HomeMy WebLinkAbout2025-10-01 Utilities Advisory Commission Agenda PacketUTILITIES ADVISORY COMMISSION
Regular Meeting
Wednesday, October 01, 2025
Council Chambers & Hybrid
6:00 PM
Amended Agenda
Amended agenda items appear below in RED
Utilities Advisory Commission meetings will be held as “hybrid” meetings with the option to
attend by teleconference/video conference or in person. To maximize public safety while still
maintaining transparency and public access, members of the public can choose to participate
from home or attend in person. Information on how the public may observe and participate in
the meeting is located at the end of the agenda. Masks are strongly encouraged if attending in
person. The meeting will be broadcast on Cable TV Channel 26, live on
YouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen Media
Center https://midpenmedia.org.
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Meeting ID: 966 9129 7246 Phone: 1(669)900-6833
PUBLIC COMMENTS
Public comments will be accepted both in person and via Zoom for up to three minutes or an
amount of time determined by the Chair. All requests to speak will be taken until 5 minutes
after the staff’s presentation. Written public comments can be submitted in advance to
UAC@PaloAlto.gov and will be provided to the Council and available for inspection on the City’s
website. Please clearly indicate which agenda item you are referencing in your subject line.
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by email to UAC@PaloAlto.gov at least 24 hours prior to the meeting. Once received, the Clerk
will have them shared at public comment for the specified item. To uphold strong cybersecurity
management practices, USB’s or other physical electronic storage devices are not accepted.
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of other attendees, or otherwise disturb the business of the meeting.
TIME ESTIMATES
Listed times are estimates only and are subject to change at any time, including while the
meeting is in progress. The Commission reserves the right to use more or less time on any item,
to change the order of items and/or to continue items to another meeting. Particular items may
be heard before or after the time estimated on the agenda. This may occur in order to best
manage the time at a meeting to adapt to the participation of the public, or for any other
reason intended to facilitate the meeting.
1 Regular Meeting October 01, 2025
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
CALL TO ORDER 6:00 PM – 6:05 PM
AGENDA CHANGES, ADDITIONS AND DELETIONS 6:05 PM – 6:10 PM
The Chair or Board majority may modify the agenda order to improve meeting management.
PUBLIC COMMENT 6:10 PM – 6:25 PM
Members of the public may speak to any item NOT on the agenda.
APPROVAL OF MINUTES
UTILITIES DIRECTOR REPORT 6:25 PM – 6:40 PM
NEW BUSINESS
1.Information Report: Utilities Quarterly Report for FY 2025-Q3/Q4 Discussion: 6:40 PM –
7:10 PM
2.Discussion of Preliminary Analysis of the Infrastructure Impacts Associated with Gas
Decommissioning Discussion: 7:10 PM – 7:25 PM
3.Discussion of Implementation Plan for Voluntary Residential Electric Service Time-of-Use
Rates Discussion: 7:25 PM – 8:10 PM
4.Reaffirmation of the Carbon Neutral Plan and the Renewable Energy Credit Exchange
Program; CEQA Status: Not a project Late Packet Item, Presentation
COMMISSIONER COMMENTS AND REPORTS FROM MEETINGS/EVENTS
ADJOURNMENT
SUPPLEMENTAL INFORMATION
The materials below are provided for informational purposes, not for action or discussion during UAC Meetings (Govt. Code
Section 54954.2(a)(3)).
INFORMATIONAL REPORTS
12-Month Rolling Calendar
Public Letter(s) to the UAC
2 Regular Meeting October 01, 2025
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
PUBLIC COMMENT INSTRUCTIONS
Members of the Public may provide public comments to teleconference meetings via email,
teleconference, or by phone.
1.Written public comments may be submitted by email to UAC@PaloAlto.gov.
2.Spoken public comments using a computer will be accepted through the teleconference
meeting. To address the Council, click on the link below to access a Zoom-based meeting.
Please read the following instructions carefully.
◦You may download the Zoom client or connect to the meeting in- browser. If using
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◦When called, please limit your remarks to the time limit allotted. A timer will be
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below. Please follow the instructions B-E above.
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You will be advised how long you have to speak. When called please limit your remarks to
the agenda item and time limit allotted.
CLICK HERE TO JOIN Meeting ID: 966 9129 7246 Phone:1-669-900-6833
Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public
programs, services and meetings in a manner that is readily accessible to all. Persons with
disabilities who require materials in an appropriate alternative format or who require auxiliary
aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at
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service.
3 Regular Meeting October 01, 2025
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
Staff Report: 2501-4079 – Page 1 of 45
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: October 1, 2025
Staff Report: 2501-4079
TITLE
Utilities Quarterly Report for FY 2025-Q3/Q4
RECOMMENDATION
This is a discussion item of Utilities quarterly report for Q3 and Q4 of Fiscal Year 2025. No action is requested.
EXECUTIVE SUMMARY
This report has been prepared to keep the Utilities Advisory Commission (UAC) apprised of the major issues that are facing
the water, gas, electric, wastewater collection and fiber utilities including legislative/regulatory issues, utility-related
capital improvement programs, operations, reliability impact measures and a utility financial summary. This updated
report does not include information about energy efficiency and water conservation programs; that information is
provided in an annual Demand Side Management Report attached to the Q2 Utilities Quarterly Report. The UAC will be
provided with copies of a separate quarterly climate report containing information about greenhouse gas reduction
programs such as electric vehicle charger installations and heat pump water heater replacements. Items of special interest
in this report are summarized below:
Vacancies and Staffing – Appendix B
The Utilities Department has 43 vacant positions out of 269 authorized positions or a 16% vacancy rate at the end
of FY 2025 compared to 48 vacancies or 18% vacancy rate in December 2024.
Six of the 43 vacant positions are currently on hold. Three of the positions were added in FY 2024 to support fiber-
to-the-premises (FTTP). These FTTP positions are on hold depending on the outcome of the FTTP pilot. The other
three positions are meter readers which are being held due to the rollout of advanced meters.
Electric Utility:
Supply cost for FY 2025 was $76.2 million, a 2% decrease compared to budget primarily driven by increased
revenue from renewable energy credit and resource adequacy sales. (Section 1.1.1)
Staff will recommend Council approval of a standalone battery energy storage system (BESS) and is pursuing some
additional solar energy resources. (Section 1.1.3)
Palo Alto’s reliability compares favorably to that of Pacific Gas & Electric Company (Section 1.3)
Electric sales volumes in FY 2025 were 12.4% higher than forecasted, mainly driven by new data center load.
(Section 1.4.1)
Gas Utility:
Gas prices have been relatively low and stable. (Section 2.1)
Two gas main replacement projects and a repair are underway. (Section 2.2)
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Gas sales in FY 2025 were 13% lower than forecasted due to a late start to the heating season. (Section 2.4.1)
Water Utility:
As of August 1, Regional Water System storage was 93% of maximum. (Section 3.1)
Water sales for FY 2025 were close to the forecast. (Section 3.4.1)
Wastewater Utility:
Actual wastewater sales revenues for FY 2025 tracked closely with the budget. (Section 4.3.1)
Fiber Utility:
Dark fiber sales in FY 2025 were $3.7 million or 8% higher than forecasted due to a large one-time connection fee.
(Section 5.4.1)
The permit for the fiber hut has been approved. Construction of the foundation at Colorado power station will
begin in September 2025. The fiber hut is anticipated to be delivered by end of 2025. (Section 5.1)
Legislative and Regulatory:
Changes to the state’s Cap & Trade Program beyond 2030 are expected. (Section 7.1)
Legislative:
o AB 825 (Petrie-Norris) was amended to replace SB 540 as the vehicle for Pathways legislation to establish
a regional day-ahead electricity market and change the language to be more favorable for a successful
market. The Governor signed AB 825 into law on September 19th.
o AB 1207 (Irwin)1 – This amended Cap-and-Trade bill was signed into law on September 19th. The bill
extends the Cap-and-Trade program until 2045 and explicitly states that there should be no impact on
how POUs utilize existing allowances. This legislation would also shift some allowances from gas
corporations to electrical distribution utilities, but those additional allowances would have to be
distributed to ratepayers as a credit. The legislative language is silent on whether the California Air
Resources Board (CARB) can change allowance allocations distributed to utilities in the future, but major
changes would have to be brought back to the legislature.
o SB 2542 (Becker) – This bill was signed into law on September 19th. SB 254 would, among other things,
reduce the frequency of wildfire mitigation plan reporting requirements to once every four years.
Cap & Trade Revenues:
An update regarding the proceeds from the sale of allocated allowance to the Electric and Gas Utilities is provided.
(Appendix D)
Infrastructure Reports:
The Electric and Water Utilities Annual Infrastructure Maintenance and Replacement Reports are provided
(Appendixes E and F)
1 AB 1207 (Irwin) https://url.usb.m.mimecastprotect.com/s/8NJSCJEnZ6C8Oo00sziJtyHlzZ?domain=leginfo.legislature.ca.gov
2 SB 254 (Becker) https://url.usb.m.mimecastprotect.com/s/ql_kCKAoOrcqKk33sAs7t52caG?domain=legiscan.com
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OVERVIEW
Utilities Quarterly Report
Fiscal Year 2023
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1 ELECTRIC UTILITY.....................................................................................................................................................................6
1.1 ELECTRICITY SUPPLY AND TRANSMISSION ...........................................................................................................................................6
1.1.1 Forecasted Supply Costs...................................................................................................................................................6
1.1.2 Hydroelectric Conditions ..................................................................................................................................................7
1.1.3 Renewable Energy Procurement ......................................................................................................................................7
1.2 CAPITAL IMPROVEMENT PLAN STATUS ...............................................................................................................................................7
1.3 RELIABILITY ..................................................................................................................................................................................8
1.4 FINANCIAL HEALTH ......................................................................................................................................................................10
1.4.1 Sales Forecasts vs. Actuals .............................................................................................................................................10
1.4.2 Financial Position ...........................................................................................................................................................11
2.1 GAS SUPPLY AND TRANSMISSION ....................................................................................................................................................12
2.1.1 Actual and Forecasted Supply Costs ..............................................................................................................................13
2.2 CAPITAL IMPROVEMENT PLAN STATUS .............................................................................................................................................13
2.3 RELIABILITY ................................................................................................................................................................................13
2.4 FINANCIAL HEALTH ......................................................................................................................................................................14
2.4.1 Sales Forecasts vs. Actuals .............................................................................................................................................14
2.4.2 Financial Position ...........................................................................................................................................................15
3.1 WATER SUPPLY AND TRANSMISSION ...............................................................................................................................................16
3.2 CAPITAL IMPROVEMENT PLAN STATUS .............................................................................................................................................17
3.3 RELIABILITY ................................................................................................................................................................................17
3.4 FINANCIAL HEALTH ......................................................................................................................................................................17
3.4.1 Sales Forecasts vs. Actuals .............................................................................................................................................18
3.4.2 Financial Position ...........................................................................................................................................................19
4.1 WASTEWATER TREATMENT UPDATES AND CAPITAL PLANNING STATUS ..................................................................................................20
4.1.1 Treatment Cost Trends...................................................................................................................................................20
4.1.2 Regional Water Quality Control Plant Capital Planning Status .....................................................................................22
4.2 COLLECTION SYSTEM CAPITAL IMPROVEMENT PLAN STATUS ................................................................................................................23
4.3 FINANCIAL HEALTH ......................................................................................................................................................................24
4.3.1 Sales Forecasts vs. Actuals .............................................................................................................................................24
4.3.2 Financial Position ...........................................................................................................................................................24
5.1 FIBER UTILITY STRATEGIC PLANNING ...............................................................................................................................................26
5.2 CAPITAL IMPROVEMENT PLAN STATUS .............................................................................................................................................26
5.3 RELIABILITY ................................................................................................................................................................................26
5.4 FINANCIAL HEALTH ......................................................................................................................................................................26
5.4.1 Fiber Sales ......................................................................................................................................................................27
5.4.2 Financial Position ...........................................................................................................................................................27
7.1 STATE LEGISLATIVE ACTIVITY ..........................................................................................................................................................30
7.2 STATE REGULATORY ACTIVITY ........................................................................................................................................................30
7.3 FEDERAL ACTIVITY .......................................................................................................................................................................31
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8 APPENDIX A: ENERGY RISK MANAGEMENT PROGRAM ..........................................................................................................33
8.1 OVERVIEW OF HEDGING PROGRAMS ...............................................................................................................................................33
8.2 OVERVIEW OF ENERGY RISK MANAGEMENT PROGRAM.......................................................................................................................33
8.3 FORWARD DEALS.........................................................................................................................................................................33
8.4 ELECTRIC MARKET EXPOSURE ........................................................................................................................................................34
8.5 TRANSACTION COMPLIANCE ..........................................................................................................................................................34
10 APPENDIX C: STAFFING AND VACANCIES ...........................................................................................................................37
12 APPENDIX E: ELECTRIC UTILITY ANNUAL INFRASTRUCTURE MAINTENANCE AND REPLACEMENT REPORT .........................39
13 APPENDIX F: WATER UTILITY ANNUAL INFRASTRUCTURE MAINTENANCE AND REPLACEMENT REPORT ............................42
Figures
FIGURE 1: FY 2025 FINANCIAL PLAN SUPPLY COST FORECAST VS. ACTUALS ..............................................................................................................6
FIGURE 2: HYDRO GENERATION: FY 2025-2027 ACTUALS & PROJECTIONS (GWH)...................................................................................................7
FIGURE 3: ELECTRIC OUTAGE RELIABILITY, FY 2019 THROUGH Q4 OF FY 2025.........................................................................................................9
FIGURE 4: ELECTRIC SALES VOLUME (KWH), FY 2025.........................................................................................................................................10
FIGURE 5: ELECTRIC SALES REVENUE ($), FY 2025.............................................................................................................................................10
FIGURE 6: PALO ALTO GAS COMMODITY RATES .................................................................................................................................................12
FIGURE 7: GAS SUPPLY COSTS ($), ACTUAL VS BUDGET, FY2025..........................................................................................................................13
FIGURE 8: GAS SERVICE INTERRUPTIONS, FY 2024 TO FY 2025............................................................................................................................14
FIGURE 9: GAS SALES VOLUME (THERMS), FY2025............................................................................................................................................14
FIGURE 10: GAS SALES REVENUE ($), FY 2025..................................................................................................................................................15
FIGURE 11: REGIONAL WATER SYSTEM STORAGE ...............................................................................................................................................16
FIGURE 12: SFPUC WATER DELIVERIES ............................................................................................................................................................17
FIGURE 13: WATER SERVICE INTERRUPTIONS, FY 2024 TO FY 2025.....................................................................................................................17
FIGURE 14: WATER SALES VOLUME (CCF), FY 2025..........................................................................................................................................18
FIGURE 15: WATER SALES REVENUE ($), FY 2025.............................................................................................................................................18
FIGURE 16: PALO ALTO’S SHARE OF ESTIMATED WASTEWATER TREATMENT EXPENSES (PROJECTION AND PLANNED CIP)................................................21
FIGURE 17: CURRENT RWQCP CAPITAL WORK IN-PROGRESS (BASED ON AUGUST 2025 PARTNERS MEETING).............................................................22
FIGURE 18: WASTEWATER SALES REVENUE ($), FY 2025....................................................................................................................................24
FIGURE 19: ELECTRIC LOAD RESOURCE BALANCE, FY 2026 – 2028.......................................................................................................................34
FIGURE 20: OFFSET PORTFOLIO COMPOSITION ...................................................................................................................................................35
FIGURE 21: OFFSET PROJECT DESCRIPTIONS ......................................................................................................................................................36
FIGURE 22: UTILITIES VACANCIES AND RECRUITMENTS BY DIVISION, AS OF YEAR-END FY 2025..................................................................................37
FIGURE 23: ELECTRIFICATION PERMITS BY CATEGORY ..........................................................................................................................................39
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1 Electric Utility
The City’s electric utility serves all residential and non-residential electric demands in Palo Alto at a lower cost than PG&E
in surrounding communities. Its electric supply portfolio is 100% carbon neutral. The City maintains and operates an
electric distribution system but does not operate any transmission lines or any generating capacity on its own. Instead,
the City belongs to Northern California Power Agency (NCPA) which operates its Calaveras hydroelectric generating plant
and provides power scheduling services for its other generating resources. This carbon free power is supplied through
power purchase agreements with various generation operators.
1.1 Electricity Supply and Transmission
Below is an update on electricity supply and transmission services.
1.1.1 Forecasted Supply Costs
The electric net supply cost for FY 2025 was $76.2 M, which represents a 2% decrease from the Adopted Budget level of
$77.0 M. The most significant change to the net supply cost was an increase in revenue from renewable energy credit
(REC) and resource adequacy (RA) sales, but these were partially offset by a decrease in surplus energy revenue.
Additionally, RA and market purchases cost less than expected. For FY 2026, electric net supply cost is projected to
increase to $99.2 M, driven primarily by an increase in Western Restoration Fund costs, transmission costs, and RA
purchase costs. During Q4 of FY 2025, net supply cost was about $1.5 M lower than the adopted budget.
Figure 1: FY 2025 Financial Plan Supply Cost Forecast vs. Actuals
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1.1.2 Hydroelectric Conditions
The City receives power from two hydroelectric projects, the Calaveras project and the Western Base Resource contract
for federal hydropower from the Central Valley Project.5 The watershed for Western hydropower is primarily in the
northern end of California, while the watershed for the Calaveras project is in the Central Sierras.
Following the wet water year of 2023-2024, reservoir levels across the state began this water year at above average levels.
As we approach the end of water year 2024-2025, precipitation levels have been near average levels. As of July 31,
precipitation in northern California is about 5% above average for this time of year, while central California is 33% below
average. As a result of these conditions, hydro generation levels were roughly average for FY 2025 and are expected to be
slightly above average for the following two years, with total output of about 125% of the long-term average level for FY
2026 through FY 2027.
Figure 2: Hydro Generation: FY 2025-2027 Actuals & Projections (GWh)
1.1.3 Renewable Energy Procurement
As discussed at the July 2025 UAC meeting, staff actively participated in NCPA’s 2024 Request for Proposals (RFP) for new
renewable energy and storage projects6, ultimately recommending a contract for a 50 MW share of the Trolley battery
energy storage system (BESS). After negotiations for a solar-plus-storage project fell apart near the finish line, staff has
begun discussions with another municipal utility about acquiring a portion of their solar portfolio that they no longer need.
Staff will continue to actively pursue these discussions, as well as participate in NCPA’s 2026 RFP for renewable energy
and storage resources and will report back to the UAC as new developments arise.
1.2 Capital Improvement Plan Status
The following capital projects are currently in progress or have been recently completed:
EL-17001 (East Meadow Circles 4/12kV Conversion)
This project is scheduled to be completed in several phases. Phase 1 is completed. Phase 2 engineering design is
completed. Phase 2 construction will be completed June 2026.
EL-10006 (Rebuild Underground 24)
This project is in the design phase and scheduled to be completed in December 2025. Construction will be
completed by December 2026.
EL-16000 (Rebuild Underground 26)
5 The Calaveras project is a hydropower project located in Calaveras County that is maintained and operated by the Northern California Power Agency
on behalf of the City and other project participants. The City is also one of several public entities with contracts with the Western Area Power
Administration for “Base Resource” electricity, which is the hydroelectric power available from the federal government’s Central Valley Project
(operated by the Bureau of Reclamation) after accounting for power used for Central Valley Project operations and power delivered to certain
“preference” customers.
6 NCPA’s RFP yielded a total of 29 proposals – nine for standalone solar projects, nine for standalone battery energy storage systems (BESS), and 11
for solar-plus-storage projects.
FY 2025 FY 2026 FY 2027
Calaveras Generation (GWh)98 117 158
Western Generation (GWh)384 351 314
Total Hydro Generation (GWh)482 469 472
% of Long-term Average Total 128%125%125%
Long-term Average Total Hydro (GWh)376 376 376
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The engineering design for this project is currently in progress. The project will be completed in multiple phases
and will take additional years to complete. All engineering design phases are expected to be completed by
February 2026. Construction will be completed by December 2026.
EL-19004 (Wood Pole Replacement)
CPAU staff and contract consultants are continuously working on pole replacement designs for construction.
In FY 2025, 66 poles were replaced. The replacement of poles will continue to be prioritized in the Grid
Modernization area.
EL-16003 (Substation Physical Security).
This project is scheduled to be completed in two phases. Substation Security lighting and camera contract was
awarded in June 2022. The installation for the first phase was completed for 7 of the 9 substations in
December 2024. The bid package for the 2nd phase and final two substations is being prepared for solicitation.
Construction is expected to be completed by December 2026.
EL-17002 (Substation 60kV Breaker Replacement)
This project funds the purchase and replacement of both 60kV and 12kV substation circuit breakers that are
reaching the end of their useful life expectancy. Council approved the purchase request for the sixteen 12KV
circuit breakers and eight 60kV breakers. The installation of the 12kV breakers is complete. The project to
purchase the eight 60KV breakers was approved by City Council on May 20, 2024. The engineering design and
installation of the 60kV breakers will begin in FY 2026 and is anticipated to be completed in conjunction with other
planned work at the Colorado Substation.
EL-21001 (Foothills Rebuild)
This project will underground approximately 9 miles of overhead line in Foothills Park, as necessary to lower the
risk of wildfires due to overhead electric lines. Staff has completed 39,200 feet of substructure work and de-
energized an equivalent amount of overhead electric lines. Substructure for Phase 1 was completed in Spring 2022
and the substructure for Phase 2 was completed in June 2023. Phase 3 construction is 100% complete with
substructures and cable installed and energized. Phase 4 construction has completed 12,000 feet of the planned
22,000 feet. Council recently approved of an easement that will allow construction of the remaining 10,000 feet.
Phase 5 substructure installation along Arastradero road is 100% completed with all substructure and cable
installed and energized. All work is expected to be complete before the end of fiscal year 2026
All substructure work remaining on Phase 4 and the installation of long-lead time, pad-mounted equipment is
planned for completion by the end of fiscal year 2026.
Utility Pole removal in Phases 1, 2, 3, and 5 is planned for completion by end of calendar year 2025. Utility pole
removal in phase 4 is planned for completion by the end of fiscal year 2026
The expanded scope to underground residential service drops is planned for completion by the end of fiscal year
2026
EL-02011 (Electric Utility Geographic Information System (GIS))
The project scope includes on-going maintenance/technical support of the existing GIS system and
implementation of the new GIS platform, ESRI.
EL-24000 (Grid Modernization)
The Pilot project was completed in April 2025. 66 poles have been replaced in the Grid Modernization Pilot area.
Additionally, 908 homes in the Pilot area are ready for electrification. Engineering design and material
procurement is in progress for the remainder of Phase 1. Target date for Engineering design is December 2025
and construction to follow (12-18 months).
1.3 Reliability
CPAU tracks electric power outages through industry recognized indices; System Average Interruption Duration Index
(SAIDI), System Average Interruption Frequency Index (SAIFI), and Customer Average Interruption Duration Index (CAIDI).
The chart below summarizes outage indices for Palo Alto. With this quarterly update, staff is presenting both outage
indices with and without the impacts of “major event days” (MED). For Palo Alto, a MED is defined as a 24-hour period
that impacts more than 10% of Palo Alto’s electric customers. By including and excluding MED, staff can review both the
impact of major events versus more typical day-to-day operations.
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Figure 3: Electric Outage Reliability, FY 2019 through Q4 of FY 2025
Major Event Days Included Major Event Days Excluded
FY SAIDI SAIFI CAIDI SAIDI SAIFI CAIDI
2019 114.7 0.935 122.7 44.4 0.330 134.6
2020 63.9 0.486 131.4 26.2 0.248 105.6
2021 70.6 0.720 98.1 14.7 0.053 279.9
2022 7.2 0.159 45.4 1.2 0.009 132.8
2023 148.9 1.378 108.0 26.1 0.164 159.6
2024 153.1 0.786 194.7 72.3 0.362 199.7
2025 95.4 0.779 122.5 44.5 0.283 157.4
CPAU reliability indices compared favorably to PG&E’s local performance, with Palo Alto’s electric system roughly five
times more reliable than PG&E’s. When compared nationally, Palo Alto’s reliability numbers for FY2025 fall within the
nation’s top quartile for best performing systems. See chart below for regional and national reliability indices. Continued
investment in preventative maintenance and asset replacement will help to maintain and improve overall system
reliability.
National Indices With MED National Indices Without MED
Calendar Year SAIDI SAIFI CAIDI SAIDI SAIFI CAIDI
PG&E 2024 DeAnza Div.471.1 2.020 233.2 211.3 1.580 133.7
National Five-Year Average
of Top Performing Utilities 83.3 0.842 87.7 82.9 0.632 73.8
Separating unplanned power outages by their
primary cause helps focus where reliability work is
needed. The pie chart to the right presents the
number of sustained unplanned outages by their
primary cause. For CPAU, most unplanned outages
are related to equipment (failure, damage or worn
out). The next two largest causes of power outages
are trees outages and outages where the cause could
not be determined (unknown). Equipment failures
continue to be the leading cause of outages,
indicating a need for ongoing planned equipment
replacements through funding of the City’s Capital
Improvement Program.
Bird, 1
Cause Unknown, 13
Construction, 2
Contact with
Foreign Object, 1
Electrical Failure,
14
Equipment
Damage, 10
Equipment Worn
Out, 5
Overloaded, 1
Squirrel, 4
Tree, 12
Vehicle Accident, 4
Fiscal Year 2025 Sustained Outages by Cause
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1.4 Financial Health
Below is a summary of the financial position for the electric utility.
1.4.1 Sales Forecasts vs. Actuals
Actual electric sales volumes in FY 2025 were 12.4% higher than forecast, driven by increased usage from the top 10
business consumers, which increased about 10% compared to last year. Tesla’s load grew 55%, mainly due to new data
center expansion, making it the largest contributor to the overall increase. As a result, actual sales revenues exceeded the
FY 2025 Financial Plan by 9.7%.
Figure 4: Electric Sales Volume (kWh), FY 2025
Figure 5: Electric Sales Revenue ($), FY 2025
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1.4.2 Financial Position
The Electric Operations Reserves FY 2024 at $32.3 M, below the target of $44 M, but above the minimum guideline of
$30.7 M. In June 2024, Council approved the FY 2025 Electric Utility Financial Plan9 , that approved a residential system
average rate increase of 9% and a transfer of $17 M from the Electric Operations Reserve to the Hydroelectric Stabilization
reserve. This transfer was completed in FY 2024 and will enhance the utility's ability to manage supply cost volatility in the
future. Staff provided a financial forecast projection to the Council in June 2025 (Staff Report 2411-3776, Item 2210).
According to staff’s latest forecast, the operations reserve balance at the end of FY 2025 is projected to be $29 M, which
reflects approximately a $3 M reduction from the prior year and is below the minimum guideline range of $34 M.11
However, by the end of FY 2026 staff forecasts that the operations reserve with return to $51 M, which is close to the
target level of $55 M and that the reserve will remain within the guideline range throughout the forecast period.
9 Staff Report 2404-2842, Attachment D, Exhibit 2: https://www.cityofpaloalto.org/files/assets/public/v/2/agendas-minutes-reports/reports/city-
manager-reports-cmrs/attachments/2024-rates/electric-utility-financial-plan-fy25.pdf
10 Staff Report 2411-3776 https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=35104f06-6925-4fe3-89c7-b0e53e6eec42
11 Staff Report 2411-3776, Attachment D, Exhibit 1 FY 2026 Electric Utility Financial Forecast and CIP Detail
https://www.paloalto.gov/files/assets/public/v/2/agendas-minutes-reports/agendas-minutes/city-council-agendas-
minutes/2025/june-16/rates-attachments/finalized-attachment-d-exhibit-1-fy26-electric-utility-financial-forecast-and-
cip-detail.pdf
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2 Gas Utility
The City’s gas utility serves all residential and non-residential gas demand in Palo Alto. The City maintains and operates a
system of low-pressure gas lines for delivering gas but does not operate any transmission lines. Costs for the gas utility
are split approximately two thirds for the operation, maintenance, and capital improvement and one third for the cost of
the gas commodity, PG&E gas transmission, compliance with the State’s Cap and Trade Program and the City’s Carbon
Neutral Gas Program.
2.1 Gas Supply and Transmission
After experiencing a notable price spike during winter 2022-2023, natural gas prices have seen a significant decline,
returning to more typical ranges. This shift can be attributed to several factors, including milder temperatures and above
average gas storage levels nationwide. The combination of these factors has kept natural gas prices low, and we do not
expect an extreme price spike to occur in the near future. The chart below shows Palo Alto’s gas commodity rates from
July 2021 through June 2025.
Figure 6: Palo Alto Gas Commodity Rates
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2.1.1 Actual and Forecasted Supply Costs
Actual supply costs in FY 2025 were approximately 22% lower than budgeted in the FY 2025 Financial Plan. This variance
was primarily driven by low natural gas prices, which remained well below initial forecasts. In June 2025, actual costs
exceeded budget due to increased activity in the industrial segment. About half of the increase was due to higher
consumption, which normalized in July; the remainder resulted from a billing issue that charged one customer for two
months in a single cycle.
Figure 7: Gas Supply Costs ($), Actual vs Budget, FY2025
2.2 Capital Improvement Plan Status
The following capital projects are currently in progress:
GS-15000 – GMR 25 (Gas Main Replacement 25)
The GMR 25 project will replace approximately 26,000 linear feet of gas mains on Ross Road from Colorado Avenue
to East Meadow Drive and surrounding streets, as well as North and Southampton Drive and surrounding streets,
and Walter Hays Drive and surrounding streets. Construction on the project is anticipated to begin in early 2026
and finish in mid-2027. A $16.5 million reimbursable grant from the Pipeline and Hazardous Material Safety
Administration was awarded for this project.
GS-25001 – Gas Line Repair at Arastradero Creek
During the 2023 winter storms, portions of Arastradero Creek eroded away and exposed a gas pipeline crossing
Arastradero Creek. This project completed the data gathering phase and will begin the design and permitting phase
of the work. A permanent solution will be presented to the permitting agencies (Water Board, CDFW, USACE) in
August 2025 for input. Construction on this project is anticipated in mid-2026 through mid-2027. All work will take
place in the Pearson Arastradero Preserve.
GS-16000 – GMR 26 (Gas Main Replacement 26)
The GMR 26 project will replace approximately 26,000 linear feet of gas mains in the Midtown, Palo Verde, Fair
meadow, and Evergreen Park neighborhoods. The project is currently in design with construction anticipated in
mid-2027.
2.3 Reliability
The City of Palo Alto tracks all gas service interruptions. A summary chart of these interruptions can be found below. Gas
service interruptions are usually due to repairs of broken or damaged gas services and mains. This kind of damage is often
caused by excavation by outside parties digging in the City. In FY25 Q1 we recorded higher numbers in our gas service
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interruption tracking due to the division allocating more resources to resolve existing gas leaks. These leaks are small and
are monitored, however expected changes in gas legislation will require them to be resolved more quickly. The gas division
has been proactively working to meet upcoming compliance goals before the new rules go into effect.
Figure 8: Gas Service Interruptions, FY 2024 to FY 2025
FY 2024 FY 2025
Gas Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
2.4 Financial Health
2.4.1 Sales Forecasts vs. Actuals
Figure 9: Gas Sales Volume (Therms), FY2025
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Figure 10: Gas Sales Revenue ($), FY 2025
2.4.2 Financial Position
The FY 2024 ending Operations Reserve balance for the Gas Utility was $4.2 M, which is below the minimum guideline of
$9.1 M and below the short-term risk assessment value of $5.3 M. This was due to one-time expense items deferred from
FY 2023 to FY 2024, such as carbon offset purchases and Cap and Trade revenue transfers, together with the impact on
reserves from the unprecedented gas price spike in FY 2023. In June 2024, Council approved the FY 2025 Gas Utility
Financial Plan15 that included a 12.5% increase in gas rates in FY 2025 to gradually restore reserves to within guideline
levels and cover rising costs. Staff provided a financial forecast projection to the Council in June 2025 (Staff Report 2411-
3776, Item 2216). Based on staff’s latest forecast, the operations reserve balance at the end of FY 2025 is projected to be
$11.7 million, which is within the guideline range and reflects an increase from the prior year.17
15 Staff Report 2404-2842, Attachment C, Exhibit 1: https://www.cityofpaloalto.org/files/assets/public/v/2/agendas-minutes-reports/reports/city-
manager-reports-cmrs/attachments/2024-rates/gas-financial-plan-fy25.pdf
16 Staff Report 2411-3776 https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=35104f06-
6925-4fe3-89c7-b0e53e6eec42
17 Staff Report 2411-3776, Attachment C, Exhibit 1 FY 2026 Gas Utility Financial Forecast and CIP Detail
https://www.paloalto.gov/files/assets/public/v/2/agendas-minutes-reports/agendas-minutes/city-council-agendas-minutes/2025/june-16/rates-
attachments/finalized-attachment-c-exhibit-1-fy26-gas-utility-financial-forecast-and-cip-detail.pdf
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3 Water Utility
The Water Utility serves water to virtually all Palo Alto residential and non-residential customers. All potable water in the
City is from the San Francisco Public Utilities Commission (SFPUC) Hetch Hetchy Water System. This system delivers high
quality water from the Sierra Nevada and uses no pumping to deliver water to the City. Palo Alto uses a small amount of
recycled water for irrigation of the Municipal Golf Course and a few other sites near the Regional Water Quality Control
Plant. The City also maintains a system of reservoirs and wells that enable Palo Alto to serve water during an interruption
of the Hetch Hetchy system. Costs for the Water Utility are split approximately half for the operation, maintenance and
periodic replacement of Palo Alto’s water system and half for the costs of the water purchased.
3.1 Water Supply and Transmission
As of August 1, 2025, cumulative Hetch Hetchy Weather Station precipitation for Water Year (WY) 2025 was 87% of
median, and the Regional Water System total storage operated by the San Francisco Public Utilities Commission (SFPUC)
was at 93% of maximum storage and the Water Bank was full. In the figure below, the solid black line shows storage in
the Regional Water System for the past 12 months (color bands show contributions to total system storage) and the
dashed black line shows total system storage for the previous 12 months. Regional Water System Storage is 1,375
Thousand Acre Feet (TAF) as of August 1, 2025.
Figure 11: Regional Water System Storage
The figure below shows water usage for the South Bay/East Bay (including Palo Alto) compared to several benchmarks,
including 2015, 2023 and a five-year average. For the South Bay/East Bay region as well as systemwide, demand for 2025
has been similar to the average of the last five years and generally higher than the same months in 2023, which had
historically wet weather.
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Figure 12: SFPUC Water Deliveries
3.2 Capital Improvement Plan Status
The following capital projects are currently in progress:
WS-16001 – WMR 30 (Water Main Replacement 30)
The WMR 30 project is currently in the design phase and will replace approximately 4,000 linear feet of water main
on streets to be determined. The anticipated project construction start date is in December 2026.
3.3 Reliability
The City of Palo Alto tracks all water service interruptions. A summary chart of these interruptions can be found below.
Water service interruptions are usually due to repairs of broken or damaged water services and mains.
FY 2024 FY 2025WaterQ1Q2Q3Q4Q1Q2Q3 Q4
Number of Breaks 8 9 8 6 8 7 7 8
Combined Minutes 1086 880 1230 475 510 1250 795 146
Customers Affected 147 96 164 75 127 99 61 960
3.4 Financial Health
Below is a summary of the financial position for the water utility.
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3.4.1 Sales Forecasts vs. Actuals
Actual water sales volumes in FY 2025 were about 2.2% higher than forecasted, and actual water sales revenues were
about 1.5% higher than budgeted in the FY 2025 Financial Plan, which aligns with the anticipated recovery in water usage
following periods of drought.
Figure 14: Water Sales Volume (CCF), FY 2025
Figure 15: Water Sales Revenue ($), FY 2025
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3.4.2 Financial Position
At the end of FY 2024, the Water Operations Reserve balance was $7.1 million, which is below the minimum guideline
range of $8.4 million. Additionally, the rate stabilization reserve had $4 million remaining at the end of FY 2024. In June
2024, Council approved the FY 2025 Water Utility Financial Plan21, which approved a 9.5% rate increase in FY 2025 to pay
for rising costs and offset decreased sales revenues. Staff provided a financial forecast projection to the Council in June
2025 (Staff Report 2411-3776, Item 2222). According to staff’s latest forecast, the operations reserve balance at the end of
FY 2025 and FY 2026 is projected to decline further to $6.1 million and $5.6 million, respectively as the utility continues to
use reserves to pay for operating costs.23 During this time, the remaining $4 million from the Rate Stabilization Reserve
will also be used to pay for operating costs. As rates increase over time, by FY 2027, the operations reserve will begin to
restore and by the end of FY 2028 the operations reserve is projected to be $10.2 million, which is within the guideline
range.
21 Staff Report 2404-2842, Attachment B, Exhibit 1: https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-
manager-reports-cmrs/attachments/2024-rates/water-financial-plan-fy25.pdf
22 Staff Report 2411-3776
https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=35104f06-
6925-4fe3-89c7-b0e53e6eec42;
23 Staff Report 2411-3776, Attachment B, Exhibit 1 FY 2026 Water Utility Financial Forecast and CIP Detail
https://www.paloalto.gov/files/assets/public/v/2/agendas-minutes-reports/agendas-minutes/city-council-agendas-
minutes/2025/june-16/rates-attachments/finalized-attachment-b-exhibit-1-fy26-water-utility-financial-forecast-and-cip-
detail.pdf
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4 Wastewater Utility
The Wastewater Utility includes the system of sewer pipes that collect and transport wastewater to the Regional Water
Quality Control Plant (RWQCP) operated by the City of Palo Alto under a partnership agreement with several surrounding
communities, as well as Palo Alto’s share of the cost of operating the RWQCP. The RWQCP provides treatment and disposal
of wastewater for Palo Alto. Costs for the Wastewater Utility are split approximately half for the operation, maintenance
and periodic replacement of Palo Alto’s sewer collection system and half for the costs of wastewater treatment at the
RWQCP.
4.1 Wastewater Treatment Updates and Capital Planning Status
The RWQCP, operated by Palo Alto's Public Works Department, provides wastewater treatment to Palo Alto, Mountain
View, Stanford, Los Altos, East Palo Alto, and Los Altos Hills. The Palo Alto Wastewater Collection Utility contributes
approximately 37% of the costs (projected for FY 2025). Capital costs, driven by necessary upgrades to aging equipment
and changing environmental regulations, are a major factor in cost increases. With plant equipment over 50 years old,
significant rehabilitation and replacement are required to maintain safe, compliant wastewater treatment operations.
4.1.1 Treatment Cost Trends
RWQCP staff project a 5.5% average annual increase in treatment costs paid by Palo Alto’s Wastewater Utility from FY
2025 to FY 2035. The main drivers are capital projects, materials, and debt service (including loan repayments). Treatment
capital expenses, including debt service, are expected to rise by about 30% per year on average to fund equipment
replacement and major upgrades. Larger increases in capital expenses are anticipated starting in FY 2030 due to new debt
for major projects. The figure below outlines Palo Alto’s share of estimated treatment costs, with upcoming capital
projects and planned debt service payments shown in the "Planned Debt Service" bar.
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Figure 16: Palo Alto’s Share of Estimated Wastewater Treatment Expenses (Projection and Planned CIP)
The figure above shows annual CIP reinvestment including Existing Debt Service, and pay-as-you-go CIP expenses and also
shows treatment operations costs. While operations costs make up the bulk of treatment expenses, they are growing
more slowly than planned debt service. The largest increase in planned debt service in FY 2030 is primarily due to the debt
service repayments beginning on the Secondary Treatment Upgrades, which is a $193 million capital project to remove
nutrients from the wastewater (denitrification) in order to meet upcoming regulatory requirements. Nutrient removal is
important to reduce algae blooms that kill fish and other aquatic life. The Secondary Treatment Upgrades project will also
replace critical, aging mechanical and electrical equipment.
Not included in Figure 17 is the remaining unencumbered and authorized amount for the future pay-as-you-go capital.
This amount is estimated to be $3.5 million in FY 2025. The wastewater collection utility needs to hold this amount in
reserves until it is needed by the treatment plant.
In June 2024, the Council approved a Cost-Sharing Agreement with the Santa Clara Valley Water District for the Guiding
Principle 5 grant program, which funds future RWQCP27 projects. The program supports communities like Palo Alto, where
taxpayers pay State Water Project property taxes but rely on non-Valley Water supplies for most of their water. Staff
estimates a total of $11.2 million in grant funding for Palo Alto’s share of approved RWQCP projects, directly benefiting
local customers. Four upcoming projects are eligible for this funding:
Outfall Line Construction
Headworks Facility Replacement
12kV Electrical Power Distribution Loop Improvements
Joint Intercepting Sewer Rehabilitation
27 Staff Report 2404-2877, June 3, 2024 https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=82864
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4.1.2 Regional Water Quality Control Plant Capital Planning Status
The RWQCP continues to undergo significant capital improvements to address aging infrastructure, respond to evolving
regulations, and meet future capacity needs. These efforts are guided by the Long-Range Facilities Plan (LRFP), which was
originally adopted in 2012 and is now undergoing a comprehensive update, anticipated for completion in 2027. The
RWQCP’s current capital work in-progress includes an estimated $495.9 million in projects. The following table
summarizes these ongoing projects and provides their status and costs.
Figure 17: Current RWQCP Capital Work In-Progress (based on August 2025 Partners Meeting)
Project Status Planned Expense
(million $)
Primary Sedimentation Tanks
Rehabilitation and Equipment
Room Electrical Upgrade
Construction Complete $16.7
12kV Electrical Loop Upgrades Phase 1: Complete
Phase 2: In Construction
Phase 1: $6.7
Phase 2: $6.8
New and Rehabilitated Outfall
Pipeline
In Design (Paused at 90% Complete)$17.8
Secondary Treatment Upgrades In Construction $193
Local Advanced Water
Purification System
In Construction $59.9
Headworks Facility
Replacement
Advanced Planning $162
Joint Interceptor Sewer
Rehabilitation
In Construction $11.5
Horizontal Levee Pilot Project In Construction $2.8
New Laboratory and
Environmental Services
Building
In Design $18.7
Subtotal $495.9
One of the largest projects is the Headworks Facility Replacement, which will upgrade the raw sewage pumping systems
along with bar screens and grit removal equipment to improve reliability and protect downstream processes. The Local
Advanced Water Purification System (AWPS) Project, also under construction, aims to reduce salinity in recycled water,
enabling expanded non-potable use and supporting future additional reuse efforts. As part of a broader campus-wide
approach to meet future space needs, the RWQCP is evaluating the purchase of neighboring properties and, following
Council approval of a 20-year lease agreement in May 2025, has initiated design and construction of tenant improvements
at a leased facility located at 2470 Embarcadero Way to provide necessary laboratory and office space.
The RWQCP plans to fund these capital projects through a combination of mechanisms including pay-as-you-go, State
Revolving Fund loans, and revenue bonds. Several sources of funding will be used for the Local AWPS: Valley Water will
provide $16 million, Palo Alto was awarded a $12.9 million grant from the United States Bureau of Reclamation’s
WaterSMART program, which allocates Title XVI Program funding under the Water Infrastructure Improvements for the
Nation (WIIN) Act, and the remaining project costs will be funded through a State Revolving Fund loan along with
contributions from the City of Mountain View. The Horizontal Levee Pilot Project is expected to receive funding from the
Environmental Protection Agency, Department of Water Resources, Association of Bay Area Governments and the Coastal
Conservancy.
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4.2 Collection System Capital Improvement Plan Status
The following capital projects are currently in progress:
WC-15002 – Sewer Master Plan Study
The Master Plan Study will evaluate the City’s existing wastewater collection system, flows, and flow patterns to
determine the adequacy of the system’s hydraulic capacity to meet current and anticipated future wastewater flow
demands, and develop a recommended prioritized Sewer Main rehabilitation plan. The project kicked off in
December 2023. The project is in the process of wrapping up and is anticipated to be completed in September
2025.
WC-15002 and WC-13002 – Lodge/Foothills Lift Station Pump #1 Repair
The Lodge/Foothills Lift Station (LFHLS) experienced pump failure of Pump #1 and partial failure of Pump #2. Pump
#1 was removed, repaired, and reinstalled. Pump vendor costs for this repair were split between the above two
WC numbers. Pump #2 is scheduled for removal and repair in September.
WC-20000 - SSR 32 (Sanitary Sewer Replacement 32)
The SSR 32 project is currently in the design phase and will replace approximately 26,000 lineal feet of sewer mains,
laterals, and manholes including Middlefield Road and Webster Street between Seale and Oregon Ave; and various
street in Crescent Park, Old Palo Alto, Midtown, Palo Verde, Fair Meadows, Marron Park, and Green Acres
neighborhoods. Design is scheduled near the end of FY 2026 and continue through FY 2027 and construction is
anticipated in FY 2028.
WC-26001 – CCTV Sanitary Sewer Mainline Inspection
The City is in the process of developing an Invitation for Bid (IFB) for a three-year program to CCTV Sanitary Sewer
Mains. The project will CCTV approximately 225,000 lineal feet of Sanitary Sewer Main over a three-year duration
at an annual rate of approximately 75,000 lineal feet per year. Results of the project will be used to identified
defective Sanitary Sewer Mains which will be incorporated into future SSRs to rehabilitate and replace Sanitary
Sewer Mains. The project will go out to RFP late 2025 for an anticipated start date in May 2026.
WC-99013 – Sanitary Sewer Lateral Rehabilitation and Replacement
The City is in the process of developing an Invitation for Bid (IFB) for a three-year program to rehabilitate or replace
Sanitary Sewer Lower Laterals (Lower Laterals). City staff has identified approximately 210 Lower Laterals that will
be rehabilitated or replaced over a three-year period at an annual rate of approximately 70 per year. In addition to
addressing defective Lower Laterals, the project will reduce inflow and infiltration into the sanitary sewer system.
Staff anticipates issuing the IFB bid in the end of 2025.
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4.3 Financial Health
Below is a summary of the financial position for the wastewater utility.
4.3.1 Sales Forecasts vs. Actuals
Wastewater sales revenues through FY 2025 was 2.9% higher than forecasted, which is consistent with the FY 2025
Financial Plan.
Figure 18: Wastewater Sales Revenue ($), FY 2025
4.3.2 Financial Position
Treatment costs were higher than forecasted in FY 2023 and FY 2024. Additionally, Palo Alto began Sanitary Sewer
Replacement project 31 with an earlier start date in FY 2023 instead of FY 2024. This project was completed in FY 2024.
Completing this sewer replacement earlier than previously anticipated was necessary in order to coordinate with Caltrans
to limit or avoid digging into newly paved street on El Camino Real. In June 2024, Council approved the FY 2025
Wastewater Collection Financial Plan29 that included a 15% rate increase in FY 2025 and a short-term loan of $3 million
from the Fiber Optics Fund Reserve for FY 2024 to cover the cashflow needs of the Wastewater Collection Utility. Although
the Wastewater Collection Operations Reserve remained low at the end of FY 2024, the utility’s overall cash balance was
$0.34 million due to the $3 million short-term loan. The short-term loan is expected to be paid in FY 2026. Staff expects
revenues to cover rising costs in FY 2025 and begin to replenish the utility’s reserves. Staff provided a financial forecast
29 Staff Report 2404-2842 Attachment A, Exhibit 1, June 17, 2024 https://www.cityofpaloalto.org/files/assets/public/v/2/agendas-
minutes-reports/reports/city-manager-reports-cmrs/attachments/2024-rates/wastewater-financial-plan-fy25.pdf
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projection to the Council in June 2025 (Staff Report 2411-3776, Item 2231). According to staff’s latest forecast, the
operations reserve balance at the end of FY 2025 is projected to be $1 million, reflecting an increase from the prior year.32
31 Staff Report 2411-3776
https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=35104f06-
6925-4fe3-89c7-b0e53e6eec42;
32 Staff Report 2411-3776, Attachment A, Exhibit 1 FY 2026 Wastewater Collection Utility Financial Forecast and CIP Detail
https://www.paloalto.gov/files/assets/public/v/3/agendas-minutes-reports/agendas-minutes/city-council-agendas-
minutes/2025/june-16/rates-attachments/finalized-attachment-a-exhibit-1-fy26-wastewater-collection-utility-financial-
forecast-and-cip-detail.pdf
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5 Fiber Utility
The City offers a "Dark" fiber service providing a fiber connection from Palo Alto businesses to the downtown Internet
Exchange. At the exchange, businesses select an internet service provider (ISP) for bandwidth and connection speed.
5.1 Fiber Utility Strategic Planning
Below are highlights and status updates of the Fiber-to-the-Premises (FTTP) Project:
The permit for the fiber hut has been approved.
Construction of the foundation for the fiber hut is scheduled to start in September/October at Colorado power
station.
Construction schedule will be provided after construction company completes their survey.
5.2 Capital Improvement Plan Status
The following capital projects are currently in progress:
FO-16000 – Fiber Optic System Rebuild
o The new fiber backbone will be built in segments in alignment with the phased FTTP. As part of the wildfire
mitigation and foothills undergrounding project, CPAU is migrating existing overhead to underground
fiber and extending the City’s fiber ring from Dahl to Montebello to support essential facilities and
communication towers in the Montebello area.
FO-24000 – Fiber-to-the-Premises
o The fiber hut permit approval will pave the way to begin construction of the foundation at the Colorado
power station in September/October, with construction schedule updated following construction
company survey completion. Staff anticipates advancing an item for Council consideration in October to
take advantage of placing fiber as developments occur citywide.
5.3 Reliability
There were no unplanned fiber outages or events to report in Q3 and Q4 of FY 2025.
5.4 Financial Health
Below is a summary of the financial position for the fiber utility.
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5.4.1 Fiber Sales
Actual dark fiber licensing sales in FY 2025 were $3.7M and $0.2M or 5% above the revenue forecast of $3.5M. The City
received a large one-time customer connection fee of $0.2M from Adobe Creek Networks (Staff Report 2407-322735).
Adobe Creek Networks is a non-profit founded in 2022 to provide fiber broadband internet to Upper Page Mill Road in
Palo Alto, and adjacent areas. Operating fiber expenses were $3.3M and $1.1M or 24% below forecast. The primary cost
driver of expenses being below budget is vacancy savings of four open positions. The Fiber Fund added four new positions
in FY 2024 to support FTTP. Three of the four new positions are on hold depending on the success and financial
sustainability of the FTTP pilot. The City will reassess whether these positions will need to be filled in FY 2026 after staff
reports back to UAC and Council with key metrics of the pilot.
5.4.2 Financial Position
The ending FY 2024 Fiber Optic Utility Rate Stabilization Reserve is $8 million and an additional $25.5 million of CIP
commitments and reappropriations. In addition, the Fiber Fund loaned the Wastewater Collection Fund $3 million in FY
2024. The Wastewater Collection utility will repay the short-term loan in FY 2026 (or sooner) at a rate equal to the City’s
portfolio rate plus 0.25%. Based on staff’s forecast, the total reserve for the fiber utility is expected to decline $3M from
$33.5 million in FY 2024 to $30.5M in FY 2025 including the $3 million loan to the Wastewater Collection utility. Of the $3
million decrease, $1.5M has been encumbered for construction labor and material for the FTTP pilot.
35 Staff Report 2407-3227: Dark license fiber agreement with Adobe Creek Networks to build dark fiber in the foothills.
https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=83022
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6 Communications
This section summarizes communications highlights, updates on major campaigns and noteworthy events. Copies of ads
bill inserts, and brochures are available online at www.cityofpaloalto.org/UTLbillinsert
Gas Utility Grant: CPAU was awarded a $16.5 million grant for the replacement of old gas pipelines under the Natural
Gas Distribution Infrastructure Safety and Modernization Grant Program, which is part of the Infrastructure Investment
and Jobs Act.
Annual Gas Leak Survey: CPAU began the annual walking and mobile gas leak survey of the City. This routine inspection
of our gas distribution system is conducted to ensure the safety of all who live and work in Palo Alto. Two types of gas leak
surveys are performed every year: a walking survey of half of the residential areas and a mobile survey of all business
districts and mains. Approximately one-half of the City is covered every year by the walking survey so the entire gas
distribution system can be reviewed in a two-year period. This year the walking survey covers the southern section of Palo
Alto.
NCPA and NWPPA Federal Policy Conference: Vice Mayor Vicki Veenker and CPAU staff attended the Northern California
Power Agency (NCPA) and Northwest Public Power Association (NWPPA) Federal Policy Conference in Washington DC
April 28 through May 1. Attendees met with regulators, commissioners, representatives, and staff from various federal
agencies to advocate for the interests of NCPA and NWPPA members.
CMUA Board of Governors: In May, Palo Alto Utilities was elected to the California Municipal Utilities Association (CMUA)
Board of Governors. CMUA advocates for the interests of 84 publicly owned utilities who provide water service to 75% of
Californians and electric service capacity to 25% of the state.
New Electric Transmission Corridor: On May 22, the California Independent System Operator (CAISO) Board of Governors
approved the 2024-2035 Transmission Plan including the NASA Ames to Palo Alto 115 kilovolt (kV) project. This is a major
milestone toward establishing a second transmission corridor serving Palo Alto. City Manager Ed Shikada addressed the
Board advocating support for the project, as it is critically important to reliability for the entire City of Palo Alto.
Audit of Natural Gas Distribution System: The California Public Utilities Commission (CPUC), on behalf of the Federal
Department of Transportation, conducted a natural gas safety inspection of CPAU’s natural gas distribution system from
May 12 through May 23. The audit included a 3-year (2022-2024) comprehensive review of all gas safety programs and
plans, field records of gas pipeline inspections, and the operations of utility field staff. The auditors acknowledged staff’s
commitment to operate a safe and reliable natural gas utility with a couple minor recommendations to modify existing
procedures.
Fred Eyerly Tower Well Park Dedication: Tower Well Park was dedicated and renamed as Fred Eyerly Tower Well Park.
Fred Eyerly had a long history of public service for the City of Palo Alto as city council member, mayor, first UAC Chair,
NCPA commissioner and commission chair, and acting NCPA manager. He was instrumental in securing key utility
resources for Palo Alto such as the Calaveras Hydroelectric Project and water supply from the San Francisco Public Utilities
Commission.
Annual Consumer Confidence Report: Every year, CPAU produces a consumer confidence report on water quality
conditions for the previous calendar year. The 2024 water quality report was published online at
paloalto.gov/waterresources in English, Spanish and Traditional Chinese, or in print upon request.
Municipal Service Center (MSC) Open House: On July 26, the City hosted an open house at the MSC to showcase the
work we do for the community. Nearly 1,000 people attended demonstrations and displays, food trucks, free ice cream,
and the opportunity to talk with staff to learn about City services and programs.
Program and Event Support: CPAU communications staff provide ongoing annual, monthly, and daily support for outreach
to residential and non-residential customers about issues pertaining to sustainability, energy and water efficiency, solar,
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electric vehicles and eBikes, beneficial electrification, capital improvement projects, operations and maintenance,
customer service, and technological innovations for utility customers. This quarter included outreach on a multitude of
events and workshops on these topics, as well as promotion via website, utility bill inserts, email newsletters, social media,
print and digital advertisements, community outreach events, media relations and public correspondence.
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7 Legislative, Regulatory and Industry Activity
7.1 State Legislative Activity
The 2025 legislative session’s energy policymaking has been dominated by discussion of utility affordability but with other
unforeseen priorities emerging. The catastrophic LA wildfires in January lent new urgency to addressing wildfire risks and
inspired much legislation related to utility wildfire mitigation activity, electricity de-enenergization events (also known as
PSPS events), system readiness, and emergency response. Pushes for utility affordability have focused on increased
regulatory oversight of utilities, potential changes to regulations that increase consumer costs, permitting and CEQA
streamlining, state financing or assistance for electric infrastructure, and establishment of an independent governing
board for a new day-ahead wholesale electricity market. Lastly, a more adversarial federal government has moved
California lawmakers to try to protect California’s leading clean energy and environmental programs, leading to a
reinvigorated push for renewal of the Cap-and-Trade program. CPAU staff met with lawmakers and their staff at NCPA
and CMUA’s Capitol Day event in February to advocate for utility affordability measures, Cap-and-Trade reauthorization,
and certain considerations for large hydroelectric facilities.
Bills of Interest
AB 130 (Committee on Budget) | Housing. This bill has been signed into law and limits building code updates
at both the state and local level until 2031, negatively impacting the City of Palo Alto’s ability to use building
code amendments to meet climate goals.
AB 825 (Petrie-Norris) | AB 825 (Petrie-Norris) was amended to replace SB 540 as the vehicle for Pathways
legislation to establish a regional day-ahead electricity market and change the language to be more favorable
for a successful market. The Governor signed AB 825 into law on September 19th.
AB 1273 (Patterson) | Public utilities: ratesetting proceedings: local publicly owned electric utilities: California
Renewables Portfolio Standard Program. This bill contains language that would extend publicly owned
utilities’ ability to avoid over-procuring renewable energy in years where at least 40% of their electricity sales
come from large hydroelectric generation. CPAU strenuously advocated for inclusion of this language and will
benefit greatly from its passage.
SB 254 (Becker) | Energy. This is the Senate’s utility affordability bill that largely addresses IOU activities but
also streamlines POU wildfire mitigation plans (WMP).. It was signed into law by the Governor on September
19th.
SB 840/AB 1207 (Limon/Irwin) | Greenhouse gases: report/Climate change: market-based compliance
mechanism: price ceiling. These two bills are the Senate and Assembly’s vehicles for reauthorizing the Cap &
Trade program beyond 2030 and addressing how funds in the Greenhouse Gas Reduction Fund (GGRF) will be
spent. It was signed into law by the Governor on September 19th.
7.2 State Regulatory Activity
Regulatory action has been light in the second half of FY25, apart from CARB updating and resubmitting the Low Carbon
Fuel Standard (LCFS) amendments. Originally adopted in November 2024, the LCFS amendments were rejected by the
Office of Administrative Law (OAL) for administrative reasons including continuity issues and lack of clarity. CARB
addressed these deficiencies in a further round of amendments and despite the administrative nature of the updates,
CARB delivered an unexpected piece of good news by removing the language that could have taken LCFS credits from
utilities and provided them to EV manufacturers. CARB will resubmit the amendments to the OAL where they are expected
to be accepted, allowing the regulations to go into effect on July 1, 2025.
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7.3 Federal Activity
In recent months, federal administration actions have challenged California and clean energy efforts on a number of fronts.
Multiple executive orders made sweeping declarations to legally challenge carbon reduction regulations like Cap-and-
Trade and LCFS, bolster the use of fossil fuels, stymie renewable development, and eliminate essential federal staff and
programs. Staff reductions at the Bureau of Reclamation (BOR) and the Western Area Power Administration (WAPA) will
likely result in an erosion of operational efficiency and safety over time. Tariffs, and their fluctuating nature, have
increased equipment prices and their overall instability will likely increase costs for grid-scale projects or cause developers
to pull out entirely. Elimination of renewable energy tax credits are further increasing utility costs and are forecasted to
reduce additions of electricity generation, while cuts to EV and energy efficiency tax credits are likely to harm the success
of CPAU’s numerous utility programs.
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Appendices
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8 Appendix A: Energy Risk Management Program
This appendix provides a quarterly update on the City’s Energy Risk Management Program.
8.1 Overview of Hedging Programs
The City’s Utilities Department maintains a hedging program for its Electric and Gas Utilities. In the Gas Utility the program
protects against short-term (intra-month) price spikes caused by weather or major incidents on the Western gas system.
However, the City does not hedge its gas supply more than one month in advance, choosing instead to protect the Gas
Utility’s financial position by passing gas supply costs through to customers via a charge that varies monthly based on gas
market prices. As a result, the Gas Utility’s only market exposure is the amount by which gas demand deviates from
forecasts within the month. This exposure is relatively small and can be managed using Gas Utility Operating Reserves. A
risk assessment is performed each year as part of the Gas Utility financial planning process to ensure adequate reserves
to cover all risks. The most recent Gas Utility Financial Plan was adopted June 21, 2021 (Staff Report #1224037).
The City has entered into long-term contracts for its Electric Utility to ensure that the City has carbon free electricity
supplies equal to 100% of Palo Alto’s annual electric demand. However, the output from these generating sources does
not match Palo Alto’s electric load. In the summer, the City has a surplus of carbon free energy and it has a deficit in the
winter. This exposes the City to market risk, and staff maintains a hedging program to protect against this risk. In addition,
hydroelectric generators make up approximately half the City’s energy supply. During dry years these resources do not
generate as much energy, creating an additional market exposure that must be hedged. Unlike the gas hedging program,
which is operated by City staff, the electric hedging program is operated by the Northern California Power Agency (NCPA),
a joint powers agency the City formed in partnership with several other California publicly owned electric utilities, with
oversight by City staff.
8.2 Overview of Energy Risk Management Program
The hedging programs described above are conducted in accordance with the City’s Energy Risk Management Program,
which includes a set of Program Policies adopted by the City Council, Guidelines adopted by the City’s Utilities Risk
Oversight Coordinating Committee (UROCC), and Procedures approved by the Utilities Director. In addition, for the electric
hedging program, NCPA maintains its own Risk Management Program. The City is able to provide policy level oversight of
this program through its seat on the NCPA Risk Oversight Committee, which is held by the City’s Risk Manager.
Per the Energy Risk Management Policies, the City Council must receive quarterly reports on the City’s forward contract
purchases, market exposure, credit exposure, counterparty credit ratings, transaction compliance, and other relevant
data.
8.3 Forward Deals
Palo Alto did not execute any Electric or Gas transactions in Q3 and Q4 of FY 2025.
37 Staff Report #12240 https://www.cityofpaloalto.org/files/assets/public/v/3/agendas-minutes-reports/reports/city-manager-reports-cmrs/year-
archive/2021/06-21-21-id-12240.pdf
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8.4 Electric Market Exposure
The chart below shows the City’s electric supply market exposure and committed purchases and sales to cover exposed
positions. Additional purchases and sales will be executed for FY 2026 and FY 2027 in the coming months.
Figure 19: Electric Load Resource Balance, FY 2026 – 2028
There are no transaction exceptions or violations to report.
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9 Appendix B: PaloAltoGreen Gas Program
In December 2020, Council adopted Resolution #993039 maintaining the Carbon Neutral Natural Gas Plan to achieve
carbon neutrality for the gas supply portfolio using high-quality carbon offsets with a cost cap of $19 per ton CO2e.
Offsets are purchased to neutralize emissions equal to those caused by natural gas usage in Palo Alto. Staff procured
115,000 tons of offsets during Spring 2025 to cover FY25 usage. The figure below shows the composition of offset
purchases.
Figure 20: Offset Portfolio Composition
The following table provides a description of the projects.
39 Resolution #9930 https://www.cityofpaloalto.org/files/assets/public/v/1/city-clerk/resolutions/resolutions-1909-to-present/2020/reso-9930.pdf
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Figure 21: Offset Project Descriptions
Project Name Project Type Description
Grotegut Dairy Livestock Grotegut Dairy is a 3,900 milk-cow operation in Newton, Wisconsin with a methane capture system.
Green Trees U.S. Forest
GreenTrees Advanced Carbon Restored Ecosystem is reforestation of agricultural lands into native
hardwood forest in Mississippi, Louisiana, Arkansas, and Illinois
San Juan Lachao Mexico Forest
Protection of forests located in High Biological Value Zones which contain flora and fauna listed in the
Mexican Endangered Species List and the International Union for Conservation of Nature’s Red List of
Threatened Species. Project in San juan Lachao near Palo Alto's Sister City of Oaxaca.
Blandin Forest U.S. Forest Blandin Native American Hardwoods Conservation and Carbon Sequestration project in Minnesota.
Pocosin+U.S. Forest
These projects are all forested land that will not be disturbed by human development. Without this
protection, the forests would be converted to grow wheat or corn. Forest conservation plays a vital role in
protecting freshwater systems like lakes. The forests around the lakes act as natural water filters and purify
the water for all who use it. The projects also support healthy populations of red wolf, bald eagle, black
bear, and various bird species.
Refex ODS Ozone Depleting Substance
The RemTec facility in Bowling Green, Ohio uses an argon arc plasma destruction device to achieve 99.99
percent removal. The majority of refrigerants originated in California, and all were sourced within the
United States.
The RemTec facility uses an argon arc plasma destruction device to achieve the required destruction and
removal efficiency of 99.99 percent. The majority of ODS refrigerants originated in California, and all were
sourced within the United States.
Methane Capture Mine Methane Capture
This project is the first of its kind. Peabody Natural Gas, LLC removed methane from the North Antelope
Rochelle Coal Mine before mining. The methane was compressed and transported to a natural gas pipeline
and distributed to a national gas grid for use as fuel. Before implementation of the project, all the methane
was vented to the atmosphere.
Virginia
Conservation
Forestry Program U.S. Forest
The Virginia Conservation Forestry Program - Clifton Farm and Rich Mountain is a 9000+ acre
improved forest management project in which the timber and carbon ownership and
management rights have been transferred to The Nature Conservancy's Conservation Forestry
Program. The program manages for multiple goals to include: Water quality protection,
habitat diversity, high value forest products, and carbon sequestration.
Co-benefits: Biodiversity, Watershed Protection, Climate Resilience, and Connectivity
Riverview Farm
Anaerobic Digester Livestock
Riverview is a carbon offset project generating emission reductions thought the capture and destruction of
methane at a dairy farm in Minnesota. Under the baseline, manure managed in open lagoons led to the
fugitive emission of methane to the atmosphere. In the project scenario, this methane is captured by an
anaerobic digester and destroyed on site in the production of electricity. Co-benefits include job creation
and the improvement of local air and water quality.
Big River / Salmon
Creek Forests IFM U.S. Forest
The Big River and Salmon Creek Forests are located in Mendocino County, CA and cover 16,000 acres of
redwood and Douglas-fir forest. This project is a conservation-based forest management project.
Co-benefits include the creation of 140 jobs, protection of 37 miles of streams, and improved water quality
for local fish and bird species.
Hiawatha
Sportsmans Club U.S. Forest
Located in Michigan’s Upper Peninsula, Hiawatha Sportsmans Club (HSC) is a member-owned 35,000-acre
forest and Michigan’s oldest certified Tree Farm. The property contains a variety of habitats: Lake Michigan
shoreline, inland lakes, spring-fed rivers, marsh, mature conifer and hardwood forest and open fields.
Supported by HSC’s sustainable forest management, these diverse habitats attract and sustain a wide
variety of birds, mammals and other wildlife.
Appalachian
Mountain Club
Maine Woods
Initiative U.S. Forest
Founded in 1876, the Appalachian Mountain Club (AMC) is the oldest outdoor conservation and recreation
organization in the U.S. By implementing sustainable management practices like deferred harvesting,
extended rotations, and the retention of standing dead wood, AMC enhances forest carbon stocks and
promotes long-term ecological health. The project sequesters carbon effectively while supporting diverse
wildlife habitats and protecting soil and water quality, all in alignment with Maine's best management
practices. Through the Maine Woods Initiative, AMC demonstrates that conservation and economic
opportunity can coexist, integrating sustainable forestry with outdoor recreation to create lasting, positive
impacts for Maine's forests and communities.
Alliance Dairy Livestock
Founded in 1876, the Appalachian Mountain Club (AMC) is the oldest outdoor conservation and recreation
organization in the U.S. By implementing sustainable management practices like deferred harvesting,
extended rotations, and the retention of standing dead wood, AMC enhances forest carbon stocks and
promotes long-term ecological health. The project sequesters carbon effectively while supporting diverse
wildlife habitats and protecting soil and water quality, all in alignment with Maine's best management
practices. Through the Maine Woods Initiative, AMC demonstrates that conservation and economic
opportunity can coexist, integrating sustainable forestry with outdoor recreation to create lasting, positive
impacts for Maine's forests and communities.
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10 Appendix C: Staffing and Vacancies
As of year-end FY 2025, the Utilities Department has 43 vacant positions out of 269 authorized positions or a 16% vacancy
rate. Below is a breakdown of the vacancies by division. Utilities is coordinating with HR to find additional resources to
assist with recruitment and fill positions at a quicker pace. Across the City, the average time-to-fill a position is 81 days
from posting to hire date, but for difficult-to-fill positions in Utilities, the average time can range between 160 to 240 days.
Utilities is working with HR to post the difficult-to-fill positions on a continual basis to increase the pool of candidates and
reduce the number of days to fill these positions.
Figure 22: Utilities Vacancies and Recruitments by Division, as of Year-End FY 2025
As of June 30, 2025
Division
Authorized
FTEs Vacant FTEs
Active
Recruitments Vacancy %
Administration 15 2 2 13%
Customer Service 24 4 1 17%
FTTP & S/CAP 6 3 0 50%
Resource Management 26 2 2 8%
Electric Engineering 25 4 4 16%
Electric Operations 81 20 16 25%
WGW Engineering 23 4 4 17%
WGW Operations 69 4 4 6%
Total 269 43 33 16%
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11 Appendix D: Cap-and-Trade Program Annual Update
California’s Cap-and-Trade Program, launched in 2013 under the Global Warming Solutions Act (AB 32), is a market-based
system that caps greenhouse gas (GHG) emissions and lowers the cap each year to drive greenhouse gas emissions
reductions. Under CARB’s cap-and-trade rules, Palo Alto must sell all of the allowances freely allocated to the Electric
Utility. For the Gas utility, Palo Alto uses some of the freely allocated allowances for greenhouse gas compliance
obligations and sells the remaining allowances using the proceeds for the benefit of ratepayers, consistent with AB 32.
The City Council approved a policy on the use of freely allocated allowances under the State’s cap-and-trade program (see
Resolution 948741 and Reso 1007742). This City policy allows auction proceeds from the sale of Allocated Allowances to be
used for renewable energy investments, energy efficiency programs, GHG emissions reduction initiatives, fuel-switching
(such as electrification), and ratepayer rebates (with Council approval). Revenues from the sale of allowances freely
allocated to the Electric Utility (“electric allowance revenues”) must benefit electric customers only, and similarly,
revenues from the sale of allowances freely allocated to the Gas Utility (“gas allowance revenues”) must benefit gas
customers.
Electric Utility
In calendar year (CY) 2024, Palo Alto received 142,536 freely allocated allowances from the State. All of which were sold
at state-run auctions, which generated about $5 million in revenue. About $2.47 million was spent on renewable energy
purchases to help meet the City’s Renewable Portfolio Standard (RPS) targets. The remaining $2.55 million was transferred
to the Electric Cap and Trade reserve to fund future electric greenhouse gas emissions reduction programs. The Electric
Cap and Trade reserve has about $4.12 million at the end of FY 2024.
Electric Allowance Revenues and Expenditures ($)
Calendar
Year
Allowance
Revenues
Allowance
Expenditures
2023 4,968,167 3,076,027
2024 5,021,890 2,470,160
Gas Utility
In CY 2024, Palo Alto received 121,912 freely allocated allowances from the State. 70% or 85,338 of those allowances were
required to be sold at State-run auctions, which generated about $3.35 million in revenue. The remaining 36,574
allowances were used to meet Palo Alto’s compliance obligation. About $0.72 million was spent on the heat pump water
heater direct installation and incentive program, while the remaining $2.63 million was transferred to the Gas Cap and
Trade reserve to fund future gas GHG emissions reduction programs. The Gas Cap and Trade reserve has about $13.57
million at the end of FY 2024.
Gas Allowance Revenues and Expenditures ($)
Calendar
Year
Allowance
Revenues
Allowance
Expenditures
2023 2,983,655 210,196
2024 3,349,973 722,122
41 Reso 9487 (2015): https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=53850
42 Reso 10077 (2022): https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=61567
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12 Appendix E: Electric Utility Annual Infrastructure Maintenance and
Replacement Report
Executive Summary
Calendar year 2024 safety metrics include zero OSHA recordable injuries and no lost workdays but did include
three minor, non-recordable accidents. To maintain employee competency with safe working practices, the City
provides ten department-wide safety meetings, numerous online training courses and field assessments. During
CY2024 employees collectively completed over 1,388 training courses.
The City of Palo Alto continues to provide safe and reliable electric service at the lowest reasonable cost. System
reliability numbers have improved primarily due to milder winter weather but also due to improvements in
restoration processes following an outage.
While slowed by the loss of key staff within the metering division, progress continues to complete the AMI project.
Currently staff are coordinating across departments to add a new AMI base station atop City Hall providing
connectivity and transmission for the downtown district, Stanford campus, and Oak Creek apartments. The base
station will allow approximately 3,000 electric meters to be modernized.
The Grid Modernization Pilot for the distribution system is completed. The electric infrastructure suppling roughly
908 homes has been upgraded including the replacement of 70 wood utility poles, 106 new transformers, and
22,650 feet of new low-voltage wire. The cost to complete the pilot area reached just over $10 million with
contracted labor being the largest cost.
Design work continues on necessary upgrades to the Colorado Substation. Recently the City Council approved of
a professional services agreement with Burns & McDonnell to support the City in the redesign and replacement
of aging infrastructure within the Colorado substation. Staff have begun scoping the work with Burns & McDonnell
and expect to have a final high-level assessment of the substation by December of 2025.
CY2025 (to-date) Electrification Permit Applications
To manage increased load, CPA’s Electric Engineering is responsible for evaluating all electrification-related applications.
Figure 1 provides a summary of activity levels across the five main categories. As shown, electrification and the adoption
of electric appliances is increasing year over year.
Figure 23 – Electrification Permits by Category
Between 2019 and 2024, electrification experienced Compound Annual Growth Rates (CAGR) ranging from 12% for EVCS
up to 162% for hot water heat pumps. This upward trajectory is anticipated to persist through 2025, as suggested by mid-
year performance data.
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Electrification is placing pressure on local permitting organizations, including The City of Palo Alto (CPA). CPA is grappling
with a flood of permit applications, often with longer review times and at times inadequate staffing to perform the
necessary permit reviews. Although CPA Electric Engineering staff are relatively new, they have undergone training to
competently conduct the required reviews.
System Reliability Indices
Major Event Days Included Major Event Days Excluded
FY SAIDI SAIFI CAIDI SAIDI SAIFI CAIDI
2019 114.7 0.935 122.7 44.4 0.330 134.6
2020 63.9 0.486 131.4 26.2 0.248 105.6
2021 70.6 0.720 98.1 14.7 0.053 279.9
2022 7.2 0.159 45.4 1.2 0.009 132.8
2023 148.9 1.378 108.0 26.1 0.164 159.6
2024 153.1 0.786 194.7 72.3 0.362 199.7
2025 95.4 0.779 122.5 44.5 0.283 157.4
CY2024 Facility Inspections
Bird, 1
Cause Unknown, 13
Construction, 2
Contact with
Foreign Object, 1
Electrical Failure,
14
Equipment
Damage, 10
Equipment Worn
Out, 5
Overloaded, 1
Squirrel, 4
Tree, 12
Vehicle Accident, 4
Fiscal Year 2025 Sustained Outages by Cause
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Type of Inspection (inspection unit)
Units Due in CY
2024 Still Outstanding
Percent
Complete
Annual Visual Patrols (equipment)6,521 0 100.0%
Overhead Detailed (poles & all related equip.)1,145 0 100.0%
Underground Detailed (subsurface equipment, boxes,
& vaults)1,033 13*98.8%
Wood Pole Intrusive (poles tested)538 11**98.3%
Substation (inspections)132 132 100.0%
*Access issues prevented 13 underground detailed inspections (vehicles on top of vaults, buried boxes, etc.). These inspections will be
completed in the current year.
**Access issues prevented 11 pole tests (rear-easements, locked gates, etc.). These intrusive inspections will be completed in the current
calendar year.
Preventative Maintenance Tags
GO 165 inspections generate maintenance tags to correct either construction infractions or maintenance issues. Tags are
graded based upon their severity and risk to the public or potential to cause a power outage. Three rankings are possible,
Priority-1 complete immediately or within 30-days, Priority-2 complete within 24 months, and Priority-3 complete within
60-months. Maintenance tags can range from minor work of clearing vegetation around poles or pad-mounted equipment
to identifying portions of the system that need fully reconstructed. Lack of maintaining and adequate number of qualified
staff impacts the City’s ability to complete preventative maintenance tags.
CY2024 Overhead Maintenance Tags
Grade Total Due in CY2024 Completed Pending
Priority-1 1 1 0
Priority-2 243 52 191
Priority-3 336 154 182
Total 580 207 373
Overhead maintenance tags typically include the replacement of reflective strips at the base of utility poles, high-voltage
warning signs, replacement of down guy visibility markers, and others. Most work helps maintain the City’s compliance
with industry construction standards and prevents future power outages.
CY2024 Underground Maintenance Tags
Grade Total Due in CY2024 Completed Pending
Priority-1 9 9 0
Priority-2 188 3 185
Priority-3 115 0 115
Total 312 13 300
Underground maintenance tags typically include the replacement of signage on vaults and pad-mounted equipment,
replacement of cracked or broken vault lids, removal of vegetation, replacement of worn or deteriorated underground
equipment, and others. This work also maintains the City’s compliance with industry construction standards and prevents
future power outages.
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13 Appendix F: Water Utility Annual Infrastructure Maintenance and
Replacement Report
Executive Summary
The City continues to meet water quality standards and regulatory requirements
Water Main Replacement program continues as planned
Construction of Water Main Replacement Project #29 began in November 2023 and was completed in September 2024.
Advanced Metering Infrastructure (AMI) program on-going as planned
Infrastructure Overview
Key infrastructure replacement efforts in the next five years include:
●Regular mains, services, hydrants, and valve replacement
●Repair or replacement of Dahl and Park Reservoirs
System Operations and Maintenance
There are 17.2 Total FTE’s working on Water System O&M.
●Water Quality (2.3 FTE):
o *Monitoring: Weekly, monthly, quarterly, and annual water quality sampling
o *System Flushing: Regular seasonal flushing of dead-end mains in the system to prevent sediment build-up and
disinfection
o Cross-Connection Control Program (CCCP): Prevents water from flowing from private water services back into the
public water system and protects the public water system from contamination
●*System Monitoring (1 FTE): Remote system controls and device of pumps, tanks, and valving. Control of water flow
and distribution throughout the water network
●System Inspections (1.3 FTE): Periodic field inspections of pump stations and other key system components
●Planned Maintenance (6.4 FTE): Test and maintain distribution system equipment required for operations such as
station mechanical equipment, valves, and meters, and non-emergency repair and replacement of degraded or
damaged assets (e.g. hydrants, valves, mains, and services).
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●*Unplanned Maintenance (2.4 FTE): Emergency response and infrastructure repairs and replacements requiring
immediate attention.
●New Construction (3.8 FTE): Installation of new water services, valves, and meters for construction projects.
*Priority programs critical to daily operation
Maintenance Status:
●Critical maintenance programs running smoothly
●CCCP inspection program meets state requirements, needs evaluations as growth continues
●AMI program being implemented in the field
Table 1: Status of Drinking Water System Operation and Maintenance Programs
System Operation
or Maintenance
Program
Status Comments
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Meter
Maintenance
Multiple one-time sampling projects have shown that most meters are in good
shape. There are many meters due for replacement, and the mass replacement
of older, small water meters with new advanced metering infrastructure (AMI)
is underway and approximately 85% complete. Meter testing was performed
by a third-party contractor.
Unplanned
Maintenance
The City maintains an emergency on-call program to respond to and control
water leaks or other system emergencies at any hour of the day or night. As
the City responds to and repairs urgent water needs immediately, no backlog
of leaks pending repair occurs.
Table 2: Condition of Drinking Water System Assets
Asset Class Quantity Maintenance Asset Condition
Water Receiving
Stations (Turnouts)
5 Meter testing (every 2 years)
Annual Maintenance (calibrate
pressure transducer and analog
gauges, exercise isolation
valves and PRV’s, clean out
cover)
Most receiving stations currently require only minor
and routine maintenance and are in good condition
overall. Some minor improvement projects may be
required in the next few years. California Ave
turnout was replaced in 2024. Page Mill Turnout
valve restraint work was completed and all valve
maintenance completed in 2024.
Booster Stations /
Pressure Reducing
Stations
7 / 6 Annual maintenance (calibrate
upstream / downstream
pressure transducer, analog
gauges, check pressure
switches, exercise isolation
valves and PRV’s, cleaning).
Mayfield and El Camino PS have
VFD’s which are maintained by
Tesco.
Weekly monitoring
Most booster stations and pressure reduction
stations require only minor and routine
maintenance and are in good condition overall. A
pipe coating project of all exposed and above
ground booster pump station piping was completed
in 2024.
Reservoirs 7 Annual maintenance (climb
tank, take physical reading of
water level, check altitude
valve, check screens, calibrate
tank pressure transducer,
analog gauges)
Water quality monitoring
Dahl and Park Reservoirs are scheduled for repair
and seismic retrofit in CY 2029-2030.
Emergency Wells 8 Annual maintenance,
inspection, and testing of wells
by Tesco, third party
contractor. Routine inspection
and water quality monitoring
City wells were rehabilitated in 2013, but some
maintenance is needed. El Camino Park Well pump
rehabilitation began in 2024 and was completed in
2025. The well pump was rehabilitated and new
column pipe and other associated components were
replaced.
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Staff Report: 2501-4079 – Page 45 of 45
and monthly maintenance of
systems performed by staff.
Water Valves ~6,500
valves
Operate every valve at least
once every five years (1200
valves per year), repair /
replace as needed
Operate 120 critical valves in
foothills annually
Valves are replaced on failure, or proactively when
water mains in the area are replaced.
Water Mains and
Services
~230
miles of
main,
~23,000
services
Repair leaks as identified
Monitor water quality
Water Main Replacement program continues as
planned, prioritizing leaky pipes and seismically
vulnerable pipes. Trenchless pipe replacement
approaches and combined pipe replacement
projects with other utilities are being implemented
to reduce cost.
Water Meters ~23,000
small
meters,
380 large
meters
Sample test small meters, test /
repair large meters annually
Replacement of oldest small water meters
continues, informed by small meter testing. Large
meter testing began in CY2023. Which helped
estimate meter accuracy. AMI meter upgrade
project is currently under way and approximately
85% complete. Older meters are being replaced as a
part of this project.
Fire Hydrants ~3000
public
hydrants
Maintenance Hydrants are replaced upon failure, or proactively
when water mains in the area are replaced.
Attachments:
Attachment A: Presentation
Approved By:
Alan Kurotori, Director of Utilities
Staff: Tim Denterlein, Resource Planner
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October 1, 2025 www.cityofpaloalto.org
FY 2025 4th Quarter
Report
Utilities Advisory Commission
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2 www.cityofpaloalto.org
UAC Work Plan – Standing Topics
#3 – Electric System and Supply
1. Electric Utility
FY 2025 Electric Sales
•Actual:12.4% higher than adopted budget
•Main driver:
-Tesla 55% data center load growth
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3 www.cityofpaloalto.org
UAC Work Plan – Standing Topics
#3 – Electric System and Supply
1. Electric Utility
FY 2025 Electric Net Supply Cost
•Actual: $76.2M (↓2% vs. Adopted Budget of $77.0M)
•Key driver of decrease: higher revenue from REC and RA sales
•Q4 2025: Net supply cost ~$1.5M below budget
FY 2026 Electric Net Supply Cost Projection
•Projected: $99.2M
•Main cost drivers:
-Higher Western Restoration Fund costs
-Higher RA purchase costs
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4 www.cityofpaloalto.org
UAC Work Plan – Standing Topics
#6 – Reliability, Resiliency and Adaptation
1.3 Reliability (Electric)
Major Event Days Included Major Event Days Excluded
SAIDI SAIFI CAIDI SAIDI SAIFI CAIDI
CPAU 95.4 0.779 122.5 44.5 0.283 157.4
PG&E 2024 DeAnza Div 471.1 2.020 233.2 211.3 1.580 133.7
National 5-Yr Avg of
Top Utilities 83.3 0.842 87.7 82.9 0.632 73.8
•CPAU’s electric system is about 5x more reliable than PG&E’s local system
•FY 2025 reliability indices place CPAU in the top quartile nationally
Key Drivers of Outages
•Most unplanned outages due to equipment failure, damage, or wear
•Highlights need for ongoing equipment replacement through CIP
SAIDI: System Average Interruption Duration Index
SAIFI: System Average Interruption Frequency Index
CAIDI: Customer Average Interruption Duration Index
Major Event Day: 24-hour period that impacts 10%+ electric customers
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5 www.cityofpaloalto.org
UAC Work Plan – Standing Topics
#6 – Reliability, Resiliency and Adaptation
2.3 Reliability (Gas)
FY 2024 FY 2025
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
Number of Breaks 5 1 5 6 13 7 6 6
Total Minutes 540 120 570 270 1860 1205 1050 930
Customers Affected 51 1 41 14 135 48 23 40
FY25 Q1 Trends
•Higher recorded interruptions due to increased resources allocated to resolve existing small gas leaks
•Leaks are monitored and low-risk, but upcoming legislation requires faster resolution
•Gas division is actively addressing leaks to meet compliance goals ahead of new rules
Key Drivers of Outages
•Most unplanned outages due to equipment failure, damage, or wear
•Damage often caused by excavation by outside parties
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Item No. 2. Page 1 of 5
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Utilities Director
Lead Department: Utilities
Meeting Date: October 1, 2025
Report #: 2502-4137
TITLE
Discussion of Preliminary Analysis of the Infrastructure Impacts Associated with Gas
Decommissioning
RECOMMENDATION
This is a discussion item and no action is requested. Staff is briefing the Utilities Advisory
Commission (UAC) on preliminary results from the Gas Transition Study to hear questions from
the UAC that could inform future work on the analysis and to provide information that could
inform 2026 UAC work planning efforts.
EXECUTIVE SUMMARY
Achieving the community’s greenhouse gas emissions reductions goals requires extensive
reductions in building emissions. Regardless of how quickly the community reaches these goals,
impacts on the gas utility’s financial structure and physical operations are expected. Staff is
studying those impacts. The study will simulate different patterns of electrification throughout
Palo Alto, identify opportunities for gas main and service abandonment and operational
efficiencies, and estimate abandonment costs, changes in operational costs, and customer class
cost allocations. It will prioritize gas system safety and identify parts of the gas system that may
need to be retained for operational reasons even after substantial parts of the system have
electrified. Staff is sharing preliminary results from the first part of the Gas Transition Study
with the UAC so it can adjust course as needed as staff works to complete the study.
BACKGROUND
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Item No. 2. Page 2 of 5
Staff reviewed the methodology for this analysis with the Climate Action and Sustainability
Committee (CASC) at its June 13, 2025 meeting1 and with the UAC at its September 3, 2025
meeting. The study involves multiple steps:
Scenario
Gas
Sales
Reduction
Residential
Space and Water
Heating
Electrification
Small and Medium Non-
Residential Space and
Water Heating
Electrification
Medical and
Industrial
Electrification*
1 20%25%25%0%
2 40%50%50%0%
3 60%75%75%0%
4 80%100%100%0%
* In practice, some electrification will occur in this sector, but staff does not have good
visibility on the potential for electrification in this space due to the prevalence of unique /
process loads
ANALYSIS
1 Climate Action and Sustainability Committee, June 13, 2025, Discussion of Gas Utility Transition Study Scoping,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=8207&meetingTemplateType=2&compil
edMeetingDocumentId=14791
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Item No. 2. Page 3 of 5
family homes had at least one major gas appliance. About 85% of single-family water heating
and 81% of single-family space heating is estimated to be gas-driven. About 61% of water
heating and 50% of space heating equipment in multi-family buildings is estimated to use gas.
This aligns with preliminary expectations in the process of community electrification, but these
numbers will likely change as results are reviewed in more detail and any data errors or
omissions are identified and fixed.
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Item No. 2. Page 4 of 5
FISCAL/RESOURCE IMPACT
3 (presented at the April 4, 2025 CASC meeting) showed
that there are some scenarios in which community benefits from electrification would exceed
community costs, including lost gas revenue. Staff and its consultants will complete more
detailed estimates of the cost and revenue impacts to the gas utility at various levels of
electrification as part of the Gas Transition Study. Staff plans to estimate the cost impacts of
various levels of electrification and the impact on various customer classes in the coming
months and will return to the UAC and CASC in early 2026 with the results and a list of potential
mitigations for any impacts as part of the Gas Transition Study.
STAKEHOLDER ENGAGEMENT
4 and January 20215 meetings, and
since then the need to more carefully assess the costs of transitioning the gas utility has been
raised in several meetings of the UAC, S/CAP climate stakeholders, the Council subcommittees
focused on climate contexts, and at City Council.
3 Climate Action and Sustainability Committee, April 4, 2025, Discussion of Preliminary Sustainability and Climate A
ction Plan (S/CAP) Funding Study Results, https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?i
d=7672&meetingTemplateType=2&compiledMeetingDocumentId=13682
4 Staff Report ID#11639, November 4, 2020, Discussion of Electrification Cost and Staffing Impacts on the City of Pa
5 Staff Report ID#11751, January 6, 2021, Discussion of Projected Electrification Impacts on Gas Utility System
Average Rates, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-
minutes/utilities-advisory-commission/archived-agenda-and-minutes/agendas-and-minutes-2021/01-06-2021-
special/01-06-21-uac-item-1.pdf
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Item No. 2. Page 5 of 5
ENVIRONMENTAL REVIEW
The CASC’s discussion of this topic does not meet the California Environmental Quality Act’s
definition of a project, pursuant to Public Resources Code Section 21065, and no environmental
review is required.
Attachment A: Assumptions, Methodology, and Preliminary Key Results from Gas Transition
Study Currently in Progress
Attachment B: Presentation
:
Alan Kurotori, Director of Utilities
Staff: Jonathan Abendschein, Assistant Director, Climate Action
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Attachment A
9
2
3
5
Assumptions, Methodology, and Preliminary Key Results from
Gas Transition Study Currently in Progress
This attachment gives a high-level overview of various inputs, estimates, assumptions,
methodological detail, and some key preliminary results for the Gas Transition Study.
Estimated Quantities of Gas Equipment in Single-Family Homes Based on Gas Use
Staff’s consultant, Energeia, used anonymized gas usage information from all homes
and businesses in Palo Alto to estimate what gas equipment was in the homes.
Seasonal usage patterns were used to estimate water heating and space heating gas
use. Other data used included home sizes and whether the County Assessor’s data for
the parcel noted a pool. Multi-family building equipment was estimated by looking at the
combined gas use for the entire building, including the house accounts, to determine
whether space and water heating equipment was centrally located or in units and
whether that equipment was gas or electric. Equipment in commercial buildings was not
estimated, but basic estimates of how much gas was used for space heating vs. water
heating were created.
Based on that information the following very preliminary estimates for populations of gas
equipment were generated. Note that the total number of single-family and multi-family
units identified are a bit lower than would be expected based on other sources,
indicating the need to review the underlying inputs for missing data. Note that multi-
family gas equipment accounts are expected to be significantly lower than the number
of multi-family units in Palo Alto, since many apartment units do not have dedicated gas
meters, having electric or central gas space heating and central gas water heating.
Equipment # units % gas % electric
Single family
Water heating 85%15%
Space heating 13,077 82%18%
Multi-family
Water heating 61%39%
Space heating 3,963 50%50%
Gas Utility Costs and How Electrification Would Affect them
The table below lists the different costs the gas utility incurs, what percentage of the
utility’s costs each category represented in FY 2024, and what factors would lead to
each category of costs declining.
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Attachment A
9
2
3
5
Cost Category Varies Based On
% of Gas
Utility
Cost
(FY24)Decreases when
Commodity, Transportation,
and Environmental
Sales 41%Sales decline
General Fund Transfers Sales 15%Sales decline
Demand Side Management Sales 1%Sales decline
Customer Service # Customers 4%Customers disconnect
Operations and Maintenance
(incl. Engineering)
Miles of main,
main age
16%Lengths of main are
abandoned, especially
older materials or steel
Capital Investment (incl.
Engineering)
Miles of Main
needing
Replacement
13%Lengths of main needing
replacement are
abandoned
Administrative Overhead:Mostly staffing 7%Enough lengths of main
abandoned that the gas
utility needs fewer staff
Supply Management Does not vary 2%Gas is no longer used in
Palo Alto
Debt Service Debt service
schedule
1%Debt is paid off
Rent Square footage of
gas receiving
stations
1%Gas is no longer used in
Palo Alto
Estimated Gas Main Abandonment Opportunity for Different Electrification Levels
The City’s consultant ran the following simulations, which loosely aligned with the
scenarios discussed with the Climate Action and Sustainability Committee and Utilities
Advisory Commission:
Scenario
Gas
Sales
Reduction
Residential
Space and Water
Heating
Electrification
Small and Medium Non-
Residential Space and
Water Heating
Electrification
Medical and
Industrial
Electrification*
1 20%25%25%0%
2 40%50%50%0%
3 60%75%75%0%
4 80%100%100%0%
* In practice, some electrification will occur in this sector, but staff does not have good
visibility on the potential for electrification in this space due to the prevalence of unique /
process loads
The consultant found the following after simulating several iterations of random
electrification among the sectors noted above. The chart below shows the number and
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Attachment A
9
2
3
5
percentage of gas mains with the number of connections shown on the x axis. So, for
example, under the 60% scenario about 300 mains (about 10%) had no connections
and could be removed, while over 500 mains (about 20%) had only one connection.
And the number of mains with no connections increased from almost none under the
20% scenario to about 40 in the 40% scenario, over 300 in the 60% scenario, and the
vast majority of mains in the 80% scenario.
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October 1, 2025 www.cityofpaloalto.org
Gas Transition Study Preliminary Results
Utilities Advisory
Commission
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Background
•City, State, and Regional policies drive building electrification
•If successful, gas use will decline significantly
•The City must plan for financial, physical, and safety impacts
•This will enable a safe, smooth, equitable transition
Council 2025 Priority Objective #32:Share preliminary analysis of
strategies for a physical and financial transition of the gas utility to
relevant policymakers and stakeholders
2023-2025 S/CAP Work Plan Work Item 5D: Develop financial and
operating plan for declining gas utility sales
2
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Study Goals
•Understand physical impacts of electrification on gas
infrastructure
•Estimate operational and financial impacts
•Estimate cost of gas main and service abandonment
•Develop strategies to:
•facilitate abandonment
•mitigate physical and financial impacts
3
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Study Outputs
4
Other Outputs
•Cost impacts to other utilities
•General Fund transfer and UUT impacts
For the Gas Utility
•Cost of gas main/service abandonment
•Operational cost impact
•System average rate changes by class
•How much funding would be needed
from some other source to keep gas
rates in line with current forecasts
•Cap and Trade cost and revenue impacts
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Overview of Study Progress
5
Study Component Status
1 Build System Model Completed Apr 2025
2 Equipment estimation First draft completed, being
reviewed and refined
3 Simulate main abandonment under various
electrification scenarios
First draft completed, being
reviewed and refined
4 Cost categorization and estimates of cost
impacts by electrification scenario Partially complete
5 Evaluate impacts on customer groups Not started
6 Identify mitigations At brainstorming stage
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Electrification Scenarios to Model
6
Scenario Reduction in Gas
Sales
Water and Space Heating Electrification
Residential Small / Med
Commercial
Large Comm /
Industrial
1 20%25%25%0%
2 40%50%50%0%
3 60%75%75%0%
4 80%100%100%0%
•Medical and Industrial electrification excluded
•Gas disconnection likelihood evaluated for buildings with
water and space heating already electrified
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Preliminary Result:Estimated Equipment Population
7
Equipment # units in data
set % gas %electric
Single family
Water heating
13,077
85%15%
Space heating 82%18%
Multi-family
Water heating
3,963
61%39%
Space heating 50%50%
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TITLE 40 FONT BOLD
Subtitle 32 font
Preliminary Result:
Cost Categories and
Cost Drivers
Outer Circle =
Cost Categories
Inner Circle =
Cost Drivers
Key Insight: Over 60% of costs
decrease with declining sales and
customer disconnections
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Preliminary Result:Mains Eligible for Abandonment
9
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
20% Reductions 40% Reductions 60% Reductions 80% Reductions
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Next Steps
10
•By end of 2025, complete modeling:
•Refine data and methodology for estimating equipment population
•Refine simulations of electrification scenarios and their outputs
•Test simulated electrification scenarios in system model to identify any
system operational issues
•Estimate utility costs and revenues for each scenario
•Estimate impacts to specific gas customer groups
•Brainstorm strategies to manage issues identified by the modeling
•Early 2026: Final report development
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Item No. 3. Page 1 of 8
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Utilities Director
Lead Department: Utilities
Meeting Date: October 1, 2025
Report #: 2508-5128
TITLE
Discussion of Implementation and Communication Plan for Voluntary Residential Electric Service
Time-of-Use Rate (E-1 TOU)
RECOMMENDATION
Staff recommends that the Utilities Advisory Commission (UAC) review and comment on the
implementation and communication plan for the voluntary residential electric service time-of-
use rates. This item is for discussion only, and no action is requested.
EXECUTIVE SUMMARY
On September 15, 2025, the City Council approved a voluntary residential electric service time-
of-use rate schedule (E-1 TOU), effective January 1, 2026.1 This report summarizes the plan for
phased enrollment of the voluntary TOU rate and the communication and marketing plan. The
implementation and communication plan is designed to ensure customers are informed,
supported, and prepared to successfully transition to TOU rates. Additionally, the communication
plan will be designed to inform the community about the new TOU rate option and to convey the
beneficial impacts of switching electricity use from the high cost 4 p.m. to 9 p.m. period to the
solar electricity generation period of 9 a.m. to 3 p.m. and night time (9 p.m. to 9 a.m.),
irrespective of whether the customer elects to be served under the TOU rate.
BACKGROUND
TOU rates are a type of electricity pricing where the cost of electricity varies depending on the
time of day it is used. Under this rate structure, electricity prices are typically lower during off-
peak hours, when demand is low, and higher during peak hours, when the grid is under more
1 Staff Report 2505-4750; https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=031339b2-
900e-422e-96c0-b5a0be11056b
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Item No. 3. Page 2 of 8
strain due to higher demand compared to available electricity supply. The TOU rate structure
reflects the actual cost of supplying electricity at different times.
ANALYSIS
Enrollment Plan for E-1 TOU
3 due to billing complexities with the annual settlement options.
3 A NEM1 customer may switch to the NEM2 rate and become eligible to participate in TOU rate. This option may
be available by mid-2026.
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Item No. 3. Page 3 of 8
month period. Once a customer reverts back to E-1, they cannot re-elect E-1 TOU for the next
12 billing cycles. These rules are designed to prevent customers from gaming the system and to
minimize the administrative burden of switching customers back-and-forth.
5.
6 and reduce strain on the
electric grid. Single family customers with the ability to shift loads to super-off peak (solar
generation hours) and off-peak hours (night hours) have the greatest potential to benefit from
TOU rates. Customers with high electricity consumption can also save by switching to TOU
rates7. Multi-family and low-use single-family households are less likely to benefit from
switching to TOU rates, as their overall usage is lower and they have limited ability to shift
consumption to lower-cost time periods.
5 All the IOUs in California and SMUD have switched all their customers to TOU rate, on an opt-out basis several
years ago. When making this switch, which was many years after experimenting with volunteer TOU rate, these
utilities made major investment in their customer portals. Their customer portals now display individualized
assessments (based on historic hourly consumption data) of comparative customer bills for different rate options.
SMUD mailed each customer a letter informing them of the impact TOU rate will have on their bill based on
historic consumption patterns. Because of the complex nature of the comparative bill calculations, staff is not
aware of any utility providing a customer facing bill comparison calculator.
6 CPAU staff is exploring hosting an individual appliance level relative cost assessment calculator on our website. It
would include information at the level of an electric appliance to inform customers about how much money they
could save from shifting the time of use of commonly used electrical appliances. An example of a tool like this is
the Time-of-Day Cost Estimator from Sacramento Municipal Utilities District. Time-of-Day Cost Estimator.
https://www.smud.org/Rate-Information/Residential-rates/Time-of-Day-5-8pm-Rate/Time-of-Day-Cost-Estimator
7 E1 is a tiered rate with customers with a consumption below 450kWh/month enjoying a lower rate of
$0.2057/kWh, compared to the higher Tier 2 rate of $0.2294/kWh for consumption above 450kWh. The TOU rates
do not have tiers and customers with an average load profile could expect to pay an average rate of $0.215/kWh,
which is in between the Tier 1 and Tier 2 rate.
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Item No. 3. Page 4 of 8
TOU rates will not be immediately available to customers with Solar PV systems, and they are
unlikely to benefit from TOU without battery storage capabilities. Due to the lower TOU rates
during super off-peak hours of 9 a.m. to 3 p.m. (when solar generation is typically highest),
NEM customers will likely receive lower compensation under the TOU structure. NEM1
customers receive full retail credit for excess solar energy exported to the grid. Under TOU
rates the NEM1 customers would see lower export credit value and likely higher bills. However,
residents with solar and BESS could cycle the battery daily (by charging during solar generation
hours and discharging during the 4 p.m. to 9 p.m. peak period) and benefit by switching to TOU
rates.
Customer Communication and Marketing Plan
11. Outreach will include the City’s website, email, bill inserts, social media,
and in-person events.
11 Though Palo Alto’s electric supply is carbon neutral on an annual basis, Palo Alto's marginal electricity source is
from the California grid. The state grid’s marginal carbon intensity difference of the electricity produced during
solar hours (9 a.m. to 3 p.m.) and non-solar generation hours (3 p.m. to 9 a.m.) is approximately 90lbs of CO2
e/MWh. A typical EV that charges only during solar generation hours, could lower annual emissions associated
with the EV's electricity consumption by ~270lbs of CO2/year.
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Item No. 3. Page 5 of 8
demands on Customer Service staff. Attachment C is an initial draft of the FAQs. The FAQs will
evolve over time with the TOU program.
Figure 1: E-1 (Tier 1 and Tier 2) and Summer E-1 TOU Volumetric Rates for FY 2026
Figure 2: E-1 (Tier 1 and Tier 2) and Winter E-1 TOU Volumetric Rates for FY 2026
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Item No. 3. Page 6 of 8
Lessons from other utility case studies suggest that tailored messaging boosts enrollment.
Recruitment materials specific to the TOU plan perform better than generic “mass marketing.”
Messaging should be direct, simple, and focused on personal financial and environmental
impacts. Sharing aggregate customer savings and environmental benefits post-enrollment can
sustain engagement and spur word-of-mouth adoption. While TOU rates can lead to cost
savings, it's important to monitor customer satisfaction and address any negative impacts.
Measures of Success
Completion of Testing: Successfully complete the testing process and resolve any
identified issues.
Program Availability: Making the E-1 TOU rate available to all eligible customers.
Customer Satisfaction: Gauging satisfaction among enrolled customers through direct
feedback, tracking questions and comments, and reporting on issue resolution.
Increased Customer Awareness: Measuring the increase in awareness of the beneficial
impacts of switching electricity use from the high cost 4 p.m. to 9 p.m. period to solar
electricity generation periods of 9 a.m. to 3 p.m.
Customer Behavior Change: Observing measurable shifts in customer energy usage to
lower-cost periods among those enrolled in the E-1 TOU rate.
Program Impact: Estimating supply cost savings, peak load reduction, and emissions
reductions based on observed changes in customer behavior.
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Item No. 3. Page 7 of 8
Implementation Plan Summary and UAC Feedback
Figure 3 below summarizes the timeline for phased enrollment and major communication
activities during each period. Staff requests UAC feedback on the following:
1. The phased enrollment plan
2. The draft Communication Plan (Attachment A)
3. The draft customer communication material (Attachment B)
Figure 3: Timeline for Voluntary Enrollment in E-1 TOU Rate & Elements of the Communication Plan
Date Customer Enrollment Customer Communication
Nov 2025-Mar
2026
Approximately 10 customers per
month, starting January 2026
Communicate with hand-selected
enrolled customers only
Mar 2026 General outreach to raise community
awareness of the new TOU rate
offering including eligibility. Explain
TOU benefits for enrollees and
benefits of avoiding energy use
during peak demand period for all
customers.
Apr-Jun 2026 Enroll up to 50 customers per
month, based on enrollment request
forms submitted
Notify customers as they are enrolled
in the TOU rate and continue
outreach and education
Jul 2026 Open up to all customers who have
requested enrollment
Continue outreach and education
Jul 2026 Open customer enrollment to NEM2
customers (tentative)
Communicate with the NEM2
customers who had already indicated
an interest in switching. (NEM1
customers will not be eligible to
participate due to billing system
limitations)
Dec 2026 Ongoing enrollment Survey participating customers
Dec 2027 Ongoing enrollment Survey participating customers and
analyze beneficial impacts
FISCAL/RESOURCE IMPACT
Staff plans to use a fiscally prudent and cautious approach to rolling out the E-1 TOU program by
moderating promotional spending and staff time and scaling the use of resources appropriately
in line with the number of customers enrolled and interested in the voluntary program. This
measured approach allows the program to be implemented within current staffing and budget
constraints.
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Item No. 3. Page 8 of 8
STAKEHOLDER ENGAGEMENT
At the December 4, 2024, UAC meeting, Staff presented preliminary rate proposals for FY 2026
and provided an update on TOU rates as an informational item for discussion purposes13. On June
4, 2025, staff presented the E-1 TOU rates to the UAC and the UAC unanimously recommended
approval of the rates14. On September 2, 2025, staff presented the E-1 TOU rates to the Finance
Committee and the Committee unanimously voted to recommend approval to Council. On
September 15th the City Council adopted the E-1 TOU rates unanimously.
ENVIRONMENTAL REVIEW
Discussion of Implementation Plan for Voluntary Residential Electric Service Time-of-Use Rates
does not meet the definition of a project under the California Environmental Quality Act (CEQA),
pursuant to the California Public Resources Code Section 21065, because it is not an activity that
will cause a direct physical change in the environment.
ATTACHMENTS
Attachment A: Description of Approach to Customer Communication and Marketing
Attachment B: Customer Communication Materials
Attachment C: Frequently Asked Questions (FAQ) and Answers
Attachment D: Illustration of Customer Bill format & Customer Portal Display
Attachment E: Presentation
AUTHOR/TITLE:
Alan Kurotori, Director of Utilities
Staff: Karla Dailey, Assistant Director, Utilities Resource Management
Staff: Catherine Elvert, Utilities Communications Manager
Staff: Shiva Swaminathan, Senior Resource Planner
13 The transcript from the meeting is available on the City’s website:
https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=15106&compileOutputType =1.
14 June 2025 UAC Report: https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=61770
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8
9
2
8
Attachment A: Description of Approach to Customer Communication and Marketing
The goal of the electric time-of-use (TOU) communication and marketing plan is two-fold. The
first goal is to increase opt-in participation from residential customers and maximize customer
satisfaction. Since the new TOU rate is voluntary, staff will proactively and effectively market the
benefits to customers for a successful outcome. Many customers may not be familiar with the
concept of TOU and will need to learn what the rates are and what they mean for their monthly
bills. The second goal is to educate all customers about the environmental benefits of consuming
electricity during the 9 a.m. to 3 p.m. solar generation periods rather than during the 4 to 9 p.m.
peak period.
Communication materials will first define what TOU rates are. Traditionally, electric rates have
been structured with average electricity prices. Collateral will be developed to explain that this
type of rate aligns the changing costs of the electric supply with the rate customers pay, and
that depending on supply and demand, electricity costs can change. Outreach materials will
explain how TOU works, and the associated rules of the program. CPAU will reinforce that
enrolling in TOU is optional, and to ease customer anxieties about trying something new, that
there are no penalties for returning to standard rates. However, once a customer switches to
TOU, they must stay on the rate for a minimum of six (6) months).
To aid in the communication, outreach messaging may include common analogies to help
explain how TOU rates compare to traditional rates. For example, TOU rates can be likened to
supply and demand basics. When supplies are short and demand is high, the cost can go up.
Additionally, consumers often change when they purchase items to take advantage of discounts
or sales and save money. It will be helpful to provide examples of popular household items
(washing machines, dishwashers, televisions, etc.) that may go on sale at certain times to
compare an estimated price during peak and off-peak hours.
CPAU will focus on customer-centric messaging in outreach materials, highlighting the benefits
of a TOU rate for customers. TOU rates can help customers save money by shifting usage to off-
peak hours and gain greater control over their utility bills, particularly for high-energy using
appliances. Outreach messaging and graphic design will convey these potential savings to
customers as an incentive to opt-in to the TOU rate. Messaging will also highlight that, whether
a customer opts in to the TOU rate or not, shifting usage way from peak hours will contribute to
a cleaner environment by supporting grid stability and renewables integration. See attachment
C for drafts of potential marketing messaging that can be used across a variety of
communication channels.
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Communications will include information regarding:
The phased approach to implementing a TOU rate, and waitlist process for those who
cannot enroll immediately in the new rate structure.
How customers can speak with Utilities Customer Service to get personalized advice
about the TOU rate and how to access their billing data via the MyCPAU online utility
account management platform to perform their own analysis of how the TOU rate may
impact their utility bills.
Eligibility requirements and program rules.
Profiles of a typical customer who may benefit from switching to the TOU rate.
Tips and tricks to get the most financial savings and environmental benefits from
electing the TOU rate.
solar
generation hours” to clearly communicate the environmental attributes of using energy during
these times.
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customer-centric decision-making, and ultimately supports TOU participation growth and a
stronger brand reputation. Customer survey questions will address issues of awareness,
understanding, reasons for opting in to a TOU rate, ease of access and enrollment process,
ability to shift energy use activities, realized benefits from shifting energy use and being on
TOU, and overall satisfaction of being on a TOU rate structure. A successful marketing campaign
for voluntary TOU rates will prioritize personalization, clear and transparent communication,
targeted outreach, and robust customer education. By doing so, CPAU strives to foster trust,
maximize participation, and help residential customers realize both financial savings and
environmental benefits.
Time-of-Use (TOU) Rate Roll Out & Communication Plan Timeline
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Phased Enrollment of TOU Rate to Customers
Communicate directly to hand-selected customers for recruitment
Enroll hand-selected customers - 10 per month
Enrollment via webform requests - 50 per month
Open enrollment to all - including NEM2 customers
Targeted & One-on-One Communication
Fact sheet for Utilities Customer Service
Seek feedback from hand-selected customers
Customer Service (CSRs) respond to customer inquiries via phone/email
Mass Communication & Outreach Plan
Finalize draft messaging and graphics
Website with FAQs, rate comparison tool, savings tips (ongoing updates)
Stakeholder outreach (City Council, UAC, neighborhood groups)E-newsletters
Utility bill inserts
Utilities and Community Announcements section of bill
Social media
Video development
Local media engagement
Community outreach events
Customer feedback surveys & testimonials
Ongoing education, monitoring, and customer support
Metrics evaluation
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Persons with disabilities who require materials in an appropriate alternative format,
auxiliary aids, or modifications to policies or procedures to access City meetings,
programs, or services should contact the City’s ADA Coordinator George Hoyt at
(650) 329-2550 or by emailing ADA@paloalto.gov.
8/25 Printed on 100% post-consumer recycled paper, bleached without chlorine
INTRODUCING A NEW
TIME-OF-USE ELECTRIC RATE!
9:00 AM-3:00 PM is your time to maximize your
electric consumption, reducing costs and emissions.
A Time-of-Use (TOU) rate is a type of utility billing arrangement
in which the amount you pay for electricity changes based on the time of day you
use power. With the current residential electric billing (E-1) rate, you pay the same
amount for electricity regardless of when you use it.
With the new TOU rate (E-1-TOU), your electric rate changes based on
when you use power:
Highest rates (Peak): 4 PM-9 PM
Lowest rates (Super Off-Peak): 9 AM-3 PM
Mid-range rates (Off-Peak): All other times
Palo Alto Utility customers have the choice of staying on the E-1 rate or
switching to the new rate. The TOU rate works best for customers who:
Curious about how TOU may impact your bill?
Email utilitiescustomerservice@paloalto.gov with your address
for a custom TOU bill impact assessment. We’ll analyze your past 6-12 months
of usage to show howthe TOU rate could affect your bill.
Starting January 1, 2026, customers can enroll for a TOU rate plan
by completing our online enrollment form.
Learn more at paloalto.gov/TOU
Use more than
800 kilowatt hours
(kWh) per month
Have an electric
vehicle (EV) or plan
to get one
Can shift major
electricity use to
9 AM-3 PM
Want to support
clean energy and
grid decarbonization
Attachment B Item #3
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Persons with disabilities who require materials in an appropriate alternative format,
auxiliary aids, or modifications to policies or procedures to access City meetings,
programs, or services should contact the City’s ADA Coordinator George Hoyt at
(650) 329-2550 or by emailing ADA@paloalto.gov.
8/25 Printed on 100% post-consumer recycled paper, bleached without chlorine
PUT YOUR APPLIANCES
IN MIDDAY MODE.
Introducing a new Time-of-Use electric rate!
A Time-of-Use (TOU) rate is a type of utility billing arrangement in which the amount you
pay for electricity changes based on the time of day you use power. With the current
residential electric billing (E-1) rate, you pay the same amount for electricity regardless of
when you use it.
With the new TOU rate (E-1-TOU), your electric rate changes based on when you use power:
Highest rates (Peak): 4 PM-9 PM
Lowest rates (Super Off-Peak): 9 AM-3 PM
Mid-range rates (Off-Peak): All other times
Palo Alto Utility customers have the choice of staying on the E-1 rate or
switching to the new rate. The TOU rate works best for customers who:
Curious about how TOU may impact your bill?
Email utilitiescustomerservice@paloalto.gov with your address for a custom TOU bill
impact assessment. We’ll analyze your past 6-12 months of usage to show how
the TOU rate could affect your bill.
Starting January 1, 2026, customers can enroll for a TOU rate plan by completing
our online enrollment form.
Learn more at paloalto.gov/TOU
Use more than
800 kilowatt hours
(kWh) per month
Have an electric
vehicle (EV) or plan
to get one
Can shift major
electricity use to
9 AM-3 PM
Want to support
clean energy and
grid decarbonization
Item #3
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Persons with disabilities who require materials in an appropriate alternative format,
auxiliary aids, or modifications to policies or procedures to access City meetings,
programs, or services should contact the City’s ADA Coordinator George Hoyt at
(650) 329-2550 or by emailing ADA@paloalto.gov.
8/25 Printed on 100% post-consumer recycled paper, bleached without chlorine
HIT THE SWEET SPOT FOR
LOWER ENERGY COSTS.
00 p.m. - 9:00 a.m.
HHoours of modest ener
age, with higher rates
4:00 - 9:00 p.m.
Peak ene use
hours with typicall
hi her rates
9:00 a.m.
The most e
efficient tim
iances,
h
- 3:00 p.m
conom call
to use your
EV cha er,
v
Introducing a new Time-of-Use electric rate!
A Time-of-Use (TOU) rate is a type of utility billing arrangement in which the amount you
pay for electricity changes based on the time of day you use power. With the current
residential electric billing (E-1) rate, you pay the same amount for electricity regardless of
when you use it.
With the new TOU rate (E-1-TOU), your electric rate changes based on when you use power:
Highest rates (Peak): 4 PM-9 PM
Lowest rates (Super Off-Peak): 9 AM-3 PM
Mid-range rates (Off-Peak): All other times
Palo Alto Utility customers have the choice of staying on the E-1 rate or
switching to the new rate. The TOU rate works best for customers who:
Curious about how TOU may impact your bill?
Email utilitiescustomerservice@paloalto.gov with your address for a custom TOU bill
impact assessment. We’ll analyze your past 6-12 months of usage to show how
the TOU rate could affect your bill.
Starting January 1, 2026, customers can enroll for a TOU rate plan by completing
our online enrollment form.
Learn more at paloalto.gov/TOU
Use more than
800 kilowatt hours
(kWh) per month
Have an electric
vehicle (EV) or plan
to get one
Can shift major
electricity use to
9 AM-3 PM
Want to support
clean energy and
grid decarbonization
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Attachment C: Frequently Asked Questions and Answers (FAQ)
What is Time-of-Use (TOU) rate? How is it different from my current billing rate?
A Time-of-Use (TOU) rate is a type of utility billing arrangement in which the amount
you pay for electricity changes based on the time of day you use electricity. With the
current residential electric billing (E-1) rate, you pay the same amount for electricity
regardless of the time of day you use it. Your billing rate increases after you use a
certain amount of electricity each month, which is called tiered pricing.
With the TOU rate (E-1 TOU), your electric rate changes based on when you use
power:
Highest rates: 4 p.m. to 9 p.m. (peak-hours)
Lowest rates: 9 a.m. to 3 p.m. (super-off-peak hours)
Mid-range rates: All other times (off-peak)
E-1 (Tier 1 and Tier 2) and Summer E-1 TOU Rate for Fiscal Year (FY) 2026
E-1 (Tier 1 and Tier 2) and Winter E-1 TOU Rate for Fiscal Year (FY) 2026
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How can I save money by switching to TOU rates?
Charge your electric vehicle (EV) between 9 a.m. to 3 p.m. and not during peak
hours from 4 p.m. to 9 p.m.
Charge your battery between 9 a.m. and 3 p.m. and discharge it between 4 p.m.
and 9 p.m.
Pre-cool your home in the summer before 4 p.m.
Start or program large appliances like your dishwasher, washing machine or
clothes dryer to run and finish before 4 p.m. or start after 9 p.m.
If you have an electric heat pump water heater or space heating system, observe
when they are turning on and try to adjust your heating needs to off-peak periods.
If you have programmable smart appliances or smart electric panels, program
them for optimal use of appliances.
:
Have an electric vehicle (EV) or plan to get one.
Have a battery energy storage system (BESS) or plan to get one.
Can shift major electricity use between 9 a.m. to 3 p.m. and away from 4 p.m. to
9 p.m.
Want to support the use of clean energy and grid decarbonization.
Consume higher amounts of electricity, typically more than 600 to 800 kilowatt
hours (kWh) per month.
Use lower amounts of electricity, typically less than 600 kWh per month.
Cannot adjust the times when electricity is used to off-peak hours.
Prefer uniform pricing every hour of the day.
Get a personalized estimate by emailing utilitiescustomerservice@paloalto.gov with
your address and account number for a custom TOU bill impact assessment. We'll
analyze the last 12 months of your electricity usage to show how the TOU rate could
affect your bill. This estimate assumes your future consumption patterns remain the
same as your historical usage. Note: The estimate is available to customer who have
12-months of hourly advanced meter data.
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Your bill impact under a TOU rate structure depends on how much you are able to
adjust what time of day you use electricity. The more you are able to use electricity
during the less expensive solar generation hours of 9 a.m. to 3 p.m., the more you can
save on your monthly utility bill.
Illustrative Numeric Example:
Table A: Bill Impact: Average Use (450kWh/month)
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this use is due to electrification such as electric vehicle (EV) charging. We assume this
customer is consuming half of this additional electricity during off-peak hours and half
during the “super” off-peak period. Table B demonstrates that for EV charging timed to
avoid the peak cost period, the E-1-TOU rate is beneficial, saving this customer
approximately $56 per year.
Table B: Bill Impact: Average Use + 200 kWh of EV Charging
Attachment C: Bill Impact: Low, Average and High Usage
How do I switch to the TOU rate? Can I switch back?
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Starting January 1, 2026, customers can enroll for a TOU rate plan by completing our
online Enrollment Form. We'll process requests in the order received. Limited capacity
to accommodate early enrollees may delay your enrollment by up to 6 months until July
2026.
Will the TOU rate become mandatory in the future?
If Palo Alto's electric supply is carbon neutral, how does shifting my energy use
reduce greenhouse gas emissions?
How do I view my current monthly electric bill?
Current and historical bills
Daily and monthly electricity usage
Usage patterns by time of day
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Attachment D: Illustration of Customer Bill Format & MyCPAU Portal Display (in
development)
Table D1 below shows an illustration of how the TOU rate would be displayed in the customer
bill. Table D2 contains the TOU rates.
E1T is the short form that refers to the E-1 TOU rate; E1 is the default tiered rate
The electricity use during the three TOU periods are shown on the top table (491kWh,
130 kWh, 164kWh); total electricity use = 785 kWh (not displayed on the bill)
There are three components to the E1T rate: commodity (for each time of use period),
distribution and public benefits (as shown in table D2). On the bill, those three
components are shown separately.
Commodity costs associated with the three electricity use period are calculated as:
o E1T Peak Commodity = 164kWh * 23.354 cents/kWh = $38.30
o E1T Off Peak Commodity = 491 kWh * 8.249 cents/kWh = $40.50
o E1T Super Off Peak Commodity = 130 kWh * 6.69 cents/kWh = $8.70
Distribution costs associated with all time periods are calculated as:
o E1T Distribution = 785 kWh * 9.351 cents/kWh = $73.40
Public Benefit costs associated with all time periods are calculated as:
o E1T Public Benefits = 785 kWh * 0.604 cents/kWh = $4.74
Table D1: Illustration of a Residential Customer Bill under a TOU Rate
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Table D2: E-1 TOU Rate Components
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Illustration of Daily Consumption Chart
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Time-of-Use (TOU) Rate Implementation & Communication Plan
Utilities Advisory Commission
October 1, 2025 PaloAlto.gov
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TITLE 40 FONT BOLD
Subtitle 32 font
October 1, 2025
•June 4, 2025: Utilities Advisory Commission (UAC) recommended to City Council that
Palo Alto pursue a voluntary Time-of-Use (TOU) rate for residential customers.
•September 15, 2025: City Council approved the Time-of-Use rate schedule (E-1 TOU),
effective January 1, 2026.
•October 1, 2025: UAC review and discussion on implementation and communication
strategy for TOU.
•Review and discussion of:
Planned phased enrollment
Draft communication plan - Attachment A
Draft customer communication material - Attachment B
Overview
PaloAlto.gov
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TITLE 40 FONT BOLD
Subtitle 32 font
October 1, 2025
•Time-of-Use (TOU) rates are a type of electricity pricing where the cost of
electricity varies depending on the time of day it is used.
•Electricity prices lower during off-peak hours, and higher during peak hours.
•The TOU rate structure reflects the actual cost of supplying electricity at different
times.
•Benefits:
•Lower cost for utilities, lower cost for customers
•Reduces peak demand, alleviates stress on the electrical grid
•Reduces grid greenhouse gas (GHG) emissions
•Improves overall system reliability
Time-of-Use (TOU) Rates
PaloAlto.gov
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Subtitle 32 font
October 1, 2025
•January 2026: small-scale phased test enrollment, 10 customers per month
through March.
•Direct communication, no mass outreach.
•Goal:
•Verify accuracy of consumption data
•Seek customer feedback
•April-June 2026: expand enrollment up to 50 customers per month.
•Maintain waitlist for interested customers.
•Testing period may be extended if necessary for quality control.
•July 2026: open enrollment for all interested, including NEM 2 (not NEM 1)
TOU Phased Enrollment Plan
PaloAlto.gov
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TITLE 40 FONT BOLD
Subtitle 32 font
October 1, 2025
•Direct communication for phased enrollment and waitlist process.
•Spread awareness.
•Utilize all communication channels:
•Traditional
•Digital
•Media engagement
•Educate customers about TOU and benefits.
•Clearly communicate:
•Lowest rates (Super Off-Peak) 9 AM-3 PM
•Mid-range rates (Off-Peak) all other times
•Highest rates (Peak) 4 PM-9 PM
•How to maximize benefits.
•How to voluntarily switch to TOU.
Communication Strategy
PaloAlto.gov
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Subtitle 32 font
October 1, 2025 PaloAlto.gov
Outreach
•Utility bill inserts
•Direct mail
•Local print advertising
•Email newsletters
•Social media
•Website
•Customer Service
•Media engagement
•Community events
•Neighborhood groups
•Targeted outreach
•Feedback surveys
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TITLE 40 FONT BOLD
Subtitle 32 font
October 1, 2025
1.What is a Time-of-Use (TOU) rate? How is it different from my current billing rate?
2.Will I save money by switching to the TOU rate?
3.How can I save money by switching to the TOU rate?
4.How will TOU rates affect my monthly electric bill?
5.How do I switch to the TOU rate? Can I switch back?
6.Will the TOU rate become mandatory in the future?
7.If Palo Alto's electric supply is carbon neutral, how does shifting my energy use reduce
greenhouse gas emissions?
8.What are the potential carbon savings?
Frequently Asked Questions
PaloAlto.gov
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Educational Messaging
PaloAlto.gov
•Save money by shifting usage to off-peak hours.
•Approximate dollar savings for specific applications.
•Simple tips and strategies to help TOU customers maximize
benefits.
•Real-life examples of typical customer profiles that benefit
from switching to TOU.
•Shifting usage away from peak hours will contribute to
a cleaner environment by supporting grid stability
and renewables integration.
•Personalized rate analysis available from Customer Service.
October 1, 2025
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Subtitle 32 font
Display of Different Rate Schedules
PaloAlto.govOctober 1, 2025
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Display of Different Rate Schedules
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October 1, 2025
Examples from Other Utilities
PaloAlto.gov
Jackson Electric Membership CorporationSioux Valley Energy
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October 1, 2025
Examples from Other Utilities
PaloAlto.gov
Southern California Edison
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October 1, 2025
Examples from Other Utilities
PaloAlto.gov
Sacramento Municipal Utility District (SMUD)
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October 1, 2025 PaloAlto.gov
Sample Draft Utility Bill Inserts
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October 1, 2025
•Phased enrollment plan
•Draft communication plan - Attachment A
•Draft customer communication material - Attachment B
PaloAlto.gov
Discussion and Feedback
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Karla Dailey
Catherine Elvert
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Item No. 4. Page 1 of 1
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: October 1, 2025
Report #: 2509-5241
TITLE
Reaffirmation of the Carbon Neutral Plan and the Renewable Energy Credit Exchange Program;
CEQA Status: Not a project
This will be a late packet report published on September 26, 2025.
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Item No. 4. Page 1 of 7
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Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: October 1, 2025
Report #: 2509-5226
TITLE
Reaffirmation of the Carbon Neutral Plan and the Renewable Energy Credit Exchange Program;
CEQA Status: Not a project
RECOMMENDATION
Staff recommends that the Utilities Advisory Commission (UAC) recommend that the City
Council:
1) Reaffirm the Carbon Neutral Plan, including the use of Renewable Portfolio Standard
(RPS) eligible, unbundled RECs (Bucket 3 RECs) to neutralize any residual emissions
resulting from the use of an hourly emissions accounting methodology;
2) Reaffirm the continuation of the “REC Exchange Program,” whereby the City exchanges
bundled RECs from its long-term renewable resources (Bucket 1 RECs) for Bucket 3 RECs,
to the maximum extent possible, while maintaining compliance with the state’s RPS
regulations, in order to allocate additional revenues toward local decarbonization efforts;
and
3) Direct staff to return to the UAC and City Council in 2028 to provide another review of the
program’s impacts.
EXECUTIVE SUMMARY
In August 2020, the City Council approved amendments to the electric utility’s Carbon Neutral
Plan that clarified and modified policies regarding the sales and exchanges of renewable energy
credits (RECs) (Staff Report 115561). The amendments permitted the exchange of Bucket 1
(primarily in-state) RECs for Bucket 3 (primarily out-of-state) RECs, provided the City maintains
compliance with State Renewable Portfolio Standard (RPS) regulations. A portion of the earnings
from the program were directed to be used to offset electric operational costs and mitigate the
economic impacts of the coronavirus pandemic, and the remainder were reserved for local
decarbonization programs. Since then, staff has purchased and sold RECs for Calendar Years (CYs)
1 Staff Report 11556: https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/reports/city-
manager-reports-cmrs/year-archive/2020-2/id-11566.pdf
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2020 through 2025 in accordance with the Carbon Neutral Plan amendments, resulting in net
earnings of $28.7 million, or about $4.8 million per year.
3
BACKGROUND
4). The City has achieved its Carbon Neutral Plan
objectives each year starting in 2013, and due to its pursuit of these objectives, the City’s electric
supply portfolio currently easily exceeds the state’s Renewable Portfolio Standard (RPS)
procurement requirements.
5 to take
advantage of the significant cost difference between Bucket 1 and Bucket 3 RECs6 to generate
additional revenue for the City’s electric utility and to fund local decarbonization initiatives
(Resolution 99137, Staff Report 115568). The Council directed that for 2020 and 2021, two-thirds
of the proceeds from this program would go to electric operating cost reductions and one-third
toward local GHG emission reduction programs, and that for 2022 onward all of the earnings
would be devoted to emission reduction programs9.
3 These funds have been set aside for future local decarbonization spending, but to date the funding for these
efforts has come solely from Public Benefits funds, Low Carbon Fuel Standard revenues, and Gas Cap & Trade
allowance revenues.
4 Resolution 9322: https://www.paloalto.gov/files/assets/public/v/1/city-clerk/resolutions/reso-9322-33835.pdf
5 The exchange of bundled RECs from the City’s in-state, long-term renewable resources (Bucket 1 RECs) for RPS-
eligible, unbundled RECs (Bucket 3 RECs), which usually come from out of state sources.
6 Due to limitations on the use of Bucket 3 RECs for compliance with the state’s RPS mandate (only 10% of a
utility’s RPS procurement may consist of Bucket 3 RECs), a significant financial premium currently exists for in-state
bundled renewable energy resources (Bucket 1 RECs).
7 Resolution 9913: https://www.paloalto.gov/files/assets/public/v/1/city-clerk/resolutions/reso-
9913.pdf?t=40151.26
8 Staff Report 11556: https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/reports/city-
manager-reports-cmrs/year-archive/2020-2/id-11566.pdf
9 The exact funding mechanism for the local decarbonization spending is that an amount equivalent to at least one-
third of the revenues earned from the REC Exchanges would be allocated from the City’s Cap and Trade Reserve to
local decarbonization efforts.
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In December 2022, the City Council reviewed the results of the REC Exchange Program and voted
to reauthorize it. They also directed staff to return to the UAC and City Council in 2025 to provide
another review of the program’s impacts, which is the subject of this report.
ANALYSIS
Carbon Neutral Plan Review
annual
accounting of the City’s load and its carbon neutral electric resources: an electric supply portfolio
with “annual net zero greenhouse gas (GHG) emissions, measured at the Citygate, in accordance
with The Climate Registry’s Electric Power Sector protocol for GHG emissions measurement and
reporting.” At the time this definition was adopted, this was the most granular accounting
approach feasible (given the lack of hourly grid emissions data) or necessary (given the small
amount of solar capacity installed at that point, and the resulting emissions profile of grid
electricity).
hourly carbon emissions accounting standard. This modification was made
because: (a) hourly grid emissions data had recently become available, and (b) the large volume
of solar generation on the grid at that point had yielded a wide variation in grid emissions
intensities over the course of the year and any given day.
REC Exchange Program Results (2020-2025) and Projections (2026-2030)
17 These REC Exchange transactions have yielded a total of $28.7 million in net
revenue, or about $4.78 million per year.
17 Staff has purchased additional Bucket 3 RECs and sold additional Bucket 1 RECs during this time period (96,198
additional RECs purchased and 49,814 additional sold); however, these are RECs that would have been bought or
sold anyway. The Bucket 3 REC purchases were needed to satisfy the City’s Carbon Neutral Plan goals during a
drought period (in 2021 and 2022), and the Bucket 1 RECs were sold because the City had an overall surplus of
such supplies relative to its RPS procurement requirements. The analysis in this report includes only the REC
transactions that were the direct result of the approval of the REC Exchange Program.
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Table 1: Summary of REC Exchange Transactions and Revenue, CY 2020-2025
19 (MWh)325,186 287,210 179,290 223,362 160,000 115,000
3.59 4.01 2.68 9.03 11.47 3.88
1.10 1.47 0.91 1.33 0.75 0.45
2.48 2.54 1.77 7.71 10.72 3.43
20.8%35.0%38.9%39.1%41.0%46.0%
When presenting the REC Exchange Program to Council for approval in 2020, staff estimated that
it would generate roughly $3.0 million per year in net revenue for FY 2021-2025, with a significant
tapering off thereafter due to the steady increases in the statewide RPS requirement level. Actual
net revenues have thus far come in significantly higher than this initial estimate, largely due to a
huge spike in Bucket 1 REC prices that occurred in 2023 and 2024.
Over the next five years, staff estimates that the program will yield approximately $9.5 million in
total net revenue, or $1.9 million per year, as shown in Table 2 below. The REC Exchange
Program’s earnings are projected to decline sharply in future years, primarily due to the ramping
up of the state’s RPS requirement levels, which reduces the volume of Bucket 1 supplies the City
is able to sell. In addition, the City has begun to experience load growth in recent years (including
a 12% increase from 2022 to 2024), and some of the City’s older renewable energy contracts are
set to expire in the coming years; both factors further reduce the volume of Bucket 1 supplies
available to exchange.
155,000 177,000 130,000 48,000 8,000
3.87 4.43 3.25 1.20 0.19
0.93 1.15 0.91 0.36 0.06
2.94 3.28 2.34 0.84 0.13
50%52%55%57%60%
19 The volume of PCC1 RECs that are sold and the volume of PCC3 RECs that are purchased, pursuant to the REC
Exchange Program.
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Impact on Palo Alto’s Supply Portfolio
As discussed in Staff Report 1155621, although exchanging in-state RECs for out-of-state RECs has
no real impact on the City’s total electricity-related carbon emissions, the downside of this
strategy is that it has a negative impact on the City’s reported portfolio make-up and carbon
emissions. California’s RPS law gives preferential treatment to in-state renewable resources over
out-of-state resources, and the same is true of how such resources are reported to customers on
the annual Power Content Label (PCL). The California Energy Commission’s (CEC’s) PCL
regulations require that utilities report their out-of-state (Bucket 3) REC purchases as
“unspecified sources of power” rather than under the appropriate renewable energy technology
category. Furthermore, utilities are now required to report the annual average GHG emissions
intensity of their electric supply on their PCLs—and again, rather than being treated as carbon-
free resources like other forms of renewable energy, Bucket 3 RECs are treated as having an
emissions intensity equivalent to generic market power purchases (944 lbs of CO2 per MWh,
which is almost 20% greater than the average emissions intensity of natural gas generation).
As a result, rather than reporting a supply mix that is over 60% renewable and nearly
carbon-free,22 under the REC Exchange Program the City must report a portfolio mix that is less
than 40% renewable and is responsible for a moderate amount of carbon emissions. Figure 1
below depicts the City’s projected electric supply portfolio mix in CY 2025, before and after
accounting for the REC Exchange Program transactions. Meanwhile, the estimated annual
average GHG emissions intensities that the City would report on its PCL for these two portfolios
are 45 and 159 lbs CO2 per MWh, respectively.23
21 Staff Report 11556: https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/reports/city-
manager-reports-cmrs/year-archive/2020-2/id-11566.pdf
22 Although the City’s baseline portfolio mix is entirely comprised of renewables and hydroelectric resources, the
CEC’s PCL regulations assign a small emission intensity to all biomass generation such as landfill gas generation,
which currently accounts for about 9% of the City’s baseline electric supply mix.
23 For reference, the statewide average GHG emissions intensity for CY 2024 was 359 lbs CO2 per MWh, while the
City’s average GHG emissions intensity as reported on its PCL (and accounting for the REC Exchange Program
transactions) was 21 lbs CO2 per MWh. The City’s emissions intensity is projected to be higher for CY 2025 than for
CY 2024 because of a significant decline in hydroelectric generation this year.
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Figure 1: Projected Electric Supplies in CY 2025, with and without REC Exchange Transactions
Use of REC Exchange Funds
Of the $28.65 million in net revenue that the REC Exchange Program has brought in since 2020,
$3.35 million of it has been directed towards general electric operating cost reductions (in
accordance with Council’s direction that two-thirds of the net proceeds should be used in this
way for 2020 and 2021, to offset the impacts of the pandemic) and the remaining $25.3 million
has been set aside for future spending on local decarbonization programs.27 If the
recommendation to continue the REC Exchange Program is approved, all of the net revenue from
the program (whose estimates are shown in Table 2) would be used for these decarbonization
efforts. To date, the programs that this funding has supported include the advanced heat-pump
water heater (HPWH) pilot, the Home Efficiency Genie program, and multi-family building
electrification efforts.
Upon the approval of the recommendation, staff will continue to execute transactions to sell the
City’s in-state renewable resources and purchase out-of-state renewables for 2026 and beyond.
27 Again, the mechanism for funding the local decarbonization programs is that an amount equivalent to the net
revenues earned from the REC Exchanges would be allocated from the City’s Cap and Trade Reserve to local
decarbonization efforts. Although, if the REC Exchange Program’s net revenues exceed the revenues from selling
the electric utility’s Cap and Trade allowances in a given year, the local decarbonization funding allocation would
be limited by the Cap and Trade allowance revenue amount.
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In addition, staff will continue to report on the portfolio’s total GHG emissions under both an
hourly and an annual carbon accounting framework in the annual report to the City Council on
the City’s Renewable Procurement Plan, Renewable Portfolio Standard Compliance, and Carbon
Neutral Electric Supplies (usually presented in Q4 of each year).
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
AUTHOR/TITLE:
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Carbon Neutral Plan & REC
Exchange Program Review
Utilities Advisory Commission
October 1, 2025 Paloalto.gov
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Background
•2013 – Council approves the Carbon
Neutral Plan (annual accounting)
•2020 – Council updates Carbon Neutral
Plan (hourly accounting) and approves
REC Exchange Program
•2/3 of revenue allocated to
offsetting supply costs for 2020 and
2021; the remainder allocated to
local decarbonization efforts
•2022 – Council reauthorizes REC
Exchange Program
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REC Exchange Program Results – 2020 to 2025
2020 2021 2022 2023 2024 2025 Total
REC Exchange Volume 1 (MWh)325,186 287,210 179,290 223,362 160,000 115,000 1,290,048
Bucket 1 REC Sales Revenue ($M)3.59 4.01 2.68 9.03 11.47 3.88 34.66
Bucket 3 REC Purchase Cost ($M)1.10 1.47 0.91 1.33 0.75 0.45 6.01
Net Revenue ($M)2.48 2.54 1.77 7.71 10.72 3.43 28.65
RPS Level (%)20.8%35.0%38.9%39.1%41.0%46.0%
[1] The volume of PCC1 RECs that are sold and the volume of PCC3 RECs that are purchased, pursuant to the REC Exchange Program.
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REC Exchange Program Projections – 2026 to 2030
2026 2027 2028 2029 2030 Total
REC Exchange Volume 1 (MWh)155,000 177,000 130,000 48,000 8,000 518,000
Bucket 1 REC Sales Revenue ($M)3.87 4.43 3.25 1.20 0.19 12.95
Bucket 3 REC Purchase Cost ($M)0.93 1.15 0.91 0.36 0.06 3.42
Net Revenue ($M)2.94 3.28 2.34 0.84 0.13 9.54
RPS Level (%)50%52%55%57%60%
[1] The volume of PCC1 RECs that are sold and the volume of PCC3 RECs that are purchased, pursuant to the REC Exchange Program.
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REC Exchange Impact on 2025 Power Content Label
PCL Emissions Intensity:
•Baseline Portfolio: 45 lb CO2/MWh
•With REC Exchanges: 159 lb CO2/MWh
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Recommended Motion
The UAC recommends that the City Council:
1)Reaffirm the Carbon Neutral Plan, including the use of RPS-eligible, unbundled
RECs (Bucket 3 RECs) to neutralize any residual emissions resulting from the use of
an hourly emissions accounting methodology;
2)Reaffirm the continuation of the “REC Exchange Program,” whereby the City
exchanges bundled RECs from its long-term renewable resources (Bucket 1 RECs)
for Bucket 3 RECs, to the maximum extent possible, while maintaining compliance
with the state’s RPS regulations, in order to allocate additional revenues toward
local decarbonization efforts; and
3)Direct staff to return to the UAC and City Council in 2028 to provide another
review of the program’s impacts.
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Jim Stack, PhD
Senior Resource Planner
james.stack@paloalto.gov
(650) 329-2314
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