CITY COUNCIL
Special Meeting
Monday, November 03, 2025
Council Chambers & Hybrid
4:30 PM
Amended Agenda
Amended agenda items appear below in RED
Councilmember Vicki Veenker Remote Call In Teleconference Location:
Arena Leme Hotel
Av. Atlantica 324, Leme, Rio de Janeiro, RJ, 22010-000, Brazil Sala Pedro Leme (the Pedro Leme Room)
Palo Alto City Council meetings will be held as “hybrid” meetings with the option to attend by teleconference or in person. Information on how the public may observe and participate in the meeting is located at the end of the agenda.
The meeting will be broadcast on Cable TV Channel
26, live on YouTube
https://www.youtube.com/c/cityofpaloalto
, and streamed to Midpen Media
Center
https://midpenmedia.org
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VIRTUAL PARTICIPATION
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https://cityofpaloalto.zoom.us/j/362027238
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Meeting ID: 362 027 238 Phone:1(669)900-6833
PUBLIC COMMENTS
General
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1 November 03, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas
.
TIME ESTIMATES
Listed
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time,
including
while
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meeting
is
in
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right
to
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more
or
less
time
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any
item,
to
change
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order
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items
and/or
to
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after
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time
estimated
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agenda.
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may
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in
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best
manage the time at a meeting or to adapt to the participation of the public.
CALL TO ORDER
SPECIAL ORDERS OF THE DAY (4:30 - 4:40 PM)
1. Proclamation Expressing Appreciation to Fire Chief Geo Blackshire Upon His Retirement
AGENDA CHANGES, ADDITIONS AND DELETIONS
PUBLIC COMMENT (4:40 - 5:10 PM)
Members of the public may speak in-person ONLY to any item NOT on the agenda. 1-3 minutes depending on number of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard at the end of the agenda.
COUNCIL MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS (5:10 - 5:25 PM) Members of the public may not speak to the item(s).
ACTION ITEMS (5:25 - 5:55 PM)
Include: Report of Committees/Commissions, Ordinances and Resolutions, Public Hearings, Report of Officials, Unfinished Business and Council Matters.
2. Approval of three reports: the City of Palo Alto Community Wildfire Protection Plan, the Emergency Preparedness: Wildfire Audit Report by the City Auditor (as recommended by the Policy and Services Committee), and Adopt a Resolution Approving the City of Palo Alto Emergency Operations Plan. CEQA status: not a Project CLOSED SESSION (Item 3: 5:55 - 6:55 PM, Item 4: 6:55 - 8:25 PM)
3. CONFERENCE WITH CITY ATTORNEY-POTENTIAL LITIGATION
Subject: Initiation of litigation in one case
Authority: Potential Exposure to Litigation Under Government Code Section 54956.9(d) (4)
Number of potential cases: 1, as Plaintiff.
2 November 03, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas
.
4. Public Employee Performance Evaluations
Authority: Cal. Gov. Code section 54957 (b)
Title: City Manager
BREAK (15 MINUTES)
CONSENT CALENDAR (8:40 - 8:45 PM)
Items will be voted in one motion unless removed from the calendar by three Council Members.
5. Approval of Minutes from October 15, October 20, and October 22, 2025 Meetings
6. FIRST READING: Adoption of an Ordinance Repealing Chapter 15.04 of the Palo Alto Municipal Code and Adopting a New Chapter 15.04, the California Fire Code (2025 Edition) With Local Amendments and Related Findings. CEQA Status: Exempt Pursuant to Section 15061 of the CEQA Guidelines.
7. Approval of Budget Amendments in the Local Housing Trust Fund, Residential Housing In- Lieu Fund, Residential Housing Impact Fee Fund, and Commercial Housing Impact Fee Fund to Reflect Prior City Council Funding Commitments for the Development of 3001 El Camino Real 100% Affordable Multi-Family Housing Project; CEQA Status: Not a Project.
8. Approval of Professional Services Contract Number C26194191 with TJC and Associates, Inc. in the Amount Not-to-Exceed $242,483 for Dahl & Park Reservoirs Structural Evaluation and Condition Assessment. CEQA Status – Exempt Under CEQA Guidelines Sections 15061(b)(2) and (b)(3).
9. Adoption of a Resolution Approving The Palo Alto Museum‘s Facility Naming Plan for the Roth Building; CEQA status – not a project.
10. Approval and Authorization for the City Manager or Designee to Execute Purchase Orders as Needed with the Okonite Company for Underground Cable for the Utility's Electric Underground System in an Annual Amount of $800,000 for a Total Not-to- Exceed Amount of $4,000,000 for a Period of Five (5) Years. CEQA Status: Not a Project.
11. Approval of Seven Items to Support the Automated Weather Observation System Project, AP-19000, at Palo Alto Airport: 1) Approval of Construction Contract No.
C26194026 with Vellutini Corporation DBA Royal Electric Company, in an Amount Not to Exceed $1,699,810; 2) Authorization for the City Manager or Designee to Negotiate
3 November 03, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas
.
Change Orders Up to a Not-to-Exceed Amount of $254,971; 3) Approval and Authorization for the City Manager or Designee to Execute Contract Amendment 3 to Contract No. C21178372C with C&S Engineers, Inc. for a Not-to-Exceed Amount of $464,613 and a Contract Extension Through December 31, 2026; 4) Authorization and Approval for the City Manager or Designee to Execute Contract Amendment 1 to Contract No. C21178372B with Burns & McDonnell for a Contract Extension Through December 31, 2026; 5) Approval and Authorization for the City Manager or Designee to Execute Contract Amendment 1 to Contract No. C211783782A with Centurion Planning & Design LLC to extend the contract term through December 31, 2027; 6) Adoption of a Resolution Authorizing the Submittal of Applications and Execution of Grant Agreements with the California Department of Transportation for Airport Improvement Program Matching Grants; and 7) Approval of a Budget Amendment in the Airport Enterprise Fund; CEQA Status - Exempt Under CEQA Guidelines Section 15302
12. Approve a Cost-Sharing Agreement with Stanford University Not-to-Exceed $878,200 for Design and Engineering Services for the Quarry Road Improvements and Transit Center Access Capital Project (PL-16000) and approve budget amendments in the General Fund, Capital Improvement Fund, and the Stanford University Medical Center (SUMC) Fund; CEQA status – statutorily exempt under Pub. Res. Code § 21080(b)(12).
13. Approval of the Acceptance of State of California Citizens Options for Public Safety (COPS) Funds of $211,715 and a Budget Amendment in the Supplemental Law Enforcement Services Fund for municipal police service expenses; CEQA status – not a project.
CITY MANAGER COMMENTS (8:45 - 9:00 PM)
STUDY SESSION (9:00 - 9:30 PM)
14. Establishing the City Council Annual Calendar of Meetings, Recesses, and City Council Events for the Calendar Year 2026; CEQA status – not a project
ADJOURNMENT
INFORMATION REPORTS
Information reports are provided for informational purposes only to the Council and the public but are not listed for action or discussion during this meeting’s agenda.
4 November 03, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas
.
A.
Information Report on Sustainability and Climate Action Plan (S/CAP) Implementation; CEQA Status - Not a Project
B.
Informational Report on the 2023 and 2024 GreenWaste of Palo Alto Certificate of End Use and Traceability Reports; CEQA Status – Not a Project C.
2025 Council Priorities and Objectives Q3 Report
OTHER INFORMATION
Standing Committee Meetings this week
Finance Committee November 4, 2025
Public Comment Letters
Schedule of Meetings
5 November 03, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas
.
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Meeting ID: 362-027-238 Phone: 1-669-900-6833
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Disability
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of
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Alto
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6 November 03, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas
.
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§84308
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7 November 03, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas
.
City Council
Staff Report
Report Type: SPECIAL ORDERS OF THE DAY
Lead Department: Fire
Meeting Date: November 3, 2025
Report #:2510-5294
TITLE
Proclamation Expressing Appreciation to Fire Chief Geo Blackshire Upon His Retirement
ATTACHMENTS
Attachment A: Proclamation Expressing Appreciation to Fire Chief Geo Blackshire Upon His Retirement
APPROVED BY:
Geoffrey Blackshire, Fire Chief
Item 1
Item 1 Staff Report
Item 1: Staff Report
Pg.
1 Packet Pg. 8 of 413
EXPRESSING APPRECIATION TO FIRE CHIEF GEO BLACKSHIRE
UPON HIS RETIREMENT
WHEREAS, Fire Chief Geo Blackshire joined the City of Palo Alto Fire Department in October 1997 and has dedicated 28 years to serving the community. Starting as a Firefighter, he worked his way through the ranks, spending seven years as Deputy Chief and six m onths as Interim Chief before being appointed Fire Chief in 2019; and
WHEREAS, Chief Blackshire earned several professional designations along the way, including being recognized as an Internationally Credentialed Fire Chief through the Center for Public Safety Excellence and Executive Chief Officer through the International Association of Fire Chiefs. He’s also been an active participant in leadership organizations such as the Santa Clara County Fire Chiefs Association, Cal Chiefs Executive Leadership Institute, and the IAFC Diversity Executive Leadership Program, where he was part of the inaugural class focused on advancing diversity and inclusive leadership within the fire service; and
WHEREAS, Chief Blackshire has been known for leading with heart, collaboration, and vision. When the COVID -19 pandemic brought uncertainty and fear, he showed up every day to lead his department through it. His calm, consistent presence and focus on the wellness of his team and community embodied the kind of strength and optimism that defined his leadership. During this time, the department made major strides in firefighter wellness and safety, expanding its critical incident stress management program into a robust peer support network; and
WHEREAS, Chief Blackshire oversaw the construction of the award-winning Fire Station 3, initiated the rebuild of Station 4, and secured a $3.7 million FEMA SAFER grant to reopen Fire Station 2. Stations were also retrofitted with modern extractors and washers t o reduce exposure to combustion byproducts. He also reintroduced Engine 64, launched special operations and water rescue programs to i mprove response in challenging environments, and is bringing in new specialized equipment such as the Breathing Support Unit “Rescue 62”; and
WHEREAS, Chief Blackshire has also focused on strengthening the department’s emergency medical services and staffing, initiating plans to expand EMS single-role staffing and implementing modern recruitment tools like HireVue to make hiring more accessible and effic ient.
His leadership deepened collaboration with mutual aid partners and Stanford University, enhancing public safety on and off ca mpus and coordinating large-scale planning for special events and multi-casualty incidents; and
WHEREAS, through every initiative — from modernizing infrastructure to advancing diversity and inclusion – Chief Blackshire has helped build a stronger, safer, and more resilient organization. His impact on the Palo Alto Fire Department and the community it serves will be felt for many years to come.
NOW, THEREFORE, I, Ed Lauing, Mayor of the City of Palo Alto on behalf of the entire City Council do hereby extend our deepest gratitude to Fire Chief Geo Blackshire for his 28 years of dedicated service and unwavering commitment to the community.
PRESENTED: October 20, 2025
APPROVED:
______________________
Mayor Ed Lauing
______________________ ______________________
Vice Mayor Vicki Veenker Councilmember Pat Burt
______________________ ______________________
Councilmember George Lu Councilmember Julie Lythcott-Haims
______________________ ______________________
Councilmember Keith Reckdahl Councilmember Greer Stone
ATTEST:
______________________
City Clerk
APPROVED AS TO FORM:
______________________ ______________________
City Manager City Attorney
Proclamation
Item 1
Attachment A - Proclamation
Expressing Appreciation to Fire Chief
Geo Blackshire Upon His Retirement
Item 1: Staff Report
Pg.
2 Packet Pg. 9 of 413
8 1
0 0
City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Office of Emergency Services
Meeting Date: November 3, 2025
Report #:2510-5338
TITLE
Approval of three reports: the City of Palo Alto Community Wildfire Protection Plan, the Emergency Preparedness: Wildfire Audit Report by the City Auditor (as recommended by the Policy and Services Committee), and Adopt a Resolution Approving the City of Palo Alto Emergency Operations Plan. CEQA status: not a Project
RECOMMENDATION
Staff recommend that the City Council
1. Adopt a resolution approving the City of Palo Alto Emergency Operations Plan (EOP),
2. Approve the City of Palo Alto Community Wildfire Protection Plan (CWPP) and authorize submittal to the County of Santa Clara, and
3. Approve the Emergency Preparedness: Wildfire Audit Report by the City Auditor (as recommended by the Policy & Services Committee).
EXECUTIVE SUMMARY
This report is the culmination of a series of sessions for the public, the Council, and multi- agency planning activities regarding wildfires and emergency preparedness topics. Palo Alto is not unique in facing wildfire risks due to climate change, prolonged drought, and human activity in the wildland-urban interface (WUI), and conducts planning, mitigation, and other activities in accordance with best management practices and as part of larger, regional efforts, as described below.
The revised Emergency Operations Plan (EOP) and Community Wildfire Protection Plan are included in this report for Council approval.
The Office of Emergency Services (OES) is dedicated to safeguarding the residents, businesses, and visitors of Palo Alto through comprehensive and effective emergency management. The Emergency Operations Plan (EOP) is a foundational tool in this effort, providing the City with a structured approach to respond to a variety of potential Item 2
Item 2 Staff Report
Item 2: Staff Report
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1 Packet Pg. 10 of 413
8 1
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hazards, including natural disasters, technological incidents, and human-caused emergencies. The last EOP was adopted in 2016.
The CWPP provides one wildfire management plan for the community that combines the historic Foothills Fire Management Plan (FFMP) first established in 1982 and the Santa Clara County Fire Department developed multi-jurisdictional Community Wildfire Protection Plan (CWPP) that establishes strategic goals for these more detailed community level fire-planning efforts.
The April 8, 2025 meeting of the Policy & Services Committee, a recommendation was made to have the Council approve the audit findings on wildfire preparedness completed by BakerTilly, the City’s Auditor.
The Approval of the audit was pulled from the Consent Calendar on June 16, 2025; staff has bundled these topics and work efforts to enable a more comprehensive view of emergency preparations with a focus on wildfire preparedness.
BACKGROUND
The topics of emergency planning and wildfire preparedness, specifically, have been a longstanding priority for the City and there has been a concerted effort to review these plans and update. This item is part of a series of items on the topic of wildfire preparedness.1 The calendar below provides a summary of engagements and Council / Commission actions discussing fire services, wildfire activities, emergency services planning, and utilities activities. March, California Fire Marshal updated wildfire risk maps for public comment (released on City webpage 3/26)
Finance Committee reviewed Fire Department Staffing Options on April 1 2, continuing discussion from November 2024 exploring changes to enhance fire and ambulance service delivery.
Policy & Services review of Emergency Preparedness - Wildfire Audit on April 8 3. June, City Council adopted additional fire staffing and capital funding to advance additional wildfire fuel reduction in the City’s Open Space Preserves as part of the FY 2026 Budget. City Council received the finished updated Community Wildfire Protection Plan / Foothills Fire Management Plan Update 2025 as an Informational Item in June 20254. 1 News Story: Wildfire Preparedness Public Discussion, April 28, 2025, https://www.paloalto.gov/News- Articles/City-Manager/Palo-Alto-Begins-Wildfire-Preparedness-Public-Discussions 2 Finance Committee, April 1, 2025, Agenda Item #3,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=7399&meetingTemplateType=2&comp iledMeetingDocumentId=13598
3 Policy & Services Committee Meeting 4/8/2025 Staff Report #2410-3635:
https://portal.laserfiche.com/Portal/DocView.aspx?id=161145&repo=r-704298fc 4 City Council, June 9, 2025, Information item,
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=c1aa0e08-9818-47b4-9085- ebc4ceb1eb17
Item 2
Item 2 Staff Report
Item 2: Staff Report
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8 1
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The CWPP is posted here:
https://cityofpaloalto.primegov.com/viewer/preview?id=7981&type=2 June, City Council held annual hearing on properties assessed for Weed Abatement work.
The Utilities Advisory Commission reviewed and approved the utilities Wildfire Mitigation Plan at its June 4, 2025 meeting9.
City Council adopted the ordinance approving the newly revised Fire Hazard Severity Zone map designations released by the State on August 11, 202510. On August 18, 2025, Council approved 11 a five-year contract with the Santa Clara County Fire Safe Council (FSC) for fuel reduction addressing Audit Recommendation #4.
The City maintains various wildfire protection plans and strategies and takes a regional approach to planning efforts. Coordination and alignment with County and State agencies is key to ensuring responsible agencies can work together in an emergency. Mutual aid agreements with neighboring jurisdictions to enhance firefighting capabilities during large-scale incidents are critical to incident response as no single agency has the resources to respond to a wildfire incident independently. Below is a list of the City’s primary emergency plans relevant to wildfires:
Emergency Operations Plan Basic Plan (EOP)
Wildland Urban Interface (WUI) Fire Response Annex
Local Hazard Mitigation Plan (LHMP)
Foothills Fire Management Plan (FFMP) / Santa Clara County Community Wildfire Protection Plan (CWPP)
City of Palo Alto Utilities (CPAU) Wildfire Mitigation Plan Emergency Operations Plan:
The Emergency Operations Plan (EOP) ”Basic Plan” is the primary emergency planning document and does not including the various annexes and subplans such as the Community Wildfire Protection Plan. The EOP is an essential guidance document for City staff, key partners, and the community. The City’s Office of Emergency Services (OES) is responsible for the review, revision, management, and distribution of the EOP. In accordance with Municipal Code Section
2.12.080, the EOP basic plan requires 1) review by the Emergency Services Council (ESC) and Palo Alto/Stanford Citizen Corps Council (CCC) and 2) adoption by the City Council. 9 Utilities Advisory Commission Meeting 6/4/2025 Staff Report #2501-4077:
https://portal.laserfiche.com/Portal/DocView.aspx?id=177873&repo=r-704298fc 10 City Council, August 11, 2025,
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=736fe7fa-b476-4738-a03a-e2efa564facb 11 City Council, August 18, 2025, https://cityofpaloalto.primegov.com/portal/item/?meetingItemId=b05aa9e6- 5dab-4cf9-9b12-dd73292fda3a
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Under the California Government Code 8610, local jurisdictions with an accredited disaster council are required to develop and maintain an EOP to facilitate coordinated and effective emergency response. The EOP incorporates organizational structures, policies, and procedures for delivering emergency services, as well as the legal authorities and references that govern emergency management in Palo Alto. Palo Alto has had an accredited disaster council since 1947 and as such has maintained a Council-adopted EOP since that time.
The Office of Emergency Services is responsible for reviewing emergency plans to ensure adherence to the law and to guidance such as the FEMA Comprehensive Preparedness Guide (CPG) 101. On October 7, 2024, the revision to the Local Hazard Mitigation Plan was adopted by City Council.15 The LHMP identifies and prioritizes potential and existing hazards across jurisdictional borders and identifies mitigation projects to reduce the impacts on Palo Alto to our hazards. See www.paloalto.gov/lhmp. Generally, it is advisable to update EOPs after each LHMP revision cycle, since hazard identification is a required step in the EOC update process.
Community Wildfire Protection Plan (inclusive of the former Foothills Fire Management Plan):
The City developed a Foothills Fire Management Plan (FFMP) in 1982 that provides the planning framework for fire control activities for the City and the Palo Alto Foothills Area which comprises the predominant wildland urban interface (WUI) area for the community. This plan addresses a broad range of integrated activities and planning documents to address and mitigate the impacts of fire hazards in the area west of Foothills Expressway to the City limits of Palo Alto. The City has updated this plan three times: in 1997, 2009, and 2017. City of Palo Alto Staff Report #8030 (10/16/2017) includes an overview of this process.16 Also in 2017, the Santa Clara County Fire Department developed a multi-jurisdictional Community Wildfire Protection Plan (CWPP) to establish strategic goals for these more detailed community level fire-planning efforts. This included a Palo Alto jurisdictional annex that accompanied this plan, but apart from the FFMP.
During the County’s substantive 2023 CWPP update process, the City made the decision to integrate the FFMP with the CWPP to provide one wildfire management plan for the community which addresses the long-standing history of the FFMP while meeting the best management practices of the CWPP format.
Emergency Preparedness - Wildfire Audit:
Baker Tilly, in its capacity serving as the Office of the City Auditor (OCA), performed a citywide risk assessment that assessed a wide range of risk areas, including strategic, financial, operational, compliance, technological, and reputation risks. The purpose of the assessment 15 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=14437 16 https://portal.laserfiche.com/Portal/DocView.aspx?id=50811&repo=r-704298fc&searchid=d0b0cc2a-8987-4531- 9392-20aa5e61d742
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was to identify and prioritize risks to develop the annual audit plan. Recognizing the need for an independent assessment of the City's wildfire preparedness, BakerTilly conducted an audit in alignment with its 2024 Risk Assessment and subsequent Council approved workplan.
After the January 2025 southern California wildfires, the Policy & Services Committee agenda item was expanded to discuss two parts, 1) Wildfire Preparedness Activities and 2) Summary and Response to the Emergency Preparedness – Wildfire Audit (conducted in 2024, prior to the recent events). Recognizing the importance of communications, education, and preparation, in collaboration with the City Auditor, this expansion was in alignment with the launch of a series of items to raise awareness of local wildfire risks and the importance of wildfire preparedness.
ANALYSIS
After the January 2025 southern California wildfires, and in alignment with the City Council 2025 priorities, staff have been proactively connecting individual initiatives regarding emergency preparedness, with a focus on wildfires. Recognizing the importance of communications, education, and preparation, a cross functional team continues to coordinate on a series of items to raise awareness of local wildfire risks and the importance of wildfire preparedness.
Key roles in the following departments: Fire, Utilities, Office of Emergency Services (OES), Community Services (Open Space Rangers), and Public Works Departments comprise the Foothillls Fire Management Team (aka Foothills Wildfire Team) and support planning efforts such as the Foothills Fire Management Plan/Community Wildfire Protection Plan (FFMP/CWPP), a City Council 2025 priority objective, as well as various efforts to reduce risk (such as the aforementioned Fire Safe Council contract work), educate the community, and improve detection and response capabilities.
The 2024 City Council priority objectives illustrated this continual effort through Objectives 70 and 71: Approve updated Local Hazard Mitigation Plan and Update the Foothills Fire Management Plan & Community Wildfire Protection Plan, respectively.
The Policy & Services April 8, 2025 report outlines wildfire preparedness activities recently completed or under way, below provides brief updates as available organized in the following groups: preparation and planning, multijurisdictional initiatives, and mitigation and prevention efforts.
This staff report presents three items for Council approval, all pieces of the comprehensive emergency preparedness work seeking to safeguard the residents, businesses, and visitors of Palo Alto. The three reports recommended for approval include:
1) The City‘s new Emergency Operations Plan (EOP)
2) Foothills Fire Management Plan / Community Wildfire Protection Plan (CWPP) 3) Emergency Preparedness – Wildfire Audit (conducted in 2024, prior to the 2025 Southern California events).
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A summary of these reports are discussed below. As noted in the prior section, emergency planning and preparedness for wildfires is included in over six planning documents, two of which are recommended for approval in this report.
Emergency Operations Plan (EOP) Attachment A & B
The Emergency Operations Plan (EOP) is a foundational tool in this effort, providing the City with a structured approach to respond to a variety of potential hazards, including natural disasters, technological incidents, and human-caused emergencies. The City’s current EOP was last adopted in 2016. The 2025 revisions to the EOP reflect changes in emergency management protocols, organizational structures, and hazard assessments, ensuring that Palo Alto remains well-prepared to manage crises effectively. These revisions are in line with best practices, ongoing regulatory requirements, and the evolving nature of potential threats.
The updated EOP is designed to facilitate both immediate response and short-term recovery efforts, while also informing long-term prevention, mitigation, and risk-based preparedness strategies. In July 2024, City OES staff began an EOP review and update process with an outside consultant, Tetra Tech. Internal and external stakeholders played a key role in provided feedback for the EOP revision. Updates were made primarily in accordance with State and Federal regulations and guidelines, as well as best practices in the emergency management landscape over the past five years.
The update was focused on the Basic Plan: modifying the document language for structure, content, and readability as well as to add illustrations for ease of use. Key elements of the updated EOP include:
Departmental Roles and Responsibilities – Clear definitions of the duties and responsibilities of various city departments and personnel during emergencies activations.
Public Alert and Warning Systems – Enhanced protocols for communicating with the public and neighboring jurisdictions during a crisis.
Emergency Management Phases – Detailed descriptions of the phases of emergency management: mitigation, preparedness, response, and recovery. Emergency Declarations – Procedures for declaring states of emergency, including the associated legal and operational implications.
Additionally, the plan includes a glossary of terms to ensure clarity and ease of use. The EOP will guide the City's response in a flexible manner that can be adapted to address all hazards and threats, ensuring a swift and effective recovery process.
The attached resolution will formally adopt the EOP as the City's primary emergency management framework, will authorize staff to carry out training, exercises, and interagency coordination as outlined in the plan, and ensures compliance with state and Item 2
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federal emergency management standards: e.g., National Incident Management System (NIMS), Standardized Emergency Management System (SEMS), the Incident Command System (ICS), etc. City staff will initiate an update process for related internal plans, procedures, and other documents to align with this new EOP. This effort will also coincide with the transition from the current Emergency Operations Center in the Palo Alto Civic Center to the new Public Safety Building (PSB).
Foothills Fire Management Plan / Community Wildfire Protection Plan (CWPP) (linked here:
https://cityofpaloalto.primegov.com/viewer/preview?id=7981&type=2) The City contracted with Wildfire Management Resource Group to assist the City in the integration of the two separate plans as well as a comprehensive update of each at the same time. Site visits, staff interviews, a public meeting, and discussions with regional partners including Santa Clara County Fire Safe Council CWPP members were completed to inform this consolidation and update to the FFMP and CWPP. This 2025 update includes these primary components:
Describes the planning environment
Discusses actions taken since the previous update
Provides an updated wildfire risk hazard assessment
Recommends new fuel treatment actions
Includes public education and outreach efforts
Lists wildfire mitigation projects the City will endeavor to complete Identifies vegetation treatment standards and methods
The City will add the finalized plan as a jurisdictional annex to the Santa Clara County CWPP19.
The Healthy Forest Restoration Act of 2003 recommends the implementation of wildfire protection plans for communities that have a wildfire threat. In compliance with this Act, three signatures are required on the plan from applicable local government, the local fire department, and the state entity responsible for forestry. For this plan the signatories will include the City of Palo Alto City Manager, the Palo Alto Fire Department Chief, the Local CalFire Unit Chief, and an additional signatory of the City of Palo Alto OES Chief.
Emergency Preparedness – Wildfire Audit (Attachment C)
The objective of the Emergency Preparedness – Wildfire Audit aimed to determine whether the City is adequately prepared to prevent and respond to wildfires as part of its overall emergency management plan. The audit provides a detailed analysis of the City's current practices and recommendations for improvement. The OCA interviewed staff, reviewed policies and 19 Santa Clara County CWPP, https://www.sccfd.org/santa-clara-county-community-wildfire-protection-plan/ Item 2
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procedures as well as FEMA and CAL FIRE standards and best practices to complete this audit work. The BakerTilly Audit Report highlights two findings:
1. While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
2. Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning, training, after action report recommendation implementation, and communication efforts.
The attached report summarizes the analysis, audit findings, and recommendations. The audit identified areas for further improvement in evacuation planning and enhancing community engagement regarding these activities. Management has provided responses in the Appendix.
The Policy & Services Committee reviewed the attached report and discussed recent wildfire preparedness activities underway and new items such as the newly released wildfire maps released by the California Fire Marshal and transmits an audit on wildfire preparedness completed by BakerTilly, the City’s Auditor. The Committee on April 8, 2025 unanimously recommended Council approval of the audit.
FISCAL/RESOURCE IMPACT
Approval of the EOP and CWPP do not have a financial impact. Upon adoption, staff resources will be required to 1) train staff on the new EOP, 2) conduct training and exercise events with staff and certain external partners, and 3) operationalize the EOP in the new Emergency Operations Center (EOC) in the new Public Safety Building (PSB). The timeline and resource needs for implementation of management’s corrective action plans are identified by management within the attached audit responses.
Implementing activities such as hardening systems and undergrounding the electricity transmission line in the foothills are within existing capital improvement plans and funding.
Acquisition of new equipment and technology is reviewed and evaluated as it arises in the context of the various plans, most currently as part of the Foothills Fire Management Plan/Community Wildfire Protection Plan (FFMP/CWPP) a multi-year plan.
The City continues to explore potential funding sources, such as grants from federal and state agencies, to offset the costs of implementing wildfire preparedness plans. For example, the N5 fire detection sensors were acquired via the Fire Safe Council through a Department of Homeland Security grant program.
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STAKEHOLDER ENGAGEMENT
Emergency Operations Plan: The Emergency Operations Plan (EOP) was reviewed during the February 6, 2025, Internal Stakeholder meeting, where representatives from all City departments reviewed the draft and provided feedback regarding edits and general questions.
The primary outcome of this meeting was to ensure that departmental roles and responsibilities were clearly defined and accurately reflected for use in an emergency scenario.
In addition, an External Stakeholders EOP review was conducted on February 26, 2025, to present the updated EOP and gather feedback from key community partners. The meeting brought together a diverse group of stakeholders, including healthcare providers such as Kaiser Permanente, Sutter Health, and Stanford Health Care. Representatives from community-based organizations—including the Ronald McDonald House, Downtown Streets Team, and Stanford’s Linear Accelerator Laboratory (SLAC)—were also in attendance.
Additional participants included the Palo Alto Unified School District, local charter schools, and faith-based organizations. East Palo Alto Police Department and the Santa Clara Fire Safe Council were also in attendance both of which operate outside of Palo Alto’s jurisdiction.
External Stakeholders voiced a strong interest in expanding community-wide emergency preparedness events. Stakeholders emphasized the value of using these events to foster collaboration, enhance mutual support among community partners, and create networking opportunities.
Additionally, staff opened a 21-day public review and comment period to provide the broader community an opportunity to offer feedback on the updated plan. Staff publicized this public input process through the City’s website, social media posts, City newsletter, and direct email to a substantive list of external stakeholders. Staff used this public feedback to make corrections where applicable and consider additional perspectives that enhanced the plan.
Public comments were presented to the Emergency Services Council (ESC) by the OES Chief along with actions taken by staff to address any concerns that were voiced in public comments.
That process closed on May 4, 2025, with four comments received.
Foothills Fire Management Plan / Community Wildfire Protection Plan (CWPP): The City hosted a public presentation on the CWPP/FFMP on 25 June 2024 as part of the City’s annual Wildfire Preparedness Community Meeting in which participants received an update on this plan and an opportunity to ask questions about it.
The City also provided a 21-day public comment period using an online collection form to give members of the public an opportunity to comment on the plan. This open comment period was publicized on the City’s website, through the Uplift Local newsletter, and direct email notifications to stakeholder agency representatives. The City received seven public responses.
Where applicable, staff made appropriate updates to the plan and in other cases will determine the appropriate response.
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ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by CEQA because reviewing and approving audit findings and emergency response plans are an organizational or administrative activity of government that will not result in direct or indirect physical changes in the environment. CEQA Guidelines section 15378(b)(5).
ATTACHMENTS
Attachment A: Resolution Adopting the Emergency Operations Plan Attachment B: City of Palo Alto Emergency Operations Plan Attachment C: Emergency Preparedness – Wildfire Audit Report Foothills Fire Management Plan / Community Wildfire Protection Plan (CWPP) linked here:
https://cityofpaloalto.primegov.com/viewer/preview?id=7981&type=2) APPROVED BY:
Kenneth Dueker, OES Chief & Kiely Nose, Assistant City Manager Item 2
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NOT YET APPROVED Attachment A
1 027060225
Resolution No.
Resolution of the Council of the City of Palo Alto Adopting the City of Palo Alto 2025 Emergency Operations Plan (EOP)
R E C I T A L S
A. The City of Palo Alto has developed an updated Emergency Operations Plan (EOP) in order to help coordinate resources to make our community safer and better prepared to deal with all hazards.
B. The Palo Alto/Stanford Citizen Corps Council is part of the Emergency Services Council as provided by Palo Alto Municipal Code section 2.12.030(a)(5), stating that members include "[s]uch representatives of civic, business, labor, veterans, professional or other organizations having an official emergency responsibility, as may be appointed by the [City Manager] with the advice and consent of the city council."
C. Per Palo Alto Municipal Code section 2.12.080, the Citizen Corps Council and the Emergency Services Council recommend that the City Council adopt the new 2025 EOP.
The City Council of the City of Palo Alto hereby RESOLVES as follows:
SECTION 1. The City Council hereby adopts the 2025 Emergency Operations Plan (EOP), attached hereto and incorporated by reference.
SECTION 2. The City Council hereby consents to the updated Palo Alto/Stanford Citizen Corps Council (CCC) membership list.
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2 027060225
SECTION 3. The Council finds that this is not a project under the California Environmental Quality Act and, therefore, no environmental impact assessment is necessary.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
City Attorney or designee City Manager
Director of Emergency Services
Director of Administrative Services
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City of Palo Alto
Emergency Operations Plan
EMERGENCY OPERATIONS PLAN
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City of Palo Alto Emergency Operations Plan
EMERGENCY OPERATIONS PLAN
March 2025
City of Palo Alto
Office of Emergency Services
275 Forest Avenue | Palo Alto, CA 94301
www.cityofpaloalto.org/oes
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EXECUTIVE SUMMARY ........................................................................................................................................... II AUTHORITY, APPROVAL, IMPLEMENTATION & DISTRIBUTION ............................................................................. III EOP ADOPTION RESOLUTION ................................................................................................................................ IV RECORD OF CHANGES ........................................................................................................................................... VI RECORD OF DISTRIBUTION .................................................................................................................................. VII DEPARTMENT ROLES AND RESPONSIBILITIES ......................................................................................................... 1
1.0 REFERENCES ..................................................................................................................................................... 9 BASIC PLAN .......................................................................................................................................................... 10
2.0 INTRODUCTION ....................................................................................................................................... 10
3.0 CONCEPT OF OPERATIONS ...................................................................................................................... 13
4.0 EMERGENCY MANAGEMENT ORGANIZATION ......................................................................................... 18
5.0 WHOLE COMMUNITY APPROACH .................................................................................................................. 20
6.0 EMERGENCY MANAGEMENT PHASES ............................................................................................................. 23
7.0 EMERGENCY OPERATIONS CENTER ......................................................................................................... 29
8.0 EMERGENCY DECLARATIONS ................................................................................................................... 34
9.0 PUBLIC INFORMATION ............................................................................................................................ 35
10.0 CONTINUITY OF GOVERNMENT .................................................................................................................... 37
11.0 PLAN DEVELOPMENT AND MAINTENANCE .................................................................................................. 39 GLOSSARY AND ABBREVIATIONS ......................................................................................................................... 40
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EXECUTIVE SUMMARY
The Emergency Operations Plan (EOP) outlines how the City of Palo Alto —its government, stakeholder agencies, community groups, business community, and residents —coordinate its response to major emergencies and disasters. This plan is regularly reviewed and updated by staff and approved by the City Council.
The EOP identifies operational strategies and plans for managing inherently complex and potentially catastrophic events. City assets, resources, and departments are potentially vulnerable and may become overwhelmed. A primary goal of the EOP is to promote flexibility whenever possible based on good judgment and common sense. This document facilitates emergency response and short -term recovery functions for emergencies and disasters that are outside of the expected capabilities of normal City operations.
Palo Alto has officially adopted and integrated the following emergency management, response, and coordination systems:
• Incident Command System (ICS)
• Standardized Emergency Management System (SEMS)
• National Incident Management System (NIMS)
• National Response Framework (NRF)
This EOP addresses the following phases of emergency management:
• Preparedness
• Response
• Recovery
• Mitigation
The City has adopted a “whole community” approach that actively promotes the inclusion and integration of community partners, neighbors, residents, people with disabilities and access and functional needs, people with language or cultural differences, and other sta keholders in all phases of emergency management planning. Through such collaboration, the City will be better prepared to meet the needs of its residents and daytime populace alike.
The City’s Emergency Operations Center (EOC) provides a centralized location where emergency management coordination and decision -making can be supported during a critical incident, major emergency, disaster, or significant event. When activated, the EOC provides support for critical tasks related to communications, coordination, resource management, and executive leadership.
If Palo Alto determines that the effects of an emergency are beyond the capability of local resources or may become so, then a local emergency can be proclaimed. There are specific circumstances where the City of Palo Alto can proclaim an emergency even if not beyond capabilities, for example during COVID- 19 and severe storms the City proclaimed an emergency . A local proclamation of emergency allows the City Manager and staff to take measures necessary to protect and preserve public health and safety and support requests for county, state, and federal assistance. A proclamation also provides City staff with additional powers and authorities to increase the speed and effectiveness of City response activities.
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The Palo Alto EOP provides an all -hazard approach to enable Palo Alto EOC staff and City employees managing emergency incidents and planned events. This plan is divided into three sections:
Basic Plan -- presents the planning assumptions, policies, and concept of operations that guide the responsibilities for emergency preparedness, response, recovery, and mitigation for Palo Alto.
Annexes – Hazard specific and functional applications of the EOP
AUTHORITY , APPROVAL , IMPLEMENTATION & DISTRIBUTION
This Emergency Operations Plan is sanctioned under the authority of the Palo Alto Municipal Code (Palo Alto Municipal Code, 2024) and issued under the authority of the City Manager acting as the statutory Director of Emergency Services. This plan applies to the operations and management of the City of Palo Alto and its respective departments and agencies.
This document shall be the official all-hazards Emergency Operations Plan for the City of Palo Alto and shall supersede all previous plans for this purpose. Nothing in this plan shall be construed in a manner that limits good judgment and common sense in matters not foreseen.
This plan is approved by the City Manager for the City of Palo Alto and adopted by the City Council. The delegation of authority for specific modifications that may be made to the plan without the senior official’s signature is the Office of Emergency Services Chief. Copies of the plan will be subsequently distributed electronically to each City Department, the EOC, and EOC section chiefs.
City of Palo Alto
____________________________________________________________________________ Ed Shikada, City Manager Date
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EOP ADOPTION RESOLUTION
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RECORD OF CHANGES
PLAN CHANGES / UPDATES
Date Change Updated by Department
With the input from key stakeholders, City of Palo Alto’s Office of Emergency Services is responsible for maintaining, reviewing, and updating this Emergency Operations Plan. Collaborative plan revisions and updates are essential to ensure accuracy and validity of the EOP, therefore any plan changes and updates will be captured in the table below.
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RECORD OF DISTRIBUTION
The City of Palo Alto’s EOP is posted online with the City’s Office of Emergency Services maintaining the primary copy.
DISTRIBUTION LIST
Name Department / Agency Date of Delivery Number of
Copies
Disclosure Exemptions
While sections of this document may be available for public review, other portions may contain sensitive information relevant to the emergency response operation of the City of Palo Alto. Portions that include information with significant implications on City, county, state and /or national security or are otherwise exempt from public disclosure are placed in attachments in accordance with th e provisions of the California Public Records Act § 7920 et seq.
Adherence to the Plan (EOP)
Information provided in this plan is guidance and not policy . Decisions and directions about the most appropriate approach and course of action for response and recovery may be influence d by numerous factors and will be determined based on the best information available at the time.
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1 DEPARTMENT ROLES AND RESPONSIBILITIES
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan City Council • ESF 5
Management
State ESF 5
• Empower City Manager in their role as
Director of Emergency Services
• Through the City Manager, provide policy-
level guidance, direction, and decisions
related to the incident(s)
• Liaison with County Board of Supervisors
• Reinforce public information and community
engagement efforts as needed
• Convene or represent the City at public
meetings as needed
• Review potential or threatened litigation as
needed
• Review and approve proclamation of local
emergency
• Review requirements for special legislation
and development of policy
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
The City of Palo Alto’s departments may be called upon for the departments’ capabilities and resources to respond to and recover from an emergency or disaster. The lead and support roles are outlined in the table below. It is important to note that lead and support roles will vary depending on the emergency or disaster. For example, the lead agency for wildfire response is the Palo Alto Fire Department while the Community Services Department may play a support role in firefighting by utilizing the Community Services Open Space Rangers. There are corresponding City annexes and plans that each department can refer to before and during an emergency to familiarize themselves with emergency functions. Additional information on roles and responsibilities, EOC activation authorities, and procedures can be found in the Palo Alto EOC Manual.
The Emergency Support Functions listed in the following table are aligned with the State of California Governor’s Office of Emergency Services Emergency Support Functions (ESFs). For more information on CAL OES ESFs, please visit CAL OES Emergency Support Functions.
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2 AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
City Attorney and City
Clerk
• ESF 5
Management
State ESF 5
• Assess City operations and provide legal
counsel as needed
• Review potential or threatened litigation as
needed
• Facilitate and administer proclamations of
local emergencies
• Oversee and ensure preservation of Vital City
documents and records
• Facilitate public meetings as needed
• Institute Emergency Stand-By Council when
necessary
• Assist the City Manager as liaison to City
Council
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Policies, Emergency
Plans (DEPs) and other related
procedures
City Manager
• ESF 15 Public
Information
State ESF 15
• Director of Emergency Services
(City Manager or designee)
• Establish EOC operational priorities
• Authorize proclamations of local
emergencies
• Approve public information release
• Guide public warnings and alerts
• Primary liaison to City Council
• Develop and maintain communication with
other government bodies
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Recovery Annex (TBP)
• Emergency Public Information and
Warning Annex (TBP)
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3 AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Office of Emergency Services
• ESF 1-18
State ESF
Functions 1-13,
15-18
Federal ESF 14
• Manage emergency management
program and operations including
managing and facilitating the City’s
EOC
• Coordinate incident management and
response efforts
• Develop plans, procedures, and
agreements to assist incident response
• Conduct EOC action planning
• Lead Emergency Management Mutual
Aid
• All
Planning and Development
Services Department
• ESF 3
Construction and
Engineering
State ESF 3
• Staff the Plans Section during EOC
Activations
• Building Inspection and Code
Enforcement
• Building Damage Assessment
• Emergency Repair Permitting
• Employ GIS and Analytics within
capabilities
• Community Planning support during
recovery phase
• Establish Local Assistance Center when
directed
• Damage Assessment Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Recovery Annex (TBP)
Administrative Services
Department/Finance
Department
• ESF 7 Resources
State ESF 7
• ESF 14 Recovery
Federal ESF 14
• Staff the Finance and Administration
Section during EOC activations
• Finance & Revenue Services
• Provide emergency procurement
assistance
• Anticipate and track financial resources
• Damage Assessment Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
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4 AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Administrative Services
Department/Finance
Department
for staff, mutual aid requests,
volunteers
• Develop financial mechanisms,
procurement applications and
contracts to facilitate procurement
• Oversee staff timekeeping
• Oversee compensations and claims
• Provide fiscal oversight and tracking of
expenses
• Oversee coordination for Public
Assistance efforts with FEMA.
Procedures
• Recovery Annex
• Multi Agency Coordination
(MAC) Plan
Fire Department
• ESF 4 Fire and
Rescue
State ESF 4
• ESF 10 Hazardous
Materials
• State ESF 10
• Staff the Operations Section During
EOC Activations
• May augment the Plans Section during
EOC activations
• Orchestrate all firefighting and fire
rescue operations
• Direct EMS operations
• Coordinate for Fire and EMS mutual aid
resources
• Conduct hazardous material response
operations
• Enhance emergency public warning
and alerts when necessary
• Aid in evacuation and re-entry
operations
• Enhance damage assessment efforts
• Provide incident planning and
management support as needed
• Lead Fire Mutual Aid
• Damage Assessment Annex
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
• Multi Agency Coordination
(MAC) Plan
• Emergency Public Information
and Warning Annex (TBP)
• Airport Emergency Plan
• Evacuation Annex
(Draft in production)
• Continuity of Operations
Plan/Continuity of
Governance
• Department Emergency Plans
(DEPs) and other related
procedures
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5 AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Human Resources
• ESF 8 Public Health
and Medical
Federal ESF 8
• Staff the Finance and Administration
Section during EOC activations
• Manage City Disaster Service Workers
• Manage Human Resources related
matters
• Provide risk management and
employee safety oversight.
• Assess employee needs) Screen and
track spontaneous volunteers
• Compensation and Claims
procedures
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
Information Technology
Department
• ESF 2
Communications
State ESF 2
• ESF 18 Cybersecurity
State ESF 8
• Staff the Logistics Section during EOC
activations
• Protect, restore, and sustain cyber and
information technology resources
• Oversee and manage
telecommunication infrastructure
• Provide additional technology support
as needed
• Communications Annex (TBP)
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Cybersecurity Annex
(Draft in production)
Community Services
Department
• ESF 6 Care and
Shelter
State ESF 6
• Staff and assist the Operations Section
during EOC Activations
• Manage emergency care and shelter
operations
• Support infrastructure restoration
• Assist in debris clearance from public
rights of way
• Facilitate evacuation and re-entry
operations
• Mass Care and Shelter Annex
• Damage Assessment Annex
• Recovery Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
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6 AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Police Department
• ESF 2
Communications
State ESF 2
• ESF 13 Law
Enforcement
• State ESF 13
• Staff the Operations Section During
EOC Operations
• Conduct law enforcement operations
• Enhance emergency public warning and
alerts
• Facilitate evacuation and re-entry
operations
• Provide access and control to affected
areas
• Provide facility and resource security
• Enforce curfew as directed
• Provide public safety and security
assistance
• Provide traffic control
• Oversee Law Enforcement Mutual Aid
• Communications Annex (TBP)
• Evacuation Annex
(Draft in production)
• Emergency Public Information
and Warning (TBP)
• Mass Care and Shelter Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
Animal Control Division
• ESF 6 Care and
Shelter
• State ESF 6
• ESF 11 Food and
Agriculture
• State ESF 11
• Assess the status of animal care needs
• Determine status of available shelters
for animal care populations (pets, large
animals, livestock)
• Determine need of veterinary services
• Provide animal support services
• Mass Care and Shelter Annex
• Department Emergency Plans
(DEPs) and other related
procedures
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
Library
• ESF 6 Care and
Shelter
State Level ESF 6
• ESF 15 Public
Information
• State ESF 15
• Enhance community care and shelter
efforts with library facility and
personnel resources
• Establish community call center when
directed and in partnership with IT and
CMO
• Department Emergency Plans
(DEP) and other related
procedures
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Public Works
• ESF 1 Transportation
State ESF 1
• ESF 3 Construction
and Engineering
State ESF 3
• Staff the Operations Section during
EOC Activations
• Conduct infrastructure protection,
emergency repair, and restoration
• Communicate movement
operation/restrictions (traffic and
access)
• Conduct debris clearance and manage
debris operations
• Conduct flood fight operations
• Provide engineering services
• Coordinate with state agencies on
state-controlled highways and roads
• Manage city facilities
• Maintain, repair, and restore
wastewater collection infrastructure
• Assist in damage assessment efforts
• Assist in evacuation and re-entry
operations
• maintain, repair, and operate Regional
Water Quality Control Plant
• Manage and respond to issues
affecting storm water system
• Maintain backup generators
• Oversee Public Works Mutual
Assistance
• Local Energy Assurance Plan
• Damage Assessment Annex
• Evacuation Annex
(Draft in production)
• Emergency Public Information and
Warning
• Airport Emergency Plan
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
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8 AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Utilities
• ESF 3 Construction
and Engineering
State Level ESF 3
• ESF 12 Utilities
• Assist the Operations Section during EOC
Activations
• Conduct utilities infrastructure protection,
emergency repair, and restoration
• Enhance public warnings and alerts
• Provide utilities engineering services
• Maintain, repair, and restore electric,
water, gas, wastewater collection, and fiber
infrastructure
• Conduct utility damage assessment efforts
• Provide potable water in support of care
and shelter operations
• Coordinate with regional water supplies
and neighboring water utilities
• Coordinate with Pacific Gas & Electric for
the restoration of PG&E electrical and gas
transmission and distribution services to
the Utilities
• Oversee Utilities Mutual Assistance
• Local Energy Assurance Plan
• Damage Assessment Annex
• Evacuation Annex
(Draft in production)
• Emergency Public Information
and Warning
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
• Electric Utility Wildfire Mitigation
Plan
Office of
Transportation
• ESF 1
Transportation
State Level ESF 1
• Assist the Planning Section during EOC
Activations
• Develop road condition information for PD,
FD, Department of Transportation, Public
Works, RACES, Utilities, County of Santa
Clara, American Red Cross, Media
• Assist in transportation planning to support
operational objectives
• Assist in coordination of regional resources
as needed
• Evacuation Annex
(Draft in production)
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
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9 1.0 REFERENCES
The following are the references used in developing the plan.
1.1 Local Authorities and References
• City of Palo Alto Municipal Code
• City of Palo Alto
• Santa Clara County Office of Emergency Management
• Santa Clara County Emergency Operations Plan
• The Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan, including the Palo Alto Local Hazard Mitigation Plan Annex
1.2 State Authorities and References
• California Government Code
• California Emergency Services Act 2023
• California Disaster Assistance Act
• California Code of Regulations
• California Governor’s Office of Emergency Services
o Standardized Emergency Management Systems Guidelines
o Cal OES EOP Crosswalk (2024) local government
o State of California Emergency Operations Plan
o California Disaster and Civil Defense Master Mutual Aid Agreement o Orders and Regulations that may be promulgated by the Governor during a State of Emergency or a State of War Emergency
o California-Federal Emergency Operations Center Guidelines: Integrating Federal Disaster Response Assistance with California’s Standardized Emergency Management System
1.3 Federal Authorities and References
• National Fire Protection Association (NFPA)
• Federal Emergency Management Agency (FEMA) / Department of Homeland Security • Robert T. Stafford Disaster Relief and Emergency Assistance Act, PL 100-707 • Pets Evacuation and Transportation Standards Act of 2006 • National Incident Management System (NIMS)
• National Response Framework (NRF)
• Developing and Maintaining Emergency Operations Plans Comprehensive Preparedness Guide (CPG-101)
• Homeland Security Presidential Directives (5, 8)
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10 BASIC PLAN
2.0 INTRODUCTION
The EOP serves as the core planning document for Palo Alto’s emergency management activities. The responsibilities of City departments, groups, and staff are outlined in the EOP Basic Plan and associated annexes. To ensure adequate preparedness, City departments should actively participate in preparedness and planning activities including the development of departmental plan s and necessary policies and procedures to fulfill assigned roles and obligations during an emergency.
As outlined in federal planning guidance, FEMA’s Comprehensive Planning Guide 101 (CPG-101), the City’s emergency management program and the EOP embrace and implement the “whole community” approach to emergency management . The city recognizes the role of non -governmental organizations (NGOs), community -based organizations (CBO), faith -based organizations (FBO), private -sector businesses, educational institutions, and other stakeholders before, during and after disasters. The EOP is intended to reflect the wide variety of support that may be required by residents, visitors, and businesses, including people with disabilities and people with access or functional needs. Consideration for people with disabilities, access or functional needs is implemented in the City’s emergency planning.
Internal and external stakeholders and non -government organization (NGOs) agencies will need to collaborate with the City’s Emergency Operations Center (EOC) and among one another , including in circumstances where normal telecommunications may be impaired. By understanding the elements of this plan, the City and such organizations can facilitate that process.
Members of the community should be aware of the potential risks and hazards that are present and the responsibility to stay informed, make an emergency plan, and build an emergency kit.
2.1 Purpose
The purpose of th is EOP is to provide and outline the framework, concepts, and policies of Palo Alto’s emergency procedures and operations to ensure effective management and coordination of the City’s response to emergencies and disasters. It identifies roles and responsibilities for various staff members and departments regarding preparedness, response, recovery, and mitigation activities. This plan serves as a foundational document for other related City plans, as well as a reference document for other government and non -government organizations and entities. It is intended to be used in concert with other related plans, such as mitigation, recovery, and continuity of operations. This EOP complies with current federal, state, and local laws and regulations and incorporates best practices.
2.2 Goals and Objectives
The overall objective of emergency management is to ensure the effective coordination of plans, policies, response forces , and resources in preparing for and responding to situations associated with natural disasters, technological incidents and human-caused (deliberate) attacks, including national security emergencies. To fulfill its responsibilities, the emergency management organization will accomplish the following objectives during an emergency/disaster:
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11 GOAL 1
Save Lives
• Objective 1.1: Prepare and disseminate emergency public information to alert, warn, and inform the public.
• Objective 1.2: Provide effective life safety measures.
GOAL 2
Incident Stabilization and Restoration of Essential Services • Objective 2.1: Maintain overall coordination/support of emergency response and recovery operations. • Objective 2.2: Coordinate and liaise with appropriate federal, state, and other local government agencies, as well as applicable segments of private sector entities and volunteer agencies. • Objective 2.3: Establish priorities and resolve conflicting demands for support. • Objective 2.4: Provide accurate documentation and records required for cost recovery efforts. • Objective 2.5: Provide for the rapid resumption of impacted businesses and community services.
2.3 Scope
The EOP applies to any significant emergency association with any hazard or threat, natural, technical, or human-caused, which may affect the City and result in a planned, coordinated response effort by City government. While all City resources may be called upon as needed, specific departmental responsibilities are outlined in the EOP Basic Plan and associated annexes. To ensure the City is adequately prepared, all City departments are required to actively participate in preparedness and planning activities to include the development and review of departmental plans, policies, procedures, resource information and contact information as necessary to fulfill their assigned roles and obligations.
GOAL 3
Protection of Property and the Environment
• Objective 3.1: Provide effective response efforts to reduce property loss and damage to the environment.
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12 For the purpose of this EOP:
2.4 Limitations
While many of the elements outlined in the EOP are designed for flexibility and can be utilized as needed to address several emergency and non-emergency events, some activities require special activation or a formal disaster declaration (proclamation) by the City Council. Similarly, the EOP is not meant to outline procedures for routine incidents or minor emergencies which are adequately addressed through existing processes.
The EOP identifies operational strategies and plans for managing inherently complex and potentially catastrophic events. Assets, resources, and departments are potentially vulnerable and may become overwhelmed. Deviations from the organizational and respon se structures outlined in the EOP may be required, based upon evolving needs and available resources.
The EOP is an operational plan and does not address or manage response tactics. Tactics are managed by the various departments in their respective field operations protocols and procedures.
The EOP is designed to promote flexibility whenever possible and is not intended to limit the use of good judgment and common sense in matters not foreseen or adequately addressed by elements of the EOP and its associated annexes or plans.
2.5 Situation / Hazard Assessment
Technological hazards, human-caused incidents, and natural hazards are identified in the City’s Threats and Hazards Identification Risk Assessment and Hazard Mitigation Plan . The City’s current Hazard Mitigation Plan Annex identifies the following as the high and medium natural hazards for the City:
Hazard Type Probability
Heavy Rain / Severe Storm Highly Likely
High Wind Highly Likely
o The City refers to the physical location and geo-political boundaries and space described as the City of Palo Alto
o The City of Palo Alto refers to the political entity, a municipality in the northern portion of Santa Clara County
o The County refers to the County of Santa Clara and its geo-political boundaries. o Event refers to a preplanned or anticipated activity that require City resources from others – government, private sector, and/or community organization. These gatherings may draw large crowd which could make them vulnerable in the case of a natural or human caused emergency.
o Incident refers to an unplanned occurrence – natural, technological, or human caused which requires a response to safeguard life and property.
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13 Extreme Heat Highly Likely
Wildfire Highly Likely
Earthquake Likely
2.6 Planning Assumptions
Planning assumptions are consider ed information accepted by planners as being true to provide a planning framework in the absence of facts. Palo Alto OES planners have made the following assumptions in preparing the Emergency Operation Plan:
• Palo Alto is susceptible to several hazards and risks that may result in critical incidents which may include natural, technological, or human caused.
• Emergencies may occur at any time with little or no warning and may exceed the capabilities of local, state, and federal governments, and the private sector in the affected areas. • All City departments will participate in planning and preparedness activities as available. • City personnel will be adequately trained to perform the emergency roles to which they are assigned; however, some employees may not be trained but will have to perform a role due to extenuating circumstances.
• The City’s EOC may be partially or fully activated to support operations during critical incidents. • The City of Palo Alto is primarily responsible for emergency action within their municipality and plans to commit all available resources to save lives, minimize injuries to persons, and minimize damage to property and the environment.
• City departments will participate during a significant emergency or disaster; however, personnel may be unavailable or unable to report to work.
• Palo Alto will utilize SEMS, ICS, and NIMS in emergency response and management of operations. • The City will commit their resources to a reasonable degree before requesting mutual aid assistance.
• Non-essential City operations will likely be reduced or cancelled to prioritize resources. • Following a major disaster or catastrophic incident, Palo Alto may have to rely on their own resources to be self-sustaining until mutual aid is available. • Transportation infrastructure may be disrupted and access to critical facilities may be blocked. • Critical infrastructure and utilities (natural gas, water, electricity, sanitary sewer, garbage, recycling, communications, among others) may be severely impacted. • Residents, businesses, and other entities may need to be self-sufficient for one week or more. • Reasonable accommodations will be made for people with disabilities and/or access and functional needs, but additional planning, resources, and support may be required during emergencies.
3.0 CONCEPT OF OPERATIONS
In accordance with state and federal laws and guidance , the City of Palo Alto officially adopted and integrated the following emergency management, response, and coordination systems into the current emergency management operations:
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14 Collectively, the congruent operational systems outline how critical incidents, emergency, and disasters will be coordinated in the field across all levels of government – local, county, regional, state, and federal.
3.1 Field-Level Coordination
As mandated by both SEMS and NIMS, Palo Alto utilizes the Incident Command System (ICS) to manage response activities in the field. ICS provides for common terminology, processes, and position titles, while allowing the delegation of functions (or tasks) to subordinate positions to promote proper span of control and unity of command. ICS is applicable to any size incident and is designed to scalable as the needs of an incident expand or contract. When utilized, the standardization of ICS principles and nomenclature can integrate large numbers of personnel from disparate organizations.
3.2 Local, Regional, and State-Level Coordination
3.2.1 Standardized Emergency Management System (SEMS)
SEMS is intended to standardize response in emergencies and is intended to be flexible and adaptable to the needs of the emergency responders. SEMS forms the foundation of emergency management organization throughout the State of California and it s use is required by all jurisdictions. SEMS requires agencies use basic principles and components of emergency management including Incident Command System, multi-agency coordinator, operational area concept and established mutual aid systems. Local government must use SEMS to be eligible for state funding of response-related personnel costs. SEMS utilizes five organizational tiers which are activated as need be and they consist of: field response, local government, operational area, regional, and the state. Palo Alto has incorporated the use of SEMS into its emergency management program.
DIAGRAM 3.2.1
• Incident Command System
• Standardized Emergency Management System
• National Incident Management System NIMS
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15 3.2.2 Multi-Agency Coordination System (MACS)
The Multi-Agency Coordination System (MACS) is a part of NIMS and provides the basic architecture for facilitating the allocation of resources, incident prioritization, coordination, and integration of multiple agencies for large -scale incidents and emergencies. A MAC group is made up of administrators or designees authorized to represent or commit agency resources and funds. MAC groups do not have direct involvement in the incident(s) and may function virtually. The principal functions and responsibilities associated with MACS include:
Examples of a MAC Group include San Francisquito Multi-Agency Coordination Group (SFC MAC) , policy groups (elected or appointed officials), emergency management committees (emergency managers, first responders and allied agencies), or multiagency committees such as Incident Management Teams or Emergency Management Planning Committees.
3.2.3 Field Response
Field response includes on -scene activities and coordination, consistent with ICS, to make tactical decisions in direct response to the emergency of disaster. The field response is managed through an Incident Command Post (ICP). Resource requests and situa tion reports are routed from the field to the next SEMS organizational level, either through participating response agencies or the local EOC if activated.
• Situation awareness / assessment
• Incident priority determination
• Critical resource acquisition and allocation
• Anticipating / identifying future resource requirements • Coordinating policy issues
• Providing strategic coordination
• Joint Information Systems
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16 3.2.4 Local Government
The City of Palo Alto, as a local government, retains the responsibility and authority for managing response
activities within its jurisdiction. To support these efforts, the City may activate its EOC and Departments may
activate respective Department Operations Center
(DOC). The EOC provides agency coordination, provides
logistical support, establishes common operating
procedures, identifies overarching priorities, and
prioritizes available resources. Additionally, the EOC
coordinates with Santa Clara County Operational Area
(OA) / County EOC. The Local Government Incident
Management Levels graphic derives from the Santa Clara
County’s Emergency Operation Plan (Santa Clara County
OEM Emergency Operations Plan 2017) and describes
the local government incident management levels.
3.2.5 Operational Area
The Operational Area (OA) provides response coordination for all political subdivisions within the county’s jurisdiction. The OA coordinates response activities within the county’s jurisdiction through the County EOC, if activated. The OA serves as a link to the regional level and other OAs within the region.
Palo Alto is part of the Santa Clara County Operational Area and coordinates with the Santa Clara County Office of Emergency Management (OEM). The City participates in Santa Clara County OA planning and during a critical incident, coordinates with the OA, through either the Santa Clara County OEM or the Santa Clara County EOC, if activated.
3.2.6 Regional
The State of California is divided into three regions that each maintains Regional Emergency Operations Centers to coordinate resource requests, support mutual aid, and promote situational awareness between their respective OAs. The City of Palo Alto and Santa Clara County are in the Coastal Region.
3.2.7 State
The Governor, through California Governor’s Office of Emergency Services (Cal OES) and its Mutual Aid Regions , will coordinate statewide operations to include the provision of mutual aid and other support to local jurisdictions and the redirection of essential supplies and other resources as required. Santa Clara County is part of the OES Coastal Region. Requests that exceed the capabilities of the Operational Area will be forwarded to the Region.
The Cal OES Director, assisted by State agency directors, their staff , and volunteer agency staff will constitute the State emergency management staff.
Coastal Region
DIAGRAM 3.2.4 1
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17 3.2.8 Mutual Aid
The California Mutual Aid System operates within the framework of the California Master Mutual Aid Agreement and under the authority of the California Emergency Services Act. The system allows for the mobilization of resources to and from emergency response agencies, local governments, operational areas, regions, and the sta te with the intent to provide requesting agencies with adequate resources.
Mutual aid is utilized by primary response disciplines:
• Fire and Rescue
• Law Enforcement
• Coroner / Medical Examiner
• Emergency Management
• Medical & Health
Mutual Aid
Response Discipline Coordinating Agency Mutual Aid Elements Included Fire and Rescue Cal OES Fire and Rescue Branch
Fire and Rescue Mutual Aid
Urban Search and Rescue Mutual Aid
Hazardous Material Mutual Aid
Law Enforcement Cal OES Law Enforcement
Branch
Law Enforcement Mutual Aid
Search and Rescue Mutual Aid
Coroner/Medical
Examiner
Cal OES Law Enforcement
Branch Coroner/Medical Examiner Mutual Aid
Emergency
Management
Cal OES Emergency
Management
Emergency Management Mutual Aid
CalWARN
Water/Wastewater Agency Response Network
Medical and
Health
California Emergency Medical
Services Authority Disaster Medical and Health Mutual Aid Public Works Cal Waste/Wastewater Agency
Response Network (CalWARN) Public Works Mutual Aid
Utilities
California Utilities Emergency
Association (CUEA)
California Water/Wastewater
Agency Response Network
(CalWARN)
Electric, Natural Gas, Water and Wastewater
Utilities
Water and Wastewater Utilities
The California Mutual Aid System includes six mutual aid regions to facilitate the coordination and flow of mutual aid requests. As part of the Cal OES Coastal Region, Palo Alto, and the Santa Clara (County) Operational Area are part of Mutual Aid Region II.
The system includes several discipline-specific mutual aid systems that operate through designated mutual aid coordinators at the Operational Area, regional, and State levels. Mutual aid requests are Item 2
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18 coordinated within their geographic area before unfilled requests are forwarded to the next level. Mutual aid requests that do not fall into one of the discipline-specific mutual aid systems are handled through the emergency services mutual aid system and by emergency management staff at the local government, operational area, regional, and state levels.
3.3 National Incident Management System
Issued on February 28, 2003, the Homeland Security Presidential Directive-5 (HSPD-5) requires all Federal departments and agencies to make the adoption of National Incident Management System (NIMS) by State, tribal, and local organizations , a condition for Federal preparedness grants, contracts, and other preparedness activities. NIMS provides a comprehensive national framework for incident management applicable at all jurisdictional levels and across all functional disciplines. Most NIMS requirements are applicable to the City of Palo Alto, including the adoption of I ncident Command System (ICS). Additional elements of NIMS outline coordination between federal agencies and the use of federal assets and resources.
NIMS is built on the following three components:
3.4 National Response Framework
The National Response Framework (NRF) is built upon the premise that incidents are typically handled at the lowest jurisdictional level. The NRF provides the framework for federal interaction with state, local, tribal, private sector, and non-governmental entities in the context of domestic incident management to ensure timely and effective federal support.
4.0 EMERGENCY MANAGEMENT ORGANIZATION
The City’s Municipal Code (Palo Alto Municipal Code, 2024) outlines the purpose of emergency services for the preparation and carrying out of plans for the protection of people and property within respective city in the event of an emergency; the direction of the emergency organization; and the coordination of the emergency functions with all other public agencies, corporations, organizations, Emergency Operation Centers, Department Operation Centers, city departments, volunteers, and affected persons. “All officers and employees of this city, together with those volunteer forces enrolled to aid them during an emergency, and all groups, organizations and persons who may by agreement or operation of law, including persons impressed into service under the provisions of Section 9.28.060, be charged with duties incident to the protection of life and property in this city during such emergency, shall constitute the emergency organization of the city.” (Palo Alto Municipal Code, 2024)
4.1 Director of Emergency Services
The Municipal Code defines the Office of Emergency Services (OES) as a public safety department. The Director of the Office of Emergency Services (OES Chief) is also the statutory Assistant Director of Emergency Services. By title and code, the City Manager is the Director of Emergency Services. The • Resource Management
• Command and Coordination, including the Incident Command System • Communications and Information Management
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19 Director of Emergency Services assists in coordinating the City’s overall response and recovery operations.
The Director of Emergency Services also acts as the City government’s key representative and lead agent for day-to-day emergency management, with powers delegated through the Municipal Code to:
1. Direct coordination and cooperation of services and staff of the emergency organization of the City, and resolve questions of authority and responsibility that may arise between them; and
2. Represent the City in all dealings with public or private agencies on matters pertaining to emergencies.
To achieve this mandate, OES leads or coordinates planning, intelligence, and coordination, not only internally but also with allied agencies such as Stanford University, the private sector, and the community to promote, coordinate, and advance the four ph ases of emergency management: preparedness, response, recovery, and mitigation.
4.2 Emergency Services Council
The City’s Municipal Code 2.12.030 (Palo Alto
Municipal Code, 2024) establishes an Emergency
Services Council. The organization chart depicts
Palo Alto’s Emergency Services Council.
The City’s Municipal Code 2.12.040 (Palo Alto
Municipal Code, 2024) establishes the powers
and duties of the emergency services council. The
Emergency Services Council is empowered to
develop and recommend for adoption by the City
Council such emergency and mutual-aid plans
and agreements, ordinances, resolutions, rules,
and regulations that are necessary to implement
these plans and agreements. The council shall
meet when called by the chairman (Mayor) or
when absent by the vice chairman (Director of
Emergency Services).
General powers and duties of director of
emergency services is listed in the City’s
Municipal Code 2.12.50 (Palo Alto Municipal
Code, 2024):
(a) There is hereby created the office of emergency services. The city manager shall be the director of emergency services.
(b) There is hereby created the position of assistant director of emergency services who shall be appointed by the director.
Palo Alto Emergency Services Council Organization Chart DIAGRAM 4.2 1
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20 (c) The director and assistant director are hereby empowered to:
(Ord. 2641 § 1 (part) 1971: Ord. 2146 (part), 1963: prior code § 2.1005)4.3 City Employees
One of the greatest resources for the City of Palo Alto is its employees. California Government Code designates that all public employees are Disaster Services Workers (DSW) (State of California, 2013). Any employee of the City of Palo Alto may be assigned to perform activities which promote the protection of public health and safety or the preservation of lives and property within their routine levels of training proficiency. Such assignments may require services at locations, times, and under conditions that are significantly different than normal work assignments and may continue into the recovery phase of emergency.
4.4 Santa Clara County Office of Emergency Management
Santa Clara County Office of Emergency Management provides Operational Area (OA) coordination during disasters and emergencies and assists jurisdictions with preparedness, mitigation, recovery, and response efforts.
Santa Clara County OA is the next SEMS level to provide the City with support and resources during and after an emergency or disaster.
5.0 WHOLE COMMUNITY APPROACH
Palo Alto ’s ability to respond and recover from significant emergencies and major disasters is highly dependent upon planning for the unique needs and specific requirements of the residents and non - resident, commuters, and visitors. To further identify and meet the se needs, a “Whole Community” approach has been adopted to include and integrate community partners, neighbors, and other stakeholders in all phases of emergency management. Through these collaborative efforts, Palo Alto will become more resilient and better prepared to meet the needs of its residents, and any daytime population increase, those with disabilities, access and functional needs and cultural consideration. The
1. Request the city council to proclaim the existence or threatened existence of a "local emergency" if the city council is in session, or to issue such proclamation if the city council is not in session, subject to ratification by the city council within seven days thereafter or the proclamation shall have no further force or effect.
2. Request the Governor to proclaim a "state of emergency" when in the opinion of the director, the resources of the area or region are inadequate to cope with the emergency upon request by proper authority.
3. Control and direct the effort of the civil emergency organization of the city for the accomplishment of the purposes of this chapter.
4. Direct coordination and cooperation of services and staff of the emergency organization of the city, and resolve questions of authority and responsibility that may arise between them; and
5. Represent the city in all dealings with public or private agencies on matters pertaining to emergencies as defined herein.
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21 City will include the Whole Community Approach when preparing for, responding to, recovering from, and mitigating against major emergencies and disasters.
5.1 Residents
Residents of Palo Alto play a fundamental role in emergency management by ensuring that they are prepared for emergencies and disasters. In most disasters, City residents will be the first to respond — family members caring for one another, neighbor helping neighbor. In a major disaster, residents may not have access to City services for days. Individual preparedness will ensure that the City’s limited resources can go where they are most needed.
The City recommends that all residents prepare for disaster by taking first aid and CPR training, maintaining disaster supplies of food and water, and safekeeping personal documentation (e.g., personal identification and individual medical records). These actions will better prepare residents to evacuate or shelter-in-place for up to a week. Those families or residents with disabilities and others with access and functional needs may require additional personal planning before, during, and after an emergency to accommodate their need for assistance with communication, maintaining healt h and medical supplies, independence, support and safety, or transportation.
5.2 Community Organization/ Volunteer Groups
OES develops structures to link non -governmental organizations (NGOs), residents, and businesses to the Incident Command System (ICS). Elements of this include the restructured Emergency Services Volunteers (ESV) program which is a unified structure that includes Amateur Radio Emergency Services (ARES), Radio Amateur Civil Emergency Services (RACES), Block Preparedness Coordinators (BPCs), and Community Emergency Response Team (CERT) volunteers. (Emergency Volunteers – City of Palo Alto, CA) The Block Preparedness Coordinator is a grass roots program that trains volunteers to build social networks in our neighborhoods, deter crimes, and prepare for emergencies. During activation, BPCs check on their neighbors, identify and report critical problems to their Neighborhood Preparedness Coordinators (NPCs), and assist in getting resources on the scene.
CERT Basic Training is a national program designed to help prepare Palo Alto residents to help themselves, their families, and their neighbors in the event of a disaster.
Community Emergency Response Team – City of Palo Alto, CA Palo Alto's A uxiliary Communications Services (ACS) supplements emergency communications with volunteer staff. Both licensed and unlicensed volunteers can serve in one or more functions across administrative, management, technical, or operational areas in both ARES and RACES. (Auxiliary Communications Services – City of Palo Alto, CA) Item 2
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22 The Palo Alto/Stanford Citizen Corps Council (CCC) serves to harness the power of individuals, businesses, and organizations through education, training, and volunteer service. Volunteers who assist and/or support emergency efforts may be required to undergo a screening process and/or background check.
Volunteer programs determine the policies, procedures, and protocols for functionality and operations during incidents and events.
5.3 Private Sector
Palo Alto has a vibrant business community that includes traditional retail, recreational, entertainment, and corporate businesses. The City engages with the private sector to better understand their needs, identify resources, and develop partnerships. Many of the City’s private sector partners address preparedness planning internally to minimize business disruptions and to support the wellbeing of their employees and offer their resources and technical capabilities to the larger community. The City acknowledges this valuable support and will continue collaborative efforts with the private sector as a component of the overarching emergency management program. In its efforts to engage the private sector, the City may solicit agreements, arrangements, memorandums of understanding and the like with various business and or business groups, such as the Chamber of Commerce. The nature of these relationships and roles and responsibilities will be outlined in any provisions and/or documents.
5.4 People with Disabilities
People with disabilities often require additional planning and support to ensure they receive equal access and coverage as required under the Stafford Act as well as other state and federal legislation such as the Americans with Disabilities Act (ADA) of 1 990. Covered disabilities are not always apparent and may include impairments of mobility, vision, and hearing as well as some cognitive disorders and mental illnesses. For more information on assisting people with disabilities in an emergency scenario please visit the Earthquake preparedness page: Be Ready for the Next Big Earthquake – City of Palo Alto, CA. To meet the needs of these individuals, Palo Alto is committed to supporting efforts and activities designed to improve and validate capabilities in support of people with disabilities, including but not limited to:
• Notifications and warning procedures
• Evacuation, transportation and sheltering considerations • Accommodations for service animals
• Accessibility to information
• Maintaining independence
• Effective communication
• Transportation
• Supervision
• Medical care
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23 5.5 Individual with Access & Functional Needs
In addition to people with disabilities, Palo Alto recognize that additional support may be necessary to support those with access and functional needs (State of Cailifornia , 2019) . These are not necessarily related to a specific condition, diagnosis, impairment and are based upon functional areas such as:
Individuals with access and functional needs may not have access to support networks outside of their immediate communities or be able to self-evacuate. As a result, they may have additional needs before, during, and after an incident. Those with functional needs often include children, the elderly, tourists, and other segments of the population, such as:
5.6 Consideration for Pets and Animals
In 2006, the federal government passed the Pets Evacuations and Transportation Standards (PETS) Act as an amendment to the Stafford Act. The PETS Act directs state and local emergency preparedness plans address the needs of individuals with pets and compan ion animals during a disaster or emergency.
American Red Cross procedures allow for assigned service animals to accompany individuals.
Palo Alto works to include consideration for the needs of pets and companion animals in plans as appropriate. Santa Clara County Society for the Prevention of Cruelty to Animals (SPCA) maintains shelters including mobile ones for various pets and can be potentially located near a designated shelter. Throughout Santa Clara County there are numerous individuals and organizations (farms, ranches, and others) with large animals such as horses, cattle, sheep, goats, and/or pigs. Owners should make appropriate preparations (e.g., sheltering, transporting) in advance for their animals before an actual disaster occurs.
6.0 EMERGENCY MANAGEMENT PHASES
Emergency management is divided into various phases with each of these phases bending into the next one. There is no clear demarcation of when one phase starts and another one ends.
Elements from each phase may be used to support or augment elements from another phase.
• People with disabilities
• People living in institutionalized settings
• People from other cultures
• People with limited English proficiency
• People without transportation
• People who are economically disadvantaged
• Women who are pregnant
DIAGRAM 6.1
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24 6.1 Preparedness Phase
The preparedness phase involves activities undertaken in advance of an emergency. These activities develop operational capabilities and effective responses to a disaster. These activities focus on maintaining or improving capabilities that will be used in the response or recovery phases. Preparedness actions might include mitigation activities, emergency/disaster planning, training, exercises, and public education. Preparedness encompasses the whole community and promotes collaboration amongst businesses, residents, agencies, and departments to achieve the common goal of disaster preparedness.
Members of the emergency management organization should prepare checklists detailing assignments, notification rosters, resource lists and other useful documents. Personnel should be acquainted with these documents through periodic training and reviews.
6.1.1 Planning
Emergency planning includes a wide variety of plans at the strategic, operational, and tactical levels.
Strategic plans include the EOP and many of its associated hazard -specific or functional annexes, while operational and tactical planning includes more detailed information such as standard operating procedures (SOP), checklists, personnel assignments, notification rosters, resource lists, and forms.
All City departments are required to participate in the development of relevant strategic and operational plans while ensuring that internal tactical planning is sufficient to meet the needs of their outlined roles and assigned objectives. This includes the development of department-specific SOPs required to meet the objectives outlined for each department.
6.1.2 Training
Training is an essential component of preparedness and impacts the ability to respond to and recover from a critical incident.
The City facilitates trainings and regularly communicates opportunities to the whole community, City staff, and fire staff members. Additionally, the City prioritize trainings that promote staff understanding and familiarity with the following concepts:
• Identification and prioritization of essential services • Establishment, promulgation, and maintenance of orders of succession • Identification of delegation of authority
• Identification of continuity of communication
• Identification and maintenance of continuity of facilities • Maintenance of vital records
• Establishment of process of reconstruction
• Development of an effective test, training, and exercise program to support continuity efforts • Development of a Continuity of Operations Plan (COOP) – detailed and comprehensive information is contained in the COOP plan; the COOP Plan should be used in concert with the EOP
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25 The City Manager and OES are responsible for ensuring that the staff members assigned to the EOC are adequately trained and competent to fulfill their designated responsibilities. Staff members are encouraged to engage in on-going emergency management training to be familiar with current plans and guidance and capable of fulfilling the EOC role to which they are assigned.
6.1.3 Exercises
Exercises are a primary tool for assessing preparedness and identifying areas for improvement. They are a valuable method to validate plans and train personnel. Palo Alto incorporates guidance from the Homeland Security Exercise and Evaluation Program (FEMA, Homeland Security Exercise and Evaluation Program (HSEEP), 2020) in the development of its exercises.
A variety of exercises and trainings are used to assess capabilities and prioritize future planning and training needs. By simulating potential response and recovery scenarios, Palo Alto can validate existing plans and determin e where additional training might be needed. The City’s Emergency Management Team will develop a Training and Exercise Program that incorporates a building block approach in the development of planned exercises to facilitate increasing awareness and knowledge.
6.1.4 Public Awareness & Education
The Palo Alto Fire Department, the Palo Alto Police Department, and other City departments and their partners promote public awareness and education to strengthen overall preparedness, awareness, and community resilience. By providing community education, outreach, training, and coordination, the City increases the ability of community members and organizations to adequately prepare for and meet their own needs. By promoting self-reliance and preparedness, the city reduces the overall burden on resources and competing needs that may arise during critical incidents.
Public Education is an essential tool to teach residents how to prepare for, react to and recover from a major emergency or disaster. Residents can visit : Palo Alto Emergency Preparedness ; Be Ready for the Next Big Earthquake ; and Stay Informed – City of Palo Alto, CA to learn more about how to prepare for, respond to, and recover from a disaster.
Residents should take advantage of various emergency preparedness information and resources from City, County, State, and Federal governments among other sources and incorporate recommended practices into their regular routines.
• Incident Command System (ICS)
• California Standardized Emergency Management System (SEMS) • National Incident Management System (NIMS)
• California Disaster Service Worker (DSW) [CA Government Code 3101] • EOC Functions
• EOP Orientation
• Department individual training and certifications
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26 6.2 Response Phase
The response phase includes any actions taken immediately before, during, or directly after a critical incident to minimize the potential or existing impacts of the incident.
6.2.1 Pre-Event
Some incidents may provide sufficient warning to allow for pre -event or precautionary measures.
Depending on the likelihood of significant impacts, pre-event response may include:
• Public warning
• Evacuations
• Resource Mobilization
• Staging
• Mutual Aid Requests
• Proclamation of a Local Emergency
6.2.2 Emergency Response
Emergency response activities are actions taken during or immediately after a critical incident to reduce or minimize actual impacts. While these activities are often associated with traditional response units – fire, law enforcement, emergency medical ser vice (EMS), and public works and utilities – the size and complexity may require support from additional governmental agencies, non -government organizations (NGOs), businesses, community and faith-based organizations and other partners.
During emergency responses, some incidents may escalate beyond the capabilities of field operation management that may necessitate the need for additional support and coordination requiring the activation of a Department Operations Center (DOC). When an incident, or multiple incidents exceed the capabilities of a DOC, or when multiple department DOCs have been activated and more coordinated efforts are needed, the EOC should be activated.
When coordinating emergency response activities and prioritizing needs and objectives, the following hierarchy is utilized:
Emergency response may include activities related to short-term recovery and often overlaps with long- term recovery operations.
6.2.3 Prolonged Emergency
In addition to continuing life and property protection; operations, mass care, relocation, public information, situation analysis, status and damage assessment operations will be initiated.
1. Life Safety
2. Incident Stabilization
3. Protection of property and infrastructure and restoration of essential services
4. Reduce impacts to the environment
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27 6.3 Recovery Phase
The Recovery Phase includes short and long -term activities focused on returning the community to pre - incident or improved conditions. In some situations, when a disaster declaration has been made, recovery activities may include the critical task of identifying, documenting and quantifying response and recovery costs eligible for reimbursement. The City of Palo Alto’s Damage Assessment Plan includes more detailed information on recovery operations within the city.
The Recovery Phase may begin during the Response Phase or as directed by the EOC Director. Depending on the incident t he recovery process may be short or be a sustained operation lasting several years . A comprehensive recovery plan may provide more detailed actions for a prolonged recovery period. A separate and detailed Recovery Plan would contain specific procedures and protocols, roles, and responsibilities. The EOP is intended to be used mostly during the response phase of an incident; it is not intended to be a comprehensive recovery plan. The following actions may assist and facilitate recovery efforts:
6.3.1 Short-term Recovery
Short-term recovery operations begin during the response phase and may include activities such as the restoration of essential services, rapid debris removal, and the re-establishment of City services.
6.3.2 Long-term Recovery
Long-term recovery operations are often required to address extensive damage to infrastructure or widespread devastation. Activities include the restoration and reconstruction of public facilities and disaster response cost recovery.
The recovery period has major objectives that may overlap with other phases of the emergency management cycle, including:
• Reinstatement of family and individuals’ autonomy
• Provision of essential public services
• Permanent restoration of private and public property
• Conducting damage assessments
• Assessing housing needs – both support and solutions
• Issuing permits for repairs and demolition
• Debris removal
• Opening roadways and transportation routes
• Restoring utilities – water, electricity, gas, communications, sewer, internet, cable • Opening local assistance centers (LAC)
• Restart government functions
• Coordinating efforts with Santa Clara County OEM
• Working with local businesses to restore operations
• Coordinating with County, State and Federal officials regarding financial recovery for the City • Coordinate with County Public Health efforts for disasters that included health issues • Identify and prioritize essential functions and services Item 2
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28 • Identification of residual hazards
• Plans to mitigate future hazards
• Recovery of costs associated with response and recovery efforts • Coordination of state and federal, private, and public assistance
As the immediate threat to life, property, and environment subsides, the rebuilding of Palo Alto will begin through various recovery activities. Long-term planning efforts, including public safety and infrastructure sustainability, are included in the Palo Alto General Plan. Recovery activities involve the restoration of services to the public and rebuilding the affected area(s). Examples of recovery activities may include:
• Restoring all utilities
• Establishing and staffing Local Assistance Centers (LACs) and Disaster Assistance Centers (DACs) • Applying for state and federal assistance programs
• Conducting hazard mitigation analysis
• Identifying residual hazards
• Determining recovery costs associated with response and recovery
Depending on the severity of the disaster, sheltering activities could be short -term or long-term. Palo Alto will open shelters using the American Red Cross-National Survey System (NSS) as well as County guidance.
6.3.3 Damage Assessment
Damage Assessment activities involve identifying, recording, compiling, and analyzing damage information to determine the type of recovery assistance needed. Following major disasters, Preliminary Damage Assessments (PDAs) are used to determine preliminary eligibility for certain state and federal financial assistance and reimbursement programs. Damage Assessments require the coordination of multiple city departments.
6.3.4 Disaster Assistance Programs
If the disaster is significant enough to warrant a gubernatorial and a presidential disaster declaration, additional state and federal assistance may become available. A local disaster proclamation does not automatically warrant the provisions of state or federal assistance. The City will have to qualify for these additional resources. If determined to be eligible, the City and its residents may be able to participate in state and federal disaster assistance programs for the following:
• Individuals – may be eligible for loans and grants for housing assistance programs (for homeowners and renters), and uninsured disaster -related necessitates (including personal property, medical, dental, and transportation expenses). Other Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) programs include crisis counseling, disaster unemployment assistance, and legal services, may be available. • Businesses – may be eligible for low -interest loans to assist with uninsured physical damaged through the United States Small Business Administration (SBA). • Government – assistance may be available through state assistance under the California Disaster Assistance Act (CDAA), as well as sever federal programs including the FEMA Public Assistance (PA) Grant Program, and the Hazard Mitigation Grant Program (HMGP). • Non-profit Organizations - assistance may be available through the state CDAA, as well as several federal programs including FEMA PA Grant Program for eligible non-profit organizations.
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29 6.3.5 Recovery Documentation
Documentation is the key to recovering eligible response and recovery costs. Damage assessment documentation will be critical in establishing the basis for eligibility of disaster assistance programs.
Various state and federal assistance programs require several types of documentation for eligible costs and in addition to structural damage, may include staff time, equipment, and materials utilized in response to the incident. To support the maximum recovery of eligible reimbursement, City departments must identify and support internal mechanisms for tracking and documenting appropriate costs.
6.3.6 After Action Report
As part of the recovery phase, and in accordance with SEMS, the State of California requires any city declaring a local emergency for which the governor proclaims a state of emergency, to complete and transmit an after-action report to the California Office of Emergency Services (Cal OES) within 90 days of the close of the incident period. The after-action report should include the following information:
6.4 Mitigation Phase
The Mitigation Phase includes actions and measures taken to reduce or eliminate the degree of long- term risk from natural and technological hazards. Whereas preparedness activities increase the City’s ability to respond to the impacts of a hazard, mitigation activities reduce the potential for those impacts in the future, thereby reducing overall risk.
Numerous mitigation activities are available and may include the implementation, augmentation, or promotion of the following:
• Building and Safety Codes
• Disaster/Fire/Flood Insurance
• Land Use Planning and Management
• Hazard Research and Analysis
• Land and Repetitive Loss Acquisition
• Monitoring and Inspection
• Public Outreach and Education
• Relocation
• Risk Mapping
• Safety Codes, Statutes, and Ordinances
• Tax Incentives and Disincentives
• Seismic Strengthening or Retrofitting
The City participates in local and regional mitigation activities such as the development of risk assessments and mitigation plans. Further, the City’s Comprehensive Plan (General Plan) includes mitigation aspects and elements. This information is located on the City’s website.
7.0 EMERGENCY OPERATIONS CENTER
Palo Alto operates an Emergency Operations Center ( EOC) that provides a centralized location where emergency management coordination and decision-making occur and can support field operations during Item 2
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30 critical incident, major emergency, or disaster. When activated, the EOC provides support for several critical tasks related to communication, coordination, resource management, and executive leadership.
7.1 EOC Locations
The primary EOC location is: 250 Sherman Ave. Palo Alto, CA 94306 The alternate EOC location is: 3201 East Bayshore Rd, Palo Alto, CA 94303 (Municipal Services Center) Alternate locations are used when the primary EOC would or might be unsafe or unusable.
Situations and circumstances may arise in which staffing an in -person EOC fully or partially may be impractical or unwise, such as with the recent COVID -19 pandemic. Alternative staffing options may be considered and implemented and may include remote, virtual, or a combination of in-person and remote.
Staff will be provided with appropriate tools, equipment, and training to perform their assigned responsibilities. The City’s Director of Emergency Services will determine if alternate options will be implemented.
7.2 Activations & Deactivation
The EOC equipment is maintained by Palo Alto OES staff and may be used for coordination and monitoring activities at any time without the need for a formal activation. However, depending upon the need and circumstances, an official EOC activation may be appropriate to support several activities, including:
The activation level and significance of the incident/event will determine who assumes the role of EOC Director. The City Manager would usually assume the role of EOC Director during a full activation.
For incidents or events that extend beyond an operational period (e.g., 12 hours) the City Manager may designate an alternate or replacement. This person could be the assistant city manager or one of the emergency services chiefs.
7.2.1 DOC Activation
A Department Operations Center (DOC) may activate at the discretion of the senior department decision maker, or the department executive leader based upon current or impending conditions that ma y alter normal operations for a temporary period of time . DOCs may also activ ate in support of EOC and field operations during a disaster.
A DOC is a centralized location or hub dedicated to coordinating a specific department or agency’s internal incident management and response during emergencies.
7.2.2 EOC Activation Authority
The following municipal positions have the authority to activate the City’s EOC:
• Field response (disaster or major emergency)
• Pre-planned events (conventions, parade, city-wide event) • Local proclamation of emergency
• Governor’s declaration of emergency
• Presidential declaration of a national emergency
• State of War
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31 Individuals serving in an acting role or empowered to act on behalf the above positions may activate the EOC.
As situations and conditions warrant, Director of Emergency Services will communicate appropriate information to the City Council of escalating or anticipated incidents or events which may have a significant impact on Palo Alto and efforts being made to address the situation.
EOC activation may occur based upon escalating incidents or in anticipation of an incident or event.
Activation of multiple DOCs may warrant the activation of the EOC. DOC commanders should be communicating with respective department heads of current and projected situation status.
7.2.3 EOC Activation Levels
When the EOC is activated, the City will notify the Santa Clara County OEM.
The City may also establish Departmental Operations Centers (DOC s) for specific departments (e.g. , Utilities, Public Works, or IT) as required to support field operations and coordinate other functions within their respective departments. Activation of multiple DOCs may warrant or necessitate the activation of the EOC.
EOC activation levels are scalable based in the evolving needs and may include full or partial staffing as required. See table below:
• Palo Alto City Manager, Assistant City Manager, or designee o Palo Alto Police Chief or designee
• Palo Alto Fire Chief or designee
• Palo Alto OES Chief, Emergency Services Coordinator, or designee Item 2
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32 Similarly, the deactivation of the EOC will be scalable based on the decreasing needs of Palo Alto .
Appropriate EOC functions and roles will be deactivated as the situation allows and as directed by the EOC Director.
7.3 EOC Communication & Coordination
The EOC has the capability to communicate and coordinate with field personnel, incident commanders, DOCs, external stakeholders, volunteer community groups, and other government agencies.
Coordination with field elements from the EOC may be coordinated through relevant DOCs or directly with an Incident Commander. If a DOC is not activated, the Incident Commander may communicate Level Operational Status
(Minimum Positions)
Trigger
Event/Situation
(examples include but
not limited to)
Activities
Level 1
Full Staffing
as needed
All positions
(as required)
• Large Winter
Storm
• Terrorist incident
• Major Earthquake
• Regional Disaster
• Major Wildland
Fire in Urban
interface
• Situational Analysis
• Public Information
• Response Coordination
• Resource Coordination
• Logistics Support
• Recovery Operations
• Sustained Operations
• Reporting to State
Level 2
Partial Staffing
Management, EOC
Section Chiefs
Branches/Divisions/Units
Liaison/Agency reps
• Large scale
evacuations
• 2+ incident sites
• Severe Weather
Warning
• Earthquake with
minor damage
• Major scheduled
event
• Situational Analysis
• Public Information
• Response Coordination
• Resource Coordination
• Logistics Support
• Reporting to State
Level 3
Minimal
Staffing
EOC Coordinator
• Small incident or
event
• One site
• Potential threat of:
o Flood
o Severe storm
• Escalating incident
• Situational Analysis
• Public Information
• Response Coordination
• Resource Coordination
• Reporting to State
TABLE 7.2.3
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33 directly with their department specific representative, sometimes located in the Operations Section of the EOC.
The EOC will communicate and coordinate with the Santa Clara County EOC, when activated, or County OEM, and other cities in the Operational Area. Affected cities will provide situational awareness and relevant resource status to the County EOC.
Communication may be by cell phone, internet, or other viable means.
Additionally, the EOC may communicate with designated volunteer community groups through alternative methods such as amateur radios.
7.4 EOC Structure – Hierarchy of Command and Span-of-Control The essential ICS functions in SEMS and NIMS are identified as “sections” in the EOC:
All other functions are organized as branches, groups, or units within these sections. Only functional elements that are required to meet current objectives will be activated. Below is a sample ICS chart that can be expanded or scaled back based on the size and extent of an incident or event.
CHART 7.4
MANAGEMENT
OPERATIONS PLANNING LOGISTICS FINANCE
Legal
PIO
Safety
o Management—Responsible for overall emergency policy and management coordination; other responsibilities of the management staff include public information, EOC safety and security, legal review of proclamations and other similar actions, and liaising with other agencies. o Operations—Responsible for supporting operations, coordinating emergency response efforts and shelter operation support.
o Planning—Responsible for collecting, evaluating, and disseminating information; assists in developing emergency action plan; responsible for collecting all documentation material; planning also includes intelligence-gathering such as weather information. o Logistics—Responsible for providing facilities, services, personnel, equipment, materials, and resources.
o Finance—Responsible for financial expenditures, records, and other administrative aspects.
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34 Management of personnel within the EOC will be accomplished through the assignment of section chiefs (general staff) to the operations, planning, logistics, and finance functions. Section chiefs report to the EOC Director in the Management Section. Management staff consists of such positions as safety, legal, public information officer (PIO), liaison, among others. See the Palo Alto EOC Manual for position descriptions.
7.5 Emergency Action Plans
At local, operational area, regional and state levels, the use of EOC action plans (EAP) provide designated personnel with knowledge of the objectives to be attained and the steps required for achievement. Action plans give direction and provide a basis fo r measuring achievement of objectives and overall system performance in the EOC. The EOC Director will determine and direct the drafting of EAPs. The Planning Section shall be responsible for overseeing EAPs development and drafting.
8.0 EMERGENCY DECLARATIONS
8.1 Local Proclamation
California Government Code allows a local emergency to be proclaimed by a city council or designed official by city council.
If the City of Palo Alto determines that the effects of an emergency are, or may become, beyond the capability of local resources, a local emergency can be proclaimed. The Palo Alto City Council has empowered the City Manager and the Director of Emergency Services to issue a proclamation of local emergency when the City Council is not in session. Such a proclamation of local emergency is invalid after seven days, unless ratified by the City Council. Proclamations must be made within ten (10) days of occurrence to qualify for assistance under the California Disaster Assistance Act and must be renewe d every 14 days. Palo Alto Municipal Code and the California Disaster Assistance Act specify the requirements for proclaiming and, when necessary, maintaining, a local emergency. Compliance to the California Disaster Assistance Act (CDAA) (State of California, 2015) is required for the City to qualify for assistance.
A local proclamation of emergency allows the City Manager and the Director of Emergency Services to take measures necessary to protect and preserve public health and safety and may trigger certain reimbursement opportunities.
8.2 State of Emergency
After a proclamation of a local emergency, the governing body, having determined that local resources are not sufficient to mitigate the situation, may request by letter or resolution that the Governor proclaim a state of emergency in the area to fully commit state and mutual aid assistance and provide resources to assist local government.
To support its request for a gubernatorial proclamation, it is essential that the City forward an estimate of damage and financial loss to Cal OES through the Santa Clara County OEM as quickly as possible.
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35 Estimates of loss are an important part of the criteria that Cal OES considers when deciding to proclaim a state of emergency and request a Presidential Declaration of Emergency or Disaster. A copy of the request for a Governor’s proclamation, with the following supporting data, must be forwarded, to the Santa Clara County OEM Director for transmission to the Cal OES Director:
Cal OES prepares a recommendation as to the action that should be taken by the Governor. If the action recommends a Governor’s proclamation, Cal OES prepares the proclamation.
The Governor may also proclaim a state of emergency without a local request if the safety of persons and property in the state are threatened by conditions of extreme peril, or emergency conditions are beyond the emergency response capacity and capabilitie s of local authorities. Local damage assessment documentation and submission may be required for reimbursement.
8.3 State of War Emergency
In addition to a State of Emergency, the Governor can proclaim a State of War Emergency whenever the state or the nation is attacked by an enemy of the United States, or upon receipt by the state of a warning from the federal government indicating that such an enemy attack is probable or imminent. The provisions of the Governor granted under a State of War Emergency are the same as those granted under a State of Emergency.
8.4 Presidential Declaration
Following the proclamation of a state of emergency, the Cal OES Director may recommend that the Governor request a Presidential Declaration of a major disaster under the authority of Public Law 93-288.
The Governor’s request to the president is submitted through the FEMA. Supplementary justification data may be required to accompany the state and local proclamations and Initial Damage Estimate.
9.0 PUBLIC INFORMATION
During a major emergency, disaster, or significant event providing residents and the public with useful and updated information is essential. The EOC PIO will oversee messaging during an EOC activation. If the EOC is not activated, then either the lead department or City’s PIO will be responsible.
9.1 Alerts and Notifications
During an incident, the City will utilize various communication tools to disseminate information and directions to its residents. Notifications may be coordinated with neighboring agencies and/or the County.
Recognizing that some residents may have limited access or functional needs , t he City will strive to address communication in various forms. Communication tools include but not limited to:
• Copy of the local emergency proclamation
• Initial damage estimate summary that estimates the severity and extent of the damage Item 2
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36 • City Notification System - ALERTSCC
o A county-wide community alert and notification system that allows the City of Palo Alto to quickly provide critical information and instructions to subscribers using registered cell phones, emails, or landline phones through a reverse 9 -1-1 function. Registration can be completed at http://www.alertscc.gov/ or by texting your zip code to 888777.
• Connect With Us – City of Palo Alto, CA
o Palo Alto PD publishes news releases, traffic advisories, urgent updates, community news, power outage notifications, and other important safety information on Nixle. o Important City updates are shared on Nextdoor, X (Twitter), and Facebook. • Local news and radio stations participating in the Emergency Alert System. • Volunteer and neighborhood groups and community or faith-based organizations.
Public education can be a useful tool to prepare residents in advance of incidents – how to prepare for, react to, and recover from various situations.
9.2 Joint Information System
The Joint information System (JIS) is the broad mechanism that organizes, integrates, and coordinates information to ensure timely, accurate, accessible, and consistent messaging activities across multiple jurisdictions and/or disciplines with the private sector and non-governmental organizations (NGOs). It includes the plans, protocols, procedures, and structures used to coordinate and share public information.
Federal, State, tribal, territorial, regional, local, and private sector PIOs and established Joint Information DIAGRAM 9.2
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37 Centers (JIC) at each level of SEMS are critical elements of the JIS. The County / Operational Area may orchestrate JIS activities for larger or countywide incidents and events.
9.3 Joint Information Center
The Joint Information Center (JIC) is the central location that facilitates the operations of the JIS during an emergency. This location supports personnel with public information responsibilities from multiple agencies, departments, and other local governments. They perform critical emergency information functions, crisis communications, and public affairs functions.
A JIC is established at a suitable location to provide for effective management of Public Information functions. When activated, the JIC is staffed by personnel trained to conduct Public Information activities, including coordinating inter -jurisdictional media releases and management of rumor control and community communications functions. Regardless of where the JIC is established, Public In formation functions will continue to be centrally managed from the EOC, when activated.
10.0 CONTINUITY OF GOVERNMENT
Continuity of Government (COG) is an essential function of emergency management and is vital during an emergency/disaster situation. Continuity of government is defined as the preservation, maintenance, or reconstitution of the civil government's ability to carry out it s constitutional responsibilities. All levels of government share a constitutional responsibility to preserve the life and property of their citizens. The California Government Code and the Constitution of California provide the authority for state and loc al government to reconstitute itself in the event incumbents are unable to serve.
A major emergency or disaster could result in great loss of life and property, including the death or injury of key government officials. At the same time, there could be partial or complete destruction of established seats of government, and the destruction of public and private records essential to continued operations of government and industry.
In the aftermath of a major emergency, law and order must be preserved and essential government services must be maintained. To this end, it is particularly essential that local units of government continue to function.
10.1 Continuity Planning
Disasters or major emergencies have the potential to disrupt or interrupt critical and essential City services that are vital to the health and welfare of its residents. Planning for such possibilities addresses the continuation of government and succession of officers.
10.2 Line of Succession
The lines of succession for essential City positions are listed below. These individuals will assume authority until relieved. This list does not include all City departments.
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38 Primary City Position Alternate
Mayor o Vice Mayor
City Manager o Assistant City Manager
City Attorney o Assistant City Attorney
Director Planning and Development
o Assistant Director Planning & Community
o Environment Chief Building Official
Police Chief
o Assistant Chief of Police
o Police Captains
Fire Chief
o Deputy Fire Chief, Operations
o Deputy Fire Chief, Administration
OES Chief o Emergency Services Coordinator
Public Works Director
o Assistant Director
o Assistant Director Sustainability Climate Action
Director Information Technology/Chief
Information Officer
o Manager Information Technology
Chief Financial Officer
o Assistant Director Administrative Services
City Clerk o Deputy City Clerk
Director Community Services o Assistant Director Community Services Director of Utilities o Utilities Chief Operating Officer City Council o Emergency Standby Council
10.3 Essential Facilities-Alternate Government Facilities In the event an alternate location is needed to perform the day-to-day governmental functions, staff will be notified to report to one of several identified governmental facility locations, or other remote locations, where those functions can be carried out. Based upon current conditions and situation status, the alternate location will be determined by the department head or senior City official.
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39 10.4 Preservation of Vital Records
City leadership will require certain vital records during a disaster. Vital Records are the documents required to continue the mission of City departments and agencies during and after a disaster. The records will assist in providing services both to internal City departments and external customers, such as citizens, contractors, other government entities. Example documents may include:
• Public Records
• Computer system back-ups/servers
• Order of Succession Ordinances or Resolutions
• Plans, policies, and procedures for critical processes • Payroll information
• Contracts and leases
• Legal and financial records
• Insurance documents
Protection of, and access to, these and other vital records requires planning and is coordinated by the Palo Alto City Clerk. Each City department is responsible for identifying vital records, coordinating with the City Clerk, and assigning internal responsibility for their preservation. Internet and server/client-based software systems also serve as vital records because of the data they host. These systems also require a similar level of planning for remote access as well as system interruptions.
11.0 PLAN DEVELOPMENT AND MAINTENANCE
The OES has delegation of authority by City Manager to review, revise, manage, and distribute the EOP.
The Chief may delegate this assignment to another public safety staff member or members.
The EOP’s Basic Plan is subject to periodic formal approval by the City Council, whereas the Annexes are revised as needed and are not subject to formal review and City Council approval.
The EOP Basic Plan will be reviewed every five years by the City’s Office of Emergency Services. The Basic Plan may be modified at any time because of a post-incident or post-exercise evaluation, or changes in responsibilities, laws, guidance, or regulations. Changes to the Basic Plan would require readoption by the City Council.
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40 GLO SSARY AND ABBREVIATIONS
Activate: At a minimum, a designated official of
the emergency response agency that implements
SEMS as appropriate to the scope of the
emergency and the agency’s role in response to
the emergency.
ADA: American with Disabilities Act
After Action Report (AAR): A report covering
response actions, application of SEMS,
modifications to plans and procedures, training
need, and recovery activities. After action reports
are required under SEMS after any emergency
that requires a declaration of an emergency.
Reports are required within 90 days.
Agency: An agency is a division of government
with specific function, or a non-governmental
organization (e.g., private contractor, business,
etc.) which offers a particular kind of assistance. In
ICS, agencies are defined as jurisdictional (having
statutory responsibility of incident mitigation); or
assisting by providing resources.
Agency Representative: An individual assigned to
an incident or to an EOC from an assisting or
cooperating agency who has delegated authority
to make decisions on matters affecting that
agency’s participation at the incident or at the
EOC.
American Red Cross: A nationwide volunteer
agency that provides disaster relief to individuals
and families.
Available Resources: Incident-based resources
that are available for immediate assignment.
Cal OES: The California Governor’s Office of
Emergency Services.
Care and Shelter: A phase of operations that
meets the food, clothing, and shelter needs of
people on a mass care basis.
CBO: Community based organization
CDAA: California Disaster Assistance Act
CERT: Community Emergency Response Team – a
volunteer group organized by a local government
to assist during an emergency and/or disaster.
Chain of Command: A series of management
positions in order of authority.
Continuity of Government (COG): All measures
that may be taken to ensure the continuity of
essential functions of governments in the event of
emergency conditions, including line-of-
succession for key decision makers.
COOP: Continuity of Operations Plan
Coordination: The process of systematically
analyzing a situation, developing relevant
information, and informing appropriate command
authority of viable alternatives for selection of the
most effective combination of available resources
to meet specific objectives.
Cultural competence: The ability to understand,
value, communicate with, and effectively interact
with people across cultures to ensure that the
needs of all community members are addressed,
with priority given to “culturally diverse
communities.” “Cultural competence” includes,
but is not limited to, being respectful and
responsive to the cultural and linguistic needs of
diverse population groups.
Culturally diverse communities: Includes, but is
not limited to, race and ethnicity, including
indigenous peoples, communities of color, and
immigrant and refugee communities; gender,
including women; age, including the elderly and
youth; sexual and gender minorities; people with
disabilities; occupation and income level including
low-income individuals and the unhoused;
education level; people with no or limited or no
English language proficiency; as well as geographic
location.
Damage Assessment: The process utilized to
determine the magnitude of damage and the
unmet needs of individuals, businesses, the public
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41 sector, and the community caused by a disaster or
emergency event.
Dam Failure: Part or complete collapse of a dam
causing downstream flooding.
Declaration: The formal action by the President to
make a State eligible for major disaster or
emergency assistance under the Robert T.
Stafford Disaster Relief and Emergency Assistance
Act, PL 3-288, as amended (the Stafford Act).
Declaration Process: When a disaster strikes, local
authorities and individuals request help from
private relief organizations and their State
government, which give all assistance possible. If
assistance is beyond their capability, the Governor
requests a Presidential declaration of a major
disaster or an emergency.
Delegation of Authority: A statement provided to
the Incident Commander by the Agency Executive
delegating authority and assigning responsibility.
The Delegation of Authority can include
objectives, priorities, expectations, constraints
and other considerations or guidelines as needed.
Department Operations Center (DOC): A location
used by a distinct discipline, such as fire, medical,
hazardous materials, or a unit, such as
Department of Public Works, Department of
Health, or local water district to manage and
coordinate their departmental response functions
in a disaster. Department operations centers may
be used at all SEMS levels above the field
response level, depending upon the impact of the
emergency.”
Disaster: A sudden calamitous emergency event
bringing great damage loss or destruction.
DSW: Disaster Service Worker [CA Gov code 3100
– 3109]
Emergency: A condition of disaster or of extreme
peril to the safety of persons and property caused
by such conditions as air pollution, fire, flood,
hazardous material incident, storm, epidemic,
riot, drought, sudden and severe energy shortage,
plant or animal infestations or disease, the
Governor’s warning of an earthquake or volcanic
prediction, or an earthquake or other conditions.
EOC Action Plan (EAP): Similar to an IAP;
developed by the Planning Section to provide
operational planning direction for the EOC.
EMS: Emergency Medical Service
Emergency Operations Center (EOC): A location
from which centralized emergency management
can be performed. EOC facilities are established
by an agency or jurisdiction to coordinate the
overall agency or jurisdictional response and
support to an emergency.
Emergency Operations Plan (EOP): The plan that
each jurisdiction has and maintains for responding
to relevant threats and hazards that defines the
emergency management organization, structure,
and coordination.
Essential Facilities: Facilities that are essential for maintaining the health, safety, and overall
wellbeing of the public following a disaster (e.g.,
hospitals, police and fire department buildings,
utility facilities, etc.). May also include buildings
that have been designated for use as mass care
facilities (e.g., schools, churches, etc.).
Evacuation: Organized, phased, and supervised
withdrawal, dispersal, or removal of people from
dangerous or potentially dangerous areas, and
their reception and care in safe areas.
Exercise: Maneuver or simulated emergency
condition involving planning, preparation, and
execution; carried out for the purpose of testing,
evaluating, planning, developing, training, and/or
demonstrating emergency management systems
and individual components and capabilities, to
identify areas of strength and weakness for
improvement of an emergency operations plan
(EOP).
FBO: Faith based organization.
Federal: Of or pertaining to the Federal
Government of the United States of America.
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42 Federal Emergency Management Agency (FEMA):
This agency was created in 1979 to provide a
single point of accountability for all Federal
activities related to disaster mitigation and
emergency preparedness, response, and recovery.
First Responder: This term refers to individuals
whose organizations specific and primary
responsibility is to respond to life safety incidents.
Hazard: Natural or man-made source of danger or
difficulty to people or property.
Hazardous Material (Hazmat): A substance or
combination of substances, which, because of
quantity, concentration, physical, chemical,
radiological, explosive, or infectious
characteristics, poses a potential danger to
humans or the environment. Generally, such
materials are classed as explosives and blasting
agents, flammable and nonflammable gases,
combustible liquids, flammable liquids and solids,
oxidizers, poisons, disease-causing agents,
radioactive materials, corrosive materials, and
other materials including hazardous wastes.
Hazard Mitigation: A cost-effective measure that
will reduce the potential for damage to a facility
from a disaster event.
Hazard Mitigation Plan (HMP): The plan resulting
from a systematic evaluation of the nature and
extent of vulnerability to the effects of natural
hazards, including the actions needed to minimize
future vulnerability to identified hazards.
HSEEP: Homeland Security Exercise and
Evaluation Program
Incident: An occurrence or event, either human-
caused or by natural phenomena that requires
action by emergency response personnel to
prevent or minimize loss of life or damage to
property and/or the environment.
Incident Action Plan (IAP): The plan developed at
the field response level that contains objectives
reflecting the overall incident strategy and specific
tactical actions and supporting information for the
next operational period. The plan may be oral or
written.
Incident Commander (IC): The individual
responsible for the command of all functions at
the field response level located at the ICP
(Incident Command Post).
Incident Command System (ICS): The nationally
used standardized on-scene emergency
management concept specifically designed to
allow its user(s) to adopt an integrated
organizational structure equal to the complexity
and demands of single or multiple incidents
without being hindered by jurisdictional
boundaries. ICS is the combination of facilities,
equipment, personnel, procedures, and
communications operating within a common
organizational structure, with responsibility for
the management of resources to effectively
accomplish stated objectives pertinent to an
incident.
Joint Information Center (JIC): A facility
established to coordinate all incident-related
public information activities. It is the central point
of contact for all news media at the scene of the
incident. Public information officials from all
participating agencies should collocate at the JIC.
Joint Information System (JIS): Integrates incident
information and public affairs into a cohesive
organization designed to provide consistent,
coordinated, timely information during crisis or
incident operations. The mission of the JIS is to
provide a structure and system for developing and
delivering coordinated interagency messages;
developing, recommending, and executing public
information plans and strategies on behalf of the
IC; advising the IC concerning public affairs issues
that could affect a response effort; and controlling
rumors and inaccurate information that could
undermine public confidence in the emergency
response effort.
Jurisdiction: The range or sphere of authority.
Public agencies have authority at an incident
related to their legal responsibilities and authority
for incident mitigation. Jurisdictional authority at
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43 an incident can be political/ geographical (e.g.,
special district city, county, state, or federal
boundary lines), or functional (e.g., police
department, health department, etc.)
Local Emergency: The duly proclaimed existence
of conditions of disaster or of extreme peril to the
safety of persons and property within the
territorial limits of a county, city and county, or
city, caused by such conditions as air pollution,
fire, flood, storm, epidemic, riot, or earthquake or
other conditions, other than conditions resulting
from a labor controversy, which conditions are or
are likely to be beyond the control of the services,
personnel, equipment, and facilities of that
political subdivision and required the combined
forces of political subdivisions to combat.
Logistics: Providing resources and other services
to support incident management.
Mitigation: Pre-event planning and actions that
aim to lessen the effects of potential disaster.
Mutual Aid Agreement: Written agreement
between agencies and/or jurisdictions in which
they agree to assist one another upon request, by
furnishing personnel and equipment.
Mutual Aid Region: A subdivision of Governor’s
Office of Emergency Services established to assist
in the coordination of Mutual Aid and other
emergency operations within a geographic area of
the state, consisting of two or more county
(operational) areas. Sonoma County is in Mutual
Aid Region II.
National Incident Management System (NIMS): A
system mandated by HSPD-5 that provides a
consistent nationwide approach for Federal, State,
local, and tribal governments; the private-sector,
and nongovernmental organizations to work
effectively and efficiently together to prepare for,
respond to, and recover from domestic incidents,
regardless of cause, size, or complexity. To
provide for interoperability and compatibility
among Federal, State, tribal, and local capabilities,
the NIMS includes a core set of concepts,
principles, and terminology. HSPD-5 identifies
these as the ICS; Multi-agency Coordination
Systems; training; identification and management
of resources (including systems for classifying
types of resources); qualification and certification;
and the collection, tracking, and reporting of
incident information and incident resources.
National Response Framework (NRF): A plan
mandated by HSPD-5 that integrates Federal
domestic prevention, preparedness, response,
and recovery plans into one all- discipline, all-
hazards plan.
NWS: National Weather Service
Nongovernmental Organization (NGO): An entity
with an association that is based on interests of its
members, individuals, or institutions and that is
not created by a government but may work
cooperatively with government. Such
organizations serve a public purpose, not a private
benefit. Examples of NGOs include faith-based
charity organizations and the American Red Cross.
Office of Emergency Services: an office that
coordinates emergency response and
management and resource support either at the
local, county, or state level. This office may also
be referred to as Emergency Management
Department (EMD) or Department of Emergency
Management (DEM) or Office of Emergency
Management (OEM).
Operational Area: An intermediate level of the
state emergency organization, consisting of a
county and all political subdivisions within the
county’s geographic borders. An operational area
is defined in law (Section 8559, California
Government Code) as an organization (not a
jurisdiction) whose boundaries are those of a
county. This organization is not necessarily a
county government; it could be several cities, or a
city and a county, a county government, or several
county governments, willing to undertake to
coordinate the flow of Mutual Aid and
information within the defined area. The
operational area concept is the backbone of
SEMS.
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44 Plan: As used by OES, a document that describes
the broad, overall jurisdictional response to
potential extraordinary emergencies or disasters.
Preparedness: The range of deliberate, critical
tasks and activities necessary to build, sustain,
and improve the operational capability to prevent,
protect against, respond to, and recover from
domestic incidents. Preparedness is a continuous
process. Preparedness involves efforts at all levels
of government and between government and
private- sector and nongovernmental
organizations to identify threats, determine
vulnerabilities, and identify required resources.
Within the NIMS, preparedness is operationally
focused on establishing guidelines, protocols, and
standards for planning, training and exercises,
personnel qualification and certification,
equipment certification, and publication
management.
Prevention: Actions to avoid an incident or to
intervene to stop an incident from occurring.
Prevention involves actions to protect lives and
property. It involves applying intelligence and
other information to a range of activities that may
include such countermeasures as deterrence
operations; heightened inspections; improved
surveillance and security operations;
investigations to determine the full nature and
source of the threat; public health and agricultural
surveillance and testing processes;
immunizations, isolation, or quarantine; and as
appropriate, specific law enforcement operations
aimed at deterring, preempting, interdicting, or
disrupting illegal activity and apprehending
potential perpetrators and bringing them to
justice.
Private Sector: Organizations and entities that are
not part of any governmental structure. It includes
for-profit and not-for-profit organizations, formal
and informal structures, commerce and industry,
and private voluntary organizations.
Public Information Officer (PIO): The individual at
field or EOC level that has been delegated the
authority to prepare public information releases
and to interact with the media. Duties will vary
depending upon the agency and SEMS level.
PAFD: Palo Alto Fire Department
PAPD: Palo Alto Police Department
Recovery: Activities traditionally associated with
providing Federal supplemental disaster recovery
assistance under a Presidential major disaster
declaration. These activities usually begin within
days after the event and continue after the
response activities cease. Recovery includes
individual and public assistance programs that
provide temporary housing assistance, grants and
loans to eligible individuals and government
entities to recovery from the effects of a disaster.
Resources: Personnel and equipment available, or
potentially available, for assignment to incidents
or to EOCs. Resources area described by kind and
type and may be used in tactical support or
supervisory capacities at an incident or at EOCs.
Response: Activities to address the immediate
and short- term effects of an emergency or
disaster. Response includes immediate actions to
save lives, protect property and the environment,
stabilize communities, and meet basic human
needs following an incident. Based on the
requirements of the situation, response assistance
will be provided to an affected State under the
National Response Framework using a partial
activation of selected Emergency Support
Functions (ESF) or full activation of all ESF to meet
the needs of the situation.
Risk: Potential for an unwanted outcome resulting
from an incident, even, or occurrence, as
determined by its likelihood and associated
consequences.
Special District: A unit of local government (other
than a city, county, or city and county) with
authority or responsibility to own, operate or
maintain a project (as defined in California Code
of Regulations 2900(s) for purposes of natural
disaster assistance. This may include a joint
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45 powers authority established under section 6500
et seq. of the Code.
Stafford Act: Robert T. Stafford disaster Relief and
Emergency Assistance Act, PL 100-707, signed into
law June 23, 1988; amended the Disaster Relief
Act of 1974, and the Sandy Recovery
Improvement Act of 2013.
Standard Operating Procedures (SOP): A set of
instructions having the force of a directive,
covering those features of operations that lends
themselves to a definite or standardized
procedure. Standard operating procedures
support an annex by indicating in detail how a
particular will be carried out.
Standardized Emergency Management System
(SEMS): A system required by California
Government Code for managing response to
multi-agency and multi-jurisdiction emergencies
in California. SEMS consists of five organizational
levels that are activated as necessary: Field
Response, Local Government, Operation Area,
Region, and State.
State of Emergency: The duly proclaimed
existence of conditions of disaster or of extreme
peril to the safety of persons and property within
the state caused by such conditions as air
pollution, fire, flood, storm, epidemic, riot,
TEP: Training and Exercise Plan – a plan that
outlines a schedule of emergency management
and related training courses for EOC and other
support staff as well as a calendar of scheduled
EOC and similar exercises.
THIRA: The Threat and Hazard Identification and
Risk Assessment is a three-step risk assessment
process that helps communities understand their
risks and what they need to do to address those
risks (FEMA).
Threat: An indication of possible violence, harm,
or danger.
Tsunami: Also called a seismic sea wave. It is a
large oceanic wave generated by earthquakes,
submarine volcanic eruptions, or large submarine
landslides in which sudden forces are applied to
the water mass.
Vulnerability: Physical feature or operational
attribute that renders and entity open to
exploitation or susceptible to a given hazard.
Tetra Tech, Inc. | Emergency & Disaster Management Unit 2301 Lucien Way, Suite 120 | Maitland, FL 32751
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Emergency Preparedness - Wildfire Audit
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Contents
Baker Tilly Advisory Group, LP and Baker Tilly US, LLP, trading as Baker Tilly, operate under an alternative practice structure and are members of the global network of Baker Tilly International Ltd., the members of which are separate and independent legal entities. Baker Tilly US, LLP is a licensed CPA firm that provides assurance services to its clients. Baker Tilly Advisory Group, LP and its subsidiary entities provide tax and consulting services to their clients and are not licensed CPA firms.
EXECUTIVE SUMMARY .................................................................................................. 1 INTRODUCTION ............................................................................................................... 4 DETAILED ANALYSIS ..................................................................................................... 7 AUDIT RESULTS.............................................................................................................. 9 APPENDIX A MANAGEMENT RESPONSE MATRIX ......………………………………..25
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1 Executive Summary
Purpose of the Audit
Baker Tilly Advisory Group, LP (Baker Tilly), in its capacity serving as the Office of the City Auditor (OCA) for the City of Palo Alto (the City), conducted an Emergency Preparedness – Wildfire Audit based on the approved Task Order 4.25. The objective of this audit was to determine whether the City is working to prevent wildfire and adequately prepared to respond to wildfire as part of the City’s emergency management plan.
Report Highlights
Finding 1:
(Page 13)
While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
• The City of Palo Alto Utilities Department (CPAU) has made significant investments to reduce wildfire risk:
o Undergrounding distribution lines – the City is in the process of undergrounding its main distribution line in the Foothills high-risk area to reduce the potential for wildfire caused by damaged or downed lines. o Installing weather stations – to collect localized weather data to share with first responders.
o Public Power Shutoff Procedure – provides guidance for when to de- energize lines when needed to reduce wildfire risk and communicating information to the public.
o Formalizing Utility Infrastructure Maintenance Program – CPAU is in the process of formalizing its utility infrastructure maintenance program which will help guide and prioritize the utilities maintenance efforts. o Use of FLIR cameras – to detect electrical hotspots and areas that may require maintenance.
• The City has several programs to address vegetation management and improved tracking efforts may increase compliance:
o Line Clearance Program – this program is managed by the Urban Forestry division of the Public Works Department in collaboration with CPAU and ensures vegetation is cleared from electrical equipment and utility lines. OCA noted areas to improve documentation of work scheduled and performed and overall program guidance.
o Property inspections in the Wildland Urban Interface (WUI) help ensure properties in high-fire danger areas are cleared of vegetation that could potentially fuel a wildfire. OCA noted areas for improved tracking and follow-up for properties that are in violation of the City’s code. • While the City has partnered with CAL FIRE and is included in Santa Clara County’s Community Wildfire Protection Plan, community involvement could be enhanced with the establishment of Palo Alto as a Firewise Community, a Item 2
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2 EXECUTIVE SUMMARY
program that offers a structured approach for communities to enhance their wildfire resilience and promotes collaboration between residents, fire departments and other stakeholders.
• Community education and outreach could be enhanced by policies and procedures to guide efforts and track and measure their effectiveness.
Key Recommendations
We recommend the City consider the following improvements to enhance its wildfire prevention efforts:
1. Continue efforts to underground Wildland Urban Interface (WUI) distribution infrastructure and prioritize, as appropriate, maintenance and possible replacement of the oldest utility poles should they remain in place.
2. Line Clearance policy documents should be established and or reviewed, updated and finalized (e.g. Draft Tree and Landscape Technical Manual
3. Continue efforts to better track and monitor property violations in the WUI to enhance enforcement.
4. Prioritize efforts to establish a Firewise Community including stakeholder engagement throughout the process
5. Formalize the contract with CAL FIRE to ensure service provision continues into the future.
6. Ensure wildfire education and outreach plans document coordination efforts between the Office of Emergency Services (OES), Fire and CPAU to ensure information is consistently and regularly provided to residents.
Finding 2:
(Page 15)
Overall, the City has a strong emergency response plan but should consider if improvements can be made to evacuation planning, after action report recommendation implementation, and communication efforts. • The City has a comprehensive set of emergency response and wildfire plans, but should consider if evacuation plans could be enhanced and some plans may require updating and review.
o Overall, OCA found that the City’s plans align with the majority of Federal Emergency Management Agency (FEMA) guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process to ensure that plans are regularly reviewed and updated. In addition, while the Foothills Fire Management Plan (FFMP) addresses evacuation routes and ensuring these routes remain clear for emergency personnel as well as residents for evacuation, we recommend the City consider additional planning activities based on the U.S. Department of Homeland Security’s, Planning Considerations: Evacuation and Shelter-in-Place; Guidance for State, Local, Tribal, and Territorial Partners, July 2019.
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3 EXECUTIVE SUMMARY
• The City monitors training requirements and compliance and recently implemented a new sign-in process to improve tracking.
• While the City conducts training and after-action reports (AAR) after critical incidents, efforts to track and implement resulting recommendations could be improved.
• The City is enhancing its wildfire detection capabilities through the use of gas monitoring sensors deployed in the Foothills area.
• The City employs several methods for communicating critical information to its residents during an emergency and should continue to explore methods to increase participation in the County’s emergency alerting system. o Based on the alert system sign-up data provided and Santa Clara County, 17% of Palo Alto residents were registered in the system in 2025.
• While the City has strong relationships with their mutual aid agreement partners
1, the City does not maintain these agreements in a central repository for easy tracking and monitoring.
Key Recommendations
We recommend the City consider the following improvements to enhance its Wildfire response efforts:
1. The City’s emergency plans align with the majority of FEMA guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process. The City should also review its evacuation plans and consider if plans could be enhanced by reviewing best practices in other cities such as establishing evacuation locations and sheltering agreements with neighboring communities.
2. City management should more formally track and monitor findings and recommendations identified during training exercises and in AARs of emergency incidents to ensure needed improvements are made and issues are timely resolved.
3. Continue to explore ways to increase resident registration in the County’s emergency alerting system. Opportunities may include partnering with schools, homeowner associations, and local businesses to disseminate wildfire education materials and encourage participation in City programs and the County’s emergency alert system.
4. Determine an appropriate solution for staff to more easily access, track and monitor the status of all mutual aid agreements, including active dates, renewal deadlines, and responsible contacts for updates. For example, a centralized tracking system for mutual aid agreements would provide clarity on the status of each agreement, preventing lapses in mutual aid coverage and ensuring that expired agreements are addressed promptly.
1 Mutual aid partners include Los Altos Hills, Santa Clara County, Woodside, Mountain View, and the California Department of Forestry and Fire protection.
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4 Introduction
Objective The objective of this audit was to determine whether the City is working to prevent wildfire and adequately prepared to respond to wildfire as part of the City’s emergency management plan.
Background The rise in wildfires in California is fueled by a complex interplay of climate change, historical land management practices, human activities, and ecological shifts, all of which impact cities like Palo Alto that are situated near high-risk wildland-urban interface (WUI) zones. Climate change has intensified the state’s wildfire risk by driving higher temperatures, wind speeds, and drier conditions, which extend the fire season and increase the probability of fires. Historical land management practices, including the suppression of indigenous fire management techniques and aggressive fire suppression policies in the 20th century, have led to an accumulation of vegetative fuels. Additionally, logging practices have left denser forests prone to more intense fires. Human activities— ranging from infrastructure failures to recreational fires—are the primary sources of ignition, particularly as urban areas expand into WUI zones, increasing both the human and economic impact of fires.
In response to wildfire risks, the City of Palo Alto’s Office of Emergency Services (OES), Fire Department, and City of Palo Alto Utilities (CPAU) are all actively engaged in wildfire preparedness, prevention, and response efforts, coordinating resources and community education initiatives to address these risks. The City works closely with CAL FIRE, regional partners, and neighboring cities to implement and refine emergency response plans, ensure effective evacuation routes, and conduct community outreach on wildfire preparedness. Recognizing the need for a multifaceted approach to wildfire mitigation, the City supports initiatives that promote sustainable land management practices, encourages defensible space in WUI zones, and advocates for policies to reduce human- caused ignitions. By fostering partnerships and promoting proactive wildfire safety measures, Palo Alto is dedicated to enhancing the city’s resilience against the growing threat of wildfires in California.
The following table provides an overview of the City’s various planning documents related to wildfire preparedness and response, as well as their purpose and when they were last updated.
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5 INTRODUCTION
Table 1: City Emergency Preparedness Plans
Title Purpose Date
Emergency
Operations Plan
Basic Plan (EOP)
The EOP embraces the FEMA "whole community" approach. According to the EOP, the City has undergone multiple hazard analysis processes per the FEMA Comprehensive Preparedness Guide 201. The EOP also states the City actively manages training activities and allocates funding in relation to fluctuating needs, personnel turnover, and course availability.
January
2016*
Emergency
Operations Center
Manual (EOC)
The EOC wildland fire response is primarily addressed through the EOC activation, the plan's emphasis extends beyond immediate response to a broader, proactive strategy. According to the EOC the City prioritizes comprehensive hazard analysis and ongoing training aligned with state and national standards such as ICS, SEMS, and NIMS.
July
2021
Wildland Urban
Interface (WUI)
Fire Response
An annex to Palo Alto’s EOP, focusing on WUI fire response. It aligns with state and national emergency management systems (SEMS and NIMS). The primary goals are to guide initial response planning, support the development of incident plans, and ensure coordinated interagency actions.
August
2023
Local Hazard
Mitigation Plan
(LHMP)
The LHMP is part of the larger Santa Clara Operational Area Hazard Mitigation Plan and has a Palo Alto Annex. The LHMP details potential hazards for Palo Alto and provides recommended action on the hazards.
October
2024
Foothills Fire
Management Plan
(FFMP)
The FFMP focuses on mitigating wildfire risks in the Foothills area through targeted vegetation management and strategic planning. The document highlights accomplishments since the initial 2009 plan, including improved evacuation routes, prescribed burns, and reduced fire hazards near critical infrastructure. The update emphasizes ongoing efforts like annual maintenance of treated areas, collaboration with regional agencies, and leveraging funding opportunities. The plan includes post-treatment fire behavior analysis, showcasing how vegetation management efforts have improved emergency access and reduced the likelihood of wildfire spread.
January
2017
CPAU Wildfire
Mitigation Plan
The CPAU Wildfire Mitigation Plan focuses on minimizing the risk of wildfires caused by electric lines and infrastructure. Key strategies include undergrounding power lines in high-risk areas, such as the Foothills region, updating Public Safety Power Shutoff (PSPS) protocols, enhanced vegetation management, and the use of advanced technologies like non-expulsion fuses and remote deenergization switches. The plan emphasizes collaboration with other departments, such as Fire and Urban Forestry, to ensure comprehensive wildfire prevention efforts. Regular inspections, vegetation clearance exceeding regulatory standards, and continuous monitoring are highlighted as critical components. The plan includes performance metrics to track the effectiveness of mitigation efforts, ensuring proactive adjustments where needed.
June
2024
Santa Clara
County
Community
Wildfire Protection
Plan (CWPP)
The Santa Clara County CWPP aims to reduce wildfire risk by establishing cooperative relationships with federal, state and local stakeholders before an event occurs and developing pre-attack plans to enhance firefighter readiness and safety. The CWPP includes annexes which offer information and project recommendations specific to geographical planning areas. The City of Palo Alto is included as an annex. Communities are currently updating their annex plans.
August 2016
* The EOP is being updated and expected to be complete by Q4 Calendar Year 2025 per management.
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6 INTRODUCTION
2 Government auditing standards require an external peer review at least once every three (3) years. The last peer review of the Palo Alto Office of the City Auditor was conducted in 2017. The Palo Alto City Council approved a contract with Baker Tilly U.S., LLP for internal audit services for October 2020 through June 2022 with an extension through June 2025. City Council appointed Kate Murdock, Audit Manager in Baker Tilly’s Risk Advisory practice, as City Auditor in May 2024. As a result of transitions in the Audit Office and peer review delays due to the COVID pandemic, an external peer review is targeted for 2025. It should be noted that Baker Tilly’s most recent firmwide peer review was completed in October 2021 with a rating of “Pass”. The scope of that peer review includes projects completed under government auditing standards. A report on the next firmwide peer review should be available later in 2024.
Scope
The OCA evaluated the City’s plans and efforts related to wildfire prevention and preparedness by assessing related activities and internal controls from FY2023 through FY2024 in the OES, Fire Department, and CPAU.
Methodology To achieve the audit objectives, the OCA performed the following procedures:
• Interviewed the appropriate individuals to understand the roles and responsibilities, processes, and controls related to Emergency Preparedness (Wildfire) activities.
• Analyzed current policies and procedures (P&P) as well as FEMA and CAL FIRE standards and best practices.
• Evaluated relevant documents such as City of Palo Alto EOC Manual, CPAU Wildfire Mitigation Plan, FFMP, and various other plans • Gathered information and reports to assess if current City plans are sufficient in preventing and responding to wildfire risks.
• Inquired with OES departments for clarification and understanding of emergency plans.
• Completed audit report of findings, conclusions, and recommendations based on the supporting evidence gathered
Compliance
Statement
This audit activity was conducted from June 2024 to December 2024 in accordance with generally accepted government auditing standards, except for the requirement of an external peer review2. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
Organizational
Strengths
During this audit activity, we noted the expertise and the responsiveness demonstrated by the Emergency Preparedness team. We also observed their willingness to provide and receive feedback regarding the emergency preparedness process, which includes their receptiveness to process improvements.
The OCA greatly appreciates the support of the Fire Department, Office of Emergency Services, City Manager’s Office, and City of Palo Alto Utilities Department in conducting this audit.
Thank you!
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7 DETAILED ANALYSIS
Detailed Analysis
Best Practices:
Emergency
Preparedness &
Response
In its publication, Developing and Maintaining Emergency Operations Plans, FEMA highlights five key areas for communities to address related to Emergency Preparedness. These include:
• Prevention – reducing risk from human-caused incidents • Protection – reducing or eliminating the threat to people and critical infrastructure
• Response – actions taken in the immediate aftermath of an incident • Recovery – short-term and long-term efforts for rebuilding and revitalizing the affected community
• Mitigation – structural and non-structural approaches to eliminating or limiting the hazards presence
This audit report focuses on the first three areas as they relate to the audit objectives, but recognizes the City has efforts related to recovery and mitigation of wildfire risks too.
Shared Community Preparedness themes
Additional best practice information comes from the National Incident Management System (NIMS) and CAL FIRE. NIMS offers guidance on resource management, mutual aid, and communication during emergency events. CAL FIRE provides guidance and best practices for wildfire events specific to Fire Hazard Severity Zones (FHSZ), further described below. Guidance from FEMA, NIMS, and CAL FIRE all emphasize the importance of the following principles in preparing communities for emergencies including wildfires. Common themes include:
• Community Engagement: Public education and participation are key to ensuring communities are informed and involved.
• Response Coordination: Implementing reliable policies for consistent response across agencies and stakeholders is key to NIMS ICS framework and mutual aid strategies with FEMA’s planning and CAL FIRE’s interagency collaboration.
• Training and Communication: Regular drills and clear communication protocols are critical to ensure preparedness and efficiency during emergencies.
FEMA offers additional guidance related to wildfire emergency preparedness.
FEMA's best practices, as highlighted in their publication Developing and Maintaining Emergency Operations Plans. These best practices include:
• Risk Assessment and Planning: Conducting thorough risk assessments to identify potential wildfire hazards and developing comprehensive emergency plans that address these risks.
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• Public Information and Warning: Ensuring that timely and accurate information is provided to the public about wildfire risks, evacuation orders, and safety measures.
NIMS offers important recommendations for departments handling wildfire emergencies. These best practices include:
• Communication and Information Management: Implementing reliable communication systems and protocols to ensure timely and accurate information sharing during wildfire emergencies.
• Incident Command System (ICS): Utilizing the ICS to coordinate response efforts and manage resources effectively during wildfires.
CAL FIRE offers comprehensive guidance related to wildfire emergency preparedness. CAL FIRE's best practices provide essential recommendations for departments handling wildfire emergencies. These best practices include:
• Fire Hazard Severity Zones (FHSZ): Identifying and mapping areas with varying degrees of fire hazard severity to prioritize resources and mitigation efforts.
• Evacuation Planning: Developing and regularly updating evacuation plans to ensure that residents can safely and efficiently evacuate in the event of wildfire.
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9 Audit Results
City Efforts to Prevent and Protect from Wildfire
Finding 1: While
the City has
made significant
investments in
and has strong
programs aimed
to prevent and
mitigate wildfire
risks; we noted
some areas for
improvement
including
enhancing
community
outreach and
engagement.
The City coordinates and collaborates across departments and with neighboring jurisdictions to prevent and protect the City and its residents from the risk of wildfire. These risk areas include utility infrastructure maintenance, vegetation management, and community outreach and education.
CPAU has made significant investments to reduce wildfire risk CPAU provides electricity to the entire Palo Alto service area including the Foothills/Wildland Urban Interface (WUI) Area and prepares and submits a Wildfire Mitigation Plan to the California Wildfire Safety Advisory Board each year. CPAU has invested in several projects to reduce wildfire risk including undergrounding distribution lines and installing weather stations. The Utility has also developed a Public Safety Power Shutoff (PSPS) procedure.
Undergrounding Distribution Lines
CPAU began the Foothills project to underground distribution lines in the Foothills high-risk area in 2021. This project, which will be completed in summer 2025, includes the undergrounding of approximately 49,200 feet of distribution lines. The project includes undergrounding the main 12470- voltage distribution line as well as fiber optic cable. Utility distribution lines pose a significant wildfire risk and undergrounding these lines largely eliminates this threat as lines cannot be damaged by trees or high winds which can spark fires by falling on vegetation below.
Based on information provided by CPAU, much of the overhead infrastructure within the Wildland Urban Interface (WUI), designated as the High Fire Threat Tier 2 zone, encompassing all city areas west of Highway 280, known as the "Foothills Area" will be undergrounded.
As part of City’s wildfire mitigation strategy, CPAU has prioritized the undergrounding of its overhead infrastructure in the WUI/Foothills Tier 2 area. The Foothill Fire Mitigation Project includes the following key activities:
• Substructure construction, including the installation of boxes and pad-mounted equipment
• Cable pulling and line energization
• Decommissioning of overhead poles and equipment
According to CPAU, the Foothill Fire Mitigation Project is estimated to underground 182 of the total of 203 poles and overhead lines in the high-risk area. The estimated 21 remaining poles require additional coordination with pole attachers, and customers prior to either undergrounding or implementation of additional fire hardening measures. As of March 2025, CPAU management reported it has completely de-energized and undergrounded electric lines for 69 of the 182 poles, significantly reducing the wildfire risk associated with overhead power lines in the area.
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10 3 Red Flag Warning
The table below shows the age of the remaining 21 poles that are not being removed as part of the initial Foothill Fire Mitigation Project.
Table 2: Age of Remaining Poles in WUI
*Analysis conducted by the OCA in March 2025
The OCA saw a range of estimates on how long utility poles can last, anywhere from 35 to 75+ years depending on conditions and maintenance, which suggests CPAU should prioritize maintenance and possible replacement of the oldest poles should they remain in place.
Additionally, CPAU is implementing a multi-year Grid Modernization initiative that will enhance grid resiliency and reliability of the electric distribution system by replacing poles, transformers, aerial wires, some cabinets and underground substructure. The initiative also includes upgrades to two of their substations, with a target completion by 2032.
Weather Station Installation
CPAU installed weather stations in the Foothills area and at the Utility Control Center to collect localized weather data which is shared with first- responder departments to determine if any actions are needed due to conditions. The Utility also monitors regional conditions and receives red flag warnings which signal when fire conditions are heightened3.
Public Safety Power Shutoff Procedure
CPAU has a Public Safety Power Shutoff procedure which provides guidance for deciding when lines may need to be de-energized to reduce Item 2
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11 4 California Public Resources Code Section 4293
wildfire risk and how best to communicate this information to the public.
Residents in the Foothills area are notified via email when de-energization is anticipated and are typically provided with dates and shutoff times.
Forward Looking Infrared (FLIR) Cameras
In addition to visual inspections, CPAU utilizes FLIR Cameras which are used to detect hotspots where electrical equipment could be overheating and treat areas before they become a problem. This use of technology helps enable the City to proactively address maintenance issues.
The City has several programs to address vegetation management and improved tracking of efforts may increase compliance
Wildfires and their spread are dependent on several conditions, such as fuel load or the accumulation of vegetation, as well as weather conditions which determine their severity. The City has several programs and resources dedicated to managing vegetation including resident assistance programs.
These programs include:
• Line Clearance Program
• Right Tree Right Place
• Property Inspections in the Wildland Urban Interface
• Santa Clara Fire Safe Council CAL FIRE
Line Clearance Program
The City’s Line Clearance Program ensures vegetation is cleared from electrical equipment and utility lines, patrol to ensure access roads to facilities remain clear, and right-of-way clearing. The Program, typically completed via a contract with the Fire Safe Council (FSC), is managed by the operations division of the Public Works Department in the absence of a contract with FSC and in collaboration with CPAU. The City’s aim is to maintain a 10-foot clearance from trees in the Foothills area which is in accordance with California law
4 and the California Public Utilities
Commission.
According to the City’s Tree Management Plan and interviews with staff, the entirety of the Foothills area is inspected and cleared each year in the Spring with a follow-up inspection conducted in the fall. Staff stated that they have not experienced any resource constraints and major tree trimming occurs every 3 to 4 years. Compliance is maintained in intervening years through the biannual inspections and subsequent tree trimming. Tree trimming activities are tracked using a software program called TreeKeeper.
Staff reported they do not currently track inspections but are working on how to capture them as a work record in TreeKeeper. The table below shows how many trees were trimmed in the Foothills area from 2021 to 2024.
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12 Table 3: Number of Trees Trimmed in the
Foothills Area from 2021 to 2024*
*Data analysis conducted by OCA in October 2024
Urban Forestry staff provided the OCA with two guiding documents: Urban Forest Master Plan and Draft Tree and Landscape Technical Manual. While the Urban Forest Master Plan provides overall guidance and includes information on the Line Clearance Program, the Draft Tree and Landscape Technical Manual provides information on what equipment and what environmental conditions to consider for conducting tree trimming to reduce the risk of ignition due to maintenance activities. Staff said that the Manual is intended as a supporting document to the City’s tree ordinance and its Fire- Safe Landscapes section provides residents with tree and landscaping guidance in support of creating a defensible space around one’s home against wildfire risk.
The OCA noted that this draft manual did not appear to be complete. For example, there were imbedded notes for staff to determine seasonal criteria for tree trimming. Overall, while these documents provide good information, they require updating, completion, and dissemination.
Right Tree Right Place Program
The Right Tree Right Place Program provides resources for residents with trees that conflict with power lines. The program includes removing trees at no cost, reimbursement for stump removal and reimbursement for replacing trees with appropriate tree alternatives.
Property Inspections in the Wildland Urban Interface
The City’s Fire Marshal oversees fire safety inspections of businesses and properties. These inspections ensure businesses and residents comply with California Fire Code and keep properties clear of fuel that could increase the risk of wildfire. When a property is found in violation of the Fire Code, they are issued a “Notice of Violation” and typically given a month to make corrections. If a property fails reinspection, the property may be referred to Item 2
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13 the Fire Prevention Bureau and potentially invoiced for any remediation or reinspection fees incurred by the City. The City also adopts a Weed Nuisance Abatement resolution annually and works in coordination with the County of Santa Clara to address properties with weeds that are deemed a nuisance and/or fire hazard.
Based on reports analyzed by the OCA, in 2023 there were 133 homes in Palo Alto’s Wildland Urban Interface (WUI). Inspections were conducted for 104 of these homes and 86 of these passed the first inspection. However, it appears that only 3 homes were reinspected and 26 homes had outstanding violations at year-end. Management stated that this report needs to be cleaned up and there may be less than 133 properties in the Palo Alto WUI.
In 2024, through the third quarter of the year, the City had performed 138 inspections in the WUI.
The City recently began using a new system to track fire inspections and management reported they are working with the City’s Information Technology Department to develop more robust reporting capabilities so the Fire Marshal can more easily track metrics on how many violations have been issued, how many have been corrected, how many referred to the fire prevention bureau, etc.
With improved data tracking and reporting capabilities, the City will be able to better and timelier follow-up with businesses and residents who are not in compliance with the Fire Code and ensure wildfire risk is reduced.
Santa Clara Fire Safe Council
The City has a short-term contract with Santa Clara Fire Safe Council to help with roadside clearance work, public education, and pursuing grant opportunities. Staff stated that the City has introduced the Firewise program in the past through the Fire Safe Council, but the program has not had much traction and Palo Alto does not currently have a Firewise Community, a program that must stem from the impacted residents. The Firewise USA ®
program offers a structured approach for communities to enhance their wildfire resilience and promotes collaboration between residents, fire departments and other stakeholders. Establishing a Firewise program is also recommended for Palo Alto in the Santa Clara County Community Wildfire Protection Plan.
A core principle in Community Wildfire Protection Plans is to include as many agency representatives and resident leaders in the planning process as possible. The first goal in FEMA’s Creating a Community Wildfire Protection Plan is to “Create fire-adapted communities” which includes pursuing Firewise site recognition, providing information to the community about fire safety, and reducing risks for home ignition. As stated in the CWPP, the City should strongly consider working with the local Foothills community to attain and maintain Firewise USA recognition.
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14 CAL FIRE
CAL FIRE has provided assistance to the City over the past couple of years in clearing out vegetation in the Foothills area and including some areas with Eucalyptus trees. The City does not currently have a formal contract with CAL FIRE for these services, however, this is something they should consider ensuring for service provision in the future.
Community Education and Outreach could be improved.
While the City has implemented various programs and trainings to promote the community's wildfire awareness and prevention efforts, there is room for improvement. Currently, there is no comprehensive policy or set of requirements established for the City's overall community outreach and education efforts to ensure sufficient information and education are provided to the residents for wildfire prevention and emergency preparedness. As a result, the City's overall community outreach and education efforts are not tracked to ensure goals are met.
Limited efforts to measure education and outreach effectiveness According to management, community outreach and education responsibilities are shared between Fire Prevention and OES and the citywide communications team. Staff said efforts were tracked in the past, but they lost the position responsible for this activity and there are currently no P&P in place to guide the provision or tracking of education and outreach efforts. Staff indicated that recent efforts have not been well attended by residents, making it difficult to assess how engaged and prepared the community is to prevent and respond to wildfires.
CPAU also performs community education and outreach activities and includes wildfire information as part of its regular communications with customers. CPAU employs several methods for communicating with customers including utility bill inserts, email newsletter, direct mail, social media, and the CPAU website. While staff provided several examples of wildfire education efforts, they indicated there is no policy or plan outlining expectations or responsibilities for outreach and education efforts, how often they should be performed and/or how to determine what information gets shared. In accordance with State law, the Utility Wildfire Management Plan is presented annually in a public meeting to the Utilities Advisory Commission. Developing a guiding document with appropriate goals and targets could help ensure the utility consistently communicates with residents and could aid in tracking the effectiveness of these efforts over time.
Some residents report a lack of wildfire preparedness education and a desire for more information related to City prevention efforts The City of Palo Alto’s Community Survey results from 2023 support the observations above that the City could improve outreach efforts to community members. When asked about the quality of Palo Alto’s fire prevention and education services, 37% of respondents in 2023 answered “don’t know”, 18% answered “fair” or “poor”, and 45% answered “good” or “excellent”. However, it should be acknowledged that this question is posed Item 2
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15 as broader “prevention” activities and does not specify wildfire prevention nor is the sample size specific to the WUI region.
In 2022, CPAU’s study of Key Account Customers found that 40% indicated being “very concerned” with future wildfires and a 2023 Residential Electric Customer Satisfaction Study reported that the second most desired topic of information (44%) is “what CPAU is doing to prepare for emergencies like wildfires and earthquakes.”
The City’s Fire Department conducts annual property inspections in the WUI to detect dangerous conditions that could contribute to or exacerbate wildfire risk. As noted above, our analysis of the fire inspection log from 2023 shows that 26 out of an approximate 133 homes in the WUI had outstanding violations and in 2024 more than 74 homes had violations. Annually doorhangers are provided to residents in this area. Additional measures such as education, outreach, and fines may help to reduce violations by informing residents of the dangers of excess vegetation and any maintenance or prevention related resources available to them. The Fire Department does maintain an online wildfire preparedness resource for community members:
https://www.cityofpaloalto.org/Departments/Fire/Prepare-For-Wildfire- READY-SET-GO.
Recommendation We recommend the City consider the following improvements to enhance its Wildfire prevention efforts:
1. Continue efforts to underground WUI distribution infrastructure and prioritize, as appropriate, maintenance and possible replacement of the oldest poles should they remain in place.
2. Line Clearance policy documents should be established and or reviewed, updated and finalized (e.g. Draft Tree and Landscape Technical Manual)
3. Continue efforts to better track and monitor property violations in the WUI to enhance enforcement.
4. Prioritize efforts to establish a Firewise Community including stakeholder engagement throughout the process
5. Formalize the contract with CAL FIRE to ensure service provision continues into the future.
6. Ensure wildfire education and outreach plans document coordination efforts between OES, Fire and CPAU to ensure information is consistently and regularly provided to residents.
Management
Response
Please see appendix for responses.
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16 City Wildfire Response Plans
Finding 2:
Overall, the City
has a strong
emergency
response plan
but should
consider if
improvements
could be made to
evacuation
planning, after
action report
recommendation
implementation,
and
communication
efforts.
The City takes a proactive and collaborative approach in responding to and mitigating wildfire risks by coordinating closely across its own departments— such as the OES, Fire Department, CPAU, and Public Works—and with neighboring jurisdictions. These risk areas include Planning, Training, Detection, Communication, and Resources.
The City has a comprehensive set of emergency response and wildfire plans, but the City should consider if evacuation plans could be enhanced and some plans may require updating and review
The City has several plans that all work in conjunction with each other to ensure the City is prepared to response to various disasters and hazardous conditions. In addition to internal plans, the City is part of Santa Clara County’s Community Wildfire Protection Plan. We discuss several of the plans guiding the City’s response approach, below.
The City has 6 plans related to wildfire.
• Overarching Emergency Operation Plans (EOP) which contains the annexes Emergency Operations Center Manual (EOC),
• Local Hazard Mitigation Plan (LHMP),
• Foothills Fire Management Plan (FFMP),
• Wildland Urban Interface Fire Response (WUI), and
• CPAU Wildfire Mitigation, which is a wildfire plan for the City Utilities Department.
•
The EOP adopted by city council on January 11, 2016, states that it follows FEMA's "whole community" approach. The EOP in general follows the format laid out by FEMA. The revision history and certification of biennial review on the EOP are blank both on the EOP provided to auditor and on the City website, indicating that the plan has not been updated or reviewed in 8 years.
The distribution section of the EOP does not adhere to FEMA's recommended format, which specifies that this section should be presented as a list. Management has identified that the EOP is currently undergoing review and update in 2025.
In the EOC, wildland fire response is primarily addressed through the EOC activation, the plan's emphasis extends beyond immediate response to a broader, proactive strategy. According to the EOC, the City prioritizes comprehensive hazard analysis and ongoing training aligned with state and national standards such as ICS, SEMS, and NIMS.
The LHMP is part of the larger Santa Clara Operational Area Hazard Mitigation Plan and has a Palo Alto Annex. The LHMP details potential hazards for Palo Alto and provides recommended actions to prepare for these hazards. This plan was recently adopted by the City Council in October 2024.
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17 The FFMP for Palo Alto focuses on mitigating wildfire risks in the Foothills area through targeted vegetation management and strategic planning. The document highlights accomplishments since the initial 2009 plan, including improved evacuation routes, prescribed burns, and reduced fire hazards near critical infrastructure. The update emphasizes ongoing efforts like annual maintenance of treated areas, collaboration with regional agencies, and leveraging funding opportunities. The plan includes post-treatment fire behavior analysis, showcasing how vegetation management efforts have improved emergency access and reduced the likelihood of wildfire spread.
There is a monthly meeting with
OES, CSD Open Space Division, Fire
Marshal’s Office, Public Works Operations, and Utilities Engineering to address and discuss current issues within the FFMP. The City is currently in the process of updating this plan.
The WUI focuses on WUI fire response and provides a concept of operations in the development of an effective and coordinated response to a significant wildland urban interface (WUI) Fire. This provides direction for city departments, community groups, and allied stakeholders ensuring interagency coordination in accordance with the City’s EOP, the California Emergency Services Act, the Standardized Emergency Management System (SEMS), and the National Incident Management System (NIMS).
The CPAU Wildfire Mitigation plan focuses on minimizing the risk of wildfires caused by electric lines and infrastructure. Key strategies include undergrounding power lines in high-risk areas, such as the Foothills region, enhanced vegetation management, and the use of advanced technologies like non-expulsion fuses and remote deenergization switches. The plan emphasizes collaboration with other city departments, such as the Fire Department and Urban Forestry, to ensure comprehensive wildfire prevention efforts. Regular inspections, vegetation clearance exceeding regulatory standards, and continuous monitoring are highlighted as critical components. The plan also includes a performance metrics framework to track the effectiveness of these mitigation efforts, ensuring proactive adjustments where needed.
Areas for Improvement
Overall, OCA found that the City’s plans align with the majority of FEMA guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process to ensure that plans are regularly reviewed and updated. In addition, while the FFMP addresses evacuation routes and ensuring these routes remain clear for emergency personnel as well as residents for evacuation, we recommend the City consider the following enhancements based on Homeland Security’s, Planning Considerations: Evacuation and Shelter-in-Place; Guidance for State, Local, Tribal, and Territorial Partners, July 2019. This guidance highlights the following responsibilities for local jurisdictions:
• Setting clear expectations for whole community partners through education, training and information sessions,
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18 • Establishing and publishing clear evacuations routes and zones for the community,
• Identify evacuation shelters within the community and in other communities working with those neighboring communities to establish notification and operational procedures,
• Create pre-approved accessible messaging for rapid distribution regarding incident and shelter in place or evacuation instructions, • Have a continuity plan to help maintain response operations if interrupted, and
• Provide real-time mapping and navigation routing systems through Geographic Information System (GIS).
Homeland Security’s guide also highlights key lessons from past wildfire emergencies that occurred in Los Angeles County, CA and Larimer County, Colorado:
• Need for increased coordination for quicker incorporation of GIS data into analysis
• Identification of the safest evacuation routes combined with the use of multiple forms of communication to keep residents informed regarding timing and location of evacuated areas.
• Use of a tiered evacuation approach
o First, direct residents out of an immediate impact zone to an evacuation point, out of danger, where additional information is provided,
o Second, if the danger is prolonged, direct residents from the evacuation point to an evacuation center where water, food and power resources are available to charge mobile devices, and
o Third, if overnight or multi-day evacuation is necessary, direct residents to shelters in nearby communities.
Training
The City monitors training requirements and compliance and recently implemented a new sign-in process to improve tracking
Fire, OES, and Police all serve critical functions in emergency response with different training requirements depending on their roles and responsibilities.
In terms of wildfire response training, the Fire Department provides wildfire training through modules provided by Vector Solutions as part of an annual fire safety refresher course, RT-130 which is required per the National Wildfire Coordinating Group (NWCG) for designated positions for all personnel assigned with Fireline duties. The training is completed before the start of the Wildland season which typically runs from May to November but can vary from year to year. A new QR check-in system may have resulted in Item 2
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19 incomplete sign-ins and a battalion chief had not yet completed the training as of the writing of this report. There was a total of 77 employees signed up and as of August 29th, 2024, 71 had completed the required training. Out of the 6 who had not completed the training, five were due to workers’ comp or medical issues. Management was unable to provide an explanation of why the remaining employee’s training was not completed but noted that the individual received follow-up training to ensure understanding of training requirements and protocols. Management stated that a new check-in system is now in place and will help the City more easily track training compliance in the future.
The OES training primarily covers critical incident response, with minimal emphasis on wildfires. Finally, the Police Department does not have specific wildfire training. Instead, they focus on support roles during such incidents, including using police speakers for warnings, directing traffic, and ensuring clear roads.
After Action Reports (AAR)
According to The National Wildfire Coordinating Group (NWCG) AARs are essential for wildland firefighters to learn from mistakes and capitalize on successes. The objective of the AAR is to immediately identify these successes and failures. Once they have been recognized, further exploration allows the team to perfect its skills and be better prepared for future endeavors. NWCG is a partnership of federal, state, tribal, and local wildfire management agencies that work together to establish standardized practices for wildland fire operations in the United States, its primary goal is to enhance efficiency, safety, and effectiveness in wildland fire management and response. The NWCG develops training programs, operational guides, and policy frameworks to ensure consistent and coordinated wildfire management across jurisdictions. It also serves as a central resource for promoting best practices, improving interagency collaboration, and supporting the professional development of fire personnel.
While the City conducts training and AARs after critical incidents, efforts to track and implement resulting recommendations could be improved
All the departments come together to engage in tabletop exercises for training purposes. Departments also work together after critical emergency incidents to conduct AARs to report their successes and improvement opportunities. While some AAR recommendations have been implemented others have not and staff said they do not formally track and monitor the implementation of recommendations. Areas of improvement noted in training exercises and in AARs cover various areas such as communication, recovery and proper use of PPE.
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20 Training Exercises
2024 XSC Readiness Drill
A drill hosted by the County of Santa Clara to provide pre-incident training on bulldozer, hand crew, and helicopter operations during a wildfire. This event was attended by county-wide OES departments. Areas of improvement included:
• Creating clarity around the communications center and coordinating the process and flow of mutual aid initial attack orders.
Vulcan Forge Tabletop Exercise
The City of Palo Alto Vulcan Forge Tabletop Exercise was intended to discuss and validate existing procedures. The drill provided an opportunity for City staff to exercise their role and gain a greater understanding of the processes and procedures that will occur during wildfire response. Areas of improvement included:
• The WUI ConOps is lacking specific procedures to reach those with limited English proficiency or for people with disabilities, and others with access and functional needs (DAFN)
• Participants didn’t appear to know how best to alert residents who were experiencing power outages
• The WUI ConOps does not have a procedure for approving PIO to disseminate to the public
• Define terms such as “mass care” vs. “sheltering” to create clear understanding of evaluation points, centers, shelters, and the like • Establish evacuation center and sheltering operation criteria, P&P and train appropriate staff
• Current plans lack sufficient detail on recovery and relief efforts • OES needs to create P&P for re-entry and re-population
After Action Reports
PAFD AAR Dish Fire
A fire of unknown origin started near the Stanford Hiking Dish Trail and the PAFD responded to put out the fire. The fire was in an area of the dish hiking trail that’s nearest the intersection of lower Reservoir Road and the Stanford Hiking Dish Trail with the closest gate access being the Gerona Gate. Areas of improvement included:
• T here was a delay in dispatching mutual aid and additional hands-on training was requested
• Proper PPE must always be worn when responding
OCA’s analysis of training exercise notes and AARs found areas of improvement are often identified with suggestions for process improvements. The OCA recommends the City more formally track and Item 2
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21 5 https://www.cityofpaloalto.org/Departments/Emergency-Services/Emergency-Preparedness 6 https://www.cityofpaloalto.org/Departments/Fire/Prepare-For-Wildfire-READY-SET-GO
monitor these findings and recommendations to better determine if they should be implemented, what resources may be needed, and to establish an appropriate timeline for implementation.
The City is enhancing its wildfire detection capabilities through the use of gas monitoring sensors deployed in the Foothills area
Detection is crucial in wildfire emergencies because it enables early response, reducing the spread and potential damage of fires by allowing for quicker containment efforts. Early detection systems, such as remote sensors and aerial surveillance, are vital for protecting communities and natural resources, as they help agencies mitigate risks before fires escalate to dangerous levels.
The City recently set up N5 Sensors which are an advanced gas monitoring system designed to provide early alerts in the event of a wildfire. In a collaborative program, the City is partnering with Stanford and Woodside, with Stanford purchasing 25 N5 sensors and receiving an additional 25 at no cost. Of these, Palo Alto will receive 12 sensors, while Woodside will receive
13. Each city will cover its own data expenses, estimated at $22,000 per city for the first two years. Palo Alto received a grant from the Department of Homeland Security to assist with the expenses. The Fire Safe Council will handle the sensor installation and program management. Although N5 Sensors will not provide complete coverage across all areas, they are strategically positioned to enhance early warning capabilities in high-risk zones. Additionally, the City has explored the use of drones for monitoring, but concerns over privacy, public perception, and restrictive municipal codes have made their approval challenging.
Communication
The City employs several methods for communicating critical information to its residents during an emergency and should continue to explore methods to increase participation in the County’s emergency alerting system
The City has established multiple communication channels such as the City’s website, news releases, social media, and radio announcements to remind residents of wildfire season and keep them informed of the City’s events and emergency notifications. City web pages dedicated to general emergency preparedness
5 and wildfire prevention include CAL FIRE’s
Ready-Set-Go6 video, Palo Alto Wildfire Planning Map, evacuation information, a link to sign up for Santa Clara County’s alerting system, and other resources.
Palo Alto utilizes Everbridge, the mass notification system used throughout Santa Clara County to communicate with residents in emergency situations.
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22 Under California’s emergency management structure, each county operates as an "Operational Area," giving it independent authority and responsibility for issuing alerts and warnings within its jurisdiction. Santa Clara County has been using Everbridge for several years, with trained personnel across jurisdictions, including staff from Palo Alto’s OES and Police dispatch.
Everbridge is Palo Alto’s primary tool for sending mass alerts in wildfire situations. There are two main response scenarios: First, if a fire breaks out within Palo Alto’s jurisdiction, OES will issue an immediate alert after assessing the fire's location and direction. Second, if a fire starts outside the area but moves toward Palo Alto, they monitor and notify residents as needed. Residents can "opt in" to receive these alerts by registering at alertscc.org. Additionally, Everbridge includes an "all records" list, which contains duplicates, and includes data from their reverse 911, purchased cell phone records, white and yellow pages, and data from the prior system, Blackboard. However, this “all records” list contains duplicates making it difficult to determine the total number of residents signed up for the service.
For example, an individual might have their information listed in all records noted above and each record lists them as a separate contact.
Based on the alert system sign-up data provided by Santa Clara County, the percentage of Palo Alto residents signed up for alerts increased from 15% in 2023 and 2024 to 17% in 2025. Participation among other Santa Clara County cities in 2025 ranges from 7% to 29%. Some cities may have more or less of their population occupying WUI areas which may account for some of the differences in emergency alert adoption.
The OCA recommends the City continue to explore ways to increase resident participation in this program since it is the City’s primary communication tool for reaching residents in an emergency.
Resources
The City has seven fire stations. Six fire stations are staffed full-time and the seventh station provides seasonal coverage in the foothills region during high-fire danger months. This seventh station is staffed through an interlocal agreement with Losa Altos Hills and Santa Clara County which specifies a rotational schedule to ensure coverage.
Mutual aid agreements are essential in wildfire management, enabling communities to combine resources, expertise, and personnel across jurisdictions for a more effective and rapid response to large-scale fires.
Wildfires spread quickly and can overwhelm local resources, making support from neighboring cities, counties, and state agencies critical for containment and suppression. These agreements establish protocols for communication, resource sharing, and logistical coordination, which helps reduce response times and enhances overall operational efficiency. FEMA and CAL FIRE emphasize that such partnerships strengthen resilience by ensuring that participating agencies are prepared to respond cohesively to the complex challenges of wildfire emergencies.
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23 Recommendation
While the City has strong relationships with their mutual aid agreement partners, the City does not maintain these agreements in a central repository for easy tracking and monitoring
Palo Alto has 5 mutual aid agreements for wildfire response, though some require updates for ongoing effectiveness. The Station 8 agreement remains active, providing 24/7 monitoring during wildfire season, while the Mutual Threat Zone operating plan with CAL FIRE establishes guidelines for resource usage and remains in force until a 30-day termination notice is issued. Additionally, the agreement among Palo Alto, Santa Clara County, and Los Altos Hills ensures the availability of nearby resources for emergencies, continuing unless ended by a 30-day notice. The agreement with Woodside, which expired sometime in 2019 had no specified end date, according to the Deputy Fire Chief negotiations for a new contract are currently underway. The mutual aid agreement with Mountain View is also expired, though still honored by both cities. The OCA noted that these agreements are not kept in a central repository which may make it difficult to track and monitor the status of the agreements.
We recommend the City consider the following improvements to enhance its Wildfire response efforts:
1. The City’s emergency plans align with the majority of FEMA guidance; however, they would be strengthened by incorporating a more comprehensive revision history and an enhanced review process. The City should also review its evacuation plans and consider if plans could be enhanced by reviewing best practices in other cities such as establishing evacuation locations and sheltering agreements with neighboring communities.
2. City management should more formally track and monitor findings and recommendations identified during training exercises and in AARs of emergency incidents to ensure needed improvements are made and issues are timely resolved.
3. Continue to explore ways to increase resident registration in the County’s emergency alerting system. Opportunities may include partnering with schools, homeowner associations, and local businesses to disseminate wildfire education materials and encourage participation in City programs and the County’s emergency alert system.
4. Determine an appropriate solution for staff to more easily access, track and monitor the status of all mutual aid agreements, including active dates, renewal deadlines, and responsible contacts for updates. For example, a centralized tracking system for mutual aid agreements would provide clarity on the status of each agreement, preventing lapses in mutual aid coverage and ensuring that expired agreements are addressed promptly.
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24 7 CPAU contracts with a third-party vendor to conduct compliance inspections to ensure utility poles and equipment are well maintained. Visual inspections are conducted annually and a detailed inspection every five years. Every ten years, the vendor performs an “intrusive inspection” which can include drilling into the poles to determine their condition. Lines and poles are rated using a 3-point scale from P1 (most serious and needing immediate attention) to P3 (less urgent). Staff stated that poles rated with a P1 are remediated immediately, however, the OCA could not assess the timeliness of response based on the reports provided.
Management
Response
Please see appendix for responses.
Additional
Observation
The OCA noted that while the Utility has a regular Capital Improvement and electric Grid Modernization Project, it does not have a formal maintenance schedule that proactively anticipates and schedules maintenance as the infrastructure ages. Instead, maintenance issues are addressed on an as needed basis. Management stated that the Utility is currently behind schedule in addressing line and pole maintenance due to resource constraints but is on schedule to complete all Overhead and Underground facility inspections for 2024.
The OCA has performed a general assessment of CPAU’s line and pole maintenance program noting some areas for the City to consider. The OCA analyzed pole data from the Utility’s pole inspection report 7 and noted that
approximately half of the City’s poles are over 40 years old, with some poles dating back to the 1940’s. 545 of CPAU’s poles are 60 years old or older and may present age-related maintenance issues. It should be noted that many of these poles may be scheduled for replacement as part of the Grid Modernization project.
In addition to the Utility’s pole inspection report, the OCA asked for example inspection reports for individual pieces of equipment and poles. These reports are entered into the CPAU Electric Equipment & Maintenance Database. The audit team noted that for the example reports received, the previous inspection dates on the forms appeared to be more than 10 years ago. The OCA recommends the City consider implementing a formal infrastructure maintenance program as part of its Grid Modernization efforts to ensure ongoing timely inspection and maintenance in the future.
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25 Appendix A: Management Response Matrix
Finding 1: While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
1. Continue efforts to
underground WUI distribution
infrastructure and prioritize as
appropriate maintenance and
possible replacement of the
oldest poles should they remain
in place.
Agree Utilities Staff appreciates the CAO’s validation of this priority and agree that efforts should continue to underground and harden distribution infrastructure within the high fire danger area. The City’s Utilities Wildfire Mitigation Plan, updated and approved annually, prioritizes the undergrounding of the City’s overhead infrastructure in the high fire danger area on Arastradero Road. The first phase of the Foothill Fire Mitigation Project will move powerlines underground and remove approximately 182 of the total of 203 power poles and overhead powerlines in the high-risk area. The estimated 21 remaining poles and associated equipment require additional engineering and coordination prior to additional fire hardening measures.
The Foothill Fire Mitigation Project includes substructure construction, including the installation of boxes and pad-mounted equipment; Cable pulling and line energization; Decommissioning of overhead poles and equipment.
Q4 2025
2. Line Clearance policy
documents should be
established and or reviewed,
updated, and finalized (e.g.
Draft Tree and Landscape
Technical Manual)
Agree Public Works Staff is actively working to update the Draft Tree Landscape Technical Manual (TLTM), and the recent the public comment period on the proposed revisions closed March 2025. Comments are under review and a draft of the TLTM is scheduled for review with the Parks and Recreation Commission, with a final version expected this year. Staff agree and plan to establish a line clearing policy for trees and landscape (like the current line clearing policy for utilities operations).
Q4 2025
3. Continue efforts to better
track and monitor property
violations in the WUI to
enhance enforcement
Agree Fire The fire prevention bureau started utilizing Streamline software in 2024 and at the time of this report has now fully implemented this tool. This software, specifically designed for fire inspections, will improve inspection management, including tracking and monitoring of properties with violations that require re-inspections.
Q1 2025
4. Prioritize efforts to establish
a Firewise Community including
stakeholder engagement
throughout the process
Agree OES, Fire The Palo Alto Fire Department (PAFD) is working towards a long-term contract with the Fire Safe Council including cost estimates for roadside clearance and public education resources, i.e. Firewise Community.
PAFD is seeking partnership with Woodside Fire Protection District and Los Altos Hills Fire District to enhance our presence and efforts towards public education and will support residents in the pursuit of participation in the Firewise Communities program. Firewise is a grassroots program Q4 2025
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26 Finding 1: While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some areas for improvement including enhancing community outreach and engagement.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
that the impacted Community must initiate. As stated in the CWPP, staff will work with local Foothills community to attain and maintain Firewise USA recognition
5. Formalize the contract with
CAL FIRE to ensure service
provision continues into the
future.
Partially
Agree
Fire Staff agree that multiyear formal contracts would be a best practice and understand that operationally this may not be feasible since it would add administration obligations for an outside agency. The summer of 2025 will be the third year that CAL FIRE assists the City of Palo Alto with hazardous fuel removal. CAL FIRE provides similar services for multiple agencies in the county (San Jose, Morgan Hill) without a contract. Staff will seek this formalization to ensure stability and continuity, though it may be infeasible if CAL FIRE does not agree to a formal contract. CAL FIRE does not charge cities for the provision of these services.
Q4 2025
6. Ensure wildfire education
and outreach plans document
coordination efforts between
Office of Emergency Services
(OES), Fire and CPAU to
ensure information is
consistently and regularly
provided to residents.
Partially
Agree
OES, Fire,
Utilities, CMO
Staff partially agree as this work is already being coordinated among departments. Staff will look to update the City’s existing plans and hazard-specific annex documents ensuring communication of information is consistent and timely, reflecting the practices in place.
The existing EOP identifies communication protocols and responsibilities in the event of a disaster but could add details to formalize wildfire preparedness and outreach. The leadership team reviews all scheduled community events and engagement points on a monthly basis, including educational events for seasonal events such as floods and wildfires.
A unified wildfire preparedness effort among departments to build community awareness, offering tools and tips, and sharing online resources already includes the following: annual door hangers, utility bill inserts, general emergency services communications such as continued promotion of AlertSCC, the City’s emergency alert system, annual test of Alert SCC, and annual community presentations on wildfire preparedness all available on the ‘Ready, Set, Go!” web resource referenced in the report. Annually, OES and PAFD host public education forums for residents and businesses in the WUI.
Q2 2026
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27 Finding 2: Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning, training, after action report recommendation implementation, and communication efforts.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
1. The emergency plans align
with the majority of FEMA
guidance; however, they would
be strengthened by
incorporating a more
comprehensive revision history
and an enhanced review
process. The City should also
review its evacuation plans and
consider if plans could be
enhanced by reviewing best
practices in other cities such as
establishing evacuation
locations and sheltering
agreements with neighboring
communities.
Agree OES, Fire OES will institute management controls to ensure scheduled reviews of the City’s published emergency plans are timely completed with revision histories clearly documented, beginning with the current update of the EOP underway.
The City has evacuation maps available on the OES website and all public education materials and sessions advise residents of the location and content of the resources. PAFD and OES continue to utilize Genasys (formally Zonehaven) software that notifies residents in a particular zone of evacuation warnings and orders related to natural and human caused disasters: what is happening, where to evacuate, etc. which also includes pre-approved messaging in the platform.
Q4 2025
2. City management should
more formally track and monitor
findings and recommendations
identified during training
exercises and in emergency
incident AAR recommendations
to ensure needed
improvements are made and
issues are timely resolved
Agree OES Staff review AARs from training/tabletop exercises and real-world incidents, though the outcomes of these are tracked differently depending on the nature of the incident or training. For tabletop exercises, OES regularly conducts citywide AARs for training exercises and incidents. OES reviews and follows-up on necessary improvements identified in the AARs, however, to instill further rigor, OES will implement a post-AAR process review every six months until resolution of identified action items for final closure.
PAFD routinely conducts AARs following major incidents, which are then reviewed by executive command staff. Depending on any identified areas for improvement, such as further training or policy updates, the Deputy Chief over operations is responsible for ensuring completion of applicable follow-up steps including additional feedback to departments outside of the Fire Department.
Q3 2025
3. Continue to explore ways to
increase resident registration in
the County’s emergency
alerting system (AlertSCC).
Opportunities may include
Agree CMO, Utilities,
OES, Fire
The City uses many forms of communication to ensure community engagement, notification, and education activities and to increase AlertSCC sign ups. This is prominent on many pages of the City’s website, a recurring item in digital newsletters and printed outreach and always included in City emergency preparedness education programs Q1 2025
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28 Finding 2: Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning, training, after action report recommendation implementation, and communication efforts.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
partnering with schools,
homeowner associations, and
local businesses to disseminate
wildfire education materials and
encourage participation in City
programs and the County’s
emergency alert system.
regardless of the type of disaster being highlighted. It isa central message provided at community events through tabling. An annual AlertSCC test is scheduled citywide to encourage more registrations.
Staff agree that continuing to support participation in this program is important, and will continue to promote AlertSCC registrations in various City engagement efforts. Note that the City continues to be ahead when compared to the Countywide 10% opt-in level. Last year, as a result of communications efforts, over 7,000 City contacts opted into receive emergency alerts. Furthermore, staff agree and will continue to partner with schools, Palo Alto Neighborhoods, and local businesses to share educational materials.
4. Determine an appropriate
solution for staff to more easily
access, track and monitor the
status of all mutual aid
agreements, including active
dates, renewal deadlines, and
responsible contacts for
updates. For example, a
centralized tracking system for
mutual aid agreements would
provide clarity on the status of
each agreement, preventing
lapses in mutual aid coverage
and ensuring that expired
agreements are addressed
promptly.
Partially
Agree
OES, Fire The City’s EOP includes a section on mutual aid within the framework of the CA Master Mutual Aid Agreement. This includes a list of mutual aid response disciplines, coordinating agencies, and specific elements included, e.g. fire & rescue, search and rescue, emergency management, etc.
Although current mutual aid agreements for fire services are retained by the Fire Department in current operations, staff agree that a central repository of auto-aid agreements will be kept with emergency protocol documentation as an appendix/reference document, for broader and more ready accessibility in an emergency. A tracking system is not needed as all auto aid agreements within Santa Clara County agencies are current and have no expiration dates. Locally, the Santa Clara County XSC Mutual Aid Plan is reviewed and updated annually.
San Mateo County fire chiefs are looking at the details of the mutual aid agreements in the County to review operational impacts countywide. The auto aid agreements with Woodside Fire Protection District and Menlo Park Fire, both of which are in San Mateo County, do have end dates and are currently for freeway responses only.
Q3 2025
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City Council
Staff Report
Report Type: CONSENT CALENDAR
Lead Department: City Clerk
Meeting Date: November 3, 2025
Report #:2510-5326
TITLE
Approval of Minutes from October 15, October 20, and October 22, 2025 Meetings
RECOMMENDATION
Staff recommends that the City Council review and approve the minutes.
ATTACHMENTS
Attachment A: October 15, 2025 Draft Action Minutes
Attachment B: October 20, 2025 Draft Action Minutes
Attachment C: October 22, 2025 Draft Action Minutes
APPROVED BY:
Mahealani Ah Yun, City Clerk
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CITY COUNCIL
DRAFT ACTION MINUTES
Special Meeting
October 15, 2025
The City Council of the City of Palo Alto met on this date in the Council Chambers and by virtual teleconference at 4:30 P.M.
Present In Person: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker Veenker Arrived at 4:32 P.M.
Present Remotely:
Absent:
Agenda Changes, Additions and Deletions
Special Orders of the Day: Boards, Commissions, Committees Interviews
1. Interview Candidates for Vacancies on the Human Relations Commission (HRC), Parks and Recreation Commission (PRC), and Public Art Commission (PAC); CEQA Status - Not a Project
NO ACTION
Closed Session
2. CONFERENCE WITH CITY ATTORNEY-POTENTIAL LITIGATION
Subject: Potential litigation regarding 156 North California Avenue, as set forth in letter(s) from Holland & Knight LLP dated September 3, 2025 Authority: Government Code Section 54956.9(d)(2); One case, as Defendant.
MOTION: Councilmember Stone moved, seconded by Council member Lu to go into Closed Session.
MOTION PASSED: 7-0
Council went into Closed Session at 8:40 P.M.
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2025 Draft Action Minutes
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DRAFT ACTION MINUTES
Sp. City Council Meeting
Draft Action Minutes: 10/15/2025
Council returned from Closed Session at 9:24 P.M.
Mayor Lauing announced no reportable action.
Adjournment: The meeting was adjourned at 9:25 P.M.
ATTEST: APPROVED:
____________________ ____________________
City Clerk Mayor NOTE: Action minutes are prepared in accordance with Palo Alto Municipal Code (PAMC)
2.04.160(a) and (b). Summary minutes (sense) are prepared in accordance with PAMC Section
2.04.160(c). Beginning in January 2018, in accordance with Ordinance No. 5423, the City Council found action minutes and the video/audio recordings of Council proceedings to be the official records of both Council and committee proceedings. These recordings are available on the City’s website.
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CITY COUNCIL
DRAFT ACTION MINUTES
Regular Meeting
October 20, 2025
The City Council of the City of Palo Alto met on this date in the Council Chambers and by virtual teleconference at 5:30 P.M.
Present In Person: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker Veenker arrived at 5:32 P.M.
Present Remotely:
Absent:
Call to Order
Special Orders of the Day: Boards, Commissions, and Committees Interviews AA1. Interview Candidate for Vacancies on the Parks and Recreation Commission; CEQA Status - Not a Project
NO ACTION
Agenda Changes, Additions and Deletions
Public Comment
Council Member Questions, Comments and Announcements
Study Session
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DRAFT ACTION MINUTES
City Council Meeting
Draft Action Minutes: 10/20/2025
1. Cubberley Project: Receive an Update on Development of a Master Concept Plan and Phasing; Review and Provide Feedback on Themes for the Second Poll; Receive an Update on Strategic Activation Plan and Review an Update on the Workplan for the Cubberley Master Plan in Consideration of a November 2026 Ballot Measure; CEQA Status – the Master Plan will undergo CEQA review.
NO ACTION
Consent Calendar
MOTION: Vice Mayor Veen ker moved, seconded by Council member Reckdahl to approve Agenda Item Numbers 2-15, AA2.
MOTION PASSED: 7-0
2. Approval of Minutes from September 29 and October 6, 2025 Meetings
3. PUBLIC HEARING / QUASI -JUDICIAL. 70 Encina Avenue [25PLN -00034]: Request for Approval of a Tentative Map to Merge Two Lots and Allow for a Condominium Subdivision to Create 10 Units on the Resulting 12,119 -Square-Foot Parcel. The Subdivision Map Would Facilitate Construction of Ten New Residential Units in One Building, which was previously approved on April 14, 2025 (24PLN -00095). CEQA Status:
Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15183 (Comprehensive Plan Consistency).
Zoning District: PC-5654.
4. PUBLIC HEARING: Finance Committee Recommends Adoption of Resolution Amending Five Rate Schedules Setting Forth Utility Connection Fees and Other Charges: Utilities Rate Schedule E-15 (Electric Service Connections), W-5 (Water Service Connections), G-5 (Gas Service Connections), S- 5 (Sewer Service Connections) and C- 1 (Utility Miscellaneous Charges); CEQA Status: Not a Project Under CEQA Guidelines Sections 15378(b)(4) and (5) and Exempt Under Section 15273(a)
5. Approval of an Increase of Construction Contingency for Contract No. C24189237 with SAK Construction, LLC in the amount of $1,000,000, funded by the Wastewater Treatment Enterprise Fund for the Joint Intercepting Sewer Rehabilitation (Phase 1) Project (WQ- 24000), and Approval of Addendum 13 to the Basic Agreement Between Mountain View, Los Altos, and Palo Alto for the Acquisition, Construction, and Maintenance of a Joint Sewer System to Increase the Maximum Authorized Project Funding of $8.9 million to $12.6 million; CEQA Status – Exempt under CEQA Guidelines Section 15301 (Repairs to Existing Facilities)
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DRAFT ACTION MINUTES
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Draft Action Minutes: 10/20/2025
6. Approval of Contract Amendment No. 1 to Contract No. C23187298C with Hinderliter, de Llamas, and Associates (HdL) for Business Tax and Business Registry Certificate Fee Administration Services in the Amount of $750,000 for Additional Administrative and Operational Services and $2,120,000 Contingent Fees for a Revised Total Not -To-Exceed Amount of $2,870,000, to Extend the Term by Two Years to June 30, 2028, and Approve a Budget Amendment in the General Fund (Requires 2/3 vote); CEQA Status – Not a Project
7. Approve Contract Amendment No. 1 to Contract No. C25193598 with Fairbank, Maslin, Maullin, Metz, and Associates (FM3) in the Amount of $26,775 for one Additional Poll (Four Polls, Total) for the Potential November 2026 Ballot Measure for a Total Not to Exceed Amount of $153,000 and Approve Budget Amendments in the General Fund and the Cubberley Property Infrastructure Fund; CEQA Status: Not a Project
8. Approval of Five Items to Support the Fire Station 4 Replacement Project PE -18004: 1) Construction Contract Number No. C26194287 with Beals Martin and Associates, Inc. in an Amount Not to Exceed $11,530,676 and Authorization for the City Manager or Their Designee to Negotiate and Execute Change Orders to the Contract up to a Not- to- Exceed Amount $1,153,067; 2) Contract Amendment No. 1 to Contract No. S24188865 with Schaaf & Wheeler Consulting Civil Engineers to Extend the Contract Term Through April 30, 2027; 3) Contract Amendment No. 1 to Contract No. S23185811 with Earth Systems Pacific, Inc. to Extend the Contract Term Through February 28, 2027; 4) Amendment No. 1 to Contract C21179569 with Brown Reynolds Watford Architects, Inc. to Add $41,366, Increasing the Not -to-Exceed Amount to $838,514 and Extend the Contract Term Through June 30, 2027 for Construction Support Services; and (5) Amendment No. 1 to Contract C24189293A with Cumming Management Group, Inc. to Extend the Contract Term Through August 31, 2027; CEQA Status - Exempt under CEQA Guidelines Sections 15302 and 15303
9. Approval of Construction Contract C26195058 with JJR Construction, Inc. in an Amount Not to-Exceed $1,281,689 and Authorization for the City Manager or Their Designee to Negotiate and Execute Change Orders for Related Additional but Unforeseen Work that May Develop During the Project Up to a Not- to-Exceed Amount of $128,169 for the Fiscal Year 2026 Sidewalk, Curb & Gutter Project, Capital Improvement Program Projects PO-89003 and PO-12001; CEQA Status – Exempt under Section 15301(c)
10. Approval of a 10 Year License Agreement with La Comida de California for Operation of a Senior Nutrition Program and Meal Service in a Portion of the City -owned Building Located at 445 Bryant Street; CEQA Status – Exempt under CEQA Guidelines sections 15301 and 15303
11. Adoption of a Resolution to Extend the City’s Participation in the Northern California Power Agency’s Support Services Program for Another 10 Years to 2037, Designating Item 5
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2025 Draft Action Minutes
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Authorized Signatories, and Updating Contracting Authority to Align with the Municipal Code; CEQA Status – Not a Project
12. Approval of the Dispatch Center Assessment Report as Recommended by the Policy & Services Committee.
13. 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.
14. 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).
15. 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) AA2. Approval of Appointment and Employment Agreement with Stephen Lindsey as Fire Chief; CEQA Status – Not a Project New Item Added
City Manager Comments
Ed Shikada, City Manager
Action Items
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DRAFT ACTION MINUTES
City Council Meeting
Draft Action Minutes: 10/20/2025
16. 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.
MOTION: Mayor Lauing moved, seconded by Vice Mayor Veenker to approve the Policy and Services Committee recommendation to direct staff to:
Phase 1:
1. Develop an urgency ordinance to prohibit parking of detached/inoperable vehicles on public streets,
2. Develop an urgency 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,
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. Recruit new safe parking on privately -owned and congregation -based parking lots, excepting any safe parking site that requires undedicating parkland,
8. Create an Ad Hoc Committee to recommend details on the increased enforcement and other issues on implementation on items 1-7 above; evaluation of activities in Phase 2 and report back to C ouncil in 4-months, in furtherance of Council goals including public health and public safety,
9. Approve amendments to the Fiscal Year 2026 Budget Appropriation (requires a 2/3 vote) to resource aspects of the phased approach in the General Fund by:
a. Increasing the contractual services appropriation for the City Manager’s Office by $157,000 for resources to support program implementation; b. Decreasing the Reserve: Business Tax Revenue for Housing Affordability by $157,000;
c. Increasing the contractual services appropriation for the Office of Transportation by $150,000 for engineering services;
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DRAFT ACTION MINUTES
City Council Meeting
Draft Action Minutes: 10/20/2025
d. Increasing the contractual services appropriation in the Public Works Department by $60,000 for street clean-up services;
e. Increasing the contractual services appropriation in the Police Department by $95,000 for marking and enforcement of vehicles; Decreasing the Budget Stabilization Reserve by $305,000;
f. Refuse Fund by:
i. Increasing the contractual services appropriation by $245,000 for new permanent and temporary street cleaning signage; and
ii. Decreasing the Ending Fund Balance by $245,000.
MOTION PASSED: 7-0
Adjournment: The meeting was adjourned at 11:49 P.M.
ATTEST: APPROVED:
____________________ ____________________
City Clerk Mayor NOTE: Action minutes are prepared in accordance with Palo Alto Municipal Code (PAMC)
2.04.160(a) and (b). Summary minutes (sense) are prepared in accordance with PAMC Section
2.04.160(c). Beginning in January 2018, in accordance with Ordinance No. 5423, the City Council found action minutes and the video/audio recordings of Council proceedings to be the official records of both Council and committee proceedings. These recordings are available on the City’s website.
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2025 Draft Action Minutes
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CITY COUNCIL
DRAFT ACTION MINUTES
Special Meeting
October 22, 2025
The City Council of the City of Palo Alto met on this date in the Council Chambers and by virtual teleconference at 5:30 P.M.
Present In Person: Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker Present Remotely: Burt
Absent:
B
oards, Commissions, and Committees Appointments
1. Appointment of Candidates to the Human Relations Commission (HRC), Parks and Recreation Commission (PRC), and Public Art Commission (PAC); CEQA Status: Not a Project
Human Relations Commission
First Round Voting for T hree (3) Vacancies (Seats 2, 3, 7) on the H uman Relations C ommission ending on October 31, 2028
Allyson C. Rosen:
Bridget Algee: Burt, Lythcott-Haims (2)
Mare Lucas:
Michelle Kraus: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker (7) Raizel Rosenberg: Lauing, Lu, Stone (3)
Salwa Ansari: Burt, Lu, Lythcott-Haims, Reckdahl, Veenker (5) Sridhar Karnam: Lauing, Reckdahl, Stone, Veenker (4)
Sunny Dykwel:
None of the Above:
Candidate M ichelle Kr aus receiving seven votes i s a ppointed to the f ull-term expiring on October 31, 2028.
Candidate Salwa Ansari receiving five votes is appointed to the full-term expiring on October 31, 2028.
Candidate S ridhar Ka rnam receiving four votes is a ppointed to the full -term expiring on October 31, 2028.
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DRAFT ACTION MINUTES
Sp. City Council Meeting
Draft Action Minutes: 10/22/2025
Parks and Recreation Commission
First Round Voting for Three (3) Vacancies ( Seats 2, 3, 4) on the Parks and Recreation Commission ending October 31, 2028.
Bobi Adle: Burt, Reckdahl (2)
Brenton Hanlon:
Drew Pearson: [Application withdrawn by applicant]
Hurjane Vongsachang: [Application withdrawn by applicant] Marc Schoenen: Lu, Lythcott-Haims, Veenker (3)
Nellis L. Freeman, Jr.: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker (7) Roger V. Smith: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone (6) Vadim Axelrod: Lauing, Stone, Veenker (3)
None of the Above:
Candidate Nellis L. Freeman, Jr. receiving seven votes is appointed to the full-term expiring on October 31, 2028.
Candidate Roger V. Smith receiving six votes is appointed to the full term expiring on October 31, 2028.
No other candidate received the four votes necessary for appointment. A second round of voting is required.
Second Round Voting for One (1) vacancy on the Parks and Recreation Commission ending October 31, 2028
Marc Schoenen: Burt, Lu, Lythcott-Haims (3)
Vadim Axelrod: Lauing, Reckdahl, Stone, Veenker (4)
None of the Above:
Candidate Vadim Axelrod receiving four votes is appointed to the full term expiring on October 31, 2028.
Public Art Commission
First Round Voting for Three (3) Vacancies ( Seats 1, 4, 7) on the Public Art Commission ending October 31, 2028.
Anjana Joshi: Burt, Lauing, Stone (3)
Claude Ezran: Reckdahl (1)
Donny Foley:
Eedit Bareket:
Marilyn Gottlieb Roberts: Lu, Lythcott-Haims, Veenker (3) Robin Mullery: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker (7) Item 5
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Simon Tran: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker (7) None of the Above:
Candidate Robin Mullery receiving seven votes is appointed to the full -term expiring on October 31, 2028.
Candidate Simon Tran receiving seven votes is appointed to the full -term expiring on October 31, 2028.
No other candidate received the four votes necessary for appointment. A second round of voting is required.
Second Round Voting for One (1) Vacancy on the Public Art Commission ending on October 31, 2028.
Anjana Joshi: Burt, Lauing, Reckdahl, Stone, Veenker (5) Marilyn Gottlieb Roberts: Lu, Lythcott-Haims (2)
None of the Above:
Candidate Anjana Joshi receiving five votes is appointed to the full -term expiring on October 31, 2028.
Agenda Changes, Additions and Deletions
Public Comment
Council Member Questions, Comments and Announcements
Study Session
2. City Council Feedback on an Updated Housing Project Design Concept and Other Project Updates Related to the City and Alta Housing Partnership to Develop the Downtown Surface Parking lot at the Corner of Kipling Street and Lytton Avenue (Lot T) for Affordable Housing. CEQA Status – Not a Project.
Item Heard Out Of Order After Item #3
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Sp. City Council Meeting
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NO ACTION
3. Reinforcing Best Practices in Managing Consultant Services Item Heard Out Of Order Before Item #2
NO ACTION
Action Items
4. Update and Direction to Staff on the Downtown Housing Plan Project and Implementation of Senate Bill 79 (2025 -2026). CEQA Status: Exempt Under CEQA Guidelines Section 15262.
NO ACTION
Adjournment: The meeting was adjourned at 8:38 P.M.
ATTEST: APPROVED:
____________________ ____________________
City Clerk Mayor NOTE: Action minutes are prepared in accordance with Palo Alto Municipal Code (PAMC)
2.04.160(a) and (b). Summary minutes (sense) are prepared in accordance with PAMC Section
2.04.160(c). Beginning in January 2018, in accordance with Ordinance No. 5423, the City Council found action minutes and the video/audio recordings of Council proceedings to be the official records of both Council and committee proceedings. These recordings are available on the City’s website.
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Fire
Meeting Date: November 3, 2025
Report #:2509-5206
TITLE
FIRST READING: Adoption of an Ordinance Repealing Chapter 15.04 of the Palo Alto Municipal Code and Adopting a New Chapter 15.04, the California Fire Code (2025 Edition) With Local Amendments and Related Findings. CEQA Status: Exempt Pursuant to Section 15061 of the CEQA Guidelines.
RECOMMENDATION
Staff recommends that the City Council adopt the attached ordinance that repeals Chapter
15.04 of the Palo Alto Municipal Code (PAMC) and adopts a new PAMC Chapter 15.04 adopting the California Fire Code (2025 Edition) with local amendments.
BACKGROUND
Every three years, California updates its Building Standards Code, known as Title 24, to incorporate the latest technology, best practices, and policy goals for safe, efficient, and sustainable buildings. Jurisdictions may adopt the model code as-is or adopt local amendments that are more stringent than the model code adopted by the state. State law imposes certain requirements when jurisdictions adopt local amendments to any of these 13 parts, including that the jurisdiction make express findings that each amendment is reasonably necessary because of local climatic, geological, topographic or environmental conditions.
If no local amendments are adopted before the beginning of the new code cycle, in this case January 1, 2026, then the model code adopted by the state automatically applies. If prior local amendments are not readopted before the new code cycle begins, they expire and can no longer be applied or enforced at the local level.
The California Building Standards Code is organized into 13 parts, as shown below. Note that there are both Parts 2 and 2.5, creating a total 13 parts. Part 7, the Wildlands-Urban Interface (WUI) Code is a new addition this cycle. It replaces Chapter 49 of the California Fire Code. ·Part 1: CA Administrative Code
·Part 2: CA Building Code
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·Part 2.5: CA Residential Code
·Part 3: CA Electrical Code
·Part 4: CA Mechanical Code
·Part 5: CA Plumbing Code
·Part 6: CA Energy Code
·Part 7: CA Wildlands-Urban Interface Code
·Part 8: CA State Historical Building Code
·Part 9: CA Fire Code
·Part 10: CA Existing Building Code
·Part 11: CA Green Building Standards Code
·Part 12: CA Reference Code Standards
On October 6, 2025 the City Council approved ordinances adopting the 2025 editions of the other parts of the California Building Standards Code and directed staff to return on the Consent Calendar with ordinances adopting the 2025 editions of the California Fire Code and California WUI Code with local amendments.1 On further review, staff determined that no local amendments to the WUI Code are necessary, and proposes to allow Part 7 of the CBSC to take effect without amendment.
ANALYSIS
Staff recommend that the Council adopt the attached ordinance adopting the 2025 Edition of the California Fire Code with local amendments. The proposed ordinance re-adopts local amendments adopted in previous code cycles with some clarifying language and formatting. It also removes prior local amendments that have been incorporated into the updated 2025 State Code or incorporated into the new Part 7 (Wildland-Urban Interface Code).
This ordinance also adopts new local amendments, most of which are administrative and similar to amendments or practices currently in place. Most of the new local amendments are derived from the collaborative efforts of the Santa Clara County Fire Marshals’ Association.
Several sections of the California Fire Code (CFC) related to definitions, fire sprinkler specifications and hazardous materials are amended to allow the Fire Department greater flexibility and application of life safety and property conservation controls.
Specifically, this ordinance adopts new local amendments that: 1) define triggers for automatic sprinkler systems and more intense fire sprinkler design for different types of new and existing nonresidential buildings; 2) specify exhaust requirements for nonresidential parking garages; 3) define maximum allowable quantities of Energy Storage Systems in fire areas; and 4) add 1 October 6, 2025 staff report:
https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=2a2b3 4e2-2c23-4b9f-ab42-c67dd1176b35.
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Business Occupancies to the list of occupancies where the use of portable unvented heaters is prohibited.
FISCAL/RESOURCE IMPACT
No additional staff, consulting or budgetary resources are required to adopt and enforce the recommended ordinances adopting and amending the California Building Standards Code at this time. Staff contemplated, requested and secured the resources needed to complete this triennial process in the FY25 and FY26 city budgets.
STAKEHOLDER ENGAGEMENT
Staff hosted a community engagement meeting as part of the Building Standards Code update process for the 2026-2028 Cycle. This was a focus group with 10 local design professionals held on August 12, 2025 that covered all Title 24 updates.
The engagement opportunity was listed on the City website. Staff sent a targeted email notice to approximately 50 design professionals and community members to increase awareness for the event and promote attendance.
ENVIRONMENTAL REVIEW
The recommended action in this report is exempt from the California Environmental Quality Act (CEQA) under section 15061(b)(3) on the grounds that the proposed standards are more stringent than the State standards, there are no reasonably foreseeable adverse environmental impacts and there is no possibility that the activity in question may have a significant adverse effect on the environment.
ATTACHMENTS
Attachment A: Ordinance repealing PAMC Chapter 15.04 and adopting a new Chapter 15.04, incorporating California Fire Code (2025 Edition) and local amendments and related findings APPROVED BY:
Stephen Lindsey, Fire Chief
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NOT YET APPROVED
1 20251017_ms29
Ordinance No. ____
Adoption of an Ordinance Repealing Chapter 15.04 of the Palo Alto Municipal Code and Adopting a New Chapter 15.04, the California Fire Code (2025 Edition) With Local Amendments and Related Findings
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Title 15 of the Palo Alto Municipal Code is hereby amended by repealing in its entirety Chapter 15.04 and enacting a new Chapter 15.04 to read as follows:
CHAPTER 15.04
CALIFORNIA FIRE CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 9
Sections
15.04.010 2025 California Fire Code, Title 24, Part 9 adopted and amended.
15.04.020 Local Amendments.
15.04.030 Section 102.5 Application of residential code.
15.04.040 Section 103.2 Appointment.
15.04.050 Sections 105.3.9 Permits/Permit fees.
15.04.060 Table 105.5.9 Permit amounts for compressed gases.
15.04.070 Table 105.5.22 Permit amounts for hazardous materials.
15.04.080 Section 105.5.25 and Sections 105.5.55 through 105.5.59 Operational permits.
15.04.090 Section 105.6.13 Hazardous materials and Section 105.6.26 Construction permits.
15.04.100 Reserved
15.04.110 Section 108.7 Certified Unified Program Agency Fees.
15.04.120 Section 109.1 Inspection authority.
15.04.130 Section 104.1.1 Enforcement/citation authority.
15.04.140 Section 113.4 Violation penalties.
15.04.150 Definitions Section 202
15.04.160 Section 316.7 Roof guiderails at interior courts.
15.04.170 320.3.13 Safety certification.
15.04.180 Section 322.6 Fire protection system.
15.04.190 Section 401.5 Making false report.
15.04.200 Section 503.1 Fire access roadways.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
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2 20251017_ms29
15.04.210 Section 503.2.1 Dimensions.
15.04.220 Section 503.2.2 Authority.
15.04.230 Section 504.5 Access control devices.
15.04.240 Section 505.1.1 and 505.1.2 Premises identification.
15.04.250 Section 509.1.2 Fire protection equipment identification.
15.04.260 Sections 603.10 through 603.12.
15.04.270 Section 4103.1.2.1.1 Prohibitive locations.
15.04.280 Section 903.2 Automatic sprinkler systems, where required.
15.04.290 Section 903.3.1.1 NFPA 13 sprinkler systems.
15.04.295 Section 903.3.1.1.5 Increase in fire sprinkler design criteria.
15.04.300 Section 903.3.1.2 NFPA 13R sprinkler systems.
15.04.310 Section 903.3.1.3 and 903.3.1.3.1 NFPA 13D sprinkler systems.
15.04.320 Section 903.3.10 Floor control valves.
15.04.330 Section 905.3.1 Height.
15.04.340 Section 909.20.7 Maintenance and operational schedule.
15.04.350 Section 1008.3 Illumination required by an emergency electrical system.
15.04.360 Section 1031.2 Where required.
15.04.370 Section 1207.1.5 Large-scale fire test.
15.04.375 Section 1207.5.2 Maximum allowable quantities.
15.04.380 Section 1207.11.3 Location.
15.04.390 Section 3303.7 Fire walls.
15.04.400 Section 3307.1.2 and 3307.1.4.
15.04.410 Reserved.
15.04.420 Reserved.
15.04.430 Reserved.
15.04.435 Section 4103.1 Portable unvented heaters.
15.04.440 Section 5001.2.2.2 Health Hazards.
15.04.450 Section 5001.7 Hazard materials management plan electronic submissions.
15.04.460 Section 5003.1.3.1 Toxic, highly toxic, moderately toxic gases and similarly used or handled materials.
15.04.470 Section 5003.1.5 Other health hazards including carcinogens, irritants and sensitizers.
15.04.480 Section 5003.1.6 Additional secondary containment requirements.
15.04.490 Section 5003.2.2.1 Design and construction.
15.04.500 Section 5003.2.2.2 Additional regulations for supply piping for health hazard materials.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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15.04.510 Section 5003.3.1 Unauthorized discharges.
15.04.520 Section 5003.5.2 Ventilation ducting.
15.04.530 Section 5003.5.3 “H” Occupancies.
15.04.540 Section 5003.9.11 Fire extinguishing systems for workstations dispensing, handling or using hazardous materials.
15.04.550 Section 5003.10.4 Elevators utilized to transport hazardous materials.
15.04.560 Section 5004.2.1 Spill control for hazardous material liquids.
15.04.570 Sections 5004.2.2 and 5004.2.2.2 and Table 5004.2.2 Secondary containment for hazardous material liquids and solids.
15.04.580 Section 5004.2.3 Containment pallets.
15.04.590 Section 5704.2.7.5.8 Overfill prevention.
15.04.600 Section 5704.2.7.5.9 Automatic and/or remote filling of tanks.
15.04.610 Reserved.
15.04.620 Section 6001.1 Site scope.
15.04.630 Section 6002.1 Definitions.
15.04.640 Section 6004.1 Highly toxic, moderately toxic, and toxic compressed gases.
15.04.650 Sections 6004.2 and 6004.2.1 Indoor storage and use.
15.04.660 Section 6004.2.1.1 and Table 6004.2.1.1 Quantities.
15.04.670 Section 6004.4 through 6004.4.8.2 General indoor requirements.
15.04.010 2025 California Fire Code, Title 24, Part 9 adopted and amended.
The California Fire Code, 2025 Edition, as adopted by the California Code of Regulations Title 24, Part 9, and Appendices B, C, D, E, F, G, H, and K is adopted as herein amended. One copy of the California Fire Code is on file and open to public inspection in the Office of the City Clerk.
Additional copies of the secondary codes set forth within the California Fire Code, and the amendments set forth in this chapter, are on file and open to public inspection in the fire department administrative office.
Whenever the phrase “California Fire Code” appears in this code or in any ordinance of the city, such phrase shall be deemed and construed to refer to and apply to the “California Fire Code, 2025 Edition” as adopted by the California Code of Regulations Title 24, Part 9 and as adopted and amended by this chapter.
15.04.020 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of the California Fire 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 15.04, ellipses shall indicate text of the California Fire Code, 2025 Edition, that has been Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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adopted without amendment but is omitted for brevity.
15.04.030 Section 102.5 amended - Application of residential code.
Section 102.5 of the California Fire Code is amended to read as follows:
102.5 Application of residential code. Where structures are designed and constructed in accordance with the California Residential Code, the provisions of this code shall apply as follows:
1. Construction and design provisions:
a. Provisions of this code pertaining to the exterior of the structure shall apply , including, but not limited to, premises identification, fire apparatus access, and water supplies.
b. Provisions of this code pertaining to the interior of the structure shall apply when specifically required by this code including, but not limited to, Sections 903.2 through 903.3.7 and Section 907.2.10.
c. Where interior or exterior systems or device s are installed, construction permits required by Section 105.6 of this code shall also apply.
2. Administrative, operational, and maintenance provisions: all such provisions of this code shall apply.
15.04.040 Section 103.2 Appointment deleted.
Section 103.2 of the California Fire Code is deleted.
15.04.050 Sections 105.3.9 Permits/Permit fees.
Section 105.3.9 is added to the California Fire Code to read as follows:
105.3.9 Permits/Permit fees. All permit fees shall be established by the City Council as set forth in the municipal fee schedule.
15.04.060 Table 105.5.9 Permit amounts for compressed gases.
Table 105.5.9 of the California Fire Code is amended to read as follows:
TABLE 105.5.9
PERMIT AMOUNTS FOR COMPRESSED GASES1
TYPE OF GAS 2 AMOUNT (cubic feet) X 0.0283 for m3
Carbon dioxide used in carbon dioxide enrichment systems 875(100 lbs) Flammable (except cryogenic and liquefied petroleum gases) 200 Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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Highly toxic Any amount
Inert and simple asphyxiant 6,000
Irritant 200
Moderately toxic 20
Other health hazards 650
Oxidizing (including oxygen) 504
Pyrophoric Any amount
Radioactive Any amount
Sensitizer 200
Toxic Any Amount
Unstable (reactive) Any amount
For SI: 1 cubic foot = 0.0283m3.
1 Refer to Chapters 27, 30, 32, 35, 37, 40 and 41 for additional requirements and exceptions.
2 Cubic feet measured at normal Temperature and pressure.
15.04.070 Table 105.5.22 Permit amounts for hazardous materials.
Table 105.5.22 of the California Fire Code is amended to read as follows:
TABLE 105.5.22
PERMIT AMOUNTS FOR HAZARDOUS MATERIALS
TYPE OF MATERIAL AMOUNT
Carcinogens 10 pounds
Combustible liquids See Section 105.5.16
Corrosive materials:
Gases
Liquids
Solids
See Section 105.5.8
55 gallons
500 pounds
Cryogens See Section 105.5.11
Explosive materials See Section 105.5.14
Flammable materials:
Gases
Liquids
Solids
See Section 105.5.8
See Section 105.5.16
10 pounds
Highly toxic materials:
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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Gases
Liquids
Solids
Any amount
Any amount
Any amount
Moderately toxic gas 20 cubic feet
Organic peroxides:
Liquids: Class I-IV
Liquids: Class V
Solids: Class I-IV
Solids: Class V
Any Amount
No Permit Required
Any Amount
No Permit Required
Oxidizing materials:
Gases
Liquids
Solids:
504 Cubic Feet
Any amount
Any amount
Other health
Hazards:
Liquids
55 gallons
500 pounds
Pyrophoric materials:
Gases
Liquids
Solids
Any amount
Any amount
Any amount
Toxic materials:
Gases
Liquids
Solids
Any amount
Any amount
Any amount
Unstable (reactive) materials:
Gases
Liquids
Solids
Any amount
Any amount
Any amount
Water reactive materials:
Liquids
Solids
Any amount
Any amount
For SI: 1 gallon = 3.785 L, 1 pound = 0.454kg.
a. 22 gallons when Table 5003.1.1(1) Note k applies and hazard identification signs in accordance with Section 5003.5 are provided for quantities of 22 gallons or less. b. 220 pounds when Table 5003.1.1(1) Note k applies and hazard identification signs in accordance with Section 5003.5 are provided for quantities of 220 pounds or less.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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15.04.080 Section 105.5.25 and Sections 105.5.55 through 105.5.59 Operational permits.
Section 105.5.25 of the California Fire Code is amended and Sections 105.5. 60 through 105.64 are added to read as follows:
[. . .]
105.5.25 Hot work operations. An operational permit is required for hot work including, but not limited to:
1. Public exhibitions and demonstrations where hot work is conducted.
2. Use of portable hot work equipment inside a structure.
Exception: (deleted)
3. Fixed-site hot work equipment, such as welding booths.
4. Hot work conducted within a wildfire risk area.
5. Application of roof coverings with the use of an open-flame device.
6. Where approved, the fire code official shall issue a permit to carry out a hot work program. This program allows approved personnel to regulate their facility’s hot work operations. The approved personnel shall be trained in the fire safety aspects denoted in this chapter and shall be responsible for issuing permits requiring compliance with the requirements found in Chapter 35. These permits shall be issued only to their employees or hot work operations under their supervision.
[. . .]
105.5.60 Liquid gas fueled equipment. An operational permit is required for liquid gas fueled equipment.
105.5.61 Battery operated equipment. An operational permit is required for commercial/industrial/research battery operated equipment. 105.5.62 Underground storage tank. An operational permit is required for Underground Storage Tanks.
105.5.63 Radioactive materials. An operational permit is required to store, use or handle any radioactive material or source.
105.5.64 Day care permit. An operational permit is required to operate a day care facility for more than six children or adults.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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15.04.090 Section 105.6.13 Hazardous materials and Section 105.6.26 Construction permits.
Section 105.6.13 of the California Fire Code is amended, and 105.6.26 of the California Fire Code is added to read as follows:
[. . .]
105.6.13 Hazardous Materials. A construction permit is required to install, repair damage to, abandon, remove, place temporarily out of service, or close or substantially modify a storage facility or other area regulated by Chapter 50 where the hazardous materials in use and when equipment is modified or installed that uses, stores, processes, or conveys hazardous materials.
Exceptions:
1. deleted
2. For repair work performed on an emergency basis, application for permit shall be made within two working days of commencement work.
[. . .]
105.6.26 Underground fire service lines: installation or modification.
A construction permit is required for the installation, modification or removal from service of underground fire service lines.
15.04.100 Reserved
15.04.110 Section 108.7 Certified Unified Program Agency Fees.
Section 107.7 is added to the California Fire Code to read as follows:
107.7 Certified Unified Program Agency (CUPA) Fees . Pursuant to the Participating Agency Agreement between the County of Santa Clara and the City of Palo Alto dated July 1, 1997, or as amended, the Fire Department is authorized to collect fees associated with the CUPA programs. The CUPA fees will be collected on an annual basis or as specified in the Palo Alto Municipal Fee Schedule.
15.04.120 Section 109.1 Inspection authority.
Section 108.1 of the California Fire Code is amended to read as follows:
109.1 Inspection authority. The fire code official is authorized to inspect, as often as necessary, buildings and premises, including such other hazards or appliances designated by the fire code official for the purposes of ascertaining and causing to be corrected any Item 6
Attachment A - Ordinance
repealing PAMC Chapter
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Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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conditions which would reasonably tend to cause fire or contribute to its spread, result in an unauthorized discharge of hazardous materials, or amount to any violation of this code or any other law or standard affecting fire and life safety.
15.04.130 Section 104.1.1 Enforcement/citation authority.
Section 104.1.1 is added to the California Fire Code to read as follows:
104.1.1 Penal code citation 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 the California Fire Code. The designated employee positions are: Fire Chief, Deputy Fire Chief, Fire Marshal, Assistant Fire Marshal, Fire Inspector, Hazardous Materials Specialist and Hazardous Materials Inspector.
15.04.140 Section 113.4 Violation penalties.
Section 112.4 of the California Fire Code is amended to read as follows:
113.4 Violation penalties. It is unlawful for any person to violate any provision or to fail to comply with any of the requirements of this Title 15 or any permits, conditions, or variances granted under this Title, and 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 Fire Chief or his/her designee determines that a violation of this Chapter has occurred, the Fire Chief or his/her designee may record a notice of pendency of code violation with the Office of the County Recorder stating the address and owner of t he property involved. When the violation has been corrected, the Fire Chief or his/her designee shall issue and record a release of the notice of pendency of code violation.
[. . .]
15.04.150 Definitions Section 202
Except as noted herein, Section 202 is adopted in full. The following definitions are amended or added to Section 202 of the California Fire Code to read as follows:
CORROSIVE LIQUID. Corrosive liquid is:
1) any liquid which, when in contact with living tissue, will cause destruction or Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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irreversible alteration of such tissue by chemical action; or 2) any liquid having a pH of 2 or less or 12.5 or more; or 3) any liquid classified as corrosive by the U.S. Department of Transportation; or 4) any material exhibiting the characteristics of corrosivity in accordance with Title 22, California Code of Regulations §66261.22.
EMERGENCY POWER OFF (EPO). A manually operated device that disconnects electrical services to the building or specific equipment.
FALSE ALARM. The willful, knowing, or negligent initiation or transmission of a signal, message, or other notification of an event of fire when no such danger exists.
LARGE-SCALE FIRE TESTING. Testing a representative energy storage system that induces a significant fire into the device under test and evaluates whether the fire will spread to adjacent energy storage system units, surrounding equipment, or through an adjacent fire-resistance-rated barrier.
MAXIMUM THRESHOLD QUANTITY (MAX TQ). Maximum threshold quantity is the maximum quantity of a moderately toxic or toxic gas, which may be stored in a single vessel before a more stringent category of regulation is applied. The following equation shall be used to calculate the Max TQ:
Max TQ (pounds) = LC50 (ppm) x 2 lb.
MODERATELY TOXIC GAS. A moderately toxic gas is a chemical or substance that has a median lethal concentration (LC50) in air more than 2000 parts per million but not more than 7500 parts per million by volume of gas or vapor, when administered by continuous inhalation for an hour, or less if death occurs within one hour, to albino rats weighing between 200 and 300 grams each.
HEALTH HAZARD -OTHER. A hazardous material which affects target organs of the body, including but not limited to, those materials which produce liver damage, kidney damage, damage to the nervous system, act on the blood to decrease hemoglobin function, deprive the body tissue of oxygen or affect reproductive capabilities, including mutations (chromosomal damage), sensitizers or teratogens (effect on fetuses).
SECONDARY CONTAINMENT. Secondary containment is that level of containment that is external to and separate from primary containment and is capable of safely and securely containing the material, without discharge, for a period of time reasonably necessary to ensure detection and remedy of the primary containment failure.
SPILL CONTROL. Spill control is that level of containment that is external to and separate from the primary containment and is capable of safely and securely containing the contents of the largest container and prevents the materials from spreading to other parts of the room.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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WORKSTATION. A workstation is a defined space or independent principal piece of equipment using hazardous materials with a hazard rating of 1.
15.04.160 Section 316.7 Roof guiderails at interior courts.
Section 316.7 of the California Fire Code is added to read as follows:
316.7 Roof guardrails at interior courts. Roof openings into interior courts that are bounded on all sides by building walls shall be protected with guardrails. The top of the guardrail shall not be less than 42 inches in height above the adjacent roof surface that can be walked on. Intermediate r ails shall be designed and spaced such that a 12 -inch diameter sphere cannot pass through.
15.04.170 320.3.13 Safety certification.
Section 320.3.13 of the California Fire Code is added to read as follows:
320.3.13 Safety certification. The equipment, process, training procedures and occupancy associated with industrial additive manufacturing may be required by the fire code official to receive a safety certification from Underwriter's Laboratory or equivalent.
15.04.180 Section 322.6 Fire protection system.
Section 322.6 of the California Fire Code is added to read as follows:
322.6 Fire protection system. The storage and/or charging of power micromobility devices shall be protected with a NFPA 13 fire sprinkler system. The system shall be designed to Ordinary Hazard II.
Exception: Micromobility powered devices in residential units.
15.04.190 Section 401.5 Making false report.
Section 401.5 of the California Fire Code is amended to read as follows:
401.5 Making false report. A person shall not, knowingly or unknowingly, give, signal, or transmit a false alarm. Initiation or transmission in a twelve -month period of three or more signals, messages, or other notifications of an event of fire when no such danger exists shall be presumed negligent.
15.04.200 Section 503.1 Fire access roadways.
Section 503.1 of the California Fire Code is amended to read as follows:
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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503.1 Fire access roadways. Where required, fire apparatus access roads shall be provided and maintained in accordance with Sections 503.1.1 through 503.1.3 and as per Fire Department Access Road Standards.
[. . .]
15.04.210 Section 503.2.1 Dimensions.
Section 503.2.1 of the California Fire Code is amended to read as follows:
503.2.1 Dimensions. Fire apparatus access roads shall have an unobstructed width of not less than 20 feet (6096 mm) exclusive of shoulders, or as required by Appendix D, except for approved security gates in accordance with Section 503.6 , and an unobstructed vertical clearance of 13 feet 6 inches (4115 mm).
15.04.220 Section 503.2.2 Authority.
Section 503.2.2 of the California Fire Code is amended to read as follows:
503.2.2 Authority. The fire code official shall have the authority to require or permit modifications to the required access widths and/or vertical clearance where they are inadequate for fire or rescue operations or where necessary to meet the public safety objectives of the jurisdiction.
15.04.230 Section 504.5 Access control devices.
Section 504.5 of the California Fire Code is amended to read as follows:
504.5 Access control devices. When access control devices including bars, grates, gates, electric or magnetic locks or similar devices, which would inhibit rapid fire department emergency access to within and throughout the building, are installed, such devices shall be approved by the fire code official. All electrically powered access control devices shall be provided with an approved means for deactivation or unlocking from a single location or otherwise approved by the fire code official or his/her designee. Access control devices must also comply with Chapter 10.
15.04.240 Section 505.1.1 and 505.1.2 Premises identification.
Sections 505.1.1 and 505.1.2 of the California Fire Code are added to read as follows:
505.1.1 Address illumination. Address identification required by Section 505.1 shall be illuminated.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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505.1.2 Address identification size. Address numbers and letters required by Section 505.1 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.
15.04.250 Section 509.1.2 Fire protection equipment identification.
Section 509.1.2 of the California Fire Code is added to read as follows:
509.1.2 Fire Protection equipment identification. Exterior fire control valves, standpipes, hose valves, fire department connection, post indicators, fire service backflow preventers and other fire department appurtenances are to be painted red for identification.
15.04.260 Sections 603.10 through 603.12.
Section 603.10 through 603.12 is added to the California Fire Code to read as follows:
603.10 Immersion heaters. All electrical immersion heaters used in dip tanks, sinks, vats and similar operations shall be provided with approved over - temperature controls and low liquid level electrical disconnects. Manual reset of required protection devices shall be provided.
603.11 Electric vehicle service equipment – car chargers. Electric vehicle service equipment shall be equipped with collision protection and an emergency power off (EPO) switch as determined necessary by the Fire Code Official. 603.12 Enclosed parking manual exhaust system. Enclosed parking garages associated with non-residential buildings shall install a Knox remote power box to manually activate the mechanical ventilation system to 100% capacity.
15.04.270 Section 4103.1.2.1.1 Prohibitive locations.
Section 4103.1.2.1.1 of the California Fire Code is amended to read as follows:
4103.1.2.1.1 Prohibitive Locations. The storage or use of portable outdoor gas- fired heating appliances is prohibited in any of the following locations:
1. Inside of any occupancy where connected to the fuel gas container.
2. Inside of tents, canopies and membrane structures.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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3. On exterior balconies and rooftops.
Exception: intentionally deleted
15.04.280 Section 903.2 Automatic sprinkler systems, where required.
Section 903.2 of the California Fire Code is amended to read as follows:
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 interior 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 3,600 square feet or w hen the addition is equal 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 that are expanded by more than 50 %. 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 creates a more hazardous fire/life safety condition, as determined by the Fire Chief.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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6. All new covered trash enclosures regardless of size require installation of fire sprinklers (nonresidential only).
Exception: A fire extinguishing system will not be required when all of the following conditions are met:
a. The trash enclosure, including the door(s) and roof are constructed of noncombustible materials.
b. The trash enclosure is 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 commercial building equipped with a fire sprinkler system.
8. Fume hoods when installed in a commercial building equipped with a fire sprinkler system.
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 wit h 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.
[. . .]
15.04.290 Section 903.3.1.1 NFPA 13 sprinkler systems.
Section 903.3.1.1 of the California Fire Code is amended to read as follows:
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.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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15.04.295 903.3.1.1.5 Increase in fire sprinkler design criteria.
Section 903.3.1.1.5 has been added to the California Fire Code to read as follows:
903.3.1.1.5 Increase in fire sprinkler design criteria.
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 shall be hydraulically designed to a 1500 square foot most remote area or as required by the fire code official.
4. Laboratory areas within buildings shall be hydraulically designed to Ordinary Hazard II density.
5. Parking areas where mechanical vehicle storage equipment is used the fire sprinkler system 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 electrical vehicle chargers, the fire sprinkler system shall be designed to Extra Hazard II density.
8. In new commercial buildings that will have power micromobility devices, the fire
sprinkler system shall be designed to Ordinary Hazard II.
9. ESS in commercial 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.
[. . .]
15.04.300 Section 903.3.1.2 NFPA 13R sprinkler systems.
Section 903.3.1.2 of the California Fire Code is amended to read as follows:
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 Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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with NFPA 13 and State and local standards.
[. . .]
15.04.310 Section 903.3.1.3 and 903.3.1.3.1 NFPA 13D sprinkler systems.
Section 903.3.1.3 of the California Fire Code is amended and 903.3.1.3.1 is added to read as follows:
903.3.1.2 NFPA 13D sprinkler systems. Where allowed, automatic sprinkler systems installed in one-and two-family dwellings shall be installed throughout in accordance with NFPA 13D and State and local standards. Fire sprinkler protection shall be provided under rear covered patios extending over 4 ft perpendicular from the exterior of the structure. 903.3.1.3.1 Increase in fire sprinkler design criteria . Structures determined by the fire code official to have higher firefighting hazardous condition, 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.
15.04.320 Section 903.3.10 Floor control valves.
Section 903.4.3 of the California Fire Code is amended to read as follows:
903.3.10 Floor control valves. Automatic sprinkler systems serving buildings two (2) or more stories in height shall have valves installed to control the system independently on each floor including basements.
15.04.330 Section 905.3.1 Height.
Section 905.3.1 of the California Fire Code is amended to read as follows:
905.3.1 Height. A Class I Standpipe System shall be installed in new buildings or buildings being retrofitted with a fire sprinkler system where the roof edge/parapet is greater than 27 feet above the lowest level of Fire apparatus access roadway and in below grade levels.
15.04.340 Section 909.20.7 Maintenance and operational schedule.
Section 909.20.7 is added to the California Fire Code to read as follows:
909.20.7 Maintenance and operational sc hedule. 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.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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15.04.350 Section 1008.3 Illumination required by an emergency electrical system.
Section 1008.3 of the California Fire Code is amended to read as follows:
Section 1008.3 Illumination required by an emergency electrical system. An emergency electrical system shall be provided to automatically illuminate the following areas in the event of a power supply failure:
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.
15.04.360 Section 1031.2 Where required.
Section 1031.2 of the California Fire 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.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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Exceptions:
1. In Groups 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.
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 m 2)
15.04.370 Section 1207.1.5 Large-scale fire test.
Section 1207.1.5 of the California Fire Code is amended to read:
1207.1.5 Large-scale fire test. Where required elsewhere in Section 1207, large-scale fire testing shall be conducted in accordance with NFPA 855 as amended, and UL 9540A.
The testing shall be conducted or witnessed and reported by an approved testing laboratory and show that a fire involving one ESS will not propagate to an adjacent ESS, and where installed within buildings, enclosed areas and walk-in units will be contained within the room, enclosed area or walk-in unit for a duration equal to the fire-resistance rating of the room separation specified in Section 1207.7.4. The test report shall be provided to the fire code official for review and approval in accordance with Section 104.822.
15.04.375 Section 1207.5.2 Maximum allowable quantities.
Section 1207.5.2 of the California Fire Code is amended to read as follows:
1207.5.2 Maximum allowable quantities. Fire areas within rooms, areas and walk-in units containing electrochemical ESS shall not exceed the maximum allowable quantities in Table 1207.5. The allowable number of fire areas, maximum allowable quantity, and fire-resistance rating of fire-barriers for commercial structures shall comply with Table 1207.5.1.
Exceptions:
Where approved by the fire code official, rooms, areas and walk-in units containing Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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electrochemical ESS that exceed the amounts in Table 1207.5 shall be permitted based on a hazardous mitigation analysis in accordance with Section 1207.1.6 and large-scale fire testing complying with Section 1207.1.7.
1. Lead-acid and nickel-cadmium battery systems installed in facilities under the exclusive control of communications utilities and operating at less than 50 VAC and 60 VDC in accordance with NFPA 76.
2. Dedicated-use buildings in compliance with Section 1207.7.1.
TABLE 1207.5.1
DESIGN AND NUMBER OF ESS FIRE AREAS
STORY PERCENTAGE OF
MAXIMUM
ALLOWABLE
QUANTITY PER
FIRE AREA
NUMBER OF
FIRE AREAS
PER STORY
FIRE-RESISTANCE
RATING FOR FIRE
BARRIERS IN
HOURS
Above grade plan Higher than 9
7-9
6 5
4 3
2 1
25 50
50 50
75 100
100
100
1 2
2 2
4 6
6 6
3 2
2 2
2 2
2 2
Below grade plan 1
2 Lower than 2
100
50 Not Allowed
4 2
Not Allowed
3 3
Not Allowed
15.04.380 Section 1207.11.3 Location.
Section 1207.11.3 of the California Fire Code is amended to read:
1207.11.3 Location. ESS shall be installed only in the following locations:
1. Detached garages and detached accessory structures.
2. Attached garages separated from the dwelling unit living space and sleeping units in accordance with Section R302.6.
3. Outdoors or on the exterior side of the exterior walls located not less than 3 feet (914 mm) from doors and windows directly entering the dwelling unit and shall not be located below or above any emergency escape and rescue openings.
4. Enclosed utility closets, basements and storage or utility spaces within dwelling Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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units and sleeping units with finished or noncombustible walls and ceilings. Walls and ceilings of unfinished wood-framed construction shall be provided with not less than 5/8-inch (15.9 mm) Type X gypsum wallboard.
5. ESS shall not be installed in sleeping rooms, or in closets, or spaces opening directly into sleeping rooms or in habitable spaces of dwelling units.
15.04.390 Section 3303.7 Fire walls.
Section 3305.9 is added to the California Fire Code to read as follows:
3303.7 Fire walls. When firewalls are required in combustible construction, the wall construction shall be completed (with all openings protected) immediately after the building is sufficiently weather-protected at the location of the wall(s).
15.04.400 Section 3307.1.2, 3307.1.4.
Section 3312.1 of the California Fire Code is amended to read as follows:
3307.1.2 Stairways required. Each level above the first story in new multi-story buildings be provided with at least two usable exit stairways after the floor decking is installed. The stairways shall be continuous and shall discharge to grade level. Stairways serving more than two floor levels shall be enclosed (with openings adequately protected) after exterior walls/windows are in place. Exit stairs in new and in existing, occupied buildings shall be lighted and maintained clear of debris and construction materials at all times.
Exception: For new multi-story buildings, one of the required exit stairs may be obstructed on not more than two contiguous floor levels for the purposes of stairway construction (i.e., installation of gypsum board, painting, flooring, etc.).
3307.1.4 Required means of egress. All new buildings under construction shall have a least one unobstructed means of egress. All means of egress shall be identified in the written site safety plan as required by Section 3303.1.
15.04.410 Reserved
15.04.420 Reserved
15.04.430 Reserved
15.04.435 Section 4103.1 Portable unvented heaters.
Section 4103.1 of the California Fire code is amended to read as follows:
4103.1 Portable unvented heaters. Portable unvented fuel-fired heating equipment Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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shall be prohibited in occupancies in Groups A, B, E, I, R-1, R-2, R-2.1, R-2.2, R-3, R-3.1 and R-4 and ambulatory care facilities.
Exceptions:
1. Portable unvented fuel-fired heaters listed and labeled in accordance with UL 647 are permitted to be used in one- and two-family dwellings, where operated and maintained in accordance with the manufacturer’s instructions.
2. Portable outdoor gas-fired heating appliances in accordance with Section 4103.1.2.
15.04.440 Section 5001.2.2.2 Health Hazards.
Section 5001.2.2.2 of the California Fire Code is amended to read as follows:
5001.2.2.2 Health Hazards. The material categories listed in this section are classified as health hazards. A material with a primary classification as a health hazard can also pose a physical hazard.
1. Highly toxic, toxic and moderately toxic.
2. Corrosive materials.
3. Moderately toxic gas.
4. Health hazards-Other.
15.04.450 Section 500 1.7 Hazard m aterials management plan (HMMP) electronic submissions.
Section 5001.7 is added to the California Fire Code to read as follows:
5001.7 HMMP electronic submissions. Each applicant for a permit, a renewed permit, or an amended permit pursuant to this title shall file an electronic submission of all hazardous materials through California Environmental Reporting System (CERS) for the fire chief's approval, to be known as a hazardous materials management plan (HMMP), which shall demonstrate the suitable storage of hazardous materials. The HMMP may be amended at any time with the consent of the fire chief. The HMMP shall be a public record except as otherwise specified. Sec tion 18.23.100 in Title 18 identifies notification requirements of the availability of the HMMP. Approval of the HMMP shall mean that the HMMP has provided adequate information for the purposes of evaluating the permit approval. Such approval shall not be understood to mean that the city has made an independent determination of the adequacy of that which is described in the HMMP electronic submission.
15.04.460 Section 5003.1.3.1 Toxic, highly toxic, moderately toxic gases and similarly used Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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or handled materials.
Section 5003.1.3.1 is added to the California Fire Code to read as follows:
5003.1.3.1 Toxic, h ighly toxic, moderately toxic gases and similarly used or handled materials. The storage, use, and handling of toxic, highly toxic and moderately toxic gases in amounts exceeding Table 6004.2 or 6004.3 shall be in accordance with this Chapter and Chapter 60. Any toxic, highly toxic or moderately toxic material that is used or handled as a gas or vapor shall be in accordance with the requirements for toxic, highly toxic or moderately toxic gases.
15.04.470 Section 5003.1.5 Other health hazards including carcinogens, irritants and sensitizers.
Section 5003.1.5 is added to the California Fire Code to read as follows:
5003.1.5 Other health hazards including carcinogens, irritants and sensitizers. The storage, use, and handling of materials classified as other health hazards including carcinogens, irritants and sensitizers in amounts exceeding 810 cubic feet for gases, 55 gallons for liquids and 5,000 pounds for solids shall be in accordance with this Section 5003.
15.04.480 Section 5003.1.6 Additional secondary containment requirements.
Section 5003.1.6 is added to the California Fire Code to read as follows:
5003.1.6 Additional secondary containment requirements. In addition to the requirements set forth in Section 5004.2, an approved containment system is required for any quantity of hazardous materials that are liquids or solids at normal temperature and pressure (NTP), where a spill is determined to be a plausib le event and where such an event would endanger people, property or the environment. The approved containment system may be required to include a combination of spill control and secondary containment meeting the design and construction requirements set fo rth in section 5004.2.
15.04.490 Section 5003.2.2.1 Design and construction.
Section 5003.2.2.1 of the California Fire Code is amended to read as follows:
5003.2.2.1 Design and construction. Piping, tubing, valves, fittings and related components used for hazardous materials shall be in accordance with the following:
1. Piping, tubing, valves, fittings and related components shall be designed and fabricated from materials compatible with the material to be contained and shall be of adequate strength and durability to withstand the pressure, structural and Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
Pg.
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seismic stress, and exposure to which they are subject.
2. Piping and tubing shall be identified in accordance with ASME A13.1 and the Santa Clara County Fire Chiefs Marking Requirements and Guidelines for Hazardous Materials and Hazardous Waste to indicate the material conveyed.
3. Manual valves or automatic remotely activated fail-safe emergency shutoff valves shall be installed on supply piping and tubing and provided with ready access at the following locations at the following locations:
a. The point of use.
b. The tank, cylinder or bulk use.
4. Manual emergency shutoff valves and controls for remotely activated emergency shutoff valves shall be clearly visible, provided with ready access and identified in an approved manner.
5. Backflow prevention or check valves shall be provided when the backflow of hazardous materials could create a hazardous condition or cause the unauthorized discharge of hazardous materials.
6. Where gases or liquids having a hazard ranking of:
Health hazard Class 3 or 4
Flammability Class 4
Reactivity Class 4
In accordance with NFPA 704 are carried in pressurized piping above 15 pounds per square inch gauge (psig)(103 Kpa), an approved means of leak detection, emergency shutoff or excess flow control shall be provided. Where the piping originates from within a hazardous material storage room or area, the excess flow control shall be located within the storage room or area. Where the piping originates from a bulk source, the excess flow control shall be located as close to the bulk source as practical.
Exceptions:
a. Piping for inlet connections designed to prevent backflow. b. Piping for pressure relief devices.
7. Secondary containment or equivalent protection from spills or leaks shall be provided for piping for liquid hazardous materials and for highly toxic and toxic corrosive gases above threshold quantities listed in Tables 6004.2 and 6004.3.
Secondary containment includes, but is not limited to, double- walled piping.
Exceptions:
a. Secondary containment is not required for toxic corrosive gases if the piping is Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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constructed of inert materials.
b. Piping under sub -atmospheric conditions if the piping is equipped with an alarm and fail-safe-to-close valve activated by a loss of vacuum.
8. Expansion chambers shall be provided between valves whenever the regulated gas may be subjected to thermal expansion. Chambers shall be sized to provide protection for piping and instrumentation and to accommodate the expansion of regulated materials.
15.04.500 Section 5003.2.2.2 Additional regulations for supply piping for health hazard materials.
Section 5003.2.2.2 of the California Fire Code is amended to read as follows:
5003.2.2.2 Additional regulations for supply piping for health hazard materials. Supply piping and tubing for gases and liquids having a health hazard ranking of 3 or 4 in accordance with ASME B31.3 and the following:
1. Piping and tubing utilized for the transmission of toxic, highly toxic, or highly volatile corrosive liquids and gases shall have welded or brazed connections throughout except for connections within an exhausted enclosure if the material is a gas, or an approved method of drainage or containment is provided for connections if th e material is a liquid.
2. Piping and tubing shall not be located within corridors, within any portion of a means of egress required to be enclosed in fire-resistance-rated construction or in concealed spaces in areas not classified as Group H Occupancies.
Exception: Piping and tubing within the space defined by the walls of corridors and the floor or roof above or in concealed space above other occupancies when installed in accordance with Section 415.11.7.4 of the California Building Code as required for Group H5 occupancies.
3. All primary piping for toxic, highly toxic and moderately toxic gases shall pass a helium leak test of 1x10-9 cubic centimeters/second where practical, or shall pass testing in accordance with an approved, nationally recognized standard. Tests shall be conducted by a qualified “third party” not involved with the construction of the piping and control systems.
15.04.510 Section 5003.3.1 Unauthorized discharges.
Section 5003.3.1 of the California Fire Code is amended to read as follows:
5003.3.1 Unauthorized discharges. In the event hazardous materials are released in quantities reportable under state, federal or local regulations or when there is a threatened release that presents a threat to health, property or the environment, the fire Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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code official shall be notified immediately in an approved manner and the following procedures required in accordance with Sections 5003.3.1.1 through 5003.3.1.4.
15.04.520 Section 5003.5.2 Ventilation ducting.
Section 5003.5.2 is added to the California Fire Code to read as follows:
5003.5.2 Ventilation d ucting. Ducts venting hazardous materials operations shall be labeled with the hazard class of the material being vented and the direction of flow.
15.04.530 Section 5003.5.3 “H” Occupancies.
Section 5003.5.4 is added to the California Fire Code to read as follows:
5003.5.3 “H” Occupancies. In “H” occupancies, all piping and tubing may be required to be identified when there is any possibility of confusion with hazardous materials transport tubing or piping. Flow direction indicators are required.
15.04.540 Section 5003.9.11 Fire extinguishing systems for workstations dispensing, handling or using hazardous materials.
Section 5003.9.11 is added to the California Fire Code to read as follows:
5003.9.11 Fire extinguishing systems for workstations dispensing, handling or using hazardous materials. Combustible and non -combustible workstations which dispense, handle or use hazardous materials shall be protected by an approved automatic fire extinguishing system.
Exception: Internal fire protection is not required for Biological Safety Cabinets that carry NSF/ANSI certification where quantities of flammable liquids in use or storage within the cabinet do not exceed 500 ml.
15.04.550 Section 5003.10.4 Elevators utilized to transport hazardous materials.
Section 5003.10.4 of the California Fire Code is amended to read as follows:
5003.10.4 Elevators utilized to transport hazardous materials. 5003.10.4.1 When transporting hazardous materials, elevators shall have no other passengers other than in the individual(s) handling the chemical transport cart. 5003.10.4.1.1 When transporting cryogenic or liquefied compressed gases, there shall be no occupants in the elevator.
5003.10.4.2 Hazardous materials liquid containers shall have a maximum capacity of 20 liters (5.28 gal).
5003.10.4.3 Highly toxic, moderately toxic, and toxic gases shall be limited to a container Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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of a maximum water capacity of 1 lb.
5003.10.4.4 When transporting cryogenic or liquefied compressed gases means shall be provided to prevent the elevator from being summoned to other floors.
15.04.560 Section 5004.2.1 Spill control for hazardous material liquids.
Section 5004.2.1 of the California Fire Code is amended to read as follows:
5004.2.1 Spill control for hazardous material liquids. Rooms, buildings or areas used for storage of hazardous material liquids shall be provided with spill control to prevent the flow of liquids to adjoining areas. Floors in indoor locations and similar surfaces in outdoor locations shall be constructed to contain a spill from the largest single vessel by one of the following methods:
1. Liquid-tight sloped or recessed floors in indoor locations or similar areas in outdoor locations.
2. Liquid-tight floors in indoor and outdoor locations or similar areas provided with liquid-tight raised or recessed sills or dikes.
3. Sumps and collection systems, including containment pallets in accordance with Section 5004.2.3.
4. Other approved engineered systems.
Except for surfacing, the floors, sills, dikes, sumps and collection systems shall be constructed of noncombustible material, and the liquid-tight seal shall be compatible with the material stored. When liquid -tight sills or dikes are provided, they are not required at perimeter openings having an open-grate trench across the opening that connects to an approved collection system.
15.04.570 Sections 5004.2.2 and 5004.2.2.2 and Table 5004.2.2 Secondary containment for hazardous material liquids and solids.
Sections 5004.2.2 and 5004.2.2.2 of the California Fire Code are amended to read as follows:
5004.2.2 Secondary c ontainment for h azardous material liquids and s olids. Buildings, rooms or areas used for the storage of hazardous materials liquids or solids shall be provided with secondary containment in accordance with this section.
Table 5004.2.2 is deleted in its entirety.
[. . .]
5004.2.2.2 Incompatible Materials. Incompatible materials shall be separated from each Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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other in independent secondary containment systems.
15.04.580 Section 5004.2.3 Containment pallets.
Section 5004.2.3 of the California Fire Code is amended to read as follows:
5004.2.3 Containment pallets. Combustible containment pallets shall not be used inside buildings to comply with Section 5004.2 where the individual container capacity exceeds 55 gallons (208 L) or an aggregate capacity of multiple containers exceeds 1,000 gallons (3785 L) for liquids or where the individual container capacity exceeds 550 pounds (250 kg) or an aggregate of multiple containers exceeds 10,000 pounds (4540 kg) for solids.
Where used as an alternative to spill control and secondary containment for outdoor storage in accordance with the exception in Section 5004.2, containment pallets shall comply with all of the following:
1. A liquid-tight sump accessible for visual inspection shall be provided;
2. The sump shall be designed to contain not less than 66 gallons (250L);
3. Exposed surfaces shall be compatible with material stored; Containment pallets shall be protected to prevent collection of rainwater within the sump of the containment pallet.
15.04.590 Section 5704.2.7.5.8 Overfill prevention.
Section 5704.2.7.5.8 of the California Fire Code is amended to read as follows:
5704.2.7.5.8 Overfill prevention. An approved means or method in accordance with Section 5704.2.9.7.5 shall be provided to prevent overfill of all Class I, II and IIIA liquid storage tanks. Storage tanks in refineries, bulk plants or terminals regulated by Sections 5706.4 or 5706.7 shall have overfill protection in accordance with API 2350.
An approved means or method in accordance with Section 5704.2.9.7.5 shall be provided to prevent the overfilling of Class IIIB liquid storage tanks connected to fuel -burning equipment inside buildings.
Exception: Outside aboveground tanks with a capacity of 1320 gallons (5000 L) or less need only comply with Section 5704.2.9.7.5.1 (1.1)
15.04.600 Section 5704.2.7.5.9 Automatic and/or remote filling of tanks.
Section 5704.2.7.5.9 is added to the California Fire Code to read as follows:
5704.2.7.5.9 Automatic and/or remote filling of t anks. Systems that remotely or automatically fill flammable or combustible liquid tanks shall be equipped with overfill Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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protection, as approved by the fire code official, that sends an alarm signal to a constantly attended location and immediately stops the filling of the tank. The alarm signal and automatic shutoff shall be tested on an annual basis. Records of such testing shall be maintained on-site, and available for review, for a period of five (5) years.
15.04.610 Reserved
15.04.620 Section 6001.1 Site scope.
Section 6001.1 of the California Fire Code is amended to read as follows:
6001.1 Site scope. The storage and use of highly toxic, moderately toxic and/or toxic materials shall comply with this chapter. Compressed gases shall also comply with Chapter
53. Exceptions:
1. Display and storage in Group M and storage in Group S occupancies complying with Section 5003.1 1.
2. Conditions involving pesticides or agricultural products as follows:
2.1. Application and release of pesticide, agricultural products and materials intended for use in weed abatement, erosion control, soil amendment or similar applications when applied in accordance with the manufacturer’s instruction and label directions.
2.2. Transportation of pesticides in compliance with the Federal Hazardous Materials Transportation Act and regulations thereunder.
2.3. Storage in dwellings or private garages of pesticides registered by the U.S. Environmental Protection Agency to be utilized in and around the home, garden, pool, spa and patio.
15.04.630 Section 6002.1 Definitions.
Section 6002.1 is amended to read as follows:
6002.1 Definitions. The following terms are defined in Chapter 2:
CONTAINMENT SYSTEM.
CONTAINMENT VESSEL.
EXCESS FLOW VALVE.
HIGHLY TOXIC.
MODERATELY TOXIC GAS
OZONE-GAS GENERATOR.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
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incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
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PHYSIOLOGICAL WARNING THRESHOLD.
REDUCED FLOW VALVE.
TOXIC.
15.04.640 Section 6004.1 Highly toxic, moderately toxic and toxic compressed gases.
Section 6004.1 of the California Fire Code is amended to read as follows:
6004.1.1 The storage and use of highly toxic, moderately toxic, and toxic compressed gases shall comply with this section.
6004.1.1 Special limitations for indoor storage and use by occupancy. The indoor storage and use of highly toxic, moderately toxic, and toxic compressed gases in certain occupancies shall be subject to the limitations contained in Sections 6004.1.1.1 through 6004.1.1 .3.
6004.1.1.1 Group A, E, I or U occupancies. Toxic, moderately toxic and highly toxic compressed gases shall not be stored or used within Group A, E, I or U occupancies.
Exception: Cylinders not exceeding 20 cubic feet (0.566 m3) at normal temperature and pressure (NTP) are allowed within gas cabinets or fume hoods. 6004.1.1.2 Group R occupancies. Toxic, moderately toxic, and highly toxic compressed gases shall not be stored or used in Group R occupancies. 6004.1.1.3 Offices, retail sales and classrooms. Toxic, moderately toxic and highly toxic compressed gases shall not be stored or used in offices, retail sales or classroom portions of Group B, F, M or S occupancies.
Exception: In classrooms of Group B occupancies, cylinders with a capacity not exceeding 20 cubic feet (0.566 m3) at NTP are allowed in gas cabinets or fume hoods.
15.04.650 Sections 6004.2 and 6004.2.1 Indoor storage and use.
Sections 6004.2 and 6004.2.1 of the California Fire Code are amended to read as follows:
6004.2 Indoor storage and use. The indoor storage and use of highly toxic, moderately toxic, and toxic compressed gases shall be in accordance with Sections 6004.2.1 through 6004.2.2.10.3.
6004.2.1 Applicability. The applicability of regulations governing the indoor storage and use of highly toxic, moderately toxic, and toxic compressed gases shall be as set forth in Sections 6004.2.1.1 through 6004.2.1.4.
15.04.660 Section 6004.2.1.1 and Table 6004.2.1.1 Quantities.
Section 6004.2.1.4 and Table 6004.2.1.4 of the California Fire Code are added to read as follows:
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Attachment A - Ordinance
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local amendments and
related findings
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6004.2.1.1 Quantities not exceeding the maximum allowable quantity per control area. The indoor storage or use of highly toxic, moderately toxic, and toxic gases in amounts exceeding the minimum threshold quantities per control area set forth in Table 6004.2.1.4 but not exceeding maximum allowable quantity per control area set forth in Table 5003.1.1(2) shall be in accordance with Sections 5001, 5003, 6001, 6004.1, and 6004.4.
Table 6004.2.1.1
Minimum Threshold Quantities for Highly Toxic, Moderately Toxic and Toxic Gases for Indoor Storage and Use
Highly Toxic 20 cubic feet
Moderately Toxic 405 cubic feet
Toxic 405 cubic feet
15.04.670 Section 6004.4 through 6004.4.8.2 General indoor requirements.
Section 6004.4 through 6004.4.8.2 of the California Fire Code is added to read as follows:
6004.4. General indoor requirements. The general requirements applicable to the indoor storage and use of highly toxic, moderately toxic, and toxic compressed gases shall be in accordance with Sections 6004.4 through 6004.4.8.2 6004.4.1 Cylinder and tank location. Cylinders shall be located within gas cabinets, exhausted enclosures or gas rooms. Portable and stationary tanks shall be located within gas rooms or exhausted enclosures.
Exception:
1. Where a gas detection system is provided in accordance with 6004.4.8 6004.4.2. Ventilated areas. The room or area in which gas cabinets or exhausted enclosures are located shall be provided with exhaust ventilation. Gas cabinets or exhausted enclosures shall not be used as the sole means of exhaust for any room or area.
6004.4.3. Piping and controls. In addition to the requirements of Section 5003.2.2, piping and controls on stationary tanks, portable tanks, and cylinders shall comply with the following requirements:
1. Stationary tanks, portable tanks, and cylinders in use shall be provided with a means of excess flow control on all tank and cylinder inlet or outlet connections.
Exceptions:
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Attachment A - Ordinance
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local amendments and
related findings
Item 6: Staff Report
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1. Inlet connections designed to prevent backflow.
2. Pressure relief devices.
6004.4.4 Gas rooms. Gas rooms shall comply with Section 5003.8.4 and both of the following requirements:
1. The exhaust ventilation from gas rooms shall be directed to an exhaust system.
2. Gas rooms shall be equipped with an approved automatic sprinkler system.
Alternative fire-extinguishing systems shall not be used. 6004.4.5 Treatment systems. The exhaust ventilation from gas cabinets, exhausted enclosures and gas rooms, required in Section 6004.4.1 shall be directed to a treatment system. The treatment system shall be utilized to handle the accidental release of gas and to process exhaust ventilation. The treatment system shall be designed in accordance with Sections 6004.2.2.7.1 through 6004.2.2.7.5 and Chapter 5 of the California Mechanical Code.
Exceptions:
1. Highly toxic, moderately toxic, and toxic gases—storage. A treatment system is not required for cylinders, containers and tanks in storage where all of the following controls are provided:
a. Valve outlets are equipped with gas-tight outlet plugs or caps. b. Hand wheel-operated valves have handles secured to prevent movement.
c. Approved containment vessels or containment systems are provided in accordance with Section 6004.2.2.3.
2. Highly toxic, moderately toxic, and toxic gases —use. Treatment systems are not required for highly toxic, moderately toxic, and toxic gases supplied by stationary tanks, portable tanks, or cylinders where a gas detection system complying with Section 6004.4.8 and listed or approved automatic-closing fail-safe valves are provided. The gas detection system shall have a sensing interval not exceeding 5 minutes. Automatic- closing fail-safe valves shall be located immediately adjacent to cylinder valves and shall close when gas is detected at the permissible exposure limit (PEL) by a gas sensor monitoring the exhaust system at the point of discharge from the gas cabinet, exhausted enclosure, ventilated enclosure or gas room.
6004.4.5.1. Design. Treatment systems shall be capable of diluting, adsorbing, absorbing, containing, neutralizing, burning or otherwise processing the contents of the largest single vessel of compressed gas. Where a total containment system is used, the system shall be designed to handle the maximum anticipated pressure of release to the system when it reaches equilibrium.
6004.4.5.2. Performance. Treatment systems shall be designed to reduce the maximum Item 6
Attachment A - Ordinance
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local amendments and
related findings
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allowable discharge concentrations of the gas to one-half immediate by dangerous to life and health (IDLH) at the point of discharge to the atmosphere. Where more than one gas is emitted to the treatment system, the treatment system shall be designed to handle the worst-case release based on the release rate, the quantity and the IDLH for all compressed gases stored or used.
6004.4.5.3. Sizing. Treatment systems shall be sized to process the maximum worst- case release of gas based on the maximum flow rate of release from the largest vessel utilized. The entire contents of the largest compressed gas vessel shall be considered. 6004.4.5.4 Stationary tanks. Stationary tanks shall be labeled with the maximum rate of release for the compressed gas contained based on valves or fittings that are inserted directly into the tank. Where multiple valves or fittings are provided, the maximum flow rate of release for valves or fittings with the highest flow rate shall be indicated. Where liquefied compressed gases are in contact with valves or fittings, the liquid flow rate shall be utilized for computation purposes. Flow rates indicated on the label shall be converted to cubic feet per minute (cfm/min) (m3/s) of gas at normal temperature and pressure (NTP).
6004.4.5.5 Portable tanks and cylinders. The maximum flow rate of release for portable tanks and cylinders shall be calculated based on the total release from the cylinder or tank within the time specified in Table 6004.2.2.7.5. Where portable tanks or cylinders are equipped with approved excess flow or reduced flow valves, the worst- case release shall be determined by the maximum achievable flow from the valve as determined by the valve manufacturer or compressed gas supplier. Reduced flow and excess flow valves shall be permanently marked by the valve manufacturer to indicate the maximum design flow rate. Such markings shall indicate the flow rate for air under normal temperature and pressure.
6004.4.6. Emergency power. Emergency power shall be provided for the following systems in accordance with Section 604:
1. Exhaust ventilation system.
2. Treatment system.
3. Gas detection system.
4. Smoke detection system.
6004.4.6.1. Fail-safe systems. Emergency power shall not be required for mechanical exhaust ventilation and treatment systems where approved fail-safe systems are installed and designed to stop gas flow.
6004.4.7. Automatic fire detection system. An approved automatic fire detection system shall be installed in rooms or areas where highly toxic, toxic, and moderately toxic compressed gases are stored or used. Activation of the detection system shall sound a local alarm. The fire detection system shall comply with Section 907.
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Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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6004.4.8. Gas detection system. A gas detection system complying with Section 916 shall be provided to detect the presence of gas at or below the PEL or ceiling limit of the gas for which detection is provided.
Exceptions:
1. A gas detection system is not required for toxic and moderately toxic gases when the physiological warning threshold level for the gas is at a level below the accepted PEL for the gas.
2. A gas detection system is not required for highly toxic, toxic, and moderately toxic gases where cylinders, portable tanks, and all non-continuously welded connects are within a gas cabinet or exhausted enclosures.
6004.4.8.1. Alarms. The gas detection system shall initiate a local alarm and transmit a signal to an approved location.
6004.4.8.2. Shut off of gas supply. The gas detection system shall automatically close the shut off valve at the source on gas supply piping and tubing related to the system being monitored for whichever gas is detected.
Exception: Automatic shutdown is not required for highly toxic, moderately toxic, and toxic compressed gas systems where all of the following controls are provided:
1. Constantly attended / supervised.
2. Provided with emergency shutoff valves that have ready access.
SECTION 2. The Council adopts the findings for local amendments to the California Fire 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 Sections
15.04.180, 260, 280, 295, 375, and 435, the changes or modifications to the California Fire 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 residenti al building standards imposed by Assembly Bill (AB) 130 (2025). T o the extent that the changes codified at the PAMC sections listed in this finding are not substantially equivalent to changes or modifications previously filed and in effect as of September 30, 2025, they do not affect residential units and are therefore not subject to the AB 130 moratorium.
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 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.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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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 California Guidelines, because it can be seen with certainty that there is no possibility that the ame ndments herein adopted will have a significant effect on the environment.
SECTION 6. This Ordinance shall become effective on the commencement of the thirty-first day after the day 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
____________________________
Fire Chief
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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EXHIBIT A
Findings for Local Amendments to the 2025 California Fire Code
The following local amendments to the 2025 California Fire Code make modifications as authorized by the California Health and Safety Code. In accordance with Section 18941.5 of said Code, Findings are hereby made to show that such modifications or changes are reasonably necessary because of local climatic, geological or topographical conditions.
I. PREAMBLE
I. Findings of fact
A. Pursuant to Section 17958.5 of the California Health and Safety Code, the report contained herein is submitted as the “Findings of Fact” document with regard to the adoption of the California Fire Code, 2025 Edition, and amendments. Under this adopting ordinance, specific amendments have been established which are more restrictive in nature than those adopted by the State of California (State Building Code Standards, State Housing and Community Development Codes) commonly referred to as California Code of Regulations, Titles 19, 24 and
25. B. These amendments to the California Fire Code, 2025 Edition, have been recognized by the City of Palo Alto (“City”) as tools for addressing the fire problems, concerns and future direction by which the authority can establish and maintain an environment which will afford a level of fire and life safety to all who live and work within the City’s boundaries.
C. Under the provisions of Section 17958.5 of the Health and Safety Code, local amendments shall be based upon the following: climatic, geological/geographical, and topographical conditions. The findings of fact contained herein shall address each of these situations and shall present the local situation which, either singularly or in combination, caused the established amendments to be adopted.
1. Climactic Conditions:
The City, on an average, experiences an annual rainfall of 16" - 18". This rainfall can be expected between October and April of each year. However, during the summer months there is little, if any, measurable precipitation. During this dry period the temp eratures are usually between 70- 90 degrees with light to gusty westerly winds. These drying winds, combined with the natural vegetation which is dominant throughout the area, create a hazardous fuel condition which can cause, and has caused in the past, e xtensive grass and brush land fires. With more and more development encroaching into these wooded and grass covered areas, wind -driven fires could have severe consequences, as has been demonstrated on several occasions in Palo Alto and other Item 6
Attachment A - Ordinance
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incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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areas of the state. Fires in structures can easily spread to the wildland as well as a fire in the wildland into a structure.
Because of the weather patterns, a normal rainfall cannot always be relied upon. This can result in water rationing and water allocation systems, as demonstrated by the drought years of 1986- 1991. Water shortages can also be expected in the future due to the current water storage capacities and increased consumption. The water supply for the Palo Alto fire department makes use of automatic fire sprinkler systems feasible as a means to reduce our dependency on large volumes of water for fire suppression.
2. Geological & Geographical Conditions:
Geographical Location. Palo Alto is located at the northern most part of Santa Clara County. Palo Alto is a major focus of the “Silicon Valley,” the center for an expanding and changing electronics industry, as well as pharmaceutical, biomedical, and genetic research.
Seismic Location. Palo Alto is situated on alluvial solids between San Francisco Bay and the San Andreas Fault zone. The City’s location makes it particularly vulnerable to damage to taller and older structures caused by seismic events. The relatively young geological pro cesses that have created the San Francisco Bay Area are still active today. Seismically, the city sits between two active earthquake faults (San Andreas and the Hayward/Calaveras), and numerous potentially active faults. Approximately 55% o f the City’s land surface is in the high -to-moderate seismic hazard zones.
Seismic and Fire Hazards. Fire following an earthquake has the potential of causing greater loss of life and damage than the earthquake itself.
The majority of the City’s high-rise structures are located in seismic risk zones. Should a significant seismic event occur, Public Safety resources would have to be prioritized to mitigate the greatest threat, and may not be available for every structural fire. In such event, individual structures, including high-rise buildings, should be equipped to help in mitigating the risk of damage.
Other variables may tend to intensify the situation:
a. The extent of damage to the water system;
b. The extent of isolation due to bridge and/or freeway overpass collapse; c. The extent of roadway damage and/or amount of debris blocking the roadways; d. Climatical conditions (hot, dry weather with high winds); e. Time of day will influence the amount of traffic on roadways and could intensify the risk to life during normal business hours;
f. The availability of timely mutual aid or military assistance; g. Many high-rise structures are located near areas of high fire danger necessitating special Item 6
Attachment A - Ordinance
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local amendments and
related findings
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precautions.
Transportation. Palo Alto is dissected by a major state highway (El Camino Real) and two major freeways (I-280 and U.S. 101), which potentially could negatively affect response times of fire suppression equipment.
Soil Conditions. Palo Alto lies at the southern end of San Francisco Bay and is built atop the alluvial deposits that surround the margins of the Bay. The alluvium was created by the flooding of many streams emptying into the San Francisco Bay depression, and from interm ittent sea water inundation that has occurred over the last 2 or 3 million years. The areas closest to the Bay are overlain by unconsolidated fine silty clay, known as Bay Mud which varies in thickness from a few feet to as much as 30 feet. Generally, the older more stable alluvium is to the south and the younger less stable material is to the north. Bedrock lies beneath the area at depths of generally 300' or more.
3. Topographical Conditions:
The findings of fact for the topographical element, as would be expected, are closely associated with the geological/geographical element. With the elevation changes within the district, development is of course following the path of least resistance, crea ting a meandering pattern.
This then does not lend itself to a good systematic street and road layout, which would promote easy traffic flow. It has, in fact, resulted in few major crosstown thoroughfares which tend to be heavily congested, primarily during commute hours and seasonal periods of the year. This creates barriers which reduce the response time of fire equipment and other emergency services. The topography of the district is being burdened by major structures. Employment areas are throughout the district. The people who work in these complexes have added to the traffic congestion throughout the city, thereby reducing the fire department’s response time capabilities.
Inherent delays caused by the traffic patterns to many of these types of projects, make it necessary to mitigate this problem by requiring additional built -in automatic fire protection systems to provide early detection and initial control until the arrival of the fire department.
The topography of the district in much of the commercial and residential zones lies within or near a flood plane. Periodically, heavy rains and high tides cause region-wide flooding which not only delays response but also increases demands on fire personnel. The fire code amendments increase safeguards and initialize early response to help compensate for these physical delays.
As a result of the findings of facts which identify the various climatic, geological/geographical and topographical elements, those additional requirements as specified in the amendments to adopting ordinance for the California Fire Code 2025 Edition, by the City of Palo Alto area are considered reasonable and necessary modifications. The experience of several disastrous fires Item 6
Attachment A - Ordinance
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Chapter 15.04,
incorporating California Fire
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local amendments and
related findings
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within the city in addition to Santa Clara, Monterey, San Mateo, Alameda and Contra Costa counties have demonstrated the need for other fire protection features, the most significant of which was located in the Oakland/Berkeley Hills in which over 3,000 homes were destroyed and 25 human lives were lost. While it is clearly understood that the adoption of such regulations may not prevent the incidence of fire, the implementation of these various amendments to the Code may reduce the severity and potential of loss of life and property.
II. Specific Findings for Local Amendments
The majority of local amendments (those not specifically listed below) are made strictly to conform to other parts of the Palo Alto Municipal Code (PAMC) and for similar administrative purposes.
Based upon the findings of fact described in section I, the City Council also makes the following specific findings regarding local climatic, geological, and topographic conditions related to local amendments to the California and International Fire Codes found in Chapter 15.04 of Title 15 of the Palo Alto Municipal Code (“PAMC”):
1. The local amendments contained in PAMC sections 15.4.030, 15.04.040, 15.04.050,
15.04.110, 15.04.130, and 15.04.140 are administrative in nature and do not require local topographical, geographical, or climatic findings.
2. The local amendments contained in PAMC sections 15.04.060 through 15.04.090,
15.04.150, 15.04.170, 15.04.260, and 15.04.440 through 15.04.670 - relating to general conditions for hazardous materials are necessary modifications to the California Fire Code flammable and hazardous materials sections because they maintain consistency with the Hazardous Materials Storage Ordinance which has been adopted county-wide since 1983.
Requirements include safeguards such as monitoring, secondary containment, separation of non-compatibles which prevent incidents should a seismic event, unauthorized release or accident occur. See Findings 2 and 3 above - Geological and Topographical.
3. The local amendment contained in PAMC section 15.04. 260- Immersion Heaters - is necessary as a fire control measure because it requires additional controls on process heating devices which are often activated when unattended. See Finding 2 above - Geological.
4. The local amendments contained in PAMC 15.04.180 and 15.04.280 through 15.04.340 relating to fire sprinkler systems are necessary for faster control of fires in the dense populated area and areas in an extended response time of our community to confine a fire to the area of origin rather than spread to neighboring structures.
The modifications contained in these amendments provide additional fire extinguishing systems in new construction, major remodels, additions, and occupancy classification changes to help Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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mitigate the problems identified in Findings 1, 2, and 3, above- Climatic, Geographical and Topographical.
5. The local amendment contained in PAMC section 15.04.320 - Floor control valves is necessary to provide fire extinguishing control devices that allow systems to remain partially in service while repairs or maintenance are ongoing. See Findings 1 and 2 above- Climatic and Geographical.
6. The local amendments contained in PAMC section 15.04.350 provides emergency lighting, where emergency lighting is required, in public restrooms regardless of size for public safety. See Findings 1, 2, and 3 – Climatic, Geographical and Topographical.
7. The local amendment contained in PAMC section 15.04.360 matches the requirements for exceptions for emergency escapes in basements/storm shelters in local amendment contained in section 16.04.360. See Findings 1 and 2 – Climatic and Geographical.
8. The local amendments contained in PAMC section 15.04.370 through 15.04.380 are recommendations from Santa Clara County Fire Marshals Association to decrease the fire hazard and risk of fire spread associated with commercial ESS installations and clarifying location for residential ESS to not interfere with emergency escapes or rescue openings. See Finding 3 above – Topographical.
9. The local amendments contained in PAMC sections 15.04.390 and 15.04.400 provide for additional fire and life safety measures during construction and demolition. See Findings 2 and 3, above- Geographical and Topographical.
10. The local amendments contained in PAMC sections 15.04.060 through 15.04.090,
15.04.150, 15.04.460, and 15.04.620 through 15.04.670 regarding toxic gases incorporate requirements initially established by the Model Toxic Gas Ordinance and California Fire Code.
Administrative and restrictive measures include changes in definitions, quantities regulated, and utilizes County consensus guidelines established by other regional agencies which share similar climatic, geological/geographical, and topographical conditions. See Findings 1, 2 and 3, above- Climatic, Geographical and Topographical.
11. The local amendments added in PAMC section 15.04.160 - Roof guardrails at interior courts provides for additional fire and life safety measures for firefighters on buildings with unconventional lightwells. See Findings 2 and 3, above- Geographical and Topographical.
12. The local amendments contained in PAMC section 15.04.020 set forth construction and design provisions for residential property to mitigate the additional risk of fire. The modifications contained in this amendment provide for additional precautions against fire risks Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
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necessitated by the conditions listed in Findings 1, 2, and 3, above- Climatic, Geographical and Topographical.
13. The local amendment contained in PAMC section 15.04.120 is necessary to identify who has the authority and to establish the frequency to inspect buildings and premises. The modifications contained in this amendment provide for additional precautions to mitigate the problems identified in Findings 1, 2, and 3, above- Climatic, Geographical and Topographical.
14. The local amendment contained in PAMC section 15.04.190 is necessary to set forth a limit of the maximum number of false alarms the city of Palo Alto Fire Department will respond to. This measure is necessary to prevent fire department resources from responding to non- emergency situations thereby being unavailable to respond to an actual emergency associated with Climatic, Geographical and Topographical conditions listed in Findings 1, 2 and 3 above.
15. The local amendments added in PAMC sections 15.04.200 through 15.04.250 – The Fire Access Roadways and Dimensions requirements are necessary to provide access for effective, efficient and safe firefighting operations. These measures are necessary to prevent a delay in fire department resources responding to and having access to an emergency situation associated with Climatic, Geographical and Topographical conditions listed in Findings 1, 2 and 3 above.
16. The local amendments added in PAMC section 15.04.270 – Prohibitive Locations and
15.04.435 - Portable Unvented Heaters are necessary to restrict the use of portable outdoor gas-fired heating appliances and portable unvented heaters in specific locations as these appliances can be a fire hazard that may also contribute to the uncontrolled spread of fire as a result of the Climatic, Geographical, and Topographical conditions described in Findings 1, 2, and 3 above.
17. The local amendment added in PAMC section 15.04.260 relating to the protection of energy storage systems is necessary to prevent potential damage and fire that may also contribute to the uncontrolled spread of fire as a result of the Climatic, Geographical, and Topographical conditions described in Findings 1, 2, and 3 above.
Item 6
Attachment A - Ordinance
repealing PAMC Chapter
15.04 and adopting a new
Chapter 15.04,
incorporating California Fire
Code (2025 Edition) and
local amendments and
related findings
Item 6: Staff Report
Pg.
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: November 3, 2025
Report #:2509-5262
TITLE
Approval of Budget Amendments in the Local Housing Trust Fund, Residential Housing In-Lieu Fund, Residential Housing Impact Fee Fund, and Commercial Housing Impact Fee Fund to Reflect Prior City Council Funding Commitments for the Development of 3001 El Camino Real 100% Affordable Multi-Family Housing Project; CEQA Status: Not a Project.
RECOMMENDATION
Staff recommend that City Council approve the following actions to reflect the prior $5,000,000 funding commitment to the 3001 El Camino Real 100% Affordable Multi-Family Housing Project:
1. Amend the Fiscal Year 2026 Budget Appropriation (Requires 2/3 Vote) for:
a. The Local Housing Trust Fund (Fund 252) by:
i. Increasing Grant Revenue by $1,900,000; and
ii. Increase appropriation for Contract Services Expenses by $1,900,000; b. The Residential Housing In-Lieu Fund (Fund 233) by:
i. Increasing appropriation for Contract Services expenses by $500,000; and ii. Decreasing the Fund Balance by $500,000;
c. The Residential Housing Impact Fee Fund (Fund 293):
i. Increasing appropriation for Contract Services expenses by $400,000; and ii. Decreasing the Fund Balance by $400,000;
d. Commercial Housing Impact Fee Fund (Fund 234):
i. Increasing appropriation for Contract Services Expenses by $2.2 million; and
ii. Decreasing the Fund Balance by $2.2 million.
EXECUTIVE SUMMARY
On January 21, 2025, City Council awarded a conditional funding commitment of $5 million to the 3001 El Camino Real 100% Affordable Multi-Family Housing Project, which was also found Item 7
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to be a Local Housing Trust Fund qualifying project.1 The funding commitment sources were as follows:
The remaining $1.9 million from the City’s 2022 Local Housing Trust Fund (LHTF) (Fund 252) program grant award from the State Department of Housing and Community Development (HCD);
A corresponding $1.9 million in City Council designated Local Housing Trust Fund local matching funds from the Residential Housing In-Lieu Fund (Fund 233) ($500,000), Residential Housing Impact Fee Fund (Fund 293) ($400,000), and Commercial Housing Impact Fee Fund (Fund 234) ($1,000,000); and
An additional $1.2 million from the Commercial Housing Impact Fee Fund (Fund 234).
It is now timely for City Council to undertake budget amendment actions that would allow disbursement of this funding. These Council actions would complete the internal budgeting process to fund this project.
BACKGROUND
On May 23, 2022, City Council authorized the Planning & Development Services Department to apply for a $3.4 million 2022 HCD Local Housing Trust Fund (LHTF) program grant and designated $3.4 million in local matching funds. Palo Alto was awarded the $3.4 million LHTF program grant on October 11, 2022. City Council approved direction of these LHTF funds toward permanent financing loans for new affordable multi-family residential rental housing projects. To qualify for these funds, a new affordable housing project must:
Use a maximum of 70% of City and LHTF funds toward affordability levels at or below 60% of area median income (AMI);
Use a minimum of 30% of City and LHTF funds toward affordability levels at or below 30% AMI; and
Establish income and rent restrictions for no less than 55 years. 2 City Council awarded the 525 E. Charleston/Mitchell Park Place project $1.5 million of the City’s 2022 Local Housing Trust Fund program grant award.3 The $1.5 million in grant funding, plus $1.5 million in local matching funds from Residential Housing In-Lieu Fund (Fund 233) were disseminated to the project.4 Therefore, there is a remaining balance of $1.9 million from the 1 City Council City Manager Report ID # 2409-3517; January 21, 2025:
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=2834b4e7-62e3-4bf4-b5a0- 76a52064282e
2 City Council City Manager Report ID # 14300; May 23, 2022:
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-services/long-range- planning/lhtf_14300.pdf
3 City Council City Manager Report ID # 14281; May 23, 2022:
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-services/long-range- planning/lhtf_14281.pdf.
4 City Council City Manager Report ID # 2310-2167; November 27, 2023:
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=e6396253-ac8c-4d66-a41f- eaa569d4b79e.
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City’s 2022 LHTF program grant award and a corresponding $1.9 million remaining balance in City Council designated Local Housing Trust Fund local matching funds in the Residential Housing In-Lieu Fund (Fund 233), Residential Housing Impact Fee Fund (Fund 293), and Commercial Housing Impact Fee Fund (Fund 234).
The Director of Planning and Development Services approved the Major Architectural Review application for a 129-unit 100% Affordable Multi-Family Housing Project at 3001 El Camino Real on June 6, 2023 (application 22PLN-00229). The Director subsequently approved a minor modification to the project on September 19, 2025, to add one additional manager‘s unit with corresponding minor façade changes for the project to be more competitive for Tax Credit Allocation Committee funds (application 25PLN-00002). Additional minor adjustments in unit affordability levels are currently being addressed based upon the updated financials and funding package prepared for the project across all project lenders.
The total development cost for this project is estimated at approximately $126.6 million. In December 2023, the County of Santa Clara awarded $13 million from the 2016 Measure A Affordable Housing Bond and allocated 42 Section 8 Project-Based Vouchers to the project. A year later, in December 2024, the County increased its funding commitment to $16 million. On January 21, 2025, City Council awarded a conditional funding commitment of $5 million to the 3001 El Camino Real 100% Affordable Multi-Family Housing Project, which was also found to be a LHTF qualifying project.
ANALYSIS
Since the project’s original entitlement in 2023 and City Council’s $5 million conditional funding award in January 2025, Charities Housing and partners applied for additional funding sources, refined the operations and financials for the project, and staff have participated in project funding meetings.
Charities Housing will construct a new five-story, multifamily rental apartment building. The project includes a unit mix of studios, one-bedroom, two-bedroom, and three-bedroom units in addition to amenity space (community room and common open space). The project description for the 3001 El Camino Real 100% Affordable Multi-Family Housing Project remains generally consistent with what was proposed at the time that City Council made its funding commitment.
Modifications to the project subsequent to City Council’s conditional funding award are described below:
a. The project was originally entitled to contain 129 units, but a unit was added under application 25PLN-00002, bringing the total unit count to 130 units. Two units will be unrestricted property manager units and the remaining 128 units will be deed restricted affordable housing.
b. At the time of City Council’s conditional funding award in January 2025, the project included at least 45% of the project units (58 units) with a preference for households experiencing or at risk of homelessness. These were comprised of 26 Homeless Item 7
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Prevention System (HPS) units and 32 Rapid Rehousing (RHH) units. Subsequently, Charities Housing determined it would be unable to provide the 26 HPS units due to operational and financial constraints. However, the project is still able to provide at least 25% of the project units (32 units offered at 30% AMI) as Rapid Rehousing (RRH) units for transitionally homeless individuals, which would be allocated through the Countywide Rapid Rehousing program.
c. Charities Housing needs to make minor adjustments in unit affordability levels based upon updated financials and the funding package prepared for the project across all project lenders. Table 1 summarizes these proposed adjustments. The maximum rent for each household remains at 30% of a household’s income. The average affordability for the project was 39.9% AMI when entitled in June 2023, went down to 38% AMI when City Council made its conditional funding award in January 2025, and the project currently proposes an average affordability of 40.39% AMI. Although 25 units would now be restricted at 60% AMI under the proposed affordability levels, City staff supports these minor affordability adjustments because the applicant has expressed that they are necessary for the purposes of funding the operation of the project and because more 2- bedroom and 3-bedroom units would now be restricted at 30% AMI than at entitlement and when City Council made its conditional funding award.
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Table 1: 3001 El Camino Real 100% Affordable Multi-Family Housing Project Unit Mix and Affordability Levels
Table 1: 3001 El Camino Real 100% Affordable Multi-Family Housing Project Unit Mix and Affordability Levels
Unit Type AMI %
June
2023
Entitlement
22PLN-00229
(units)
January
2025
Conditional
Funding Award
(units)
November
2025
Proposed
Affordability
Adjustments
(units)
Studio 30% 15 22 12
1BR 30% 25 20 12
2BR 30% 12 15 20
3BR 30% 10 15 20
Sub-Total 30% 62 72 64
Studio 40% 0 2 6
1BR 40% 0 5 6
2BR 40% 0 7 4
3BR 40% 0 7 4
Sub-Total 40% 0 21 20
Studio 50% 5 0 4
1BR 50% 15 7 7
2BR 50% 23 7 4
3BR 50% 22 7 4
Sub-Total 50% 65 21 19
Studio 60% 0 0 2
1BR 60% 0 8 15
2BR 60% 0 3 4
3BR 60% 0 3 4
Sub-Total 60% 0 14 25
2BR-
Manager
Unit
Unrestricted 0 1 1
3BR-
Manager
Unit
Unrestricted 2 1 1
TOTAL 129 130 130
Average
Affordability: 39.9% 38% 40.39%
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The terms of the loan and other necessary documents for 3001 El Camino Real are still in the process of finalization, including review by HCD. However, according to the Affordable Housing Funding Guidelines, the typical loan terms included in the loan and other documents are a 3% interest rate, deferred, residual receipts, and a 55-year term loan. Underwriting and other LHTF-specific requirements are incorporated into the loan documents and the City’s regulatory agreements for the project. The promissory note contains the obligation to repay the $5 million with 3% interest per annum.
Regardless of the negotiation regarding the establishment of preferences and the adjustments in the affordability levels in the unit mix, staff has confirmed that the proposed dissemination of HCD LHTF funding ($1.9 million) and local matching LHTF funding ($1.9 million) will be directed to accomplish City Council’s requirement of a minimum of 30% of total LHTF funds toward extremely low-income units (at/below 30% AMI) and a maximum of 70% of total LHTF funds toward low-income units (at/below 60% AMI).
POLICY IMPLICATIONS
The funding award by City Council in January 2025 to support the 3001 El Camino Real affordable housing project assisted with advancing the City's Housing Element program implementation objectives, including:
Program 2.1 Affordable Housing Development regarding partnering with a housing developer to provide housing for homeless, large families, and low-income persons; Program 6.2 Family Housing and Large Units due to the number of 3-bedroom units that City funding will assist; and
Program 6.6 Fair Housing Impediments regarding the project being mixed-income project located in a high opportunity and resource rich area.
FISCAL/RESOURCE IMPACT
It is now timely for City Council to undertake budget amendment actions that would allow disbursement of City Council’s previous funding commitment to the 3001 El Camino Real 100% Affordable Multi-Family Housing Project. These Council actions would complete the internal budgeting process to fund this project.
The staff recommended actions do not involve any new fiscal or resource impact to the funding commitment already made by City Council on January 21, 2025. The budget appropriations described in this report will exhaust all the remaining $1.9 million in City Council designated Local Housing Trust Fund local matching funds from the Residential Housing In-Lieu Fund (Fund 233) ($500,000), Residential Housing Impact Fee Fund (Fund 293) ($400,000), and Commercial Housing Impact Fee Fund (Fund 234) ($1,000,000), as well as fully exhaust the remaining balance from the City’s 2022 Local Housing Trust Fund (LHTF) award from HCD ($1,900,000).
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The budget actions would also further reduce the Commercial Housing Impact Fee Fund (Fund 234) balance by $1.2 million to $2.4 million.9
STAKEHOLDER ENGAGEMENT
The 3001 El Camino Real 100% Affordable Multi-Family Housing Project was reviewed at public hearings before the Architectural Review Board in 2022 and 2023, prior to entitlement. The project also applied for funding under the City’s September 2024 Notice of Funding Availability.
Applications were reviewed in December 2024 by the Housing Ad-Hoc Council Committee and City Council held a public hearing on the recommendation for action on the applications and a conditional funding award for the project on January 21, 2025.
ENVIRONMENTAL REVIEW
The commitment of funds does not qualify as a project in accordance with the California Environmental Quality Act (CEQA). For the project entitlement process, the project was reviewed under CEQA. A Draft Mitigated Negative Declaration (MND) was circulated for the project for a 30-Day public review period beginning on February 13, 2023, and ending March 15, 2023. A Final MND was made available on April 27, 2023. The project was approved on June 6, 2023, under application 22PLN-00229. Minor modifications to the project were approved on September 19, 2025, under application 25PLN-00002; the minor modifications did not affect the findings of the previously approved CEQA analysis. The additional minor adjustments in unit affordability levels would similarly not affect the findings of the previously approved CEQA analysis.
APPROVED BY:
Jonathan Lait, Planning and Development Services Director 9 After City Council made its conditional funding award of $5 million to the 3001 El Camino Real project, the corresponding amounts in Fund 233, Fund 293, and Fund 234 were committed for the project. These amounts already specified for 3001 El Camino Real are not included in recent reporting to City Council in the October 22, 2025, City Manager Report #2505-4745 of available fund balances for potential affordable housing at Lot T.
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Utilities
Meeting Date: November 3, 2025
Report #:2506-4867
TITLE
Approval of Professional Services Contract Number C26194191 with TJC and Associates, Inc. in the Amount Not-to-Exceed $242,483 for Dahl & Park Reservoirs Structural Evaluation and Condition Assessment. CEQA Status – Exempt Under CEQA Guidelines Sections 15061(b)(2) and (b)(3).
RECOMMENDATION
Staff recommends that City Council approve and authorize the City Manager or their designee to execute Contract Number C26194191 (Attachment A) with TJC and Associates Inc. for Dahl & Park Reservoirs Structural Evaluation and Condition Assessment for a term of three years and a total, not-to-exceed amount of $242,483, including $232,483 for basic services and $10,000 for additional services.
EXECUTIVE SUMMARY
The City of Palo Alto’s Water Tank Seismic Upgrade and Rehabilitation (WS-09000) projects provide proactive rehabilitation, seismic upgrades, and replacement of the City’s aging water storage tank infrastructure. Since 2010, five of the City’s seven drinking water storage reservoirs have been seismically retrofitted, rehabilitated, or newly constructed. The two remaining tanks, Dahl Reservoir and Park Reservoir, are currently included in the Water Tank Seismic Upgrade and Rehabilitation (WS-09000) budget for engineering inspections and seismic assessment, with potential replacements planned for FY 2029 and FY 2030. To support the upcoming design phase for the Dahl and Park Tank project and a pending grant application, staff seek to retain professional services to perform a condition assessment, which includes seismic assessment and conceptual level improvements with estimated construction costs. The contract with TJC and Associates, Inc. includes the necessary engineering seismic analysis to inform you of the full design and provide the information required by the state’s 2025 Hazard Mitigation Grant Program, which may provide up to $6,000,000 in grant funding for the project.
BACKGROUND
The City of Palo Alto (City) owns and maintains two welded steel, potable water storage tanks called Park Reservoir and Dahl Reservoir, located in the Palo Alto foothills area near Page Mill Item 8
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Road. The tanks are 61 years old and require seismic retrofits, roof replacement, new coating, modifications to vents, and other miscellaneous improvements and repairs. Both reservoirs are one million gallon tanks, serving residential customers on Page Mill Road and in the Los Trancos area. The tank sites are located in the Palo Alto Foothills, approximately 4.5 miles south of Interstate 280 off Page Mill Road. While both tanks have been tentatively programmed for full replacement in FY 2029 and FY 2030, seismic retrofitting or other rehabilitation may be feasible, instead of a full tank replacement.
On January 18, 2025, the California Office of Emergency Services invited the City to submit a grant application for this project under the Hazard Mitigation Grant Program. This contract with TJC and Associates provides necessary condition assessment and seismic analysis for the first phase of design for the Dahl and Park Reservoir Seismic Upgrade and Rehabilitation project and for the Hazard Mitigation Grant Program application for up to a $6,000,000 grant.
ANALYSIS
The Dahl and Park Water Storage Reservoirs are the last two drinking water storage tanks in the water utility system that have not been rebuilt, rehabilitated, or seismically retrofitted, under the Water Tank Seismic Upgrade and Rehabilitation (WS-09000) projects. Both tanks were designed prior to modern seismic design codes and require a seismic analysis and hazard evaluation to support grant funding opportunities and future retrofit or replacement.
Solicitation Process
On November 6, 2023, staff posted a formal request for proposals (RFP) for the project on OpenGov, the City’s eProcurement platform, for professional consulting services for the Engineering Design of Park & Dahl Tank, PR# 1890411. The project consisted of three phases: 1) Condition Assessment; 2) Design; and 3) Engineering Services During Construction. The solicitation period was posted for 102 days. 47 proposal packages were downloaded however no proposals were received. Four potential proposers attended a pre-proposal meeting, some expressed concerns to deliver the complexity of the scope with their current staffing. The solicitation closed on February 16, 2024.
Therefore, Staff solicited a negotiated scope and fee with TJC and Associates, as permitted by section 2.30.360(c) of the City’s municipal code, to complete the condition assessment for the project to support grant funding and identify cost saving opportunities. Staff evaluated TJC and Associates’ qualifications and determined the firm qualified for the first phase of the project with sufficient capacity and proper engineering licenses to render the services. Results of the Condition Assessment Project Phase (1) will inform the final design and improvements phases of the Water Tank Seismic Upgrade and Rehabilitation (WS-09000) project. 1 Public Link to Solicitation: https://procurement.opengov.com/portal/palo-alto-ca/projects/67117/ Item 8
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FISCAL/RESOURCE IMPACT
Funding for the contract is funded through the Fiscal Year 2026 Adopted Water Tank Seismic Upgrade and Rehabilitation (WS-09000) Capital Project.
STAKEHOLDER ENGAGEMENT
The key stakeholders for this project include the Utilities Department, Fire Department, Office of Emergency Services, and Administrative Services. Engagement strategies include coordination meetings among various City departments and working groups involved with hazard mitigation, grant funding, and infrastructure planning.
ENVIRONMENTAL REVIEW
Council action on this item is exempt from California Environmental Quality Act (CEQA) review under sections 15061(b)(2) and (b)(3) because the proposed actions to assess conditions and prepare a seismic analysis have no potential to result in physical impacts on the environment and because the Dahl and Park Tanks project, which the proposed action relates to, was previously evaluated under CEQA prior to approval and was found to be categorically exempt under CEQA Guidelines Section 15301 (repair, maintenance, or minor alteration of existing public facilities involving negligible or no expansion of existing or former use) and Section 15302 (replacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity).
ATTACHMENTS
Attachment A: TJC and Associates, Contract C26194191
APPROVED BY:
Alan Kurotori, Director Utilities
Staff: Patrick LaBruzzo P.E., Principal Engineer, Water, Gas and Wastewater Engineering Item 8
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Professional Services
Rev. Oct 16,2024