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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
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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
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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 8 1
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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/ 8 1
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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