Palo Alto City Council
March 9, 2026

described in the approved work plan in accordance with 2 CFR 200.308.

12. Obtain the written approval of EPA’s Award Official prior to awarding a subaward to an individual if the EPA-approved scope of work does not include a description of subawards to individuals.

13. Establish and follow written procedures under 2 CFR 200.302(b)(7) for determining that subaward costs are allowable in accordance with 2 CFR Part 200, Subpart E and the terms and conditions of this award.

These procedures may provide for allowability determinations on a pre-award basis, through ongoing monitoring of costs that subrecipients incur, or a combination of both approaches provided the pass-through entity documents its determinations.

14. Establish and maintain a system under 2 CFR 200.332(d)(3) and 2 CFR 200.521 for issuing management decisions for audits of subrecipients that relate to Federal awards. However, the recipient remains accountable to EPA for ensuring that unallowable subaward costs initially paid by EPA are reimbursed or mitigated through offset with allowable costs whether the recipient recovers those costs from the subrecipient or not.

15. As provided in 2 CFR 200.333, pass-through entities must obtain EPA approval to make fixed amount subawards. EPA is restricting the use of fixed amount subawards to a limited number of situations that are authorized in official EPA pilot projects. Recipients should consult with their EPA Project Officer regarding the status of these pilot projects.

By accepting this award, the recipient is certifying that it either has systems in place to comply with the requirements described in Items 1 through 14 above or will refrain from making subawards until the systems are designed and implemented.

9. Management Fees
Management fees or similar charges in excess of the direct costs and approved indirect rates are not allowable.

The term "management fees or similar charges" refers to expenses added to the direct costs in order to accumulate and reserve funds for ongoing business expenses; unforeseen liabilities; or for other similar costs which are not allowable under this assistance agreement. Management fees or similar charges may not be used to improve or expand the project funded under this agreement, except to the extent authorized as a direct cost of carrying out the scope of work.

10. Federal Employee Costs
The recipient understands that none of the funds for this project (including funds contributed by the recipient as cost sharing) may be used to pay for the travel of Federal employees or for other costs associated with Federal participation in this project unless a Federal agency will be providing services to the recipient as authorized by a Federal statute.

11. Foreign Travel
EPA policy requires that all foreign travel must be approved by its Office of International and Tribal Affairs. The recipient agrees to obtain prior EPA approval before using funds available under this agreement for international travel unless the trip(s) are already described in the EPA approved budget for this agreement. Foreign travel includes trips to Mexico and Canada but does not include trips to Puerto Rico, the U.S. Territories or possessions. Recipients that request post-award approval to travel frequently to Mexico and Canada by motor vehicle (e.g. for sampling or meetings) may describe their proposed travel in general terms in their request for EPA approval. Requests for prior approval must be submitted to the Project Officer for this agreement.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
59 Packet Pg. 122 of 291

12. The Fly America Act and Foreign Travel
The recipient understands that all foreign travel funded under this assistance agreement must comply with the Fly America Act. All travel must be on U.S. air carriers certified under 49 U.S.C. Section 40118, to the extent that service by such carriers is available even if foreign air carrier costs are less than the American air carrier.

13. Combating Race and Sex Stereotyping (Added December 9, 2020) By accepting this award, the recipient certifies that no federal funds awarded, or funds used to satisfy a cost share requirement, for this assistance agreement will be used to promote the concepts (including by conducting research premised upon these concepts) identified in Section 5 of the Executive Order on Combating Race and
Sex Stereotyping issued on September 22, 2020.

Reporting and Additional Post-Award Requirements

14. System for Award Management and Universal Identifier Requirements

14.1. Requirement for System for Award Management (SAM) Unless exempted from this requirement under 2 CFR 25.110, the recipient must maintain current information in the SAM. This includes information on the recipient’s immediate and highest level owner and subsidiaries, as well as on all the recipient’s predecessors that have been awarded a Federal contract or Federal financial assistance within the last three years, if applicable, until the submittal of the final financial report required under this award or receipt of the final payment, whichever is later. This requires that the recipient reviews and updates the information at least annually after the initial registration, and more frequently if required by changes in the information or another award term.

14.2. Requirement for Unique Entity Identifier. If the recipient is authorized to make subawards under this award, the recipient:
a. Must notify potential subrecipients that no entity (see definition in paragraph 14.3 of this award term) may receive a subaward unless the entity has provided its Unique Entity Identifier. b. May not make a subaward to an entity unless the entity has provided its Unique Entity Identifier.

Subrecipients are not required to obtain an active SAM registration, but must obtain a Unique Entity Identifier.

14.3. Definitions. For the purposes of this award term:
a. System for Award Management (SAM) means the Federal repository into which an entity must provide information required for the conduct of business as a recipient. Additional information about registration procedures may be found at the SAM Internet site:
https://www.sam.gov/SAM/.
b. Unique Entity Identifier means the identifier assigned by SAM to uniquely identify business entities.
c. Entity includes non-Federal entities as defined at 2 CFR 200.1 and also includes all of the following:

14.3.c.1. A foreign organization;

14.3.c.2. A foreign public entity;

14.3.c.3. A domestic for-profit organization; and

14.3.c.4. A domestic or foreign for-profit organization; and

14.3.c.5. A Federal agency.
d. Subaward is defined at 2 CFR 200.1.
e. Subrecipient is defined at 2 CFR 200.1.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
60 Packet Pg. 123 of 291

15. Reporting Subawards and Executive Compensation

15.1. Reporting of first-tier subawards.
a. Applicability. Unless the recipient is exempt as provided in paragraph 15.4. of this award term, the recipient must report each action that obligates $30,000 or more in Federal funds for a subaward to a non-Federal entity or Federal agency (see definitions in paragraph 15.5 of this award term).
b. Where and when to report. (1) The recipient must report each obligating action described in paragraph 15.1.a of this award term to www.fsrs.gov. (2) For subaward information, report no later than the end of the month following the month in which the obligation was made. (For example, if the obligation was made on any date during the month of November of a given year, the obligation must be reported by no later than December 31 of that year.) c. What to report. The recipient must report the information about each obligating action as described in the submission instructions available at: http://www.fsrs.gov.

15.2. Reporting Total Compensation of Recipient Executives. a. Applicability and what to report. The recipient must report total compensation for each of their five most highly compensated executives for the preceding completed fiscal year, if:

15.2.a.1. the total Federal funding authorized to date under this award is $30,000 or more;

15.2.a.2. in the preceding fiscal year, the recipient received: (i.) 80 percent or more of their annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards); (ii.) and $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards); and

15.2.a.3. The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine if the public has access to the compensation information, see the U.S. Security and Exchange Commission total compensation filings at: http:// www.sec.gov/answers/execomp.htm. )
b. Where and when to report. The recipient must report executive total compensation described in paragraph 15.2.a of this award term: (i.) As part of the registration Central System for Award Management profile available at https://www.sam.gov/SAM/ (ii.) By the end of the month following the month in which this award is made, and annually thereafter.

15.3. Reporting of Total Compensation of Subrecipient Executives. a. Applicability and what to report. Unless exempt as provided in paragraph 15.4. of this award term, for each first-tier non-Federal entity subrecipient under this award, the recipient shall report the names and total compensation of each of the subrecipient’s five most highly compensated executives for the subrecipient’s preceding completed fiscal year, if:

15.3.a.1. in the subrecipient's preceding fiscal year, the subrecipient received: (i.) 80 percent or more of its annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards); and (ii.) $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts), and Federal financial assistance subject to the Transparency Act (and subawards); and

15.3.a.2. The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine if the public has access to the compensation information, see the U.S. Security and Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
61 Packet Pg. 124 of 291

Exchange Commission total compensation filings at:
http://www.sec.gov/answers/execomp.htm.)
b. Where and when to report. The recipient must report subrecipient executive total compensation described in paragraph 15.3.a. of this award term:

15.3.b.1. To the recipient.

15.3.b.2. By the end of the month following the month during which the recipient makes the subaward. For example, if a subaward is obligated on any date during the month of October of a given year (i.e., between October 1 and 31), the recipient must report any required compensation information of the subrecipient by November 30 of that year.

15.4. Exemptions
a. If, in the previous tax year, the recipient had gross income, from all sources, under $300,000, the recipient is exempt from the requirements to report:

15.4.a.1. (i) subawards, and (ii) the total compensation of the five most highly compensated executives of any subrecipient.

15.5. Definitions. For purposes of this award term:
a. Federal agency means a Federal agency as defined at 5 U.S.C. 551(1) and further clarified by 5 U.S.C 552(f).
b. Non-Federal entity means all of the following, as defined in 2 CFR Part 25: (i.) A Governmental organization, which is a State, local government, or Indian tribe; (ii.) A foreign public entity; (iii.) A domestic or foreign nonprofit organization; and (iv.) A domestic or foreign for-profit organization. c. Executive means officers, managing partners, or any other employees in management positions. d. Subaward:

15.5.d.1. This term means a legal instrument to provide support for the performance of any portion of the substantive project or program for which you received this award and that you as the recipient award to an eligible subrecipient.

15.5.d.2. The term does not include procurement of property and services needed to carry out the project or program (for further explanation, see 2 CFR 200.331).

15.5.d.3. A subaward may be provided through any legal agreement, including an agreement that the recipient or a subrecipient considers a contract.
e. Subrecipient means a non-Federal entity or Federal agency that:

15.5.e.1. Receives a subaward from the recipient under this award; and

15.5.e.2. Is accountable to the recipient for the use of the Federal funds provided by the subaward. f. Total compensation means the cash and noncash dollar value earned by the executive during the recipient’s or subrecipient’s preceding fiscal year and includes the following (for more information see 17 CFR 229.402(c)(2)):

15.5.f.1. Salary and bonus.

15.5.f.2. Awards of stock, stock options and stock appreciation rights. Use the dollar amount recognized for financial statement reporting purposes with respect to the fiscal year in accordance with the Statement of Financial Accounting Standards No. 123 (Revised 2004) (FAS 123R), Shared Based Payments.

15.5.f.3. Earnings for services under non-equity incentive plans. This does not include group life, health, hospitalization or medical reimbursement plans that do not discriminate in favor of executives, and are available generally to all salaried employees.

15.5.f.4. Change in pension value. This is the change in present value of defined benefit and actuarial pension plans.

15.5.f.5. Above-market earnings on deferred compensation which is not tax-qualified.

15.5.f.6. Other compensation, if the aggregate value of all such other compensation (e.g. severance, termination payments, value of life insurance paid on behalf of the employee, perquisites or property) for the executive exceeds $10,000.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
62 Packet Pg. 125 of 291

16. Recipient Integrity and Performance Matters - Reporting of Matters Related to Recipient Integrity and Performance

16.1. General Reporting Requirement
If the total value of your currently active grants, cooperative agreements, and procurement contracts from all Federal awarding agencies exceeds $10,000,000 for any period of time during the period of performance of this Federal award, then you as the recipient during that period of time must maintain the currency of information reported to the System for Award Management (SAM) that is made available in the designated integrity and performance system (currently the Federal Awardee Performance and Integrity Information System (FAPIIS)) about civil, criminal, or administrative proceedings described in paragraph 2 of this award term and condition. This is a statutory requirement under section 872 of Public Law 110- 417, as amended (41 U.S.C. 2313). As required by section 3010 of Public Law 111-212, all information posted in the designated integrity and performance system on or after April 15, 2011, except past performance reviews required for Federal procurement contracts, will be publicly available.

16.2. Proceedings About Which You Must Report
Submit the information required about each proceeding that:
a. Is in connection with the award or performance of a grant, cooperative agreement, or procurement contract from the Federal Government;
b. Reached its final disposition during the most recent five-year period; and c. Is one of the following:

16.2.c.1. A criminal proceeding that resulted in a conviction, as defined in paragraph 5 of this award term and condition;

16.2.c.2. A civil proceeding that resulted in a finding of fault and liability and payment of a monetary fine, penalty, reimbursement, restitution, or damages of $5,000 or more;

16.2.c.3. An administrative proceeding, as defined in paragraph 5. of this award term and condition, that resulted in a finding of fault and liability and your payment of either a monetary fine or penalty of $5,000 or more or reimbursement, restitution, or damages in excess of $100,000; or

16.2.c.4. Any other criminal, civil, or administrative proceeding if:

16.2.c.4.1. It could have led to an outcome described in paragraph 16.2.c.1, 16.2.c.2, or 16.2.c.3 of this award term and condition;

16.2.c.4.2. It had a different disposition arrived at by consent or compromise with an acknowledgment of fault on your part; and

16.2.c.4.3. The requirement in this award term and condition to disclose information about the proceeding does not conflict with applicable laws and regulations.

16.3. Reporting Procedures
Enter in the SAM Entity Management area the information that SAM requires about each proceeding described in paragraph 2 of this award term and condition. You do not need to submit the information a second time under assistance awards that you received if you already provided the information through SAM because you were required to do so under Federal procurement contracts that you were awarded.

16.4. Reporting Frequency
During any period of time when you are subject to the requirement in paragraph 16.1 of this award term and condition, you must report proceedings information through SAM for the most recent five year period, either to report new information about any proceeding(s) that you have not reported previously or affirm that there is no new information to report. Recipients that have Federal contract, grant, and cooperative agreement awards with a cumulative total value greater than $10,000,000 must disclose semiannually any information about the criminal, civil, and administrative proceedings.

16.5. Definitions
For purposes of this award term and condition:
a. Administrative proceeding means a non-judicial process that is adjudicatory in nature in order to make a determination of fault or liability (e.g., Securities and Exchange Commission Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
63 Packet Pg. 126 of 291

Administrative proceedings, Civilian Board of Contract Appeals proceedings, and Armed Services Board of Contract Appeals proceedings). This includes proceedings at the Federal and State level but only in connection with performance of a Federal contract or grant. It does not include audits, site visits, corrective plans, or inspection of deliverables. b. Conviction, for purposes of this award term and condition, means a judgment or conviction of a criminal offense by any court of competent jurisdiction, whether entered upon a verdict or a plea, and includes a conviction entered upon a plea of nolo contendere. c. Total value of currently active grants, cooperative agreements, and procurement contracts includes—

16.5.c.1. Only the Federal share of the funding under any Federal award with a recipient cost share or match; and

16.5.c.2. The value of all expected funding increments under a Federal award and options, even if not yet exercised.

17. Federal Financial Reporting (FFR)
Pursuant to 2 CFR 200.328 and 2 CFR 200.344, EPA recipients must submit the Federal Financial Report (SF-425) at least annually and no more frequently than quarterly. EPA’s standard reporting frequency is annual unless an EPA Region has included an additional term and condition specifying greater reporting frequency within this award document. EPA recipients must submit the SF-425 no later than 30 calendar days after the end of each specified reporting period for quarterly and semi-annual reports and 90 calendar days for annual reports. Final reports are due no later than 120 calendar days after the end date of the period of performance of the award Extension of reporting due dates may be approved by EPA when requested and justified by the recipient. The FFR form is available on the internet at: https://www.epa.gov/financial/forms.

All FFRs must be submitted to the Research Triangle Park Finance Center (RTPFC) via email at rtpfc- [email protected] or mail it to:

US Environmental Protection Agency
RTP-Finance Center (Mail Code AA216-01)
4930 Page Rd.

Durham, NC 27703

The RTPFC will make adjustments, as necessary, to obligated funds after reviewing and accepting a final Federal Financial Report. Recipients will be notified and instructed by EPA if they must complete any additional forms for the closeout of the assistance agreement.

18. Indirect Cost Rate Agreements
This term and condition provides requirements for recipients using EPA funds for indirect costs and applies to all EPA assistance agreements unless there are statutory or regulatory limits on IDCs. See also EPA’s Indirect Cost Policy for Recipients of EPA Assistance Agreements (IDC Policy).

In order for the assistance agreement recipient to use EPA funding for indirect costs, the IDC category of the recipient’s assistance agreement award budget must include an amount for IDCs and at least one of the following must apply:
• With the exception of “exempt” agencies and Institutions of Higher Education as noted below, all recipients must have one of the following current (not expired) IDC rates, including IDC rates that have been extended by the cognizant agency:
• Provisional;
• Final;
• Fixed rate with carry-forward;
• Predetermined;
Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
64 Packet Pg. 127 of 291

• 10% de minimis rate authorized by 2 CFR 200.414(f)
• EPA-approved use of an expired fixed rate with carry-forward on an exception basis, as detailed in section 6.4.a. of the IDC Policy.
• “Exempt” state or local governmental departments or agencies are agencies that receive up to and including $35,000,000 in Federal funding per the department or agency’s fiscal year, and must have an IDC rate proposal developed in accordance with 2 CFR Part 200, Appendix VII, with documentation maintained and available for audit.
• Institutions of Higher Education must use the IDC rate in place at the time of award for the life of the assistance agreement (unless the rate was provisional at time of award, in which case the rate will change once it becomes final). As provided by 2 CFR Part 200, Appendix III(C)(7), the term “life of the assistance agreement”, means each competitive segment of the project. Additional information is available in the regulation.

IDCs incurred during any period of the assistance agreement that are not covered by the provisions above are not
allowable costs and must not be drawn down by the recipient. Recipients may budget for IDCs if they have submitted a proposed IDC rate to their cognizant Federal agency or requested an exception from EPA under subsection 6.4 of the IDC Policy. However, recipients may not draw down IDCs until their rate is approved, if applicable, or EPA grants an exception. IDC drawdowns must comply with the indirect rate corresponding to the period during which the costs were incurred.

This term and condition does not govern indirect rates for subrecipients or recipient procurement contractors under EPA assistance agreements. Pass-through entities are required to comply with 2 CFR 200.332 (a)(4)(i) and
(ii) when establishing indirect cost rates for subawards.

19. Audit Requirements
In accordance with 2 CFR 200.501(a), the recipient hereby agrees to obtain a single audit from an independent auditor, if their organization expends $750,000 or more in total Federal funds in their fiscal year beginning on or after December 26, 2014.

The recipient must submit the form SF-SAC and a Single Audit Report Package within 9 months of the end of the recipient’s fiscal year or 30 days after receiving the report from an independent auditor. The SF-SAC and a Single Audit Report Package MUST be submitted using the Federal Audit Clearinghouse’s Internet Data Entry System available at: https://facides.census.gov/
For complete information on how to accomplish the single audit submissions, you will need to visit the Federal Audit Clearinghouse Web site: https://facweb.census.gov/

20. Closeout Requirements
Reports required for closeout of the assistance agreement must be submitted in accordance with this agreement. Submission requirements and frequently asked questions can also be found at:
https://www.epa.gov/grants/frequent-questions-about-closeouts

21. Suspension and Debarment
Recipient shall fully comply with Subpart C of 2 C.F.R. Part 180 entitled, “Responsibilities of Participants Regarding Transactions Doing Business With Other Persons,” as implemented and supplemented by 2 C.F.R.

Part 1532. Recipient is responsible for ensuring that any lower tier covered transaction, as described in Subpart B of 2 C.F.R. Part 180, entitled “Covered Transactions,” and 2 C.F.R. § 1532.220, includes a term or condition requiring compliance with 2 C.F.R. Part 180, Subpart C. Recipient is responsible for further requiring the inclusion of a similar term and condition in any subsequent lower tier covered transactions. Recipient acknowledges that failing to disclose the information required under 2 C.F.R. § 180.335 to the EPA office that is entering into the transaction with the recipient may result in the delay or negation of this assistance agreement, or pursuance of administrative remedies, including suspension and debarment. Recipients may access the Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
65 Packet Pg. 128 of 291

System for Award Management (SAM) exclusion list at https://sam.gov/SAM/ to determine whether an entity or individual is presently excluded or disqualified.

22. Representation by Corporations Regarding Delinquent Tax Liability or a Felony Conviction under any Federal Law.

This award is subject to the provisions contained in an appropriations act(s) which prohibits the Federal Government from entering into a contract, memorandum of understanding, or cooperative agreement with, make a grant to, or provide a loan or loan guarantee to any corporation having a delinquent Federal tax liability or a felony conviction under any Federal law, unless the agency has considered suspension or debarment of the corporation and has made a determination that this further action is not necessary to protect the interests of the Government. A “corporation” is a legal entity that is separate and distinct from the entities that own, manage, or control it. It is organized and incorporated under the jurisdictional authority of a governmental body, such as a State or the District of Columbia. A corporation may be a for-profit or non-profit organization.

As required by the appropriations act(s) prohibitions, the Government will not enter into a contract, memorandum of understanding, or cooperative agreement with, make a grant to, or provide a loan or loan guarantee with any corporation that — (1) Has any unpaid Federal tax liability that has been assessed, for which all judicial and administrative remedies have been exhausted or have lapsed, and that is not being paid in a timely manner pursuant to an agreement with the authority responsible for collecting the tax liability, where the awarding agency is aware of the unpaid tax liability, unless an agency has considered suspension or debarment of the corporation and made a determination that suspension or debarment is not necessary to protect the interests of the Government; or (2) Was convicted of a felony criminal violation under any Federal law within the preceding 24 months, where the awarding agency is aware of the conviction, unless an agency has considered suspension or debarment of the corporation and made a determination that this action is not necessary to protect the interests of the Government.

By accepting this award, the recipient represents that it is not a corporation that has any unpaid Federal tax liability that has been assessed, for which all judicial and administrative remedies have been exhausted or have lapsed, and that is not being paid in a timely manner pursuant to an agreement with the authority responsible for collecting the tax liability; and it is not a corporation that was convicted of a felony criminal violation under a Federal law within the preceding 24 months.

Alternatively, by accepting this award, the recipient represents that it disclosed unpaid Federal tax liability information and/or Federal felony conviction information to the EPA. The Recipient may accept this award if the EPA Suspension and Debarment Official has considered suspension or debarment of the corporation based on a tax liabilities and/or Federal felony convictions and determined that suspension or debarment is not necessary to protect the Government's interests.

If the recipient fails to comply with this term and condition, EPA will annul this agreement and may recover any funds the recipient has expended in violation of the appropriations act(s) prohibition(s). The EPA may also pursue other administrative remedies as outlined in 2 CFR 200.339 and 2 CFR 200.340 , and may also pursue
suspension and debarment.

23. Disclosing Conflict of Interests

23.1. For awards to Non-federal entities and individuals (other than states and fellowship recipients under 40 CFR Part 46).

As required by 2 CFR 200.112, EPA has established a policy (COI Policy) for disclosure of conflicts of interest (COI) that may affect EPA financial assistance awards. EPA’s COI Policy is posted at https://www.epa.gov/grants/epas-financial-assistance-conflict-interest-policy.

The posted version of EPA’s COI Policy is applicable to new funding (initial awards, supplemental and incremental funding) awarded on or after October 1, 2015. This COI term Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
66 Packet Pg. 129 of 291

and condition supersedes prior COI terms and conditions for this award based on either EPA’s May 22, 2015 Revised Interim COI Policy or December 26, 2014 Interim COI Policy.

For competitive awards, recipients must disclose any competition related COI described in section

4.0(a) of the COI Policy that are discovered after award to the EPA Grants Specialist listed on the Assistance Agreement/Amendment within 30 calendar days of discovery of the COI. The Grants Specialist will respond to any such disclosure within 30 calendar days.

EPA’s COI Policy requires that recipients have systems in place to address, resolve and disclose to EPA COIs described in sections 4.0(b), (c) and/or (d) of the COI Policy that affect any contract or subaward regardless of amount funded under this award. The recipient’s COI Point of Contact for the award must disclose any COI to the EPA Grants Specialist listed on the Assistance Agreement/Amendment within 30 calendar days of the discovery of the potential COI and their approach for resolving the COI.

EPA’s COI Policy requires that subrecipients have systems in place to address, resolve and disclose COI’s described in section 4.0(b)(c) and (d) of the COI Policy regardless of the amount of the transaction. Recipients who are pass-through entities as defined at 2 CFR 200.1 must require that subrecipients being considered for or receiving subawards disclose COI to the pass-through entities in a manner that, at a minimum, is in accordance with sections 5.0(d) and 7.0(c) of EPA’s COI Policy. Pass-through entities must disclose the subrecipient COI along with the approach for resolving the COI to the EPA Grants Specialist listed on the Assistance Agreement/Amendment within 30 calendar days of receiving notification of the COI by the subrecipient.

EPA only requires that recipients and subrecipients disclose COI’s that are discovered under their systems for addressing and resolving COI. If recipients or subrecipients do not discover a COI, they do not need to advise EPA or the pass-through entity of the absence of a COI.

Upon notice from the recipient of a potential COI and the approach for resolving it, the Agency will then make a determination regarding the effectiveness of these measures within 30 days of receipt of the recipient’s notice unless a longer period is necessary due to the complexity of the matter. Recipients may not request payment from EPA for costs for transactions subject to the COI pending notification of EPA’s determination. Failure to disclose a COI may result in cost disallowances.

Disclosure of a potential COI will not necessarily result in EPA disallowing costs, with the exception of procurement contracts that the Agency determines violate 2 CFR 200.318(c)(1) or (2), provided the recipient notifies EPA of measures the recipient or subrecipient has taken to eliminate, neutralize or mitigate the conflict of interest when making the disclosure.

23.2. For awards to states including state universities that are state agencies or instrumentalities

As required by 2 CFR 200.112, EPA has established a policy (COI Policy) for disclosure of conflicts of interest (COI) that may affect EPA financial assistance awards. EPA’s COI Policy is posted at:
https://www.epa.gov/grants/epas-financial-assistance-conflict-interest-policy. The posted version of EPA’s COI Policy is applicable to new funding (initial awards, supplemental, incremental funding) awarded on or after October 1, 2015. This COI term and condition supersedes prior COI terms and conditions for this award based on either EPA’s May 22, 2015 Revised Interim COI Policy or December 26, 2014 Interim COI Policy.

For competitive awards, recipients must disclose any competition related COI described in section 4.0(a) Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
67 Packet Pg. 130 of 291

of the COI Policy that are discovered after award to the EPA Grants Specialist listed on the Assistance Agreement/Amendment within 30 calendar days of discovery of the COI. The Grants Specialist will respond to any such disclosure within 30 calendar days.

States including state universities that are state agencies and instrumentalities receiving funding from EPA are only required to disclose subrecipient COI as a pass-through entity as defined by 2 CFR 200.1. Any other COI are subject to state laws, regulations and policies. EPA’s COI Policy requires that subrecipients have systems in place to address, resolve and disclose COIs described in section 4.0(b)(c) and (d) of the COI Policy that arise after EPA made the award regardless of the amount of the transaction. States who are pass-through entities as defined at 2 CFR 200.1 must require that subrecipients being considered for or receiving subawards disclose COI to the state in a manner that, as a minimum, in accordance with sections

5.0(d) and 7.0(c) of EPA’s COI Policy. States must disclose the subrecipient COI along with the approach for resolving the COI to the EPA Grants Specialist listed on the Assistance Agreement/Amendment within 30 calendar days of receiving notification of the COI by the subrecipient.

EPA only requires that subrecipients disclose COI’s to state pass-through entities that are discovered under their systems for addressing, resolving, and disclosing COI. If subrecipients do not discover a COI, they do not need to advise state pass-through entities of the absence of a COI.

Upon receiving notice of a potential COI and the approach for resolving it, the Agency will make a determination regarding the effectiveness of these measures within 30 days of receipt of the state’s notice of a subrecipient COI unless a longer period is necessary due to the complexity of the matter. States may not request payment from EPA for costs for transactions subject to the COI pending notification of EPA’s determination. A subrecipient’s failure to disclose a COI to the state and EPA may result in cost disallowances.

Disclosure of a potential subrecipient COI will not necessarily result in EPA disallowing costs, with the exception of procurement contracts that the Agency determines violate 2 CFR 200.318(c)(1) or (2), provided the subrecipient has taken measures that EPA and the state agree eliminate, neutralize or mitigate the conflict of interest.

24. Transfer of Funds

Applicable to all assistance agreements other than Continuing Environmental Program Grants subject to 40 CFR 35.114 and 40 CFR 35.514 when EPA’s share of the total project costs exceeds the Simplified Acquisition Threshold. Simplified Acquisition Threshold is defined at 2 CFR 200.1 and is currently set at $250,000 but the amount is subject to adjustment.
(1) As provided at 2 CFR 200.308(f), the recipient must obtain prior approval from EPA’s Grants Management Officer if the cumulative amount of funding transfers among direct budget categories or programs, functions and activities exceeds 10% of the total budget. Recipients must submit requests for prior approval to the Grant Specialist and Grants Management Officer with a copy to the Project Officer for this agreement. (2) Recipients must notify EPA’s Grant Specialist and Project Officer of cumulative funding transfers among direct budget categories or programs, functions and activities that do not exceed 10% of the total budget for the agreement. Recipients must also notify the EPA Grant Specialist and Project Officer when transferring funds from direct budget categories to the indirect cost category or from the indirect cost category to the direct cost category. Prior approval by EPA’s Grant Management Officer is required if the transfer involves any of the items listed in 2 CFR 200.407 that EPA did not previously approve at time of award or in response to a previous post-award request by the recipient.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
68 Packet Pg. 131 of 291

Applicable to Continuing Environmental Program Grants subject to 40 CFR 35.114 and 40 CFR 35.514. when EPA’s share of the total project costs exceeds the Simplified Acquisition Threshold. Simplified Acquisition Threshold is defined at 2 CFR 200.1 and is currently set at $250,000 but the amount is subject to adjustment.

Recipients of continuing environmental program grants subject to 40 CFR 35.114 and 40 CFR 35.514 must notify the EPA Grant Specialist and Project Officer of funding transfers among direct budget categories, programs, functions and activities or transfers that change amounts budgeted for indirect costs, but prior EPA approval is not required unless the transfer results in significant changes to work plan commitments. Recipients must obtain prior written approval if the transfer involves any of the items listed in 2 CFR 200.407 that EPA did not previously approve at time of award, in response to a previous post-award request by the recipient, or is subject to an EPA waiver of prior approval under 40 CFR 35.114(d) or 40 CFR 35.514(d).

25. Electronic/Digital Signatures on Financial Assistance Agreement Form(s)/Document(s) Throughout the life of this assistance agreement, the recipient agrees to ensure that any form(s)/document(s) required to be signed by the recipient and submitted to EPA through any means including but not limited to hard copy via U.S. mail or express mail, hand delivery or through electronic means such as e-mail are: (1) signed by the individual identified on the form/document, and (2) the signer has the authority to sign the form/document for the recipient. Submission of any signed form(s)/document(s) is subject to any provisions of law on making false statements (e.g. 18 U.S.C. 1001).

26. Extension of Project/Budget Period Expiration Date
EPA has not exercised the waiver option to allow automatic one-time extensions for non-research grants under 2 CFR 200.308
(e)(2). Therefore, if a no-cost time extension is necessary to extend the period of availability of funds, the recipient must submit a written request to the EPA prior to the budget/project period expiration dates. The written request must include: a justification describing the need for additional time, an estimated date of completion, and a revised schedule for project completion including updated milestone target dates for the approved workplan activities. In addition, if there are overdue reports required by the general, administrative, and/or programmatic terms and conditions of this assistance agreement, the recipient must ensure that they are submitted along with or prior to submitting the no-cost time extension request.

27. Utilization of Disadvantaged Business Enterprises

GENERAL COMPLIANCE, 40 CFR, Part 33
The recipient agrees to comply with the requirements of EPA's Disadvantaged Business Enterprise (DBE) Program for procurement activities under assistance agreements, contained in 40 CFR, Part 33.

The following text either provides updates to 40 CFR, Part 33 based upon the associated class exception or highlights a requirement.

1. EPA MBE/WBE CERTIFICATION, 40 CFR, Part 33, Subpart B EPA no longer certifies entities as Minority-Owned Business Entities (MBEs) or Women-Owned Business Entities (WBEs) pursuant to a class exception issued in October 2019. The class exception was authorized pursuant to the authority in 2 CFR, Section 1500.3(b).

2. SIX GOOD FAITH EFFORTS, 40 CFR, Part 33, Subpart C
Pursuant to 40 CFR Section 33.301, the recipient agrees to make good faith efforts whenever procuring construction, equipment, services and supplies under an EPA financial assistance agreement, and to require that sub-recipients, loan recipients, and prime contractors also comply. Records documenting compliance with the six good faith efforts shall be retained. The specific six good faith efforts can be found at: 40 CFR Section 33.301 (a)-(f)
.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
69 Packet Pg. 132 of 291

However, in EPA assistance agreements that are for the benefit of Native Americans, the recipient must solicit and recruit Native American organizations and Native American-owned economic enterprises and give them preference in the award process prior to undertaking the six good faith efforts (40 CFR Section

33.304). If recruiting efforts are unsuccessful, the recipient must follow the six good faith efforts.

3. CONTRACT ADMINISTRATION PROVISIONS, 40 CFR Section 33.302 The recipient agrees to comply with the contract administration provisions of 40 CFR Section 33.302 (a)- (d) and (i).

4. BIDDERS LIST, 40 CFR Section 33.501(b) and (c)
Recipients of a Continuing Environmental Program Grant or other annual reporting grant, agree to create and maintain a bidders list. Recipients of an EPA financial assistance agreement to capitalize a revolving loan fund also agree to require entities receiving identified loans to create and maintain a bidders list if the recipient of the loan is subject to, or chooses to follow, competitive bidding requirements. Please see 40 CFR Section 33.501 (b) and (c) for specific requirements and exemptions.

5. FAIR SHARE OBJECTIVES, 40 CFR, Part 33, Subpart D
In October 2019, a class exception to the entire Subpart D of 40 CFR, Part 33 has been authorized pursuant to the authority in 2 CFR Section 1500.3(b). Notwithstanding Subpart D of 40 CFR, Part 33, recipients are not required to negotiate or apply fair share objectives in procurements under assistance agreements.

6. MBE/WBE REPORTING, 40 CFR, Part 33, Subpart E
When required, the recipient agrees to complete and submit a “MBE/WBE Utilization Under Federal Grants and Cooperative Agreements” report (EPA Form 5700-52A) on an annual basis. The current EPA Form 5700-52A can be found at the EPA Grantee Forms Page at https://www.epa.gov/sites/production/files/2020-06/documents/epa_form_5700_52a_fill-sign.pdf .

Reporting is required for assistance agreements where funds are budgeted for procuring construction, equipment, services and supplies (including funds budgeted for direct procurement by the recipient or procurement under subawards or loans in the “Other” category) with a cumulative total that exceed the Simplified Acquisition Threshold (SAT) (currently, $250,000 however the threshold will be automatically revised whenever the SAT is adjusted; See 2 CFR Section 200.1), including amendments and/or modifications. When reporting is required, all procurement actions are reportable, not just the portion which exceeds the SAT.

Annual reports are due by October 30th of each year. Final reports are due 120 days after the end of the project period.

This provision represents an approved exception from the MBE/WBE reporting requirements as described in 40 CFR Section 33.502.

7. MBE/WBE RECORDKEEPING, 40 CFR, Part 33, Subpart E
The recipient agrees to comply with all recordkeeping requirements as stipulated in 40 CFR, Part 33, Subpart E including creating and maintaining a bidders list, when required. Any document created as a record to demonstrate compliance with any requirement of 40 CFR, Part 33 must be maintained pursuant to the requirements stated in this Subpart.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
70 Packet Pg. 133 of 291

Programmatic General Terms and Conditions

28. Sufficient Progress
EPA will measure sufficient progress by examining the performance required under the workplan in conjunction with the milestone schedule, the time remaining for performance within the project period and/or the availability of funds necessary to complete the project. EPA may terminate the assistance agreement for failure to ensure reasonable completion of the project within the project period.

29. Copyrighted Material and Data
In accordance with 2 CFR 200.315, EPA has the right to reproduce, publish, use and authorize others to reproduce, publish and use copyrighted works or other data developed under this assistance agreement for Federal purposes.

Examples of a Federal purpose include but are not limited to: (1) Use by EPA and other Federal employees for official Government purposes; (2) Use by Federal contractors performing specific tasks for [i.e., authorized by] the Government; (3) Publication in EPA documents provided the document does not disclose trade secrets (e.g. software codes) and the work is properly attributed to the recipient through citation or otherwise; (4) Reproduction of documents for inclusion in Federal depositories; (5) Use by State, tribal and local governments that carry out delegated Federal environmental programs as “co-regulators” or act as official partners with EPA to carry out a national environmental program within their jurisdiction and; (6) Limited use by other grantees to carry out Federal grants provided the use is consistent with the terms of EPA’s authorization to the other grantee to use the copyrighted works or other data.

Under Item 6, the grantee acknowledges that EPA may authorize another grantee(s) to use the copyrighted works or other data developed under this grant as a result of:
• the selection of another grantee by EPA to perform a project that will involve the use of the copyrighted works or other data or;
• termination or expiration of this agreement.

In addition, EPA may authorize another grantee to use copyrighted works or other data developed with Agency funds provided under this grant to perform another grant when such use promotes efficient and effective use of Federal grant funds.

30. Patents and Inventions
Rights to inventions made under this assistance agreement are subject to federal patent and licensing regulations, which are codified at Title 37 CFR Part 401 and Title 35 USC Sections 200-212.

Pursuant to the Bayh-Dole Act (set forth in 35 USC 200-212), EPA retains the right to a worldwide, nonexclusive, nontransferable, irrevocable, paid-up license to practice the invention owned by the assistance agreement holder, as defined in the Act. To streamline the invention reporting process and to facilitate compliance with the Bayh-Dole Act, the recipient must utilize the Interagency Edison extramural invention reporting system at iEdison.gov . Annual utilization reports must be submitted through the system. The recipient is required to notify the Project Officer identified on the award document when an invention report, patent report, or utilization report is filed at iEdison.gov. EPA elects not to require the recipient to provide a report prior to the close-out of a funding agreement listing all subject inventions or stating that there were none.

In accordance with Executive Order 12591, as amended, government owned and operated laboratories can enter into cooperative research and development agreements with other federal laboratories, state and local governments, universities, and the private sector, and license, assign, or waive rights to intellectual property “developed by the laboratory either under such cooperative research or development agreements and from within individual laboratories.”
Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
71 Packet Pg. 134 of 291

31. Acknowledgement Requirements for Non-ORD Assistance Agreements The recipient agrees that any reports, documents, publications or other materials developed for public distribution supported by this assistance agreement shall contain the following statement:

"This project has been funded wholly or in part by the United States Environmental Protection Agency under assistance agreement (number) to (recipient). The contents of this document do not necessarily reflect the views and policies of the Environmental Protection Agency, nor does the EPA endorse trade names or recommend the use of commercial products mentioned in this document.”

Recipients of EPA Office of Research Development (ORD) research awards must follow the acknowledgement requirements outlined in the research T&Cs available at: https://www.nsf.gov/awards/managing/rtc.jsp. A Federal-wide workgroup is currently updating the Federal-Wide Research Terms and Conditions Overlay to the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and when completed recipients of EPA ORD research must abide by the research T&Cs.

32. Electronic and Information Technology Accessibility Recipients are subject to the program accessibility provisions of Section 504 of the Rehabilitation Act, codified in 40 CFR Part 7, which includes an obligation to provide individuals with disabilities reasonable accommodations and an equal and effective opportunity to benefit from or participate in a program, including those offered through electronic and information technology (“EIT”). In compliance with Section 504, EIT systems or products funded by this award must be designed to meet the diverse needs of users (e.g., U.S. public, recipient personnel) without barriers or diminished function or quality. Systems shall include usability features or functions that accommodate the needs of persons with disabilities, including those who use assistive technology. At this time, the EPA will consider a recipient’s websites, interactive tools, and other EIT as being in compliance with Section 504 if such technologies meet standards established under Section 508 of the Rehabilitation Act, codified at 36 CFR Part 1194. While Section 508 does not apply directly to grant recipients, we encourage recipients to follow either the 508 guidelines or other comparable guidelines that concern accessibility to EIT for individuals with disabilities.

Recipients may wish to consult the latest Section 508 guidelines issued by the U.S. Access Board or W3C’s Web Content Accessibility Guidelines (WCAG) 2.0 (see https://www.access-board.gov/guidelines-and- standards/communications-and-it/about-the-section-508-standards/guide-to-the-section-508-standards).

33. Human Subjects
Human subjects research is any activity that meets the regulatory definitions of both research AND human subject. Research is a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. Human subject means a living individual about whom an investigator (whether professional or student) conducting research obtains (1) data through intervention or interaction with the individual, or (2) identifiable private information. [40 CFR 26.102 (d)(f)]

No research involving human subjects will be conducted under this agreement without prior written approval of the EPA to proceed with that research. If engaged in human subjects research as part of this agreement, the recipient agrees to comply with all applicable provisions of EPA Regulation 40 CFR 26 (Protection of Human Subjects). This includes, at Subpart A, the Basic Federal Policy for the Protection of Human Research Subjects, also known as the Common Rule. It also includes, at Subparts B, C, and D, prohibitions and additional protections for children, nursing women, pregnant women, and fetuses in research conducted or supported by EPA.

The recipient further agrees to comply with EPA’s procedures for oversight of the recipient’s compliance with 40 CFR 26, as given in EPA Order 1000.17 Change A1 (Policy and Procedures on Protection of Human Research Subjects in EPA Conducted or Supported Research). As per this order, no human subject may be involved in any research conducted under this assistance agreement, including recruitment, until the research Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
72 Packet Pg. 135 of 291

has been approved or determined to be exempt by the EPA Human Subjects Research Review Official (HSRRO) after review of the approval or exemption determination of the Institutional Review Board(s) (IRB(s)) with jurisdiction over the research under 40 CFR 26.

For HSRRO approval, the recipient must forward to the Project Officer: (1) copies of all documents upon which the IRB(s) with jurisdiction based their approval(s) or exemption determination(s), (2) copies of the IRB approval or exemption determination letter(s), (3) copy of the IRB-approved consent forms and subject recruitment materials, if applicable, and (4) copies of all supplementary IRB correspondence.

Following the initial approvals indicated above, the recipient must, as part of the annual report(s), provide evidence of continuing review and approval of the research by the IRB(s) with jurisdiction, as required by 40 CFR 26.109(e). Materials submitted to the IRB(s) for their continuing review and approval are to be provided to the Project Officer upon IRB approval. During the course of the research, investigators must promptly report any unanticipated problems involving risk to subjects or others according to requirements set forth by the IRB.

In addition, any event that is significant enough to result in the removal of the subject from the study should also be reported to the Project Officer, even if the event is not reportable to the IRB of record.

34. Animal Subjects
The recipient agrees to comply with the Animal Welfare Act of 1966 (P.L. 89-544), as amended, 7 USC 2131- 2156. Recipient also agrees to abide by the “U.S. Government Principles for the Utilization and Care of Vertebrate Animals used in Testing, Research, and Training.” (Federal Register 50(97): 20864-20865. May 20,1985). The nine principles can be viewed at https://olaw.nih.gov/policies-laws/phs-policy.htm. For additional information about the Principles, the recipient should consult the Guide for Care and Use of Laboratory Animals, prepared by the Institute of Laboratory Animal Resources, National Research Council and can be accessed at: http://www.nap.edu/readingroom/books/labrats/.

35. Light Refreshments and/or Meals

APPLICABLE TO ALL AGREEMENTS EXCEPT STATE CONTINUING ENVIRONMENTAL PROGRAMS (AS DESCRIBED BELOW):

Unless the event(s) and all of its components are described in the approved workplan, the recipient agrees to obtain prior approval from EPA for the use of grant funds for light refreshments and/or meals served at meetings, conferences, training workshops and outreach activities (events). The recipient must send requests for approval to the EPA Project Officer and include:
(1) An estimated budget and description for the light refreshments, meals, and/or beverages to be served at the event(s);
(2) A description of the purpose, agenda, location, length and timing for the event; and, (3) An estimated number of participants in the event and a description of their roles.

Costs for light refreshments and meals for recipient staff meetings and similar day-to-day activities are not allowable under EPA assistance agreements.

Recipients may address questions about whether costs for light refreshments, and meals for events may be allowable to the recipient’s EPA Project Officer; however, the Agency Award Official or Grant Management Officer will make final determinations on allowability. Agency policy prohibits the use of EPA funds for receptions, banquets and similar activities that take place after normal business hours unless the recipient has provided a justification that has been expressly approved by EPA's Award Official or Grants Management Officer.

EPA funding for meals, light refreshments, and space rental may not be used for any portion of an event where alcohol is served, purchased, or otherwise available as part of the event or meeting, even if EPA funds are not Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
73 Packet Pg. 136 of 291

used to purchase the alcohol.

Note: U.S. General Services Administration regulations define light refreshments for morning, afternoon or evening breaks to include, but not be limited to, coffee, tea, milk, juice, soft drinks, donuts, bagels, fruit, pretzels, cookies, chips, or muffins. (41 CFR 301-74.7)

FOR STATE CONTINUING ENVIRONMENTAL PROGRAM GRANT RECIPIENTS EXCLUDING STATE UNIVERSITIES:

If the state maintains systems capable of complying with federal grant regulations at 2 CFR 200.432 and 200.438, EPA has waived the prior approval requirements for the use of EPA funds for light refreshments and/or meals served at meetings, conferences, and training, as described above. The state may follow its own procedures without requesting prior approval from EPA. However, notwithstanding state policies, EPA funds may not be used for (1) evening receptions, or (2) other evening events (with the exception of working meetings). Examples of working meetings include those evening events in which small groups discuss technical subjects on the basis of a structured agenda or there are presentations being conducted by experts. EPA funds for meals, light refreshments, and space rental may not be used for any portion of an event (including evening working meetings) where alcohol is served, purchased, or otherwise available as part of the event or meeting, even if EPA funds are not used to purchase the alcohol.

By accepting this award, the state is certifying that it has systems in place (including internal controls) to comply with the requirements described above.

36. Tangible Personal Property

36.1 Reporting Pursuant to 2 CFR 200.312 and 200.314, property reports, if applicable, are required for Federally-owned property in the custody of a non-Federal entity upon completion of the Federal award or when the property is no longer needed. Additionally, upon termination or completion of the project, residual unused supplies with a total aggregate fair market value exceeding $5,000 not needed for any other Federally-sponsored programs or projects must be reported. For Superfund awards under Subpart O, refer to 40 CFR 35.6340 and

35.6660 for property reporting requirements. Recipients should utilize the Tangible Personal Property Report form series (SF-428) to report tangible personal property.

36.2 Disposition

36.2.1 Most Recipients. Consistent with 2 CFR 200.313, unless instructed otherwise on the official award document, this award term, or at closeout, the recipient may keep the equipment and continue to use it on the project originally funded through this assistance agreement or on other federally funded projects whether or not the project or program continues to be supported by Federal funds.

36.2.2 State Agencies. Per 2 CFR 200.313(b), state agencies may manage and dispose of equipment acquired under this assistance agreement in accordance with state laws and procedures.

36.2.3 Superfund Recipients. Equipment purchased under Superfund projects is subject to specific disposal options in accordance with 40 CFR Part 35.6345.

37. Dual Use Research of Concern (DURC)
The recipient agrees to conduct all life science research* in compliance with EPA’s Order on the Policy and Procedures for Managing Dual Use Research of Concern (EPA DURC Order) and United States Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern (iDURC Policy). If the recipient is an institution within the United States that receives funding through this agreement, or from any other source, the recipient agrees to comply with the iDURC Policy if they conduct or sponsor research involving any of the agents or toxins identified in Section 6.2.1 of the iDURC Policy. If the institution is outside the United States and receives funding through this agreement to conduct or sponsor research involving any of those same agents or toxins, the recipient agrees to comply with the iDURC Policy. The recipient agrees to provide any additional information that may be requested by EPA regarding DURC and iDURC. The recipient Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
74 Packet Pg. 137 of 291

agrees to immediately notify the EPA Project Officer should the project use or introduce use of any of the agents or toxins identified in the iDURC Policy. The recipient’s Institution/Organization must also comply with USG iDURC policy and EPA DURC Order and will inform the appropriate government agency if funded by such agency of research with the agents or toxins identified in Section 6.2.1 of the iDURC Policy. If privately funded the recipient agrees to notify the National Institutes of Health at [email protected].

*“Life Sciences Research,” for purposes of the EPA DURC Order, and based on the definition of research in 40 CFR §26.102(d), is a systematic investigation designed to develop or contribute to generalizable knowledge involving living organisms (e.g., microbes, human beings, animals, and plants) and their products. EPA does not consider the following activities to be research: routine product testing, quality control, mapping, collection of general-purpose statistics, routine monitoring and evaluation of an operational program, observational studies, and the training of scientific and technical personnel. [Note: This is consistent with Office of Management and Budget Circular A-11.]

38. Research Misconduct
In accordance with 2 CFR 200.329, the recipient agrees to notify the EPA Project Officer in writing about research misconduct involving research activities that are supported in whole or in part with EPA funds under this project. EPA defines research misconduct as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results [65 FR 76262. I], or ordering, advising or suggesting that subordinates engage in research misconduct. The recipient agrees to:

(1) Immediately notify the EPA Project Officer who will then inform the EPA Office of Inspector General (OIG) if, at any time, an allegation of research misconduct falls into one of the categories listed below:

A. Public health or safety is at risk.

B. Agency resources or interests are threatened.

C. Circumstances where research activities should be suspended.

D. There is a reasonable indication of possible violations of civil or criminal law.

E. Federal action is required to protect the interests of those involved in the investigation.

F. The research entity believes that the inquiry or investigation may be made public prematurely so that appropriate steps can be taken to safeguard evidence and protect the rights of those involved.

G. Circumstances where the research community or public should be informed. [65 FR 76263.III]

(2) Report other allegations to the OIG when they have conducted an inquiry and determined that there is sufficient evidence to proceed with an investigation. [65 FR 76263. III]

39. Scientific Integrity Terms and Conditions
The recipient agrees to comply with EPA’s Scientific Integrity Policy when conducting, supervising, and
communicating science and when using or applying the results of science. For purposes of this award condition scientific activities include, but are not limited to, computer modelling, economic analysis, field sampling, laboratory experimentation, demonstrating new technology, statistical analysis, and writing a review article on a scientific issue. The recipient agrees to:

39.1 Scientific Products

39.1.1 Produce scientific products of the highest quality, rigor, and objectivity, by adhering to applicable EPA information quality guidelines, quality policy, and peer review policy.

39.1.2 Prohibit all recipient employees, contractors, and program participants, including scientists, managers, and other recipient leadership, from suppressing, altering, or otherwise impeding the timely release of scientific findings or conclusions.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
75 Packet Pg. 138 of 291

39.1.3 Adhere to EPA’s Peer Review Handbook, 4th Edition, for the peer review of scientific and technical work products generated through EPA grants or cooperative agreements which, by definition, are not primarily for EPA’s direct use or benefit.

39.2 Scientific Findings

39.2.1 Require that reviews regarding the content of a scientific product that are conducted by the project manager and other recipient managers and the broader management chain be based only on scientific quality considerations, e.g., the methods used are clear and appropriate, the presentation of results and conclusions is impartial.

39.2.2 Ensure scientific findings are generated and disseminated in a timely and transparent manner, including scientific research performed by employees, contractors, and program participants, who assist with developing or applying the results of scientific activities.

39.2.3 Include, when communicating scientific findings, an explication of underlying assumptions, accurate contextualization of uncertainties, and a description of the probabilities associated with both optimistic and pessimistic projections, if applicable.

39.2.4 Document the use of independent validation of scientific methods.

39.2.5 Document any independent review of the recipient’s scientific facilities and testing activities, as occurs with accreditation by a nationally or internationally recognized sanctioning body.

39.2.6 Make scientific information available online in open formats in a timely manner, including access to data and non-proprietary models.

39.3 Scientific Misconduct

39.3.1 Prohibit intimidation or coercion of scientists to alter scientific data, findings, or professional opinions or non-scientific influence of scientific advisory boards. In addition, recipient employees, contractors, and program participants, including scientists, managers, and other leadership, shall not knowingly misrepresent, exaggerate, or downplay areas of scientific uncertainty.

39.3.2 Prohibit retaliation or other punitive actions toward recipient employees who uncover or report allegations of scientific and research misconduct, or who express a differing scientific opinion. Employees who have allegedly engaged in scientific or research misconduct shall be afforded the due process protections provided by law, regulation, and applicable collective bargaining agreements, prior to any action. Recipients shall ensure that all employees and contractors of the recipient shall be familiar with these protections and avoid the appearance of retaliatory actions.

39.3.3 Require all recipient employees, contractors, and program participants to act honestly and refrain from acts of research misconduct, including publication or reporting, as described in EPA’s Policy and Procedures for Addressing Research Misconduct , Section 9.C.

Research misconduct does not include honest error or differences of opinion. While EPA retains the ultimate oversight authority for EPA-supported research, grant recipients conducting research bear primary responsibility for prevention and detection of research misconduct and for the inquiry, investigation, and adjudication of research misconduct alleged to have occurred in association with their own institution.

39.3.4 Take the actions required on the part of the recipient described in EPA’s Policy and Procedures for Addressing Research Misconduct, Sections 6 through 9, when research misconduct is suspected or found.

39.4 Additional Resources
For more information about the Scientific Integrity Policy, an introductory video can be accessed at:
https://youtu.be/FQJCy8BXXq8. A training video is available at: https://youtu.be/Zc0T7fooot8.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
76 Packet Pg. 139 of 291

Public Policy Requirements

40. Civil Rights Obligations
This term and condition incorporates by reference the signed assurance provided by the recipient’s authorized representative on: 1) EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting EPA Financial Assistance”; and 2) Certifications and Representations in Sam.gov or Standard Form 424D, as applicable.

These assurances and this term and condition obligate the recipient to comply fully with applicable civil rights statutes and implementing federal and EPA regulations.

a. Statutory Requirements
i. In carrying out this agreement, the recipient must comply with:

1. Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, and national origin, including limited English proficiency (LEP), by entities receiving Federal financial assistance.

2. Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination against persons with disabilities by entities receiving Federal financial assistance; and

3. The Age Discrimination Act of 1975, which prohibits age discrimination by entities receiving Federal financial assistance.
ii. If the recipient is an education program or activity (e.g., school, college or university) or if the recipient is conducting an education program or activity under this agreement, it must also comply with:

1. Title IX of the Education Amendments of 1972, which prohibits discrimination on the basis of sex in education programs and activities operated by entities receiving Federal financial assistance. For further information about your compliance obligations regarding Title IX, see 40 CFR Part 5 and https://www.justice.gov/crt/title-ix iii. If this agreement is funded with financial assistance under the Clean Water Act (CWA), the recipient must also comply with:

1. Section 13 of the Federal Water Pollution Control Act Amendments of 1972, which prohibits discrimination on the basis of sex in CWA-funded programs or activities.

b. Regulatory Requirements
i. The recipient agrees to comply with all applicable EPA civil rights regulations, including:

1. For Title IX obligations, 40 C.F.R. Part 5; and

2. For Title VI, Section 504, Age Discrimination Act, and Section 13 obligations, 40 CFR Part7.

3. For statutory and national policy requirements, including those prohibiting discrimination and those described in Executive Order 13798 promoting free speech and religious freedom, 2 CFR 200.300.

4. As noted on the EPA Form 4700-4 signed by the recipient’s authorized representative, these regulations establish specific requirements including maintaining compliance information, establishing grievance procedures, designating a Civil Rights Coordinator and providing notices of non-discrimination.
c. TITLE VI – LEP, Public Participation and Affirmative Compliance Obligation i. As a recipient of EPA financial assistance, you are required by Title VI of the Civil Rights Act to provide meaningful access to LEP individuals. In implementing that requirement, the recipient agrees to use as a guide the Office of Civil Rights (OCR) document entitled "Guidance to Environmental Protection Agency Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons." The guidance can be found at:

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
77 Packet Pg. 140 of 291

https://www.federalregister.gov/documents/2004/06/25/04-14464/guidance-to- environmental-protection-agency-financial-assistance-recipients-regarding-title-vi ii. If the recipient is administering permitting programs under this agreement, the recipient agrees to use as a guide OCR’s Title VI Public Involvement Guidance for EPA Assistance Recipients Administering Environmental Permitting Programs. The Guidance can be found at: https://www.govinfo.gov/content/pkg/FR-2006-03-21/pdf/06-2691.pdf iii. In accepting this assistance agreement, the recipient acknowledges it has an affirmative obligation to implement effective Title VI compliance programs and ensure that its actions do not involve discriminatory treatment and do not have discriminatory effects even when facially neutral. The recipient must be prepared to demonstrate to EPA that such compliance programs exist and are being implemented or to otherwise demonstrate how it is meeting its Title VI obligations.

41. Drug-Free Workplace
The recipient organization of this EPA assistance agreement must make an ongoing, good faith effort to maintain a drug-free workplace pursuant to the specific requirements set forth in Title 2 CFR Part 1536 Subpart B. Additionally, in accordance with these regulations, the recipient organization must identify all known workplaces under its federal awards, and keep this information on file during the performance of the award.

Those recipients who are individuals must comply with the drug-free provisions set forth in Title 2 CFR Part 1536 Subpart C.

The consequences for violating this condition are detailed under Title 2 CFR Part 1536 Subpart E. Recipients can access the Code of Federal Regulations (CFR) Title 2 Part 1536 at www.ecfr.gov/.

42. Hotel-Motel Fire Safety
Pursuant to 15 USC 2225a, the recipient agrees to ensure that all space for conferences, meetings, conventions or training seminars funded in whole or in part with federal funds complies with the protection and control guidelines of the Hotel and Motel Fire Safety Act (PL 101-391, as amended). Recipients may search the Hotel-Motel National Master List at https://apps.usfa.fema.gov/hotel/ to see if a property is in compliance, or to find other information about the Act.

43. Lobbying Restrictions

a) This assistance agreement is subject to lobbying restrictions as described below. Applicable to all assistance agreements:
i) The chief executive officer of this recipient agency shall ensure that no grant funds awarded under this assistance agreement are used to engage in lobbying of the Federal Government or in litigation against the U.S. unless authorized under existing law. The recipient shall abide by the Cost Principles available at 2 CFR Part 200 which generally prohibits the use of federal grant funds for litigation against the U.S. or for lobbying or other political activities.

ii) The recipient agrees to comply with Title 40 CFR Part 34, New Restrictions on Lobbying. The recipient shall include the language of this provision in award documents for all subawards exceeding $100,000 and require that subrecipients submit certification and disclosure forms accordingly.

iii) In accordance with the Byrd Anti-Lobbying Amendment, any recipient who makes a prohibited expenditure under Title 40 CFR Part 34 or fails to file the required certification or lobbying forms Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
78 Packet Pg. 141 of 291

shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such expenditure.

iv) Contracts awarded by a recipient shall contain, when applicable, the anti-lobbying provision as stipulated in the Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.

v) By accepting this award, the recipient affirms that it is not a nonprofit organization described in Section 501(c)(4) of the Internal Revenue Code of 1986 as required by Section 18 of the Lobbying Disclosure Act; or that it is a nonprofit organization described in Section 501(c)(4) of the Code but does not and will not engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act. Nonprofit organizations exempt from taxation under section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities are ineligible for EPA subawards.

b) Applicable to assistance agreements when the amount of the award is over $100,000:

i) By accepting this award, the recipient certifies, to the best of its knowledge and belief, that:

(1) No Federal appropriated funds have been or will be paid, by or on behalf of the recipient, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement.

(2) If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, or any employee of a Member of Congress in connection with this Federal grant or cooperative agreement, the recipient shall complete and submit the linked Standard Form -- LLL,
"Disclosure Form to Report Lobbying," in accordance with its instructions.

(3) The recipient shall require that the language of this certification be included in the award documents for all subawards exceeding $100,000 at all tiers (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements) and that all subrecipients shall certify and disclose accordingly.

ii) This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by Section 1352, Title 31, U.S. Code. Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each failure.

44. Recycled Paper
When directed to provide paper documents, the recipient agrees to use recycled paper and double-sided printing for all reports which are prepared as a part of this agreement and delivered to EPA. This requirement does not apply to reports prepared on forms supplied by EPA.

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
79 Packet Pg. 142 of 291

45. Resource Conservation and Recovery Act
Consistent with goals of section 6002 of RCRA (42 U.S.C. 6962), State and local institutions of higher education, hospitals and non-profit organization recipients agree to give preference in procurement programs to the purchase of specific products containing recycled materials, as identified in 40 CFR Part 247.

Consistent with section 6002 of RCRA (42 U.S.C. 6962) and 2 CFR 200.323, State agencies or agencies of a political subdivision of a State and its contractors are required to purchase certain items made from recycled materials, as identified in 40 CFR Part 247, when the purchase price exceeds $10,000 during the course of a fiscal year or where the quantity of such items acquired in the course of the preceding fiscal year was $10,000 or more. Pursuant to 40 CFR 247.2 (d), the recipient may decide not to procure such items if they are not reasonably available in a reasonable period of time; fail to meet reasonable performance standards; or are only available at an unreasonable price.

46. Trafficking in Persons

a. Provisions applicable to a recipient that is a private entity. i. The recipient, the recipient’s employees, subrecipients under this award, and subrecipients’ employees may not—

1. Engage in severe forms of trafficking in persons during the period of time that the award is in effect;

2. Procure a commercial sex act during the period of time that the award is in effect; or

3. Use forced labor in the performance of the award or subawards under the award. ii. We as the Federal awarding agency may unilaterally terminate this award, without penalty, if the recipient or a subrecipient that is a private entity—

1. Is determined to have violated a prohibition in paragraph a of this award term; or

2. Has an employee who is determined by the agency official authorized to terminate the award to have violated a prohibition in paragraph a of this award term through conduct that is either—
a. Associated with performance under this award; or
b. Imputed to the recipient or subrecipient using the standards and due process for imputing the conduct of an individual to an organization that are provided in 2 CFR Part 180, ‘‘OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement),’’ as implemented by our Agency at 2 CFR Part 1532.

b. Provision applicable to a recipient other than a private entity. EPA may unilaterally terminate this award, without penalty, if a subrecipient that is a private entity— i. Is determined to have violated an applicable prohibition in paragraph a. of this award term; or
ii. Has an employee who is determined by the agency official authorized to terminate the award to have violated an applicable prohibition in paragraph a of this award term through conduct that is either—

1. Associated with performance under this award; or

2. Imputed to the subrecipient using the standards and due process for imputing the conduct of an individual to an organization that are provided in 2 CFR Part 180, ‘‘OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement),” as implemented by EPA at 2 CFR Part 1532.

c. Provisions applicable to any recipient.
i. The recipient must inform the EPA immediately of any information received from any source alleging a violation of a prohibition in paragraph a of this award term. ii. Our right to terminate unilaterally that is described in paragraph a and b:

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
80 Packet Pg. 143 of 291

1. Implements section 106(g) of the Trafficking Victims Protection Act of 2000 (TVPA), as amended (22 U.S.C. 7104(g)), and

2. Is in addition to all other remedies for noncompliance that are available to us under this award.
iii. The recipient must include the requirements of paragraph a of this award term in any subaward made to a private entity.

d. Definitions. For purposes of this award term:
i. ‘‘Employee’’ means either:

1. An individual employed by you or a subrecipient who is engaged in the performance of the project or program under this award; or

2. Another person engaged in the performance of the project or program under this award and not compensated by you including, but not limited to, a volunteer or individual whose services are contributed by a third party as an in-kind contribution toward cost sharing or matching requirements.
ii. ‘‘Forced labor’’ means labor obtained by any of the following methods: the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.
iii. ‘‘Private entity’’:

1. Means any entity other than a State, local government, Indian tribe, or foreign public entity, as those terms are defined in 2 CFR 175.25.

2. Includes:
a. A nonprofit organization, including any nonprofit institution of higher education, hospital, or tribal organization other than one included in the definition of Indian tribe at 2 CFR 175.25(b).
b. A for-profit organization.
iv. ‘‘Severe forms of trafficking in persons,’’ ‘‘commercial sex act,’’ and ‘‘coercion’’ have the meanings given at section 103 of the TVPA, as amended (22 U.S.C. 7102).

Docusign Envelope ID: 9522220A-B875-471E-85A1-F3DE409AEE01 Item 7
Attachment A - Geosyntec
Consultants, Inc. Contract
C26194015

Item 7: Staff Report
Pg.
81 Packet Pg. 144 of 291

City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Transportation
Meeting Date: March 9, 2026
Report #:2512-5768
TITLE
Approval of Contract Amendment No. 3 to Contract No. C23185922 with Kittelson & Associates, INC. to Increase Compensation by $17,000 to $350,945 and to Extend the Term for an Additional Six Months Through December 31, 2026, for the City's Bicycle and Pedestrian Transportation Plan Update; CEQA status - exempt under Public Resource Code section 21080.20.

RECOMMENDATION
Staff recommends that the City Council approve and authorize the City Manager or their designee to execute Amendment No. 3 to Contract No. C23185922 with Kittelson & Associates, Inc. for professional consultant services in the amount of $17,000, for a revised total contract amount not-to-exceed $350,945, and to extend the term for an additional six-months of service through December 31, 2026 for the City's Bicycle and Pedestrian Transportation Plan Update.

EXECUTIVE SUMMARY
The City of Palo Alto is currently updating its 2012 Bicycle and Pedestrian Transportation Plan (BPTP) to establish an updated 10-year strategy for bicycle and pedestrian network investments, policies, and programs. Kittelson & Associates INC. (Kittelson) was selected to assist staff with consultant services at a cost not exceeding $333,945.

Staff recommends the approval of Amendment No. 3 to Contract No. C23185922 with Kittelson & Associates, Inc., increasing the contract amount by $17,000 for a revised not-to-exceed total of $350,945. This amendment provides the necessary funding for the final milestone of the project: the production of the Final Plan document. During the development of the Draft Plan, the project team undertook several critical but unforeseeable scope changes to ensure the Plan was responsive to community, Pedestrian and Bicycle Advisory Committee (PABAC) and Council direction. These included developing a dual-layered project prioritization framework, pivoting the Draft Plan focus from arterial corridors to a residential "low-stress" bike network, and facilitating additional focus groups and expert facilitated discussion on topics including Item 8
Item 8 Staff Report

Item 8: Staff Report
Pg.
1 Packet Pg. 145 of 291

separated bikeways. Given these changes, additional work is needed to prepare the Final Plan and carry out additional engagement to ensure that the Final Plan is reviewed with PABAC prior to Council presentation. This amendment is required to cover labor associated with preparing the Final Plan and incorporate this final round of feedback into the document prior to Council consideration and potential adoption in summer 2026.

BACKGROUND
The City’s 2012 Bicycle and Pedestrian Transportation Plan (BPTP) has served as the foundational policy document for improving the safety and appeal of active transportation in Palo Alto. To modernize this vision, the City Council supported a grant application for State TDA Article 3 funds approved by the Metropolitan Transportation Commission (MTC).

On June 19, 2023, City Council awarded a professional services contract to Kittelson & Associates, Inc. for a not-to-exceed amount of $333,945 to assist with the development of the 2026 BPTP Update1. The 2026 BPTP Update aims to incorporate robust community feedback; reevaluate implementation progress from previous plans; determine appropriate prioritization criteria and metrics; and update recommendations for new policies, facilities, and programs.

Throughout 2024, the project team completed a comprehensive technical analysis of existing conditions, including Level of Traffic Stress (LTS) and safety data, while conducting extensive community outreach through bike rides, walking tours, and workshops.

In early 2025, the project transitioned to its recommendations phase, launching a third round of engagement to vet proposed bicycle and pedestrian related project recommendations, such as the proposed bicycle network and facilities, Policy & Program recommendations, Pedestrian District Guidelines, and an initial Prioritization Framework. This phase included targeted collaboration with PABAC, the Planning and Transportation Commission (PTC), and the Parks and Recreation Commission (PRC). On June 2, 2025, the City Council considered the Revised Prioritization Framework and also provided feedback on the project recommendations.

Staff released the Draft 2026 BPTP Update2 on October 3, 2025, and the public comment period extended through November 14, 2025. The Draft Plan is the culmination of multiple rounds of community engagement starting in late 2023, including in-person events, online surveys, and meetings with Committees, Commissions and the City Council. In addition to community members providing feedback, PABAC also reviewed and provided feedback on the Draft Plan at their October 7, 2025 and November 3, 2025 meetings, and PTC voted unanimously to 1 Palo Alto City Council Meeting, June 19, 2023. Consent Calendar: Approval of Professional Services Contract with Kittelson & Associates for a Not-to-Exceed Amount of $333,945 for the Bicycle and Pedestrian Transportation Plan Update. CEQA Status: Exempt under Public Resources Code Section 21080.20. https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=1172&compileOutputType=1 2 Palo Alto Draft 2026 Bicycle and Pedestrian Transportation Plan, October 2025. https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=b3a03041-bbe5-4afb-8fc6- ee406fed4311
Item 8
Item 8 Staff Report

Item 8: Staff Report
Pg.
2 Packet Pg. 146 of 291

recommend that Council adopt the 2026 BPTP Update on November 12, 2025. 5 On December 1, 2025, Council considered the Draft Plan and near-term projects6. Councilmembers spoke positively about the effort and recommended refinements to proactively address the growth of e-bikes in future facility design, ensure seamless alignment with other City efforts (such as Cubberley Master Plan), and reviewing Comprehensive Plan policies that may limit future safety improvements. City staff are now reviewing community and Council feedback and preparing the Final 2026 BPTP Update. This process will include an additional presentation to PABAC in spring 2026, incorporating final PABAC feedback, followed by consideration of the Final Plan for potential Council adoption in summer 2026.

There have been two previous amendments to the contract (No. C23185922) to extend the contract term to June 30, 2026: the first Administrative extension approved by City Staff, and the second extension approved by the City Council on April 21, 2025.7 There have been no previous amendments to the not-to-exceed amount of $333,945.

ANALYSIS
In response to Council and community feedback, several significant enhancements to tasks were added to this effort throughout 2025. These scope changes include:

1. Dual-Layered Prioritization Framework: In response to PABAC and public requests for a more rigorous methodology for project prioritization, the project team developed a supplemental project evaluation framework, which involved filtering the project list through both the initial quantitative framework and a secondary qualitative "community values" filter. This dual-layered analysis was essential for building trust in the priority list and required technical adjustments beyond the initial scope.

2. Strategic Pivot to Low-Stress Network: On June 2, 2025, Council requested that the project team shift the Plan’s network and safety improvements from separated bikeways along arterials network (a “big streets” approach) to a comprehensive "low- stress network” with a focus on enhancing the City’s bicycle boulevards, with limited improvements on arterials concentrated around crossing locations for the low-stress network. This change required substantial analysis in order to create a completely 5 Palo Alto Planning and Transportation Commission Meeting, November 12, 2025. Action Item. Bicycle and Pedestrian Transportation Plan (BPTP) Update: Provide Feedback and Recommend the Draft Plan to the City Council for Adoption. CEQA Status: Exempt Pursuant to Public Resources Code Section 21080.20.
https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16610&compileOutputType=1 6 Palo Alto City Council Meeting, December 1, 2025. Study Session: Bicycle and Pedestrian Transportation Plan (BPTP) Update: Draft Plan and Near-Term Projects. CEQA Status: Exempt Pursuant to Public Resources Code Section 21080.20. https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16332&compileOutputType=1 7 Palo Alto City Council Meeting, April 21, 2025. Consent Calendar: Approval of Contract Amendment No. 2 to Contract No. C23185922 with Kittelson & Associates, INC. to Extend Term for an Additional Year of Service Through June 30, 2026 for professional consultant services for the City's Bicycle and Pedestrian Transportation Plan Update; CEQA status - exempt under- California Senate Bill 922 (2022), codified as Public Resources Code section 21080.20.
https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16056&compileOutputType=1 Item 8
Item 8 Staff Report

Item 8: Staff Report
Pg.
3 Packet Pg. 147 of 291

updated priority project list as well as recommendations regarding policy frameworks to support a low-stress network and high-comfort approach.

3. Expanded Stakeholder Engagement: To address PABAC feedback, the team also facilitated additional focus group sessions to allow for a deeper dive into the Draft Plan’s recommendations, in addition to consultant-led educational sessions on modern best practice design guidance and implications.

The above task enhancements have resulted in a more robust project list and a Draft Plan that reflects community input and Palo Alto’s unique and successful approach to creating a walkable and bikeable environment. The changes were achieved using project contingency. Additionally, extensive reworking of the Draft Plan document was achieved by reallocating consultant labor that was initially designated for Final Plan preparation. To complete the Plan, an additional $17,000 is therefore requested for Final Plan Production. This work involves:
Incorporating direction from the Council Study Session on the Draft Plan on December 1, 2025.
Facilitating an additional round of community engagement with PABAC review of the Final Plan in Spring 2026.
Integrating final public and PABAC feedback into the Plan, where possible. Finalizing all maps, graphic design, and document formatting for the final document for Council presentation.

This work will allow the project team to deliver a Final Plan that adequately reflects the community and Council’s vision.

Staff anticipates presenting a Final Plan document for Council review and consideration for adoption in summer 2026.

FISCAL/RESOURCE IMPACT
The original contract for the 2026 Bicycle and Pedestrian Transportation Plan Update was supported by a reimbursable Metropolitan Transportation Commission Transportation Development Act Article 3 grant of $334,852. Contract Amendment Number 3 increases the total agreement by $17,000, bringing the new Not-to-Exceed total to $350,945.

While previous work utilized project contingency and grant funds, this additional $17,000 exceeds the original grant award. These funds are available in the Fiscal Year 2026 Adopted Capital Improvement Budget within the Bicycle and Pedestrian Transportation Plan Implementation project (PL-04010). There is no additional impact on the General Fund beyond what was already appropriated in the Fiscal Year 2026 Capital Budget.

Item 8
Item 8 Staff Report

Item 8: Staff Report
Pg.
4 Packet Pg. 148 of 291

STAKEHOLDER ENGAGEMENT
The Draft 2026 BPTP Update is the result of an extensive, four-phase engagement process that combined digital outreach with in-person events to ensure a broad representative voice. Phases 1 & 2 (Visioning and Needs) included public workshops, walking tours, and cycling tours. Feedback during this phase identified safety (particularly for students) as the top priority, as well as strong demand for a seamless, low-stress network that overcomes major barriers like highways and railroads while providing direct connections to schools and transit hubs.
Phases 3 & 4 (Recommendations and Draft Plan) included a community workshop, two series of board, commission and committee meetings (January-June 2025) as well as public comment on the Draft Plan (October-November 2025). Feedback during this phase called for a more robust, dual-layered prioritization framework (integrating qualitative and quantitative measures) and a to pivot from a "big streets" to "low-stress network" approach. During the final public comment period, feedback emphasized the desire for 20 mph speed limits on bike boulevards, proactive e-bike policies, and upgrades to Bryant Street corridor.

Members of the public also had opportunity to provide input on the Draft Plan at the November 12, 2025 PTC meeting, where PTC unanimously recommended adoption of the Plan and supported the focus on residential low-stress routes. Community members also provided input on the Draft Plan at the City Council Study Session on December 1, 2025.11 Since this time, City staff has also obtained further input from PABAC and community members at the February 4, 2026 PABAC meeting.

ENVIRONMENTAL REVIEW
California Senate Bill 922 (2022), codified as Public Resources Code section 21080.20, exempts active transportation plans, such as bicycle transportation plans like the BPTP Update, from environmental review under the California Environmental Quality Act (CEQA).

ATTACHMENTS
Attachment A: Kittelson & Associates, Contract C23185922 Amendment 3 APPROVED BY:

Ria Hutabarat Lo, Chief Transportation Official
11 Palo Alto City Council Meeting, December 1, 2025. Study Session: Bicycle and Pedestrian Transportation Plan (BPTP) Update: Draft Plan and Near-Term Projects. CEQA Status: Exempt Pursuant to Public Resources Code Section 21080.20. https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16332&compileOutputType=1 Item 8
Item 8 Staff Report

Item 8: Staff Report
Pg.
5 Packet Pg. 149 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

AMENDMENT NO. 3 TO CONTRACT NO. C23185922

BETWEEN THE CITY OF PALO ALTO AND
KITTELSON & ASSOCIATES. INC.

This Amendment No. 3 (this "Amendment") to Contract No. C23185922 (the "Contract" as defined below) is entered into as of March 2, 2026, by and between the CITY OF PALO ALTO, a California chartered municipal corporation ("CITY"), and KITTELSON & ASSOCIATES, INC. a California corporation, located at 155 Grand Ave. Suite 505, Oakland CA 94612 ("CONSULTANT"). CITY and CONSULTANT are referred to collectively as the "Parties" in this Amendment.

RECITALS

A. The Contract (as defined below) was entered into by and between the Parties hereto for the provision of production of the 2026 Bicycle and Pedestrian Transportation Plan Update, also known as the 2026 BPTP Update, as detailed therein.

B. The Parties now wish to amend the Contract in order to extend the term by six months from June 30, 2026, through December 31, 2026, and increase the compensation by Seventeen Thousand Dollars ($17,000) from Three Hundred Thirty -Three Thousand, Nine -Hundred Forty -five Dollars and Five Cents ($333,945.05) to a new not -to- exceed amount of Three Hundred Fifty Thousand. Nine Hundred Forty -Five Dollars, Five Cents ($350,945.05).

NOW, THEREFORE, in consideration of the covenants, terms, conditions, and provisions of this Amendment, the Parties agree:

SECTION 1. Definitions. The following definitions shall apply to this Amendment:

a. Contract. The term "Contract" shall mean Contract No.

C23185922 between CONSULTANT and CITY, dated May 30, 2023, as amended by:

1. Amendment No.1, dated November 8, 2024

2. Amendment No.2, dated March 26, 2025
Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
6 Packet Pg. 150 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

b. Other Terms. Capitalized terms used and not defined in this Amendment shall have the meanings assigned to such terms in the Contract.

SECTION 2 . Section 4 " NOT -TO-EXCEED COMPENSATION" of the Contract is hereby amended to read as follows:

The compensation to be paid to CONSULTANT for performance ofthe Services shall be based on the compensation structure detailed in Exhibit C, entitled "COMPENSATION," including any reimbursable expenses specified therein, and the maximum total compensation shall not exceed, Three Hundred Sixteen Thousand, Two Hundred Ninety -Five Dollars and Fifty Cents
Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
7 Packet Pg. 151 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

($316,295.50). The hourly schedule of rates, if applicable, is set out in Exhibit C -1, entitled "SCHEDULE OF RATES." Any work performed or expenses incurred for which payment would result in a total exceeding the maximum compensation set forth in this Section 4 shall be at no cost to the CITY.

� Optional Additional Services Provision (This provision applies only if checked and a not- to-exceed compensation amount for Additional Services is allocated below under this Section 4.)
In addition to the not- to-exceed compensation specified above, CITY has set aside the not- to-exceed compensation amount of Thirty-Four Thousand, Six Hundred Forty-Nine Dollars and Fifty-Five Cents, ($34,649.55) for the performance of Additional Services (as defined below)). The total compensation for performance of the Services, Additional Services and any reimbursable expenses specified in Exhibit C, shall not exceed Three Hundred Fifty Thousand, Nine Hundred Forty-Five Dollars, Five Cents ($350,945.05), as detailed in Exhibit C.
"Additional Services" means any work that is determined by CITY to be necessary for the proper completion of the Project, but which is not included within the Scope of Services described at Exhibit A. CITY may elect to, but is not required to, authorize Additional Services up to the maximum amount of compensation set forth for Additional Services in this Section 4. CONSULTANT shall provide Additional Services only by advanced, written authorization from CITY as detailed in this Section. Additional Services, if any, shall be authorized by CITY with a Task Order assigned and authorized by CITY's Project Manager, as identified in Section 13 (Project Management). Each Task Order shall be in substantially the same form as Exhibit A-1, entitled "PROFESSIONAL SERVICES TASK ORDER". Each Task Order shall contain a specific scope of services, schedule of performance and maximum compensation amount, in accordance with the provisions of this Agreement. Compensation for Additional Services shall be specified by CITY in the Task Order, based on whichever is lowest: the compensation structure set forth in Exhibit C, the hourly rates set forth in Exhibit C-1, or a negotiated lump sum.

To accept a Task Order, CONSULTANT shall sign the Task Order and return it to CITY's Project Manager within the time specified by the Project Manager, and upon authorization by CITY (defined as counter -signature by the CITY Project Manager), the fully executed Task Order shall become part of this Agreement. The cumulative Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
8 Packet Pg. 152 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

total compensation to CONSULTANT for all Task Orders authorized under this Agreement shall not exceed the amount of compensation set forth for Additional Services in this Section

4. CONSULTANT shall only be compensated for Additional Services performed under an authorized Task Order and only up to the maximum amount of compensation set forth for Additional Services in this Section 4. Performance of and payment for any Additional Services are subject to all requirements and restrictions in this Agreement.

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
9 Packet Pg. 153 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

SECTION 4. The following exhibit(s) to the Contract is/are hereby amended or added, as indicated below, to read as set forth in the attachment(s) to this Amendment, which is/are hereby incorporated in full into this Amendment and into the Contract by this reference:

a. Exhibit "B" entitled "EXHIBIT B, SCHEDULE OF PERFORMANCE, AMENDMENT NO. 3", AMENDED, REPLACES PREVIOUS.

b. Exhibit "C" entitled "COMPENSATION, AMENDMENT NO. 3", AMENDED, REPLACES PREVIOUS.

SECTION 5. Legal Effect. Except as modified by this Amendment, all other provisions of the Contract, including any exhibits thereto, shall remain in full force and effect.

SECTION 6. Incorporation of Recitals. The recitals set forth above are terms of this Amendment and are fully incorporated herein by this reference.

(SIGNATURE BLOCK FOLLOWS ON THE NEXT PAGE.)
Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
10 Packet Pg. 154 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

SIGNATURES OF THE PARTIES

IN WITNESS WHEREOF, the Parties have by their duly authorized representatives executed this Amendment effective as of the date first above written.

CITY OF PALO ALTO KITTELSON & ASSSOCATES

City Manager Officer 1

APPROVED AS TO FORM:

By:

Name: Dave Mi 7 7 s
Title: vice President

City Attorney or designee
Officer 2

By:

Name: Lawrence van Dyke
Title: vice President, CFO

Attachments:
"EXHIBIT B, SCHEDULE OF PERFORMANCE, AMENDMENT NO. 3", AMENDED, REPLACES PREVIOUS.
"EXHIBIT C, COMPENSATION, AMENDMENT NO. 3", AMENDED, REPLACES PREVIOUS.

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
11 Packet Pg. 155 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

EXHIBITB
SCHEDULE OF PERFORMANCE, AMENDMENT NO. 3 (AMENDED,

REPLACES PREVIOUS)

CONSULTANT shall perform the Services so as to complete each milestone within the number of days/weeks specified below. The time to complete each milestone may be increased or decreased by mutual written agreement of the Project Managers for CONSULTANT and CITY so long as all work is completed within the term of the Agreement.

CONSULTANT shall provide a detailed schedule of work consistent with the schedule below within 2 weeks of receipt of the notice to proceed ("NTP") from the CITY.

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

1. Prepare Detailed Work Plan and Strategy 6 days

2. Review Policy and Program Documents 30 days

3. Inventory Existing Facility Conditions 140 days

4. Community Outreach 375 days

5. Bicycle and Pedestrian Network
Enhancements
125 days

6. Implementation and Funding Strategy 35 days

7. Bicycle and Pedestrian Plan Document 300 days

8. Project Management and Oversight 80 weeks
[8J Optional Schedule of Performance Provision for On-Call or Additional Services Agreements. (This provision only applies if checked and only applies to on -call agreements per Section 1 or agreements with Additional Services per Section 4.)

The schedule of performance shall be as provided in the approved Task Order, as detailed in Section 1 (Scope of Services) in the case of on-call Services, or as detailed in Section 4 in the case of Additional Services, provided in all cases that the schedule of performance shall fall within the term as provided in Section 2 (Term) of this Agreement.

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
12 Packet Pg. 156 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

EXHIBIT C COMPENSATION,
AMENDMENT NO. 3
(AMENDED, REPLACES PREVIOUS)

CITY agrees to compensate CONSULTANT for Services performed in accordance with the terms and conditions of this Agreement, and as set forth in the budget schedule below.

Compensation shall be calculated based on the rate schedule attached as Exhibit C -1 up to the not to exceed budget amount for each task set forth below.

CITY's Project Manager may approve in writing the transfer of budget amounts between any of the tasks or categories listed below, provided that the total compensation for the Services, including any specified reimbursable expenses, and the total compensation for Additional Services (if any, per Section 4 of the Agreement) do not exceed the amounts set forth in Section 4 of this Agreement.

CONSULTANT agrees to complete all Services, any specified reimbursable expenses, and Additional Services (if any, per Section 4), within this/these amount(s). Any work performed or expenses incurred for which payment would result in a total exceeding the maximum amount of compensation set forth in this Agreement shall be at no cost to the CITY.

BUDGET SCHEDULE

TASK NOT TO EXCEED AMOUNT
Task 1
(Prepare Detailed Work Plan and Strategy)
$3,590.00
Task2
(Review Policy and Program Documents)
$9,130.00
Task 3
(Inventory Existing Facility Conditions)
$34,655.00
Task 4
(Community Outreach)
$90,360.00
Task 5
(Bicycle and Pedestrian Network Enhancements)
$71,185.00
Task 6
(Implementation and Funding Strategies)
$3,760.00
Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
13 Packet Pg. 157 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

Task 7
(Bicycle and Pedestrian Plan Document)
$61,300.00
Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
14 Packet Pg. 158 of 291

Docusign Envelope ID: B4D1EC1B-F482-4186-A44D-92B194A76706 Vers.: Aug. 5, 2019

Task 8
(Project Management and Oversight)
$12,515.50
Sub-total for Services $276,495.50
Reimbursable Expenses (if any) $29,800.00
Total for Services and Reimbursable Expenses $316,295.50 Additional Services (if any, per Section 4) $34,649.55
Maximum Total Compensation (w/ 10%Contingency) $350,945.05

REIMBURSABLE EXPENSES

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

Reimbursable expenses , if any are specified as reimbursable under this section, will be reimbursed at actual cost. The expenses (by type, e.g. travel) for which CONSULTANT will be reimbursed are: up to the not-to-exceed amount of: $29,800.00

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

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

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
15 Packet Pg. 159 of 291

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
16 Packet Pg. 160 of 291

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
17 Packet Pg. 161 of 291

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
18 Packet Pg. 162 of 291

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
19 Packet Pg. 163 of 291

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
20 Packet Pg. 164 of 291

Item 8
Attachment A - Kittelson &
Associates, Contract
C23185922 Amendment 3

Item 8: Staff Report
Pg.
21 Packet Pg. 165 of 291

City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: March 9, 2026
Report #:2601-5829
TITLE
FIRST READING: Adoption of an Ordinance Adding a New Section 18.70.105 (Noncomplying facility - De minimis exceptions) to Chapter 18.70 (Nonconforming Uses and Noncomplying Facilities) of Title 18 (Zoning) of the Palo Alto Municipal Code; CEQA Status: Exempt Pursuant to CEQA Guidelines Section 15061(b)(3) (Common Sense Exemption).

RECOMMENDATION
Staff recommends that the City Council (Council) adopt the draft Ordinance (Attachment A) amending Palo Alto Municipal Code (PAMC) Title 18 (Zoning) regulations to add a new section regarding noncomplying facilities de minimis exceptions.

EXECUTIVE SUMMARY
On September 15, 2025, Council directed staff to prepare a text amendment within six months authorizing the Director of Planning and Development Services to approve de minimis exceptions from noncomplying facility regulations and similar minor adjustments that are not impactful to adjacent properties or public realm for residential properties. The proposed ordinance amending PAMC Chapter 18.70 to add a new code section for a de minimis exception for modifications to noncomplying facilities responds to Council’s direction. The proposed ordinance limits this exception to allow minor relocations of non-complying floor area for single-family homes as detailed further in this report.

On January 14, 2026, the Planning and Transportation Commission (PTC) unanimously recommended approval of the ordinance with minor modifications for clarity.

BACKGROUND
On May 8, 2025, the Director of Planning and Development Services issued a formal interpretation of PAMC Chapter 18.70, concluding that noncomplying gross floor area (GFA) may not be removed and replaced elsewhere on a site, even where total GFA is not increased.

Item 9
Item 9 Staff Report

Item 9: Staff Report
Pg.
1 Packet Pg. 166 of 291

This interpretation was prompted by a minor remodel of a single-family home that remains over the district’s GFA limit.

A timely appeal challenged the interpretation, arguing that the project does not intensify noncompliance and should be allowed. Staff believe that the Director’s interpretation (Attachment A to the September 15, 2025, Council staff report1) reflects the most reasonable and consistent application of the Municipal Code and that it supports the broader policy goal of reducing noncomplying conditions over time. While the proposal in the appellant’s case was minor, permitting it would have rendered portions of the code meaningless and could have created a precedent for larger changes inconsistent with the Code’s purpose.

Council Consideration and Direction
The appeal of the Director’s Interpretation was placed on the consent calendar on June 16, 2025, and was pulled by three members of City Council for full discussion. On September 15, 2025, Council held a public hearing to consider the appeal and approved the staff recommendation by a vote of 6-0-1, with Council Member Lu abstaining, with the following motion:

1. Uphold the Director of Planning and Development Services’ formal interpretation dated May 8, 2025, concluding that noncomplying residential gross floor area may not be removed and restored elsewhere on the property pursuant to Palo Alto Municipal Code (PAMC) Chapter 18.70, denying the associated appeal; and,

2. Direct staff to prepare a text amendment within six months authorizing the Director of Planning and Development Services to consider or approve de minimis exceptions from noncomplying facility regulations and similar minor adjustments that are not impactful to adjacent properties or public realm for residential properties.

The September 15, 2025, City Council meeting minutes are available online.2 On January 14, 2026, the PTC unanimously recommended approval of the draft ordinance with minor modifications for clarity.

ANALYSIS
The draft Ordinance (Attachment A), revised per the PTC’s recommendation, would add a new section to PAMC Chapter 18.70:

18.70.105 Noncomplying facility - De minimis exception
1 September 15, 2025, Council Staff Report:
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=9235&meetingTemplateType=2&comp iledMeetingDocumentId=16839
2 September 15, 2025, Council Summary Minutes:
https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=16227&compileOutputType =1
Item 9
Item 9 Staff Report

Item 9: Staff Report
Pg.
2 Packet Pg. 167 of 291

Notwithstanding the requirements of Sections 18.70.080, 18.70.090, and 18.70.100, up to 250 square feet of non-complying floor area (i.e. floor area associated with a non-complying feature) may be relocated as follows, provided that the degree and manner of non-compliance is not increased:
(a) The non-complying facility houses a single-family residential use in a low-density residential zone district; and
(b) Any proposal to relocate non-complying floor area will comply with the following:

1. Projects that include relocation of 150 to 250 square feet to a location above the ground floor shall be subject to Section 18.10.040, subd. (i), or 18.12.110, as applicable; or

2. Projects that include relocation of less than 150 sf above the ground floor and that are therefore not subject to Individual Review, shall comply with the objective standards for single-family development as applicable to the proposed relocation.

This proposal would allow minor relocations of non-complying floor area by right for single- family homes. While staff initially explored allowances for a broader range of exceptions, this would likely require a discretionary review process with flexible findings related to impacts on neighboring properties. Rather than creating more processes, which would require staff resources and add expense for applicants, staff is proposing the narrow and simple exception stated above. This proposed text was developed based on the following goals:
Six-month turnaround for code amendment;
Align with the meaning of “de minimis” – trivial or minor; Avoid additional process/delay/appeals;
Preventing impacts on neighboring properties;
Align with other floor area thresholds existing in the code; and Allow flexibility for projects similar in scale to the one proposed by the appellant.

Staff recommend 250 square feet as the proposed threshold of what constitutes de minimis for alignment with square foot thresholds used in other areas of the Zoning Code as it relates to allowances within low-density residential zone districts. Through the application of the Individual Review process, where applicable, or the two-story objective design standards (if Individual Review does not apply), any modifications to the second floor would be reviewed to minimize impact to adjacent properties or the public realm. Both the Individual Review guidelines and the objective standards address massing, neighborhood context, and privacy for residential properties.

FISCAL/RESOURCE IMPACT
Implementation of the draft ordinance is not anticipated to have significant fiscal or budgetary impact. The new de minimis exception is intended to be a ministerial process that would occur Item 9
Item 9 Staff Report

Item 9: Staff Report
Pg.
3 Packet Pg. 168 of 291

within an existing building permit review process and would therefore be absorbed within the department budget and resources. If a project were to require Individual Review, per PAMC Section 18.12.110, then standard application fees would apply.

STAKEHOLDER ENGAGEMENT
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post on February 27, 2026, which is 10 days in advance of the meeting. This recommendation is the culmination of stakeholder engagement through the meetings with City Council and stakeholders described earlier in this report.

ENVIRONMENTAL REVIEW
This action is categorically exempt from the California Environmental Quality Act (CEQA) under CEQA Guidelines Section 15061(b)(3), the common sense exemption, because it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.

ATTACHMENTS
Attachment A: Draft Ordinance Amending PAMC Chapter 18.70 APPROVED BY:

Jonathan Lait, Planning and Development Services Director Item 9
Item 9 Staff Report

Item 9: Staff Report
Pg.
4 Packet Pg. 169 of 291

*NOT YET APPROVED*

0160183_20260202_ay16
1 Ordinance No. ______
Ordinance of the Council of the City of Palo Alto Amending Title 18 (Zoning) of the Palo Alto Municipal Code to Amend Requirements Relating to Accessory Dwelling Units and Junior Accessory Dwelling Units

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

SECTION 1. Section 18.70.105 (Noncomplying facility – de minimis exception) of Chapter 18.70 (Nonconforming Uses and Noncomplying Facilities) of Title 18 (Zoning) of the Palo Alto Municipal Code is added to read as follows:

18.70.105        Noncomplying facility - De minimis exception

Notwithstanding the requirements of Sections 18.70.080, 18.70.090, and 18.70.100, up to 250 square feet of non-complying floor area (i.e. floor area associated with a non-complying feature) may be relocated as follows, provided that the degree and manner of non-compliance is not increased:

(a) The non-complying facility houses a single-family residential use in a low-density residential zone district; and
(b) Any proposal to relocate non-complying floor area will comply with the following:
(1) Projects that include relocation of 150 to 250 square feet to a location above the ground floor shall be subject to Section 18.10.040, subd. (i), or 18.12.110, as applicable; or
(2) Projects that include relocation of less than 150 sf above the ground floor and that are therefore not subject to Individual Review, shall comply with the objective standards for single-family development as applicable to the proposed relocation.

SECTION 2. If any section, subsection, sentence, clause, or phrase of this Ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have passed this Ordinance and each and every section, subsection, sentence, clause, or phrase not declared invalid or unconstitutional without regard to whether any portion of the ordinance would be subsequently declared invalid or unconstitutional.

SECTION 3. The Council finds that the adoption of this Ordinance is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Public Resources Code Section 21080.17 and CEQA Guidelines sections 15061(b)(3), 15301, 15302 and 15305 because it constitutes minor adjustments to the City’s zoning ordinance to implement State law requirements related to accessory dwelling units as established in Government Code Section 65852.2, and these changes are also likely to result in few additional dwelling units dispersed throughout the City. As such, it can be seen with certainty that the proposed action will not have the potential for causing a significant effect on the environment.

Item 9
Attachment A - Draft
Ordinance Amending PAMC
Chapter 18.70

Item 9: Staff Report
Pg.
5 Packet Pg. 170 of 291

*NOT YET APPROVED*

0160183_20260202_ay16
2 SECTION 4. This ordinance shall be effective on the thirty-first date after the date of its adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

NOT PARTICIPATING:

ATTEST: _______________________________ __________________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:
_______________________________ __________________________________ Assistant City Attorney City Manager
__________________________________
Director of Planning & Community
Environment
Item 9
Attachment A - Draft
Ordinance Amending PAMC
Chapter 18.70

Item 9: Staff Report
Pg.
6 Packet Pg. 171 of 291

City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: March 9, 2026
Report #:2602-5893
TITLE
Receive Update and Provide Direction to Staff on the Implementation of Senate Bill 79 (2025) and Work Related to the Downtown Housing Plan. CEQA Status: Exempt Under CEQA Guidelines Section 15262.

RECOMMENDATION
Staff recommends that the City Council:
Consider the implications of Senate Bill (SB) 79 in the identified transit-oriented development (TOD) areas and the potential approaches towards its implementation; and
Provide direction on the preferred approach for the citywide implementation of SB 79 and the Downtown Housing Plan initiative.

EXECUTIVE SUMMARY
SB 79 will take effect on July 1, 2026. The legislation is intended to facilitate the upzoning of land located in proximity to qualifying transit stations, thereby promoting TOD through the establishment of new minimum standards for building height, residential density, and floor area.

In the City of Palo Alto, numerous parcels are located within the influence areas of three qualifying transit stations: two Caltrain stations within the City of Palo Alto and one Caltrain station in the City of Mountain View adjacent to the City and are therefore subject to the provisions of SB 79.

This report provides an overview of the implications of SB 79 and outlines the next potential steps for the citywide implementation of State law, including a range of policy options for City Council consideration and direction.

Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
1 Packet Pg. 172 of 291

BACKGROUND
SB 79, codified in Government Code Section 65912.155, et seq., supersedes locally adopted standards for density, floor area ratio (FAR), and height. These new standards are for housing projects proposed on qualifying sites located within one-half mile of a TOD stop, provided the development meets specified statutory requirements. Local jurisdictions may adopt an ordinance to exempt historic properties or may prepare a TOD Alternative Plan that modifies applicable development standards, subject to review and approval by the California Department of Housing and Community Development (HCD).

On October 22, 2025,1 staff provided the City Council an update on the Downtown Housing Plan and an overview of SB 79 and requested direction on the implementation of the State law. The classification of qualifying transit stops, and key statutory provisions discussed in that report are highlighted below:

Distance from Pedestrian Access Point to a TOD Stop
Tier 1 TOD Stop (Caltrain)Development
Standard Up to ¼-mile Up to ½-mile
“Adjacent” (within
200’) Bonus Height,
Density, and
Residential FAR
Height2 75’ 65’ 95’
Density 120 du/ac 100 du/ac 160 du/ac
Residential Floor
Area Ratio (FAR)

3.5 3.0 4.5
The City Council appointed a Downtown Housing Plan/Senate Bill 79 Implementation Ad Hoc Committee to further evaluate the implications of SB 79. Staff met with the Ad Hoc Committee on January 27, 2026, and presented a detailed analysis of areas affected by SB 79, projected residential development, and policy options for Council consideration. The Ad Hoc Committee discussed the analysis and recommended staff bring the suggested approaches to the full Council for consideration, as well as share this information with Palo Alto’s state legislators.

ANALYSIS
As previously noted, the implementation of SB 79 is limited to sites that meet specific statutory eligibility criteria, including applicable zoning designations and proximity to qualifying transit stops. Although SB 79 requires the Metropolitan Transportation Commission (MTC), the 1 October 22, 2025 City Council Staff Report
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=18007 2 Note that a qualifying project may use the standards in SB 79 as its base density under state density bonus law; however, if the project exceeds the City’s height limit due to the provisions of SB 79, the City is not required to grant an additional height waiver.

Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
2 Packet Pg. 173 of 291

region’s designated Metropolitan Planning Organization, to prepare and publish official maps identifying applicable TOD zone boundaries, City staff have not yet received these maps.

Staff analyzed SB 79 TOD zones and eligible parcels within the City for informational purposes to support discussion and an analysis of the areas affected by SB 79. The exhibits developed are preliminary and are subject to revision upon release of the official maps by MTC. The analysis was presented to the City Council’s Ad Hoc Committee. A summary of the key takeaways from the analysis is provided below.

Key Takeaways
Lack of data from MTC and HCD:

Staff are currently awaiting the release of the official TOD zone maps from the MTC, as well as the forthcoming technical advisory toolkit from HCD, to ensure accurate interpretation and implementation of SB 79. These materials are expected to provide critical guidance on implementing the State law.
SB 79 significantly reshapes development near transit:

SB 79 establishes state-mandated minimums for height, density, and FAR on qualifying parcels near Caltrain stations, substantially limiting the City’s discretion under existing zoning and adopted planning frameworks. Cities can adopt an Ordinance temporarily exempting sites that are: within a Very High Fire Hazard Severity Zone, subject to Flooding, are Historic Resources listed in the local register, or that are zoned for high density residential use providing at least 50% of the capacity required by SB 79. Downtown Housing Plan Scope Is Smaller Than SB 79 Impact Area:

While the University Avenue/Downtown Priority Development Area encompasses approximately 206 acres, the Downtown Housing Plan covers only 76 acres. In contrast, SB 79 affects a much larger area; approximately 325.23 acres, around the Downtown/University Avenue Caltrain Station. This includes the Downtown Housing Plan area, South of Forest Avenue (SOFA) areas, the transit center, and Stanford Shopping Center.
Historic resources require consideration:

Downtown Palo Alto and the San Antonio Road area contain a high concentration of historic properties or properties within historic districts. SB 79 includes limited provisions for historic resources. The City is allowed to adopt an ordinance to temporarily ensure these resources are protected. Ongoing protection is achievable only by adopting, prior to January 31, 2032, a TOD Alternative Plan; even then, protected historic resources cannot exceed 10% of the area of a TOD zone. SB 79 currently does not provide express guidance on the Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
3 Packet Pg. 174 of 291

treatment of historic districts, but it appears that a local ordinance may protect historic districts in addition to individual historic structures. This is subject to change with additional guidance from HCD.
Small parcel sizes limit realistic redevelopment potential:

Feasibility analysis indicates that parcels smaller than approximately 5,200 square feet are less likely to redevelop, unless multiple parcels are combined. This reduces development potential particularly in the Downtown/University Avenue area, limiting the number of sites that can realistically take advantage of SB 79 standards. Historically, there has been little interest for lot consolidation in Palo Alto, even with development incentives. Redevelopment is likely to occur on a limited subset of eligible land:

Although SB 79 enables substantial theoretical housing capacity across all three station areas, the realistic capacity is substantially lower and difficult to translate into future unit production. To illustrate potential housing growth over the next 25 years within these TOD areas, staff conducted a screening-level analysis that excluded parcels less likely to redevelop, including those with historic resource designations, properties redeveloped within the last 25 years, small lots that would not support feasible redevelopment or meet SB 79 unit density standards, public facility and planned community zoned properties, transit-owned land, sites with condominium subdivision maps, and properties with office development exceeding 1.5 times the parcel area. After applying these filters, staff estimates a more realistic picture of redevelopable property as follows:
Downtown/University Avenue Transit Station Area: Approximately 163 acres California Avenue Transit Station Area: Approximately 222 acres San Antonio Transit Station Area: Approximately 32 acres Further discounting is necessary, however, because redevelopment is costly and carries risk for developers. Many property owners will be satisfied leaving their properties as-is despite the potential for increased housing development. Staff anticipates that the vast majority of single-family homeowners are unlikely to pursue apartment buildings on their property, though some may choose to do so. A review of development activity over the past 25 years shows that only ten percent of all parcels redeveloped, with exceedingly few single-family zoned properties converting to multifamily housing. Applying a ten percent redevelopment factor consistent with this historical activity, and a one percent factor for single-family zoned property, staff can estimate a theoretical range of future housing production from SB 79 for each transit station area over the next 25 years. These figures are not a projection or formal estimate; they are simply a calculation based on screening criteria and existing Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
4 Packet Pg. 175 of 291

baseline data, and are subject to numerous variables that cannot be fully accounted for through this type of screening-level analysis.
Downtown/University Avenue Transit Station Area: Approximately 1600 units California Avenue Transit Station Area: Approximately 900 units San Antonio Transit Station Area: Approximately 200 units The above analysis does not account for recent changes to state law that promote greater development potential including exemptions to the California Environmental Quality Act, allowances for taller buildings, greater floor area, reduced parking requirements, and state density bonus concessions and waivers and application streamlining. These measures add greater predictability to the development process and may encourage additional property owners to consider redevelopment.
California Avenue faces the greatest zoning shift:

The California Avenue SB 79 area contains a substantial proportion of single-family zoned property, including larger 10,000-square-foot lots in the Old Palo Alto neighborhood that would not require land consolidation to support apartment development. New construction built to SB 79 standards may appear contextually inconsistent with the historic development pattern northeast of the Caltrain station.

The commercial areas along and near California Avenue have seen little significant redevelopment in recent years, due in part to small lot sizes and the former requirement for on-site parking, both of which made redevelopment economically impractical. The interaction of SB 79 with other state laws could catalyze future housing or mixed-use development, with uncertain implications for the area's retail environment. New development may also lack coordinated design or placemaking, with larger parcels likely proving more attractive for redevelopment than smaller ones. San Antonio Road area raises unique historic district uncertainties:

San Antonio Road area includes large concentrations of Eichler homes and a designated historic district. SB 79’s treatment of historic districts, where individual properties are not separately listed, may be the subject of additional guidance from HCD. Because exclusion of historic sites is limited to 10% of TOD land area after January 31, 2032, not all historic sites can be protected in the long term.
The Economic Feasibility Analysis prepared for the Downtown Housing Plan remains relevant:

Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
5 Packet Pg. 176 of 291

While SB 79 provides development opportunities to owners of qualifying properties, the feasibility of such projects depends on current market conditions, broader market trends, site constraints, competing uses, impact fees, and inclusionary housing requirements. This is outlined in the Economic Feasibility Analysis prepared for the Downtown Housing Plan, which was included as Attachment A to the October 22, 2025, City Council Staff Report.5 State Density Bonus Law:

SB 79 projects are eligible to use State Density Bonus Law6 to seek a density bonus, incentives or concessions, waivers or reductions for development standards and parking ratios. The density allowed under SB 79 serves as the base density for calculating the density bonus. However, a project proposing a height allowed by SB 79 that is in excess of the local height limit is ineligible for a waiver for additional height beyond that specified in SB 79. This does not apply for 100% affordable projects located within one-half mile of a major transit stop.
Assembly Bill (AB) 130 (2025):

AB 130 (2025)7 significantly streamlines housing development approvals in urban communities by creating a new statutory exemption from CEQA for qualifying infill residential projects. This means that qualifying residential or mixed-use infill projects (generally up to 20 acres) that are consistent with either applicable Comprehensive Plan or zoning regulations (as modified by SB 79 and/or state density bonus law) could bypass CEQA review entirely, with an accelerated permitting timeline. The exemption applies to projects meeting minimum density thresholds, and site qualifications (i.e., not located in floodplains, fault zones, wetlands, or very high fire severity zones, not a hazardous waste site, and not demolishing a historic structure).

AB 130 amends the Permit Streamlining Act by imposing strict timelines for City review and approval. If the City does not act within 30 days following its objective standards review and the required tribal consultation, a project may be deemed automatically approved. This substantially reduces staff’s ability to present projects for review by the ARB, PTC, or City Council.

Developers must comply with the new labor standards for 100% affordable housing projects and buildings over 85 feet in height, meet air quality requirements, and perform 5 October 22, 2025 City Council Staff Report:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=18007 6 https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=65915&lawCode=GOV 7 https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB130 Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
6 Packet Pg. 177 of 291

contamination cleanup as appropriate. The law does not alter State Density Bonus Law provisions, including waivers and parking reductions. This means that in addition to the increased FAR permitted under SB 79, developers could seek to waive maximum lot size limitations in residential zones, setbacks, open space requirements, site coverage, daylight plane requirements, or even retail preservation requirements through the State Density Bonus Law.
Assembly Bill (AB) 2097 (2022):

AB 2097 (2022)11 eliminates minimum parking requirements for new development (residential, commercial, and most other uses) located within one-half mile of high-quality transit service (i.e., major transit stops such as the Caltrain Station). This essentially prohibits local governments from enforcing minimum parking requirements for qualifying projects. In Palo Alto, the State law is applicable to all properties that lie within one-half mile radius of the University Avenue, California Avenue, and San Antonio Road Caltrain Stations. It is unclear at this time whether the applicable area for AB 2097 will be identical to the applicable area for SB 79, as the two statutes have slightly different language regarding the one-half mile radius.

Downtown Housing Plan/SB 79 Implementation Ad Hoc Committee:

On January 27, 2026, staff presented four potential approaches to implementing SB 79 to the Ad Hoc Committee, each reflecting varying levels of effort and scope. These approaches considered:
Existing and ongoing planning initiatives;
Anticipated additional workload and its potential impact on City Council priorities for the current year;
Expected near term planning initiatives;
Staff capacity and available resources;
Fiscal implications;
Opportunities for community engagement; and
Review and approval timeline established by HCD pursuant to the state law.

While all four approaches advance the State’s pro-housing objectives, they differ in the degree to which the City exercises local control. The City may choose to allow SB 79 to preempt local codes, adopt an ordinance clarifying how SB 79 applies locally, including exclusion of historic properties, and/or prepare a Transit-Oriented Development (TOD) Alternative Plan, based on 11 https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB2097 Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
7 Packet Pg. 178 of 291

the considerations outlined above. Both an ordinance and a TOD Alternative Plan may require environmental analysis and are subject to HCD review.

In addition, the City Council may provide direction to staff to either continue or discontinue work on the Downtown Housing Plan. Discontinuing work on the Downtown Housing Plan would not require the City to return MTC grant funds that have already been paid to the City.

The four potential approaches are listed below. Staff requests Council’s feedback and direction to staff on a preferred approach with respect to SB 79 implementation and continued effort on the Downtown Housing Plan.
Approach 1: No action on SB 79
Under this approach, the default development standards established by SB 79 would take effect on July 1, 2026, for all qualifying TOD zones. This approach requires no action by the City and no review by HCD, resulting in automatic compliance with State law.

However, it provides the least amount of local control and community input and does not protect historic resources.
Approach 2: Adopt an Ordinance
Under this approach, the default SB 79 standards would still take effect on July 1, 2026, but the City would adopt an ordinance clarifying the application of SB 79 locally and identify sites that are exempt. This approach provides additional local control and community input and allows for the temporary exemption of historic resources.

Adoption of the ordinance would be subject to HCD review. If this option were selected, staff would return before July 1, 2026, with an emergency ordinance on the consent calendar and follow up with formal adoption through the Planning and Transportation Commission (PTC) and City Council later in the year.
Approach 3: Rezone all TOD eligible sites to allow 50 percent of the SB 79 development potential
Pursuant to Government Code Section 65912.161(b), sites can be exempted from SB 79 default standards through January 31, 2032, if they allow at least 50 percent of SB 79 base density standards. Under this approach, the City would rezone TOD-eligible sites accordingly and adopt a subsequent ordinance exempting all sites until January 31, 2032, either as historic sites or because they are sufficiently high density. This option provides the City approximately six years to consider a TOD Alternative Plan, incorporate targeted policy measures, and plan for infrastructure upgrades in anticipation of future growth. However, the initial rezoning would require a consultant to prepare the environmental review and its associated costs, and shifts staff resources from other policy initiatives. Any ordinance exempting sites would be subject to HCD review and approval.

Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
8 Packet Pg. 179 of 291

Given the anticipated timeline for environmental review, Planning and Transportation Commission consideration, and City Council adoption, it is unlikely that the rezoning could be adopted prior to July 1, 2026. As a result, there would be an interim period during which SB 79 default standards would apply until the rezoning becomes effective, likely twelve months after receiving direction to proceed. Approach 4: Prepare a TOD Alternative Plan
Under this approach, the default SB 79 standards would take effect on July 1, 2026, while the City concurrently prepares a TOD Alternative Plan applicable to all TOD zones.

The TOD Alternative Plan could include targeted development standards, infrastructure planning, and a structured community outreach process. Adoption of a TOD Alternative Plan would render planning efforts such as the Downtown Housing Plan redundant and may overlap to some degree with other work related to Housing Element Program 3.7:

Objective Design Standards for the SOFA area. The approach, however, provides greater local control and public input, but would require several hundred thousand dollars for consultant work and significant staff resources, both of which are currently unaccounted for and resourced. The TOD Alternative Plan would be subject to HCD review and approval.

As suggested, continuing with the Downtown Housing Plan with Approach 4 is not recommended, but remains an option for the other approaches.

NEXT STEPS
Based on Council direction, staff will proceed with implementation efforts for SB 79 and the required environmental analysis as directed. For Approach 4, staff would need to return to Council with a scope of work and cost estimate before seeking consultant solicitation for the planning and environmental work. For Approaches 1-3 staff will engage the Council ad hoc as necessary.

Based on guidance for the Downtown Housing Plan – if the initiative continues, staff will engage the Council ad hoc throughout the remainder of the year to strategize on continued analysis and community engagement and strive to complete the project, likely in 2027.

FISCAL/RESOURCE IMPACT
Fiscal and resource impacts will vary based on Council direction and the associated level of effort. Approaches 1 and 2 would not result in additional fiscal nor resource impacts. Approach 3 would require preparation of an environmental analysis, necessitating consultant support and associated costs. However, these costs are not anticipated to exceed existing funding available within the department’s budget.

Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
9 Packet Pg. 180 of 291

If Council directs staff to pursue Approach 4, staff will return with a detailed scope of work and cost estimate. Preliminary estimates indicate that the effort would cost approximately $500,000 in additional funds beyond those already allocated for the Downtown Housing Plan, including the grant funding from MTC.

STAKEHOLDER ENGAGEMENT
Although SB 79 was intended as a streamlining mechanism to accelerate housing production near transit, its implementation includes requirements for broader community engagement and public input, including public hearings, if a local agency chooses to prepare a TOD Alternative Plan. While no public engagement is required if the City takes no action on SB 79 (Approach 1), Approaches 2, 3, and 4 would each involve varying levels of public engagement.

Additionally, if Council directs staff to complete the Downtown Housing Plan, the project team will build upon outreach activities already conducted and will ensure the planning process remains transparent, inclusive, and responsive to the perspectives of residents, businesses, and other key stakeholders.

ENVIRONMENTAL REVIEW
The actions recommended in this report are exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15262: A project involving only feasibility or planning studies for possible future actions that have not been approved, adopted, or funded would not have significant impact on the environment.

Staff, however, will prepare an environmental analysis for the citywide implementation of SB 79, as appropriate, based on the approach selected by City Council.

ATTACHMENTS
None.

APPROVED BY:

Jonathan Lait, Planning and Development Services Director Item 10
Item 10 Staff Report

Item 10: Staff Report
Pg.
10 Packet Pg. 181 of 291

City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Manager
Meeting Date: March 9, 2026
Report #:2602-6021
TITLE
Approval of City Council Values (as Recommended by Policy & Services Committee), 2026 Objectives, Ad Hoc Purpose Statements, and Committee Workplans

RECOMMENDATION
Staff recommends that the City Council approve: (a) Revised Council Values, as recommended by the Policy & Services Committee, (b) 2026 City Council Group 1 Objectives, and (c) Ad Hoc Purpose Statements and Committee Workplans.

EXECUTIVE SUMMARY
At its January 24, 2026 annual retreat, the City Council adopted a refined framework for establishing priorities and objectives that emphasizes clarity, focus, and implementation. Under this approach, City Council Values represent enduring policy commitments; Priorities identify a limited number of areas requiring heightened focus; and Objectives define specific, measurable actions to advance both values and priorities. This structure is intended to strengthen accountability, align resources with Council direction, and ensure meaningful progress within the year.

This report presents: (a) recommended revised City Council Values as recommended by the Policy & Services Committee; (b) the proposed 2026 Group 1 Objectives aligned with the adopted Priorities; and (c) Ad Hoc Purpose Statements and Committee Workplans for City Council consideration and adoption. Objectives are organized into three categories: Group 1 (mission-critical and requiring City Council engagement), Group 2 (value-adding initiatives with flexible timing), and Staff Not Recommended. While all Group 1 and Group 2 objectives will be tracked for progress, quarterly reporting will focus on Group 1 objectives to align with City Council’s highest priorities. The Policy & Services Committee reviewed and consolidated proposed revisions to the City Council Values and unanimously recommends adoption of an updated set of values.

Item 11
Item 11 Staff Report

Item 11: Staff Report
Pg.
1 Packet Pg. 182 of 291

It should be noted that the objectives and timeframes described here were developed prior to the identification of potential near-term changes being considered at railroad grade crossings.

The effort required to address this issue may impact timelines of other priority objectives.

BACKGROUND
At its January 24, 2026 annual retreat, the City Council articulated a refined approach to identifying priorities that emphasizes clarity, focus, and implementation1. City Council distinguished between enduring Council Values, time-bound priorities, and actionable objectives, noting that values should reflect long-standing policy commitments, while priorities should represent a limited number of areas requiring heightened Council attention in the near term. Several policy areas previously treated as annual priorities were recognized as ongoing in nature and more appropriately reflected as values, allowing annual priorities to be more targeted and strategic. This refined approach remains consistent with the Council’s Policies and Protocols Handbook.

Under this approach, the Council seeks to limit the number of priorities to those initiatives where focused effort can realistically result in meaningful progress within the year, taking into account staff capacity, fiscal considerations, and operational complexity. Objectives will be used to capture the full scope of ongoing work and define specific milestones, while priorities will signal areas requiring elevated focus or resource alignment. City Council expressed interest in further refining the City Council Values framework through the Policy & Services Committee to ensure priorities clearly guide implementation and support accountability throughout the year.

The 2026 City Council Priorities are:
Achieve Near-Term Priority Housing Milestones
Cubberley Acquisition and Renovation Funding
Enhance Business Vibrancy
Government Efficiency
The original City Council Values referred to Policy & Services Committee to revise are:

The Palo Alto City Council has universally shared values that help guide our decision and the work we do. These values include:

1. We will make decisions that balance revenues and expenses, now and in the future.

2. We will make decisions that are environmentally sustainable, now and in the future.

3. We will integrate equity into our decisions, considering how decisions affect people differently based on their identity or circumstances.

4. We will make decisions that create a healthy, safe and welcoming community for all.

5. We will safeguard public trust through transparent practices and open communication. 1 January 24, 2026 City Council Retreat:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=18520 Item 11
Item 11 Staff Report

Item 11: Staff Report
Pg.
2 Packet Pg. 183 of 291

6. We embrace innovation.

This report outlines the reorganized proposed 2026 Objectives within the adopted Priorities and City Council Values, incorporating City Council feedback and the refined priority framework. It also includes ad hoc purpose statements and committee workplans for City Council consideration and adoption, as well as the recommended City Council Values refined by the Policy & Services Committee for City Council consideration.

ANALYSIS
City Council Values
On February 10, 2026, the Policy & Services Committee discussed the City Council referral to refine the City Council Values and considered proposed revisions submitted by City Councilmembers Burt, Reckdahl, and Mayor Veenker.3 The Committee noted that the proposals were mostly aligned, with differences primarily related to wording, organization and level of specificity. The Committee emphasized readability, clarity, succinctness, and ensuring that the final values incorporated key themes raised in all the suggested drafts, including economic development, fiscal stewardship, equity, belonging, innovation, climate action and adaptation, transparency, and community well-being. Following revisions and consensus on language, the Committee agreed on a consolidated set of seven City Council Values and voted unanimously to recommend that the City Council adopt the updated values:

1.Vibrant Community. Cultivate a dynamic community by fostering retail vibrancy, economic development, engaging public spaces, and a high quality of life for all.

2.Fiscal Responsibility. Exercise disciplined financial management to ensure city revenues and expenses remain balanced and sustainable, and are fiscally strategic and responsible.

3.Accountable Governance. Earn public trust through transparent leadership, inclusive engagement, and open communication.

4.Strategic Innovation. As the birthplace of Silicon Valley, embrace innovation in the public and private sectors to optimize efficiency and outcomes.

5.Equity and Shared Prosperity. Center equity in every decision, and advance housing, workforce, and social policies that promote inclusion, socioeconomic diversity, and opportunity.

6.Climate Leadership and Environmental Stewardship. Lead with urgency on climate action and adaptation, sustainability, and environmental protection for current and future generations.

7.Community Well-Being & Belonging. Foster a safe, healthy, and welcoming community where everyone belongs and can thrive physically, mentally, and socially. 3 February 10, 2026 Policy & Services Meeting:
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=10899&meetingTemplateType=2&com piledMeetingDocumentId=18478
Item 11
Item 11 Staff Report

Item 11: Staff Report
Pg.
3 Packet Pg. 184 of 291

Proposed 2026 Objectives
At its retreat, the City Council reviewed and provided feedback on a preliminary list of objectives which included continuing projects from the 2025 objectives list, existing City Council referrals, as well as newly proposed objectives. As proposed, the objectives were presented under three groups, Group 1, Group 2, and Staff Not Recommended. All are intended to reflect SMARTIE (Specific, Measurable, Realistic, Time-bound, Inclusive, and Equitable) framing.

Group 1 objectives are categorized as mission-critical, and must be achieved to meet legal, operational, safety, or strategic requirements. Objectives in this group will require City Council engagement. These are captured in Attachment A.

Group 2 objectives are value-adding initiatives that are important, improve quality of life or advance longer-term goals, but flexible in timing and dependent on capacity or completion of Group 1 priorities. These do not create immediate risk if delayed. Many of the objectives captured in this category are already underway and will not require Council action to be completed. These are captured in Attachment B.

Staff Not Recommended objectives include projects that are not recommended to be part of the 2026 list of objectives, for a variety of reasons including feasibility challenges, or work is already underway as part of a greater effort, such as the draft proposed Business Retention, Expansion, and Attraction (BRE/A) strategy in Attachment G. A narrative for each objective not being recommended is summarized in Attachment C.

In total, a total of 42 objectives are in Group 1. A total of 24 objectives are in Group 2. Lastly, a total of 14 objectives are in the Staff Not Recommended group. While progress will be tracked for all objectives in Groups 1 and 2, quarterly reporting will focus on Group 1 objectives to align with City Council’s highest priorities.

Priority Group
1 Group
2 Staff Not
Recommended
Achieve Near Term Priority Housing Milestones 15 6 6
Cubberley Acquisition and Renovation Funding 2 0 0
Enhance Business Vibrancy 5 7 4
Government Efficiency 8 0 0
Council Values 12 11 4
Total 42 24 14
Objectives in the City Council Values sections refer to the original values as outlined in the Handbook since the Policy & Services Committee recommended edits have not yet been adopted. Staff will made administrative corrections to corresponding values after Council approval.

Item 11
Item 11 Staff Report

Item 11: Staff Report
Pg.
4 Packet Pg. 185 of 291

Ad Hoc Purpose Statements and Committee Workplans
Achieving progress on Priorities and Objectives is a partnership between City Council and staff.

City Council engagement is reflected through their strategic and focused work on standing and ad hoc committees; this year there are eight (8) ad hoc committees in addition to the City Council’s Standing Committees (Finance, Policy & Services, Council Appointed Officers, and City/Schools Liaison):
Rail Committee (Brown Act)
Rail Safety/Youth Mental Health Ad Hoc
Cubberley Ad Hoc
Economic Development Ad Hoc (Brown Act)
Climate Action & Sustainability Ad Hoc (Brown Act)
Oversized Vehicles Impacts & Services Ad Hoc
Downtown Housing Plan and SB79 Ad Hoc
Valley Water Shoreline Funding Allocation Ad Hoc- the purpose of this ad hoc was fulfilled in 2025.

The City Council Handbook defines ad hoc committees as a temporary advisory committee limited to a single purpose and is not intended to be perpetual but rather to be dissolved in a finite period of time, once its specific task is completed. The Handbook also states that if an ad hoc does not complete its task by the end of the calendar year, it shall not continue unless reappointed by the new Mayor in the following year. A summary of the ad hoc purpose statements for the year is included in Attachment D.

Recommended workplans for the Standing Policy & Services and Finance Committees are included in Attachments E and F, respectively. As work proceeds over the year, it is likely that changes to committee workplans may be desired. Staff or Committees may recommend such changes for City Council approval at any point during the year.

FISCAL/RESOURCE IMPACT
City Council approval of Priority Objectives does not have an immediate fiscal impact; however, resources will need to be allocated to implement City Council Priorities. Opportunities to allocate resources to projects include the FY 2027 annual budget process, with adoption scheduled for June 2026. In addition, the City Council may amend the budget throughout the year.

STAKEHOLDER ENGAGEMENT
City Council, community and stakeholder engagement is a key area of focus that is woven into the workplans to implement the proposed City Council objectives contained in this report.

Item 11
Item 11 Staff Report

Item 11: Staff Report
Pg.
5 Packet Pg. 186 of 291

The City uses the International Association for Public Participation (IAP2) as a guide to structure community participation and align that participation with the type of input or feedback needed based on the project/issue. Workplan engagement typically fit within these general focus areas:

Inform: Fact sheets, webpages, blog posts, information sessions, open houses, frequently asked questions, community briefings, and website feedback forms Consult & Involve: Surveys, focus groups, questions and answer sessions, office hours, public meetings like community meetings, town halls, panel discussions, workshops, and polling Collaborate & Empower: Working groups, ad hoc groups, feedback groups, boards, commissions and committee meetings, community advisory panels, advisory groups, digital engagement platforms, and voter ballot measures.

ENVIRONMENTAL REVIEW
City Council action on this item is not a project as defined by CEQA because the City Council discussion on 2026 Priority and Objectives, Ad Hoc Purpose Statements, and Committee Workplans are a continuing administrative or maintenance activity. CEQA Guidelines section 15378 (b)(2).

ATTACHMENTS
Attachment A: City Council 2026 Priorities & Objectives- Group 1 Attachment B: City Council 2026 Priorities & Objectives- Group 2 Attachment C: Staff Not Recommended Objectives
Attachment D: 2026 Ad Hoc Committee Purpose Statements
Attachment E: Policy & Services Committee Workplan
Attachment F: Finance Committee Workplan
Attachment G: Draft Business Retention, Expansion, and Attraction (BRE/A) Strategy

APPROVED BY:

Ed Shikada, City Manager
Item 11
Item 11 Staff Report

Item 11: Staff Report
Pg.
6 Packet Pg. 187 of 291

ATTACHMENT A
1 2
3 4
5 6
7 8
9 10
11 BCDE F G H IJ K L M
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
ANPHM
CA&RF
EBV
GE $'s
Achieve Near‐Term Priority Housing Milestones (ANTPHM)‐ 15 Total x
Adopt an updated Accessory Dwelling Unit (ADU) ordinance to comply with State law and implement additional policy alternatives, including increased allowable square footage and condominium conversions, consistent with City Council direction (05.15.23). Milestone: Planning and Transportation Commission recommendation and City Council consideration of draft ordinance. x 1
x
Evaluate opportunities that make multi‐family housing an attractive alternative to commercial office development, consistent with Housing Element Program 3.9A.

Milestones: Feedback from Policy & Services Committee in Q1 and advance ordinance to Council in Q2. x 1
x
Partner with Santa Clara County Housing Authority to achieve construction timeline milestones for the Palo Alto Homekey project (which will provide transitional housing and services for unhoused residents). Milestone: Formal opening of the Palo Alto Homekey facility at 1237 San Antonio Rd. x 1
x
Receive a Prohousing Designation from the California Department of Housing and Community Development in order to enhance the City's competitive advantage for qualifying grants. Milestone: Apply to HCD in Q1; receive approval in Q2.   x x
Select a preferred alternative for the San Antonio Road Area Plan land use and transportation alternatives based on community input and City Council direction.

Milestones : Stakeholder input for alternatives (PTC, community, and advisory bodies') in Q1, Council selection of preferred alternative(s) in Q2, Environmental Impact Review in Q3, and Council review of policy recommendations in Q4. x 1 x
Develop and adopt Objective Development Standards for the South of Forest Area Coordinated Area Plan (SOFA), and present plan amendment options to replace subjective standards with objective standards for Planning and Transportation Commission and City Council consideration, consistent with Housing Element Program 3.7. Explore alignment opportunities with SB 79 work and Downtown Housing Plan. Milestones: Planning and Transportation Commission recommendation and City Council consideration of amended SOFA CAP and/or municipal code amendments by end of 2026.  x 1
x
Codify the R1/SB 9 interim ordinance by establishing objective development standards and increasing the maximum floor area for SB 9 units from 800 to 1,200 square feet, consistent with Housing Element Program 6.3A, and evaluate implications for R1 and SB 9 projects within the City’s Individual Review Program.

Milestones: Planning and Transportation consideration of draft ordinance in Q3; Council consideration in Q4. x 1
Priority
CC Value  #
OBJECTIVES (42 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
Attachment A - Page 1 of 6
Item 11
Attachment A - City Council
2026 Priorities Objectives-
Group 1

Item 11: Staff Report
Pg.
7 Packet Pg. 188 of 291

ATTACHMENT A
1 2
3 BCDE F G H IJ K L M
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
ANPHM
CA&RF
EBV
GE $'s
Priority
CC Value  #
OBJECTIVES (42 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
12 13
14 15
16 17
x
Conduct and complete a study of short‐term rentals and adopt housing and neighborhood preservation regulations that prioritize long‐term occupancy, consistent with Housing Element Programs 4.2D–E (anticipates ordinance adoption by July, 2027). Milestones: report to City Council in Q3; prepare alternatives for Council and Planning and Transportation Commission review in Q4, 2026 or Q1, 2027, if request
ed. x 1
x
Receive Council direction on optional SB 79 implementation strategies and, as appropriate, present scenario Downtown Housing Plan scenarios to Council and initiate environmental review. Milestones: Work with SB 79 and Downtown Housing Plan City Council Ad‐Hoc Committee on next steps in Q1 and Q2 based on SB 79 imp
lementation approach; advance Downtown Housing Plan based on direction received from City Council through Q4. x 1
x
Adopt zoning incentives and development standards that support innovative housing typologies, including micro‐units, intergenerational housing, housing for aging adults, students, and lower‐income households, consistent with Housing Element Program

6. 5B. Milestones : Study session with Planning and Transportation Commission in Q1; recommendations for Architectural Review Board consideration in Q2; Planning and Transportation Commission recommendation and City Council consideration of draft ordinance in Q4. x 1
x
Update and adopt development impact fees for public safety, government facilities, housing, transportation, parks, and community services, including comp letion of nexus and feasibility studies and establishment of fee waivers for low‐income inclusionary units. (Housing Element Programs 2.1B; 3.1B & C). Milestone: Present development scenarios and growth assumptions to Council for feedback by Q2.

Adopt Parks, Library & Community Facility Fee Updates by Q3. Adopt additional fee update
s by Q1 2027. x 1
x
Issue Requests for Information or Requests for Proposals (RFI/P) to develop approximately 218 affordable or workforce housing units on City‐owned surface parking lots. (Housing Element Program 1.4A). Milestone: Review draft RFI/P with Policy & Services Committee by Q3 2026 to issue the solicitation process by year end. x 1 x
Identify and designate additional Housing Element site capacity to maintain RHNA compliance and buffer by evaluating new opportunity sites to address anticipated capacity shortfalls in 2026, including impacts from development on faith‐based sites and downtown parking lots. Milestones : Select consultant to provide technical analysis in Q1; Planning and Tran sportation Commission recommendation and City Council consideration of replacement Housing Element sites in Q3. x 1 $‐$$ Attachment A - Page 2 of 6
Item 11
Attachment A - City Council
2026 Priorities Objectives-
Group 1

Item 11: Staff Report
Pg.
8 Packet Pg. 189 of 291

ATTACHMENT A
1 2
3 BCDE F G H IJ K L M
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
ANPHM
CA&RF
EBV
GE $'s
Priority
CC Value  #
OBJECTIVES (42 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
18 19
20 21
22 23
24 25
26 x
Implement Oversized Vehicles (OSV) Phase 1 work, including options for RV buyback and storage, new recruiting safe parking and enforcement/signage relating to detached/inoperable vehicles prohibition. Milestones: In coordination with the OSV Ad hoc, seek Council direction on preferred option(s) on RV buyback and storage in Q2. Implement signage and enforce detached/inoperable vehicl es prohibition in Q2.

Work with OSV Ad Hoc on recruiting new safe parking and bring any potential projects to Council for consideration in Q3. (related to 2025 Objective 3.3.4).  x 1 $$‐
$$$
x
Initiate and advance Oversized Vehicles Phase 2 work, including oversized vehicle permit pilot (e.g., collecting count data, designing permit process & terms, conducting informal RFI/Q to operate pilot). Milestone : Develop OSV permit pilot, including enhanced services and bring to Council for consideration. (related to 2025 Objective

3.3.4). x  1
$$‐
$$$
Cubberley Acquisition and Renovation Funding (CA&RF)‐ 2 Total Continue to advance the Cubberley Project focusing on anticipated purchase of 7 acres from PAUSD and community polling for potential placement of a measure on the November 2026 ballot and other funding source(s).  x 1 Continue to explore and develop partnership opportunities with community nonprofit organizations to advance certain elements of the master concept plan throu
gh a combination of city and private investments. x 1
Enhance Business Vibrancy (EBV)‐ 5 Total
x
Develop a formal business retention/expansion/attraction program focused on supporting existing Palo Alto businesses seeking to diversify the local economy, increase the tax base that pays for essential public services, job creation, support placemaking and special events, and branding opportunities. Milestone: With the Economic Development Ad Hoc Committee, review and solidify for Council approv al a Business Retention, Expansion, and Attraction (BRE/A) Strategy with various implementation actions; an initial draft is attached to this staff report. x 1 x
Adopt an ordinance expanding retail opportunities and strengthening retail resiliency, including refining retail and retail‐like definitions and updating the retail preservation ordinance. Milestone:  PTC review and recommendation in Q2; City Co uncil review and action in Q3. Continued engagement with stakeholders prior to implementation. X 1 x
Implement the California Avenue near‐term signage plan replacing the El Camino Real (October 2026) and Oregon Expressway (August 2026) signs—by  completing their procurement and installation.  x 1
Attachment A - Page 3 of 6
Item 11
Attachment A - City Council
2026 Priorities Objectives-
Group 1

Item 11: Staff Report
Pg.
9 Packet Pg. 190 of 291

ATTACHMENT A
1 2
3 BCDE F G H IJ K L M
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
ANPHM
CA&RF
EBV
GE $'s
Priority
CC Value  #
OBJECTIVES (42 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
27 28
29 30
31 32
33 34
35 x
Continue design work on new parking structure in Downtown core (Lot D).

Milestone: Complete entitlement process and design development phase by the end of 2026. x  1
x
Secure City Council approval for the California Avenue Outdoor Activation Guidelines.

These guidelines will be finalized through continued stakeholder engagement that includes a representative mix of busines s owners and residents and a formal Architectural Review Board (ARB) review. x 1 $
Government Efficiency (GE)‐ 8 Total
x
Develop and balance FY 2027 budget by June 30 prioritizing government efficiency, ongoing solutions and balancing fiscal impacts of policies and practices including consultant contracts, downtown parking and general fund subsidies, nonprofit partnerships and revenue enhancements. x1
x
Implement a standardized Citywide Consultant Stewardship Framework—covering the lifecycle from the decision to outsource and scope drafti ng to contract close‐ out—to  develop and manage scope of services and enhanced reporting on use of professional services. x1
x
Improve City processes by streamlining approval of revised procurement thresholds and contract authority. x1
xx
Improve and streamline staff work on homelessness, housing and services for vulnerable residents. Milestones: Centralize in City Manager's Office, Identify and imp
lement ways to improve processes and reporting (e.g., consolidating contracts, standardizing reporting, HSRAP). x1
x
Leverage the Palo Alto 311 staff working group workplan, vendor support and City Auditor benchmarking advice to improve clarity and timing of constituent response and satisfaction, and enhance staff efficiencies by aligning report categories with cons
tituent expectations, and implementing vendor‐proposed 2026 system upgrades—including  integrating AI tools. x1
x
Modify the municipal code to remove the requirement for planning entitlement approval (such as architectural review) or compliance with zoning regulations and procedures for capital improvement or other city‐initiated projects on publicly owned right of way and land.  x1
Attachment A - Page 4 of 6
Item 11
Attachment A - City Council
2026 Priorities Objectives-
Group 1

Item 11: Staff Report
Pg.
10 Packet Pg. 191 of 291

ATTACHMENT A
1 2
3 BCDE F G H IJ K L M
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
ANPHM
CA&RF
EBV
GE $'s
Priority
CC Value  #
OBJECTIVES (42 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
36 37
38 39
40 41
42 43
44 45
x
Explore options to streamline delivery of low‐cost, high‐value (aka quick build) traffic safety improvements and update the City’s Traffic Calming Policy to align with Safety Action Plan, Bicycle/Pedestrian Transportation Plan (BPTP) and Safe Routes to School.

Milestone: Council review of existing program, policy needs and approaches. x1 x
Relocate City operations in Utilities and th e Development Center back to City Hall in order to reduce rent expense to third party landlords, maximizing revenue to the General Fund, and consolidating property and facility management within City owned land. x  1
Council Values‐ 12 Total
3,4
Open 429 Bryant Street Community Center. Complete construction and any necessary partnership agreements to begin La Comida Senior Lunch Program at the facility by end of July, 2026; plan further work for general community center operations concurrently.  x 1
3,4
Execute MOU with Santa Clara County for assignment of clinician to PD Psychiatric Emergency Response Team (PERT) in Jan 2026. x 1
2 Adopt ordinance updates establishing additional Green Building Standards and Energy Reach Codes. Milestone: City Council consideration of ordinance for adoption by June 2026. x 1
2 Complete 2026 Bicycle and Pedestrian Transportation Plan (BPTP) with City Council adoption of the plan. x 1
2 Advance recommendations for the Regional Water Quality Control Plant Biosolids Facility Plan. Milestone: Conduct community engagement, refine and review recommendations with Council Committee in 2026, and further develop implementation strategies in preparation for Council acceptance of the Biosolids Facility Plan in 2027.   x 1
2 Advance design of Grade Separation projects at Charleston Road, Meadow Drive and Churchill Avenue. Milestone: Complete 15% design and select Locally Preferred Alternative for 35% design at each crossing. x 1
4 Update the Safety Element and develop an Evacuation Plan pursuant to SB 99, AB 747, and AB 1409. Milestones: contract with consultant to develop evacuation plan, present draft Safety Element amendments to Planning and Transportation Commission and City Council consideration with final submittal to state for review in Q3.  x 1
Attachment A - Page 5 of 6
Item 11
Attachment A - City Council
2026 Priorities Objectives-
Group 1

Item 11: Staff Report
Pg.
11 Packet Pg. 192 of 291

ATTACHMENT A
1 2
3 BCDE F G H IJ K L M
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
ANPHM
CA&RF
EBV
GE $'s
Priority
CC Value  #
OBJECTIVES (42 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
46 47
48 49
50 51
3,4
Support Community Mental Health through provision of support for all ages through community partnerships, programs, and initiatives. Milestone: continue work with the Jed Foundation engagement to support youth mental health and suicide prevention efforts. x 1
2 Implement the strategies contained in the 2026‐2027 Sustainability and Climate Action Plan Work Plan. Milestone: Complete progress on strategies implementation in substantial alignment with the Target Completion Dates contained in the Work Plan. x 1
4 Pursue a natural grass athletic field pilot project to determine the best management practices to enhance playability and durability. Milestones : Q1 work with the Parks and Recreation Commission (PRC) to develop a workplan for the Turf Pilot. Q2 seek Council approval of work plan and funding. Q3 Conduct enhanced maintenance pilot and feasibility study at two locatio
ns. Q4 Conduct stakeholder engagement on
conceptual designs and present to PRC. Funding and construction of high performing grass fields to be completed in 2027‐28 pending Council review and approval. x 1 $$‐
$$$
2 Develop and recommend for Council approval a multi‐year grid modernization capital improvement plan focused on improving reliability and facilitating city‐wide customer electrification by upgrading  sub‐transmission, substation, and distribution infrastructure. Issue the first tranche of debt financing in 2026. x1 $$$$ 4 Advance Quiet Zones at Palo Alto Avenue, Churchill Avenue, Meadow Drive, and Charleston Road Rail Crossings. Milestone: Council approval of Notice of Establishment and Quiet Zone implementation at Palo Alto Avenue; and identification of funding and procurement of professional services for design of required improvements to establish Quiet Zones at Churchill, Meadow and Charleston . x 1 $$$$ $ = up to 50K;    $$ = 51‐499K,     $$$ = 500K‐999k,      $$$$ = 1M + Attachment A - Page 6 of 6
Item 11
Attachment A - City Council
2026 Priorities Objectives-
Group 1

Item 11: Staff Report
Pg.
12 Packet Pg. 193 of 291

ATTACHMENT B
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16

BCDE F G HI JK L MG
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
ANPH
CA&RF
EBV
GE $'s
Achieve Near‐Term Priority Housing Milestones (ANPHM)‐ 6 Total x
Present initial data from the first year rental registry program to Policy and Services for discussion and an information report update to City Council.  x 2 x
Present to Policy and Services an analysis related to anti‐rent gouging and forward Committee recommendations to the City Council.  x 2
x
Adopt a renter protection “fair chance” ordinance, including findings and implementing regulations. (Housing Element Program 6.6I). Milestones:  City Council Policy and Services Committee consideration in Q2 of ordinance revised based on City Council direction; City Council consideration upon P&S recommendation in Q3. x 2
x
Release a Request for Proposals for development of the one‐acre site near Matadero Creek dedicated to the City under the 2023 Sobrato/City Development Agreement. Milestone: Issue RFP by end of 2026. x 2
x
Expand and implement the Safe Parking Program in commercial areas by increasing geographic coverage and service availability citywide. (Housing Element Program

6.4A and Council assigned 12.04.23). Milestones: Initiate draft of zoning text amendment by end of 2026. x 2
x
Organize an initial review of sources and methods to raise funding to support new affordable housing production for future evaluation. x 2 Cubberley Acquisition and Renovation Funding (CA&RF)‐ 0 Total Enhance Business Vibrancy (EBV)‐ 7 Total
x
Complete stable car free street improvements on Ramona Street, e.g. bollards and barriers, signage, and parking regulations. Milestone: Implementation of updated parking signage and painted curbs, and installation of spherical bollards, vehicular barriers, and updated signage. x 2
x
Modernize Downtown parking policy to increase availability of premium parking, reduce operating subsidies, encourage development and economic diversity and vibrancy, and reduce fossil fuel dependency. Milestone: Council review of options to modernize parking policy. x 2
Priority
CC Value #
OBJECTIVES (24 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
Attachment B - Page 1 of 3
Item 11
Attachment B - City Council
2026 Priorities Objectives-
Group 2

Item 11: Staff Report
Pg.
13 Packet Pg. 194 of 291

ATTACHMENT B
1 2
3 BCDE F G HI JK L MG
ANPH
CA&RF
EBV
GE $'s
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
Priority
CC Value #
OBJECTIVES (24 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
17 18
19 20
21 22
23 24
25 26
27 x
Extend the existing interim ordinance or adopt a new ordinance that restores and implements subjective wireless communication facility regulations. Milestones:

Present an ordinance to the City Council in Q4. x 2
x
Begin feasibility analysis of Assessment District for University Avenue Streetscape.

Conduct analysis to determine practicality of an assessment district or similarly funding strategy as a funding mechan
ism for capital enhancements to University
Avenue Streetscape.  x 2 $$
x
Design and provide funding appropriations to improve the car free portion of California Ave for bike and pedestrian markings and calming and minor physical environment adjustments to reduce friction with the outdoor dining guidelines (e.g. movement of bike racks).  x 2 $$$
x
Engage stakeholders to develop design proposals for Car‐Free Ramona Street and present to Council for necessary funding appropriations to implement initial phase(s). Begin Historic Resource Board and Architectural Review Board  review of activation guidelines in late 2026/early 2027.  x 2 $$$ x
Initiate process for Development of the Comprehensive Plan Update. Milestone :

Confirm a more limited scope for the upcoming 2030 Comprehensive Plan to inform the release of an RFP by Q4 2026 to select a consultant to support the limited scope refresh; consultant funding will be necessary.
x 2 $$$
Government Efficiency (GE)‐ 0 Total
N/A
Council Values‐ 11 Total
2 Adopt Bird‐Friendly Design standards. Milestones: City Council consideration in March/April 2026 of ordinance recommended by PTC in late 2025. x 2 2 Adopt an ordinance updating Stream and Creek Corridor Setback requirements.

Milestone: PTC consideration of revised draft ordinance in Q2, 2026; Council consideration of draft ordinance in Q3, 2026. x 2
2,4
Update the City's Natural Environment Element Update to comply with recent state law. Milestone: Prepare draft revisions for review by the Parks and Recreation Commission, Planning and Transportation Commission, and City Council by Q3, 2026. Present Comp Plan amendments to PRC, PTC, and City Council by the Q4 of 2026.  x 2
Attachment B - Page 2 of 3
Item 11
Attachment B - City Council
2026 Priorities Objectives-
Group 2

Item 11: Staff Report
Pg.
14 Packet Pg. 195 of 291

ATTACHMENT B
1 2
3 BCDE F G HI JK L MG
ANPH
CA&RF
EBV
GE $'s
2026 DRAFT CITY COUNCIL PRIORITIES AND OBJECTIVES
Priority
CC Value #
OBJECTIVES (24 Total)
Sorted by:

Council Priority, Group #, estimated completion date, and finally by additional resource needs.

Q1
Q2
Q3
Q4
Group #
28 29
30 31
32 33
34 35
36 2,4
Advance design on South Palo Alto Bikeway project to increase walking and biking and enhance safety. Milestone: Initiate work on pilot bikeway project. x 2 2,4
Complete concept design for additional east‐west bicycle/pedestrian crossing of railroad tracks in the southern part of the City. Milestone: Council review of draft report on South Palo Alto Connectivity. x 2
2 Continue to implement 3‐phase plan presented to Council in September 2024 for phasing out leaded fuel at Palo Alto Airport. Milestone: Initiate lead air monitoring program in Q1, work with the new fuel provider and supplier to inform tenants and encourage the use of unleaded fuel, and provide a progress update to City Council. x 2
4 Restart and make progress on the Palo Alto Airport master planning process.

Milestone: Develop updated alternatives informed by Council feedback from September 2024, conduct public stakeholder meetings, and conduct a study session with Council to review progress. x 2
4 Develop and adopt updates to the City’s seismic risk mitigation ordinance.

Milestone: Seek policy guidance from Policy and Services Committee, review draft ordinance with Policy and Services Committee, and Council consideration of ordinance updates by Q4 2026. x 2
2,3
Launch new Palo Alto education and rebate program for electric stoves and cooktops, with a goal of 50 electric cooktop conversions from gas. Milestone:

Program is available to customers by the end of Q2 2026. x 2 2 Implement Quarry Road Extension in Partnership with Stanford University, Caltrans and VTA. Milestone: Execute grant agreement with MTC and submit initial engineering package to Caltrans to confirm process. x 2 6 Complete build‐out of fiber‐to‐the‐premises (FTTP) pilot Phase 1 and begin provision of beta service for a municipal high speed fiber service. Establish internet service provider operations and through iterative customer engagement, and provision services to  residents in the initial pilot area. x 2
$ = up to 50K;    $$ = 51‐400K,     $$$ = 500K‐999k,      $$$$ = 1M + Attachment B - Page 3 of 3
Item 11
Attachment B - City Council
2026 Priorities Objectives-
Group 2

Item 11: Staff Report
Pg.
15 Packet Pg. 196 of 291

ATTACHMENT C
1 0
5 6
7 Staff Not Recommended Objectives
For various reasons, including staff capacity to advance, feasibility challenges, or that work is already underway, some objectives from the 2025 Priority Objectives list, previous Council suggestions, or the Annual Retreat suggestions are not recommended to become priority objectives for 2026. Staff will be prepared to respond to any Councilmember’s questions.

12. Begin implementation of the City Facility Electrification Plan. Milestone: Council approval of design consultant contract and procurement of a contractor to construct projects at first two buildings. This objective will continue as a staff priority but is not recommended for inclusion as a standalone project, as it is already incorporated into the 2026–2027 Sustainability and Climate Action Plan Work Plan. Instead, staff has added a broader objective focused on implementing the Work Plan items overall, which encompasses this initiative.

15. Pilot electrification as a service, charging as a service, or creative financing programs to complement the City' s single-family, multi-family, and/or non-residential electrification programs, that can be scaled.

Milestone: At least one new financing program is available to single-family, multi-family, and/or non- residential customers by the end of 2026.
This objective will continue as a staff priority but is not recommended for inclusion as a standalone project, as it is already incorporated into the 2026–2027 Sustainability and Climate Action Plan Work Plan. Instead, staff has added a broader objective focused on implementing the Work Plan items overall, which encompasses this initiative.

16. Develop long-term Climate Action funding and financing strategies and scenarios for Council consideration. Milestone: Present strategies and scenarios to the Council Committee for consideration by December 2026.
This objective will continue as a staff priority but is not recommended for inclusion as a standalone project, as it is already incorporated into the 2026–2027 Sustainability and Climate Action Plan Work Plan. Instead, staff has added a broader objective focused on implementing the Work Plan items overall, which encompasses this initiative.

54. Implement Senate Bill 79 by developing and presenting implementation options and advancing a recommended approach for City Council adoption. Seek direction from SB 79 and Downtown Housing Plan City Council Ad-Hoc Committee on next steps in Q1 and Q2; present recommendations for City Council consideration and next steps on SB 79 implementation before July 1, 2026; develop SB 79 alternative plan if directed by City Council.
Objective has been combined and updated with Objective #50.

82. Implement a gas-powered leaf blower ban citywide, based on recommendation from Policy and Services Committee.
Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway.

Item 11
Attachment C - Staff Not
Recommended Objectives

Item 11: Staff Report
Pg.
16 Packet Pg. 197 of 291

ATTACHMENT C
1 0
5 6
7 83. Develop and implement strategies to activate vacant commercial storefronts, including establishing regulatory tools and streamlined permitting for temporary pop-up stores. Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway.

84. Zoning Code Update. Comprehensively Update the City's Zoning Code including policies that support Economic Development Strategies. Reformat for improved readability, update definitions, use categories, development standards and permitting processes. Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway.

85. Prepare and present an El Camino Real Area Plan that prioritizes housing production and advance implementation consistent with City Council direction. Milestones: Initiate discussion of scope of and vision for new area plan.
Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway.

86. Study and report on vacancy tax options for commercial properties and residential “ghost homes,” including enforcement mechanisms used in other jurisdictions. Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway.

87. Increase housing capacity in the California Avenue corridor by developing and adopting policy and zoning options for City Council approval (assigned 08.14.23). Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway.

88. Coordinate and partner with CalCHA (California Community Housing Agency) to support affordable housing development initiatives.
Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway.

89. Zoning Code Text Amendments relating to impacts of higher density housing on neighboring properties multi-family uses on commercially zoning properties next to residential uses (even if not residentially zoned). Assigned 11.13.23: Direct staff to review proposed amendments to PAMC

18.16.040(b) and 18.16.060 regarding Redwood residences as described in the November 7, 2023 letter from Kristi Bascom.
Staff is not recommending this project at this time due to limited resources and the need to prioritize other Council-directed initiatives currently underway. Moreover, the interested parties can file a text amendment application to initiate this process.

Item 11
Attachment C - Staff Not
Recommended Objectives

Item 11: Staff Report
Pg.
17 Packet Pg. 198 of 291

ATTACHMENT C
1 0
5 6
7 90. Council consideration of a design option for California Avenue. Continue engaging stakeholders to refine alternative street designs for California Avenue and present to Council for discussion and action, including funding appropriations to pursue a street design in late Q2/early Q3 2026. Staff is not recommending this project at this time due to limited human and financial resources.

Suspending the project will allow staff to focus on completing the California Avenue Outdoor Activation Guidelines and supporting businesses in their requests and plans for improvements.

To activate this project funding would be necessary both for staff and professional services ($$$).

91. Refine destination marketing efforts and enhance Palo Alto’s international reputation. Meet with hospitality partners and incubator/accelerators to assess willingness to partner with the City on destination marketing efforts and propose next steps, including necessary appropriation actions, to City Council in Q2 2026.
These efforts are being incorporated into the proposed Business Retention, Expansion, and Attraction (BRE/A) Strategy.

Item 11
Attachment C - Staff Not
Recommended Objectives

Item 11: Staff Report
Pg.
18 Packet Pg. 199 of 291

ATTACHMENT D
2026 Ad Hoc Committee Purpose Statements
And Tentative meeting schedules
Rail Committee
To meet every other month
The Rail Committee reviews the projects and provides recommendations to the City Council based on the Rail Guiding principles adopted by the City Council (August 8, 2022). The projects include: the grade separations and safety improvements at existing crossings, additional east-west bicycle and pedestrian railroad crossings, and quiet zone improvements. Rail committee will review and advance projects for Council approval.

Rail Safety/Youth Mental Health
Meeting as needed
The Rail Safety/Youth Mental Health Ad Hoc Committee will facilitate Council decision-making on near- term modifications to rail crossings in response to and for prevention of youth and other suicides. This Ad Hoc Committee will also support communication with other agencies such as Caltrain.

City Council involvement and coordination with the JED Foundation’s ongoing postvention engagement is handled by the City/Schools Liaison Committee.

Cubberley Ad Hoc Committee
To meet monthly or as necessary to meet the project schedule The Cubberley Ad Hoc will facilitate City Council review and approval of the master plan process and serve as the Council ambassador for engagement with the community and building community support for development for a new community center at the Cubberley site. This includes making recommendations to the Council on the future operating model (e.g. services available, recommend to Finance Committee an approach to fees & charges, space allocation) and master plan that will successfully receive voter support in 2026.

Coordination with PAUSD on Cubberley will occur through this committee rather than the City Schools Liaison Committee. Operations, funding, and ballot measure work (including polling) may be heard by the Finance Committee rather than the Cubberley Ad Hoc for recommendations to the full City Council.

Economic Development Ad Hoc Committee
To meet every other month
The Economic Development Committee will provide a regular forum for business and community stakeholders to engage with Council members on implementation of the City’s economic development strategy. The Economic Development Committee will make recommendations to the City Council and provide ongoing engagement on approved economic development priorities to enhance business vibrancy efforts, including business retention, expansion, and attraction.

Item 11
Attachment D - 2026 Ad
Hoc Committee Purpose
Statements

Item 11: Staff Report
Pg.
19 Packet Pg. 200 of 291

ATTACHMENT D
Climate Action & Sustainability Ad Hoc Committee
To meet monthly
The Climate Action & Sustainability Committee facilitates implementation of the Climate Action workplan items of the 2026/2027 Sustainability and Climate Action Plan (S/CAP) Workplan and the 2026 Council Priority Objectives which fall under the Council values on environmental sustainability.

Oversized Vehicles Impacts & Services Ad Hoc
Meeting as needed
The Oversized Vehicles (OSV) Ad Hoc Committee was created at the October 20, 2025 Council Meeting.

The Committee is tasked with 1) recommending details on increased enforcement; 2) sharing recommendations on other issues related to the implementation of the Oct. 20 Council motion on OSVs (including safe parking street cleaning, urgency ordinances for detached trailers and “vanlording,” and considering options for buyback or parking program); 3) evaluating Phase 2 activities; and 4) participating with staff in further engagement. To date, meeting frequency has been weekly, with few exceptions.

Downtown Housing Plan and SB 79 Ad Hoc
Meeting as needed
Established late 2025, the purpose of the ad hoc is to explore options to implement SB 79, including no additional action, and support staff’s continued work on the Downtown Housing Plan through the balance of calendar year 2026. Meeting frequency will vary throughout the year with more meetings initially and fewer meetings toward the end of the year averaging out to approximately one meeting every two months.

Valley Water Shoreline Funding Allocation Ad Hoc
Meeting as needed
The Valley Water Shoreline Funding Allocation Ad Hoc was announced at the February 24, 2025 City Council meeting, in response to a Valley Water proposal to shift funding for addressing sea level rise in the north County to a south County project. The committee was announced with an expectation of being active for approximately 60 days. Valley Water ultimately deferred taking the action in 2025, and proceeded with making process improvements to support better communications and consultation for future proposals affecting project funding.

The purpose of this ad hoc was fulfilled in 2025.

Item 11
Attachment D - 2026 Ad
Hoc Committee Purpose
Statements

Item 11: Staff Report
Pg.
20 Packet Pg. 201 of 291

City of Palo Alto I 250 Hamilton Avenue, Palo Alto, CA I www.paloalto.gov – February 2026

POLICY & SERVICES TENTATIVE TOPICS CALENDAR 2026

Tentative as of February 10, 2026

January
• Nonprofit Workplan item
• Referral (2024): Establish a frequency for joint City Council meetings or Policy & Services meeting with Boards and Commissions, Youth Council, and meetings with Boards and Commissions Chairs; - Kept referral per P&S on Dec. 9, 2025

February
• Council referral (from Jan 24, 2026 retreat): Update City Council Values and Consider Renaming them (linked to adopted values on November 7, 2022 –
https://portal.laserfiche.com/Portal/DocView.aspx?id=31240&repo=r- 704298fc&searchid=0d712abe-b8ef-435e-9045-9198fc7001ae) • SB 707 Brown Act Updates
• Seismic Ordinance Follow up discussion

Note: All items listed for the following months are tentative in date at this time. Items will be moved around based on item readiness and agenda capacity in partnership with Committee Chair closer to the actual meeting date.

March
• Nonprofit Partnership Phase I Improvements
• Consider Policy Tool Options to Encourage Multi-Family Development in Mixed-Use Districts (2023- 2031 Housing Element Program 3.9(A)).
• Audit: Utilities Reserves

April
• Discussion of Local Residential Rental Market Data and Recommendation regarding whether to Pursue a Rent Stabilization Program
• Present initial data from the first-year rental registry program to Policy and Services for discussion and an information report update to City Council.
• Legislative Update
• Fair Chance in Housing Ordinance
• Incentives at Strategic Locations to Shift the Economic Benefit of Redevelopment from Commercial Toward Home Building (2023-2031 Housing Element Program 3.9(A)). • Auditor Report: Junior Museum and Zoo
• Auditor Report: Annual Follow-up on Audit Recommendations

Item 11
Attachment E - Policy
Services Committee
Workplan

Item 11: Staff Report
Pg.
21 Packet Pg. 202 of 291

City of Palo Alto I 250 Hamilton Avenue, Palo Alto, CA I www.paloalto.gov – February 2026 May
• Referral Follow Up: Discussion and Recommendation to Council Regarding Potential New Procedure for Councilmembers to Make Referrals to Staff Besides Colleagues’ Memo • Auditor Task Orders
• Auditor Report: Public Safety Overtime
• Auditor Risk Assessment
• Quarterly Audit Status Report
June
• Review of Proposed Amendments to Seismic Risk Mitigation Ordinance • Present to Policy and Services an analysis related to anti-rent gouging and forward Committee recommendations to the City Council.
• (other items carried forward from April or May)
July – No meeting; Council break
August
• Tentative: Auditor Report
• Legislative Update (State and Federal)
September
• Tentative: Auditor Report
• Review RFI/P solicitation related to Housing Element Program 1.4A October 29
• Tentative: Auditor Report
November 19
• Legislative Agenda and Guidelines; and Brief Legislative update • Tentative: Nonprofit workplan
• 2027 City Council Priorities Discussion (focused on process, the retreat and submitted ideas) December 9
• Tentative: Auditor report
• No Procedures & Protocols Handbook Discussion (every other year and this is an off year) • Informational: Report out on Status of Committee Referrals I
tems removed:
• Referral (2024): Policy & Services to review and make recommendations for any initiatives to support and strengthen neighborhood programs (linked to discussions in 2021) Removed from referral list at Dec. 9, 2025 P&S Meeting1 as the spirit of the referral has been accomplished 1 P&S Discussion, December 9, 2025, Item #5, Link:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16351 Item 11
Attachment E - Policy
Services Committee
Workplan

Item 11: Staff Report
Pg.
22 Packet Pg. 203 of 291

City of Palo Alto I 250 Hamilton Avenue, Palo Alto, CA I www.paloalto.gov – February 2026

Referrals from February 9, 2026:

1. Refer to staff and subsequently the Policy & Services Committee for a recommendation to the full City Council on the permissible and recommended practices relating to an item going to more than one standing committee when appropriate (Procedures Section 1.2(a)2).

2. Refer to staff to return with recommended language regarding if staff should provide briefings, respond to Councilmember questions, collaborate with Councilmembers to support City Council representatives on regional bodies. (Not required to come to P&S, but could if needed)

3. Refer to staff and return to Council on the use of verbatim transcripts for PTC and UAC Board minutes using AI. (Not required to come to P&S, but could if needed)

Further Work Requested Related to these Referrals:

1. Discussion of the Creation of the Advisory Committee regarding Council Compensation (Previous Committee action completed. P&S Committee requested on Dec. 9, 2025 to keep this item on the list to bring back)

2. Initial Discussion Regarding Potential New Procedure for Councilmembers Referrals to Staff Item 11
Attachment E - Policy
Services Committee
Workplan

Item 11: Staff Report
Pg.
23 Packet Pg. 204 of 291

City of Palo Alto I 250 Hamilton Avenue, Palo Alto, CA. I www.cityofpaloalto.org ATTACHMENT F

FINANCE COMMITTEE TENTATIVE TOPICS
CALENDAR 2026
As of January 30, 2026

The Municipal Code states that the role of the Council Finance Committee is to consider and make recommendations on matters referred to it by the Council relating to finance, budget, financial audits, capital planning and debt. (§2.04.210).

See the end of the document for information on the completed 2025 referrals as well as the outstanding and on hold referrals to date.

January (6
th) (Special Meeting)
 Update and Adoption of the Investment Policy (to be done by June 30 per code)  Mayor appoints Committee and designates Chair; usually no FC meeting

February  (3rd & 17th)
 Feb 3 ‐‐ No Meeting, City Council meetings schedules for January impacts

March (3rd & 17th)
 Utilities Advisory Commission Rate Forecasts and Five‐Year Financial Plans: Water, Wastewater Collection
 Storm Water Management Fee

April (7th & 21st)
 Utilities Advisory Commission Rate Forecasts and Five‐Year Financial Plans: Gas, Electric.  Planning & Development Services ‐ Electrification State caps & fee subsidies  City Fee Updates (various)
 Grid Mod Financing (Tentative)

May (5th, 6th, & 19th)
 Annual Budget Review: Operating and Five‐year Capital Improvement Plan  Alternative meeting times (9:00am – 5:00pm) May 5 and May 6  Including Nonprofit Partnership Workplan Phase I funding

June (2
nd & 16th)
 Third Quarter Fiscal Year 2025 Financial Report

July
No meeting; Council Break

Item 11
Attachment F - Finance
Committee Workplan

Item 11: Staff Report
Pg.
24 Packet Pg. 205 of 291

Finance Committee Tentative Topics, Calendar 2026
As of January 2026
August
 Grid modernization financing

September
 Accept California Public Employees’ Retirement System (CalPERS) Pension Annual Valuation. Reports as of June 30, 2024.
 Retiree Benefit Policy – review and update, if necessary.

October

November
 Informational: Report out on Status of Committee Referrals  Discussion and Recommendation to the City Council to Accept the Macias Gini & O'Connell's Audit of the City of Palo Alto's Financial Statements as of June 30, 2026 and Management Letter
 Discussion and Recommendation to Approve the Fiscal Year (FY) 2026 Annual Comprehensive Financial Report (ACFR) and Approve Budget Amendments in Various Funds

December
 Review and Forward the FY 2028 ‐ FY 2037 Long Range Financial Forecast  First Quarter Fiscal Year 2026 Financial Report
 Preliminary Utility Rate Forecast Review

Referred Topics:

A full report on the status of Finance Committee referrals and the status can be found on Item 2 on the November 18, 2025 agenda

1. Completed Referrals
1) Planning and Development Services Fee Study and Update 2) Parking Permits Pricing and Parking Permit Funds Financial Status. [scheduled for Council consideration Spring 2026]
3) Ability Path financial support [addressed in FY 2025 Mid‐Year Report] 4) Fire Emergency Medical Response Fee Analysis and Update. 5) Fire Emergency Medical Reponses; Supplemental Resources – Approved 12‐Hour Peak Ambulance with Single Role Staff (Implementation in 2026) 6) Active Recruitment Digital Marketing Services (Contract Services) – Staff discontinued request due to financial situation, available workforce due to layoffs (federal level and local tech) and limitations on digital marketing into the hard to recruit industries.

1 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16320

Item 11
Attachment F - Finance
Committee Workplan

Item 11: Staff Report
Pg.
25 Packet Pg. 206 of 291

Finance Committee Tentative Topics, Calendar 2026
As of January 2026
7) Establish Organizational Development & Safety Division – Without adding headcount, Staff created a merged division of organizational development and HRIS to support. 8) Explore financial, outreach, and policy processes for adding East Palo Alto to resident rates for the golf course – East Palo Alto added to resident rates for golf course, effective July 1, 2025.

In Progress/Pending Referrals:
9) Review Parks Restroom Prioritization; Specifically, Pardee Park – Incorporated into FY22026 CIP that was approved by Council on June 16, 2025, CIP PG‐19000 anticipated to begin mid‐ 2026.
10) Increasing Revenue‐ Generating CSD Programming to Meet Demand\Cost recovery policy 100% ‐‐ Further analysis and review in Spring 2026
11) Cost Recovery Policy – Update to include new 100% Category ‐ Spring 2026 12) Update Fee Cost Recovery Category for current fee cost categories – update fee categories and fees as a part of budget development – Spring 2026
13) Risk Mgt, General Liability and Insurance – Update Council on risk management, safety policies and risk transfer and claim analysis and mitigation strategies – going to Council February 2026

Item 11
Attachment F - Finance
Committee Workplan

Item 11: Staff Report
Pg.
26 Packet Pg. 207 of 291

1 0
5 8
1 City of Palo Alto - 2026 City Council Priorities
Business Retention, Expansion, and Attraction (BRE/A) Strategy Introduction:

At the January 24, 2026 meeting, the Palo Alto City Council reached consensus on adopting a 2026 Economic Development priority titled, “Enhance Business Vibrancy.” The City Council acknowledges the importance of Economic Development and the intersection between a healthy local economy and the City’s long-term fiscal sustainability. The City of Palo Alto continues to build from the current Economic Development Strategy to achieve the City Council’s goals and priorities.

Executive Summary:

Economic Development is taking a proactive approach to advocating for Palo Alto’s business and entrepreneurial ecosystem that is reflective of the population it serves.

Economic Development is a concerted effort by the City of Palo Alto’s City Council to ensure that the business climate is healthy. As such, the Economic Development team recommends that the Economic Development Ad Hoc Committee (formerly Retail Ad Hoc Committee) and City Council proceed with a formal Business Retention, Expansion, and Attraction (BRE/A) Strategy.

A Business Retention, Expansion, and Attraction (BRE/A) Strategy will formalize Economic Development’s Work Plan for calendar year 2026. A BRE/A Strategy consists of identifying key industries for retention, expansion, and attraction, proactive business engagement to build strategic partnerships, determining areas where the City of Palo Alto can gain a competitive advantage, and providing support for a favorable business environment that can lead to increased employment opportunities and overall economic prosperity. The BRE/A Strategy will result in preserving and enhancing the local business climate to ensure the City is fiscally stable to provide essential services that the Palo Alto community deserves.

The BRE/A Strategy includes two tactical categories: Enhance Business Vibrancy and Engagement and Promotions. While two 2026 City Council priority objectives are included in the BRE/A such as #29 to develop a formal business retention, expansion, and attraction program and #34 focused on activation activities and events, other key components include strengthening the tax base, developing a competitive advantage, real estate assets, business and community engagement, and promotions and marketing.

Performance Metrics are specific, measurable, achievable, relevant, and timely.

Enhance Business Vibrancy
Item 11
Attachment G - Draft BREA
Strategy

Item 11: Staff Report
Pg.
27 Packet Pg. 208 of 291

1 0
5 8
1 Business Retention, Expansion and Attraction (BRE/A) Strategy – Enhancing Business Vibrancy is a 2026 City Council priority and includes priorities #29 and #34.
Strengthening the Tax Base
oSales tax, property tax, and transient occupancy tax revenue bases - Establish a formal Corporate Visitation Program. Review quarterly data for sales/transient occupancy tax revenues and bi-annually for property tax revenues to identify and respond to changing trends. Performance Metric:

Convene up to five of the top twenty-five sales tax generators by the end of 2026 with the goal of retaining businesses that enhance the City’s long-term fiscal sustainability on a quarterly basis.
oNew Investment Opportunities - Encourage new investments that create economic impact, multiplier effects and sales tax revenue. Performance Metric: Staff will explore financial and non-financial incentives and develop a list to support, retain, and grow business opportunities to drive economic vitality by Quarter 3 2026, and present to the Economic Development Ad Hoc Committee for review and feedback.
Competitive Advantage
oVenture Capital, Incubators, and Accelerators - IDA Ireland, Japan Innovation Campus (JIC), Consulate General and Innovation Centre Denmark, Nordic Innovation House, Flanders Investment and Trade (FIT), The Hive, Archimedes Labs, StartX, Venture Dock, etc. Performance Metric: Meet with at least four Venture Capital investment firms, incubators, and accelerators to develop foreign direct investment (FDI) opportunities and continue to cultivate the innovation and entrepreneurial ecosystem by the end of calendar year 2026.
oBusiness Technical Assistance - Performance Metric: Partner with the Silicon Valley Small Business Development Center (SV SBDC), Small Business Administration (SBA), SCORE, Chamber of Commerce, etc. to host two small business (live and virtual) training workshops in 2026. Real Estate Assets
oReal Estate Network - Property Owners, Real Estate Brokerage, Property Managers, and Development Community Network to foment relationships to fill vacant spaces and attract a mix of retail, office, and industrial businesses to enhance diversity of businesses for a broader customer base.

Performance Metric: Economic Development will host a Real Estate Broker roundtable by Quarter 4 2026 to learn about new opportunities, market trends, new uses, permit processes, and align development efforts with market needs.

Item 11
Attachment G - Draft BREA
Strategy

Item 11: Staff Report
Pg.
28 Packet Pg. 209 of 291

1 0
5 8
1 oCity Real Estate Assets – Leverage City’s real estate assets for revenue generation. Performance Metric: Economic Development will execute a lease with Nobu for the use of 20 valet services parking spaces in Parking Lot Q by April 2026 to generate new revenues for the City.

Engagement and Promotions
Business and Community Engagement
oPublic-Private Partnerships - Engagement fosters trust and collaboration, allowing for effective partnerships that leverage resources for community projects - Performance Metric: Economic Development will promote the Retail Vibrancy Ordinance reflecting flexibility in land use/zoning to the real estate network starting in Quarter 2, and establish two office hour events on California Avenue and Downtown for additional business and community engagement opportunities by Quarter 3 2026.
oOpen Container Resolution and Entertainment Zone - Performance Metric: Economic Development will present to the Economic Development Ad Hoc Committee to obtain a recommendation for the City Council’s consideration of a California Avenue Entertainment Zone Ordinance in April/May 2026.
Promotions and Marketing
o2026 Activities and Events - Performance Metric: Economic Development will partner with businesses, Palo Alto Recreation Foundation, and Chamber on at least 3 California Avenue activities (3rdThursday/FIFA World Cup) and promote the hospitality sector (digital/print) during the 2026 sporting events (March Madness Tournament/FIFA World Cup) from March through July 2026.

The BRE/A Strategy is bounded by two strategic categories: Enhance Business Vibrancy and Engagement and Promotions. The two categories are supported by nine new Economic Development focused implementation actions for calendar year 2026.

Economic Development staff will continue to lead, co-lead, and/or monitor 2025 City Council priority projects currently underway including: #30 Retail Vibrancy Ordinance, #31 California Avenue Signage, and #33 California Avenue Outdoor Activation Guidelines.

Economic Development staff recommends suspending #35 Car-free street improvements on Ramona Street. And, obtain City Council feedback on whether to proceed with #39 California Avenue Design and Funding given that lack of financial resources and to directly focus on the aforementioned 2025 on-going projects and the new BRE/A Strategy.

Item 11
Attachment G - Draft BREA
Strategy

Item 11: Staff Report
Pg.
29 Packet Pg. 210 of 291

1 0
5 8
1 The BRE/A Strategy lays a foundation for creating a vibrant, resilient, inclusive, and diversified economic future. Notwithstanding, the BRE/A Strategy highlights the need for a future Economic Development Strategy that serves as a policy document that will guide the City of Palo Alto’s economic development activities for a designated period. Should the City Council consider a new Economic Development Strategy, it would align with the City’s Comprehensive Plan and the Economic Development Element, Sustainability and Climate Action Plan (S/CAP), and other City policy documents. A new Economic Development Strategy will serve as Palo Alto’s road map to grow and diversify the local economy, support businesses and workers, and improve the quality of life for Palo Altans.

Item 11
Attachment G - Draft BREA
Strategy

Item 11: Staff Report
Pg.
30 Packet Pg. 211 of 291

City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: City Manager
Meeting Date: March 9, 2026
Report #:2512-5589
TITLE
Informational Report: Report from the National Policing Institute Regarding Palo Alto's RIPA Data (Racial and Identity Profiling Act of 2015); CEQA – Not a Project

RECOMMENDATION
Staff recommends that the City Council accept this informational report containing the report from the National Policing Institute regarding Palo Alto’s Racial and Identity Profiling Act of 2015 (RIPA) data as well as information from City staff as context related to the report.

BACKGROUND
Assembly Bill 953, the Racial and Identity Profiling Act of 2015 (RIPA), requires all California law enforcement agencies to collect specific information on certain types of police contacts (detentions and contacts during which a person is searched). It also requires that this data be reported to the California Department of Justice (DOJ) and publicly shared. RIPA also requires the Attorney General to issue regulations for the collection and reporting of this stop data (statewide). (Gov. Code, § 12525.5, subd. (e)).

The implementation timeline for law enforcement agencies varied based on the number of sworn officers employed by the agencies. The first wave of agencies required to start data collection were those with 1,000 or more officers; this data collection began mid-2018. The second wave of agencies, with 500-999 officers started data collection in January 2020. The third wave of agencies, with 250-499 officers started data collection in January 2021. The last wave of agencies, with fewer than 250 officers, started data collection in January 2022. Palo Alto was in the fourth wave of agencies for implementation and began the first year of RIPA data collection, per state law, in 2022. Thus, the data shared with the National Policing Institute (NPI) for analysis was the full year data of 2022 and 2023, both of which were also publicly available on the City’s RIPA data dashboard.

The City’s RIPA dashboard published the first round of data in 2023. The information in the dashboard has been available for public review through an interactive RIPA data dashboard Item A
Item A Staff Report

Item A: Staff Report
Pg.
1 Packet Pg. 212 of 291

that display that same data by applying user-defined filters. In addition to the data dashboard, the public can also download the raw data. The dashboard is one of the only RIPA data dashboards among nearby law enforcement agencies.

The City’s Wellness and Belonging Action Plan is a result of work done in 2020 and 2021. The Action Plan follows these year-over-year broad objective areas to support ongoing consistency in the City's wellness and belonging work even beyond the initial action plan years. The objective areas are:
Cultivating Experiences and Appreciation
Fostering a Welcoming Environment
Applying an Equity Lens: Strategic Review of the Organization through an Equity Lens The City’s desire to analyze the RIPA data is included in the Action Plan as an item to complete with an outside partner in recognition of the fact that the interpretation and analysis of RIPA data is complex and nuanced. The outside partner the City sought to find was an independent, third-party, qualified data analyst group to review the City’s RIPA data and provide a report on it. It took some time to find a researcher who could be an independent reviewer without a particular outcome intended on the data. Staff researched options and landed on the National Policing Institute (NPI) based on NPI’s background as an organization and the opportunity to advance the work with NPI at no cost to the City.

The City worked with NPI through The Knowledge Lab which is a resource for communities and law enforcement agencies to advance researching, identifying, and sharing of fair and effective policing practices and technical assistance. The Knowledge Lab collaborates with stakeholder organizations, researchers, and agencies to leverage and share resources and guidance already developed within these professional networks and works to create resources where they are needed.

As a project sponsored by The Knowledge Lab, there was no financial obligation from the City required for this work and the project was supported by Grant No. 15PBJA-21-GK-04011-JAGT awarded by the Bureau of Justice Assistance (which is a component of the U.S. Department of Justice’s Office of Justice Programs, which also includes the Bureau of Justice Statistics, the National Institute of Justice, the Office of Juvenile Justice and Delinquency Prevention, the Office for Victims of Crime, and the SMART Office).

The National Policing Institute (NPI) is an independent, nonpartisan, nonprofit research and training institute committed to addressing policing’s most complex challenges through evidence-informed, innovative solutions. By translating research and lessons learned into practice, NPI assists law enforcement organizations in adopting and adapting the most effective programs, resources, and tools available to serve their communities. NPI partnered with the City to advance this report to the City Council.

Item A
Item A Staff Report

Item A: Staff Report
Pg.
2 Packet Pg. 213 of 291

ANALYSIS
Palo Alto’s RIPA data is entered by officers at the completion of their interaction with the person/contact. The data required to be collected includes:
The date, time, duration, and location of the stop
Information about the stopped person, as perceived by the officer:
Race or ethnicity
Gender
Age
If the officer perceived the person to be LGBT[QIA+]
If the officer perceived the person as having limited or no English fluency If the officer perceived the person as having a disability The reason for the stop
If the stop was made in response to a call for service Actions taken by the officer during the stop
The basis for any search and if property was seized
If any contraband or evidence was discovered
The result of the stop
The officer's unique identification number, years of experience at the time of the stop, and assignment at the time of the stop
At the end of each calendar year, Palo Alto staff compile the data and submit it for review to the California Department of Justice for certification. Upon certification of the data, the City uploads the data to the City’s website and makes it available on the City’s RIPA Dashboard.

The City asked NPI to work collaboratively with the City to assist in understanding the context of police encounters with members of the public during stops and to advise the City on the interpretation and policy implications of RIPA data from analysis findings. The City also asked NPI to examine the public dashboard and to recommend any enhancements. The key findings in the report, found on report pages 34-36 in more detail, are:
- Expand and improve data collection
- Implement ongoing trend monitoring
- Improve the utility of the RIPA Dashboard
- Integrate officer and community perspectives
Regarding the Dashboard, the key findings are:
- Clean and pre-process data before publication
- Enhance visualizations and functionality
- Expand methodological documentation
The recommendations related to the Dashboard are intended to improve the Dashboard usefulness and functionality. As stated in the Police Department responses (Attachment B), the Item A
Item A Staff Report

Item A: Staff Report
Pg.
3 Packet Pg. 214 of 291

Police Department will seek to implement some aspects of these recommendations. It is noteworthy that the NPI report references the Dashboard as a compliance tool for State law.

However, the State RIPA requirement is for an agency to collect the data, report it to DOJ, and then make the data publicly available. The Palo Alto Dashboard goes beyond State RIPA data requirements by having a publicly available interactive data dashboard. Of all the cities in the State, Palo Alto is one of the few cities with a dashboard and is one of the smallest cities with a dashboard. The Dashboard recommendations are suggestions to make the existing dashboard more user friendly and better able to assist individuals that are seeking to interact with the data differently. The Police Department will continue to improve the Dashboard as resources allow.

The full NPI report is included in Attachment A and responses from the Palo Alto Police Department regarding the recommendations and key findings are in Attachment B. In addition to those responses, staff also wanted to provide some additional information below as considerations when reviewing the report.

Note, this report is being presented as an informational report because it is funded by the BJA and as of 2025, that Federal agency has created more limitations on NPI‘s ability to give presentations about this type of data. In future analysis projects related to the City’s RIPA data, if the project is funded by the City, these limitations will not be factors/concerns.

Next Steps:

The NPI analysis provides the City with data analysis of two (2) years of RIPA data and offers some additional methodologies for RIPA data analysis especially beyond general Census data comparison. It is an opportunity for the City to establish baseline analysis of the RIPA data and as a baseline, now the City can consider moving forward with more analysis on additional years of data since the City now has data for 2022, 2023, 2024, and soon to be data for 2025. As NPI referenced, with multiple years of data the City can monitor for trends over time which can be useful to the City while also learning from this initial analysis.

FISCAL/RESOURCE IMPACT
This report was provided to the City at no cost to the City as it was funded through the Bureau of Justice Administration’s Knowledge Lab program for the City to partner with the reputable National Policing Institute (NPI). Any future analysis the City would like to engage with regarding the RIPA data would require funding for a contract with research firm.

STAKEHOLDER ENGAGEMENT
Staff has provided updates about this RIPA data at Policy and Services Committee members.

Staff also kept interested stakeholders in the Palo Alto community apprised about this report being forthcoming. Note, this report is being delivered well after the original timeline due to focus on other Council priority assignments as well as navigating changes with the federal funding agency.

Item A
Item A Staff Report

Item A: Staff Report
Pg.
4 Packet Pg. 215 of 291

ENVIRONMENTAL REVIEW
This is not a project as defined by the California Environmental Quality Act (CEQA) because this report is an administrative or maintenance activity. CEQA Guidelines section 15378(b)(2).

ATTACHMENTS
Attachment A: National Policing Institute (NPI) RIPA Data Report, 2026 Attachment B: Palo Alto Police Department Responses to NPI Recommendations APPROVED BY:

Ed Shikada, City Manager
Item A
Item A Staff Report

Item A: Staff Report
Pg.
5 Packet Pg. 216 of 291

AN ANALYSIS OF POLICE

STOP DATA
Prepared for the City of Palo Alto, California
January 2026
Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
6 Packet Pg. 217 of 291

This project was supported by Grant No. 15 PBJA - 21 - GK - 04011 - JAGT awarded by the Bureau of Justice Assistance. The Bureau of Justice Assistance is a component of the U.S.

Department of Justice’ s Office of Justice Programs, which also includes the Bureau of Justice Statistics, the National Institute of Justice, the Office of Juvenile Justice and Delinquency Prevention, the Office for Victims of Crime, and the SMART Office. Points of view or opinions in this document are those of the author and do not necessarily represent the official position or policies of the U. S. Department of Justice.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
7 Packet Pg. 218 of 291

ABOUT THE KNOWLEDGE LAB

The Knowledge Lab is a trusted resource for law enforcement and the communities they serve. It supports public safety by identifying and disseminating fair and effective policing practices and technical assistance. The Knowledge Lab collaborates with stakeholder organizations, researchers, and agencies to leverage and share resources and guidance already developed within these professional networks and works to create resources where they are needed. Learn more about the Knowledge Lab at www.leknowledgelab.org.

ABOUT NPI

The National Policing Institute (NPI) is an independent, nonpartisan, nonprofit research and training institute committed to addressing policing’s most complex challenges through evidence-informed, innovative solutions. By translating research and lessons learned into practice, NPI assists law enforcement organizations in adopting and adapting the most effective programs, resources, and tools available to serve their communities. Learn more at www.policinginstitute.org .

ABOUT PALO ALTO POLICE DEPARTMENT

The Palo Alto Police Department (PAPD) serves a diverse and engaged community of approximately 68,000 residents covering 24 square miles in the heart of Silicon Valley. The department’s jurisdiction includes residential neighborhoods, a dynamic downtown business district, Stanford University, and several major transit corridors. PAPD has 150 employees and provides a full range of law enforcement services, including patrol, investigations, traffic enforcement, and community policing initiatives.

AUTHOR ACKNOWLEDGEMENT

This report was written by Colby Dolly, Ph.D., Director of Science & Innovation; Ryan Fisher, Ph.D., Senior Research Manager; Sarah Lawrence, Senior Program Manager; Jie Gao, Research Data Scientist; and Murat Yildirim, M.S., Research Data Manager, at the National Policing Institute.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
8 Packet Pg. 219 of 291

TABLE OF CONTENTS

ABOUT THE KNOWLEDGE LAB

2 ABOUT NPI 2
ABOUT PALO ALTO POLICE DEPARTMENT 2
AUTHOR ACKNOWLEDGEMENT 2
INTRODUCTION 1
DATA AND METHODOLOGY 1
RIPA DATA 1
METHODOLOGY 4
PAPD DATA ANALYSIS RESULTS 7
PAPD STOP PATTERNS 7
PAPD STOP OUTCOMES 13
SPATIOTEMPORAL ANALYSIS 21
PAPD RIPA DASHBOARD ANALYSIS 30
SUMMARY OF FINDINGS 33
RECOMMENDATIONS 34
REFERENCES 37
APPENDIX A: RE-CLASSIFYING PAPD RIPA CODES 38

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
9 Packet Pg. 220 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 1

INTRODUCTION

The City of Palo Alto requested assistance from the Law Enforcement Knowledge Lab (the Lab) to analyze their Racial and Identity Profiling Act (RIPA) data and public dashboard, including analyzing stop patterns throughout the city. Data collected by the Palo Alto Police Department (PAPD) from 2022 to 2023 under California’s state-mandated RIPA were analyzed by the Lab’s research team. The PAPD serves a diverse community of approximately 68,000 residents, encompassing residential neighborhoods, Stanford University, and several major commercial corridors. As part of statewide efforts to promote transparency and accountability in policing, the department routinely records detailed information on stops, including demographic details, reasons for stops, searches conducted, and stop outcomes.

The City was interested in questions related to when, where, and how stops were occurring. The primary goal of this work was to support the PAPD in assessing and strengthening its collection, analysis, and presentation of stop data reported under RIPA. PAPD asked the Knowledge Lab for a detailed audit of the department’s stop records, a comprehensive analysis of stop patterns, and an evaluation of the public-facing dashboard. The project aimed to help the City, including the Police Department and its stakeholders, better understand how this data can be interpreted, identify appropriate benchmarks, and provide clear, recommendations to improve the quality, transparency, and utility of stop data moving forward.

The analysis employed descriptive and inferential statistics to identify patterns in Palo Alto’s stops.

Specifically, PAPD asked the Knowledge Lab to examine the frequency of stops by time of day, geographic mapping of stops by street and police beat, and evaluating differences in stop reasons and outcomes by race and ethnicity. A veil of darkness analysis—commonly used to detect potential racial disparities in policing—was conducted to explore whether stop likelihood varied by time of day. The approach is useful in identifying potential racial disparities but in and of itself does not conclusively explain why disparities are present. .

By systematically examining PAPD stop patterns and characteristics, the report aims to highlight trends, inform policy discussions, and support ongoing efforts to evaluate equitable policing practices that emphasize public safety. While this analysis does not make causal determinations, it identifies areas where further review may be warranted based on observed disparities or enforcement patterns.

DATA AND METHODOLOGY
RIPA Data
Under the Racial and Identity Profiling Act (RIPA) of 2015, California law enforcement agencies are required to collect information on certain types of police contacts, including detentions and contacts during which a person is searched. The data items collected include:

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
10 Packet Pg. 221 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 2

• Date, time, duration, and location of the stop
• Demographic Information about the stopped person, as perceived by the officer:
• Race or ethnicity
• Gender
• Age
• If the officer perceived the person to be LGBT
• If the officer perceived the person as having limited or no English fluency • If the officer perceived the person as having a disability • Reason for the stop
• If the stop was made in response to a call for service • Actions taken by the officer during the stop
• Basis for any search and if property was seized
• If any contraband or evidence was discovered
• Result of the stop
• Officer's unique identification number, years of experience at the time of the stop, and assignment at the time of the stop

DATA CLEANING AND PREPARATION
Stop Data
The PAPD provided the Lab’s research team with two RIPA data files (submitted to and verified by the California Department of Justice) for 2022 and 2023 reported stops. This data includes traffic and pedestrian stops made by the PAPD, either as a result of officer-initiated activity or a call for service. The files were merged to create a master stops file that included 10,509 records with 170 fields. Of these 10,509, over 83% resulted from officer-initiated activity (8,686). The initial data files were provided at the stop level and included instances where multiple people were present for a single stop. The Lab’s research team created two files for the analysis: a stop- level file and an individual-level file. This allowed researchers to examine stops without double- counting incidents for which more than one person was present and examine the demographics of individuals involved in stops.

As part of the data cleaning process, the perceived race and ethnicity of stopped individuals needed to be recoded since it was a multiple-selection field (allowing officers to record multiple race or ethnicity categories per individual). The Lab research team used the race and ethnicity coding structure that the California RIPA Board reports have been using in their reporting. Thus, when an individual was recorded with multiple race and ethnicity designations, that individual was coded as “multi-racial” (219 total records). All other race and ethnicity codes were single- selection, and this is reflected in the race and ethnicity analyses presented below (with the exception of six missing race and ethnicity records). Preliminary analyses indicated that several racial and ethnic groups (e.g., Multi-racial, Native American, Pacific Islander, Unknown) represented fewer than 5% of total stops. Due to these groups’ limited representation, and to maintain clarity and interpretability in visualizations and analyses throughout this report, these categories have not been included in detailed figures and tables. Their overall representation and counts are provided below for transparency.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
11 Packet Pg. 222 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 3

Table 1- Race and Ethnicity Stop Counts (2022 to 2023)

Race and Ethnicity Number of Stops Percentage
White 3423 32.57%
Hispanic 3289 31.30%
Black 1262 12.01%
Asian 1232 11.72%
Middle Eastern/South
Asian

826

7.86%
Other 1 252 2.40%
Multi -racial 219 2.08%
Missing 6 0.06%

Additional data fields allowed for multiple selections, including the actions taken and stop results fields, which required cleaning and preparation for analysis. As the multiple selections were all included in a single field and separated by commas, recoding was done to make the data usable for analysis. The Lab research team separated each value to create two different variable types for each field: a hierarchical variable code and a series of dichotomous variables to capture each code associated with the recorded activity. The hierarchical classifications created by the Lab research team are in Appendix A. The recoding process involved classifying officer stop actions and results of stops by severity, with the most serious types superseding all others regardless of the number of codes present. For example, if both a chemical spray was used and a person was searched during the stop, then chemical spray was recorded as the most severe action taken during that stop, being “Use of Non-Lethal Force” for our analyses. For ease of analysis moving forward, the PAPD should explore the feasibility of fixing this multi-response issue by allowing

1 This includes individuals coded as Native American, Pacific Islander, or Unknown.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
12 Packet Pg. 223 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 4

D ES C R I P T I V E A N A LY S I S

each response to be its own field. This will provide analytical clarity for any analyses moving forward and aid with interpretation and transparency in the public dashboard.

These classifications were developed using a combination of legal reasoning, use-of-force policy frameworks, and empirical logic. Each action code was assigned to a broader category reflecting its relative severity, intrusiveness, or impact on individual liberty, informed by nationally recognized frameworks such as the National Institute of Justice (NIJ) use-of-force continuum and guiding principles from the Police Executive Research Forum (PERF). Actions involving physical control, weapon use, or evidence collection were assigned higher severity. The stop result hierarchy reflects the legal weight and practical consequences of each outcome for the stopped individuals (e.g., arrests involve the deprivation of liberty and are subject to the highest level of legal scrutiny vs. a warning or infraction). The classification also aligns with standard reporting and accountability frameworks used by state agencies and civil rights organizations to monitor law enforcement outcomes. These hierarchical frameworks are intended to support descriptive comparisons and statistical modeling by capturing the escalating legal, physical, or procedural implications of officer decisions. While the categorizations required subjective judgment, they were refined in consultation with agency partners to ensure they accurately reflect officer behavior.

Spatial Data
The PAPD provided beats, reporting districts, and neighborhood shapefiles. The RIPA stop data were geocoded using the PAPD-provided address location fields and spatially joined with beats, reporting districts, and neighborhood shapefiles. The address field in the RIPA data was typically represented at the hundred-block level, masking some location specificity. While valuable for identifying broad patterns, analyses using hundred-block address aggregation can create artificial clustering effects. Understandably, officers may need to identify the closest intersection or point of interest during some stops. However, this does lead to multiple stops being clustered at specific points and obscuring some of the micro- differences that more precise location reporting would provide. Recognizing this issue, the research team created additional spatial datasets to try and disentangle this issue and better represent the clustering of stop activity. This data collection issue and its implications for analysis are discussed further in the spatiotemporal analysis methodology section below.

Methodology

To better understand police enforcement actions and their impact on disparities, the first step is to describe the available data and examine its patterns and trends. Descriptive analysis involves summarizing outcome data to provide a clear and concise overview of key characteristics and patterns within a dataset, allowing for insights into the data's central tendencies, variability, and distribution (Witte and Witte, 2017). Descriptive analyses, including crosstabulations, help facilitate understanding of basic patterns and distributions in the data and cannot be used to explain or Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
13 Packet Pg. 224 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 5

P A P D R I P A D A T A D A S H BOA R D R E V I E W

V E IL O F D A R K N E S S A N A L Y S IS

predict trends. Such analyses are typically a precursor to more complex statistical techniques (Shadish et al., 2002; Witte and Witte, 2017).

In addition to the quantitative analysis of stop data, the project team conducted a focused review of the department’s public-facing RIPA dashboard. This review assessed the dashboard’s structure, content accuracy, user navigation, and visual presentation. The team evaluated how effectively the dashboard communicated stop data trends to different audiences and compared its design and functionality against similar tools used by peer agencies. Findings from this assessment informed a set of targeted recommendations aimed at enhancing the dashboard’s clarity, accessibility, and utility for both public transparency and internal decision- making.

The veil of darkness technique, developed by Grogger and Ridgeway (2006), tests for potential racial and ethnic bias in vehicle stops by exploiting variations in natural lighting conditions. This method compares the racial distribution of vehicle stops made during daylight versus in darkness during the "inter-twilight period"—times of day that are light during certain parts of the year and dark during others due to seasonal variation in sunset times. The underlying logic is that if officers use race in stop decisions, this behavior would be more difficult during darkness when drivers' race is less visible, leading to different racial distributions between daylight and darkness stops made during the same clock times.

The implementation of the veil of darkness test involves several key analytical steps. First, the appropriate inter-twilight window based on local sunset times throughout the year is identified.

This typically includes those evening hours transitioning between light and dark as seasons change. Next, stops within this window are coded for lighting conditions based on precise sunset times for each date. Finally, a statistical analysis (typically logistic regression) compares the odds of non-white drivers being stopped during daylight versus darkness while controlling for location, day of week, and seasonal patterns. The primary output of the analysis is an odds ratio that quantifies the relationship between lighting conditions and the racial distribution of stops. An odds ratio greater than 1.0 indicates that non- white drivers are likelier to be stopped during daylight hours, potentially suggesting bias in stop decisions. Conversely, a ratio of less than 1.0 indicates that non-white drivers are more likely to be stopped during darkness. The statistical significance of these ratios helps determine whether observed differences reflect systematic patterns rather than random variation.

While the veil of darkness test represents a methodologically rigorous approach to analyzing potential bias, it relies on several key assumptions to consider when interpreting results. The method assumes that driving patterns by race and ethnicity remain consistent between daylight and darkness during comparable clock times and that the visibility of the driver by officers is the primary factor that changes between lighting conditions. Similarly, this analysis assumes that officers do not consider the condition or type of vehicle as a proxy for race (Baumgartner et al., Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
14 Packet Pg. 225 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 6

S P A T IO T E MP O R A L A N A L Y S IS

AN OVERVIEW OF THE RESEARCH

2017). Additionally, the analysis is limited to vehicle stops during inter-twilight, which may not represent patterns and practices in all enforcement activity. Furthermore, the increased presence of artificial lighting in some areas may reduce the distinction between daylight and nighttime conditions. Despite these limitations, the veil of darkness technique provides valuable insights by controlling for many confounding factors that complicate other approaches to measuring enforcement disparities.

A series of geographic and time-of-day analyses examined the geographic and hourly patterns in officially recorded PAPD stops. First, all PAPD-provided official data sources that included addresses or latitude and longitude coordinates were geocoded to their nearest street segment using ArcGIS Pro, a geographical analysis software system. The geocoding results consistently demonstrated a hit rate of over 90%, well above the established standard of 85% (Chainey and Ratcliffe, 2005). Spatial data was analyzed using ArcGIS Pro to create density and heat maps to examine associations among PAPD activity datasets and the underlying environment.2 Administrative datasets that included incident time information were rounded to the nearest hour in a 24-hour period and visualized using radar plots to examine what times of day had the highest number of events to examine differences across police activity and racial and ethnic groups.

2 Due to the PAPD's reporting methods for location data, addresses are typically recorded at the hundred-block level (e.g., 1200 Main St rather than 1234 Main St.), which can create artificial hot spots of data as slightly different addresses may all be classified into a single point. Thus, an additional analytical step was taken to join all geocoded event points to Palo Alto street segments and then calculate the density of police activity per the street segment length to better approximate and visualize official police activity at the street segment level.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
15 Packet Pg. 226 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 7

PAPD DATA ANALYSIS RESULTS

The Lab research team’s findings are presented below. They begin with descriptive statistics and then present the more sophisticated approaches discussed above.

PAPD Stop Patterns
PAPD’s monthly stops from January 2022 through December 2023 were examined, as shown below in Figure 1, revealing fluctuations in enforcement activity over time. During this time period, the number of monthly stops averaged 438 per month. The number of stops remained relatively stable for much of 2022 before increasing sharply in late 2022 and early 2023. The highest number of stops occurred in March 2023, with 686 recorded stops. After this peak, stop frequency declined throughout the remainder of 2023.

Ridgeway, 2006; Smith et al., 2017; 2021). However, these advanced techniques often

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
16 Packet Pg. 227 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 8

Figure 1- PAPD Monthly Stops (January 2022 to December 2023)

Figure 2 shows stop patterns by racial and ethnic groups. The trends for these groups followed a general overall pattern, with an apparent increase in stops leading up to early 2023, peaking in March/April of 2023 and followed by a decline to roughly 100 monthly stops. Stops of individuals perceived as Black, Asian, and Middle Eastern/South Asian remained lower in absolute numbers and exhibited less pronounced fluctuations over time.

The data suggest that the overall volume of stops and their distribution by race changed over time in ways that may be relevant for further examination. The period of increased stops in early 2023 and the subsequent decline may warrant a closer review to understand what factors coincided with these shifts. The department might consider examining whether the increased stop activity in early 2023 corresponds with specific enforcement initiatives, shifts in policing priorities, seasonal variations in community activity, or changes in staffing and resource deployment. Additional data, such as calls-for-service, crime incident reports, community events calendars, or officer deployment schedules, could be integrated into analyses to better contextualize these patterns.

Linking stop data to other operational datasets would enable the department to determine whether these trends align with specific operational decisions or community dynamics, providing a deeper understanding of the observed fluctuations in enforcement activity. In addition, qualitative research via interviews or focus groups with PAPD staff and community members may reveal other critical contextual factors that may have impacted these patterns.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
17 Packet Pg. 228 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 9

Figure 2- PAPD Monthly Stops by Race/Ethnicity (January 2022 to December 2023)

Figure 3 presents stops by police beat for 2022 and 2023. Beat 2 recorded the highest number of stops in both years and increased from 1,908 in 2022 to 2,636 in 2023, a 38% increase. Beat 3 also experienced an increase between 2022 and 2023, with stops increasing from 753 to 1,378, an 83% increase year over year. Beats 1 and 4 were relatively more stable, with Beat 1 increasing 9% from 860 to 936 stops, and Beat 4 decreasing 6% from 548 to 515. These differences suggest enhanced enforcement activity between 2022 and 2023 in Beats 2 and 3 but not in Beats 1 and 4.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
18 Packet Pg. 229 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 10

Figure 3- PAPD Stops by Police Beat (2022 vs. 2023)

Figure 4 examines stop patterns by police beat and perceived race and ethnicity3. Across all beats and both years, individuals perceived as white or Hispanic experienced the highest number of stops. In Beat 2, the number of stops increased notably for nearly all racial and ethnic groups:
stops of white individuals rose from 616 in 2022 to 832 in 2023 (a 35% increase); Hispanic individuals increased 40% from 604 to 844; Asian individuals from 149 to 326 (119% increase); and Middle Eastern/South Asian individuals from 130 to 251 (93% increase). Interestingly, stops of Black individuals in Beat 2 remained stable (290 to 292) across both years.

In Beat 3, there were substantial increases in stops across all racial and ethnic groups, particularly for Asian and Middle Eastern/South Asians, which more than doubled with a 177% and 105% increase, respectively. In contrast, white (72%), Hispanic (87%), and Black (58% ) stops rose more moderately.

The sharp increases in stop volume in Beats 2 and 3 may benefit from further exploration. In contrast, the relative stability or decline in Beats 1 and 4 suggests that there may be important contextual differences between the increasing and decreasing beats. Further examining these geographic differences could provide additional insight into the factors influencing stop distribution across Palo Alto (e.g., specific land uses, crime and call-for-service data, or PAPD enforcement priorities). It should be noted that these could also result from changes in reporting

3 Use caution when comparing across racial and ethnic groups, as each has a slightly different maximum value on the y-axis.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
19 Packet Pg. 230 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 11

practices between the two years and that additional years of data may display more stable trends moving forward.

Figure 4- PAPD Stops by Police Beat and Race/Ethnicity (2022 vs. 2023)

Figure 5 presents the reasons for stops and reveals that traffic violations accounted for the majority of stops, with 7,712 recorded instances (74%). The second most common reason was reasonable suspicion that an individual was engaged in criminal activity, which accounted for 1,848 stops. Stops for traffic violations occurred at more than four times the rate of the next highest category—stops based on reasonable suspicion of criminal activity (a ratio of just over 4:1). Stops related to outstanding arrest warrants was the next most common type at 489 stops, followed by consensual encounters (331 stops).

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
20 Packet Pg. 231 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 12

Figure 5- PAPD Stops by Reason Provided (2022 to 2023)

Figure 6 shows the two most frequent stop reasons by perceived race and ethnicity, revealing notable differences in the distribution of stops across demographic groups. The chart on the left shows that stops for traffic violations were most frequently associated with individuals perceived as Hispanic (34.2%) and white (31.3%), followed by Asian (14.6%), Black (10.3%), and Middle Eastern/South Asian (9.7%) individuals.

The chart on the right shows a different distribution for stops based on reasonable suspicion of criminal activity. White individuals comprised the largest share (42.1%) of these stops, followed by Hispanic (28.4%) and Black (18.0%) individuals. Asian (7.1%) and Middle Eastern/South Asian (4.4%) individuals represented smaller proportions.

These comparisons highlight differences in the racial and ethnic makeup of stops depending on the stated reason for the stop. To better understand what may be driving these differences, further analysis could examine whether geographic areas, types of encounters, or enforcement assignments are associated with each stop reason.

An in-depth examination of these types of stops, specifically via case reports, interviews with officers, or analysis of additional administrative datasets (e.g., calls for service, suspect and victimization data), may provide additional insight into the causes of these patterns.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
21 Packet Pg. 232 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 13

Figure 6- PAPD Stops by Reason by Race/Ethnicity (2022 to 2023)

PAPD Stop Outcomes
STOP ACTIONS TAKEN BY RACE/ ETHNICITY 2022 -2024
An analysis of the most serious action undertaken during a stop is presented in Table 2. As mentioned in the methodology section, multiple actions could be taken within a stop, and actions were coded into a hierarchy of seriousness, with the most serious action being used (See Appendix A). The stop actions in Table 2 reveal that most stops resulted in no action being recorded, accounting for 7,525 of all stops across racial groups (excluding those in “Other” and “Multi-racial” categories). Notably, Asian (83.2%) and Middle Eastern (80.5%) individuals had the highest proportion of stops resulting in no action, while Black individuals had the lowest proportion at

60.3%.

Among stops that did result in further action, detention and restraint was the most common type of action taken, occurring in 1,968 stops. Black individuals experienced the highest rate of detention and restraint (26.7%), compared to other groups, followed by white (19.7%), Hispanic (18.3%), Middle Eastern (14.0%), and Asian (13.4%) individuals. Search and seizure occurred in 682 stops, again disproportionately impacting Black individuals (9.6%) compared to white (7.6%), Hispanic (6.9%), Middle Eastern (2.7%), and Asian (1.9%) individuals. Other actions—including non- physical actions, firearm pointing, physical contact without force, and use of non-lethal force— occurred less frequently, with firearm pointing and use of non-lethal force being particularly rare.

The observed differences in the proportion of stops leading to more intrusive outcomes, particularly detention and search activity among Black individuals, highlight areas where further exploration into enforcement practices and community interactions may be beneficial.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
22 Packet Pg. 233 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 14

Table 2- PAPD Actions Taken during Stop by Race/Ethnicity (2022 to 2023)

Action Taken

Stops

Asian

Black

Hispanic
Middle
Eastern

White
None 7,525 1,025
(83.2%)
760
(60.3%)
2,354
(71.7%)
665
(80.5%)
2,365
(69.2%)
Detention and 1,968 165 337 601 116 673
Restraint (13.4%) (26.7%) (18.3%) (14.0%) (19.7%)
Search and Seizure 682 23 121 227 22 260
(1.9%) (9.6%) (6.9%) (2.7%) (7.6%)
Non-Physical 276 16 36 89 21 105
Actions (1.3%) (2.9%) (2.7%) (2.5%) (3.1%)
Firearm Pointing 18 1 3 10 4
(0.1%) (0.2%) (0.3%) - (0.1%)
Physical Contact 15 1 3 3 8
without Force (0.1%) (0.2%) (0.1%) - (0.2%)
Use of Force (Non- 7 1 1 1 2 2
lethal) (0.1%) (0.1%) (0.1%) (0.2%) (0.1%)
Note: 18 records were removed due to missing the ‘action taken’ value.

Percentages denote the number of stops relative to the total number of stops in each group.

STOP RESULTS BY RACE/ ETHNICITY
More than half of the stops across these racial and ethnic groups (~57%4 during 2022 and 2023) resulted in no action or minimal intervention, including written and verbal warnings (see Table 3).

Approximately 28% resulted in administrative actions, and 12% resulted in an arrest. Table 3 indicates that the distribution of stop results also varied by race. Again, stop results were re- classified into higher-order categories to provide clarity and improve analysis and interpretation5.

Hispanic individuals (59.9%) and Middle Eastern individuals (58.7%) had the highest proportion of stops resulting in no action or minimal intervention, followed closely by Asian (55.4%), white (54.5%), and Black (53.6%) individuals. Administrative actions, which include citations and other formal processes, were more common among Asian individuals (36% of their stops) compared to different groups, followed by Middle Eastern (32%), white (27.2%), Hispanic (26.1%), and Black (20.8%) individuals. Arrests also occurred disproportionately among Black individuals (21.6%), compared to white (12.7%), Hispanic (12%), Middle Eastern (6.1%), and Asian (5.5%) individuals.

The disparities in stops, particularly in relation to disparities seen in the actions taken during stops (e.g., firearm pointing, detention, and restraint) and the stop outcomes (e.g., arrests), highlight notable differences in the results of enforcement actions across demographic groups. The PAPD

4 Total stops for these five racial and ethnic groups equals 10,029, as it excludes the “Other” and “Multi-Racial” groups. Including those groups produced similar percentages.
5 212 stops were re-classified using the stop result hierarchy in Appendix A.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
23 Packet Pg. 234 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 15

may want to further investigate, monitor, and report these demographic trends to examine changes and patterns. Qualitative research, including interviews or focus groups with officers and community members, coupled with policy review, may provide additional context to these patterns. Additional administrative datasets could allow for more in-depth and complex statistical analysis, especially if the department could link stop data with calls for service, arrest, and crime data to include additional contextual information about the circumstances surrounding stops.

Table 3- PAPD Stop Result by Race/Ethnicity (2022 to 2023)

Stop Result

Stops

Asian

Black

Hispanic
Middle
Eastern

White

No Action or Minimal
Intervention

5682 683
(55.4%)
677
(53.6%)
1971
(59.9%)
485
(58.7%)
1866
(54.5%)
Administrative Actions 2757 444
(36%)
262
(20.8%)
857
(26.1%)
264
(32%)
930
(27.2%)
Arrests 1220 68
(5.5%)
273
(21.6%)
394
(12%)
50 (6.1%)
435
(12.7%)
Non-Criminal
Interventions

370 35
(2.8%)
50 (4%)
66 (2%)
27 (3.3%)
192
(5.6%)

Note: 2 records classified as “Federal Involvement” are not included. Percentages denote the number of stops relative to the total stops in each group.

PERCENTAGE OF MONTHLY STOPS WITH SEARCH CONDUCTED
An examination of search activity across stops, presented in Figure 7, reveals fluctuations in the proportion of stops that resulted in a search. Analyzing monthly trends in stops involving searches is crucial for understanding variations in police practices over time, identifying potential disparities, and evaluating the consistency and effectiveness of search decisions. Examining data across a two-year period provides sufficient detail to detect meaningful patterns and trends, ensuring a more comprehensive analysis than shorter time frames. On average, 16.8% of stops involved a search, though this percentage varied over time. The highest search rate occurred in August 2022, when 27.3% of stops included a search. While the search rate showed periods of increase and decline, it generally remained within a range of 10% to 20% in most months.

When disaggregated by race and ethnicity, as in Figure 8, Black individuals consistently experienced the highest monthly percentage of stops involving searches, with frequent peaks approaching or exceeding 30%. In comparison, search rates for Hispanic and white individuals were lower but often mirrored each other closely, typically between 10% and 25%. Asian and Middle Eastern/South Asian individuals consistently had the lowest search rates, generally below 15%.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
24 Packet Pg. 235 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 16

Supporting these findings, the average monthly search rate over the two years varied significantly by race and ethnicity. Black individuals had the highest average monthly search rate of 27.1%, substantially exceeding those of other groups. White and Hispanic individuals experienced searches on ~18% of their average monthly stops, while Asian and Middle Eastern/South Asian individuals were subject to searches on roughly 8% of their monthly stops. For Black, white, and Hispanic individuals, their monthly search percentage exceeded their average at least 33% of the months during the two-year period, while Asian and Middle Eastern/South Asian individuals only exceeded their monthly average 25% of the time. These fluctuations indicate that PAPD may want to continuously monitor search and hit rates over time to ensure that spikes and troughs in these patterns reflect strategic public safety needs and priorities.

Figure 7- PAPD Percentage of Monthly Stops with Search Conducted (January 2022 to December 2023)

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
25 Packet Pg. 236 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 17

Figure 8- PAPD Percentage of Monthly Stops with Search Conducted by Race/Ethnicity (January 2022 to December 2023)

HIT RATE ANALYSIS BY RACE/ ETHNICITY
The search hit rate, or the percentage of searches that resulted in the discovery of contraband or evidence, varied across racial groups and is presented in Table 4. Searches of white individuals had the highest hit rate at 12.4%, followed by Hispanic individuals at 10.3%, Black individuals at

8.3%, Asian individuals at 5.7%, and Middle Eastern/South Asian individuals at 4.9%. Searches of white individuals were more likely to yield contraband or evidence compared to searches of other racial and ethnic groups.

Figure 9 provides additional insights by comparing search effectiveness, or "hit rates," for non- white groups relative to white individuals across police beats. The diagonal dashed line represents equal hit rates between white individuals and another racial/ethnic group. Points above the diagonal line indicate that the non-white group had a higher search hit rate than white individuals in that police beat; points below the line indicate that white individuals had a higher hit rate than the non-white group6.

For Asian individuals, only police Beat 1 showed higher hit rates compared to white individuals during 2022 and 2023. For Black individuals, three out of four beats (Beats 1, 2, and 3) showed

6 Where points fall along the X-axis for the non-white groups, this indicates that no searches were conducted for that group in that beat.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
26 Packet Pg. 237 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 18

points clearly below the parity line, indicating consistently lower search hit rates than white individuals. The pattern for Hispanic individuals showed two beats (Beats 1 and 2) below the diagonal line, indicating lower hit rates than white individuals, with Beats 3 and 4 slightly above parity. Finally, the pattern for Middle Eastern/South Asian individuals had all hit rates falling below the parity line, although 3 of these were the result of zero searches in those beats.

Taken collectively, Figure 9 indicates that searches involving Black, Hispanic, and particularly Middle Eastern/South Asian individuals typically yielded lower hit rates compared to searches of white individuals across most police beats. This pattern raises questions about the effectiveness of searches across different racial groups and whether search criteria result in different success rates in discovering contraband or evidence. Again, qualitative research or the inclusion of additional quantitative administrative datasets could provide important insights into the context surrounding stop and search activity by PAPD.

Table 4- Search Hit Rates by Race/Ethnicity (2022 to 2023)

Race/Ethnicity Search Hit Rate
Asian 5.7%
Black 8.3%
Hispanic 10.3%
Middle Eastern/South Asian 4.9%
White 12.4%
Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
27 Packet Pg. 238 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 19

Figure 9- PAPD Search Hit Rates by Police Beat and Race/Ethnicity (2022 to 2023)

VEIL OF DARKNESS ANALYSIS
The Veil of Darkness (VoD) analysis is a statistical method used to assess whether drivers of different racial groups are stopped at different rates depending on whether it is daylight or nighttime. The underlying idea is that during low-light conditions, such as after sunset, it becomes more difficult for officers to visually identify a driver’s race before initiating a stop. If racial disparities in stop rates are driven by visual identification of race, we would expect non-white drivers to be stopped more frequently during daylight (when race is visible) and less frequently after dark (when race identification is difficult). This difference in stop rates between daylight and darkness can serve as evidence of racial bias in traffic enforcement.

Important limitations of VoD analysis should be noted. The method assumes that driver behavior, traffic patterns, and the likelihood of committing traffic violations are similar across racial and ethnic groups during both daylight and nighttime hours. If different groups have systematically different driving patterns, locations, or behaviors during these time periods, this could confound the results. Additionally, VoD analysis cannot establish direct causation and should be interpreted alongside other evidence when assessing potential bias in traffic enforcement.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
28 Packet Pg. 239 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 20

The VoD analysis results presented below use an odds ratio to compare the likelihood of a traffic stop occurring under different lighting conditions for drivers of different racial groups. The odds ratio represents how much more or less likely a driver is to be stopped during darkness compared to daylight. An odds ratio of 1.0 means no difference between daylight and darkness; an odds ratio below 1.0 indicates lower likelihood of being stopped during darkness (suggesting higher stop rates during daylight when race is visible), while an odds ratio above 1.0 indicates higher likelihood of being stopped during darkness. When the analysis of non-white driver stops show odds ratios significantly below 1.0, this pattern suggests that racial cues visible during daylight may be influencing stop decisions. Table 5 below displays the results of the Veil of Darkness tests for all race and ethnicity groups.

For Black drivers (compared to white drivers), the odds ratios of 0.62 (without controlling for police beat) and 0.54 (when controlling for police beat) are both statistically significant (p < .05) as shown in Table 5. This means that Black drivers were significantly less likely to be stopped at nighttime than during daytime, with the likelihood of being stopped during darkness being about 38% lower (0.62) to 46% lower (0.54) than during daylight. The odds ratio of 0.54 after controlling for police beat suggests an even more substantial effect. Put differently, this indicates that Black drivers experience higher stop rates during daylight hours when their race is more easily identifiable to officers. This difference in stop rates between lighting conditions warrants further investigation to understand the underlying factors contributing to this pattern.

In contrast, the odds ratios for Hispanic and white drivers were 0.86 in both models, and these results were not statistically significant. Similarly, Asian drivers showed odds ratios close to 1.0 (0.96 without control, 0.84 with control), neither statistically significant, indicating no strong relationship between lighting condition and stops. Middle Eastern/South Asian individuals also had odds ratios close to 1.0 (1.02 in both models), demonstrating no significant relationship between darkness conditions and their likelihood of being stopped. This suggests that there was no meaningful difference in the likelihood of stops for other non-white and white drivers based on whether the stop occurred during daylight or nighttime hours.

The significant difference in odds ratios observed for Black drivers but not for Hispanic drivers may warrant further examination. While the VoD analysis does not establish direct causation, the significantly lower odds of Black drivers being stopped during darkness (when race identification is difficult) compared to daylight represents a notable pattern that differs from other racial groups analyzed. Palo Alto PD staff and city officials have noted that the city experiences significant commuter traffic that substantially changes the population dynamics throughout the day, which may contribute to differences in stop patterns between daylight and nighttime hours. This commuter presence could influence the demographic composition of drivers on the road during different time periods, potentially affecting the interpretation of VoD results. Additional review of stop activity via case reports and qualitative interviews or focus groups with officers may help to understand what factors contribute to these observed differences.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
29 Packet Pg. 240 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 21

Table 5- Veil of Darkness Results (2022 to 2023)

Race

Control for Police Beat

Sample Size

Odds Ratio
Black and White Drivers No 1488 0.62*
Black and White Drivers Yes 1488 0.54*
Hispanic and White Drivers No 1093 0.85N.S.

Hispanic and White Drivers Yes 1093 0.86N.S.

Asian and White Drivers No 669 0.96N.S.

Asian and White Drivers Yes 669 0.84N.S.

Middle Eastern/South Asian
and White Drivers
No 663

1.02N.S.

Middle Eastern/South Asian
and White Drivers
Yes 663

1.02N.S.

Note: N.S. = Not significant. * = p < .05

Spatiotemporal Analysis

STOPS BY TIME OF DAY
The circular bar chart in Figure 10 visualizes the distribution of stops across different hours of the day. The radial design means that each bar extends outward from the center, representing the total number of stops during each hour. The labels along the outer edge of the chart indicate the hour of the day, ranging from 0:00 (midnight) to 23:00 (11 PM). Longer bars correspond to more stops during that hour, while shorter bars indicate fewer stops. This format allows for an intuitive comparison of stop frequency across different times of the day.

Figure 10 shows a peak in stop activity between 22:00 (10 PM) and 0:00 (midnight), with the highest number of stops occurring around 23:00 (11 PM). Stops declined after midnight through the early morning hours. The number of stops rose during the morning and increased steadily through the afternoon. A more pronounced increase occurred in the evening, leading to the late-night peak.

Several factors could help understand this time-of-day pattern, such as enforcement strategies, changes in officer deployment schedules, or variations in traffic and pedestrian activity and behavior by time-of-day. The sharp increase in stops in the late evening, followed by a steep Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
30 Packet Pg. 241 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 22

decline after midnight, may be worth further exploration to assess whether this is a result of enforcement priorities, shift schedules, policy decisions, or calls for service that contribute to this observed pattern.

Figure 10- PAPD Stops by Time of Day (2022 to 2023)

The set of circular bar charts in Figure 11 visualizes the distribution of stops across different hours of the day, broken down by race and ethnicity. While all groups experience a notable concentration of stops in the late evening, primarily between 9:00 PM and midnight, the shape and intensity of these peaks differ across racial and ethnic categories. For instance, Hispanic individuals experience not only the highest total number of stops but also the most pronounced late-night concentration. White individuals similarly experience a notable late-evening peak, but their stop distribution also extends further into early morning hours compared to other groups. The distributions for Black and Middle Eastern/South Asian individuals reflect similar late -evening peaks, but these groups experience comparatively fewer stops overall. Asian individuals display a distinct pattern with fewer total stops and a narrower late -night peak.

The lowest stop volumes for all racial and ethnic groups occurred in the early morning hours, particularly between 5:00 AM and 10:00 AM, before increasing throughout the afternoon and peaking again in the late evening. These differing temporal patterns raise questions about the underlying operational decisions, community behaviors, or geographic distributions that drive stop activity at different hours for these groups. Exploring these hourly stop distributions further by integrating additional data such as calls -for-service patterns, officer shift assignments, local event calendars, and geographic deployment strategies could shed valuable light on the observed disparities and similarities. Understanding these nuances may assist the department in evaluating enforcement strategies to ensure alignment with both community safety priorities and equitable policing objectives.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
31 Packet Pg. 242 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 23

Figure 11- PAPD Stops by Time of Day and Race/Ethnicity (2022 to 2023)

PAPD STOP DENSITY HEATMAPS
Figure 12 displays the geographic distribution of stops conducted by the PAPD across police beats from January 2022 through December 2023. The heat maps in this report are color-coded to represent ranges of stop density, with red and yellow areas representing the higher concentration of stops and blue and green areas indicating areas with lower stop density.

The visualization reveals that stops were heavily concentrated in Beat 1 and Beat 2. The most prominent hotspots were in Beat 2 near the border with East Palo Alto and Menlo Park, the College Terrace area in Beat 1, and locations within Beat 2 closer to the border with Beat 3.

These areas showed the highest densities of stops, suggesting significant enforcement activity in these regions.

Beats 3 and 4 exhibited notably lower stop densities, with only a few scattered points of moderate activity. This suggests that enforcement activity was concentrated in specific zones. The spatial distribution of stops may warrant further examination to determine whether stop patterns correlate with factors such as traffic volume, business districts, residential areas, or specific law enforcement initiatives in these beats (as the geographic context varies by beat observed).

Additionally, the concentration of stops in particular
Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
32 Packet Pg. 243 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 24

locations could be relevant for discussions on resource allocation and community engagement efforts within Palo Alto.

Figure 12- PAPD Stop Density Heat Map

In contrast, Figure 13 offers a more detailed, zoomed-in perspective on the specific hotspots identified within these beats, providing greater clarity on the intensity and location of police enforcement activities. The detailed heatmap reveals highly concentrated enforcement in specific intersections and blocks, notably near downtown Palo Alto in Beat 2, and a significant cluster at a major intersection in the southern portion of Beat 1. Moderate clusters in Beat 2 also emerge distinctly, highlighting locations that received consistent but less intense enforcement attention.

Conversely, enforcement activities within Beats 3 and 4 appear relatively sparse and dispersed, suggesting that stops in these areas may be related more to routine patrols rather than targeted enforcement initiatives.

This detailed visualization reinforces the key insight that stop patterns are not evenly distributed throughout Palo Alto, prompting important questions regarding the factors behind concentrated enforcement in specific areas. However, interpreting these patterns requires caution due to PAPD data recording practices. Addresses often reflect approximate or commonly reported locations (e.g., intersections or landmarks), potentially inflating apparent stop densities in these mapped Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
33 Packet Pg. 244 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 25

hotspots. To enhance reliability and interpretability, stops were also aggregated at the street- segment level, allowing for a more nuanced understanding of enforcement concentrations along specific streets rather than isolated hotspots. The street-level analysis presented in Figures 14 and 15 can further inform discussions around resource allocation, strategic deployment, and community engagement by clarifying precisely which areas experience the most frequent and sustained police attention.

Figure 13- PAPD Stop Density Detailed Heat Map

PAPD STOP DENSITY BY STREET SEGMENT
Figure 14 visualizes the density of stops per 1,000 feet of roadway in Palo Alto from 2022 to 2023, highlighting which streets experienced the highest concentration of stops. Aggregating the count of stops to specific street segments minimizes reporting issues and provides a more accurate representation of where stops occur at the street level. Streets are color -coded to reflect different levels of stop density, with darker red lines indicating areas with the highest concentration of stops, moderate red lines representing streets with mid-level stop density, and lighter-colored streets showing areas with lower stop activity.

The data reveal that stops were most heavily concentrated along major corridors, such as University Avenue, Embarcadero Road, and El Camino Real. These thoroughfares, known for their high traffic volume and commercial activity (according to discussions with PAPD representatives), accounted for a significant portion of the stops recorded in the city. The central and northern parts of Palo Alto, particularly near downtown and the Stanford area, also exhibited high stop densities, Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
34 Packet Pg. 245 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 26

suggesting that enforcement efforts were focused along these busy streets. In contrast, the southern and more residential areas of Palo Alto saw noticeably lower stop densities. Many neighborhood streets experienced minimal stop activity compared to the main arterial roads. This pattern suggests most stops occurred along primary traffic routes rather than within residential zones.

This map provides valuable insight into the distribution of enforcement activity across Palo Alto by illustrating the geographic concentration of stops. The precise concentration of stops along major roads, while residential streets saw fewer stops, highlights potential areas for PAPD to ensure that they align their stop activity with those areas that maximize public safety and community needs. In addition, coupling this analysis with geographic information about calls for service and crime would allow the PAPD to ensure that their stop activity is aligned with the underlying public safety needs of the community.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
35 Packet Pg. 246 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 27

Figure 14- PAPD Stop Density by Street Segment

Finally, the Lab research team examined whether the concentration of nightly stops seen in the time-of-day analyses resulted in different spatial patterns along street segments. Figure 15 provides a breakdown of stop density by street for only those stops occurring between 9 PM and 12 AM from January 2022 to December 2023.

Stop activity during this period was concentrated along Embarcadero Road, University Avenue, and sections of El Camino Real, which were indicated by PAPD staff to be among the busiest sections of roadway in the jurisdiction. Additional areas with moderate stop densities appeared along Hamilton Avenue, Channing Avenue, and Churchill Avenue. These roads likely represent high-traffic areas during nighttime hours, with greater pedestrian and vehicle activity. Compared to the broader stop density map covering all hours, this time-specific analysis highlights how late- Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
36 Packet Pg. 247 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 28

night enforcement efforts were concentrated along major thoroughfares but with a somewhat different distribution. While stops remained clustered along key roads, certain streets with high stop densities in the overall analysis showed reduced activity at night, suggesting variations in enforcement or travel patterns throughout the day.

The concentration of stops along specific corridors between 9 PM and 12 AM may warrant further exploration into the factors contributing to this pattern, including nightlife activity, traffic enforcement priorities, and the relationship between stop frequency and areas with high vehicle or pedestrian presence during these hours. Additional data sources from other city and state agencies may highlight the types of ambient population movement that likely increase the likelihood of stops in these areas. Other types of PAPD administrative data may also provide helpful context around the general public safety environment in these areas during these times that may impact the probability of a stop being made.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
37 Packet Pg. 248 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 29

Figure 15- PAPD Stop Density by Street Segment (9PM to Midnight)

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
38 Packet Pg. 249 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 30

S T R A T E G I C R EC O M M E N D A T I O N S F O R D A S H B O A R D EN H A N C EM EN T

PAPD RIPA Dashboard Analysis
In August 2024, PAPD also asked the Knowledge Lab to provide an assessment of its public RIPA data dashboard ( https://www.paloalto.gov/Departments/Police/Public-Information-Portal/Racial- and-Identity-Profiling-Act-RIPA-Data ). The Lab’s examination found that while the dashboard effectively presents required RIPA data, significant opportunities exist to transform it from a basic reporting tool into a valuable resource for both community members and department personnel.

Specifically, improvements in usability, audience clarity, and contextual analysis would be beneficial. The current dashboard is primarily a data repository rather than an analytical tool, with minimal contextual information to guide interpretation. The following section outlines recommendations to enhance the dashboard’s effectiveness.

DEFINE PURPOSE AND AUDIENCE
As of the writing of this report, the RIPA dashboard lacks clarity regarding its intended audience and purpose, increasing the risk of misinterpretation of complex policing data. The absence of explicit interpretive guidance leaves stakeholders uncertain about how to appropriately use and understand the data.

Recommendations:
• Clearly articulate the dashboard's purpose on the landing page, specifying whether it is intended primarily for public transparency, community education, internal analysis, or a combination thereof.
• Develop differentiated user pathways that guide stakeholders, such as community members, researchers, and department personnel, to visualizations and contexts most relevant to their needs.
• Create separate, secure interfaces for internal operational analyses distinct from public transparency dashboards.
• Provide interpretive text that clearly explains both what the data show and its inherent limitations, particularly in interpreting disparities or enforcement outcomes. • Clarify how dashboard insights could support strategic departmental goals and operational decision-making, clearly communicating this alignment within the dashboard's stated purpose.

ENHANCE DATA COMPREHENSIVENESS AND CONTEXT
While the dashboard effectively presents raw stop counts, the absence of comparative benchmarks or analytical context limits users' ability to interpret the data meaningfully.

Additionally, certain data fields, such as "Action Taken" and "Multiple Basis" for searches, present ambiguity or redundancy, further complicating interpretation.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
39 Packet Pg. 250 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 31

Recommendations:
• Incorporate carefully selected benchmarks to contextualize stop data, such as traffic patterns, calls-for-service data, or at least population demographics, accompanied by clear caveats explaining the limitations of these benchmarks. • Undertake thorough data cleaning and pre-processing, specifically addressing issues such as inconsistent "Action Taken" fields and the overly broad "Multiple Basis" category. • Incorporate dynamic, trend-focused visualizations that clearly illustrate changes over time rather than static annual snapshots.
• Add geographic visualizations to display spatial patterns of enforcement clearly. • Include detailed methodological explanations describing how RIPA data are collected and processed, and the associated limitations for interpretation. • Allow users to download raw data for independent analysis and consider automating more frequent data updates to ensure timeliness and relevance. • Integrate performance metrics that directly relate dashboard findings to departmental objectives, facilitating the measurement of strategic policing goals.

IMPROVE DASHBOARD DESIGN AND USER EXPERIENCE
The existing two-tab structure (General and Individual) presents navigation challenges, and the current data presentation emphasizes dense tables over intuitive, interactive visualizations.

Filtering capabilities are limited and do not persist across dashboard views, inhibiting comprehensive data exploration.

Recommendations:
• Restructure the dashboard around clearly defined, purpose-specific tabs, such as Overview, Stops, Searches, Outcomes, and Demographics.
• Enhance filtering capabilities, ensuring user selections persist across multiple dashboard views to facilitate deeper data exploration.
• Prioritize intuitive visualizations, such as interactive charts, graphs, and maps, complemented by interpretive context rather than relying solely on dense data tables. • Create interactive elements allowing users to explore targeted questions of interest. • Provide clear definitions of technical terms directly within the dashboard interface to support accurate interpretation.
• Ensure the dashboard design is responsive and accessible across all device types, including mobile platforms.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
40 Packet Pg. 251 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 32

IMPLEMENTATION CONSIDERATIONS
Effective implementation of these enhancements requires a commitment beyond technical development. They could be incorporated more broadly into PAPD's strategic priorities to further PAPD’s transparency and accountability efforts.

Recommendations:
• Engage community stakeholders throughout the dashboard redesign process to ensure the tool addresses public information needs as appropriate. • Develop a comprehensive communication strategy to educate users on the dashboard’s purpose, data limitations, and appropriate interpretation. • Establish regular review procedures to monitor and address data quality issues proactively.
• Implement formal feedback mechanisms enabling users to suggest continuous improvements.
• Clearly link dashboard data to broader departmental transparency and accountability initiatives.
• Establish internal processes to routinely leverage dashboard data for operational decisions, ensuring alignment between enforcement practices and broader departmental goals.

By implementing these recommendations, PAPD can significantly enhance its RIPA dashboard, transforming it into a dynamic resource that effectively communicates policing practices, fosters community trust through transparency, and provides actionable insights for continuous departmental improvement.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
41 Packet Pg. 252 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 33

G E N E R A L TR E N D S A N D P A T T E R N S

SUMMARY OF FINDINGS

An analysis of the Palo Alto Police Department's administrative data from January 2022 to December 2023 reveals several important patterns in the nature and distribution of PAPD activity.

These findings, derived from various analytical approaches, provide insights into general enforcement patterns and traffic citations, including potential disparities that warrant attention.

The analyses conducted by the Knowledge Lab can help inform the Palo Alto Police Department's strategic priorities and long-term planning as the department continues to collect this data (2024 data was not yet available at the time of analysis for this report ).

• After relative stability in 2022, the number of monthly stops significantly increased in early 2023, followed by a notable decrease in the second half of the year. An examination of stops by PAPD beats shows that the increase in early 2023 was driven by Beats 2 and 3.

Beat 2 experienced a 38% increase in stops, and Beat 3 experienced an 83% increase between 2022 and 2023. Stops in Beats 1 and 4 were relatively more stable, increasing only by 9% and 6% during that period, suggesting enhanced enforcement activity in Beats 2 and 3 but not in Beats 1 and 4.
• Of the 10,509 stops included in this analysis, 8,686 (over 83%) were recorded as resulting from officer-initiated activity rather than in response to a call. • When PAPD stops were examined by the reason for the stop, 74% were found to be for traffic violations during the two-year period. The second most frequent reason was reasonable suspicion that the person engaged in criminal activity at 18% of stops. • When PAPD stops were examined by the actions taken during the stop, most stops (over 70%) involved no action being recorded. Asian (83.2%) and Middle Eastern (80.5%) individuals had the highest proportion of stops resulting in no action, while Black individuals had the lowest proportion at 60.3%.
• When PAPD stops were examined by the result of the stop, more than half of stops (~57%) resulted in no action or minimal intervention, including written and verbal warnings; 28% of stops resulted in administrative actions, and 12% resulted in an arrest. Disaggregating stop results by race/ethnicity shows that stops involving Black individuals were more likely to end with an arrest, and stops involving Asian individuals were more likely to end with a citation.
• On average, 16.8% of stops involved a search during 2022 and 2023. Looking at monthly data, most months saw 10% to 20% of stops involving a search, with a peak occurring in August 2022, when 27.3% of stops included a search.
• While monthly stops involving Black individuals generally had the highest percentage of searches (often over 30%) compared to other groups, stops involving Black individuals resulted in lower hit rates than white or Hispanic individuals. Searches of white individuals Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
42 Packet Pg. 253 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 34

had the highest hit rate at 12.4%. Searches of white individuals were more likely to yield contraband or evidence compared to searches of other racial and ethnic groups. • Veil of darkness tests (as described on page 5) indicated that Black drivers were significantly less likely to be stopped during nighttime hours compared to daytime stops, relative to white drivers. No meaningful difference was found in the likelihood of stops for Hispanic and white drivers based on whether the stop occurred during daylight or nighttime hours.
• The majority of stops occurred during the evening hours. Stop activity peaked between 10 PM and midnight, with the highest number of stops occurring around 11 PM. This pattern was maintained across all groups when looking at the time of stops by race and ethnicity. • The shifting concentration of stops along specific corridors between 9 PM and 12 AM may warrant further exploration into the factors contributing to this pattern, including nightlife activity, traffic enforcement priorities, and the relationship between stop frequency and areas with high vehicle or pedestrian presence during these hours.

RECOMMENDATIONS

The City asked the Knowledge Lab to provide recommendations based on the data analysis and findings of this work. The following recommendations are grounded in the findings from the stop data audit, analysis of enforcement patterns, and review of the department's public-facing dashboard. They reflect best practices in law enforcement transparency, data quality, and performance management. The goal is to help the Palo Alto Police Department strengthen its data infrastructure, improve public accountability, and align enforcement activities with community needs.

DATA INFRASTRUCTURE AND COLLECTION
Expand and Improve Data Collection
• Consider recording all police-citizen encounters: It is recommended that PAPD establish a process for documenting all police- public contacts, including those that do not result in citations or searches, to provide a complete picture of PAPD activity. • Detailed traffic violation coding: It is recommended that PAPD consider recording specific traffic violation types rather than general categories to support more precise analysis of stop patterns and enforcement priorities.
• Improve accuracy and completeness of key fields: It is recommended that PAPD consider enhancing data entry quality, particularly for stop reasons, outcomes, and officer actions, to reduce ambiguity and support clearer interpretation by recording each action or stop reason/outcome in their own fields. The current data structure allows for multiple selections but does not separate the selections from one another, resulting in added complexity to interpret or analyze the data.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
43 Packet Pg. 254 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 35

• Improve location data reporting: It is recommended that PAPD consider recording exact addresses or intersections where stops occur to improve spatial analysis and limiting the use of general landmarks or business names to avoid clustering unrelated stops. • Create integrated operational datasets: It is recommended that PAPD consider linking stop data with calls-for-service, crime reports, and arrest records. This will support more holistic and sophisticated analysis of officer activity and improve understanding of whether stops are aligned with crime prevention and community safety objectives.

STRATEGIC MONITORING AND ANALYSIS
Implement Ongoing Trend Monitoring
• Track changes over time: It is recommended that PAPD consider establishing routine internal monitoring of stop volumes, reasons, outcomes, and demographic breakdowns to detect meaningful changes or emerging trends and utilizing the current dashboard and RIPA data for operational decision -making and monitor trends in stops alongside other key department metrics.
• Identify outliers and anomalies: It is recommended that PAPD consider using the ongoing monitoring mechanisms (e.g., dashboards and regular internal meetings) and data analysis to flag significant shifts in stop activity (e.g., surges in searches, increases in nighttime stops, or demographic disparities in outcomes) that may require operational or policy review.
• Evaluate alignment with community priorities: It is recommended that PAPD consider periodically assessing whether stop activity corresponds to known crime or traffic concerns, helping ensure that enforcement is strategic and responsive to current trends and community needs.

PUBLIC TRANSPARENCY AND DASHBOARD ENHANCEMENTS
Improve the Utility of the RIPA Dashboard
• Clean and pre-process data before publication: It is recommended that PAPD consider standardizing values and resolving inconsistencies or multiple coding options in key fields before presenting data on public dashboards to minimize confusion and complexity. • Enhance visualizations and functionality: It is recommended that PAPD consider improving interactivity and clarity of data displays and including filters that persist across views, incorporate more intuitive, engaging graphs and maps, and include explanatory text to guide interpretation.
• Expand methodological documentation: It is recommended that PAPD consider providing clear explanations on the dashboard of how RIPA data is collected, processed, and where it is limited, helping community users understand what the data can and cannot say.

COMMUNITY ENGAGEMENT AND QUALITATIVE RESEARCH
Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
44 Packet Pg. 255 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 36

Integrate Officer and Community Perspectives
• Conduct interviews or focus groups: It is recommended that PAPD consider engaging officers and community members to explore perceptions of stop activity, contextual factors influencing enforcement decisions, and opportunities for improvement. These perspectives can complement quantitative analysis and provide deeper insight into the meaning behind the numbers.

These recommendations will position PAPD to make its stop data more actionable, interpretable, and meaningful. Enhanced data infrastructure and monitoring can support more effective internal decision-making. Improving transparency and community engagement will build public trust and ensure that policing practices are equitable and evidence-based.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
45 Packet Pg. 256 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 37

REFERENCES

Baumgartner, F. R., Christiani, L., Epp, D. A., Roach, K., & Shoub, K. (2017). Racial Disparities in Traffic Stop Outcomes. Duke Forum for Law & Social Change, 9(21).

Chainey, S., & Ratcliffe, J. H. (2005). GIS and Crime Mapping. Chichester, West Sussex, England:

Wiley.

Geller, A., Goff, P. A., Lloyd, T., Haviland, A., Obermark, D., & Glaser, J. (2021). Measuring Racial Disparities in Police Use of Force: Methods Matter. Journal of Quantitative Criminology, 37(4), 1083–1113. https://doi.org/10.1007/s10940-020-09471-9
Grogger, J., & Ridgeway, G. (2006). Testing for Racial Profiling in Traffic Stops From Behind a Veil of Darkness. Journal of the American Statistical Association. https://doi.org/10.1198/016214506000000168
Knox, D., & Mummolo, J. (2020a). Making Inferences About Racial Disparities in Police Violence.

Proceedings of the National Academy of Sciences, 117(3), 1261–1262. https://doi.org/10.1073/pnas.1919418117
Knox, D., & Mummolo, J. (2020b). Toward a General Causal Framework for the Study of Racial Bias in Policing. Journal of Political Institutions and Political Economy, 1(3), 341–378.

Neil, R., & Winship, C. (2019). Methodological Challenges and Opportunities in Testing for Racial Discrimination in Policing. Annual Review of Criminology, 2(1), 73–98. https://doi.org/10.1146/annurev-criminol-011518-024731
Shadish, W. R., Cook, T. D., & Campbell, D. T. (2002). Experimental and Quasi-Experimental Designs for Generalized Causal Inference. (pp. xxi, 623). Houghton, Mifflin and Company.

Smith, M. R., Rojek, J. J., Petrocelli, M., & Withrow, B. (2017). Measuring Disparities in Police Activities: A State of the Art Review. Policing: An International Journal of Police Strategies & Management, 40(2), 166–183. https://doi.org/10.1108/PIJPSM-06-2016-0074 Smith, M. R., Tillyer, R., Lloyd, C., & Petrocelli, M. (2021). Benchmarking Disparities in Police Stops:

A Comparative Application of 2nd and 3rd Generation Techniques. Justice Quarterly, 38(3), 513– 536. https://doi.org/10.1080/07418825.2019.1660395
Swencionis, J. K., & Goff, P. A. (2017). The Psychological Science of Racial Bias and Policing.

Psychology, Public Policy, and Law, 23(4), 398–409. https://doi.org/10.1037/law0000130 Withrow, B. L. (2004). A Comparative Analysis of Commonly Used Benchmarks in Racial Profiling:

A Research Note. Justice Research and Policy, 6(1), 71–92. https://doi.org/10.3818/JRP.6.1.2004.71 Witte, R. S., & Witte, J. S. (2017). Statistics. Wiley.

Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
46 Packet Pg. 257 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 38

C L A S S IF IC A T I O N S C HE M E FO R A C T I O NS T A K E N

APPENDIX A: RE-CLASSIFYING PAPD RIPA
CODES

USE OF FORCE ( LETHAL)
Code 9: Firearm discharged or used

POINTING OF FIREARM
Code 8: Firearm pointed at a person

USE OF FORCE (NON- LETHAL)
Code 7: Canine removed from vehicle or used to search
Code 10: Electronic control device
Code 11: Impact projectile discharged or used (e.g., blunt impact projectile, rubber bullets, or bean bag)
Code 12: Canine bit or held person
Code 13: Baton or other impact weapon used
Code 14: Chemical spray used (e.g., pepper spray, mace, or other chemicals)

DETENTION AND RESTRAINT
Code 4: Curbside detention
Code 5: Handcuffed or flex cuffed
Code 6: Patrol car detention

SEARCH AND SEIZURE
Code 18: Search of person was conducted
Code 20: Search of property was conducted
Code 21: Property was seized
Code 22: Vehicle impounded

PHYSICAL CONTACT WITHOUT FORCE
Code 2: Person removed from vehicle by physical contact Code 15: Other physical or vehicle contact
Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
47 Packet Pg. 258 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 39

C L A S S I FI C A T I O N S C HE M E FO R R E S U L T O F T HE S T O P

NON -PHYSICAL ACTIONS
Code 1: Person removed from vehicle by order
Code 3: Field sobriety test conducted
Code 16: Person photographed
Code 17: Asked for consent to search person
Code 19: Asked for consent to search property
Code 23: Admission or written statement obtained from student Code 24: None

ARRESTS
Code 5: Custodial arrest pursuant to outstanding warrant Code 6: Custodial arrest without warrant

FEDERAL INVOLVEMENT
Code 11: Contacted U.S. Department of Homeland Security (e.g., ICE or CBP)

NON - CRIMINAL INTERVENTIONS
Code 10: Psychiatric hold (W&I Code 5150 or 5585.20)
Code 8: Noncriminal transport or caretaking transport (including transport by officer, ambulance, or other agency)
Code 9: Contacted parent/legal guardian or other person responsible for the minor Code 12: Referral to school administrator
Code 13: Referral to school counselor or other support staff

ADMINISTRATIVE ACTIONS
Code 3: Citation for infraction (use for local ordinances only) Code 4: In-field cite and release
Code 7: Field interview card completed

NO ACTION OR MINIMAL INTERVENTION
Code 1: No action
Code 2: Warning (verbal or written)
Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
48 Packet Pg. 259 of 291

A N A N A L Y SI S O F P OL I C E STO P D A TA / 40

LEGAL AUTHORITY
Code 3: Search warrant
Code 10: Incident to arrest
Code 4: Condition of parole/probation/PRCS/mandatory supervision

SAFETY AND EXIGENT CIRCUMSTANCES
Code 11: Exigent circumstances/emergency
Code 2: Officer safety/safety of others

EVIDENCE OF CRIME
Code 9: Evidence of crime
Code 5: Suspected weapons
Code 6: Visible contraband
Code 7: Odor of contraband
Code 8: Canine detection

CONSENT AND INVENTORY
Code 1: Consent given
Code 12: Vehicle inventory

POLICY VIOLATIONS
Code 13: Suspected violation of school policy

C L A S S IF IC A T I O N S C H E ME O F B A S I S FO R S E A R C H C O DE S Item A
Attachment A - National
Policing Institute (NPI) RIPA
Data Report, 2026

Item A: Staff Report
Pg.
49 Packet Pg. 260 of 291

Palo Alto Police Department Responses to Recommendations from the National Policing Institute (NPI) Report
February 2026

The following information is organized by recommendation as labeled by NPI. These are responses from the Palo Alto Police Department.

Data Infrastructure and Collection
The Palo Alto Police Department (“the Department”) collects data as legally required by the RIPA Act. Collecting RIPA-analogous demographic data for all police-public contacts is not practicable as it would be overly burdensome due to the many community interactions that officers have daily. Additionally, the brevity of many interactions (and the ubiquity of e-mail and telephonic interactions) makes collecting meaningful demographic data problematic.

Consistent with the RIPA Act, for stops initiated due to a traffic violation, the Department already documents whether the violation is a moving violation, an equipment violation, or a non-moving violation, as well as the specific CA Vehicle Code section violated. The Department is exploring whether its RIPA Data Dashboard can be modified to allow the data set to be sorted at an even greater level of specificity.

The RIPA Act sets forth a specific set of data points to be collected. The application that the Department uses to make RIPA data entries is an industry standard tool, used by a majority of CA agencies, that has been specifically designed to collect the prescribed data set. The Department cannot customize existing fields, and its ability to add non-mandatory fields is limited.

Stop location data is captured via the computer-aided dispatch (CAD) system and derived from officer radio traffic or information provided by a reporting party (in the case of a dispatched call for service). When broadcasting the location of a stop, officers are trained to use landmarks, intersections, or 100 blocks for officer safety reasons (i.e., so that other officers can quickly locate the stop if help is needed). This practice does not diminish the precision of stop location data in a way that would meaningfully impact analysis.

The Department’s CAD and report-writing systems are already integrated. The Department will explore whether further integration of these systems, and other disparate systems, is feasible, and whether future analysis could include this broader dataset.

Item A
Attachment B - Palo Alto
Police Department
Responses to NPI
Recommendations

Item A: Staff Report
Pg.
50 Packet Pg. 261 of 291

Strategic Monitoring and Analysis
Going forward, the Department will review year-over-year RIPA data sets on an annual basis, in order to better track changes over time, identify any outliers and anomalies, and to evaluate alignment with community priorities.

Public Transparency and Dashboard Enhancements
The data points prescribed by the RIPA Act changed from 2023 to 2024, making year-over- year data comparison (and visual representation) challenging for those years. The Department is hopeful that, going forward, the standardized data fields will alleviate these issues.

Of note, the Department was the first (and continues to be the only) local law enforcement agency in the Bay Area to maintain a sortable RIPA data dashboard. The dashboard is not required by statute and goes beyond the state requirements to collect and post static data.

The Department will continue to update the dashboard’s functionality annually, as resources permit, to improve the user interface and will use the recommendations from the report as suggestions.

The Department will continue to maintain a dedicated RIPA webpage, which includes explanations of how RIPA data is collected and processed, and where it is limited.

Community Engagement and Qualitative Research
Per the recommendation in the NPI report to create a space for feedback, the Department has added to its dedicated RIPA webpage a “community feedback” function, which allows community members to submit questions, comments or concerns.

Item A
Attachment B - Palo Alto
Police Department
Responses to NPI
Recommendations

Item A: Staff Report
Pg.
51 Packet Pg. 262 of 291

City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Public Works
Meeting Date: March 9, 2026
Report #:2511-5441
TITLE
Information Report on Sustainability and Climate Action Plan (S/CAP) Implementation, 2025 Quarters 3-4; CEQA Status - Not a Project

RECOMMENDATION
No City Council action is required. This is an update on Sustainability and Climate Action Plan (S/CAP) Implementation Progress in quarters three and four of calendar year 2025. It is provided to give the City Council and public an overview of S/CAP workplan items status since adopted by the City Council in June of 2023.

EXECUTIVE SUMMARY
The City is implementing the Sustainability and Climate Action Plan (S/CAP) to help meet its sustainability goals, including its goals of reducing greenhouse gas (GHG) emissions 80% below 1990 levels by 2030 (the “80 x 30” goal) and achieving carbon neutrality by 2030. Since the S/CAP was adopted in June 2023, staff has provided implementation updates covering progress from Q3 2023 through Q2 2025. This update covers progress in Q3 and Q4 2025. Highlights of Q3 and Q4 2025 progress include:

Climate Action
Served 152 utilities customers through the free online home electrification assessment service launched in January 2025
The City Council approved design guidelines for an Advanced Packaged HVAC Pilot Program serving commercial utilities customers
Provided rebates that enabled projects providing electric vehicle charger access to 125 Alta Housing income-qualified apartments by the end of 2025 Completed the e-Mobility Strategic Roadmap, which the City Council accepted in August 2025
Conducted community engagement and began developing land use alternatives for the Bayshore Alma San Antonio Priority Area. This Priority Area is part of the San Antonio Road Area Plan, which has the potential to reduce emissions by creating cohesive mixed-use neighborhoods with improved mobility and interconnectivity Item B
Item B Staff Report

Item B: Staff Report
Pg.
1 Packet Pg. 263 of 291

Identified preferred alternatives for the South Palo Alto Bike/Ped Connectivity Project Sustainability
Began construction on the Local Advanced Water Purification System Project that could expand the use of recycled water of irrigation by improving the quality of recycled water Began construction of the Palo Alto Horizontal Levee Pilot Project, an innovative project intended to protect infrastructure from sea level rise while supporting biodiversity and water quality
Conducted fuel management on 400 acres of Foothills and Arastradero Nature Preserves to mitigate potential risks from wildfires

BACKGROUND
In April 2016, the City Council adopted the goal of reducing GHG emissions 80% below 1990 levels by 2030 (the “80 x 20” goal),1 and in October 2022 the City Council adopted the ambitious goal of achieving carbon neutrality by 2030.2 Staff, with community and City Council input, referred to the 2016 Sustainability and Climate Action Plan (S/CAP) Framework and 2018- 2020 Sustainability Implementation Plan to create a comprehensive S/CAP and Three-Year S/CAP workplan.3 In June 2023, Council adopted the 2022 Sustainability and Climate Action Plan, certified the Comprehensive Plan Environmental Impact Report Addendum: Update to the Sustainability and Climate Action Plan, and accepted the 2023-2025 S/CAP Workplan.

The S/CAP is an ambitious plan to reduce the City and community’s GHG emissions, while also guiding how Palo Alto uses land and natural resources in ways that ensure quality of life for future generations. The S/CAP aligns with several goals of the 2030 Comprehensive Plan Implementation Plan. All previous S/CAP Implementation progress reports can be found in the Sustainability and Climate Action Plan (S/CAP) Program Reports section of the Sustainability Actions and Accomplishments page of the City website.4 The 2022 S/CAP and 2023-2025 S/CAP Work Plan align closely with one of the four City Council Priorities for calendar year 2025:
“Climate Action and Adaptation, and Natural Environment Protection.” In addition, there are several overlapping City Council Priority Objectives, the status of which can be found in the 2025 City Council Priority Objectives Q4 Report presented to Council on January 12, 2026.5 This report references the City Council Priority Objectives in parentheses where applicable.

1 City Council, April 18, 2016; Agenda Item #10; SR #6754, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=79086&dbid=0&repo=PaloAlto 2 City Council, October 3, 2022; Agenda Item #9; SR #14720, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82036&dbid=0&repo=PaloAlto 3 City Council, November 3, 2025; Agenda Item #14; SR #2505-4672, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83784&dbid=0&repo=PaloAlto 4 Sustainability and Climate Action Plan (S/CAP) Progress Reports; https://www.paloalto.gov/City- Hall/Sustainability/Emissions-Reduction-Goals-and-Progress/Sustainability-Actions-and-Accomplishments 5 City Council, January 12, 2026; Agenda Item #2; SR #2511-5583; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85203&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
2 Packet Pg. 264 of 291

ANALYSIS
The City is committed to a sustainable future. The City owns, operates, and maintains a full- service utilities portfolio that provides electric, natural gas, fiber, water, refuse, and wastewater services to residents and businesses in Palo Alto. Palo Alto’s continued leadership in advancing sustainability commitments has succeeded mainly because of the continued collaboration of community stakeholders, City departments, and the leadership of the City Council.

The S/CAP Goals and Key Actions are divided into eight areas, four of which are climate-focused and include actions to achieve the City’s 80 x 30 and carbon neutrality by 2030 goals (Climate Action, Energy, Electric Vehicles, and Mobility) and four of which are focused on actions that create a sustainable natural environment and adapting to a warming climate (Water, Climate Adaptation and Sea Level Rise, Natural Environment, and Zero Waste). The Work Plan is similarly divided between climate-focused and sustainability-focused priorities.

There are 23 City Council Priority Objectives in the 2025 City Council Priority Area Climate Action and Adaptation, & Natural Environment Protection (CA).11 This report addresses 18 of those City Council Priority Objectives, as well as one in City Council Priority Area Economic Development & Retail Vibrancy (ED), three in Implementing Housing Strategies for Social & Economic Balance (IHS), and one in Public Safety, Wellness & Belonging (PS), as shown in Table

1. One CA City Council Priority, "Implement plan for phaseout of leaded fuel at Palo Alto Airport,” was not addressed in the 2023-2025 S/CAP Implementation Work Plan.

Table 1: 2025 City Council Priority Objectives Addressed in the S/CAP Informational Report Number City Council Priority Objective
Economic Development & Retail Vibrancy (ED)
ED 6 Council approval of funding to continue Downtown cleanliness enhancements and other medium-term investments such as a Mobility Hub.

Climate Action and Adaptation, & Natural Environment Protection (CA) CA 13 Council Adoption of the Safe Streets for All (SS4A) Safety Action Plan.

CA 14 Begin construction of the Newell Road Bridge Replacement project.

CA 15 Complete construction of initial pilot area of electric grid modernization.

CA 16 Begin construction of Hamilton Avenue storm drain system capacity upgrades project.

CA 19 Council Adoption of the 2025 Bicycle and Pedestrian Transportation Plan (BPTP).

CA 20 Develop and begin implementing a City Facility Electrification Plan.

CA 22 Complete implementation of the Reliability and Resiliency Strategic Plan, including Strategy 4 – conducting a cost/benefit analysis of flexible energy resources such as battery storage and microgrids (including evaluation of the airport microgrid), and Strategy 5 – recommending potential programs for Council consideration.
11 City Council, August 18, 2025; Agenda Item #A; SR # 2508- 5034; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83560&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
3 Packet Pg. 265 of 291

CA 24 Refine Grade Separation Design Alternatives per Council Direction and Conduct Outreach to Support Rail Committee Review of Locally Preferred Alternatives.

CA 25 Identify locations and design concepts for additional east-west bicycle and pedestrian crossings of the Caltrain railroad tracks in the southern part of the city.

CA 26 Advocate for the San Francisquito Creek Flood Protection capital project (Reach 2) through Council’s JPA representation and any Council approvals involved.

CA 27 Begin development of a Regional Shoreline Adaptation Plan meeting new standards approved by BCDC.

CA 28 Initiate Preliminary Engineering and Environmental Clearance Work for Quarry Road Extension in Partnership with Stanford University, Caltrans, & VTA.

CA 29 Complete deployment of 65,000 residential Advanced Metering Infrastructure (AMI) meters by end of FY 2025 and begin deployment of commercial AMI meters.

CA 30 Complete E-Mobility Strategic Plan for Council acceptance.

CA 34 Council approval for Phase 2 (full service program) of the Advanced Whole Home Electrification Pilot Program and begin implementation.

CA 35 Develop an Advanced Commercial Rooftop HVAC Pilot Program proposal and review with the Climate Action and Sustainability Ad Hoc Committee for
recommendation to Council.

CA 36 Propose an updated multi-family EV charger program (EV 2.0) for Council approval.

Implementing Housing Strategies for Social & Economic Balance (IHS) IHS 48 Present to Council the Downtown Housing Plan Community Assessment report and receive Council direction on draft housing plan scenarios.

IHS 49 Initiate the San Antonio Road Area Plan.

IHS 50 Advance affordable housing project on Downtown surface parking lot (Lot T).

Public Safety, Wellness & Belonging (PS)
PS 58 Council to adopt the updated Foothills Fire Management Plan and Community Wildfire Protection Plan.

Climate Action
Covering the S/CAP Areas of Climate Action, Energy, Electric Vehicles, and Mobility, this section reports on progress based on the Work Plan Climate Action Priority areas. This includes five priorities with various work items under each priority. This report notes where these work items have been designated as City Council Priority Objectives.

P1. Grid Modernization
P2. Launch Programs
P2.1 Residential Emissions Reduction
P2.2 Non-Residential Emissions Reduction
P2.3 Citywide Mobility
P2.4 Municipal Electrification
P2.5 Electric Vehicle (EV) Strategic Plan
P3. Build Awareness and Confidence
P4. Additional Emissions Reductions
P5. Funding Needs and Sources
Item B
Item B Staff Report

Item B: Staff Report
Pg.
4 Packet Pg. 266 of 291

P1. Grid Modernization
Electric grid reliability and resilience will be important to inspire confidence in electrified homes and vehicles. The focus of Priority 1 is to preserve and enhance reliability, modernize the electric grid and replace aging infrastructure, increase electric grid capacity to accommodate electrification, and explore ways to enhance resiliency.

Grid Modernization (Work Plan Item 1A; Council Priority Objective CA 1): Staff has been evaluating results from a pilot project that replaced and upgraded aging infrastructure serving approximately 1000 residents before determining how to most cost-efficiently continue the project. Staff is gathering feedback from the Utilities Advisory Commission (UAC) and Climate Action and Sustainability Committee (CASC) about the costs, pros, and cons of different approaches to grid modernization (a proactive replacement approach or a flexible approach of replacing as capacity is needed). More detail on these proposals can be found in the January 7, 2026 report to the UAC.13
Reliability & Resiliency Strategic Plan (Work Plan Items 1B, 1C; Council Priority Objective CA 4):

In April 2024, the City Council accepted the Reliability and Resiliency Strategic Plan (RRSP). Staff has been implementing the plan and providing status updates to the UAC and CASC. The most recent updates to these bodies were December 3, 2025 and November 20, 2025 respectively.14,15 A status update will be provided to the City Council in March 2026.

One major focus for the UAC and CASC has been implementing Strategy 4 (Evaluate the benefits of flexible energy and resiliency technologies and efficient electrification strategies to the utility and community) and Strategy 5 (Evaluate the resource needs to promote the adoption of various flexible demand reduction and resiliency solutions and efficient electrification strategies) of the RRSP. Through 2025, the UAC and CASC provided feedback at various points on a study of the cost-benefit associated with using these technologies to reduce utility supply costs, defer utility distribution investment, and improve long-term resiliency in the community. The completed study was presented to the UAC and CASC at their December and November meetings.16,17
13 Utilities Advisory Commission, January 7, 2026, Agenda Item #3, Fiscal Year 2026 Mid-Year Electric Grid Moderniz ation Update, Staff Report 2512-5638 ; https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id= 10311&meetingTemplateType=2&compiledMeetingDocumentId=18174 14 Utilities Advisory Commission, December 3, 2025; Agenda Item #2; SR #2508-5038; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84166&dbid=0&repo=PaloAlto 15 Climate Action and Sustainability Committee, November 20, 2025; Agenda Item #3; SR #2507-5028; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83907&dbid=0&repo=PaloAlto 16 Utilities Advisory Commission, December 3, 2025; Agenda Item #2; SR #2508-5038; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84166&dbid=0&repo=PaloAlto 17 Climate Action and Sustainability Committee, November 20, 2025; Agenda Item #3; SR #2507-5028; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83907&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
5 Packet Pg. 267 of 291

Few technologies analyzed showed a positive cost-benefit result that would merit incentives, but the CASC and the UAC identified the need for a continued focus on outreach, regular Item B
Item B Staff Report

Item B: Staff Report
Pg.
6 Packet Pg. 268 of 291

updates to the analysis as costs and benefits may change, and barrier reduction in the areas of permitting, interconnection, and other barriers. The City Council will consider recommendations from the CASC and the UAC in March.

Utility Rates and Fees (Work Plan Item 1D; Council Priority Objective CA 5): The City is on track to complete the advanced metering infrastructure project by the end of 2026. On June 4, 2025, the UAC recommended approval of time of use rates that customers could use to achieve savings by moving electric consumption to times of lower cost electricity.23 Modifications to transformer upgrade fees were adopted in late 2025 to avoid situations where the resident who triggers a transformer upgrade would pay the entire cost of that upgrade.24 P2. Launch Programs
The focus of Priority 2 is to launch effective programs for emissions reductions with the highest impact and lowest cost such as single-family electrification, strategic promotion of EVs, commercial rooftop HVAC (heating, ventilation, and air conditioning), and expanded transportation alternatives.

P2.1. Residential Emissions Reduction: The goals for residential emissions reduction embodied in the Work Plan include encouraging electric vehicle (EV) adoption for all residents, helping multi-family residents access EV charging, and facilitating building electrification of single-family homes and multi-family affordable housing.

Advanced Heat Pump Water Heater Pilot (Work Plan Items 2.1D, 2.1E): The City launched the Advanced Heat Pump Water Heater Pilot Program in March 2023 with the goal to install 1,000 heat pump water heaters (HPWH). The City launched a new Emergency Water Heater Replacement program in September 2024. As of December 31, 2025, 745 residents had either completed installations or signed contracts to get a heat pump water heater installed through the City’s programs, with 100 of these projects applying for on-bill financing. The City has completed around 250 water heater conversions per year through the Advanced HPWH Pilot Program, equivalent to almost 20% of the water heaters estimated to be replaced each year. In addition, the City and State Energy Reach Codes encourage new construction and major renovations to be built all-electric, which adds another 100-200 new heat pump water heaters each year.25 The rate of HPWH retrofits has slowed in 2025 compared to the first year and a half of the program. The pilot has moved past the early adopters after the first 18 months. 23 Utilities Advisory Commission, June 4, 2025; Agenda Item #4; SR #2503-4361; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61770&dbid=0&repo=PaloAlto 24 City Council, October 20, 2025, Staff Report #2505-4736, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83645&dbid=0&repo=PaloAlto&searchid=fe40954f- c0ac-49f4-b75f-daea4dc9bac7
25 City Council, June 3, 2024; Agenda Item #17; SR #2405-3073; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82875&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
7 Packet Pg. 269 of 291

Because the next wave of customers tends to be more cost-conscious and/or have more complex projects, they will need additional incentives or support to make the switch.

The City is continuing to pursue various efforts to promote HPWH adoption among single-family households. In 2025, the City worked on the following initiatives:
Innovative marketing: launched a HPWH Giveaway campaign on Earth Day with the prize of a free HPWH installation to encourage residents to install a HPWH, as well as a new Refer-a-Neighbor program launched in October. Water Heater Safety stickers were mailed out in December, promoting the emergency replacement program. Facilitate rebate applications: continued the Rebate Hub that was launched the first half of 2025.
Expert Consultation: continued the free expert consultation program that was launched in the first half of 2025 to help residents complete installations. Customer outreach: promoted HPWHs at community events and hosted two webinars on home electrification. The City also rented an “All-Electric Dream Home” display for the Municipal Service Center Open House in July, with over 200 residents touring this life-sized model. Ongoing outreach includes promotions through the City’s social media channels as well as Google ad campaigns.

Whole Home Electrification (Work Plan Items 2.1G, 2.1H; Council Priority Objective CA 34): The City is launching its whole home electrification program in two phases. The first phase, launched in January 2025, offers new rebates and a contractor directory through the Rebate Hub, an online home electrification assessment tool, free phone consultation with an electrification expert, and financing through the state’s GoGreen program. As of December 31, 2025, the City had processed rebates for 89 heat pump HVAC projects, 17 electric panel upgrades, and 19 gas meter removal incentives. Additionally, 152 customers have completed the online home electrification assessment. The City expects to soft launch phase two in early 2026, with a full launch planned in spring 2026.

Electric Vehicles and Charging (Work Plan Items 2.1A, 2.1C, 2.1J; Council Priority Objective CA 19): The City’s promotion of EV adoption and expansion of multi-family EV infrastructure continued. To promote the benefits of clean driving, the City offered 12 free EV activities to the public and one EV educational webinar for City staff in Q3 and Q4 2025. Over 1,150 people attended six online webinars about EVs and incentives. Events in Q3 and Q4 consisted of two new EV discount programs; two in-person EV and e-bike showcases at City facilities; two in- person EV showcases at community-gathering events; and three in-person EV workshop and showcase events at affordable housing properties. The City plans to continue offering additional EV showcases, free workshops, webinars, and discount programs in 2026, with a focus on residents at multi-family market-rate and affordable housing properties.

In Q3 and Q4 2025, four multi-family properties representing 342 housing units installed EV chargers through the City EV Charger Rebate program. To date, a total of 26 multi-family Item B
Item B Staff Report

Item B: Staff Report
Pg.
8 Packet Pg. 270 of 291

properties representing 1,324 housing units (about 12.4% of all multi-family units in Palo Alto) have installed a total of 325 EV charging ports and 48 EV-ready spaces (i.e. infrastructure to support additional charger installation at a later date) facilitated through the City's EV programs. Another 13 multi-family projects are in the permitting and installation phases and an additional 22 are in the project design phase (representing a total additional 1,753 residential units).

On November 17, 2025, City Council approved the Design Guidelines for the Successor to the Current Multifamily EV Charger Program (EV 2.0) as recommended by the Climate Action and Sustainability Committee.29 The EV 2.0 design guidelines are focused on:
financial models aimed at scaling installations communitywide; serving different types of multi-family buildings with different levels of EV adoption utilizing a variety of EV charging technologies;
deploying shared charging at low levels of adoption and individual chargers where demand supports them;
grid-friendly installations and inclusion of active and shared transportation facilities where appropriate; and
complementary programming to help drive adoption of e-mobility and use of active and shared transportation.

Affordable Housing Electrification (Work Plan Item 2.1I; Council Priority Objective CA 19): The City continues to engage with multi-family affordable housing providers in Palo Alto on building electrification and EV charging. The City is working to design a program to provide incentives for electrification of dedicated affordable multi-family housing central and in-unit gas equipment, with program launch targeted in early 2026. As part of this effort, the City is coordinating with the State’s Low-Income Weatherization Program (LIWP) to align program enrollment processes and eligibility requirements and allow projects to leverage program technical assistance and LIWP incentives for energy efficiency and electrification alongside the City’s incentives planned to the greatest extent possible.

Through the City’s EV Charger Rebate program, Alta has completed EV charging projects at two of their properties to date, providing access to 125 income-qualified apartments by the end of 2025. Two additional Alta Housing properties and one MidPen Housing property are expected to complete projects in early 2026, providing EV charging access to an additional 316 units.

The City’s Residential Energy Assistance Program (REAP) for income-qualified customers continues to reach the City’s most vulnerable population, offering energy and water efficiency improvements at no cost to the customer. In Q3 and Q4 2025, 18 customers participated in the REAP program. Four REAP customers received HPWHs at no cost, and two additional REAP 29 City Council, November 17, 2025; Agenda Item #3; SR #2508-5087; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83873&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
9 Packet Pg. 271 of 291

customers received a site assessment for a HPWH and are awaiting installation. Fourteen REAP customers received energy and water efficiency upgrades.

P2.2. Non-Residential Emissions Reduction: The goals for non-residential emissions reduction embodied in the Work Plan include encouraging electrification of rooftop packaged HVAC units in commercial buildings, developing custom partnerships with major employers, and developing strategies to promote lower emissions commuting.

Rooftop Packaged HVAC (Work Plan Items 2.2A, 2.2B; Council Priority Objective CA 24): In September 2024 the City launched an update to the commercial heat pump HVAC pilot with the goal of collecting additional data to inform the design of an advanced pilot program. To achieve this goal, the City is offering enhanced incentives to a limited group of 10 customers. In return, these customers are required to gather and provide detailed cost and project information to the City. Businesses that prefer not to share this data can still participate in the program at the original incentive level.

Outreach efforts are ongoing through various channels to encourage participation. So far, 18 building owners have applied to join the program, with six permits issued and three projects successfully completed; three projects have withdrawn from the pilot.

On November 17, 2025, the City Council adopted the program design guidelines for the Advanced Packaged HVAC Pilot Program.31 To ensure the program is cost-effective, legally viable, and scalable, the guidelines prioritize providing financing rather than up-front incentives, without increasing tenant utility bills. To facilitate electrification of nonresidential packaged HVAC units, staff will explore streamlining the permit process, providing technical and permitting assistance to program participants, developing a courtesy contractor list, and providing support to contractors on program rules.

Major Employer Partnerships (Work Plan Item 2.2C): This work plan item focuses on building strategic partnerships with major employers to advance emissions reductions and support key facility projects across the community. At PAUSD, electrification efforts continue to advance meaningful decarbonization in school facilities. The ongoing heat pump retrofit project at El Carmelo Elementary School is replacing aging gas systems with high-efficiency electric equipment and is paired with domestic hot water system upgrades to further reduce fossil fuel reliance and improve site resiliency. Stanford Health Care and Stanford School of Medicine, which are within the City of Palo Alto and served by Palo Alto Utilities, also completed multiple high impact projects across the medical campus and surrounding facilities. Recent projects include extensive LED lighting upgrades at 900 Blake Wilbur, 875 Blake Wilbur, and multiple locations at Stanford Hospital, improving lighting quality while delivering substantial long-term electricity savings. Additional Stanford Health Care and Stanford School of Medicine campus 31 City Council, November 17, 2025; Agenda Item #4; SR #2508-5088; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83874&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
10 Packet Pg. 272 of 291

measures included chilled water system optimization, new building pumping controls, and chiller replacement each improving system efficiency, lowering operational energy use, and reducing lifecycle maintenance costs.

CPAU continues to support small and medium-sized businesses with energy efficiency, water conservation services, and electrification technical assistance through the Business Energy Advisor and Business Electrification Technical Assistance programs. In Q3 and Q4 of 2025, program staff visited over 100 small businesses in-person, conducted 56 onsite assessments, and provided energy efficiency project recommendations and project support, including access to rebates. While no projects were completed during Q3 and Q4, 14 projects are currently underway and are expected to be completed in the first half of 2026.

Altogether, in 2025, commercial efficiency and electrification projects delivered annual energy savings exceeding 1,600,000 kWh and 76,000 therms (60% of which is reduced through electrification projects) and resulted in the avoidance of 218 metric tons carbon dioxide equivalent per year. Projects that increased electricity use but transitioned away from gas still received incentives as long as there is a net reduction in energy use.

Commuter/Visitor Emissions Reduction (Work Plan Items 2.2D, 2.2E): Following the adoption of the E- Mobility Strategic Roadmap (formerly titled “Electric Vehicle Strategic Plan” - see Priority

2.5, below) in the fall of 2025,33 the City plans to proceed with this work item in 2026. Work on commuter/visitor emissions reduction will be coordinated with updated multi-family EV charging programs.

P2.3. Citywide Mobility: The goals for citywide mobility embodied in the Work Plan include both transportation-focused and land-use focused actions.

Transportation and Land Use Policies and Programs (Work Plan Item 2.3A; Council Priority Objectives IHS 40, IHS 53): The Safe Routes to School (SRTS) program carried out a successful bike rodeo season in fall 2025 and recruited a new Safe Routes to School planner to fill a vacancy. The City made significant progress on two plans that are expected to reduce greenhouse gas emissions while also implementing the Housing Element.34 In Q3 and Q4 2025, staff moved forward the San Antonio Road Area Plan, which will guide redevelopment of a portion of the Bayshore Alma San Antonio Priority Development Area. The San Antonio Road Area Plan envisions creating cohesive mixed-use neighborhoods with improved mobility and interconnectivity when compared with existing conditions. The resulting integrated transportation network in the plan area is anticipated to reduce greenhouse gas emissions and the use of single-occupancy motor vehicles. Q3 included community engagement on initial plan goals, including discussions with the Planning and Transportation Commission, Architecture 33 City Council, August 18, 2025; Agenda Item #6; SR #2507-4943; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83554&dbid=0&repo=PaloAlto 34 2023-2031 City of Palo Alto Housing Element; https://www.paloalto.gov/files/assets/public/v/1/planning-amp- development-services/housing-element/housing-element_2023_2031/palo-alto-housing-element.pdf Item B
Item B Staff Report

Item B: Staff Report
Pg.
11 Packet Pg. 273 of 291

Review Board, Pedestrian and Bicycle Advisory Committee, and City School Transportation Safety Committee. Feedback was also sought from the Community and Technical Advisory Groups. Q4 activities included a community workshop, online survey, and study session with City Council. Following the initial community feedback, the project team began developing transportation and land use alternatives to discuss with the public in 2026.

The Downtown Housing Plan, once adopted, will implement Housing Element programs by establishing policies, development standards, and a plan for the public infrastructure necessary to support increased housing in the area. The project advances the objectives of the S/CAP by analyzing components such as climate change and resilience, as well as land use, housing, and transportation by focusing on housing production near the downtown Palo Alto Caltrain station. In October 2025, staff presented the City Council with an update on the project, an Economic Feasibility and Implementation Analysis, an outreach summary, and preliminary policy recommendations based on the feasibility analysis, as well as a discussion of the implications of Senate Bill 79. Passage of SB 79 has introduced housing planning complexities, requiring the broader Downtown Housing Plan effort to be placed on hold pending further City Council guidance and direction.

Housing Element Adoption and Implementation (Work Plan Items 2.3C; Council Priority Objective IHS 44 and IHS 42): The City has made considerable progress in implementing the 110 program objectives in the 2023-2031 Housing Element. Implementation activities in Q3 and Q4 2025 include:
In the second half of 2025, the City used grant-funded technical analysis to consider housing options for a future affordable housing development on land to be dedicated to the City from the 2023 Sobrato/City Development Agreement. City Council reviewed findings from the analysis on November 17, 2025.37 Based on City Council feedback, a draft RFP will be prepared for future City Council consideration. The City Council provided informal feedback on Alta Housing’s project proposal during a study session on October 22, 2025.38 Alta Housing and the City jointly hosted a community meeting to gather further project input on December 1, 2025. The proposed fully affordable housing project would develop a surface parking lot within one-half mile of the downtown Palo Alto Caltrain station into a 72-unit community serving families.

Alta Housing intends to submit its formal planning application in January 2026. Staff made progress in 2025 towards implementing Program 6.5B of the Housing Element, which envisions creating zoning incentives or updating development standards to support various housing typologies, including micro-units, intergenerational housing, 37 City Council, November 17, 2025; Agenda Item #10; SR #2507-4927; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83868&dbid=0&repo=PaloAlto 38 City Council, October 22, 2025; Agenda Item #2; SR #2505-4745; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83672&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
12 Packet Pg. 274 of 291

aging adults, students, and lower-income units.41 Stakeholder outreach was completed in July 2025, and an analysis of opportunities and challenges was prepared in August 2025. The project team is currently refining the alternative approaches to be presented to the Architectural Review Board and the Planning and Transportation Commission in early 2026.

Last Mile Solutions (Work Plan Items 2.3D, 2.3E; Council Priority Objectives CA 15, CA 18): The Office of Transportation continues to conduct the Shared Micromobility Feasibility study to understand local demand for micromobility and to identify if a micromobility program would be financially sustainable for the City. The study is scheduled to be completed in early 2026, after which staff will report on the study’s findings. The City Council previously approved a one-year micromobility pilot program, but the program was not implemented at the time due to the COVID-19 pandemic and staffing limitations.42
Bicycling Improvements (Work Plan Items 2.3A, 2.3F, 2.3G; Council Priority Objectives CA 13, CA 15, CA 16, CA 17):

After staff incorporated input on draft recommendations for the 2026 Bicycle and Pedestrian Transportation Plan (BPTP) Update from the public, the Policy and Services Committee, and the Pedestrian and Bicycle Advisory Committee, the City Council reviewed the Draft Plan and near- term projects on December 1, 2025.43 City staff is now reviewing community and City Council feedback and preparing the Final 2026 BPTP Update document for presentation to the City Council in spring 2026.

The City will begin procurement for a transportation planning firm to finalize the South Palo Alto Bikeways Demonstration Project street design when a project manager has been recruited to fill a recent vacancy.

The South Palo Alto Bike/Ped Connectivity Project will identify locations and design concepts where new grade-separated bicycle and pedestrian pathways across the Caltrain corridor may be constructed in south Palo Alto (south of Oregon Expressway). Creating a path above or below the tracks will improve bicycle and pedestrian connectivity in support of the mobility and sustainability goals of the City. On December 1, 2025, the City Council reviewed eight shortlisted alternatives for the South Palo Alto Bike/Ped Connectivity Project and, based on recommendations from the Rail Committee and Staff, selected Alternative A (a crossing near El Dorado Avenue) as the preferred alternative, eliminating all other options from further 41 City of Palo Alto 2023-2031 Housing Element, 2024; https://www.paloalto.gov/files/assets/public/v/1/planning- amp-development-services/housing-element/housing-element_2023_2031/palo-alto-housing-element.pdf 42 City Council, March 2, 2020; Agenda Item #5; SR #11075; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=80712&dbid=0&repo=PaloAlto 43 City Council, December 1, 2025; Agenda Item #2; SR #2507-4967; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84114&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
13 Packet Pg. 275 of 291

consideration.47 Two variants of Alternative A were advanced: A1 (signalized crossing of Alma Street at El Dorado Avenue) and A2 (tunnel under both Alma Street and the Caltrain tracks).

The City Council passed a motion to focus evaluations on Alternatives A1 and A2, with a preference for A2. Staff will continue to focus evaluations on Alternatives A1 and A2, prioritizing Alternative A2 as directed by the City Council. Additional community engagement activities are planned for early 2026 to support the decision-making process and incorporate public feedback on the alternatives in the vicinity of El Dorado Avenue.

Transportation Demand Management (Work Plan Item 2.3H): In 2025, the Palo Alto Transportation Management Association (PATMA) conducted essential outreach to businesses on El Camino Real regarding available transit, bike, and parking programs to support businesses following the parking changes to the corridor as part of the Caltrans repaving project, as funded by a $25,000 Santa Clara Valley Transportation Authority (VTA) Transit Oriented Communities Grant. In coordination with other local sustainable transportation advocates, PATMA held summertime community bike rides along the new protected bike lanes of El Camino Real with turnouts of 8-20 cyclists per week. PATMA completed an e-bike and e-scooter pilot program for five participants with funding from the City. In the fall, PATMA administered a commute survey for 2025 and received 920 completed responses with findings helping to shape programs in 2026. In 2025, PATMA distributed 38 free transit passes to workers at businesses along El Camino Real and 104 to workers at the Stanford Mall encouraging sustainable commutes. By the end of 2025, 453 workers in Palo Alto were using train and/or bus passes from PATMA.

Work on the City’s Transportation Demand Management (TDM) Ordinance is on hold until staff capacity is available.

Parking (Work Plan Items 2.3I, 2.3J): The City and contractors continued installing Automated Parking Guidance Systems in downtown garages, which seek to limit the time that drivers spend circulating to find parking. Installation in the Civic Center Garage began in January 2025.

Community engagement regarding proposed enhancements to parking facilities will proceed in early 2026, following the start of a new parking permit management vendor contract.48 Traffic Signals (Work Plan Item 2.3K): The City continually monitors, maintains, and optimizes traffic signal operations, and addresses concerns from the community daily. As funding and staffing allow, the City also works on a variety of capital improvement program projects to update and upgrade the current traffic signal network and keep up with changing standards, modernization, and intelligent transportation systems (ITS) technologies. These improvements are a key component to optimizing operations to reduce delays and GHG emissions from idling. 47 City Council, December 1, 2025; Agenda Item #18; SR #2507-4950; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84110&dbid=0&repo=PaloAlto 48 City Council, December 15, 2025; Agenda Item #20; SR #2503-2330; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84136&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
14 Packet Pg. 276 of 291

In Q3 and Q4 of 2025, the City made substantial progress on several projects and has completed modifications at the intersection of Alma Road/Churchill Avenue. The City completed procurement and testing and started installation/construction of hardware upgrades for systems at four intersections along Quarry Road. Included with the traffic signal program, the City has made vehicular safety and visibility upgrades and procured accessible pedestrian system push buttons to be installed in 2026. These pedestrian crossing improvements are essential in encouraging walking and alternative modes of transportation.

The City also started the procurement process for updating the network communication switches for the city-wide traffic signal network.

Mobility Hub (Work Plan Item 2.3D; Council Priority Objectives CA 12, ED 31): The City is working with Stanford University to initiate the design phase of the Quarry Road Transit Connection project that would reduce travel time to access the Palo Alto Transit Center. A cost-sharing agreement between Stanford and the City has enabled project design kick-off. Grant funding from the Metropolitan Transportation Commission and coordination with Caltrans are being pursued next to complete project design of the extension of Quarry Road between El Camino Real and the Transit Center. Separately, VTA has convened the Palo Alto University Avenue Mobility Hub Ad Hoc Committee to explore short- and long-term active transportation and other improvements to the Palo Alto Transit Center to activate the space.

In Q2 staff submitted a funding application for $126,000 to the Bay Area Air District’s Charge! Program. If funded, the project could support the installation of EV charging infrastructure in the City-owned Midtown parking lot in advance of a potential future small-scale neighborhood mobility hub, if feasible. This site could support EV charging and future micromobility services for adjacent multi-family housing and commercial uses.

P2.4. Municipal Electrification: The City’s municipal electrification efforts include both facility and fleet electrification and are intended to show the community that the City will participate in the same electrification efforts it is encouraging the community to undertake.

Facility Electrification (Work Plan Items 2.4A, 2.4B, 2.4C; Council Priority Objective CA 20): The City has reviewed the Facility Electrification Assessment reports and supporting data to identify five facilities for the initial Facility Electrification pilot program. This pilot is intended to validate electrification delivery methods, evaluate logistical and construction challenges, and identify best practices for future facility conversions. Outcomes from the pilot will help refine project scoping, scheduling, and procurement strategies, strengthening the City’s long-term facility electrification planning.

The Facility Electrification pilot program was presented to the Climate Action and Sustainability Committee, at which time the following pilot facilities were identified: Golf Course Pro Item B
Item B Staff Report

Item B: Staff Report
Pg.
15 Packet Pg. 277 of 291

Shop/Restaurant, Ventura Community Center, Art Center, Downtown Library, and College Terrace Library.51
Fleet Electrification (Work Plan Items 2.4D, 2.4E): In Q3, the City replaced three internal combustion engine vehicles with four electric vehicles, consisting of one Ford E-Transit and three Chevrolet Silverado EVs. In Q4, two additional internal combustion engine vehicles were replaced with two Ford E-Transit EVs. As a result, the City fleet now includes 41 active electric vehicles, representing approximately 16% of passenger vehicles and light-duty trucks and vans.

Publicly Owned Charger Planning (Work Plan Item 2.4F): There is no change in the number of City-owned chargers or charger ports since the previous S/CAP Progress Report.52 The e- Mobility Strategic Roadmap, accepted by the City Council in August 2025,53 will guide future publicly owned charger planning.

P2.5. E-Mobility Strategic Plan (CA 18): The City Council accepted the e-Mobility Strategic Roadmap (formerly the EV Strategic Plan) in August 2025 following the CASC recommendation.54 The Roadmap will guide the promotion of e-mobility citywide and the integration of e-mobility into other City efforts, such as active transportation efforts. It was informed by the EV Charger Needs Assessment. A review of e-mobility electric grid impacts, EV charging benefits, mitigation strategies, and opportunities has been incorporated into the Reliability and Resiliency Strategic Plan (see Priority 1, Work Plan Items 1B/1C, above).55 P3. Build Awareness and Confidence
The focus of Priority 3 is to build community awareness and confidence in electrification through engagement, addressing concerns, and program results.

Building Awareness of the Need for and Benefits of Climate Action (Work Plan Item 3.1A): The City continues to publish a monthly Climate Action Blog and Quarterly Sustainability Newsletter. In Q3 and Q4 2025, the City published Climate Blogs in July, September, October, November, and December, and Sustainability Newsletters in August and October. Historically, the Sustainability Newsletters have an average 56% open rate, which is the percentage of readers that open the e-mail sent to them. The average open rate for government e- newsletters is 19.4%.56
51 Climate Action and Sustainability Committee, December 12, 2025; Agenda Item #1; SR #2511-5575; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84027&dbid=0&repo=PaloAlto 52 City Council, November 3, 2025; Agenda Item #A; SR #2505-4672; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83784&dbid=0&repo=PaloAlto 53 53 City Council, August 18, 2025; Agenda Item #6; SR #2507-4943; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83554&dbid=0&repo=PaloAlto 54 City Council, August 18, 2025; Agenda Item #6; SR #2507-4943; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83554&dbid=0&repo=PaloAlto 55 City Council, April 15, 2024; Agenda Item #4; SR #2401-2496; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82776&dbid=0&repo=PaloAlto 56 Campaign Monitor, 2022; https://www.campaignmonitor.com/resources/guides/email-marketing-benchmarks/ Item B
Item B Staff Report

Item B: Staff Report
Pg.
16 Packet Pg. 278 of 291

In Q3 and Q4 2025, the City held one Municipal Services Center Open House (968 attendees), one City Hall Open House, three electric vehicle and e-bike webinars (125 total attendees), five EV and e-bike expos (370 attendees), two gardening and landscape events (68 total attendees), one home electrification webinar (54 attendees), one commercial heat pump water heater webinar, one firescaping 101 webinar (7 attendees), one Scare Faire and Costume Swap, and one heat pump water heater Happy Hour. The City also participated in the Midtown Ice Cream Social (200 attendees) and the California Avenue Third Thursday “Sustainability Fair”.

The City co-sponsored Acterra’s Green@Home Tour on November 8, 2025, which engaged Bay Area residents in a unique opportunity to explore sustainable home electrification. There was a total of 539 attendees, with 55 registered attendees from Palo Alto, and 113 attendees visiting homes in Palo Alto.

In September, the Youth Climate Advisory Board (YCAB), comprised of 11 high school students attending schools in Palo Alto, convened for its second school year. In Q4, 2025, YCAB met monthly and appointed three leadership positions: Chair, Aiden Miao, Junior, Palo Alto High School; Vice Chair, Chanew Kim, Junior, Gunn High School; and Vice Chair Jenna Mu, Sophomore, The Kehillah School.

In December, the City held a public workshop with the Climate Action and Sustainability Committee.63 Participants discussed the insights from the S/CAP Funding Study, challenges it highlighted about community-wide electrification, and ideas being discussed around the region and among City staff to meet those challenges. There were 27 attendees (not including staff and Committee members), which included five students (high school and college) and a staff member from the Bay Area Air District. Staff and the Committee members heard a lot of great ideas about strategies for expanding electrification in Palo Alto that staff is eager to engage with in 2026, as well as positive feedback from attendees and Committee members who found the workshop engaging.

S/CAP Reporting and Surveys (Work Plan Items 3.1C, 3.1D): The City continues to calculate an annual GHG emissions inventory. Both the 2023 and 2024 GHG emissions inventories will be presented to the City Council in March, 2026.

P4. Additional Emissions Reductions
The focus of Priority 4 is to identify an additional 9% in emissions reduction opportunities to achieve 80 x 30, primarily through a focus on studying multi-family and commercial building equipment. The City is finalizing studies of the multi-family and commercial sectors in conjunction with the S/CAP Funding Study but is already making use of the insights delivered by the consultant in S/CAP strategic planning and program design. These studies include review of 63 Climate Action and Sustainability Committee, December 13, 2025; Special Meeting Agenda; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84040&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
17 Packet Pg. 279 of 291

publicly available data sources and on-site surveys of building equipment at multi-family and commercial buildings. CASC reviewed these studies in December 2025,65 and in January 2026 recommended that the City Council receive the studies. The studies will be provided to the City Council in March, 2026.

P5. Funding Needs and Sources (CA 22)
The focus of Priority 5 is to identify funding needed and potential funding sources for full scale implementation of the highest impact emissions reductions. The S/CAP Funding Study is being finalized as are its companion studies (an EV Charger Needs Assessment, Building Sector Study, and Funding Source Survey). All studies are being completed by the same group of consultants.

Staff and consultants presented preliminary results from the S/CAP Funding Study to the CASC in April 2025. The final draft studies were presented to the CASC in November 2025.66 The City Council will receive the reports in March, 2026.

Sustainability
Water: Further Water Conservation
Maximize Water Conservation and Efficiency (Work Plan Item 8.A): The City has offered an online water management tool, WaterSmart, to customers since 2022. The tool provides information on water consumption and personalized water conservation recommendations. As of December 2025, 36% of all single-family customers have accessed the portal – an increase from 33% as of June 2025. On a monthly basis, all single-family customers receive home water reports via email or regular mail if an email is not on file. The average open rate of home water report emails is 70%. Home water reports result in residential water savings of approximately

26.2 MG (3% savings) annually.

Design and build a salt removal facility for the Regional Water Quality Control Plant (Work Plan Item 8.B): The City Council approved the construction contract for the Local Advanced Water Purification System Project at the Regional Water Quality Control Plant (RWQCP) in May,67 and the Project began construction in June 2025. Once construction is complete, the Project will improve recycled water quality by blending reverse osmosis permeate to encourage expanded use of recycled water for non-potable uses such as irrigation. 65 Climate Action and Sustainability Committee, December 13, 2025; Agenda Item #A; SR #2511-5579; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84030&dbid=0&repo=PaloAlto 66 Climate Action and Sustainability Committee, November 20, 2025; Agenda Item #2; SR #2507-5028; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83907&dbid=0&repo=PaloAlto 67 City Council, May 19, 2025; Agenda Item #10; SR #2503-4327; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83405&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
18 Packet Pg. 280 of 291

Develop a “One Water” Portfolio for Palo Alto (Work Plan Item 8.C) and develop a tool for dynamic water planning in the future (Work Plan Item 8.D): The City has completed both of these items. Staff developed an Excel-based tool for water planning as part of One Water Plan Item B
Item B Staff Report

Item B: Staff Report
Pg.
19 Packet Pg. 281 of 291

development. The results of these efforts, including feedback from the Utilities Advisory Commission, were presented to CASC on September 19, 2025.71 The City Council received the One Water Plan as an information report on October 20, 2025.72 Climate Adaptation and Sea Level Rise: Prepare for Climate Change Foothills Fire Management Plan and Collaboration on Reducing Wildfire Hazards (Work Plan Items 8.K, 8.L, 8.M, 8.N; Council Priority Objective PS 58): The City Council accepted the final 2025 Community Wildfire Protection Plan on November 3, 2025. The Foothills Fire Management Plan is now encompassed within the Community Wildfire Protection Plan. Also on November 3, the City Council received the Wildfire Preparedness Audit, with recommendations across many departments that the City could enact to make improvements to this program.73 In the second half of 2025, the City began planning the fire mitigation work for calendar year 2026 in collaboration with Los Altos Hills County Fire District, the Woodside Fire Protection District, as well as the Santa Clara County Firesafe Council (SCCFSC) and the San Mateo County Fire Safe Council. Additionally, staff extended the City’s contractual relationship with the SCCFSC to enable them to perform directed fire management tasks prescribed by the Foothills Fire Management Plan. The SSCFSC sub-contracted the fuel reduction/fire mitigation of Arastradero and Los Trancos Roads in August 2025, and Page Mill Road in September 2025, which resulted in a very aggressive reduction of vegetative fuels to enhance the shaded fuel break of Page Mill Road. City staff accomplished fuel management activities in Foothills and Arastradero Nature Preserves treating 400 acres of fuel reductions. This effort was aided by a rented Green Climber robotic mower which treated 26 additional acres and improved their ability to reach more difficult terrain and reduced staff overhead. This was a successful test of a new tool that can augment fuel management performance, in conjunction with CEQA requirements.

Progress on the Foothills Fire Mitigation Project continues. The City has completed undergrounding 41,700 feet of power lines out of 49,200 feet. Cable installation and energization of 39,200 feet has been completed out of 49,200 feet. Overhead lines have been de-energized up to Foothills Nature Preserve with power running underground.

Develop a Sea Level Rise Adaptation Plan (Work Plan Item 8.F; Council Priority Objective 8): The City has been working on sea level rise adaptation efforts for several years as discussed in 71 Climate Action and Sustainability Committee, September 19, 2025; Agenda Item #1; SR #2509-5164; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83901&dbid=0&repo=PaloAlto 72 City Council, October 20, 2025; Agenda Item #A; SR #2509-5258; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83667&dbid=0&repo=PaloAlto 73 City Council, November 3, 2025; Agenda Item #2; SR #2510-5338; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83775&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
20 Packet Pg. 282 of 291

previous S/CAP Progress Reports.77 Accomplishments to date include completing the “San Francisquito Creek Downstream Project” to protect the adjacent area from three feet of sea level rise and a 100-year storm, a Sea Level Rise Vulnerability Assessment, online mapping tools that help City engineers and project planners design for future sea level rise conditions, elevated equipment and the inclusion of sea level rise in the Long Range Facility Plan Update for the Regional Water Quality Control Plant, construction commencement for the Palo Alto Horizontal Levee Pilot Project, and the development of K-5 sea level rise school curricula.

In 2023, SB 272 (Laird) initiated new statewide requirements for local sea level rise adaptation planning. The San Francisco Bay Conservation and Development Commission (BCDC) administers these requirements for local governments in the Bay Area via the Regional Shoreline Adaptation Plan (RSAP). On September 30, 2025, Santa Clara County Office of Sustainability was awarded a $2.6 million Ocean Protection Council grant to develop a multi- jurisdictional “subregional” sea level rise vulnerability assessment and adaptation plan for RSAP project partners which include Palo Alto, Mountain View, Sunnyvale, San Jose, Milpitas and Santa Clara. This team will work closely with Valley Water and Valley Transportation Authority.

The project will submit a subregional vulnerability assessment to BCDC in summer 2027 and a subregional shoreline adaptation plan in 2029. The City submitted a letter of commitment to participate in this effort in summer 2025. The grant partnership will complement Palo Alto’s sea level rise planning work to date in addition to providing a project funding strategy and cost of inaction, a CEQA determination, a list of potential projects, and ensuring that social equity considerations have been properly vetted.

Begin Design Process for Levee Projects (Work Plan Item 8.G): Construction of the Palo Alto Horizontal Levee Pilot Project (PAHLPP) began in September 2025 and is set to finish in summer 2026. Horizontal levees are nature-based sea level rise adaptations with multiple benefits over traditional flood-control levees such as habitat enhancement, sea level rise adaptation, and additional wastewater treatment. The PAHLPP will be the first horizontal levee to be built in the Bay Area to be both irrigated with treated wastewater and hydrologically connected to San Francisco Bay. The project will provide much-needed data to inform the design of future horizontal levees around the greater San Francisco Bay Area. The City has also developed three interpretive signs, including one in partnership with the Association of Ramaytush Ohlone.

Identify Protection Strategies from Significant Flood Events at Newell Road Bridge (Work Plan Item 8.H; Council Priority Objective CA 2): The Newell Road Bridge Replacement Project pre- construction activities began in summer 2025, with construction taking 1.5 years to complete.

Identify Protection Strategies from Significant Flood Events (Work Plan Item 8.I, 8.J; Council Priority Objective CA 3, CA 11): There are no updates to this work plan item since the previous 77 All previous S/CAP reports are available on the City website: https://www.paloalto.gov/City- Hall/Sustainability/Emissions-Reduction-Goals-and-Progress/Sustainability-Actions-and-Accomplishments Item B
Item B Staff Report

Item B: Staff Report
Pg.
21 Packet Pg. 283 of 291

S/CAP Progress Report.79 The San Francisquito Creek Joint Powers Authority (SFCJPA) is the project lead. The City will continue to provide assistance through review and City Councilmember participation in SFCJPA Board discussions.

Hamilton Avenue Storm Drain Capacity Upgrades (CA 16): While the S/CAP work plan focuses on Pope Chaucer Bridge and San Francisquito Creek through the partnership with SFCJPA, a storm drain improvement project that also serves to mitigate Creek flooding is underway at Hamilton Avenue. The City awarded the construction contract for Hamilton Avenue Storm Drain Capacity Upgrades in fall 2025.80 Construction began in December 2025 and is expected to be completed within approximately one year.

Natural Environment: Enhance Biodiversity
Increase Palo Alto’s Tree Canopy and Ensure No Net Tree Canopy Loss (Work Plan Items 8.O,

8.P): The City will publish the new Tree and Landscape Technical Manual in early 2026. The manual is a companion document to the Tree Protection Ordinance and will provide guidance to residents, property owners, and industry professionals on both required and recommended practices regarding trees and landscaping.81 The primary focus is on preserving and growing urban canopy during development. Included in the new manual are an updated Model Water Efficient Landscape Ordinance process, revised tree replacement calculations that account for canopy size of the replacement tree(s), and updated in-lieu fees for when trees can not be planted on site.

Coordinate Implementation of City Natural Environment-Related Plans (Work Plan Item 8.R):

S/CAP has the goal of restoring and enhancing resilience and biodiversity of our natural environment throughout the City. Coordinating implementation and updates of City plans allows for achieving multiple benefits. A recent example of this coordination is the participation of multiple City departments in work on the San Antonio Road Area Plan, including contributions to the Existing Conditions Assessment presented to the City Council in October.82 The e-Mobility Strategic Roadmap is also an exemplar of coordination between programs and departments involved in implementing the S/CAP.

Support the Green Stormwater Infrastructure (GSI) Plan and incorporate GSI in Municipal Projects (Work Plan Item 8.S): Staff will request that City Council approve a contract in early 79 City Council, November 3, 2025; Agenda Item #A; SR #2505-4672; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83784&dbid=0&repo=PaloAlto 80 City Council, October 6, 2025; Agenda Item #5, SR #2507-5009; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83624&dbid=0&repo=PaloAlto 81 Palo Alto Municipal Code Title 8; https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0- 65799
82 City Council, October 6, 2025; Agenda Item #3; SR #2509-5194; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83631&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
22 Packet Pg. 284 of 291

2026 to develop the design for a proposed GSI project in a City park. Completion of the design is expected in summer 2027.

Zero Waste: Support Waste Reduction
Encourage Commercial Food Waste Prevention and Provide Technical Assistance (Work Plan Items 8.T, 8.W): There are no updates on this work item since the previous S/CAP Progress Report.87
Promote Residential Food Waste Reduction (Work Plan Item 8.U): There are no updates to this item since the previous S/CAP Progress Report. The technical assistance, outreach, assessments of compliance with Senate Bill 1383 – the State’s Short-Lived Climate Pollutant legislation – and inspections are on-going.

Champion Waste Prevention, Reduction, Reusables, and the Sharing Economy (Work Plan Item

8.V): There are no updates to this item since the previous S/CAP Progress Report. As of June 2025, the open rate for the Zero Waste Minute weekly e-newsletter averaged 52 to 54%.

Prioritize Domestic Processing of Recyclable Materials (Work Plan Item 8.X): There are no updates to this item since the previous S/CAP Progress Report. Domestic processing for mixed paper and mixed rigid plastics began in April 2022. The City continues to review processing efforts.

Eliminate Single-Use Disposable Containers (Work Plan Item 8.Y): The City is reviewing the strategy and timeline for expanding the Disposable Foodware Ordinance and preparing to evaluate the compliance of food services establishments with existing requirements.

Expand the Deconstruction and Construction Materials Management Ordinance (Work Plan Item 8.Z): There are no updates to this item since the previous S/CAP Progress Report. The City continues to conduct outreach and educate homeowners, general contractors, and architects on the deconstruction ordinance requirements when building permit applications are submitted and when permits are issued. Number of projects and percentages of recovered, recycled, and landfilled materials are measured each fiscal year and reported in calendar year Q1-2 S/CAP Progress Reports.

FISCAL/RESOURCE IMPACT
Current and future initiatives will be managed and funded across various departments and funds. No new funding is needed, and the implementation of this 2023-2025 S/CAP Work Plan is subject to the standard budget appropriation process. 87 City Council, November 3, 2025; Agenda Item #A; SR #2505-4672; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83784&dbid=0&repo=PaloAlto Item B
Item B Staff Report

Item B: Staff Report
Pg.
23 Packet Pg. 285 of 291

Some items in other work plans are also relevant to the S/CAP Work Plan. The Utilities Strategic Plan, for example, includes workforce development and advanced metering infrastructure (AMI) work items that are directly relevant to S/CAP. Some of these may involve future budget requests as well.

STAKEHOLDER ENGAGEMENT
Stakeholder engagement on S/CAP implementation is wide-reaching and coordinated with multiple departments. Efforts include direct engagement, webinars, social media and other digital marketing/outreach, website updates, public signage, CASC meeting participation, leveraging the City’s communication platforms, and more. Stakeholder engagement efforts were described in the Analysis section, under P3. Build Awareness and Confidence as well as other Work Plan areas.

ENVIRONMENTAL REVIEW
This report is for informational purposes only with no action required by the City Council and therefore it is not a project subject to review under the California Environmental Quality Act (CEQA).

ATTACHMENTS
None.

APPROVED BY:

Brad Eggleston, Director Public Works/City Engineer
Item B
Item B Staff Report

Item B: Staff Report
Pg.
24 Packet Pg. 286 of 291

City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Administrative Services
Meeting Date: March 9, 2026
Report #:2512-5665
TITLE
Semi-annual Reports of Contracts Awarded by the City Manager, Procurement Officer or Other Designated Employees for the period of July 1, 2025, through December 31, 2025; CEQA Status- Not a Project.

RECOMMENDATION
This is an informational report and no action is required.

EXECUTIVE SUMMARY
Palo Alto Municipal Code (PAMC) Section 2.30.710(a)1 requires the City Manager to provide a semi-annual report to Council consisting of contracts awarded by the City Manager, Procurement Officer or other designated employees for:

1. Goods contracts $85,000 through $250,000 per year (Attachment A), and

2. Professional and General Services $25,000 through $85,000 and Public Works Contracts $85,000 through $250,000 per year (Attachment B).

The contracts in Attachment A consist of fourteen (14) distinct awards for goods, and the contracts in Attachment B consist of forty-seven (47) distinct awards for a range of services.

These awards are a core element of the efficient and effective provision of services by the City to our community and reflect extensive coordination and prudent decision-making. The PAMC section that sets forth the authority designated by Council to the Procurement Officer to award and sign contracts is PAMC 2.30.2002 and to the City Manager to award and sign contracts is PAMC 2.30.2103.
1 Palo Alto Municipal Code 2.30.710 City Manager reports https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-62183 2 Palo Alto Municipal Code 2.30.200 Procurement officer contract award authority https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-61873 3 Palo Alto Municipal Code 2.30.210 City Manager contract award authority https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-61881 Item C
Item C Staff Report

Item C: Staff Report
Pg.
1 Packet Pg. 287 of 291

Summary of Contract Definitions Per PAMC Chapter 2.30. The contracts included in this report are defined as follows:

1.Public Works ( PAMC 2.30.100): Contracts for the construction, repair, or improvement of public buildings, utilities, streets, and parks.

2.Goods ( PAMC 2.30.110): Purchase orders for supplies, equipment, and technology. This includes blanket purchase orders with set expenditure limits and labor incidental to the purchase, such as installation.

3.General Services ( PAMC 2.30.120): Services not requiring specialized training, such as maintenance of public facilities, janitorial work, tree trimming, street sweeping and street sweeping.

4.Professional Services ( PAMC 2.30.130): Services requiring professional discretion and specialized certification or expertise, such as engineering, architectural, financial, or information technology consulting.

Legal services contracts entered into under the City Attorney’s authority are not subject to PAMC 2.30.710 and therefore are not required to be included in this report.

ENVIRONMENTAL REVIEW
This activity is not a project under California Environmental Quality Act (CEQA) as defined in CEQA Guidelines, section 15378, because it has no potential for resulting in either a direct or reasonably foreseeable indirect physical change in the environment.

ATTACHMENTS
Attachment A: Goods Contracts Awarded $85,000 through $250,000 per year Attachment B: Professional and General Services $25,000 through $85,000 per year and Public Works Contracts $85,000 through $250,000 per year.

APPROVED BY:

Lauren Lai, Administrative Services Director
Item C
Item C Staff Report

Item C: Staff Report
Pg.
2 Packet Pg. 288 of 291

ATTACHMENT A
Goods Contracts Awarded $85,000 through $250,000 per year July 1, 2025 through December 31,2025
Contract Awarded To Award Date Award Amount
Bidding Exemption
or Number of Bids
Sent/Received
*PAMC 2.30.360
Description
ANIXTER INC 8/27/2025 $229,528.47 3625/2 Assorted Electric Items CTOS CALIFORNIA LLC 11/12/2025 $247,547.94 2.30.360(j) 2018 Freightliner M2106 Aerial Tree Truck GOLDEN GATE SYSTEMS LLC 8/21/2025 $218,073.87 2.30.360 (j) HP EliteBook 6 G1i 14 AI -Laptops GOLDEN GATE SYSTEMS LLC 12/9/2025 $236,060.04 2.30.360(j) HP Computer Workstations HASA INC 7/17/2025 $118,000.35 250/1 Pool Chemicals YR3 MOTOROLA SOLUTIONS, INC. 8/13/2025 $117,162.30 2.30.360 (j) Motorola Mobile Interoperability Equipment MOUNTAIN VIEW GARDEN CENTER 7/25/2025 $109,125.00 2.30.360(d) Conc rete-Small Batches ONESOURCE SUPPLY SOLUTIONS LLC 11/12/2025 $145,672.81 3655/4 Assorted Electric Items ONESOURCE SUPPLY SOLUTIONS LLC 7/21/2025 $211,836.34 3572/2 Fault Indicators for Utilities SEL ENGINEERING SERVICES, INC 7/7/2025 $85,000.00 2.30.360(d) Schweitzer Engineer ing Laboratories Relays- Year 1 TEC OF CALIFORNIA INC 8 /5/2025 $233,875.00 2.30.360 (j) One new 2025 Isuzu NRR EV TEREX SERVICES 12/22/2025 $194,280.69 2.30.360(j) TSE Model DPT30B Trailer Puller/Tensioner WEST COAST ENERGY SYSTEMS LLC 8/6/2025 $143,011.78 2.30.360(j) Lodge Lift Station Generator ZOLL MEDICAL CORPORATION 9/24/2025 $156,572.51 2.30.360(j) Critical Care and EMS Equipment Contract Type Count Total Award Amount
Goods 14 $2,445,747.10
*PAMC 2.30.360
https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-61990