTATION CONSIDERATIONS RESOURCE Potential Actions to Accommodate Some Demand
A. Expand safe parking at
Baylands Athletic
Center
Impact other uses of area
Adds approximately 10-20 safe parking spaces
Limits future opportunities for habitat restoration or recreational uses
$$$
B. Allow safe parking on
privately owned
commercial lot
Not currently staff resourced
No identified private property owner willing to lease
$$
C. Expand congregation-
based safe parking
May not be ideal because daily movement is difficult
for OSVs.
Changing operations to 24-hours would require
neighbor outreach and consideration of feedback
received.
$
D. Increased cleaning
and street sweeping
on selected streets
Impacts all vehicles parking on street
Could displace OSVs to areas more sensitive to impacts $$
E.Enhance services, with
or without new
regulations
Increased outreach worker staffing to cover
evenings/weekends
Buyback program efficacy and cost not known
Pump-out likely uptake and costs not known
$$-$$$*45
Potential Actions to Increase Regulation
F. Prohibit renting of
public parking spaces
Identifying/investigating ‘vanlords’ can be difficult $ G. Prohibit storage of
detached trailers/
inoperable vehicles on
public streets
Applies equally to all vehicles $
H. Limit OSVs to certain
streets
Identifying adequate parking locations for OSVs $-$$$
*I. Prohibit OSVs on
certain streets
May lead to escalating restrictions
Could displace OSVs to areas more sensitive to impacts $-$$$
*J. Prohibit OSVs citywide  See litigation description above $$$ Phased Approach
Phased Approach Combines above, with the exception of the *asterisked approaches.
$-$$$
*Not recommended in the phased approach.
$ ≤50,000 $$ 51,000-400,000 $$$ ≥400,000
$-$$$ Scales over time, increasing resource impacts as various actions are implemented.

45 Depending on the scale and type of services selected.

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FISCAL/RESOURCE IMPACT
As discussed in this report, each potential approach has an estimated fiscal impact. Overall based on the options presented it should be anticipated that this effort will require City funding in excess of one million dollars annually and a significant ongoing staff allocation for the foreseeable future. Funding sources for these impacts have not been identified, however, significant General Fund allocation should be expected. Staff will also research and evaluate funding options based on the Committee discussion (e.g., funding for additional staff, grant funding and/or entitlement opportunities). Implementing the options described will also impact other Council priorities. At this time, no resources are required to support the Committee discussion outlined in this report.

Beyond the immediate steps described in this report, a comprehensive strategy to address homelessness in our community will require available housing for the unhoused individuals being assisted. While beyond the scope of this report, this longer term effort should be recognized.

STAKEHOLDER ENGAGEMENT
As mentioned elsewhere in this report, staff has not yet conducted outreach to housed or unhoused residents, affected property or business owners, or other stakeholders on these ideas. Based on the Committee and Council discussion and direction, stakeholder engagement plans will be developed.

ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by the California Environmental Quality Act (CEQA). CEQA Guidelines section 15378(b)(2).

ATTACHMENTS
Attachment A: Summary of Other Cities’ Experiences
APPROVED BY:

Ed Shikada, City Manager
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2100 Attachment A: Summary of Other Cities’ Experiences
The following is a summary of other cities’ experiences addressing homelessness impacts relating to people living in vehicles.

Mountain View
In 2019, the City of Mountain View adopted two oversize vehicle parking ordinances: the “Narrow Streets Ordinance” prohibited parking an oversized vehicle (OSV) on streets less than 40 feet wide, and the “Bike Lanes Ordinance” prohibited parking an OSV on streets with Class II bikeways (i.e., striped, separate bike lanes adjacent to the outer lanes of traffic). A violation of either ordinance could result in a ticket and/or towing at the owner’s expense.

A group of plaintiffs represented by the American Civil Liberties Union (ACLU) and the Silicon Valley Law Foundation, among others, sued to invalidate the two ordinances. Plaintiffs alleged that they were Mountain View residents who were priced out of their homes in the city and decided to live in recreational vehicles (RVs) on public streets. The complaint alleged that the two ordinances would ban oversize vehicle parking on about 89% of the City’s streets.

The plaintiffs brought various statutory and constitutional claims, including 1) that the $65 ticket for violations and the cost of retrieving a towed vehicle both violated the Eighth Amendment Excessive Fines Clause, 2) the city created a “state-created danger” under the Fourteenth Amendment by failing to leave plaintiffs a safe alternative place to park, 3) towing for violations of the ordinances was an unreasonable seizure under the Fourth Amendment, and 4) that the signs the city posted did not provide sufficient notice to satisfy the Due Process Clause. The city moved to dismiss the case. The trial court granted the city’s motion in part and denied it in part, allowing all the claims listed above to proceed.1 In 2022, following the court’s ruling on the motion to dismiss, the city settled the case. The settlement agreement required Mountain View to provide at least three miles of parking capacity for oversized vehicles, though it could continue to apply the 72-hour rule there.

Mountain View also was required to publish a map of the available parking areas and distribute it proactively to persons living in OSVs and when doing enforcement.2 The settlement agreement also included terms related to pre-enforcement notice (signage and individualized notice) as well as a process for those with disabilities to request accommodations, such as more time to move their vehicle.
1 The court dismissed plaintiffs’ claims for invasion of privacy, right to travel, and disability discrimination, with leave to amend.
2 The map is available
here: https://www.mountainview.gov/home/showpublishedimage/3580/638200916486970000.

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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2100 Pacifica
In late 2019, Pacifica passed an ordinance that prohibited “oversized vehicle” parking at any time on streets less than 40 feet wide and gave the city discretion to prohibit RV parking on other streets based on aesthetics and traffic safety concerns. Pacifica began enforcing this ordinance in September 2020. Those who violated the ordinance were subject to escalating fines. If five tickets were left unpaid, the RV could be towed and impounded.

In 2021, advocates for persons living in RVs filed a class action lawsuit challenging the ordinance.5 The lawsuit argued that ordinance was an attempt by the city to banish those who rely on RVs for housing and mobility. Instead of providing any clear parking rule, the suit alleged that the city was giving out tickets based on housed residents’ complaints, even when an RV was parked on a street where there was no justification for prohibiting RV parking. Plaintiffs brought many of the same claims as in the Mountain View suit.6 Shortly after filing the complaint, the plaintiffs moved for a preliminary injunction, asking the court to immediately stop Pacifica from enforcing the ordinance. Just before a scheduled hearing on the motion, the city agreed that the Court could enter a preliminary injunction that required it to issue and publicize a list and map of streets allowable for oversized vehicle parking.

In November 2021, the parties settled the case. Among other things, the settlement required the city to refund fines previously imposed for violation of the RV ordinance; to preserve at least two miles of streets as allowable for OSV parking; to continue to make the list and map of “allowable” streets broadly available; and to establish a process for people with disabilities to seek accommodations relating to the parking of their vehicles. The settlement also required the city to establish a safe parking program for OSVs, and to set up facilities for OSVs to empty their waste tanks and dispose of trash.

Sebastopol
In 2022, the City of Sebastopol was sued over an ordinance that prohibited parking an RV: (1) on public streets zoned as residential, (2) on public streets zoned as commercial, industrial, or community facility between 7:30 a.m. and 10:00 p.m., (3) on any park, square, or alley, and (4) in a city-owned parking lot unless the person is conducting city-related business during business hours at the location for which the parking lot is designated. Unlike Mountain View and 5 The advocates included the ACLU, Disability Rights Advocates, and Legal Aid of San Mateo County. 6 Plaintiffs alleged that the City violated their right to free movement under the U.S. and California Constitutions, that the ordinance was void for vagueness and susceptible to discriminatory enforcement, that the fines for violations were excessive under the Eighth Amendment, that the ban subjected them to a state-created danger, that towing to enforce the ordinances was an unlawful seizure under the Fourth Amendment, and that the ordinance violated several statutes prohibiting disability discrimination.

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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2100 Pacifica, the city relied not on traffic safety but on a record of complaints about availability of parking and public health/safety complaints (e.g., belongings blocking the sidewalks, human waste, garbage, etc.) related to RV residents. Plaintiffs brought many of the same claims as in the Mountain View and Pacifica suits.9
The trial court granted summary judgment to the city on all claims. Plaintiffs have appealed the trial court’s ruling, and the Ninth Circuit will likely hear oral argument in the case this fall. A Ninth Circuit ruling is applicable to the federal trial courts in Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington.
2025 City Regulations and Programs
In the last few months, a number of Bay Area cities have taken action to respond to needs and impacts associated with persons living in OSVs. San Francisco, San José, Fremont, San Mateo, and Menlo Park have adopted new regulations placing limits on OSV parking. Santa Clara and San Francisco have increased housing and shelter resources and increased services to the unhoused. It is too early to assess the impact and cost of these approaches, and it is unknown whether advocates will file litigation.
9 These included: excessive fines in violation of the Eighth and Fourteenth Amendments and the California Constitution; state-created danger in violation of the Fourteenth Amendment; equal protection in violation of the Fourteenth Amendment, unreasonable seizure of property in violation of the Fourth Amendment, the California Constitution and California Vehicle Code § 22650(b); procedural due process under the Fourteenth Amendment; void for vagueness under the Fifth and Fourteenth Amendments; and violation of several disability discrimination statutes. Plaintiffs were represented by the ACLU, Disability Rights Advocates, Legal Aid of Sonoma County, and California Rural Legal Assistance.

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ADDRESSING

OVERSIZED VEHICLE
(OSV) IMPACTS IN

PALO ALTO
Presenter:

Melissa McDonough,
Assistant to the City Manager
AUGUST 25, 2025 Paloalto.gov
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TITLE 40 FONT BOLD
Subtitle 32 font
AUGUST 25, 2025
• Responding to 2025 Council Priority Objective:

Present options to address homelessness impacts, particularly relating to individuals living in vehicles, to Policy & Services Committee for participation.

Identify feasible (1) regulatory approaches to manage the use of public space and (2) policy solutions to expand RV safe parking. Present options to Policy & Services for consideration and prioritization.
• Responds to increasing complaints and visible street-level impacts. • Balances compassion, community livability and public safety.

PURPOSE/OVERVIEW OF COUNCIL ITEM
Paloalto.gov
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1 BASELINE INFORMATION
• 2023 Point-in-Time Count:
206 unhoused individuals; 88% (~102 vehicles); estimates suggest doubling since then.
• Recent efforts include:
• Homekey interim shelter under construction.
• Safe parking program – 22 RV spaces at Geng Road + 14 vehicle spaces at congregation-based sites
• Below Market Rate (BMR) - 401 entitled units, ~315 pipeline • $57M to affordable housing projects since 2017, including $5M in 2025 towards 130 affordable units (3001 El Camino Real)
• >2,000 existing affordable units
• Enhanced renter protections
• Service support and referrals
• Law enforcement coordination
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