City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: March 2, 2026
Report #:2512-5618
TITLE
Authorize Transmittal of the 2025 Comprehensive Plan Annual Progress Report to the Governor’s Office of Land Use and Climate Innovation and the 2025 Housing Element Annual Progress Report to the Department of Housing and Community Development. CEQA Status: Not a Project.
RECOMMENDATION
The Planning and Transportation Commission and staff recommend City Council review the following state-mandated Annual Progress Reports and direct staff to submit them to the appropriate state authorities by April 1, 2026:
1. 2025 Comprehensive Plan Annual Progress Report (Attachment A) to the Governor’s Office of Land Use and Climate Innovation (LCI); and
2. 2025 Housing Element Annual Progress Report (Attachments B and C) to the Department of Housing and Community Development (HCD).
EXECUTIVE SUMMARY
This report provides an update on the status of the 410 implementation programs contained in the 2030 Comprehensive Plan (Comp Plan) and the 110 implementation program objectives in the City Council adopted 2023-2031 Housing Element (Housing Element), a chapter of the Comp Plan. The City is required to submit a progress report on the implementation progress of the Comp Plan and Housing Element annually by April 1.
With the program status updates in 2025, a total of 28 (7%) of the 410 Comp Plan programs have been, or are now complete, and 293 (71%) are considered ongoing tasks, which generally are not expected to become complete. The remaining 89 (22%) of the programs, the partially complete and pending programs, still need to be completed. Refer to Attachment A for the list of all programs and their status.
For the Housing Element Implementation Programs, a total of 31 (28%) of the 110 programs have been completed, and 46 (42%) are considered ongoing tasks. The remaining 33 (30%) programs are either currently making progress to be completed (“In Progress”) or have not started yet (“Pending”). Refer to Attachment B for the list of all programs and their status.
On November 12, 2025, the Planning and Transportation Commission (PTC) reviewed the statuses of the Comp Plan and Housing Element programs and unanimously recommended that the City Council authorize the transmittal of the annual reports to the relevant state entities by April 1, 2026.
BACKGROUND
This Annual Progress Report (APR) is for the eighth year of annual reporting since the adoption of the 2030 Comprehensive Plan in 2017 and for the third year of the 6th Cycle Housing Element. The City Council reviewed the 2024 annual reports on February 24, 2025.1 The PTC reviewed and recommended the 2025 APRs on November 12, 2025.2 Comprehensive Plan Implementation Annual Progress Report The Comprehensive Plan Implementation APR is a state mandated report, required by Government Code Section 654003, and submittal is due by April 1 each year. The Government Code states that after a legislative body (City Council) adopts the Comp Plan, an annual review must be submitted to the City Council, the Office of Land Use and Climate Innovation (LCI, formerly called the Office of Planning and Research, or OPR), and the Department of Housing and Community Development (HCD) on the status of the plan’s progress in implementing programs. In addition to the state mandated annual reporting, the Palo Alto Municipal Code Section 19.04.0303 specifies that the PTC shall annually review the Comprehensive Plan, “and recommend to the City Council such extensions, changes or additions to the plan as the commission may consider necessary in the view of any change in conditions.” The PTC did not recommend any extensions, changes, or additions to the plan this year.
Housing Element Annual Progress Report
HCD requires an APR addressing the City’s progress in implementing the Housing Element. The report is due by April 1 each year. The report includes data on housing production and accomplishments toward the City’s Regional Housing Needs Allocation (RHNA) goals. The Housing Element APR for 20244 reflected the second year of the 6th Cycle 2023-2031 Housing Element that was readopted by City Council on April 15, 2024, and certified by HCD on August 1 City Council Hearing Agenda on February 24, 2025 (Item 3 under Consent Calendar):
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=15969 2 Planning and Transportation Commission Hearing Agenda on November 12, 2025 (Item 2 under Action Items):
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16610 3 Palo Alto Municipal Code Section 19.04.030:
https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-82254 4 City of Palo Alto 2024 Housing Element APR: https://www.paloalto.gov/files/assets/public/v/1/planning- ampdevelopment-services/housing-element/housing-element_2023_2031/paloalto2024_revised.pdf 20, 2024. Staff are preparing the 2025 Housing Element APR following the standard requirements (refer to Attachment B). HCD requires that the APR for the Housing Element focus on three topics:
Total number of net housing units produced or “permitted” by the City in a calendar year;
Status of jurisdiction’s progress in addressing its Regional Housing Needs Allocation (RHNA); and
Status of the implementation of the Housing Element’s programs and goals.
Planning and Transportation Commission Review
On November 12, 2025, the PTC reviewed the Comp Plan and Housing Element Implementation Programs. The PTC’s questions ranged from the procedural review schedule, to specific staffing needs required to move forward with the implementation of pending programs. The PTC unanimously approved staff’s recommendation to present the year-end statuses of the programs to the City Council in 2026.
ANALYSIS
This section provides an overview of the draft APRs for the Comp Plan and adopted Housing Element and provides high-level summaries of the related data. Refer to Attachments A and B for details.
Comprehensive Plan Program Implementation Reporting
The Comp Plan is intended to be a living document, to grow and evolve as local conditions change. The role of PTC is to review the Comp Plan programs annually and recommend to the City Council any modifications that it considers necessary. All amendments require public hearings by the PTC and City Council and evaluation of the potential impacts on Palo Alto’s physical environment, in accordance with the California Environmental Quality Act (CEQA).
According to the Comp Plan, the PTC may recommend changing priorities or adding or subtracting programs in the course of their annual review, and staff may likewise recommend prioritization or funding during the annual budget process.
Attachment A provides detailed status summaries of the 410 programs. It contains:
The Comp Plan program text;
The lead department responsible for overseeing the program; The target completion date of the program at the time of Comp Plan adoption in 2017; The level of effort required to accomplish the program; and The current status of the program as assessed by the City departments.
Staff were asked to use the “Staff Comments” field to discuss:
Why some programs may be shown as pending;
Current program status relative to target completion date; Changes in completion status from the prior year; or
Any changes in level of effort required to complete a program.
If no such staff comments were provided for particular program, this has been noted.
City staff assessed the implementation programs of the Comp Plan and reported on the following three aspects:
1. Completion Status
Staff have categorized programs as follows:
Complete: Program implemented; tasks complete; no follow-up needed. Partially Complete: Program implementation tasks in progress; or programs with some, but not all, components completed.
Ongoing: Program activities ongoing as standard business practice. Pending: Program implementation not started.
The table below indicates how many programs fall into each of these categories as of December 2025 and compares this to the status at the end of 2024.
Table 1: Completion Status of the Comprehensive Plan Programs (as of December 2025) Status
Number of
Programs,
2024
Number of
Programs,
2025
Percent
Total,
2025
Complete 17 28 7%
Ongoing 291 293 71%
Partially Complete 52 48 12%
Pending 50 41 10%
Total 410 410 100%
2. Target Completion Date at Time of Comp Plan Adoption Comp Plan Implementation Programs priorities were identified in 2017 when the Plan was adopted. These priorities correlated to the timeframe within which the programs should be completed.
Table 2. Completion Status of the Comprehensive Plan Programs by Target Completion Date (as of December 2025)
Target Completion
Date
Complete Ongoing Partially
Complete
Pending Total
By 2022 11 66 13 7 97
2022-2027 8 41 25 19 93
After 2027 2 3 2 4 11
Continuous 7 183 8 11 209
Total Programs 28 293 48 41 410
3. Level of Effort Required to Complete
For each Comp Plan program, the level of effort for program implementation is assessed annually. The level of effort reflects the magnitude and complexity of the program in terms of project size (e.g., small, medium, or large), required staffing, departmental planning, interdepartmental or cross jurisdictional involvement, and overall financial cost. For the purposes of Comp Plan program annual reporting the following level of effort categories are identified:
Standard: Relatively lower level of effort to complete; can likely be accomplished with existing resources.
Significant: Moderate level of effort required to complete; may require some additional resources.
Substantial: High level of effort required to complete; very likely to require additional staffing, financial or other resources.
Program completion information is grouped in the table below according to the level of effort required to complete the implementation of each program.
Table 3. Completion Status of the Comprehensive Plan Programs by Level of Effort for Programs Not Yet Completed (as of December 2025)
Level of Effort to
Complete Ongoing Partially
Complete Pending
Standard 182 13 17
Significant 76 26 19
Substantial 35 9 5
Total Programs 293 48 41
4. Changes from 2024
A new field was added to the Comp Plan Program Implementation Status table to identify changes from the previous reporting year. The last column, "Changes from 2024," identifies any changes made this year to the 2024 Level of Efforts, Status, and/or Staff Comments.
Housing Element Programs Status
The current 2023-2031 Housing Element, which is the 6th cycle, was approved and adopted by the City Council on April 15, 2024, and certified by the HCD on August 20, 2024.
The adopted Housing Element has 110 implementation program objectives that address a range of initiatives to support housing development in the City. At this time, considerable progress has been made on program implementation as shown in Table 4, and as provided in Attachment B.
1. Completion Status
Staff have categorized the status of Housing Element implementation programs as follows:
Complete: Program implemented; tasks complete; no follow-up needed. In Progress: Program implementation tasks in progress; or programs with some, but not all, components completed.
Ongoing: Program activities ongoing as standard business practice. Pending: Program implementation not started.
Table 4. Completion Status of Housing Element Implementation Programs Status Number of
Programs, 2025
Percent Total,
2025
Complete 31 28%
In Progress 27 25%
Ongoing 46 42%
Pending 6 5%
Total 110 100%
2. 2025 Achievements Towards 2023-2031 RHNA
For the 2023-2031 RHNA, the City’s allocation is 6,086 units. Table 5 below shows City’s progress in housing production as of December 2025.
Table 5. Progress Towards 2023-2031 RHNA (as of December 2025) Income Level 2023-2031
RHNA
(by income
level)
Total Units
permitted as
of December
2025
Total
Remaining
RHNA
% of RHNA
Permitted
Extremely Low Income 778 16 762 2.06%
Very Low Income 778 25 753 3.21%
Low Income 896 47 849 5.25%
Moderate 1,013 80 933 7.90%
Above Moderate 2,621 456 2,165 17.40%
Total 6,086 624 5,462 10.25%
By end of December 2025, the City issued building permits for 624 units. Approximately 73% of these units were in Above Moderate-Income category.
FISCAL/RESOURCE IMPACT
There is no resource impact from the presentation of this information. Staff time to prepare and submit reports was contemplated in the allocation of resources to the departments. The Comprehensive Plan is the primary tool for guiding development in Palo Alto and reflects community values. The Comprehensive Plan’s goals and policies reflect the community’s priorities regarding land use, circulation, conservation, housing, open space, business and economics, and safety. Advancing those efforts is expected to have a net positive impact on revenue bases through sales and property taxes, new development, and other revenue streams.
STAKEHOLDER ENGAGEMENT
The public had an opportunity to comment on the draft APR reports during the PTC hearing held on November 12, 2025. There were no public speakers for this item. The Palo Alto Municipal Code requires the publication of a notice of this public hearing in a local paper at least ten days in advance of the meeting. Public notice for both City Council and PTC hearings were published at least 10 days before the hearing dates per Gov Code Section 65090. Staff did not conduct any specific community outreach for this item.
ENVIRONMENTAL REVIEW
The review and comment on the draft 2025 Comprehensive Plan Implementation Annual Progress Report and draft 2023-2031 Housing Element Annual Progress Report is not considered a project requiring review under the California Environmental Quality Act (CEQA).
ATTACHMENTS
Attachment A: Comprehensive Plan Implementation Program Status, 2025 Attachment B: 2023-2031 Housing Element Implementation Programs, 2025 Attachment C: City’s RHNA Progress, 2025
APPROVED BY:
Jonathan Lait, Planning and Development Services Director