HomeMy WebLinkAbout2017-11-13 City Council Agenda Packet
City Council
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Monday, November 13, 2017
Special Meeting
Council Chambers
5:00 PM
Agenda posted according to PAMC Section 2.04.070. Supporting materials are available in
the Council Chambers on the Thursday 11 days preceding the meeting.
PUBLIC COMMENT
Members of the public may speak to agendized items; up to three minutes per speaker, to be determined by the presiding officer. If you wish to address the Council on any issue that is on this agenda, please complete a speaker
request card located on the table at the entrance to the Council Chambers, and deliver it to the City Clerk prior to
discussion of the item. You are not required to give your name on the speaker card in order to speak to the Council, but it is very helpful.
TIME ESTIMATES
Time estimates are provided as part of the Council's effort to manage its time at Council meetings. Listed times are estimates only and are subject to change at any time, including while the meeting is in progress. The Council
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 or to adapt to the participation of the public. To ensure participation in a particular item, we suggest arriving at the beginning of the meeting and remaining until the item
is called.
HEARINGS REQUIRED BY LAW
Applicants and/or appellants may have up to ten minutes at the outset of the public discussion to make their
remarks and up to three minutes for concluding remarks after other members of the public have spoken.
Call to Order
Special Orders of the Day 5:00-5:30 PM
1. Appointment of two Candidates to the Architectural Review Board and
Four Candidates to the Historic Resources Board for Terms Ending
December 15, 2020; and two Candidates to the Planning and
Transportation Commission for Terms Ending December 15, 2021
2. Special Recognition for Police and Fire Personnel who Responded to
the Wildfires in Napa, Sonoma, Lake, and Mendocino Counties in
October 2017
3. Meritorious Awards Recognizing the Cardiac Lifesaving Skills of two
Individuals at the 2017 Annual Moonlight Run & Walk
4. Proclamation Honoring Pickleball in Palo Alto
2 November 13, 2017
MATERIALS RELATED TO AN ITEM ON THIS AGENDA SUBMITTED TO THE CITY COUNCIL AFTER DISTRIBUTION OF THE AGENDA
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Agenda Changes, Additions and Deletions
City Manager Comments 5:30-5:40 PM
Oral Communications 5:40-5:55 PM
Members of the public may speak to any item NOT on the agenda. Council reserves the right to limit the duration of
Oral Communications period to 30 minutes.
Minutes Approval 5:55-6:00 PM
5.Approval of Action Minutes for the October 30, 2017 Council Meeting
Consent Calendar 6:00-6:05 PM
Items will be voted on in one motion unless removed from the calendar by three Council Members.
6.Adoption of a Resolution Declaring Weeds to be a Public Nuisance and
Setting January 22, 2018 for a Public Hearing for Objections to
Proposed Weed Abatement
7.SECOND READING: Adoption of an Ordinance of the Council of the City
of Palo Alto Repealing Chapter 9.17 (Personal Cultivation of Marijuana)
of Title 9 (Public Peace, Morals and Safety) of the Palo Alto Municipal
Code; Repealing Ordinance No. 4422; and Amending Chapters 18.04
(Definitions) and 18.42 (Standards for Special Uses) of Title 18
(Zoning) to Prohibit Medical Cannabis Dispensaries and Prohibit
Commercial Cannabis Activities, Except for Deliveries. Environmental
Assessment: The Ordinance is Exempt in Accordance With Section
15061(b)(3) of the California Environmental Quality Act (CEQA)
Guidelines (FIRST READING: October 30, 2017 PASSED: 9-0)
8.SECOND READING: Adoption of an Ordinance Updating the Fiscal Year
2018 Municipal Fee Schedule to Adjust Development Services
Department Fees (FIRST READING: October 2, 2017 PASSED: 7-1
Tanaka no, Scharff Absent)
9.Direct Staff to Return to Policy and Services Committee With
Amendments to the Municipal Code for the Regulation of Seismic
Vulnerable Buildings (Continued From October 16, 2017)
Action Items
Include: Reports of Committees/Commissions, Ordinances and Resolutions, Public Hearings, Reports of Officials,
Unfinished Business and Council Matters.
6:05-10:00 PM
10.PUBLIC HEARING: Adoption of a Resolution Certifying the Final
Environmental Impact Report (EIR) for the Comprehensive Plan
Update; a Resolution Adopting Findings Pursuant to the California
Environmental Quality Act (CEQA) Related to Significant Environmental
Q&A
MEMO
3 November 13, 2017
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Impacts, Mitigation Measures and Alternatives; a Statement of
Overriding Considerations and a Mitigation Monitoring and Reporting
Program; and a Resolution Adopting the Updated Comprehensive Plan
Dated June 30, 2017 With Desired Corrections and Amendments,
Which Comprehensively Updates and Supersedes the City's 1998-2010
Comprehensive Plan, Except for the Housing Element Adopted in
November 2014. (This is the Third Public Hearing; the First Hearing
was on October 23, 2017, Continued to October 30, 2017 and Further
Continued to November 13, 2017.)
Inter-Governmental Legislative Affairs
Council Member Questions, Comments and Announcements
Members of the public may not speak to the item(s)
Adjournment
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would like information on the City’s compliance with the Americans with Disabilities Act (ADA) of 1990, may
contact (650) 329-2550 (Voice) 24 hours in advance.
4 November 13, 2017
MATERIALS RELATED TO AN ITEM ON THIS AGENDA SUBMITTED TO THE CITY COUNCIL AFTER DISTRIBUTION OF THE AGENDA
PACKET ARE AVAILABLE FOR PUBLIC INSPECTION IN THE CITY CLERK’S OFFICE AT PALO ALTO CITY HALL, 250 HAMILTON AVE.
DURING NORMAL BUSINESS HOURS.
Additional Information
Standing Committee Meetings
Sp. Policy and Services Committee Meeting November 14, 2017
City/School Committee Meeting November 16, 2017
(THIS AGENDA PACKET WILL BE PRODUCED ON NOVEMBER 9, 2017)
Schedule of Meetings
Schedule of Meetings
Tentative Agenda
Tentative Agenda
Informational Report
City of Palo Alto Investment Activity Report for the First Quarter, Fiscal Year
2018
Council Roster
Public Letters to Council
Set 1
CITY OF PALO ALTO OFFICE OF THE CITY CLERK
November 13, 2017
The Honorable City Council
Palo Alto, California
Appointment of two Candidates to the Architectural Review Board
and Four Candidates to the Historic Resources Board for Terms Ending
December 15, 2020; and two Candidates to the Planning and
Transportation Commission for Terms Ending December 15, 2021
On November 13, 2017, the Council is scheduled to appoint two (2) candidates to the
Architectural Review Board (ARB) and four (4) candidates to the Historic Resources
Board (HRB) for terms ending December 15, 2020; and two (2) candidates to the
Planning and Transportation Commission (PTC) for terms ending December 15, 2021.
Voting will be by paper ballot.
Background
On October 24, 2017, the Council interviewed applicants for the ARB, HRB, and PTC.
Applications can be viewed online HERE. The recording of the interviews can be viewed
online HERE.
Architectural Review Board
Vote to appoint two (2) three-year terms on the Architectural Review Board (ARB) for
terms ending December 15, 2020. The first two candidates to receive at least five votes
(required) will be appointed.
The 3 ARB Candidates are as follows:
1. Wynne Furth (Incumbent)
2. Amie Neff
3. Osma Dossani Thompson
Historic Resources Board
Vote to appoint four (4) three-year terms on the Historic Resources Board (HRB) for
terms ending December 15, 2020. The first four candidates to receive at least five votes
(required) will be appointed.
The 7 HRB Candidates are as follows:
1. Martin Bernstein (Incumbent)
2. Carl Darling
3. Rita French
4. Gogo Heinrich
Page 2
5. Roger Kohler (Incumbent)
6. Michael Makinen (Incumbent)
7. Margaret Wimmer (Incumbent)
On October 24, 2017, Valerie Madeline Driscoll withdrew her application for the Historic
Resources Board.
Planning and Transportation Commission
Vote to appoint two (2) four-year terms on the Planning and Transportation
Commission (PTC) for terms ending December 15, 2021. The first two candidates to
receive at least five votes (required) will be appointed.
The 7 PTC Candidates are as follows:
1. Michael Alcheck (Incumbent)
2. Rebecca Eisenberg
3. David Hirsch
4. Rebecca Parker Mankey
5. Lisa Peschcke-Koedt
6. Rishiraj Pravahan
7. William Riggs
On October 23, 2017, Sarah Flamm withdrew her application for the Planning and
Transportation Commission. On October 24, 2017, Kate Jason-Moreau withdrew her
application for the Planning and Transportation Commission.
Department Head: Beth Minor, City Clerk
Page 3
City of Palo Alto (ID # 8654)
City Council Staff Report
Report Type: Special Orders of the Day Meeting Date: 11/13/2017
City of Palo Alto Page 1
Summary Title: Pickleball Proclamation
Title: Proclamation Honoring Pickleball in Palo Alto
From: City Manager
Lead Department: City Clerk
Attachments:
Attachment A: Proclamation Honoring Pickleball in Palo Alto
Proclamation
Honoring Pickleball in Palo Alto
WHEREAS, Pickleball is one of the fastest growing sports with more than 2.5 million participants
in the United States; and
WHEREAS, Pickleball is an intergenerational, low impact, competitive sport that is easy to learn,
inexpensive to play and promotes camaraderie, teamwork, kindness and enjoyment for individuals and
the community as a whole; and
WHEREAS, Pickleball volunteers and enthusiasts share their joy of Pickleball and build
community by providing nets, paddles, balls and a gathering place at Mitchell Park to host free drop-in
clinics; and
WHEREAS, the Palo Alto Chapter of the nonprofit Silicon Valley Pickleball Club reaches out to
Palo Altans of all generations, from youth to super seniors who may be isolated, to give them a
welcoming place to play Pickleball, which helps improve their physical, social, and emotional health;
and
WHEREAS, records show that the number of people who play Pickleball at Mitchell Park totals
over 300 participants each week on only three tennis courts; and
WHEREAS, the Bay Area Senior Games Pickleball event will be hosted by volunteers at Mitchell
Park next May for the third year running, which had 147 competitors last year, some over 80 years old;
and
WHEREAS, the Pickleball classes which have been taught by volunteers and offered in the City
of Palo Alto’s Enjoy! Catalogue have all been full; and
WHEREAS, the City of Palo Alto Parks and Recreation Commission has established an Ad Hoc
Committee focused specifically on promoting Pickleball in Palo Alto.
NOW, THEREFORE, I, H. Gregory Scharff, Mayor of the City of Palo Alto, on behalf of the
City Council do hereby proclaim appreciation for the sport of Pickleball and recognize the health and
wellness benefits it provides to the Palo Alto community.
Presented: November 13, 2017
______________________________
H. Gregory Scharff
Mayor
CITY OF PALO ALTO OFFICE OF THE CITY CLERK
November 13, 2017
The Honorable City Council
Attention: Finance Committee
Palo Alto, California
Approval of Action Minutes for the October 30, 2017 Council Meeting
Staff is requesting Council review and approve the attached Action Minutes.
ATTACHMENTS:
Attachment A: 10-30-17 DRAFT Action Minutes (DOCX)
Department Head: Beth Minor, City Clerk
Page 2
CITY OF PALO ALTO CITY COUNCIL
DRAFT ACTION MINUTES
Page 1 of 12
Special Meeting
October 30, 2017
The City Council of the City of Palo Alto met on this date in the Council
Chambers at 5:09 P.M.
Present: DuBois, Filseth, Fine, Holman, Kniss, Kou, Scharff, Tanaka,
Wolbach
Absent:
Special Orders of the Day
1. Introduction of Lord Mayor, Professor, Dr. Eckart Wuerzner of
Heidelberg, Germany and the Heidelberg Delegation.
Council took a break from 5:19 P.M. to 5:53 P.M.
Action Items
1A. Discussion and Consideration of the Planning & Transportation
Commission's Recommendations Regarding the Comprehensive Plan
Update and Adoption of Resolutions Certifying the Final Environmental
Impact Report (EIR) for the Comprehensive Plan Update; Adopting
Findings Pursuant to the California Environmental Quality Act (CEQA),
and Adopting the Updated Comprehensive Plan Dated June 30, 2017
With Desired Corrections and Amendments, Which Comprehensively
Updates and Supersedes the City's 1998-2010 Comprehensive Plan
(Two Public Hearings Will Be Held: October 23, 2017 and November
13, 2017. On October 23, 2017, the City Council may Consider Action
on the Planning & Transportation Commission’s Recommendations,
Providing Direction to Staff, and Certification of the Final EIR. Other
Actions Will be Deferred Until the Hearing on November 13, 2017.)
(CONTINUED FROM OCTOBER 23, 2017).
Public Hearing Continued at 5:57 P.M. from October 23, 2017.
Public Hearing closed at 6:33 P.M.
DRAFT ACTION MINUTES
Page 2 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
MOTION: Mayor Scharff moved, seconded by Council Member Filseth to
thank the Planning and Transportation Commission for their input and
thoughtful consideration of changes to the Comprehensive Plan.
MOTION: Council Member Wolbach moved, seconded by Council Member
Fine to:
A. Thank the Planning and Transportation Commission for their input and
thoughtful consideration of changes to the Comprehensive Plan; and
B. Replace Program L1.3.1 with Policy L-1.4, “commit to creating an
inventory of below market rate housing for purchase and rental. Work
with neighbors… that is affordable so that the City consistently attains
the quantified goals for housing production in the adopted Housing
Element.”
SUBSTITUTE MOTION: Council Member DuBois moved, seconded by
Council Member Filseth to:
A. Thank the Planning and Transportation Commission for their input and
thoughtful consideration of changes to the Comprehensive Plan; and
B. Upgrade Program L1.3.1 to Policy L-1.4.
SUBSTITUTE MOTION PASSED: 6-3 Fine, Kniss, Wolbach no
MOTION: Council Member DuBois moved, seconded by Council Member
Kou to:
A. Replace in Program L4.8.2, “for retail at Stanford” with “for non-profit
office, small medical office, or retail uses at Stanford;” and
B. Move Policy B-2.1, Program B4.2.1, Program B4.2.2, Program B4.6.2,
and Program B4.6.3 to the Land Use Element under Goal L-4 and
renumber the Business and Economics Element and Land Use Element
accordingly.
INCORPORATED INTO THE MOTION WITH THE CONSENT OF THE
MAKER AND SECONDER to add to the Motion Part A, “on non-ground floor”
after “retail uses.”
DRAFT ACTION MINUTES
Page 3 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
MOTION AS AMENDED RESTATED: Council Member DuBois moved,
seconded by Council Member Kou to:
A. Replace in Program L4.8.2, “for retail at Stanford” with “for non-profit
office, small medical office, or retail uses on non-ground floor at
Stanford;” and
B. Move Policy B-2.1, Program B4.2.1, Program B4.2.2, Program B4.6.2,
and Program B4.6.3 to the Land Use Element under Goal L-4 and
renumber the Business and Economics Element and Land Use Element
accordingly.
MOTION RESTATED: Council Member DuBois moved, seconded by Council
Member Kou to move Policy B-2.1, Program B4.2.1, Program B4.2.2,
Program B4.6.2, and Program B4.6.3 to the Land Use Element under Goal
L-4 and renumber the Business and Economics Element and Land Use
Element accordingly.
MOTION PASSED: 9-0
MOTION: Council Member Fine moved, seconded by Council Member
Wolbach to add a new Program L2.4.8, “identify development opportunities
for Below Market Rate housing and more affordable market rate housing on
publicly owned properties in a way that is integrated with and enhances
existing neighborhoods.”
AMENDMENT: Council Member Kou moved, seconded by Vice Mayor Kniss
to remove “market rate” after “more affordable” from the Motion.
AMENDMENT FAILED: 4-5 DuBois, Filseth, Kniss, Kou yes
MOTION PASSED: 6-3 Filseth, Holman, Kou no
MOTION: Vice Mayor Kniss moved, seconded by Council Member XX to
implement the Planning and Transportation Commission Priority 4 changes.
MOTION FAILED DUE TO THE LACK OF A SECOND
MOTION: Vice Mayor Kniss moved, seconded by Council Member Fine to
add to Program L4.6.1, “the Coordinated Area Plan should include a study of
the feasibility of converting parts of University Avenue to a pedestrian-only
zone.”
DRAFT ACTION MINUTES
Page 4 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
SUBSTITUTE MOTION: Mayor Scharff moved, seconded by Council
Member Wolbach to add a new Program, “study the feasibility of converting
parts of University Avenue to a pedestrian-only zone.”
AMENDMENT TO THE SUBSTITUTE MOTION: Council Member Tanaka
moved, seconded by Council Member XX to add to the Substitute Motion, “or
California Avenue” after “University Avenue.”
AMENDMENT TO THE SUBSTITUTE MOTION FAILED DUE TO THE LACK
OF A SECOND
AMENDMENT TO THE SUBSTITUTE MOTION: Council Member Fine
moved, seconded by Council Member XX to replace in the Motion,
“pedestrian-only” with “non-motorized only.”
AMENDMENT TO THE SUBSTITUTE MOTION RESTATED: Council
Member Fine moved, seconded by Council Member XX to replace in the
Motion, “pedestrian-only” with “bike and pedestrian-only.”
AMENDMENT TO THE SUBSTITUTE MOTION WITHDRAWN BY THE
MAKER
SUBSTITUTE MOTION RESTATED: Mayor Scharff moved, seconded by
Council Member Wolbach to add a new Program, “study the feasibility of
converting parts of University Avenue to a pedestrian zone.”
SUBSTITUTE MOTION PASSED: 9-0
MOTION: Council Member Wolbach moved, seconded by Vice Mayor Kniss
to add a new Program T1.2.5, “pursue full participation of Palo Alto
employers in the Palo Alto Transportation Management Association.”
MOTION PASSED: 9-0
MOTION: Council Member Filseth moved, seconded by Council Member
DuBois to:
A. Update Goal L-1 to “a compact and resilient city prioritizing diverse
and vibrant neighborhoods and compatibility with shopping and
services, work places, public facilities, parks, and open spaces;” and
B. Renumber Policy L-1.2 to Policy L-1.1 and replace “strengthen” with
“prioritize;” and
DRAFT ACTION MINUTES
Page 5 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
C. Move and renumber Policy L-1.1 to L-1.2.
AMENDMENT: Council Member Wolbach moved, seconded by Mayor
Scharff to remove Part A from the Motion.
AMENDMENT PASSED: 7-2 Holman, Kou no
MOTION AS AMENDED RESTATED: Council Member Filseth moved,
seconded by Council Member DuBois to:
A. Renumber Policy L-1.2 to Policy L-1.1 and replace “strengthen” with
“prioritize;” and
B. Move and renumber Policy L-1.1 to L-1.2.
MOTION AS AMENDED PASSED: 9-0
MOTION: Council Member Wolbach moved, seconded by Vice Mayor Kniss
to replace in Policy L-1.3, “promote infill development” with “Palo Alto has a
preference for infill housing. Infill development” and “that is compatible”
with “should be compatible.”
MOTION PASSED: 5-4 Filseth, Fine, Holman, Kou no
MOTION TO RECONSIDER: Council Member DuBois moved, seconded by
Mayor Scharff to reconsider the last Motion.
MOTION PASSED BY ACCLAMATION
MOTION: Council Member Wolbach moved, seconded by Vice Mayor Kniss
to replace in Policy L-1.3, “promote infill development” with “Palo Alto has a
preference for infill housing. Infill development” and “that is compatible”
with “should be compatible.”
MOTION FAILED: 2-7 Kniss, Wolbach yes
MOTION: Council Member Wolbach moved, seconded by Council Member
DuBois to add to the Introduction under the “Maintaining and Enhancing
Community Character” heading, “in residential neighborhoods, commercial
centers, and employment districts” after “best features” and “foster inviting
pedestrian-scale commercial centers and distinctive employment districts”
after “preserve neighborhoods.”
DRAFT ACTION MINUTES
Page 6 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
INCORPORATED INTO THE MOTION WITH THE CONSENT OF THE
MAKER AND SECONDER to replace in the Motion, “distinctive” with
“distinct.”
MOTION AS AMENDED RESTATED: Council Member Wolbach moved,
seconded by Council Member DuBois to add to the Introduction under the
Maintaining and Enhancing Community Character heading, “in residential
neighborhoods, commercial centers, and employment districts” after “best
features” and “foster inviting pedestrian-scale commercial centers and
distinct employment districts” after “preserve neighborhoods.”
MOTION AS AMENDED PASSED: 9-0
MOTION: Council Member DuBois moved, seconded by Council Member
Holman to add a targeted list of Community Indicators as identified by the
Comprehensive Plan Update Citizens Advisory Committee.
SUBSTITUTE MOTION: Council Member Fine moved, seconded by Mayor
Scharff to add a targeted list of Community Indicators including:
A. Measure, greenhouse gas emissions; Metric, 80 percent below 1990
emissions by 2030 (Sustainability and Climate Action Plan goal);
Recommended Monitoring Frequency, annually as part of Earth Day
Report; and
B. Measure, Vehicle Miles Traveled (VMT) per capita; Metric, decrease per
year; Recommended Monitoring Frequency, annually as part of Earth
Day Report; and
C. Measure, Jobs/Housing balance (expressed as a ratio of jobs to
employed residents); Metric, Ratio of jobs to employed residents;
Recommended Monitoring Frequency, every 4 years; and
D. Measure, Below Market Rate (BMR) units; Metric, number of units;
Recommended Monitoring Frequency, annually as part of report to
California Department of Housing and Community Development
(HCD); and
E. Measure, progress toward Housing Element goals; Metric, annual
report to HCD; Recommended Monitoring Frequency, annually as part
of report to HCD.
DRAFT ACTION MINUTES
Page 7 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
AMENDMENT TO THE SUBSTITUTE MOTION: Council Member Filseth
moved, seconded by Council Member XX to direct Staff to propose a list of
Community Indicators.
AMENDMENT RESTATED AND INCORPORATED INTO THE SUBSTITUTE
MOTION WITH THE CONSENT OF THE MAKER AND SECONDER to add
to the Substitute Motion, “direct Staff to propose up to three additional
Community Indicators.” (New Part F)
SUBSTITUTE MOTION AS AMENDED RESTATED: Council Member Fine
moved, seconded by Mayor Scharff to add a targeted list of Community
Indicators including:
A. Measure, greenhouse gas emissions; Metric, 80 percent below 1990
emissions by 2030 (Sustainability and Climate Action Plan goal);
Recommended Monitoring Frequency, annually as part of Earth Day
Report; and
B. Measure, Vehicle Miles Traveled (VMT) per capita; Metric, decrease per
year; Recommended Monitoring Frequency, annually as part of Earth
Day Report; and
C. Measure, Jobs/Housing balance (expressed as a ratio of jobs to
employed residents); Metric, Ratio of jobs to employed residents;
Recommended Monitoring Frequency, every 4 years; and
D. Measure, Below Market Rate (BMR) units; Metric, number of units;
Recommended Monitoring Frequency, annually as part of report to
California Department of Housing and Community Development
(HCD); and
E. Measure, progress toward Housing Element goals; Metric, annual
report to HCD; Recommended Monitoring Frequency, annually as part
of report to HCD; and
F. Direct Staff to propose up to three additional Community Indicators.
SUBSTITUTE MOTION AS AMENDED PASSED: 9-0
MOTION: Mayor Scharff moved, seconded by Vice Mayor Kniss to continue
Agenda Item Numbers 3- 285 Hamilton [17PLN-00309]… and 11- PUBLIC
HEARING/QUASI-JUDICIAL: 999 Alma… to a date uncertain.
DRAFT ACTION MINUTES
Page 8 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
MOTION: 9-0
Council took a break from 8:40 P.M. to 8:53 P.M.
At this time Council took up Agenda Item Numbers 4-10.
Minutes Approval
4. Approval of Action Minutes for the October 16, 2017 Council Meeting.
MOTION: Vice Mayor Kniss moved, seconded by Council Member Wolbach
to approve the Action Minutes for the October 16, 2017 Council Meeting.
MOTION PASSED: 9-0
Consent Calendar
MOTION: Mayor Scharff moved, seconded by Vice Mayor Kniss to approve
Agenda Item Numbers 5-9.
5. Resolution 9715 Entitled, “Resolution of the Council of the City of Palo
Alto Authorizing the City Manager to Regulate Operation of Personal
Delivery Devices, Also Known as Autonomous Robots Within the City of
Palo Alto for an Approximate 1-year Period.”
6. Approval of Amendment Number 1 to Contract Number S18169410
With Dixon Resources Unlimited in the Amount of $69,862 for a Total
Not-to-Exceed Amount of $100,762 to Conduct the California Avenue
Parking Management Study and Approval of a Budget Amendment in
the California Avenue Parking Permit Fund.
7. Approval of Salary Schedule Amendments for Service Employees
International Union (SEIU), Local 521 and the Utilities Management
Professional Association of Palo Alto (UMPAPA).
8. Approval of a 5-year Contract With EnvisionWare, Inc. for Maintenance
of the Automated Materials Handling Systems (AMHS) at Rinconada
and Mitchell Park Libraries for a Not-to-Exceed Amount of $448,634.
9. Approval of a Professional Services Agreement With BKF Engineers for
the Amount of $450,000 Over a 3-year Term for On-call Surveying and
Design Support Services.
MOTION PASSED: 9-0
DRAFT ACTION MINUTES
Page 9 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
Action Items (Continued)
10. Adoption of an Ordinance of the Council of the City of Palo Alto
Repealing Chapter 9.17 (Personal Cultivation of Marijuana) of Title 9
(Public Peace, Morals and Safety) of the Palo Alto Municipal Code;
Repealing Ordinance No. 4422; and Amending Chapters 18.04
(Definitions) and 18.42 (Standards for Special Uses) of Title 18
(Zoning) to Prohibit Medical Cannabis Dispensaries and Prohibit
Commercial Cannabis Activities, Except for Deliveries. Environmental
Assessment: The Ordinance is Exempt in Accordance With Section
15061(b)(3) of the California Environmental Quality Act (CEQA)
Guidelines.
MOTION: Mayor Scharff moved, seconded by Council Member Filseth to:
A. Find the proposed Ordinance exempt from the California
Environmental Quality Act (CEQA) in accordance with CEQA Guidelines
Section 15061(b)(3); and
B. Adopt an Ordinance prohibiting medical cannabis dispensaries and
prohibiting commercial cannabis activities in the City of Palo Alto
except for deliveries. The Ordinance would also repeal the temporary
ban on outdoor cultivation due to new State law that regulates outdoor
cultivation for personal use.
AMENDMENT: Council Member Fine moved, seconded by Council Member
Wolbach to add to the Motion, “using commercial cannabis regulations in
nearby cities and our existing Public Peace, Morals, and Safety Codes as
guides, direct Staff to return to Council within 6 months with options that
would:
i. Permit commercial cultivation, testing, manufacture, retail, and
distribution of cannabis; and
ii. Distinguish between sale and use on site; and
iii. Create a monitoring mechanism.
INCORPORATED INTO THE AMENDMENT WITH THE CONSENT MAKER
AND SECONDER to remove from the Amendment Part i, “cultivation,
testing, manufacture.”
INCORPORATED INTO THE AMENDMENT WITH THE CONSENT MAKER
AND SECONDER to add to the Amendment, “distinguish between
consumption by smoking versus other types of consumption.” (New Part iv)
DRAFT ACTION MINUTES
Page 10 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
INCORPORATED INTO THE AMENDMENT WITH THE CONSENT OF THE
MAKER AND SECONDER to add to the Amendment, “distinguish between
medical and recreational use.” (New Part v)
AMENDMENT TO THE AMENDMENT: Council Member Wolbach moved,
seconded by Council Member XX to replace “within 6 months” to “in 6 to 12
months.”
AMENDMENT TO THE AMENDMENT FAILED DUE TO THE LACK OF A
SECOND
AMENDMENT TO THE AMENDMENT: Council Member Wolbach moved,
seconded by Council Member XX to replace “return to Council” with “return
to the Policy and Services Committee, followed by the Planning and
Transportation Commission, and then Council.”
AMENDMENT TO THE AMENDMENT RESTATED AND INCORPORATED
INTO THE AMENDMENT WITH CONSENT OF THE MAKER AND
SECONDER to replace “return to Council” with “return to the Policy and
Services Committee.”
AMENDMENT AS AMENDED RESTATED: Council Member Fine moved,
seconded by Council Member Wolbach to add to the Motion, “using
commercial cannabis regulations in nearby cities and our existing Public
Peace, Morals, and Safety Codes as guides, direct Staff to return to the
Policy and Services Committee within 6 months with options that would:
i. Permit commercial retail and distribution of cannabis; and
ii. Distinguish between sale and use on site; and
iii. Create a monitoring mechanism; and
iv. Distinguish between consumption by smoking versus other types
of consumption; and
v. Distinguish between medical and recreational use.
AMENDMENT AS AMENDED FAILED: 2-7 Fine, Wolbach yes
MOTION PASSED: 9-0
At this time Council returned to Agenda Item Number 1A.
1A. Discussion and Consideration of the Planning & Transportation
Commission's Recommendations Regarding the Comprehensive Plan
DRAFT ACTION MINUTES
Page 11 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
Update and Adoption of Resolutions Certifying the Final Environmental
Impact Report (EIR) for the Comprehensive Plan Update; Adopting
Findings Pursuant to the California Environmental Quality Act (CEQA),
and Adopting the Updated Comprehensive Plan Dated June 30, 2017
With Desired Corrections and Amendments, Which Comprehensively
Updates and Supersedes the City's 1998-2010 Comprehensive Plan
(Two Public Hearings Will Be Held: October 23, 2017 and November
13, 2017. On October 23, 2017, the City Council may Consider Action
on the Planning & Transportation Commission’s Recommendations,
Providing Direction to Staff, and Certification of the Final EIR. Other
Actions Will be Deferred Until the Hearing on November 13, 2017.)
(CONTINUED FROM OCTOBER 23, 2017).
MOTION: Council Member DuBois moved, seconded by Council Member
Filseth to implement Planning and Transportation Commission Consensus
Item 1.
AMENDMENT: Council Member Wolbach moved, seconded by Council
Member XX to remove the proposed revision to Policy L-1.6.
AMENDMENT FAILED DUE TO THE LACK OF A SECOND
INCORPORATED INTO THE MOTION WITH THE CONSENT OF THE
MAKER AND SECONDER to add to the Motion, “add to Policy L-1.6, ‘such
as’ after ‘plans to guide development.’”
MOTION AS AMENDED RESTATED: Council Member DuBois moved,
seconded by Council Member Filseth to implement Planning and
Transportation Commission Consensus Item 1, and add to Policy L-1.6,
“such as” after “plans to guide development.”
MOTION AS AMENDED PASSED: 6-3 Fine, Kniss, Scharff no
MOTION: Mayor Scharff moved, seconded by Vice Mayor Kniss to accept no
additional Planning and Transportation Commission Consensus Items.
MOTION RESTATED: Mayor Scharff moved, seconded by Vice Mayor Kniss
to accept Planning and Transportation Commission Consensus Items 3, 6, 8,
and 9 and no additional Consensus Items.
MOTION PASSED: 9-0
MOTION: Mayor Scharff moved, seconded by Council Member Fine to
implement changes included in the Errata Table/Comp Plan Corrections and
Clarifications.
DRAFT ACTION MINUTES
Page 12 of 12
City Council Meeting
Draft Action Minutes: 10/30/17
MOTION PASSED: 8-1 Holman no
MOTION: Mayor Scharff moved, seconded by Council Member Holman to
continue this Item to November 13, 2017.
MOTION PASSED: 9-0
Agenda Changes, Additions and Deletions
None.
11. PUBLIC HEARING/QUASI-JUDICIAL. 999 Alma: Council Determination
on a Waiver Request From the Retail Preservation Ordinance.
Environmental Assessment: Exempt in Accordance With the California
Environmental Quality Act (CEQA) Section 15061(b)(3) Guidelines
(STAFF REQUESTS THIS ITEM BE CONTINUED TO A DATE
UNCERTAIN).
Study Session
3. 285 Hamilton [17PLN-00309]: Applicant Requests a Prescreening
Discussion for a Possible Text Amendment That Would Allow
Development Exceptions for Rooftop Decks Within the Downtown Area,
Including the Subject Property. Environmental Assessment: The
Subject Request is not a Project in Accordance With the California
Environmental Quality Act (CEQA).
Inter-Governmental Legislative Affairs
None.
Council Member Questions, Comments and Announcements
Council Member Holman requested an update regarding Council Contingency
Fund support of disaster relief for the North Bay fires.
Council Member Wolbach reported his attendance at the Santa Clara Valley
Transit Authority El Camino Real Rapid Transit Policy Advisory Committee.
The Committee recommended each member city consider participating in a
right-lane High Occupancy Vehicle (HOV) lane pilot along El Camino Real.
Adjournment: The meeting was adjourned at 11:03 P.M.
City of Palo Alto (ID # 8445)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 11/13/2017
City of Palo Alto Page 1
Summary Title: Declaration of Weeds a Nuisance
Title: Adoption of a Resolution Declaring Weeds to be a Public Nuisance and
Setting January 22, 2018 for a Public Hearing for Objections to Proposed
Weed Abatement
From: City Manager
Lead Department: Fire
Adoption of a Resolution Declaring Weeds to be a Public Nuisance and Setting January 22,
2018 for a Public Hearing for Objections to Proposed Weed Abatement For the 2018 Weed
Abatement Cycle
Recommendation
Staff recommends that Council adopt the attached resolution:
1) Declaring weeds to be a public nuisance;
2) Setting January 22, 2018 for a public hearing on objections to proposed weed
abatement; and
3) Directing staff to publish a notice of hearing in accordance with the provisions of the
Palo Alto Municipal Code.
Background
On April 18, 1977, the City Council approved an agreement with Santa Clara County for the
administration of weed abatement within the City of Palo Alto. This agreement has reduced
the City’s costs and staff time required for administration of weed abatement. For the past 40
seasons, the weed abatement program has been expeditiously carried out by the County
Department of Agriculture and Resource Management with results satisfactory to Palo Alto
residents.
Discussion
Palo Alto Municipal Code Chapter 8.08 specifies weed abatement procedures. The chapter
requires property owners or occupants to remove certain weeds, as defined in Section 8.08.010
that exist upon their premises, public sidewalks, streets or alleys. It also specifies the
procedures to be followed to abate weeds, in the event owners do not remove them. The
procedures:
City of Palo Alto Page 2
- Resolution of the City Council declaring weeds to be a public nuisance. This
resolution sets the time and place for hearing any objections to the proposed weed
abatement.
- Public Notice. This notice informs property owners of the passage of the resolution
and provides that property owners shall remove weeds from their property, or the
abatement will be carried out by Santa Clara County (County). The City then
publishes a legal advertisement in the local newspaper announcing the date of the
public hearing.
- Public Hearing. The Council must conduct a public hearing, at which time any
property owner may appear and object to the proposed weed destruction or
removal. After the City Council hearing and considering any objections the Council
may allow or overrule any or all objections. If objections are overruled, the County
will be asked to perform the work of destruction and removal of weeds. The action
taken by the Council at the November 13, 2017 meeting will set this public hearing
date for January 22, 2018.
Resource Impact
There is no direct fiscal impact of this action to the City. The City of Palo Alto administers the
weed abatement program with the County Department of Agriculture and Resource
Management with a minimal amount of staff time. All charges for the weed abatement
services are included as a special assessment on bills for taxes levied against the respective lots
and parcels of land. Such charges are considered liens on these properties.
The Weed Abatement Program is a cost recovery program and does not receive funding from
City or County general funds.
Policy Implications
This procedure is consistent with existing City policies.
Environmental Review
The Santa Clara County Counsel has determined the Weed Abatement Program to be
Categorically Exempt from CEQA pursuant to CEQA Guidelines Section 15308.
Attachments:
Attachment A: Weed Abatement Setting for Pub Hearing Resolution
1
Resolution No. ____
Resolution of Intention of the Council of the City of Palo Alto
Declaring Weeds to be a Nuisance and Setting January 22, 2018 for a
Public Hearing for Objections to Proposed Weed Abatement
R E C I T A L S
A. Weeds, as defined in Section 8.08.010(b) of the Palo Alto Municipal Code, are
anticipated to develop during calendar year 2018 upon streets, alleys, sidewalks, and parcels of
private property within the City of Palo Alto sufficient to constitute a public nuisance as a fire
menace when dry or are otherwise combustible, or otherwise to constitute a menace to the
public health as noxious or dangerous.
NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as follows:
SECTION 1. Weeds, as defined in Section 8.08.010(b) of the Palo Alto Municipal
Code, which are anticipated to develop during calendar year 2018 upon streets, alleys,
sidewalks, and parcels of private property within the City of Palo Alto, are hereby found and
determined to constitute a public nuisance. Such nuisance is anticipated to exist upon some of
the streets, alleys, sidewalks, and parcels of private property within the City, which are shown,
described, and delineated on the several maps of the properties in said City which are recorded
in the Office of the County Recorder of the County of Santa Clara, reference in each instance for
the description of any particular street, alley, or parcel of private property being hereby made
to the several maps aforesaid, and, in the event of there being several subdivision maps on
which the same lots are shown, reference is hereby made to the latest subdivision map.
SECTION 2. THEREFORE, IT IS ORDERED that the said public nuisance be abated in
the manner provided by Chapter 8.08 of the Palo Alto Municipal Code:
IT IS FURTHER ORDERED that a public hearing shall be held on the 22 day of
January, 2018 at the hour of 6:00 pm, or as soon thereafter as the matter may be heard, at the
Council Chambers of the Civic Center of said City, at which the Council shall hear objections to
the proposed weed abatement of such weeds and give any objections due consideration;
IT IS FURTHER ORDERED that the Fire Chief of the City of Palo Alto is directed to
give notice of the public hearing in the time, manner and form provided in Chapter 8.08 of the
Palo Alto Municipal Code.
SECTION 3. Unless the nuisance is abated without delay by the destruction and
removal of such weeds, the work of abating such nuisance will be done by the County of Santa
Clara Department of Agriculture and Resource Management Office on behalf of the City of Palo
Alto, and the expenses thereof assessed upon the lots and lands from which, and/or in the
front and rear of which, such weeds shall have been destroyed and removed.
2
SECTION 4. The Santa Clara County, County Counsel has determined the Weed
Abatement Program to be categorically exempt from the provisions of the California
Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15308.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
__________________________ _____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
__________________________ _____________________________
Senior Deputy City Attorney City Manager
_____________________________
Fire Chief
_____________________________
Director of Administrative Services
CITY OF PALO ALTO OFFICE OF THE CITY CLERK
November 13, 2017
The Honorable City Council
Palo Alto, California
SECOND READING: Adoption of an Ordinance of the Council of the City
of Palo Alto Repealing Chapter 9.17 (Personal Cultivation of
Marijuana) of Title 9 (Public Peace, Morals and Safety) of the Palo Alto
Municipal Code; Repealing Ordinance No. 4422; and Amending
Chapters 18.04 (Definitions) and 18.42 (Standards for Special Uses) of
Title 18 (Zoning) to Prohibit Medical Cannabis Dispensaries and
Prohibit Commercial Cannabis Activities, Except for Deliveries.
Environmental Assessment: The Ordinance is Exempt in Accordance
With Section 15061(b)(3) of the California Environmental Quality Act
(CEQA) Guidelines (FIRST READING: October 30, 2017 PASSED: 9-0)
This Ordinance is before you today for a second reading. It was first heard on October 30, 2017
where it was unanimously passed by the City Council.
ATTACHMENTS:
Attachment A: ORD Amending 9.17 Regulation of Marijuana (DOCX)
Department Head: Beth Minor, City Clerk
Page 2
NOT YET APPROVED
170503 th TS/ORD Amending 9.17
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Repealing Chapter 9.17
(Personal Cultivation of Marijuana) of Title 9 (Public Peace, Morals and Safety) of
the Palo Alto Municipal Code; Repealing Ordinance No. 4422; and Amending
Chapters 18.04 (Definitions) and 18.42 (Standards for Special Uses) of Title 18
(Zoning) to Prohibit Medical Cannabis Dispensaries and Prohibit Commercial
Cannabis Activities, Except for Deliveries.
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1: The Council of the City of Palo Alto finds and declares as follows:
A. On June 9, 1997, the Palo Alto City Council adopted uncodified urgency
Ordinance No. 4422 declaring the establishment and operation of medical cannabis
dispensaries to be a prohibited use under the City’s zoning ordinance.
B. On October 24, 2016, the Palo Alto City Council adopted Ordinance No. 5399,
prohibiting the outdoor cultivation of cannabis. That ordinance had a sunset date of one year
from the date the ordinance took effect.
C. On November 8, 2016, California voters passed Proposition 64, known as the
Adult Use of Marijuana Act (AUMA), which legalized the use, sale, and consumption of
recreational cannabis by persons 21 years of age and older.
D. In June 2017, the California Legislature passed SB 94, which consolidated the
state regulation of medical and recreational cannabis into the Medicinal and Adult Use
Cannabis Regulation and Safety Act (MAUCRSA), taking the place of the Medical Cannabis
Regulation and Safety Act and the AUMA.
E. The MAUCRSA provides base standards for personal cultivation of cannabis and
allows local jurisdictions to legislate additional standards. (See Health and Safety Code section
11362.2).
F. The MAUCRSA permits commercial cannabis activities subject to state licensure,
but preserves local governments’ authority to regulate or ban commercial cannabis activities.
(See, e.g., Business and Professions Code section 26200).
G. Medical cannabis dispensaries and commercial cannabis activities are not listed
in the City’s zoning code as permitted or conditionally-permitted land uses, making them
prohibited under the principles of permissive zoning provisions. (See, e.g., City of Corona v.
Naulls (2008) 166 Cal.App.4th 418). Nevertheless, the state may not necessarily recognize the
application of permissive zoning principles as to cannabis-related uses.
H. In order to protect the public health, safety, and welfare, the Palo Alto City
Council desires to replace the existing uncodified prohibition of medical cannabis dispensaries
NOT YET APPROVED
170503 th TS/ORD Amending 9.17
in Ordinance No. 4422 with new Code section 18.42.150 to prohibit medical cannabis
dispensaries and prohibit commercial cannabis activities, with the exception of deliveries. The
Palo Alto City Council also desires to repeal Ordinance No. 5399, codified at Chapter 9.17 of
Title 9 of the Palo Alto Municipal Code, in recognition of new state law regulating cultivation for
personal use.
SECTION 2. Chapter 9.17 of Title 9 of the Palo Alto Municipal Code is hereby repealed.
SECTION 3. Ordinance No. 4422 of the City of Palo Alto is hereby repealed.
SECTION 4. Chapter 18.04 of Title 18 of the Palo Alto Municipal Code is hereby
amended to add new subsection 18.04.030(a)(94.5) to read as follows:
(94.5) “Cannabis” means all parts of the plant Cannabis sativa Linnaeus, Cannabis indica, or
Cannabis ruderalis, whether growing or not; the seeds thereof; the resin, whether crude or
purified, extracted from any part of the plant; and every compound, manufacture, salt,
derivative, mixture, or preparation of the plant, its seeds, or resin. “Cannabis” also means the
separated resin, whether crude or purified, obtained from cannabis. “Cannabis” does not
include the mature stalks of the plant, fiber produced from the stalks, oil or cake made from the
seeds of the plant, any other compound, manufacture, salt, derivative, mixture, or preparation
of the mature stalks (except the resin extracted therefrom), fiber, oil, or cake, or the sterilized
seed of the plant which is incapable of germination. For the purpose of this Title, “cannabis”
does not mean “industrial hemp” as defined by Section 11018.5 of the Health and Safety Code.
(A) “Commercial cannabis activity” includes the cultivation, possession, manufacture,
distribution, processing, storing, laboratory testing, packaging, labeling, transportation, delivery
or sale of cannabis and cannabis products as provided for in Division 10 of the California
Business and Professions Code. “Commercial cannabis activity” does not include personal uses
allowed by Health and Safety Code sections 11362.1 and 11362.2 or personal medicinal uses
allowed by sections 11362.765 and 11362.77, as amended from time to time.
(B) “Cultivation” means any activity involving the planting, growing, harvesting, drying,
curing, grading, or trimming of cannabis.
(C) “Medical cannabis dispensary” is a facility where cannabis is made available for medicinal
purposes in accordance with any provision of state law that authorizes the use of cannabis for
medicinal purposes.
SECTION 5. Chapter 18.42 of Title 18 of the Palo Alto Municipal Code is hereby
amended to add new section 18.42.150 to read as follows:
18.42.150 Cannabis Cultivation and Commercial Activities
(a) Prohibition of commercial activities.
Commercial cannabis activity is not permitted.
NOT YET APPROVED
170503 th TS/ORD Amending 9.17
(b) Exception for qualified delivery services.
Notwithstanding the prohibition in section 18.42.150(a), delivery of cannabis from a business
located outside the City of Palo Alto is permitted subject to the conditions of California Business
and Professions Code section 26090, as amended from time to time. This section does not
permit any temporary, persistent, or fixed physical presence used for commercial cannabis
activities besides delivery vehicles in the active state of making a delivery to a specific person
and location
(c) Prohibition of medical cannabis dispensaries.
Medical cannabis dispensaries are not permitted.
(d) Regulations.
The City Manager is authorized to approve and enforce regulations consistent with this
section.
(e) Enforcement.
The City may enforce this section and its regulations in any manner permitted by law and is
entitled to recover all costs, including attorneys fees, related to enforcement. The violation of
this section is hereby declared to be a public nuisance and shall, at the discretion of the city,
create a cause of action for injunctive relief.
SECTION 6. Severability. If any provision, clause, sentence or paragraph of this
ordinance, or the application to any person or circumstances, shall be held invalid, such
invalidity shall not affect the other provisions of this ordinance which can be given effect
without the invalid provision or application and, to this end, the provisions of this ordinance are
hereby declared to be severable.
SECTION 7. CEQA. The City Council finds and determines that this Ordinance is not a
“project” within the meaning of section 15378 of the California Environmental Quality Act
(CEQA) Guidelines because it has no potential for resulting in physical change in the
environment, either directly or ultimately. In the event that this Ordinance is found to be a
project under CEQA, it is subject to the CEQA exemption contained in CEQA Guidelines section
15061(b)(3) because it can be seen with certainty to have no possibility of a significant effect on
the environment.
/ /
/ /
/ /
/ /
/ /
/ /
NOT YET APPROVED
170503 th TS/ORD Amending 9.17
SECTION 8. Effective Date. This ordinance shall be effective on the thirty-first date after
the date of its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSTENTIONS:
ABSENT:
ATTEST: APPROVED:
______________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: ____________________________
City Manager
______________________________
Deputy City Attorney
City of Palo Alto (ID # 8646)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 11/13/2017
City of Palo Alto Page 1
Summary Title: SECOND READING: Development Services Muni Fee Schedule
Title: SECOND READING: Adoption of an Ordinance Updating the Fiscal Year
2018 Municipal Fee Schedule to Adjust Development Services Department
Fees (FIRST READING: October 2, 2017 PASSED: 7-1 Tanaka no, Scharff
Absent)
From: City Manager
Lead Department: Development Services Department
This ordinance was first heard by the City Council on October 2, 2017 and was passed 7-1 with Council
Member Tanaka voting no, and Mayor Scharff absent. During the course of the staff presentation for a
second reading on October 23, 2017, this item was pulled from the consent calendar to address some
questions from the Council.
Staff has prepared answers to Council’s questions on a small set of fees that were addressed at the
October 23, 2017 City Council meeting.
1. Service conductor switch greater/less than 800 amps – why does the larger cost less than the
smaller ($209 v. $367)?
It is correct that “Greater than 800 amps” has a lower fee than “Less than 800 amps”, and these fees
were set based on an analysis of actual costs to inspect these types of applications. Inspections for the
larger are usually connected to larger scope projects that may have a combination of related inspections
and overlapping field review. The larger scale projects benefit from economies of scale and types of staff
assigned to each inspection.
In contrast, Less than 800 amps projects have higher fees because they are generally small scale projects
that require a single specialized inspection.
2. Landscape plan review – SF Residential - $1,193 seems out of scale with other fees; why is this
so high?
This fee includes compliance with regulations specific to landscaping, including a state mandated water
efficiency ordinance and the City of Palo Alto Urban Forest Master Plan requirements. The fee is based
on the 3.5 hours of intricate plan review required to cover both requirements. These fees are only
triggered for landscape plans attached to a building permit, if the square footage of landscape for new
City of Palo Alto Page 2
development is an area of 500 sq. ft. or more, or if the square footage of landscape for rehabilitated
projects is an area of 2,500 sq. ft. or more.
3. Carnivals and Fairs – please define what events trigger this and prior applications
This is a “legacy” Commercial permit that has been in our Muni Code for decades but has not been
assessed in recent memory.
This is designed to be used for large scale productions such as a circus, county fair, or carnival which
would require extensive review of site plans, egress routes, as well as tent, ride, generator and cooking
facility locations. This permit would also include several hours of on-site inspection (ride safety, tent
anchoring, exit signage, fire extinguishers, etc.) to ensure public safety.
City sponsored events and neighborhood or backyard events would not trigger this special permit and
are typically inspected by the on-duty Engine Company from the district in question. This allows the Fire
Department a no-cost means to promote public safety and goodwill, while also “pre-fire planning” how
best to handle any emergency that might occur at the venue.
4. Parade Float – please define what events trigger this and prior applications
This is a “legacy” Commercial permit that has been in our Muni Code for decades but has not been
assessed in recent memory. This permit was designed to be used for large scale parades requiring the
design review and inspection of dozens of mobile floats for fire resistance and structural integrity.
5. Place of Assembly – please define what events trigger this and prior applications
This Commercial permit is for long-term, ongoing, venues used as gathering places for groups larger
than 50 people. These would include restaurants, theaters, concert halls, etc. These facilities are
inspected (exiting, CO2 & propane, sprinkler & alarm systems, ansul systems, extinguishers, signage,
lighting, etc.) and permitted on an annual basis to ensure public safety. This fee does apply to non-
profits, schools, etc., but not outdoor events. Basically, this permit is for large rooms inside buildings
that are used for congregating.
6. Tent or Air Supported Structure – can you provide an example of this (if not a jumpy house)?
Please define what events trigger this and prior applications. Also a question of whether this applies
to city sponsored events.
The Fire Department is bound by the California Fire Code (CFC Sec. 3103.2) to permit tents and
membrane structures in excess of 400 square feet. This standard exists to protect the public
from poorly engineered and improperly anchored structures which have been known to injure
and even kill individuals due to collapse, fire, or becoming airborne in strong winds.
The Fire Department follows the guideline set forth by the CFC to review any proposed structure
which exceeds the minimum square footage. Working with the Building Department, a
determination is made whether the proposed structure warrants a review of the engineering
City of Palo Alto Page 3
and anchoring systems (as well as proposed: egress paths, exiting signage, and location of
electrical/heating/extinguishers/etc.), at which time the permit fee would be assessed.
This Commercial permit has been used for structures on the order of HP’s 20,000 square foot “tent”
(April 2016), and has never been applied to a “jumpy house”.
City sponsored events and small neighborhood or backyard events would not trigger this permit and are
typically inspected by the on-duty Engine Company from the district in question. This allows the Fire
Department a no-cost means to promote public safety and goodwill while also “pre-fire planning” how
best to handle any emergency that might occur at the venue.
Conclusion
In an effort to clarify that many of the permits in question are geared toward commercial scale events,
Staff is proposing to modify the fee titles as part of the FY 19 budget process while eliminating seldom
used fees and making minor adjustments to any fees that need to be realigned to be fully cost
recoverable.
Attachments:
Attachment A: Ordinance for the FY 18 Muni Fee Schedule to Adjust Development
Services Fees
Not Yet Approved
1
Ordinance No. ____
Ordinance of the Council of the City of Palo Alto to Update the Fiscal Year 2018
Municipal Fee Schedule to Adjust Development Services Department Fees
The City Council of the City of Palo Alto does hereby ORDAIN as follows:
SECTION 1. Findings and declarations.
A. In 2016, the Development Services Department completed Phase I of a fee study to
update certain non‐valuation‐based fees for services, reserving an update of valuation‐based
fees for Phase II of the fee study.
B. In 2017, the Development Services Department completed Phase II of the fee study,
which recommended adjustments to the Department’s valuation‐based fees, the adoption of
an operating reserve, and associated changes.
C. On September 19, 2017, the Finance Committee reviewed the fee study and
recommended adoption of an ordinance updating Development Services Department fees in
accordance with the study’s recommendations, adjusted by the annual salary and benefits
adjustment of 5.5 percent.
SECTION 2. The Council of the City of Palo Alto adopts the Development Services
Department Reserve Fund Policy, as set forth in Exhibit “1” and incorporated herein by
reference.
SECTION 3. The Council of the City of Palo Alto adopts the changes to the Municipal
Fee Schedule as set forth in Exhibit "2" and incorporated herein by reference. When effective,
such fees shall supersede any prior inconsistent fees charged by the Development Services
Department.
SECTION 4. The amount of the new or increased fees and charges is no more than
necessary to cover the reasonable costs of the governmental activity, and the manner in which
those costs are allocated to a payer bears a fair and reasonable relationship to the payer's
burden on, or benefits received from, the governmental activity.
SECTION 5. Fees in the Municipal Fee Schedule are for government services provided
directly to the payor that are not provided to those not charged. The amount of this fee does
not exceed the reasonable costs to the City of providing the services. Consequently, pursuant to
Art. XIII C, Section l(e)(2), such fees are not a tax.
SECTION 6. Effective Date. The fee increases proposed for FY 2017 described in
Exhibit A shall become effective no sooner than sixty (60) days from the date of adoption of this
ordinance.
2
SECTION 7. CEQA. The adoption of user fees is exempt from environmental review
under the California Environmental Quality Act (CEQA). (See CEQA Guidelines Section 15273.)
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Deputy City Attorney City Manager
____________________________
Director of Development Services
____________________________
Director of Administrative Services
Page 1 of 2
Development Services Department
Reserve Fund Policy
Section 1. Purpose
The purpose of the Development Services Department Reserve Fund (DSDRF) is to build and
maintain an adequate level of unrestricted funds available to cover any unforeseen shortfalls
that arise outside of the regular budget planning process, as well as one‐time, nonrecurring
expenses that will build long‐term capacity The fund may not be used to create or hire new full
time benefited positions. The department intends for the operating reserve to be used and
replenished within a reasonable period of time. This policy will be implemented in conjunction
with the other financial policies of the City and is intended to support the goals and strategies
contained in those related policies and in strategic and operational plans.
Section 2. Definitions and Goals
The DSDRF is a designated fund set aside by action of the City Council. The target of the DSDRF
is equal to three (3) months of average recurring operating costs; with a range of 23 (minimum)
to 27 (maximum) percent with a target of 25 percent of average recurring operating cost.
The DSDRF is dynamic and will be reviewed and adjusted in response to internal and external
changes. In addition to calculating the actual reserve at the fiscal year‐end, the reserve fund
minimum, target and maximum can be adjusted by the Council as necessary each year during
the annual budget development process. These reserves will be reported to the Finance
Committee and City Council.
Section 3. Funding of Reserves
The DSDRF will be funded by a five (5) percent increase to all Development Services
Department fees as listed in the City’s Municipal Fee Schedule beginning in Fiscal Year 2018,
upon City Council approval, through Fiscal Year 2022. The City Council may, from time to time,
direct that a specific source of revenue be set aside for the DSDRF.
Section 4. Accounting for Reserves
The DSDRF will be recorded in the City’s accounting system and financial statements titled as
the Development Services Department Reserve Fund. The DSDRF will be maintained in
accordance with the City’s investment policy.
Section 5. Authority to Use the DSDRF
Authority to use the DSDRF will remain with the City Council. The City Manager will submit a
request to use the DSDRF to the City Council. The Director of Development Services
Department will prepare the report identifying the need for access to the DSDRF and confirm
that the use is consistent with the purpose of the reserves as described in this policy.
Determination of need requires analysis of the sufficiency of the current level of reserve funds,
the availability of any other sources of funds before using reserves, and evaluation of the time
period for which the funds will be required and replenished.
Exhibit 1
Page 2 of 2
Section 6. Fee or Rate Stabilization
DSDRF may be added to the Development Services Department revenue projections by action
of the City Council and held to manage the trajectory of future year rate increases.
Section 7. Reappropriation of DSDRF
At the end of each fiscal year the DSDRF will be reappropriated to the following fiscal year in
accordance with Palo Alto Municipal Code Section 2.28.090.
Section 8. Relationship to Other Policies
The City Manager maintains City Council approved policies, which may contain provisions that
affect the creation, sufficiency, and management of the DSDRF. It will be the responsibility of
the City Manager and Director of Administrative Services Officer to notify the Director of
Development Services if changes to city‐wide policies impact the DSDRF. These policies may be
City Council approved policies such as the Investment Policy or administrative policies within
the confines of the Municipal Code.
Section 9. Reporting, Monitoring and Review of Policy
The Director of Development Services is responsible for ensuring that the DSDRF is maintained
and used only as described in this policy. Upon approval of the use of DSDRF, the Director of
Development Services and the Director of Administrative Services will maintain records of the
use of funds and plan for replenishment. Staff will provide reports to the City Council within the
annual budget process, or sooner if warranted by internal or external events.
Exhibit 1
Municipal Fee Schedule
Proposed Fee
Business Registry Fee $50.00
Technology Surcharge
Note: This surcharge will be added to all fees in Development Services.
1.8% per fee
A. $1.00 ‐ $1,000.00 Delete
B. $1,000.01 ‐ $2,000.00 Delete
C. $2,000.01 ‐ $25,000.00 Delete
D. $25,000.01 ‐ $50,000.00 Delete
E. $50,000.01 ‐ $100,000.00 Delete
F. $100,000.01 ‐ $500,000.00 Delete
G. $500,000.01 ‐ $1,000,000.00 Delete
H. $1,000,000.01 and Up
Delete
Building Permit Fee Restructured to be 1.44% of Construction
Valuation based on the ICC Table
I. Building Demolition Permit $498.00
J. Commercial Interior Non‐Structural Demolition Permit $179.00
Commercial and Multi‐Family Projects greater than or equal to $25,000.00 in
Valuation
$305.00
See Above
Current Fee
$412.00 per permit
$1,895.94 for the first $100,000.00 plus $10.63 for each additional $1,000.00 or
fraction thereof, to and including
$500,000.00
$6147.94 for the first $500,000.00 plus $9.03 for each additional $1,000.00 or
fraction thereof, to and including
$1,000,000.00
$10,662.94 for the first $1,000,000.00 plus $7.12 for each additional $1,000.00 or
fraction thereof
If valuation exceeds $5,000,000.00, an alternative fee arrangement may be
established by the Chief Building Official to achieve full cost recovery.
$431.00 (does not include C&D fees) per permit
$196.00 (does not include C&D fees) per permit
Construction & Demolition
Building Permit Fees
$73.00 Base Fee
$73.00 for the first $1,000.00 plus $5.80 for each additional
$100.00 or fraction thereof, to and including $2,000.00
$131.00 for the first $2,000.00 plus $26.53 for each additional $1,000.00 or fraction
thereof, to and including
$25,000.00
$741.19 for the first $25,000.00 plus $19.69 for each additional $1,000.00 or
fraction thereof, to and including
$50,000.00
$1,233.44 for the first $50,000.00 plus $13.25 for each additional $1,000.00 or
fraction thereof, to and including
$100,000.00
DEVELOPMENT SERVICES
Business Registry
$50.00 per business
Miscellaneous
1.8% of each transaction
Building
Exhibit 2
Municipal Fee Schedule
Single Family and Two Family Projects greater than
$25,000.00 and less than $75,000.00 in Valuations1
$163.00
Single Family and Two Family Projects greater than
$75,000.00 in Valuation1
$210.00
A. Base Fee $115.00
B. New or Remodeled Square Footage Delete
Air Conditioners $70.00
Busway, Power Duct, or Floor Duct Per Foot $58.00
Conditional Utility Agreement $236.00
Each Additional Meter $153.00
Fixtures, Switches, and Outlets $58.00
Lighting, Power and/or Control Panel Board, Switchboard Cabinet or Panel $70.00
Motor $58.00
Motor Generator $441.00
Range, Electric Clothes Dryer, or Water Heater $58.00
Service Conductor/Switch ‐ Greater than 800 amp $209.00
Service Conductor/Switch ‐ Less than 200 amp Delete
Service Conductor/Switch ‐ Less than 800 amp $367.00
Special Circuit (Not Listed Herein)$58.00
Temporary Power Pole $58.00
Temporary Wiring for Construction $58.00
Commercial (Level 1 and 2)$357.00 plus $67.00 for each additional
station
Commercial (Level 3 and 4)$426.00 plus $83 for each additional
station
Residential (Level 1 and 2)$154.00
Residential (Level 3)$235.00
Commercial System (less than 10 kW)$557.00
Commercial System (10kW ‐ 49kW)$557.00
Commercial System (greater than 49kW)$748.00
Residential Systems (greater than 10kW)$357.00
$976.00 each
$340.00 each
$518.00 plus $102.00 for each additional station each
$188.00 per station
$264.00 per station
Electrical Permits ‐ Photovoltaic Systems
$600.00 each
$901.00 each
$181.00 each
$75.00 each
$75.00 each
$75.00 each
Electrical Permits ‐ Electrical Vehicle Charging Stations
$427.00 plus $83.00 for each additional station
$75.00 each
$75.00 each
$75.00 each
$75.00 each
$272.00 each
$136.00 each
$0.02 per square foot per square foot
$91.00 per unit
$75.00 each
$265.00 each
$75.00 each
$75.00 each
DEVELOPMENT SERVICES
$172.00 per permit
$252.00 per permit
Electrical Permits
$92.00 per permit
Exhibit 2
Municipal Fee Schedule
Residential Systems (less than 10kW)$165.00
Address Change $505.00 single; $244.00 each additional
All Other Publications $16.00
Construction/Maintenance Vehicles $80.00
Electric Service and Safety Inspection $197.00
Extension of Building Permit or Building Permit Application $79.00
Inspections and Investigations ‐ Outside Normal Business Hours
Note: Inspections and investigations outside normal business hours (2‐ hour minimum).
$369.00 per 1.5x OT Hour; $492.00 per
2.0x OT hour
Inspections and Investigations ‐ Unclassified
Note: Inspections and investigations for which no fee is specifically indicated (2‐hour
minimum).
$246.00
Reactivation of Expired Building Permit ‐ All Others $222.00
Reactivation of Expired Building Permit ‐ Final Inspection Only $256.00
Reactivation of Expired Building Permit Application $156.00
Real Property Research Fee (1‐hour minimum)$229.00
Records Retention $6.00 per plan sheet
Reinspection Fee ‐ Multi‐Family Residential and Non‐ Residential $137.00
Reinspection Fee ‐ Single Family Residential $76.00 each secondary inspection type;
$141.00 each primary inspection type per
Request for Release of Building Plans $77.00
Residential Inspection Guidelines
Note: Available free online
No Change
Alterations and additions for single and multifamily > 1,000 sq ft $728.00
Alterations and additions for single family and multifamily < 1,000 sq ft and
increases conditioned space
$441.00
If the project is over $100,000 Energy Star is required after 12 months of
occupancy
$144.00$140.00 per review
$247.00 each secondary inspection type; $315.00 each primary inspection type per
inspection
$85.00 each
$37.00 each
Green Building
$708.00 per review
$429.00 per review
50% of original Building Permit Fee not to exceed the full cost to perform
remaining inspections as determined by the Chief Building Official
$283.00 or 50% of original Building Permit Fee, whichever is less
$211.00 per permit plus Plan Check Fees as applicable per permit
$271.00 per hour
$6.00 per plan sheet
$315.00 each
$18.00 each
$81.00 per space per week. This includes FY 18 adjustment rate of 6%.
$169.00 per hour
$95.00 per application
$408.00 per 1.5x OT Hour; $544.00 per 2.0x OT hour
$254.00 per hour
$91.00 each
General & Miscellaneous Fees
$399.00 single address; $192.00 each additional address
DEVELOPMENT SERVICES
Exhibit 2
Municipal Fee Schedule
Landscape Inspection $190.00
Landscape Plan Review ‐ Non‐Residential & Multi‐Family $1,939.00
Landscape Plan Review ‐ Single Family Residential $1,193.00
Multi Family New Construction of 1‐3 (attached) units $949.00
Multi Family New Construction of 4 or More $1,523.00
New Commercial >50,000 SF $1,810.00
New Commercial 1,000 ‐ 25,000 SF $1,236.00
New Commercial 25,001 ‐ 50,000 SF $1,523.00
New Single Family $949.00
Tenant improvements, renovations or alterations > $200,000 in valuation (and
not triggered by a Calgreen Tier)
$662.00
Tenant improvements, renovations or alterations > 5,000 SF Note: includes
replacement or alteration of at least two of the following: HVAC systems, building
envelope, hot water system, or lighting system and project greater than $200,000
$662.00
A. Base Fee $115.00
B. New or Remodeled Square Footage Delete
Air Handlers up to and including 10,000 cfm $47.00
Boilers, Compressors and Absorption Systems: For the installation or
reloacation of each boiler or compressor up to 30 hp or each absorption
system up to and including 1,000,000 Btu/h
$93.00
Boilers, Compressors, and Absorption Systems: For the installation or
relocation of each boiler or compressor exceeding 30 hp, or each absorption
system exceeding 1,000,000 Btu/h
$93.00
Furnace, Flue and Associated Ducts $93.00
Miscellaneous
Note: For each appliance or piece of equipment regulated by this code, but not classed
in other appliance categories, or for which no other fee is listed.
$47.00
Process Piping System $46.00
Process Piping System ‐ Hazardous $47.00
Swimming Pool Heater $56.00
Ventilation and Exhaust $47.00$60.00 each
Plan Review Fees
$182.00 each
$182.00 each
$60.00 each
$60.00 per permit
$145.00 per permit
$72.00 per permit
$644.00 per review
Mechanical Permits
$92.00 per permit
$0.02 per square foot
$60.00 each
$122.00 each
$1761.00 per review
$1202.00 per review
DEVELOPMENT SERVICES
$1481.00 per review
$923.00 per review
$644.00 per review
$185.00 per inspection
$1886.00 per review
$1161.00 per review
$923.00 per review
$1481.00 per review
Exhibit 2
Municipal Fee Schedule
Additional Plan Review
Note: Required by changes, additions, or revisions to plans including Alternative Means
and Methods (2‐hour minimum). For Elective (3rd party) and over‐the‐counter reviews
(half hour minimum).
$191.00
Building Plan Check 75%
Certified Access Specialist (CASp) Review/Consultation $367.00
Elective Plan Check 35%
Fire and Life Safety Plan Check 54%
Public Works Plan Check 44%
Zoning Plan Check 35%
A. Base Fee $115.00
B. New or Remodeled Square Footage Delete
Atomospheric‐type vaccum Breakers $115.00
Backflow protective device other than atomospheric‐type $167.00
Gas Piping System $167.00
Industrial Waste Pretreatment Interceptor
Note: Including trap and vent, except kitchen‐type grease interceptors functioning as
fixture traps
$167.00
Medical Gas Piping System $167.00
Plumbing Fixtures
Note: For each plumbing fixture on one trap or a set of fixtures on one trap (including
water, drainage piping, and backflow protection).
$116.00
Plumbing Fixtures: For each building sewer $112.00
Rain Water Systems Delete
Solar Hot Water System
Note: Does not include Plan Check fee.
$167.00
Storm Drain System $167.00
Swimming Pool $56.00
Water Heater, Vent or Other $84.00
Water Piping
Note: Installation, alteration or repair of water piping, water treatment equipment or
both
$84.00
Clotheswasher System $70.00
Complex System $167.00
Simple System $70.00
SB 1473 Fee
$109.00 each
$109.00 each
Plumbing Permits ‐ Graywater Systems
$91.00 each
$217.00 plus plan review at cost
$91.00 plus plan review at cost
$91.00 each
$145.00 each
$91.00 each
$217.00 each
$217.00 each
$72.00 each
DEVELOPMENT SERVICES
$109.00 each
$217.00 each
$217.00 each
$217.00 each
$217.00 each
45% of Building Permit fee
12% of Building Permit fee
30% of Building Permit fee
Plumbing Permits
$92.00 per permit per permit
$0.02 per square foot
$225.00 per hour
80% of Building Permit fee
Actual cost of CASp Consultant plus 15% per hour. Restructured to a flat fee.
35% of Building Plan Check fee
Exhibit 2
Municipal Fee Schedule
A. $1.00 ‐ $25,000.00 Permit Valuation No change
B. $25,001.00 ‐ $50,000.00 Permit Valuation No change
C. $50,001.00 ‐ $75,000.00 Permit Valuation No change
D. $75,001.00 ‐ $100,000.00 Permit Valuation No change
E. Each $25,000.00 Increment or Fraction Thereof Above
$100,000.00
No change
F. Minimum No change
Commercial No change
Residential No change
Certificate of Use and Occupancy $1,095.00
Certificate of Use and Occupancy ‐ Replacement $228.00
SB 1186 Mandated Fee
Note: Does not include fees collected by the Fire Department.
No change
Temporary Occupancy Permit ‐ Multi‐Family Residential, Non‐Residential, and
Other Commercial
$826.00
Temporary Occupancy Permit ‐ Single Family Residential and Commercial
Tenant Improvement less than 10,000 sq. ft.
$606.00
Additional Non‐Residential Long‐Term (More than 5 days) Monthly No Change
Dumpster, Container No Change
Non‐Residential ‐ Single Day No Change
Non‐Residential Long‐Term (More than 5 days)No Change
Non‐Residential Short‐Term (Less than 5 days)No Change
A. 101 ‐ 1,000 cubic yards No Change
B. 1,001 ‐ 10,000 cubic yards No Change
Public Works
Engineering
$197.00 for the first 100 cubic yards, plus $197.00 for each additional 100 cubic
yards or fraction thereof
$1970.00 for the first 1,000 cubic yards plus $186.00 for each additional 1,000
cubic yards or fraction thereof
Encroachment Permit
$746.00 per month
$310.00 each
$1,249.00 each
$2,039.00 each
$1,466.00 each
$123.00 each
DEVELOPMENT SERVICES
$1.00 each
$673.00 each
$498.00 each
$1.00 minimum
Strong Motion Instrument Program
$28.00 per $100,000.00 permit valuation ($0.50 minimum)
$13.00 per $100,000.00 permit valuation ($0.50 minimum)
Use & Occupancy Permits
$287.00 each
$1.00 per valuation increment
$2.00 per valuation increment
$3.00 per valuation increment
$4.00 per valuation increment
Add $1.00 per valuation increment
Exhibit 2
Municipal Fee Schedule
C. 10,001 or more cubic yards No Change
Tree Inspection for Private Development No Change
Construction in Public Right‐of‐Way ($1.00 ‐ $5,999)
Note: Including public or private subdivision streets
No Change
Construction in Public Right‐of‐Way ($6,000 ‐ $25,999)
Note: Including public or private subdivision streets
No Change
Construction in Public Right‐of‐Way ($26,000 ‐ $100,999)
Note: Including public or private subdivision streets
No Change
Construction in Public Right‐of‐Way ($101,000 +)
Note: Including public or private subdivision streets
No Change
Storm Drain Plan Check Fee No Change
Temporary Discharge to Storm Drain from Construction Site Dewatering No Change
Additional Temporary Discharge to Storm Drain from Construction Site
Dewatering
No Change
Wet Season Construction Site Stormwater Inspection Note: MRP requirement
for sites >1 acre and/or high priority (hillside, near creek, prior violation)
No Change
Emergency Response Fee ‐ Hazmat (PAMC 17.24.050)$350.00
Installation or Closure Without Approved Plans and/or Permits No Change
Emergency Planning Guide No Change
Long‐term Offsite Document Storage No Change
Microfilm Copy/Print No Change
Photographs No Change
Fire
$30.00 first print; $0.55 each additional print
Hazardous Materials Classification Permits
Up to $1,212.00 for each incident up to 100% cost recovery
$275.00 ‐ $813.00 average fee range
Documents
$253.00 each
$0.25 per page
$3.25 per blueprint page; $0.30 per specification/ calculation page
$4,093 per request to discharge
$313.00 per week for the duration of dewatering activities
DEVELOPMENT SERVICES
$287.00 per month, charge monthly October through April
Compliance Fees
Permit Fees
$712.00 per occurrence
$712.00 + 8.8% of value greater than $6,000.00
$2472.00 + 10.8% of value greater than $26,000.00
10,572.00 + 9% of value greater than $100,000.00
$743.00 per project
$3830.00 for the first 10,000 cubic yards plus $711.00 for each additional 10,000
cubic yard or fraction thereof
Inspection Fees
$139.00 per inspection
Exhibit 2
Municipal Fee Schedule
Compressed Gas $351.00
Corrosives $351.00
Cryogenic Fluid $351.00
Flammable and Combustible Liquids $351.00
Flammable Gas $351.00
Flammable Solids $351.00
Health Hazard (Liquids & Solids)$351.00
Liquefied Petroleum Gases $351.00
Organic Coatings $351.00
Organic Peroxides $351.00
Other Hazardous Materials ‐ Unclassified
Note: Inspections and investigations for which no fee is specifically indicated (1‐hour
maximum)
$351.00
Ovens ‐ Industrial Baking or Drying $351.00
Oxidizers (Liquids & Solids)$351.00
Oxidizing Gas $351.00
Pyrophoric Gas $351.00
Pyrophoric Materials (Liquids & Solids)$351.00
Pyrotechnical Special Effects Material $351.00
Radioactive Materials $351.00
Refrigeration Equipment $351.00
Spraying/Dipping $351.00
Tire Recapping/Tire Storage $1,397.00
Toxic, Highly Toxic, Moderately Toxic, Health Hazard Gas
Note: Includes pesticides, fumigants, and etiologic agents.
$351.00
Toxic, Highly Toxic, Moderately Toxic, Health Hazard Materials $351.00
Unstable Reactive Gas $351.00
Unstable Reactive Materials (Liquids & Solids)$351.00
Water Reactive Materials (Liquids & Solids)$351.00
Additional Approvals for Hazardous Materials Storage Permit Note: Additional
approval for permit to construct, temporary closure, permanent closure, otherwise
modify a hazardous materials storage facility. See CEQA for additional fees.
$761.00 per occurrence plus $498.00 per
hour for time above two hours per
occurrence
Business Plan (HMBP)$498.00
Late Fee for Hazardous Materials Storage Permit No Change
$848.00 per occurrence plus $554.00 per hour for time above two hours per
occurrence
$554.00 per location annually
25% of total Hazardous Material permit fee
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
Hazardous Materials Storage Permits
$391.00 annually
DEVELOPMENT SERVICES
$391.00 annually
$391.00 annually
$391.00 annually
$1,561.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
$391.00 annually
Exhibit 2
Municipal Fee Schedule
Level I Facility
Note: Minimal storage as defined by having no hazardous materials over CFC permit
amounts as specified in CFC section 105.
$351.00
Level II Facility
Note: Quantities exceeding CFC permit threshold, but less than 50 gal., 500lbs or 200 cu.
ft. Category also includes dry cleaning, fixed medical gas, auto or aircraft repair, and
service stations.
$703.00
Level III Facility
Note: Quantities exceed 50 gal. 500lbs, or 200 cu. ft. and not categorized as Level II.
$1,406.00
Petroleum Aboveground Storage Tank
Note: Includes 2 hrs inspection time.
$703.00
Provisional (6 Month)$703.00
Additional Inspection or Reinspection Fee $699.00 for up to 2 hours reinspection plus
$349.00 per hour (during business hours)
After Hours Inspection Fee
Note: Fee for before or after normal business hours; weekends and holidays included.
Fee is to be paid in advance of inspection.
$524.00
As‐Built Plan Check and Additional Work $699.00
Care Facility Inspection Including Fire Clearance $349.00 for facilities with 7‐25 clients;
$699.00 for facilities with more than 25
Christmas Tree Lot/Pumpkin Patch $349.00
High Rise Building ‐ Certificate of Compliance
Note: Certificate of compliance inspection for each high rise building which is required
by state law to be inspected and certified annually as meeting minimum compliance
with applicable state of California fire and life safety standards for existing high rise
b ildi (CFC11143)
$1456.00 annually for up to 4 hours;
$349.00 for each additional hour
Outside Cooking Booths $524.00
Standby Fire Watch
Note: Per person.
$349.00
Use and Occupancy Fire Inspection $349.00
Additional Hours Over Plan Review/Inspection $249.00
Alternate Means and Methods Application
Note: 2 hr maximum.
$746.00
Appeals to Decisions $349.00
Consultation Fee $349.00
Hydrant Flow Fee $349.00$391.00 per occurrence
Life Safety & Fire Protection
$148.00 per inspection
Investigations & Consultations
$308.00 per hour
$735.00 per application
$391.00 per hour
$391.00 per hour
$390.00 for facilities with 7‐25 clients; $780.00 for facilities with more than 25
clients per inspection
$391.00 each
DEVELOPMENT SERVICES
$1626.00 annually for up to 4 hours; $391.00 for each additional hour
$210.00 each
$391.00 per hour
$782.00 annually
$782.00 plus other hazardous materials classification permit fees if applicable.
Includes 2 hrs inspection time.
Inspection Fees
$781.00 for up to 2 hours reinspection plus $390.00 per hour (during business
hours) per inspection
$585.00 per hour; 4 hour minimum
$780.00 per review
$391.00 annually per location. Includes 1 hr inspection time.
$782.00 annually per location plus other hazardous materials classification permit
if applicable. Includes 2 hrs inspection time.
$1565.00 annually per location plus other hazardous materials classification permit
if applicable. Includes 4 hrs inspection time.
Exhibit 2
Municipal Fee Schedule
Hydrant Installation/Modification ‐ Private $175.00
Automatic Fire Sprinkler Installation/Modification
Note: Includes hydrostatic test
$1543.00 for 1‐19 Sprinkler Heads;
$1,724.00 plus $3.00 per head for 20 or
Express Fire Protection Plan Check Fee No Change
Fire Alarm System Installation and Modification $948.00 plus $21.00 a device or contract
point
Fire and Life Safety Plan Check ‐ Commercial
Note: Includes one inspection and reinspection.
$0.54
Fire Prevention Inspection of Private Schools $699.00
Fire Protection and Fire Access Plan Review for New Single Family Dwellings
or Additions
$773.00
Multifamily dwellings, hotels & motels 51‐100 units $699.00
Multifamily dwellings, hotels & motels greater than 100 units $1,048.00
Multifamily dwellings, hotels, motels 4‐50 Units $349.00
Other Automatic Fire Extinguishing System
Note: Includes hood and duct, FM 200, Inergen, and C02. If a system has a release
panel, Fire Alarm fees apply as well.
$948.00
Site Disaster Planning $349.00
Standpipe System ‐ Wet, Dry, or Combination $699.00
Temporary Certificate of Occupancy $757.00
Underground Fire Service Line
Note: Includes 4 hrs of inspection and 1 hr of plan check
$1,647.00
Verification of Fire Protection System Maintenance and Certification $64.00
Aerosol Products $437.00
Bowling Alley and Pin Refinishing Involving the use of Flammable Liquids $1,019.00
Candles and Open Flames in Assembly Areas $349.00
Carnivals and Fairs $1,456.00
Cellulose Nitrate Storage/Nitrate Film $102.00
Hot Work (Welding) Operations No Change
Liquid or Gas‐Fueled Powered Equipment/Generator $349.00
Malls ‐ Covered $699.00
Occupant Load Increase ‐ Temporary Public Assembly $349.00
Open Burning $349.00
$113.00 annually
$391.00 each
$391.00 each
$782.00 annually
$391.00 each
$391.00 each
DEVELOPMENT SERVICES
Specific Hazard Permits
$488.00 annually
$1,138.00 each
$391.00 annually
$189.00 each
$1,090.00 per occurrence
$390.00 per hour
$780.00 per riser
$377.00 per occurrence
$1,870.00 per occurrence
$88.00 annually
The Fire and Life Safety Plan Review Fee is 45% of the Building Plan Check Fee and
is collected by the Building Division at the time an application of a Building Permit
is submitted.
$780.00 annually
$894.00 each
$780.00 annually
$1,170.00 annually
$391.00 annually
$195.00 per device
$780.00 for 1‐19 Sprinkler Heads; $1,724.00 plus $4.80 per head for 20 or more
Sprinkler Heads
$173.00 per occurrence
$1090.00 plus $23.00 a device or contract point
Exhibit 2
Municipal Fee Schedule
Open Flame/Flame Producing Devices $349.00
Operate a Tank Vehicle to Transport Flammable/Combustible Liquids $495.00
Parade Float $351.00
Place of Assembly $703.00
Place of Public Assembly ‐ Temporary $349.00
Tent or Air Supported Structure
Note: Tent or air‐supported structure having an area in excess of 200 sq. ft. or canopies
in excess of 400 sq. ft. Fee includes a public assembly permit of $125.00 for all tents.
$734.00
Commercial & Residential windows, skylights and doors, New and alteration
(structural) (per 5)
$279.00
Commercial & Residential windows, skylights and doors, New and alteration
(structural) (per 10)
$140.00
Residential Reroof $279.00
Residential Reroof (overlay)$70.00
Commercial and multifamily reroof (first 5000 sf)$279.00
commercial and multifamily reroof (each additional 2500 sf)$70.00
Kitchen (non structural) per each $210.00
Bathroom (non structural) per each $279.00
Commercial & Residential Siding replacement or repair $140.00
commercial & Residential Stucco replacement or repair $210.00
Commercial doors, new and alteration (structural) per 5 doors $210.00
Commercial doors, new and alteration (structural) per 10 doors $140.00
Residential dry rot repair and replacement $70.00
Deck, new or repair up to 1000 sf $210.00
Deck, new or repair each additional 1000 SF $70.00
Sign permit $116.00
Residential and commercial window awnings (group of 5)$70.00
Cell Tower Equip $210.00
Building New Fees
$391.00 each
$553.00 per vehicle
$122.00 per hour
$782.00 per occurrence
$391.00 each
$307.00 each
Exhibit 2
Municipal Fee Schedule
Utilities Handling Fee $116.00
Progress and partial inspections $56.00
Green Building ‐ Special Inspector applications and qualifications (internal
review)
$395.00
Green Building ‐ Special Inspector applications and qualifications (renewal
update)
$197.00
Special Inspections ‐ materials testing lab certification (up to 4 hours)$1,579.00
Miscellananeous Building ‐ base fee $115.00
Retaining Walls ‐ first 100 LF $93.00
Retaining Walls ‐ each additional 100 LF $46.00
Fees not listed above will either be based on an applicable hourly rate or at
the given valuation
TCO fee for Vendors/Stock Occupancy (requires at least one additional
inspection
$1,125.00
Emergency Responder Radio Coverage (testing) fee $492.00
Fire New Fee
Certifications
Exhibit 2
Attachment B
City of Palo Alto (ID # 8586)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 11/13/2017
City of Palo Alto Page 1
Summary Title: Vulnerable Buildings Seismic Risk Assessment Study
Title: Direct Staff to Return to Policy and Services Committee With
Amendments to the Municipal Code for the Regulation of Seismic Vulnerable
Buildings (Continued From October 16, 2017)
From: City Manager
Lead Department: Development Services Department
Recommendation
Unless council directs otherwise, staff intends to take the existing research and findings on
seismically vulnerable buildings completed to date (explained in this report and attachments)
and start the process of drafting updates to local regulations, policies, and procedures including
an analysis of any potential CEQA requirements. Staff will be returning to Council for request to
enter into a new contract(s) for technical services and then work with the Policy and Services
Committee and ultimately the City Council to review revised language, options, and
implications associated with modifications to seismic compliance in our municipal code.
Background
This work was completed per direction given by the City Council in 2014, in response to the
Napa Valley earthquake. Staff has been working in collaboration with a multi-stakeholder group
made up of other city departments and external interest groups along with support from a
technical consultant to review our exposure to seismic hazards. We have developed the
following findings.
In 1986, the City Council adopted the Seismic Hazards and Identification Program, codified in
the Palo Alto Municipal Code, to establish a mandatory evaluation and reporting program
including incentives for property owners to voluntarily upgrade their structurally deficient
buildings. Three categories of buildings are addressed in that ordinance:
1. Category I Buildings: Buildings constructed of unreinforced masonry (URM), except for
those smaller than 1,900 square feet with six or fewer occupants. These buildings are
located in the Downtown Commercial area.
2. Category II Buildings: Buildings constructed prior to January 1, 1935, containing one
City of Palo Alto Page 2
hundred (100) or more occupants.
3. Category III Buildings: Buildings constructed prior to August 1, 1976, containing three
hundred (300) or more occupants.
On September 15, 2014, several weeks after August 24, 2014 Napa Valley earthquake, the City
Council received an update from the Office of Emergency Services regarding the Threats and
Hazard Identification Risk Assessment report. During the study session, City Council suggested
that the Policy and Services Committee:
1. Identify and prioritize buildings that pose potential risks in earthquakes, including soft story
buildings and other types of construction.
2. Review and summarize best practices from other government agencies regarding
prioritization of various seismically vulnerable buildings, including retrofit incentives and
requirements.
3. Review current or pending State legislation related to soft-story buildings and other
structurally deficient buildings.
On December 9, 2014 the Council’s Policy and Services Committee recommended the City
Council authorize a Request for Proposal to prepare an update to the City’s Seismic Hazards
Identification Program and update the inventory of structurally deficient buildings in the multi-
family, commercial and industrial areas of the city, categorizing building typologies to include:
1. URM, 2. Soft-Story, 3. Tilt-Up Construction, 4. Non-ductile Concrete, and 5. Steel Moment
Frame.
On August 17, 2015, City Council approved a contract with Rutherford + Chekene to complete a
study and provide recommendations for improvement of City’s Seismic Program. On April 17,
2017, staff advanced a comprehensive information report to City Council including the results
of the Rutherford + Chekene report.
Discussion
The April 17, 2017 staff report (attached) is a thorough analysis including a 34 page staff
summary of the Rutherford + Chekene’s 110 page report. The Rutherford + Chekene report is
also attached however any non-pertinent appendixes have been removed to save paper. All
documents related to the study and previous staff reports are located on the City’s website:
http://www.cityofpaloalto.org/gov/depts/ds/srmag.asp.
In addition to the support from our consultant, staff convened a Seismic Risk Management
Advisory Group (SRMAG). The group consisted of residents, experienced contractors, property
owners and local advocates. Six meetings were held, led by the Rutherford + Chekene and
included staff from Building, Planning, Fire, Office of Emergency Services, and Public Works.
The intent of the SRMAG process was not to gain consensus or ratify any particuarly policy
proposal, but rather to gauge community interest, clarify alternative directions, and highlight
City of Palo Alto Page 3
key issues that need to be addressed moving forward.
The SRMAG expressed little to no support for leaving the status quo program unchanged.
Strong support did exist for: 1. Taking action to resolve buildings (through retrofit or
demolition) already in the program, particularly URM buildings, 2. Addressing more building
types, particularly soft story wood-frame, and 3. Utilizing a variety of disclosure measures and
potentially some incentives. All presentations and minutes from the meetings are also available
on the aforementioned website. Attachment A summarizes policy options that came out of the
Seismic Risk Assessment, as presented to staff and discussed by the SRMAG.
Staff intends to take action on recommendations provided to the Council on provided on April
17, 2017 in Staff Report 7095.
Program Options:
1. Status quo;
2. Increase number of building types regulated, but retrofit remains voluntary;
3. Increase number of building types regulated with additional disclosure measures
incorporated;
4. Increase number of building types regulated, some building types have voluntary retrofit
and a few building types have mandatory retrofit, with enforcement by a trigger threshold
when the building is sold or undergoes substantial renovation;
5. Increase number of building types regulated, retrofits for some categories are voluntary and
a few categories are mandatory, with enforcement by a fixed timeline;
6. Increase number of building types regulated, but more categories are required to have
mandatory retrofits.
Building Types:
In an effort to more accurately capture the diverse range of existing building types the study
suggested staff consider the expansion of the existing building types to include four additional
types. Attachment A is a summary table indicating the category, approximate number of
buildings in each category, the building type, date of construction, occupant levels, threshold
elements, deadlines and potential incentives.
1. Existing: Category I Buildings: Buildings constructed of unreinforced masonry (except for
those smaller than 1,900 square feet with six (6) or fewer occupants). These buildings are
located in the Downtown Commercial area.
2. Existing: Category II Buildings: Buildings constructed prior to January 1, 1935, containing
one hundred (100) or more occupants.
3. Existing: Category III Buildings: Buildings constructed prior to August 1, 1976, containing
three hundred (300) or more occupants.
4. Proposed: Category IV Buildings: Buildings constructed of soft-story wood frame, prior to
1977.
City of Palo Alto Page 4
5. Proposed: Category V Buildings: Building constructed of tilt-up, prior to 1998.
6. Proposed: Category VI Buildings: Building constructed of soft-story concrete, prior to 1977.
7. Proposed: Category VII Buildings: Buildings constructed of steel moment frame, prior to
1998.
Types of Disclosure Measures
Another outcome of the study and stakeholder engagement resulted in the identification of
potential ways to disclose the seismic vulnerability of a building. Attachment B is a table
describing the disclosures listed below with their description, examples of use, advantages, and
disadvantages. Given that staff has to further define and verify the current inventory of
vulnerable buildings and assess community, business and economic implications, having all
measures available will be helpful.
1. Mandatory disclosure at the time of sale
2. Recorded notice on deed
3. Public listing of affected properties
4. External signage
5. Tenant notification
6. Earthquake performance rating system
Types of Incentives
The study conducted by the team of staff, stakeholders and technical consultant revealed a
range of incentives that could be used in seeking compliance with a proposed seismic retrofit
ordinance. Attachment C is a table describing the incentives listed below with their
description, examples of use, advantages, and disadvantages. Going forward staff intents to
explore the following incentives as we review options and draft an ordinance that will be
reviewed by the Policy and Services Committee and back to the City Council.
1. Expedited Planning Entitlement
2. Density or Intensity Bonuses, such as Floor-to-Area Ratio (FAR) bonuses
3. Exemptions for Non-Conformities
4. Zoning Incentives
5. Condominium Conversion Assistance
6. Exemption from Future Retrofit Requirements
7. Transfer of Development Rights (TDR’s)
8. Permission to add units (such as in soft-story wood frame apartment construction)
9. Expedited Building Permitting
10. Technical Assistance
Summary of Seismic Risk Assessment Study Key Findings
Due the volume and depth of information provided in the April 17, 2017 staff report as well as
the Seismic Risk Assessment Study, staff and our consultant have prepared the following key
findings. For a more detailed understanding of these findings staff recommends the City Council
City of Palo Alto Page 5
and community read the April 17, 2017 staff report and the Seismic Risk Assessment Study.
1. Thirty years later, Palo Alto’s existing mandatory evaluation, voluntary retrofit program has
been largely successful at addressing buildings with URM load-bearing walls.
2. The modest scope of the existing program and lessons learned from seismic events since
the program was adopted, means that we now believe there are vulnerable building types
that have not been addressed. Five additional categories were identified from the Risk
Assessment Study as meeting the criteria of being potentially hazardous and having a
meaningful presence in Palo Alto. The decision whether to include some or all of these five
categories in an expanded seismic retrofit program is an important policy decision. Based
on an initial review, there are approximately 635 buildings located throughout the City,
both residential and commercial uses, that may fall into these categories.
3. If no action is taken, losses in these buildings from a large nearby seismic event may be
significant, on the order of $2 billion. That estimate does not include lives lost, economic
disruption, loss of housing, emergency services costs, displacement or other effects.
4. Estimated losses could be reduced by up to one third to one half if all the identified
vulnerable structures were retrofitted. For all five additional categories recommended for
consideration, analysis of protype retrofitting strategies showed high likelihood of being
cost-effective. In other words, losses avoided will exceed retrofit costs, in some categories
by fourfold or more. This does not suggest that all of the retrofits would necessarily be
financially feasible for current building owners, particularly in the absence of incentives
and/or favorable financing terms.
5. Over the past ten years, an increasing number of California cities have expanded their
seismic mitigation programs to address one or more of the five additional vulnerable
building types identified in the Risk Assessment. In particular, five Bay Area cities (San
Leandro, Fremont, Berkeley, Oakland and San Francisco) have well-established mandatory
retrofit programs for soft-story wood frame buildings, which are typically multi-family
residential or mixed use. Cities with newer programs include Los Angeles and West
Hollywood. Several cities have also implemented or are actively considering ordinances for
tilt-up and older concrete structures.
6. Most programs package together a variety of policy features and timelines that differ by
building type(s) and priority tiers. Education, notification and appeal, evaluation, permit
application and retrofit deadlines are implemented in phases during an overall timeframe
ranging from two to 25 years. A variety of incentives can also be offered for some or all
affected owners, but in fact, very few cities offer any kind of significant financial assistance
beyond fee waivers.
Resource Impact
Implementation of future City Council action and development of an expanded Seismic Hazards
and Identification program and ordinance would result in additional costs to private property
owners. Attachment D is a table of financing tools provide by Rutherford + Chekene. Staff is not
seeking Council input at this stage. Upon returning to Policy and Services Committee, staff will
provide recommendations for possible financing strategies.
City of Palo Alto Page 6
Staff time from Development Services, Planning and Community Environment, Fire, Office of
Emergency Services, and Public Works departments will continue to be needed. Additionally,
consulting services to further define and verify the current inventory of vulnerable buildings;
assess community, business and economic implications; and to determine scope of updates to
local regulations, policies and procedures will be required. Staff will return to the Council for
authorization to enter into a new contract(s) for technical services including potentially CEQA
compliance and will work with the Policy and Services Committee to review options,
implications and ultimately draft a new ordinance that will come before the City Council for
approval.
Environmental Review
No environment review is necessary under California Environmental Quality Act (CEQA) at this
time, as staff is continuing to collect information for City Council action. Staff will conduct the
appropriate level of environmental assessment may be required prior to adoption of updates to
the City’s Seismic program.
Attachments:
Attachment A - Program Options and Building Types
Attachment B - Types of Disclosure Approaches
Attachment C - Types of Policy Incentives
Attachment D - Types of Financial Tools
Attachment E - 4-17-17 Staff Report
Attachment F - Seismic Risk Assessment Study by Rutherford + Chekene
Palo Alto Seismic Risk Assessment Study December 21, 2016
Final Report Page 4
Summary of Recommended Policy Directions from the Seismic Risk Management Program Advisory Group
Category Approx.
Number
Building
Type
Date of
Construction
Occupants Evaluation
Report
Voluntary,
Triggered, or
Mandatory
Retrofit1
Deadlines for Evaluation Report and
Retrofit Construction (years)2
Disclosure Potential Incentives
Current Program (Potential Revision in Italics)
I 10 Un-
reinforced
masonry
NA Over 6
(and over
1,900 sf)
Required Mandatory Report: Expired
Construction: 2-4
Website
listing and
tenant
notification
Fee waiver, expedited
permitting, FAR bonus/
transfer of development
rights (TDR) II 4 Any Before 1/1/35 Over 100 Required Voluntary or
Triggered
Report: Expired
Construction
• Voluntary: Not required
• Triggered: At sale or renovation
III 9 Any Before 8/1/76 Over 300 Required Voluntary or
Triggered
Expanded Program
IV 294 Soft-story
wood
frame
Before 1977 Any Required Triggered or
Mandatory
Report: 2-4
Construction
• Triggered: At sale or renovation
• Mandatory: 4-6
Same as
above
Fee waiver, expedited
permitting, TDR, parking
exemptions, permission to
add units
V 99 Tilt-up Before 1998 Any Required Triggered or
Mandatory
Report: 2-4
Construction
• Triggered: At sale or renovation
• Mandatory: 4-6
Same as
above
Same as Categories I, II and
III
VI 37 Soft-story
concrete
Before 1977 Any Required Voluntary,
Triggered or
Mandatory
Report: 2-4
Construction
• Voluntary: Not required
• Triggered: At sale or renovation
• Mandatory: 6-8
Same as
above
Same as Categories I, II and
III
VII 35 Steel
moment
frame
Before 1998 Any Required Voluntary,
Triggered or
Mandatory
VIII TBD Other older
nonductile
concrete
Before 1977 Any Not rec. at
this time
Not
recommended
at this time
Report: NA
Construction: NA
NA NA
1Voluntary: Retrofit is voluntary.
Triggered: Retrofit is triggered when the building is sold or undergoes substantial renovation.
Mandatory: Retrofit is required per a fixed timeline.
2Deadlines provide a potential range. Timelines would vary depending on tiers or priority groupings of different subcategories.
Attachment A
Seismic Risk Assessment Study December 21, 2016
Final Report Page 56
Table 4: Description of disclosure approaches used in local earthquake risk reduction programs.
Name Description Examples of Use Advantages Costs, Issues or Concerns
Mandatory Disclosure
at Time of Sale
Sellers of property are required
to disclose features that could
relate to earthquake
performance.
California Earthquake
Fault Zone disclosure;
Sellers of pre-1960
homes are required to
fill out to the best of
their knowledge and
provide buyers with
Residential
Earthquake Hazards
Report.
Empowers buyers to be
aware of any known
existing hazard issues.
Anecdotally, many buyers do
not pay enough attention to
these disclosures, which occur
during emotional, busy
decisionmaking periods. They
may not seek expert
information to interpret the
reported information. It is also
possible that sellers shirk on
the disclosure requirements if
buyers do not know that they
are supposed to receive them.
Difficult to enforce.
Recorded Notice on
Deed
Jurisdictions can record on the
property title or deed the fact
that the building is subject to
additional requirements
related to its earthquake
vulnerable status.
For soft-story wood
frame: Oakland,
Berkeley, and San
Francisco.
Relatively low cost for
jurisdictions to implement.
Empowers buyers but also
mortgage companies to be
aware of any known
existing hazard issues.
Anecdotally, it is not clear how
many buyers or mortgage
companies pay attention to
these notices. Such notices are
primarily effective only at time
of sale or refinance.
Attachment B
Table 4 (continued)
Seismic Risk Assessment Study December 21, 2016
Final Report Page 57
Name Description Examples of Use Advantages Costs, Issues or Concerns
Public Listing of
Affected Properties
Jurisdictions that operate web
sites to describe their
programs can feature a full list
of property addresses,
potentially also including also
the compliance status of the
property. In general, owner
names are not listed, though
that information is available if
a member of the public
searched for it separately.
For soft-story wood
frame: Oakland,
Berkeley, and San
Francisco.
Relatively low cost for
jurisdictions to implement.
Could be used by tenants
and buyers when
searching for properties,
thus empowering well-
informed market
negotiations over pricing.
Website information needs to
be updated on a regular basis
in order to be perceived as fair
and useful. Public lists work
better if the property
addresses are searchable,
rather than static (e.g., on a
pdf).
External Signage Jurisdictions that operate web
sites to describe their
programs can feature a full list
of property addresses,
potentially also including the
compliance status of the
property. Some lists are
searchable, while others are
static.
California state
requires a sign on all
URM buildings. Similar
signage has been
required since 2007
on soft-story wood
frame buildings in the
City of Berkeley.
Advocates argue that signs
are justified based on the
public's right to know. The
physical presence and
repeated viewing of
signage may make the
issue more salient for
visitors, employees, lease
holders, and owners alike.
Owners may view the signs as
stigmatizing or threatening to
property value or business
revenues, but anecdotally, it is
not clear how much visitors,
employees, residents, and
other users of a building pay
attention to signage when
entering or leaving a property.
Attachment B
Table 4 (continued)
Seismic Risk Assessment Study December 21, 2016
Final Report Page 58
Name Description Examples of Use Advantages Costs, Issues or Concerns
Tenant Notification Owners are required to present
straightforward, standardized
information about the listed
status of the property. Some
jurisdictions require proof of
notification (e.g., tenant
signature) to be returned and
kept on file with the city.
For soft-story wood
frame: Oakland,
Berkeley, and San
Francisco.
Tenant notification may be
more influential than
signage because it is
personalized and the
information is delivered at
a useful time in that
person's decision process.
Advocates claim that
tenant notification is
justified based on the
public's right to know.
To be effective, tenant
notification should be required
to occur well before the
potential tenant is ready to
sign the lease.
Earthquake
Performance Rating
Systems
Owners can be either
encouraged or required to
have their building rated on a
standardized scale that
classifies expected building
performance in an earthquake
in an easier to understand
format, for instance from one
to five stars. Viable rating
systems exist for many building
types.
The City of Los
Angeles in 2015
officially launched a
voluntary effort to
encourage owners to
rate their properties
using the US
Resiliency Council
system and pledged to
rate its own public
buildings as well.
Rating system use is
common for institutions
like universities and
hospitals. Mechanisms for
implementing
performance ratings for
commercial use have
recently matured and are
now viable. Ratings have
the potential to inform
owner, renter and buyer
decisions, creating a
market effect.
Obtaining a rating potentially
adds cost to a design project.
Ratings systems such as USRC’s
are relatively new and not yet
widely implemented.
Attachment B
Policy Incentives Used in Local Earthquake Risk Reduction Programs.
Type of Incentive Description Examples of Use Advantages Costs, Issues or Concerns
Density or Intensity
Bonuses
Specific increases in the
maximum allowable
building density or
intensity to help offset
the added costs of
seismic upgrades.
Palo Alto’s Floor Area Ratio
bonus program.
Owners that invest in a retrofit
can expand their projects in
order to increase future
revenue.
Typically,feasible only in areas
of high growth. Sometimes
controversial because of
potential community impacts
such as increased traffic, parking
needs, and rental rates.
Exemptions for Non‐
Conformities
Relief from timelines or
waivers of required work
such as fire resistance
upgrades and sprinklers,
Title 24 energy analysis
and upgrades, parking,
setback or other current
code measures that
would otherwise be
triggered by the size of
the project being
undertaken for projects
involving qualifying
retrofit work.
None identified.Offering relief from what may
be expensive rehabilitation of
nonconforming uses can make
seismic retrofits easier to design
and more affordable.
May be viewed as an excessive
concession to owners among
some members of the public.
Attachment C
Type of Incentive Description Examples of Use Advantages Costs, Issues or Concerns
Zoning Incentives Specific concessions
regarding encroachment
into setbacks, increased
allowable floor/area
ratios (FAR), height
limits, or onsite parking
requirements to help
offset the added costs of
seismic upgrades.
Since 1986, Palo Alto
allowed owners of included
buildings in the downtown
area to expand the floor
area if the owner
performed seismic
upgrades. Buildings were
also exempted from onsite
parking requirements and
fees for offsite parking.
Useful when bond financing
options are prohibitively costly
or not much more attractive
than private credit terms. Most
likely to work when zoning plans
in the community generally call
for limited to no growth. Costs
to the city are mainly in the
form of technical and design
cost review of proposed
projects.
Similarly‐situated properties
must be treated alike so as to
avoid claims of "spot zoning."
Citizens may object to special
treatment for work that could
be seen as essential anyhow.
Not likely to work in locations
with little development pressure
or where the community favors
growth.
Condominium
Conversion Assistance
Process expediting for
condo conversion for
properties that
seismically retrofit.
None identified.In jurisdictions where condo
conversation rates are capped
or allocated by lottery, offering
priority to buildings that retrofit
could be an effective tool to
promote seismic upgrading of
multifamily buildings.
May negatively impact other
housing affordability goals. Only
available to owners that can
afford it, unless accompanied by
other assistance programs.
Exemption from Future
Retrofit Requirements
Relief from imposition of
future retrofit
requirements for a
certain period following
completion of qualifying
seismic work.
The City of Berkeley offered
a 15‐year exemption from
future retrofit requirements
for soft‐story wood frame
properties that did a retrofit
concurrent with its
mandatory evaluation
program.
This can motivate owners to
complete retrofit work sooner
rather than later in order to
reduce uncertainty about future
city policies, and allows owners
to better anticipate business
expenses over a longer term.
The jurisdiction could not easily
impose new regulation on
exempted properties, even if
such policies became warranted
by new technologies or
knowledge.
Attachment C
Type of Incentive Description Examples of Use Advantages Costs, Issues or Concerns
Transfer of Development
Rights (TDR)
TDR allow owners to
transfer unused
development rights that
are comparable to the
value of the retrofit to
another site.
Very commonly used for
historic preservation,
including in Palo Alto.
Useful when the use of the
building in question is not likely
to generate added value to
justify the costs of the retrofit
work. This is most useful when
retrofit costs can be particularly
high and there are natural or
regulatory use restrictions.
Careful analysis of construction
costs is necessary to avoid
situations of under‐ or over‐
compensation.
Expedited Permits,
Inspections, and Reviews
Prioritization,
expediting, or bypassing
of certain internal
protocols for over the
counter permits and
inspection processes for
projects involving
seismic retrofit work.
Several Bay Area cities have
anecdotally stated that this
is their internal policy, but
no official records of such
were identified.
This can relieve the burden of
time and hassle for owners in
getting permits and inspections,
which are a significant source of
cost and uncertainty for owners
during retrofit projects.
Requires flexibility on the part of
city staff and plan check
consultants.
Technical Assistance Case‐management style
assistance for owners
and/or engineers during
the process of obtaining
financing, complying,
permitting, and carrying
out retrofit projects. This
is different than
engineering advice
about how to resolve
specific technical issues
of design.
Cities such as Berkeley have
found it necessary to
maintain additional staff to
operate their mitigation
programs. A significant
portion of their staff time is
devoted to owner and
engineer consultation.
Knowledgeable staff can help
owners navigate complex issues
such as investigating and
applying for incentives (if
offered), following guidelines, or
addressing the necessary
standards.
Labor costs to the city for
additional staff. Difficulty
sustaining project funding and
staff continuity over time.
Attachment C
Financial Tools Used in Local Earthquake Risk Reduction Programs.
Financial Tools Description Examples of Use Advantages Costs, Issues or Concerns
General Obligation or
Special District Bonds
Direct provision of funds
for qualifying retrofit
work based on voter
approval of issuance of
new municipal or state
debt to be repaid by
taxation.
This mechanism is
commonly used for seismic
improvements to
infrastructure, but also has
been used in URM building
programs and for retrofit of
historic properties. One
URM example is the city of
Long Beach, which offered
11.3% interest financing to
participating members of a
Special District created for
URM building owners.
Once passed, this type of
funding can be distributed over
time as provided for in the
approved wording.
Must be approved by two thirds
of voters, which sets a high bar
even if there is significant public
support. Jurisdictions must
administer the allocation of
funds and have at times not
been able to use all of it. Owner
education about the provisions
of the program is critical.
Owners of highly leveraged
buildings and buildings in
depressed areas may be unable
to meet prerequisite loan‐to‐
value ratio criteria. Retrofits are
generally not revenue‐
generating improvements upon
which financing can be
leveraged.
Grants Direct provision of funds
for qualifying retrofit
work.
CEA's Earthquake Brace &
Bolt program for single
family homes.
Some sources exist for city‐scale
projects or privately‐owned
buildings, such as FEMA Pre‐
Disaster Mitigation Grants.
Limited sources exist. Programs
can be difficult to manage
administratively. Fairness
concerns exist over which
owners can benefit.
Attachment D
Financial Tools Description Examples of Use Advantages Costs, Issues or Concerns
Property‐Assessed
Financing Loans
Also known as a
Property Assessed Clean
Energy (PACE) program,
this works as a loan to
an individual property
owner, transferrable to
future owners, where
the upfront costs of
qualifying work are
repaid over a period of
approximately 20 years
through the owner's
property tax
assessment.
San Francisco's PACE
program.
Provides an upfront way for
owners to access private capital
to afford retrofit projects. The
loan can be paid off over time
through higher rents or at future
sale, as well as being
transferrable to future owners.
Administratively complex for
both jurisdictions and owners.
Challenges include setting up
this complex financing
instrument which has heavy
involvement of third parties,
barriers to owners that want to
refinance, and barriers to the
transfer of a PACE‐financed
properties to a new owner.
Owners may not need it if
affordable regular market
capital is available. Lenders may
resist allowing an additional
lien.
Tax Credits Waiver of a portion of a
business, parcel, or
income tax for a number
of years to encourage
owners to retrofit.
Although vetoed by the
Governor, the legislature of
California passed AB 428 in
2015, which would have
offered up to 30% credit for
qualifying retrofit costs.
The funding source can be
outside the local jurisdiction,
and depending on the clarity of
program requirements, owners
can count on the funds as part
of planning their project.
Owners would need to be aware
of the credit and verify
qualifying work and complete all
follow up documentation.
Mostly benefits owners already
intending to retrofit and those
with more financial and business
sophistication.
Attachment D
Financial Tools Description Examples of Use Advantages Costs, Issues or Concerns
Real Estate Transfer Tax
Rebates
Building owners can
apply for a rebate of a
fraction (usually 1/3, up
to a cap) of the amount
of the transfer tax owed
to the city for a property
at sale for any qualifying
seismic improvement
expenditures made
within a certain period
before or after transfer
of title.
This policy has existed in
Berkeley since 1991 for
residential dwellings up to
four units and in San
Francisco since 2008 for
properties worth $5 million
or more.
In Berkeley, the program was
immediately popular and
eventually highly influential in
increasing support for other
earthquake policies because it
touched so many community
members and firmly established
a tone that the city takes seismic
risk seriously and will put its
“money where its mouth is.”
About half the single‐family
homes and one third of the
smaller rental buildings in
Berkeley have claimed the
credit, leading to widespread
community awareness of
seismic safety issues.
The jurisdiction forgoes tax
revenue. Anecdotally in
Berkeley, city officials had no
easy way to assess the quality of
work done. Some experts
suspect that some of the funds
went to incomplete or
improperly done retrofits.
Waivers or Reductions of
Building Department
Fees
Full waivers, fixed,or
percentage‐based
reductions of building
permit fee reductions.
The Jurisdictions of San
Francisco, Berkeley, and
Alameda have offered flat
or waived plan check fees
as an incentive for owners
to retrofit their buildings.
Oakland currently offers a
flat permit fee of $250 for
owners of qualified single‐
family residences to
perform seismic retrofits.
Modestly reduces the cost of a
retrofit project. Easy for city to
implement. Perceived by
owners as a significant gesture
of good will by owners, who
may feel it is "the least the city
could do."
This measure has direct loss of
revenue implications for the
jurisdiction.
Attachment D
Financial Tools Description Examples of Use Advantages Costs, Issues or Concerns
Pass Through of Retrofit
Costs to Tenants
For residential
properties in
jurisdictions with rent
control laws in place,
owners who seismically
retrofit their buildings
could be allowed to pass
through all or a fraction
the costs of these
retrofits to renters in
rent‐controlled units,
amortized over a
particular time period
such as 10 years.
Berkeley is 100% pass‐
through, San Francisco is
50%, and Oakland is %75.
Perceived as fair by owners
because tenants that benefit
most from the retrofit work pay
a share of it. Owners can use
this anticipated source of
revenue as a basis for securing a
loan.
Tenants with fixed or low
incomes might suffer hardship
with the added costs, although
hardship provisions can lessen
those effects.
Special District or
Historic Designation Tax
Reductions
Creation of Mello‐Roos,
Mills Act, historic or
other special districts
that are then eligible for
special loans, grants, or
tax credits.
For URM buildings, the
jurisdictions of St. Helena
and West Hollywood used
Mello‐Roos funding.
Provides a clear way for a local
jurisdiction to provide direct
funding or special financing
rates for privately‐owned
vulnerable properties.
Can be difficult for jurisdictions
to initiate and carry out. Owners
must join the special district at
the outset or will be left out of
future funding availability.
Attachment D
City of Palo Alto (ID # 7095)
City Council Staff Report
Report Type: Informational Report Meeting Date: 4/17/2017
City of Palo Alto Page 1
Summary Title: Palo Alto Seismic Risk Assessment Study Results
Title: Palo Alto Seismic Risk Assessment Study Results
From: City Manager
Lead Department: Development Services Department
RECOMMENDATION
This is an Informational Report, no City Council action is required at this time. Staff
recommends that the City Council review the Seismic Risk Assessment Study prepared by
Rutherford + Chekene, structural engineers. The study includes input from City of Palo Alto’s
Seismic Risk Management Advisory Group. Once Council is familiar with this study, staff will
prepare to return for a study session and direction.
EXECUTIVE SUMMARY
This informational item is intended to give the City Council advance background for an
upcoming study session related to a Seismic Risk Assessment Study of vulnerable building
construction in Palo Alto. In 2014, following the 6.0 magnitude earthquake in August 2014 in
the Napa Valley and the Office of Emergency Service’s Threats and Hazard Identification and
Risk Assessment Report, the Council directed staff to identify and prioritize buildings that pose
a potential seismic hazard in Palo Alto; review ‘best practices’ used by other communities for
addressing retrofit of seismically vulnerable buildings; and review current and pending State
legislation addressing these building types.
Rutherford + Chekene was selected to perform a comprehensive assessment of the expected
performance of the City’s building stock in potential earthquakes, including a community
engagement effort to help identify resiliency goals and associated mitigation policies and
programs. Specific details about the report can be found in this staff report and attached
consultant report. (Attachments B)
In this staff report, staff has summarized the outcome of the Seismic Risk Assessment and the
Advisory Group’s input on revisions to consider for the City’s Building and Zoning Ordinances.
Some of the study recommendations have significant policy and cost implications that will
require further study and Council review. All of these recommendations are discussed in this
staff report and in the detailed technical reports attached. (Attachments B and G)
Attachment E
City of Palo Alto Page 2
Next steps following council study session on this matter may include public outreach to
educate the community on vulnerable buildings. Staff, with the help of consultants, will review
potential incentives for retrofits and policies to minimize displacement of existing uses and
tenants. Staff would return to the Council with a recommendation to revise the current seismic
mitigation ordinance based on findings and community feedback. To be effective, there will
need to be a plan for staffing the program. Finally, during the study session staff will also
discuss potential policy implications such as displacement of existing building uses and tenants,
incentives for voluntary building retrofits, and the effects these benefits might have on
construction.
BACKGROUND
On September 15, 2014, the City Council directed staff to work with the Policy and Services
Committee to address the following:
A. Identification and prioritization of buildings that pose a potential hazard in an
earthquake, including soft-story buildings and other types of construction
B. Review of "best practices" from other cities regarding prioritization of various
seismically vulnerable buildings, including retrofit incentives and requirements
C. Review of current or pending State legislation related to soft-story buildings and other
structurally deficient buildings
Two events precipitated the Council’s direction: (1) the 6.0 magnitude earthquake on August
24, 2014, in Napa Valley and (2) the City Council’s review of the Office of Emergency Service’s
Threats and Hazard Identification and Risk Assessment report on September 15, 2014, which
identified over 130 seismically vulnerable buildings. (Attachment C)
<http://www.cityofpaloalto.org/civicax/filebank/documents/43866>
Current Code Provisions, Building Identification and Prioritization
In 1986, the City Council adopted the Seismic Hazards and Identification Program codified at
PAMC Section 16.42. (Attachment A) This ordinance established a mandatory evaluation
and reporting program and created incentives for property owners primarily in the
Downtown area to voluntarily upgrade their structurally deficient buildings. Three
categories of buildings were identified, including:
1. Category I Buildings: Buildings constructed of unreinforced masonry (except for those
smaller than 1,900 square feet with six (6) or fewer occupants). These buildings are
located in the Downtown Commercial area.
2. Category II Buildings: Buildings constructed prior to January 1, 1935, containing one
hundred (100) or more occupants.
3. Category III Buildings: Buildings constructed prior to August 1, 1976, containing three
hundred (300) or more occupants.
Attachment E
City of Palo Alto Page 3
The categories used in 1986 were developed by a citizens’ committee, reviewed by staff and
the Policy and Services Committee, and adopted by the City Council. These categories were
created to record known URM buildings and other potentially structurally deficient buildings
with relatively high numbers of occupants.
This program identified 89 buildings and was successful in two significant ways. One
hundred percent (100%) of the property owners complied with the ordinance and submitted
engineering reports detailing structural deficiencies and recommendations to strengthen
structures to alleviate the threat of collapse. Further, approximately seventy-four percent
(74%), or sixty-six buildings, were strengthened, demolished, or proposed to be demolished.
See (Attachment D) for current status of all inventoried properties.
Part of this success may be attributed to incentives that allowed upfront engineering report
costs be applied toward permit fees and the ability for property owners in the Downtown
Commercial (CD) district to add up to 2,500 square feet of new floor area, or twenty-five
percent (25%) of the existing building area, whichever is greater, to the site without having
to provide additional parking. This floor area bonus could be used onsite or transferred to
another owner or property in the Downtown Commercial district. Approximately twenty-
one (21) property owners took advantage of this incentive.
Despite its successes, twenty-three (23) buildings identified from that original inventory
remain vulnerable. Further, there are other building types in the City that were not
surveyed prior to adoption of the 1986 ordinance. For example, problems with soft story
wood-frame construction were documented following the 1994 Northridge Earthquake,
which resulted in changes to construction industry standards a few years later.
In 2003, the Collaborative for Disaster Mitigation at San Jose State University completed an
“Inventory of Soft-First Story Multi-Family Dwellings in Santa Clara County.” According to
the report, the City of Palo Alto had 130 soft story multi-family buildings including 1,263
residential units housing 3,158 occupants.
Other construction types of concern that were not surveyed in 1986 include non-ductile
concrete buildings, older steel moment frame buildings, and older concrete tilt-up buildings,
in addition to soft story wood-frame construction.
The City’s existing ordinance requires annual reporting to the City Council on the status of
the program. This reporting appears to have ended in 2004 for unknown reasons. More
recently, the City Council adopted an ordinance (Attachment E - update to ORD 5356)
modifying the seismic incentive so that parking must now be provided if an owner seeks to
add 2,500 square feet or 25% of the total building area in the CD District.
Policy and Services Recommendation and Council Authorization
On December 9, 2014, the Policy and Services Committee of the Palo Alto City Council
Attachment E
City of Palo Alto Page 4
recommended the City Council authorize a Request for Proposal (RFP) to develop
information for use in updating the City’s Seismic Hazards Identification Program (Ordinance
3666). See Staff Report 5293 “Discussion of Updating the Seismic Safety Chapter of the
Municipal Code for Hazardous Buildings” (Attachment D). The City Council approved the
recommendation and an RFP was prepared. A consulting team led by Rutherford + Chekene
was selected to:
A. Develop summarize relevant state and local seismic mitigation legislation
B. Obtain detailed information on Palo Alto’s existing building stock
C. Develop conceptual retrofits for vulnerable building types
D. Make loss estimates of expected damage to current and retrofitted building
E. Work with a City advisory group to develop policy recommendations for
consideration by the Council.
A stakeholder Advisory Group was convened and was an essential element in discussing
earthquake risks in Palo Alto’s existing building stock prepared by the consultant team and in
reviewing policy alternatives. Members included people with a range of relevant expertise
and interests, including interested citizens, earthquake risk and engineering experts, local
developers and owners, and representatives of various community groups. City
departments also participated in the Advisory Group, including Building, Planning, Fire,
Office of Emergency Services, and Public Works. See Attachment F for a list of Advisory
Group members.
City Policy Implications
Currently, the City is in the process of updating its Comprehensive Plan. In its Goal
statements, this document expresses the community’s vision for its future. Further, in its
policies, the Plan defines the appropriate actions to implement the vision. The Seismic Risk
Assessment Study’s findings and its guiding conclusions informed by the Seismic Risk
Management Advisory Group are integral to several key elements of the Comprehensive
Plan: the Safety Element, the Housing Element, and the approach to, and needs for,
coordinated Community Emergency Services. Policies being considered in the
Comprehensive Plan Safety Element support regular review and update of the City’s seismic
retrofit regulations.
Although focused on multiple family and commercial structures, the seismic risk assessment
identifies both the type of seismically vulnerable structures and the geographic areas in the
community that will be most affected by a major earthquake. To gage the impact, the study
looked at the cost of retrofitting each type of structure. It also evaluated the community
impact of the aftermath of a major earthquake in terms of loss of property and effect on the
City’s economy.
Palo Alto is currently participating with the other cities in the County in updating the State
and Federally mandated five-year update of the Santa Clara County Local Hazard Mitigation
Attachment E
City of Palo Alto Page 5
Plan (Santa Clara LHMP) as required by the Federal Disaster Mitigation Act of 2000. This
plan is required before Palo Alto can request FEMA assistance following a natural disaster.
The Local Hazard Mitigation Plan focuses on community mitigations to fire, flood and
earthquake events.
The data in the Seismic Risk Assessment Study will be useful as a tool to inform the Santa
Clara LHMP about the City’s needs in the event of a major earthquake. The Council’s
subsequent direction on revising of the City’s seismic renovation requirements will be
integrated into Palo Alto’s mitigations outlined in the Santa Clara LHMP plan.
The Seismic Risk Assessment Study and its implementation have important implications for
both City and emergency planning policy. First and foremost, the study provides valuable
information for the development of the City’s long range planning policy expressed in the
Comprehensive Plan in areas of community safety, housing, and coordination of community
services, which also includes community education and neighborhood volunteers. It also
provides information that can be used to refine the community’s vision regarding its
residents’ wellbeing and improve its preparedness for a major seismic event by addressing
risk to loss of life and property associated with vulnerable building types. The information
can also improve the community’s ability to recover from a major seismic event including
displacement of residents and businesses, loss of housing and commercial buildings and
community wide economic impacts and recovery.
Other policy implications involve the potential for displacement of existing uses and tenants
if building owners need to remove the uses/tenants to upgrade their buildings or if they
increase rents to cover the cost of engineering studies and retrofit work, and the how this
displacement can be minimized. Also, potential incentives for voluntary building retrofits
may need to be considered along with changes to the existing zoning incentives (Transfer of
Development Rights program) that grant bonus square footage to buildings that are
retrofitted downtown, and the potential impacts/benefits that might result from new
incentives or modifications.
SEISMIC RISK ASSESSMENT STUDY
The risk assessment carried out by R+C included a series of task reports. They have been
combined into one composite report as Attachment B and include surveys of state and local
seismic policies and practices, an inventory of buildings in Palo Alto, a summary of vulnerable
building categories, conceptual seismic retrofitting of representative vulnerable buildings, loss
estimates for the current condition of the building stock and if buildings are retrofit, a review of
past seismic retrofits in Palo Alto from selected City records, and a discussion of additional
recommended program features for an improved seismic risk mitigation program.
Table 1 summarizes the outcome of the seismic risk assessment and includes the Advisory
Group discussions. The table is organized around eight vulnerable building categories or
building types. Categories I, II and III encompass the identified vulnerable buildings for the
Attachment E
At
t
a
c
h
m
e
n
t
E
,,
Table 1: Summary of Recommended Policy Directions from the se1smic Risk Management Program Advisory Group
Category Approx. Building Date of Occupants Evaluation Voluntary, Deadlines for Evaluation Report and Disclosure Potential Incentives
Number Type Construction Report Triggered, or Retrofit Construction (years)1
Mandatory
Retroflt1
Current Program (Potential Revision In Italics)
I 10 Un-N/A Over6 Required Mandatory Report: Expired Website Fee waiver, expedited
reinforced (and over Construction: 2-4 listing and permitting, FAR bonus/
masonry l,900Sf} tenant trans/ er of development
II 4 Any Before 1/1/35 OverlOO Required Voluntary or Report: Expired notification rights (TDR)
Triggered Construction
Ill 9 Any Before 8/1/76 Over300 Required Voluntary or • Voluntary: Not required
Triggered • Triggered: At sole or renovation
Expanded Program
IV 294 Soft-story Before 1977 Any Required Triggered or Report: 2-4 Same as Fee waiver, expedited
wood Mandatory Construction above permitting, TOR, parking
frame • Triggered: At sale or renovation exemptions, permission to
• Mandatory: 4-6 add units
V 99 Tilt-up Before 1998 Any Required Triggered or Report: 2-4 Same as Same as Categories I, II and
Mandatory Construction above Ill
• Triggered: At sale or renovation
• Mandatory: 4-6
VI 37 Soft-story Before 1977 Any Required Voluntary, Report: 2-4 Same as Same as Categories I, II and
concrete Triggered or Construction above Ill
Mandatory • Voluntary: Not required
VII 35 Steel Before 1998 Any Required Voluntary, • Triggered: At sale or renovation
moment Triggered or • Mandatory: 6-8
frame Mandatory
VIII TBD Other older Before 1977 Any Not rec. at Not Report: N/A N/A N/A
non-ductile this time recommended Construction: NA
concrete at this time
'voluntary: Retrofit Is voluntary.
Triggered: Retrofit Is triggered when the building ls sold or undergoes substantial renovation.
Mandatory: Retrofit ls required per a fixed tlmellne.
2Deadllnes provide a potential range. Timellnes would vary depending on tiers or priority groupings of different subcategories.
City of Palo Alto Page 7
Figure 1: Category IV, Wood-frame Soft Story Building built before 1977 Earthquake Damage
Figure 2: Category I, Unreinforced Masonry Building Earthquake Damage
Figure 3: Category I, Unreinforced Masonry Building Earthquake Damage
Attachment E
City of Palo Alto Page 8
Survey of State and Local Seismic Policies
The risk assessment study includes two reports that address (1) a detailed review of the
seismic risk management policy context within the State of California including relevant
State legislation, and (2) the status of local seismic safety and mitigation programs.
Development of the reports included searches of legislative data bases, search and
review of published and online reports and materials, phone interviews with community
leaders as well as local and State government staff, and development of insights from
the consulting team based on their experiences in this arena. The two reports were
discussed at Advisory Group meetings and helped inform the development of potential
seismic risk management policies relevant to Palo Alto.
State Level Policy Review
The report on State level risk mitigation policies provides review of relevant historic and
pending State legislation related to seismic risk mitigation of vulnerable buildings. High
level legislative findings from the report include the following:
A. Palo Alto is affected by numerous relevant California existing laws and
regulations dating from the 1930s through the present. These laws regulate
many aspects of Palo Alto’s built environment, including certain classes of
building uses such as hospitals, public schools, and essential facilities; setting
code minimums for new construction; and mandating land use planning and real
estate disclosure measures for natural hazards including earthquakes.
Unreinforced masonry (URM) is at present the only structural system type for
which the State requires local jurisdictions to have a program.
B. If it so chooses, Palo Alto has wide authority to expand or strengthen its
approaches to seismic mitigation. The power to do more about earthquake
vulnerabilities is primarily in the hands of the local jurisdictions that have
significant discretion in the kinds of policies they can adopt.
C. Palo Alto has many additional actions it can take to make sure it is complying and
taking greatest possible advantage of State level regulations and opportunities.
In particular, opportunities exist now to align a new seismic program with two
ongoing mandated planning efforts the City is already engaged in: Palo Alto’s
Comprehensive Plan update and the Santa Clara County Local Hazard Mitigation
Plan update.
Based on what state laws allow and in some cases recommend policy directions Palo
Alto could pursue going forward include the following:
A. Implement measures to increase the effectiveness of its current program, for
instance by offering additional or larger incentives or devoting more resources to
program visibility and implementation
B. Expand the City’s current voluntary seismic mitigation programs to address
additional building types, uses, or sizes
Attachment E
City of Palo Alto Page 9
C. Add mandatory screening or evaluation measures for one or more vulnerable
building types such as soft-story wood frame or concrete buildings
D. Upgrade the City’s current voluntary URM program to make retrofitting
mandatory
E. Create a program that mandates seismic retrofits for one or more additional
(non-URM) vulnerable building types
F. Craft a program that combines any or all of the above measures. Local
precedents for all of these types of approaches exist
G. Continue the status quo current program
Local Program Best Practice Assessment
The local program best practices assessment report reviews current practices among local
jurisdictions and agencies that require seismic retrofitting. The report summarizes what has
been done legislatively and programmatically to increase awareness, assess, and motivate
mitigation of seismically vulnerable buildings.
Palo Alto is currently laying a solid foundation for future program development by investing
in new inventory and risk information as well as community outreach and internal staff
discussions. In doing so, it is joining a group of leading California coastal jurisdictions such as
Berkeley, Oakland, San Francisco and Los Angeles that have recently stepped up their
earthquake risk reduction efforts. San Leandro and Fremont have also had policies in place
for over a decade. While there is much learning and information sharing going on, each
jurisdiction has developed their own customized policy package. There is no single best
model that Palo Alto can straightforwardly adopt. Existing local approaches differ widely in
the following ways:
A. Policy mechanisms used to achieve progress
B. Scope of targeted building types or uses addressed
C. Prioritization for retrofit among vulnerable structures and compliance timeframes
D. Types of incentives offered to property owners
E. Disclosure measures used to increase public awareness
Policy Mechanisms
The policy mechanisms being used by other jurisdictions range from inventory only with no
subsequent requirements to mandatory retrofit completion in under five years. In between
are more gradual approaches such as voluntary retrofit advocacy, incentives, provisions that
make building deficiencies more visible to the public (disclosure measures), and mandatory
screening and evaluation requirements. An important policy decision is whether any
mandated actions are implemented on a fixed timeline or triggered at sale or at some
renovation cost threshold.
Attachment E
City of Palo Alto Page 10
Scope of targeted building types and characteristics
The most commonly addressed building type is unreinforced masonry (URM) construction
due to state law SB 547, passed in 1986. Over half of URM building programs in the state
require mandatory retrofit, often but not always, with a time frame on the order of ten to
twenty years. By 2006, seventy percent of all identified URM buildings statewide were
either demolished or retrofitted. Retrofit rates on average were three times higher in
jurisdictions with mandatory retrofit compared to voluntary programs. Jurisdictions used a
wide variety of both financial and policy incentives to assist URM building owners. Some
voluntary URM building programs coupled with incentives, including Palo Alto’s, have
achieved similar rates of success to mandatory programs.
More recent programs have focused on soft-story wood frame multi-family residential
buildings, including ten Bay Area jurisdictions and, most recently, Los Angeles as of 2015.
Soft-story wood frame building programs range in requirements from notification only to
mandatory retrofit. Several jurisdictions have innovatively used intermediate mandatory
screening and evaluation phases to further assess risk exposure and determine the final set
of buildings that will be affected by retrofit requirements. Soft-story wood frame programs
have largely been supported in the local community. Compliance timeframes in soft-story
wood frame programs tend to be short, on the order of two to seven years.
A comparatively small number of Southern California jurisdictions have acted to address
older concrete buildings, including Los Angeles, Burbank, Santa Monica, and Long Beach.
Non-ductile concrete frame and tilt-up concrete structures, in particular, are known to pose
serious risks. Programs aimed at older concrete buildings range from voluntary guidelines to
mandatory evaluation and full retrofit requirements. Timeframes on mandatory retrofit of
older concrete buildings vary greatly, from years to decades. Information about the
implementation and outcomes of these few programs is very limited.
Incentives
To complement program compliance requirements, jurisdictions can offer either financial or
policy oriented incentives. Financial incentives in increasing order of cost and
implementation difficulty include: waivers or reductions of building department fees, pass
through of retrofit costs to tenants (in jurisdictions with rent control), property-assessed
financing loads, subsidized or special term loans, real estate transfer tax rebates, special
district or historic designation tax reductions, tax credits, grants, and general obligation
bonds. Program incentives in order of increasing difficulty include exemption from future
retrofit requirements, expedited reviews, exemption or relief from standards or non-
conforming conditions, condominium conversion assistance, technical assistance for
retrofitting, zoning incentives, transfer of development rights, and density or intensity bonus
such as a floor area or floor area ratio bonus. Jurisdictions vary widely in the extent and type
of incentives offered, and many offer a number of different types of incentives.
Attachment E
City of Palo Alto Page 11
Disclosure Measures
Public disclosure provides a powerful mechanism for influencing the opinions and actions of
owners, renters, and buyers, particularly in programs without mandatory retrofitting
requirements. Officially publicizing a city’s concerns about deficiencies of a specific building
type could, for instance, change public opinion about the resale or rental value of listed
properties, an owner’s eligibility for refinancing or future loan terms, or the cost of
purchasing property and earthquake insurance.
Jurisdictions have used a variety of techniques to motivate attention to seismic risk
concerns.
Disclosure measures include the following:
A. Mandatory disclosure at time of sale: Sellers of property are required to disclose
features that could relate to earthquake performance.
B. Recorded notice on deed: Jurisdictions can record on the property title or deed, the
fact that the building is subject to additional requirements related to its seismic
vulnerability status.
C. Public listing of affected properties: Jurisdictions that operate web sites to describe
their programs can feature a full list of property addresses and the compliance status
of the property. Generally, owner names are not listed.
D. External signage: California law requires signage on all URM buildings. Similar
signage has been required since 2007 on soft-story wood frame buildings in the City
of Berkeley and non-complying soft-story wood frame buildings in San Francisco.
E. Tenant notification: Owners are required to present straightforward, standardized
information about the listed status of the property.
F. Earthquake performance rating systems: Owners can be either encouraged or
required to have their building rated on a standardized scale that classifies expected
performance in an earthquake. In 2015, the City of Los Angeles launched a voluntary
effort to encourage owners to rate the properties using the US Resiliency Council’s
rating system and pledged to rate its own public buildings. For more information
about the US Resiliency Council, see their website at <http://www.usrc.org/>.
Palo Alto Options
Based on the review of state and other jurisdiction policies, alternative program options
for Palo Alto were identified:
1. Status Quo: In this option, the existing ordinance with its mandatory evaluation,
voluntary retrofit approach remains in place without changes. Floor area ratio
bonuses are (were) available and could continue to be offered.
2. Increase Number of Building Types Regulated, but Retrofit Remains Voluntary:
Additional categories of structures are added to the mandatory evaluation
requirements beyond those of the current ordinance. These could include any or
Attachment E
City of Palo Alto Page 12
all of the building types discussed above, potentially also using additional location,
use, or occupancy criteria.
3. Increase Number of Building Types Regulated with Additional Disclosure Measures
Incorporated: This option would be similar to Option 2, but with increased use of
disclosure measures such as prominently posting the building list on the City
website, notifying tenants, requiring signage, and/or recording notice on the
property title.
4. Increase Number of Building Types Regulated, Some Building Types Have
Voluntary Retrofit and a Few Building Types Have Mandatory Retrofit, with
Enforcement by a Trigger Threshold: This option builds on Option 3, but
retrofitting would be required for some building types at whenever future time a
building is sold or undergoes substantial renovation above a set threshold.
5. Increase Number of Building Types Regulated, Retrofits for Some Categories are
Voluntary and a Few Categories are Mandatory, with Enforcement by a Fixed
Timeline: This option would be similar to Option 4, but retrofitting is required
according to a fixed timeline. Timelines and enforcement emphasis could vary
depending on tiers or priority groupings to motivate prompt action for the most
vulnerable or socially important structures.
6. Increase Number of Building Types Regulated, but More Categories are Required
to Have Mandatory Retrofits: This alternative is similar to Option 5, but retrofitting
would be required for additional categories on a fixed timeline.
Other Program Features and Implementation Factors
By updating its current ordinance, Palo Alto has a variety of opportunities to expand and
better link its earthquake mitigation program efforts to other City efforts in support of
community resilience goals. For instance, Palo Alto could encourage a building occupancy
and resumption program like San Francisco, encourage or fund installation of strong
motion instruments, or pursue special programs or requirements for cell phone towers,
facades, private schools, and/or post-earthquake shelter facilities. A detailed description
of several leading local program models and planning resources for these types of efforts
are included in Attachment B.
Building Inventory
Summary of Survey Methodology
One of the first steps in the Seismic Risk Assessment Study was to develop a digital
inventory of buildings in Palo Alto that includes all the information necessary to build the
exposure model for the loss estimate. Information sources used to develop the inventory
included county tax assessor files, City GIS files, a survey done by the Palo Alto Fire
Department and San Jose State University of soft-story wood frame buildings, field notes
from the building department files of selected buildings when the 1986 ordinance was
being developed, Google Earth and Street View visual reviews, and an extensive visual
sidewalk survey.
Attachment E
City of Palo Alto Page 13
After the sidewalk surveys and additional quality assurance refinements, the study
identified a total of 2,632 buildings in the study group for Palo Alto. This included 66
buildings subject to Palo Alto’s current seismic mitigation ordinance, because 23 of the
original 89 buildings subject to the ordinance have been demolished.
Not all buildings were field surveyed and not all key attributes needed for loss estimation
were available for all buildings. For buildings that were not surveyed and were missing
information, the missing attributes were developed using statistical comparisons with
buildings that were surveyed on a sector- by- sector basis. A multi-step procedure was
developed to fill in other missing attributes based on the best available comparative
information. As a result, while the information for buildings that were not surveyed may
not be fully accurate at the individual building level, the overall data set is seen as
sufficiently representative for the type of loss estimates used in the project and relative
comparisons made between different building types that are discussed ahead.
Replacement Cost Values for Palo Alto
In addition to the information discussed above, a locally-customized replacement cost
had to be established for each building. Standard 2014 RS Means Replacement Cost
values included in the project loss estimation software (Hazus) used were reviewed as a
starting point, but not considered representative for Palo Alto. R+C and Vanir
Construction Management prepared adjustments to RS Means values to capture 2016
data and local factors unique to Palo Alto. These were reviewed by a task group of the
City’s project Advisory Group that included local design professionals and developers
familiar with the local cost climate. The group recommended an increase of the values in
general and identified target values for selected common occupancies. Based on these
recommendations, R+C updated the values and Vanir reviewed them and revised the
non-targeted occupancies for estimating consistency. The resulting replacement costs
are shown in Table 2, and were used in the loss calculations. It is noted that resulting
costs are 1.7-2.6 times the RS Means-based Hazus default values (2014 cost data), and
that costs are intended to be representative of averages across the town.
Attachment E
City of Palo Alto Page 14
Table 2: Average $/SF replacement building cost by Hazus occupancy class.
Occupancy Class RS
Means
2014
Average
Palo
Alto
Cost1
[$/SF]
Market
Factor
for
Palo
Alto
Escalation
Factor
from 2014
costs to
2016
costs
Demo &
Minimal
Sitework
(5’
around
building)
[$/SF]
Soft Cost
Premium2
Average
2016
Palo
Alto
Cost w/
Soft
Costs
[$/SF]
Multiplier
(Replaced
with Soft
Costs / RS
Means)
Multi Family, duplex $130.75 40% 10% $17.50 20% $263 2.01
Multi Family, triplex/quad $114.94 40% 10% $17.50 20% $233 2.03
Multi Family, 5-9 units $206.41 40% 10% $17.50 20% $402 1.95
Multi Family, 10-19 units $194.12 40% 10% $17.50 20% $380 1.96
Multi Family, 20-49 units $212.26 40% 10% $17.50 20% $413 1.95
Multi Family, 50+ units $199.90 40% 10% $17.50 20% $390 1.95
Temporary Lodging $217.83 40% 10% $17.50 20% $424 1.94
Institutional Dormitory $234.44 50% 14% $25.00 20% $511 2.18
Nursing Homes $238.07 50% 12% $25.00 20% $510 2.14
Retail Trade $121.66 80% 10% $17.50 20% $310 2.55
Wholesale Trade $118.13 60% 10% $17.50 20% $$270 2.29
Personal & Repair Services $143.47 60% 10% $17.50 20% $324 2.26
Professional/Technical/ Business
Services
$194.52 65% 12% $17.50 20% $452 2.33
Banks $281.88 40% 12% $25.00 20% $560 1.99
Hospitals $372.59 50% 14% $35.00 20% $807 2.16
Medical Office/Clinics $267.85 20% 10% $17.50 20% $445 1.66
Entertainment/Recreation $248.61 25% 12% $25.00 20% $448 1.80
Theaters $186.45 35% 12% $25.00 20% $368 1.98
Parking $84.59 20% 10% $17.50 20% $155 1.83
Heavy $144.71 25% 10% $17.50 20% $260 1.80
Light $118.13 25% 10% $17.50 20% $216 1.83
Food/Drugs/Chemicals $229.48 30% 12% $17.50 20% $422 1.84
Metal/Minerals Processing $229.48 30% 12% $17.50 20% $422 1.84
High Technology $229.48 40% 14% $17.50 20% $461 2.01
Construction $118.13 30% 10% $17.50 20% $224 1.89
Church $118.13 50% 12% $25.00 20% $268 2.27
Agriculture $199.08 10% 12% $17.50 20% $315 1.58
General Services $152.63 40% 10% $17.50 35% $341 2.23
Emergency Response $259.52 40% 14% $25.00 35% $593 2.28
Schools/Libraries $193.00 40% 12% $25.00 35% $442 2.29
Colleges/Universities $214.91 60% 12% $25.00 35% $554 2.58
Notes:
1. RS Means average cost includes RS Means default location factors to adjust national average to Palo Alto of 15% for
residential and 11% for commercial.
2. Soft costs include architect and engineer design fees, testing and inspection, utility connection fee, permits, and an
allowance for owner change order contingency.
3. Costs are intended to be representative of average in Palo Alto across the town, including downtown areas together
with other areas in the city.
4. Costs were previously prepared following a 3/7/2016 discussion with the Palo Alto Seismic Risk Program Advisory
Group Technical Advisory Committee. Table includes minor updates based on internal review between
Attachment E
City of Palo Alto Page 15
Rutherford + Chekene and Vanir Construction Management to achieve improved relative ratios between
different occupancy types.
Number and Distribution of Vulnerable Buildings by Aggregate Size and Value
Table 3 shows how the number and aggregate value of Palo Alto’s buildings is distributed
by type of structure, using the FEMA Model Building Type classification system for
structural system. The table is sorted by aggregate building value. Wood frame buildings
make up about 60% of the number of buildings and represent 35% of the total value.
About 20% of the buildings are concrete, and they represent over 40% of the total value.
Of the remaining 20%, about two-thirds are masonry buildings, and one-third steel.
However, the steel buildings represent about twice the value of the masonry buildings.
Attachment E
City of Palo Alto Page 16
Table 3: Distribution of number of buildings, building area,
and building value by Model Building Type.
Model Building Type Number of
Buildings
Aggregate Square
Feet (1,000)
Aggregate Building
Value ($M)
Concrete shear wall (C2) 318 9,699 4,082
Concrete tilt-up (PC1) 242 8,054 3,368
Wood frame larger residential (W1A) 331 8,403 3,232
Wood frame commercial/industrial (W2) 307 6,209 2,369
Steel braced frame (S2) 50 3,116 1,391
Wood frame smaller residential (W1) 898 3,821 1,278
Steel moment frame (S1) 75 3,005 1,242
Reinforced masonry, wood floor (RM1) 285 2,806 1,209
Reinforced masonry, concrete floor (RM2) 30 574 211
Steel light metal frame (S3) 41 533 177
Precast concrete frame (PC2) 5 334 125
Concrete moment frame (C1) 18 325 117
Steel frame with concrete shear walls (S4) 13 162 72
Unreinforced masonry bearing wall (URM) 9 274 15
Concrete with masonry infill (C3) 8 26 8
Steel frame with masonry infill (S5) 2 6 3
Totals 2,632 47,346 18,899
The study group of buildings can be further divided into age groups separated by
significant milestones in building code implementation. The following age groups were
selected: pre-1927, 1927-1961, 1962-1976, 1977-1997, and 1998 to present. The
milestones reflected include the first earthquake code in Palo Alto in 1926, adoption of
the 1961 Uniform Building Code (UBC) and associated more stringent design
requirements, code changes in the 1976 UBC following the 1971 San Fernando
Earthquake, and code changes in the 1998 UBC following the 1994 Northridge
Earthquake. Figure 1 shows a histogram of the year built of the buildings in the study
group.
Attachment E
City of Palo Alto Page 17
Figure 1: Distribution of year built of buildings in study group with significant changes in the
building design practice.
Vulnerable Building Categories
One of the important tasks in the risk assessment study was to identify potentially
vulnerable building categories specific to Palo Alto. Using the building inventory that was
developed early in the project, R+C identified potentially vulnerable structural system
types based on insights from past earthquake events, milestone improvements in seismic
code requirements made in Palo Alto, rankings in prominent seismic risk assessment tools
such as the 2015 edition of FEMA P-154 Rapid Visual Screening of Buildings for Potential
Seismic Hazards, results from past seismic risk assessment studies in California
communities, and engineering judgment. The building categories were then evaluated in
analytical loss estimate studies, described ahead, which helped to narrow in on the most
important categories for Palo Alto. Key building vulnerability metrics include the risk of
deaths and injuries, the cost of damage, and the extent of downtime or loss of use.
Buildings in the identified vulnerable building categories tend to perform poorly with
respect to all three of these metrics though the relative degree of vulnerability to each
factor varies.
Attachment E
City of Palo Alto Page 18
Community Resilience
Community resilience is improved if residents have homes that remain usable after an
earthquake and if businesses can still operate. From a program perspective, the consultant
team and advisory group believe that the greatest reduction in losses and the largest benefit
to community resilience will come from seismically retrofitting building types known to be
both potentially hazardous and present in significant numbers in Palo Alto. .
In addition to the three categories already in Palo Alto’s seismic hazard identification
ordinance (Categories I, II, and III below), five additional categories of vulnerable building
types were identified. All five categories meet the criteria of being potentially hazardous
and having a significant presence in Palo Alto. The eight categories and the approximate
number of buildings included in each category are as follows:
1. Category I: Constructed of unreinforced masonry, except for those small than 1,900
square feet with six or few occupants (10 remaining buildings in Palo Alto)
2. Category II: Constructed prior to January 1, 1935 containing 100 or more occupants
(4 remaining buildings)
3. Category III: Constructed prior to August 1, 1976 containing 300 or more occupants
(9 remaining buildings)
4. Category IV: Pre-1977 soft-story wood frame (294 buildings)
5. Category V: Pre-1998 tilt-up concrete (99 buildings)
6. Category VI: Pre-1977 concrete soft-story (37 buildings)
7. Category VII: Pre-1998 steel moment frame (35 buildings)
8. Category VIII: Other pre-1977 concrete construction (170 buildings)
The technical assessment confirms that the potential reduction in losses from retrofitting is
significant for these categories.
Conceptual Seismic Retrofitting of Representative Vulnerable Buildings
Retrofit was considered for all buildings that have not already been retrofitted and were
either constructed before 1961 or between 1962 and the “benchmark” year with a soft
story. A “benchmark” year is when the code requirements for that building type became
similar to those currently in place. Consistent with typical practice, the performance of the
retrofitted buildings in an earthquake is assumed to be less than that of newly constructed
buildings.
Attachment E
City of Palo Alto Page 19
For estimating the cost of retrofit for the improved buildings, R+C developed conceptual
designs for Model Building Types that represent a significant number and value of Palo Alto’s
building stock, as well as a significant loss and loss reduction after retrofit. This process
identified wood frame (W1, W1A, W2), steel moment frame (S1), concrete shear wall (C2),
concrete tilt-up (PC1), and reinforced masonry (RM1) and unreinforced masonry (URM) as
appropriate candidates. For each Model Building Type, the age, square footage and number of
stories were reviewed to identify a “prototype” building. In cases where the prototype building
was not representative of more than two-thirds of the total number of buildings, multiple
prototypes were considered.
Figure 2: Retrofit scheme for Large Multi-family Soft-Story Wood Frame Building.
An example of a conceptual retrofit for the W1A prototype building is shown in Figure 2
from a 2000 brochure by R+C for the City of San Jose entitled “Practical Solutions for
Improving the Seismic Performance of Buildings with Tuck-under Parking.” The retrofit
elements were keyed to representative details in 2006 FEMA 547 Techniques for the Seismic
Attachment E
City of Palo Alto Page 20
Rehabilitation of Existing Buildings, and a written description of collateral impacts was
developed as well to provide sufficient detail to allow a rough order of magnitude cost
estimate to be prepared.
The cost estimators of Vanir Construction Management used the conceptual designs to
estimate a range of probable cost to implement the retrofits. The retrofit costs for each
prototype building are shown in Table 4. These costs include hard costs, which are the costs
the owner pays the contractor, plus a design contingency since these are conceptual
retrofits. The estimate further includes soft costs, representing architect and engineer
design fees, testing and inspection costs, permit fees, and an owner change order
contingency.
Considered costs do not include hazardous material abatement, costs associated with
performing the work while occupants are using the building, triggered accessibility upgrades,
cost premiums associated with retrofit of a historic building, tenant relocation or business
interruption during construction, project management, renovation, financing, repair of
existing conditions, and legal fees. These costs are more variable and project and site
specific, and are typically not included in loss estimates for this type of study.
The retrofit costs were extrapolated to Model Building Types not represented by a prototype
retrofit as shown in the fifth column of Table 4.
Additional information the conceptual retrofits and their estimate cost is contained in
Attachment B.
Attachment E
City of Palo Alto Page 21
Table 4: Conceptual retrofit cost.
Retrofit
Prototype
Model Building Type Stories Square
Feet
Used for
Model
Building
Types
Used for
Square
Feet
Average
Retrofit
Cost
($/SF)
1 Wood frame smaller
residential (W1)
2 5,320 W1 All 12
2 Wood frame larger
residential (W1A)
2 9,500 W1A < 15,000 11
3 Wood frame larger
residential (W1A)
3 30,000 W1A ≥ 15,000 6
4 Wood frame
commercial/industrial (W2)
2 10,000 W2 All 14
5 Steel moment frame (S1) 2 43,900 S1, S2, S3 All 10
6 Concrete shear wall (C2) 1 5,000 C1, C2, S4,
PC2
< 10,000 50
7 Concrete shear wall (C2) 2 17,280 C1, C2, S4,
PC2
≥ 10,000 40
8 Concrete tilt-up (PC1) 1 18,435 PC1 < 25,000 29
9 Concrete tilt-up (PC1) 2 38,400 PC1 ≥ 25,000 21
10 Reinforced masonry, wood
floor (RM1)
1 2,750 RM1, RM2 < 5,000 74
11 Reinforced masonry, wood
floor (RM1)
2 8,150 RM1, RM2 ≥ 5,000 46
12 Unreinforced masonry
bearing wall (URM)
1 5,000 URM, S5, C3 All 110
Attachment E
City of Palo Alto Page 22
Loss Estimate Findings for Current Condition
Hazus is a geographic information system (GIS) based, standardized, nationally applicable
multi-hazard loss estimation methodology and software tool. It is used by local, state, and
federal government officials for preparedness, emergency response, and mitigation
planning. The Advanced Engineering Building Module from the latest Hazus version 3.1 was
used to conduct the loss estimates in the study so that individual buildings could be analyzed
using the specific inventory data collected for Palo Alto.
Analyses were conducted for two specific earthquake scenarios developed by the United
States Geological Survey (USGS): a major M7.9 San Andreas Fault event, and a strong M6.7
San Andreas Fault event.
Contour plots for the short period spectral acceleration for the two M6.7 and M7.9 scenarios
are shown in Figure 3. Spectral acceleration is a measure of the building response to shaking
at the site.
Figure 2: Predicted short period spectral acceleration in vicinity of Palo Alto (city boundary
shown) for two selected San Andreas Fault scenarios.
Attachment E
City of Palo Alto Page 23
Estimated Losses for Buildings in Their Current Condition
Table 5 summarizes the total loss calculated by Hazus for the as-is condition for the two
earthquake scenarios. The results show that the estimated losses to Palo Alto buildings
and contents in a M6.7 scenario will be significant, on the order of $1.2 billion. Though
ground shaking in the M7.9 scenario is only about 25% larger than it is in the M6.7
scenario, overall building and content losses double to $2.4 billion. Average building
damage and content damage also approximately double with a M7.9 event. The
difference in the number of buildings that are heavily damaged with the larger
earthquake is more pronounced with a 12-fold increase from the M6.7 to the M7.9
scenarios. This is shown in the fourth column of Table 5 as the number of buildings with a
damage ratio exceeding 20%.
Table 5: Total losses for study group in as-is condition.
Earthquake
Scenario
Building
Value1
($B)
Content
Value2
($B)
Number of
Bldgs.
with
Damage
Ratio ≥
20%3
Estimated
Building
Damage4
($B)
Estimated
Content
Damage4
($B)
Total
Building
and
Content
Damage
($B)
M7.9 18.9 17.3 224 1.7 0.7 2.4
M6.7 18.9 17.3 19 0.8 0.4 1.2
Ratio of M7.9/M6.7 2 2 2
Notes:
1. Building value is the complete replacement cost for the building, and
includes the structure, architectural, mechanical, electrical, and plumbing
components (e.g., ceilings and lighting).
2. Content value includes the complete replacement cost of furniture and
equipment that is not integral with the structure (e.g., computers and
other supplies). They are estimated as a percent of structure replacement
value, dependent on occupancy.
3. Damage ratio is defined as the cost of repairing damage divided by the
replacement cost of the building.
4. Estimated building and content damage cost is the cost associated with
repair and replacement of the building and its content.
To put the loss from building damage in context, the average annual valuation of Palo
Alto construction permits was $400M between 2013 and 2016 (which represents a boom
period). The total loss of $1.7B in a major M7.9 earthquake represents more than four
years’ worth of construction, and the total loss of $0.8B in a strong M6.7 earthquake
represents more than two years’ worth of construction.
It should be noted that these losses do not include the effects of lives lost and business
disruption, or the ripple effects in the local economy or real estate market. Much of this
loss will not be insured.
Attachment E
City of Palo Alto Page 24
Estimated Losses by Building Type
It is important to look at multiple metrics when deciding which buildings are the most
vulnerable and significant to the community as a whole. Table 6 breaks out the estimated
loss and damage ratio for various model building types, and it can be seen that it depends
on the metric used which building type is considered the poorest performer. Looking at
the total loss alone, concrete bearing wall buildings and commercial wood frame
buildings are responsible for the highest total loss. This tracks well with the earlier
finding that these structural systems are the most prevalent ones. If we look at the
highest average building damage ratio instead, buildings with unreinforced masonry
bearing walls and unreinforced masonry infills are the most prone to damage. However,
not very many of them exist in Palo Alto, and as a result they do not represent much of
the aggregate loss.
Additional information on the loss estimate for the existing building stock is contained in
Attachment B.
Table 6: Top three vulnerable building types ranked by total loss, average damage ratio,
and number of severely damaged buildings.
Building Type Number
of
Buildings
Building
Value
($M)
M7.9 EQ
Total
Building +
Content
Losses
($M)
M7.9 EQ
Average
Building
Damage
Ratio
M7.9 EQ
Number
of
Bldgs.
with
Damage
Ratio ≥
20%
Concrete shear wall (C2) 318 4,082 477 14% 75
Concrete tilt-up (PC1) 242 3,368 365 12% 32
Wood frame commercial/industrial (W2) 307 2,369 216 9% 9
Steel frame with masonry infill (S5) 2 3 1 38% 1
Unreinforced masonry bearing wall (URM) 9 15 4 29% 9
Concrete frame with masonry infill (C3) 8 8 2 29% 6
Concrete shear wall (C2) 318 4,082 477 14% 75
Concrete tilt-up (PC1) 242 3,368 365 12% 32
Steel moment frame (S1) 75 1,242 130 18% 27
Loss Estimate Findings with Buildings Retrofitted
A second Hazus AEBM run was done assuming a retrofitted building stock. For this model
run, it was assumed that a building would be retrofitted if it has not already been
retrofitted and was either constructed before 1961 or between 1962 and the benchmark
year with a soft story. The Hazus model was rerun with the updated properties
simulating retrofit.
Attachment E
City of Palo Alto Page 25
Table 7 shows the resulting total losses and damage ratios after buildings have been
retrofitted. Though total losses are still significant, comparing the results of Table 7 with
Table 5 shows a reduction in total loss of 45% for the M7.9 scenario, and 33% for the
M6.7 scenario. In other words, aggregate loss to the community if all considered
properties were retrofit could be reduced by one third in a very plausible event and
almost halved in a much larger event.
Another important improvement is the reduction of the number of buildings with more
than 20% damage. The M7.9 scenario shows a reduction from 224 buildings to 6
buildings. This means that the probability of building collapse and resulting injuries and
fatalities has become very low.
Finally, the damage and loss of the M7.9 scenario remain approximately two times the
amount of loss sustained in the M6.7 scenario. This suggests that the retrofit has a
similar impact for both levels of ground shaking.
Table 7: Total losses after retrofitting.
Earthquake
Scenario
Building
Value
($B)
Content
Value
($B)
Estimated
Building
Damage
($B)
Number
of Bldgs.
with
Damage
Ratio ≥
20%
Estimated
Content
Damage
($B)
Total
Building
&
Content
Damage
($B)
M7.9 18.9 17.3 0.9 6 0.5 1.3
M6.7 18.9 17.3 0.5 0 0.3 0.8
Ratio of M7.9/M6.7 2 - 2 2
Table 8 breaks out the reduction in total loss by model building type for the M7.9
scenario, and shows the associated retrofit cost. The average reduction in loss varies by
building type. URM buildings showed the highest reduction in loss after retrofit as a
percentage of the loss itself. Steel braced framed buildings showed the lowest reduction
in losses as a percentage of the loss itself. Wood frame and concrete buildings are
responsible for the largest reduction in total loss, with wood frame construction
representing over 20% of the loss reduction, and concrete buildings over 50%.
It should be noted that the data in Table 8 also includes buildings that were not retrofitted. As
a result, further parsing of the data is needed to better understand which buildings are
responsible for the most loss, and those that can be improved more cost-effectively.
Table 8: Comparison of retrofit benefits and costs by Model Building Type.
Model Building Type M7.9 EQ M7.9 EQ Average Retrofit
Attachment E
City of Palo Alto Page 26
Average
Damage
($/SF)
Total
Damage
Reduction
($1,000)
Damage
Reduction
($/SF)
Cost
($/SF)
Wood frame smaller residential (W1) 16 13,775 4 12
Wood frame larger residential (W1A) 25 61,317 7 6-11
Wood frame commercial/industrial (W2) 50 160,155 26 14
Steel moment frame (S1) 62 76,150 25 10
Steel braced frame (S2) 44 24,222 8 10
Steel light metal frame (S3) 108 38,163 72 10
Steel frame with concrete shear walls (S4) 101 11,118 69 40-50
Steel frame with masonry infill (S5) 247 695 121 110
Concrete moment frame (C1) 55 8,045 25 40-50
Concrete shear wall (C2) 70 336,574 35 40-50
Concrete frame with masonry infill (C3) 120 865 34 110
Concrete tilt-up (PC1) 68 218,491 27 21-29
Precast concrete frame (PC2) 21 0 0 21-29
Reinforced masonry, wood floor (RM1) 59 87,697 31 46-74
Reinforced masonry, concrete floor (RM2) 35 3,727 6 46-74
Unreinforced Masonry Bearing Wall (URM) 23 5,216 19 110
Totals 51 1,046,210 22
Table 9 shows those types of buildings that may be considered good candidates for a
retrofit program. Although representing only about 15% of the total inventory, these
buildings are responsible for over 30% of the total loss. This is reflected in the
considerably higher than average loss (fourth column of Table 9). The benefit of retrofit is
also considerable for this group of buildings, since they are responsible for over 50% of
the reduction in loss. Additionally, the cost to retrofit them is only a fraction of the losses
avoided in a major event, ranging from a third for the concrete buildings to a tenth for
the steel frames. Note that these values are based on conceptual retrofits. Actual
retrofit costs for individual buildings would vary substantially. The steel moment frame
benefit-to-cost ratio is higher than expected by engineering judgment, caused in part by a
comparatively low retrofit cost for this Model Building Type.
Additional information on the loss estimate for the retrofitted building stock is contained
in Attachment B.
Table 9: Comparison of benefits and costs by selected
Model Building Type, date and characteristics.
Model Building Type Number
of
Buildings
Total
SF
(1,000)
M7.9 EQ
Average
Loss by
M7.9 EQ
Average
Loss
Average
Cost to
Retrofit
(Average
Loss
Avoided)
Attachment E
City of Palo Alto Page 27
Building
($/SF)
Avoided
by
Retrofit
($/SF)
($/SF) /
(Average
Retrofit
Cost)
Pre-1977 wood frame soft-
story (W1, W1A, W2)
294 3,690 66 46 12 4
Pre-1998 tilt-up (PC1) 99 3,078 106 71 23 3
Pre-1977 concrete soft-story
(C1, C2, C3)
37 842 149 108 42 3
Pre-1998 steel moment frame
(S1)
35 690 152 110 10 11
Review of Past Seismic Retrofits
To gain a better understanding of the quality of the retrofits and identify relevant issues to
updating Palo Alto’s seismic risk mitigation program, a sample of the submitted engineering
studies and building retrofits drawings for existing buildings was reviewed.
The review identified the following relevant needs for future seismic risk mitigation
programs:
A. Clear identification of retrofit design intent, scope, and limitations, also for voluntary
retrofits
B. Identification of existing structural systems
C. Decision on requirements for buildings that have had partial seismic retrofits
completed; and may have remaining seismic deficiencies
Attachment E
City of Palo Alto Page 28
Additional Recommended Program Features
In addition to expansion of the building categories included within the City’s seismic risk
mitigation program and refinement of disclosure measures and incentive options, a number
of other program features are recommended. They are described in Attachment B, and
include the following:
A. Use the current inventory, taking note of its limitations - The inventory developed for
the effort to date involved use of digital information and field surveys. A complete
field survey of all buildings in Palo Alto was outside the scope of the project.
However, the inventory that has been developed is an excellent resource. The first
step in any future ordinance will involve notification of building owners that they
may be subject to the requirements of the ordinance. Those buildings that were field
surveyed and fall within the scope of the ordinance can be notified using the existing
inventory. For the remaining buildings, additional field survey is recommended. This
would be a rapid visual assessment and could be conducted by City staff or outside
consultants.
B. Use an initial screening form phase - Typically, as part of the notification process, a
screening form of about one page in length is sent, and the owner is required to have
a design professional, such as a structural engineer or architect, complete the form.
This cost for to confirm whether or not the building actually is subject to the City’s
ordinance should be relatively nominal.
C. Clearly specify seismic evaluation and retrofit scope - For all buildings subject to
regulation, the seismic evaluation (and retrofit) methodology for each building
category will need to be defined. Industry consensus standards exist and cover the
vulnerable building categories identified for Palo Alto. These include the 2015
International Existing Building Code (IEBC) and 2014 ASCE 41-13 Seismic Evaluation
and Retrofit of Existing Buildings. Both are currently being updated by groups of
engineers and building officials. For soft-story wood frame buildings, there is also the
2012 FEMA P-807 Seismic Evaluation and Retrofit of Multi-Unit Wood-Frame
Buildings with Weak First Stories. For steel moment frame buildings, there is also the
2000 FEMA 351 Recommended Seismic Evaluation and Upgrade Criteria for Existing
Welded Moment Resisting Steel Structures. The following table provides
recommended evaluation and retrofit standards.
D. Provide detailed evaluation report submittal requirements - Minimum submittal
requirements for evaluation reports will need to be defined. The above evaluation
and retrofit standards provide some guidance but a short clear set of requirements
will be beneficial.
E. Specify how past partial retrofits will be handled: In the past, some buildings have had
partial seismic retrofits where only selected portions of the seismic force-resisting
system have been upgraded; Some seismic deficiencies may still exist in these
structures. If mandatory retrofit requirements are implemented that provide for
comprehensive retrofitting of the full seismic load path, there may be buildings with
previous partial retrofits that do not fully comply and need remaining deficiencies to
Attachment E
City of Palo Alto Page 29
be addressed. The seismic evaluation reports will help identify these cases.
F. Update both new and existing building permit submittal requirements: Review of City
records found that basic information such as the building structural system, date of
construction, and retrofit standard used (where applicable) are not readily available.
It is recommended that submittals for permit for both new buildings and existing
building renovations require this information. This will allow the city to have a much
better understanding of its total building stock and its expected performance in an
earthquake.
G. Write a new ordinance or set of ordinances to update the program: After the Council
has provided direction and the above issues have been addressed, an updated
ordinance will need to be written.
H. Carefully address program management and interdepartmental coordination needs:
To successfully manage Palo Alto’s updated Seismic Risk Mitigation Program, an
effective management plan is needed so that progress is monitored by the City and
community intent is achieved.
I. Delineate department and key staff responsibilities: For Palo Alto’s updated Seismic
Risk Mitigation Program, City staff will be responsible for several categories of
activities. These will include the basic activities such as managing the notification and
inventory process, reviewing evaluation reports and plan checking retrofit
construction documents, and field inspections of retrofit work. Less obvious activities
will include evaluating requested exceptions to the program or alternative means of
compliance; managing feedback from design professionals, owners, and the public;
tying pre-earthquake retrofitting to post-earthquake safety evaluations records; and
managing post-earthquake safety evaluation, repair, and recovery plans. Depending
on the scale of the updated program, it is possible that additional staff members,
consultants, and/or an appropriately experienced structural engineer may be needed
to provide advice on technical and program management issues, particularly as the
program moves to final definition and to initial implementation. Later, as is done in
some communities, it may be desirable to create volunteer review boards of local
structural engineers who review questions on the evaluation and retrofit criteria and
provide the City with technical opinions that staff can use.
Attachment E
City of Palo Alto Page 30
Table 10: Recommended Evaluation and Retrofit Standards.
Category Description Evaluation and Retrofit Standards
I Unreinforced masonry IEBC Appendix Chapter A1
II Built before 1/1/35 with 100 or
more occupants
ASCE 41
III Built before 8/1/76 with 300 or
more occupants
ASCE 41
IV Pre-1977 soft-story wood
frame
IEBC Appendix Chapter A4, ASCE 41, or FEMA P-807
V Pre-1998 tilt-up IEBC Appendix Chapter A2 and ASCE 41
VI Pre-1977 soft-story concrete ASCE 41
VII Pre-1998 steel moment frame ASCE 41, or FEMA 351
VIII Other pre-1977 concrete ASCE 41
ADVISORY GROUP INPUT
Summary Report of the Advisory Group
The purpose of convening an Advisory Group composed of members with local expertise and
construction experience was not to create a consensus document or ratify particular
recommendations by majority vote. Instead, the goal was to educate, solicit, and explore
the range of issues and opinions among interested parties who participated. A summary
report, reviewed by all the members of the Group, was prepared to document their input in
to the study (Attachment G). The Advisory Group was a first step in community engagement
regarding seismic hazard reduction in Palo Alto. It was intended that the information in the
Advisory Group’s summary memo would be provided to the City Council as they consider
potential revisions to the City of Palo Alto’s seismic risk management program and seismic
hazard identification ordinance.
Preferred Policy Directions
In summary, discussions with the Advisory Group revealed little to no support for
maintaining the status quo. Strong support did exist for retrofitting buildings already in
the program, particularly URM buildings, and for addressing more building types,
particularly soft-story wood frame buildings and older concrete tilt-ups.
For buildings addressed in the current ordinance, the group generally thought a
mandatory retrofit requirement would be feasible and fair. Three decades later, market
forces alone have clearly not been enough to motivate upgrade of these remaining
structures. Because the barriers to retrofit work for these properties are not known,
case-by-case management by City staff may be necessary. There was hesitance, however,
about extending or increasing incentives for owners that had not voluntarily taken
advantage of the FAR bonus available in the past.
More detailed conversations took place about other building category priorities and
Attachment E
City of Palo Alto Page 31
policy features focused on extending the vulnerable building types they addressed and
the requirements for retrofit compliance. These program alternatives are incorporated
into Options 3, 4, and 5 (see the “Survey of State and Local Seismic Policies” section). The
Advisory Group was briefed on structural types generally known to be vulnerable that are
common or significant to Palo Alto and estimated to have reasonable loss reduction to
retrofit cost ratios. The Group’s goal was to focus on a subset of categories that seemed
to have high potential to benefit the owner, occupants, and the broader community.
Some participants showed greater concern about residential properties, and debated
whether commercial and residential properties should be treated the same or differently.
The Advisory Group showed high interest in addressing multi-family residential
earthquake risks, in particular by starting a soft-story wood frame program as many other
California cities have done. One soft-story wood frame program approach discussed was
to have two phases: 1) owners following notification would be given several years to do a
voluntary retrofit, along with more generous incentives; and 2) later a mandatory
timeline would kick in and incentives would be phased out. The group noted that
exemptions such as parking requirements, permission to add other unit(s), or the ability
to transfer development rights for additional square footage would likely be attractive
and useful incentives for the multi-family soft story building type.
Other vulnerable building categories of concern were also reviewed, including pre-1977
tilt-up concrete structures. There are a modest number of these buildings in Palo Alto,
but Advisory Group members noted that their uses are changing. Many buildings
previously used as warehouses are now being repurposed for office space. The higher
occupancies increase the public safety stakes of any seismic deficiencies. Currently, there
is no mandate in the regulations to address earthquake vulnerabilities while other
upgrades and build out are being done to these structures. A substantial renovation
trigger mandate might make sense, but the percent of the value of the structure used as a
trigger might need to be lowered in order to get compliance. Such properties with more
than one story should perhaps receive higher priority for retrofit.
Potential Issues for Future Study and Consideration
For some issues, based in part on Advisory Group discussions, additional information may
be beneficial to help develop a strategy and to better understand potential impacts on
key stakeholders and community concerns. Some of these issues are primarily economic
and were outside the scope of the current study. The City Council may wish to direct staff
and/or outside consultants to investigate some of these items in more detail as the
seismic risk management program effort proceeds. These issues include the following:
A. Occupants and tenants
a. How much would a typical retrofit add to the monthly rent of a multifamily
Attachment E
City of Palo Alto Page 32
soft-story wood frame apartment tenant?
b. Would some tenants be unable to afford a rent increase and seek housing
elsewhere in Palo Alto or move outside the city (and if so, how many might
be displaced)?
c. If soft-story wood frame apartments in Palo Alto are retrofitted in time
before the next major earthquake, how much less displacement of
residents would occur as a result of the earthquake?
d. What categories of buildings are most important to address in order to
help maintain the commercial viability and vitality of the City’s core
business districts and tax base?
B. Property owners, developers, and business owners
a. What are the characteristics of property owners that would be affected?
b. How might small businesses be affected compared to larger ones?
c. How many property owners are in need of lower cost capital or other
substantial financial assistance to fund retrofitting?
C. Impacts of Seismic Restoration on Retention of Historic Structures in the City
a. How can we ensure that the review of initial seismic evaluations identify
those structures that are listed in the City’s Historic Inventory or
potentially significant and flag them for attention during subsequent
review?
b. How can we develop a clear process for reviewing proposed seismic
retrofits to historic structures that is coordinated among responsible city
departments and is consistent with current regulations and Community
policies?
c. How can we ensure that property owners take advantage of Seek out
retrofit alternatives that are consistent with the Historic Building Code,
historic characteristics of the structure, and provide the required most risk
reduction?
D. City departmental resources and budgets
a. What would be the loss in revenue to the Building Department if fee
waivers were offered?
b. What would be the staffing and budgetary needs over time to administer
an expanded program that addresses additional building types?
c. What kinds of interdepartmental cooperation and staff resources in other
departments are necessary to ensure effective implementation and
coordination with other city planning and public safety efforts?
d. What would be the costs to provide and administer any incentives offered
to property owners?
E. Overall community economic health
a. What kind of benefits could accrue to Palo Alto in terms of maintaining
community function and ability to recover if various building categories are
retrofitted in time before the next major earthquake?
F. Other related issues
Attachment E
City of Palo Alto Page 33
a. It was brought up in the Advisory Group that the Building Department
needs flexibility and authority to take steps to get tough seismic mitigation
projects done. One idea was to grant the Building Official the ability to
classify certain projects (with well-specified criteria) as warranting a kind of
“seismic safety” or “earthquake resilience” fast tracking, with city
departments agreeing to coordinate on a specified accelerated project
review timeframe.
b. Although outside the formal scope of this planning effort, several Advisory
Group members commented that it would be desirable for the City to do
some kind of assessment of any earthquake mitigation needs in public
buildings and facilities serving the City.
c. Advisory group members recommended the community be informed of
Palo Alto’s overall potential seismic risk by providing a summary of
potential impacts on the City’s website, including the expected
performance of vulnerable buildings.
d. The group also had a high degree of support for recommending that the
City initiate and nest future earthquake mitigation programs within a
broader disaster or community resilience initiative, as cities such as Los
Angeles, Berkeley, and San Francisco have done. This could be
incorporated into the update of the City’s Comprehensive Plan Safety
Element. There was insufficient time in the project’s six advisory group
meetings to consider potential initiatives to assess risks for cell phone
towers, water supply, facades, private schools, post-earthquake shelter
facilities, and/or other assets important to community recovery.
TIMELINE
The timeline for updating the current seismic mitigation regulation is dependent on Council’s
review of the Seismic Risk Assessment Study and directions to staff.
RESOURCE IMPACT
Implementation of the report recommendations would result in additional costs to private
property owners and prior to any decision to proceed, staff is proposing additional public
outreach at a cost of about $50,000. Technical requirements and design guidelines to support
a new ordinance would require additional consultant services at an estimated cost of $50,000.
If desired, an analysis of the fiscal impact on residents and business could be prepared for an
additional $50,000. Any incentives offered to building owners could also have a cost to the
City, which would not be known until those incentives are further defined.
ENVIRONMENTAL REVIEW
The preparation of the Seismic Risk Assessment Study is exempt from environmental review
under the California Environmental Quality Act (CEQA) Guidelines Section 15306 (Information
collection leading to an action which a public agency has not yet approved, adopted, or
funded).
Attachment E
City of Palo Alto Page 34
TABLE OF CONTENTS FOR ATTACHMENTS
A. Palo Alto Municipal Code, Chapter 16.42: Seismic Hazards Identification Program
B. Seismic Risk Assessment Study. The study includes the following items.
a. Legislative Review Report
b. Local Program Best Practices Assessment
c. Building Inventory for Loss Estimate
d. Conceptual Seismic Retrofits and Cost Estimate
e. Loss Estimate of Existing Building Stock
f. Loss Estimate of Retrofitted Building Stock
g. Review of Past Retrofits
h. Additional Recommended Program Features
C. Threat and Hazard Identification and Risk Assessment (August 2014)
D. Policy and Services Committee Staff Report 5293, Discussion of Updating the Seismic
Safety Chapter of the Municipal Code for Hazardous Buildings (December 9, 2014)
E. Palo Alto Municipal Code, Chapter 18.18: Downtown Commercial (CD) District
F. Seismic Risk Management Program Advisory Group Members
G. Seismic Risk Management Program Advisory Group Summary Report on Process,
Discussions, and Outcomes (November 21, 2016)
H. Advisory Group Meeting Minutes, Presentations and Handouts (contained at the Seismic
Risk Management Advisory Group website at
<http://www.cityofpaloalto.org/gov/depts/ds/srmag.asp>
Attachments:
Attachments
Attachment_A_-_PAMC_16.42_Seismic_Hazards_ID_Prgm[1]
Attachment_B_-_Palo_Alto_Seismic_Risk_Assessment_Study_-_Final_Report_-
_2016_12_21[1]
Attachment_C_-_Palo_Alto_Threats_Hazards_Risk_Assessment_(August_2014.1)[1]
Attachment_D_-_Policy_and_Services_Staff_Report_5293[1]
Attachment_E_-_PAMC_18.18_CD_District[1]
Attachment_F_-
_Seismic_Risk_Management_Program_Advisory_Committee_Members_01.15.16[1]
Attachment_G_-
_Palo_Alto_Seismic_Risk_Mgt_Prog_AG_Summary_Rev_2016_11_21[1]
Attachment_H_-_SRMP_Advisory_Group_Agenda-Minutes-Presentations-Handouts[1]
Attachment E
Final Report
Seismic Risk Assessment Study
Palo Alto, California
21 December 2016
#2015-087S
Rutherford + Chekene
375 Beale Street, Suite 310
San Francisco, CA 94105
Attachment F
Palo Alto Seismic Risk Assessment Study December 21, 2016
Final Report Page i
TABLE OF CONTENTS
PALO ALTO SEISMIC RISK ASSSESSMENT STUDY
Section / Subsection
I. INTRODUCTION ............................................................................................................................................. 1
II. LEGISLATIVE REVIEW REPORT ....................................................................................................................... 5
1. Introduction ..................................................................................................................................... 7
2. Current California Seismic-Related Building Codes, Legislation, and Key Institutions .................... 7
3. Legislative Leadership and Recent Development .......................................................................... 18
4. Conclusions .................................................................................................................................... 20
5. References Cited ............................................................................................................................ 24
III. LOCAL PROGRAM BEST PRACTICES ASSESSMENT ...................................................................................... 25
1. Introduction ................................................................................................................................... 28
2. Analysis of Policy Features and Outcomes of local Seismic Risk Mitigation Programs ................. 30
3. Implications and Potential Policy Directions for Palo Alto ............................................................ 67
4. References and Resources ............................................................................................................. 77
IV. BUILDING INVENTORY FOR LOSS ESTIMATE ............................................................................................... 79
V. VULNERABLE BUILDING CATEGORIES ......................................................................................................... 85
VI. CONCEPTUAL SEISMIC RETROFITTING OF REPRESENTATIVE VULNERABLE BUILDINGS ............................. 87
VII. LOSS ESTIMATING FINDINGS FOR EXISTING BUILDING STOCK ................................................................... 91
VIII. LOSS ESTIMATING FINDINGS WITH BUILDINGS RETROFITTED ................................................................... 97
IX. REVIEW OF PAST SEISMIC RETROFITS ....................................................................................................... 101
X. ADDITIONAL RECOMMENDED PROGRAM FEATURES .............................................................................. 103
XI. QUESTIONS TO GUIDE COUNCIL DELIBERATIONS AND POTENTIAL ISSUES FOR FUTURE STUDY ............ 107
1. Questions to help guide council deliberations ............................................................................ 107
2. Potential issues for future study and consideration .................................................................... 108
Attachment F
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Final Report Page ii
APPENDICES:
Appendix A - Table of Historic California Earthquake Risk Reduction Legislation.
Appendix B - Table of Contemporary California Earthquake Risk Reduction Legislation.
Appendix C - Table Describing Incentives Used in Local Earthquake Risk Reduction Programs.
Appendix D - Options for Moving to a Comprehensive, Resilience Approach
Appendix E – Retrofit Concepts Designs for 12 Prototype Buildings
Appendix F – Retrofit Cost Estimates for 12 Prototype Buildings
Attachment F
Palo Alto Seismic Risk Assessment Study December 21, 2016
Final Report Page 1
CHAPTER I.
INTRODUCTION
In 1986, the City of Palo Alto was one of the first cities in California to establish a comprehensive
seismic mitigation program. It covers unreinforced masonry buildings, buildings built before 1935 with
over 100 occupants, and buildings built before August 1, 1976 with over 300 occupants. After 30 years,
75% of the 89 buildings included in the program have been demolished or retrofitted. The 2014 South
Napa Earthquake spurred the City to reevaluate its program. They engaged a team led by Rutherford +
Chekene (R+C) to perform a comprehensive assessment of the expected performance of the City’s
building stock in potential earthquakes, and started a community engagement effort to help identify
resiliency goals and associated mitigation policies and programs. The R+C project team includes Sharyl
Rabinovici, a public policy and community engagement specialist; Hope Seligson (initially with MMI
Engineering and now Seligson Consulting) for loss estimating; and Vanir Construction Management for
cost estimation of building replacement cost and retrofitting.
The technical assessment covered over 2,500 buildings (single family and two-family residences were
excluded) with a wide array of potentially vulnerable structural systems. The findings show that the
estimated losses to Palo Alto buildings and contents in a M7.9 scenario event will be significant, on the
order of $2.4 billion. Furthermore, this figure does not include business disruption, or ripple effects in
the local economy or real estate market, nor does it include the economic value of loss of life. Among
the categories of highest concern are pre-1977 “soft-story” wood frame, pre-1978 tilt-up concrete,
pre-1977 cast-in-place concrete construction, and pre-1998 steel moment frames. The technical
assessment revealed that the potential reduction in losses from retrofitting these buildings is over $1
billion in a M7.9 scenario event.
R+C’s scope included a series of tasks and associated task reports and presentations. These included
the following:
A survey of state and local seismic policies and best practices;
Development of a building inventory for Palo Alto using digital information and field surveys;
Assignment of costs to buildings and contents in the inventory;
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Description of vulnerable building categories, including five additional categories not covered
under the current ordinance;
Conceptual seismic retrofitting of representative vulnerable buildings;
Loss estimate findings in a major seismic event for the current condition and after retrofitting;
Review of past seismic retrofits; and
Discussion of additional recommended program features.
These task reports and presentation information have been compiled to form this Seismic Risk
Assessment Study. Each chapter in the study addresses one or more of the project task efforts.
Appendices provide additional details for selected tasks.
A Seismic Risk Management Advisory Group made up of community and industry stakeholders and City
staff was appointed and was also an essential component of the overall project. The Advisory Group
insured that local building experience and community priorities were considered as the study moved
forward. The group met six times with City staff and the R+C team over a period of nine months. The
Advisory Group was introduced to the findings regarding the community’s earthquake vulnerability,
impacts on vulnerable building types, as well as the ‘best practices’ used by other communities to
promote community wide welfare and to encourage seismic retrofit of various vulnerable buildings
types. The Advisory Group then discussed the assessment findings and formulated potential directions
for City of Palo Alto leaders to consider going forward in updating the City’s seismic mitigation
programs. At the end of the Advisory Group process, a summary memo, reviewed by all members of
the Group, was prepared to document their input to the study. The November 21, 2016 memo is
entitled “Seismic Risk Management Program Advisory Group Summary Report on Process, Discussions,
and Outcomes.”
The following table summarizes the outcome of the seismic risk assessment and includes the Advisory
Group discussions. The table is organized around eight vulnerable building categories or building types.
Categories I, II and III encompass the identified vulnerable buildings for the 1986 ordinance and are
primarily located in the downtown commercial district. Categories IV through VIII include additional
buildings at risk, as identified in the Seismic Risk Assessment Study. These buildings are located
throughout the city.
There was little to no support for maintaining the status quo within the Advisory Group. As shown in
the following table, the Advisory Group favored requiring property-owner prepared seismic evaluation
reports for all categories, except for Category VIII (other older nonductile concrete buildings). They
also favored mandatory retrofit for the remaining Category I unreinforced masonry buildings identified
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Palo Alto Seismic Risk Assessment Study December 21, 2016
Final Report Page 3
in the 1986 ordinance that have not been seismically retrofitted or demolished. For the Category II
and III buildings in the current ordinance, retrofit should be required when a certain event or “trigger”
occurs such as when a substantial renovation occurs or the property is put up for sale. Among the new
vulnerable building types, the greatest concern was expressed for soft-story wood frame buildings and
older concrete tilt-up buildings. The Advisory Group thought that retrofit of these structures should be
either mandatory or triggered by substantial renovation or sale. The Advisory Group was concerned
about delay in the retrofit of these structures given the number of the vulnerable buildings, the
number of people who could be affected should the buildings be significantly damaged, and the
considerable cost to the community if the structures in these categories were lost because of an
earthquake. The Advisory Group considered a timeline of 2-4 years for the mandatory evaluation
report and 4-8 years to complete mandatory retrofit construction. The Advisory Group supported
increasing disclosure measures on building status through website listing and tenant notification. They
also suggested that the most beneficial financial and policy incentives to encourage compliance with
the new requirements would be fee waivers, expedited permitting, and property-assessed financing
tools.
Following the preparation of the Advisory Group summary, R+C assisted City staff in preparing a staff
memo for an upcoming City Council meeting. It includes more detailed recommendations to the
Council on proposed revisions to the City’s seismic hazard mitigation ordinance and recommends that
the Council provide direction to City staff on revising and expanding the City’s building code and
related ordinances.
Attachment F
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Final Report Page 4
Summary of Recommended Policy Directions from the Seismic Risk Management Program Advisory Group
Category Approx.
Number
Building
Type
Date of
Construction
Occupants Evaluation
Report
Voluntary,
Triggered, or
Mandatory
Retrofit1
Deadlines for Evaluation Report and
Retrofit Construction (years)2
Disclosure Potential Incentives
Current Program (Potential Revision in Italics)
I 10 Un-
reinforced
masonry
NA Over 6
(and over
1,900 sf)
Required Mandatory Report: Expired
Construction: 2-4
Website
listing and
tenant
notification
Fee waiver, expedited
permitting, FAR bonus/
transfer of development
rights (TDR) II 4 Any Before 1/1/35 Over 100 Required Voluntary or
Triggered
Report: Expired
Construction
• Voluntary: Not required
• Triggered: At sale or renovation
III 9 Any Before 8/1/76 Over 300 Required Voluntary or
Triggered
Expanded Program
IV 294 Soft-story
wood
frame
Before 1977 Any Required Triggered or
Mandatory
Report: 2-4
Construction
• Triggered: At sale or renovation
• Mandatory: 4-6
Same as
above
Fee waiver, expedited
permitting, TDR, parking
exemptions, permission to
add units
V 99 Tilt-up Before 1998 Any Required Triggered or
Mandatory
Report: 2-4
Construction
• Triggered: At sale or renovation
• Mandatory: 4-6
Same as
above
Same as Categories I, II and
III
VI 37 Soft-story
concrete
Before 1977 Any Required Voluntary,
Triggered or
Mandatory
Report: 2-4
Construction
• Voluntary: Not required
• Triggered: At sale or renovation
• Mandatory: 6-8
Same as
above
Same as Categories I, II and
III
VII 35 Steel
moment
frame
Before 1998 Any Required Voluntary,
Triggered or
Mandatory
VIII TBD Other older
nonductile
concrete
Before 1977 Any Not rec. at
this time
Not
recommended
at this time
Report: NA
Construction: NA
NA NA
1Voluntary: Retrofit is voluntary.
Triggered: Retrofit is triggered when the building is sold or undergoes substantial renovation.
Mandatory: Retrofit is required per a fixed timeline.
2Deadlines provide a potential range. Timelines would vary depending on tiers or priority groupings of different subcategories.
Attachment F
Palo Alto Seismic Risk Assessment Study December 21, 2016
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CHAPTER II.
LEGISLATIVE REVIEW REPORT
Executive Summary
This chapter summarizes the seismic risk management policy context within the state of California to
support Palo Alto’s current effort to update its program. The report was prepared per Task 2 of the
Consulting Agreement between Rutherford + Chekene and the City of Palo Alto, dated August 17,
2015. The scope of Task 2 is to:
Review existing and pending State legislation related to soft-story buildings and other seismically
vulnerable buildings and provide a brief summary.
Provide a concise review of relevant and pending state legislation, with a summary that can be
presented at community and staff meetings or in reports to Council.
The process of creating this legislative review included searches of legislative data bases, search and
review of published and online reports and materials, several phone interviews with leaders in the
engineering profession as well as local and state government staff, and development of insights from
the consulting team based on their experiences in this arena.
High level findings include the following:
Palo Alto is affected by numerous relevant California existing laws and regulations dating from
the 1930s through the present. These laws regulate many aspects of Palo Alto’s built environment,
including certain classes of building uses such as hospitals, public schools, and essential facilities;
setting code minimums for new construction; and mandating land use planning and real estate
disclosure measures for natural hazards including earthquakes. Unreinforced masonry (URM) is at
present the only structural system type for which the state requires local jurisdictions to have a
program.
If it so chooses, Palo Alto has wide authority to expand or strengthen its approaches to seismic
mitigation. The power to do more about earthquake vulnerabilities is primarily in the hands of the
local jurisdictions that have significant discretion in the kinds of policies they can adopt.
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Palo Alto has many additional actions it can take to make sure it is complying and taking greatest
possible advantage of state level regulations and opportunities. In particular, opportunities exist
now to align a new seismic program with two ongoing mandated planning efforts the City is already
engaged in: Palo Alto’s General Plan and its Local Hazard Mitigation Plan.
Based on what state laws allow and in some cases recommend, many broad policy directions exist for
Palo Alto going forward in terms of updating its seismic mitigation program. For example, Palo Alto
could choose to:
(1) implement measures to increase the effectiveness of its current program, for instance by
offering additional or larger incentives or devoting more resources to program visibility and
implementation;
(2) expand the City’s current voluntary seismic mitigation programs to address additional
building types or uses;
(3) add mandatory screening or evaluation measures for one or more vulnerable building types
such as soft-story buildings or older concrete structures;
(4) upgrade the City’s current voluntary URM program to make retrofitting mandatory;
(5) create a program that mandates seismic retrofits for one or more additional (non-URM)
vulnerable building types;
(6) craft a program that combines any or all of the above measures. Local precedents for all
these types of approaches exist and are described and discussed in a separate Task 3 report; or,
(7) continue the status quo current program.
Although formally outside the scope of the current effort, Palo Alto also has additional opportunities
for strengthening and expanding its earthquake-related efforts in terms of land use planning, public
education and awareness, and small residential structures, such as:
(8) develop partnerships with the private and non-profit sectors to promote insurance take up
and business continuity planning; and,
(9) devote more resources to increasing awareness among its citizens about low cost or free
ways to become more aware and prepared for disasters more broadly.
Ultimately, the recommended policy directions and action steps for Palo Alto will be informed by
related efforts in this project to analyze the most current vulnerability information available, and later
determined through an inclusive decisionmaking process going forward.
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1. INTRODUCTION
This report surveys the public policy landscape in the state of California related to earthquake
mitigation and describes each policy or program’s relevance for Palo Alto and similar jurisdictions. The
scope is intentionally broad so that it can serve as a primer or look-up resource for persons with varied
levels of background knowledge about the topic. Section 2 organizes information about the reviewed
policies, programs, and institutions based on the type of policy or program. These range from building
codes and mitigation mandates to educational efforts and tax-based loan financing strategies.
Section 3 briefly provides information about current State level policy leadership and the small amount
of earthquake-related recent and proposed legislation. Section 4 presents options for Palo Alto
through a summary of the review’s findings. Appendices A and B to this report provide detailed tables
of current and pending or recent legislative proposals, respectively.
The process of creating this Legislative Review included searches of the California’s LegInfo database,1
search and review of published and online reports and materials, several phone interviews with state
and engineering profession leaders, and development of insights from the consulting team based on
their experiences in this arena. This review covered over 50 related individual existing laws or passed
referenda, in addition to the state’s Existing and Historic Building Code provisions.
2. CURRENT CALIFORNIA SEISMIC-RELATED BUILDING CODES, LEGISLATION, AND KEY INSTITUTIONS
This section presents legislation and programs in narrative format to address interrelationships among
these laws and to present broader implications for Palo Alto. Relevant laws and programs related to
Palo Alto’s obligations and opportunities regarding earthquake mitigation are categorized by type and
how each works. Specific laws referenced are shown in bold. The accompanying table in Appendix A
lists the identified relevant current state legislation organized by year established.
State laws related to seismic safety can be categorized as relating to building codes, targeting of
existing building types or uses, land use planning, real estate practice requirements, and financial
policies such as the tax code, insurance, and incentives.
1 http://www.leginfo.ca.gov (Accessed January 13, 2016).
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Building Codes
New construction in Palo Alto is governed by the California Building Code (CBC) that is updated every
three years. Updates are adopted by the City Council. The International Building Code (IBC) is the
underlying model code on which the provisions of the CBC are based. Legally, every local jurisdiction in
California is required to adopt the state building code and to enforce that code. Above and beyond the
minimums of the CBC, each jurisdiction has flexibility if justified by local climatic, geological (including
seismic), and topographical conditions. Several jurisdictions have done that as part of their seismic
mitigation programs, as detailed later and in Chapter III.
Standards for rehabilitation, renovation, repairs, retrofits, or additions to existing structures exist in
Chapter 34 of the CBC. The International Existing Building Code (IEBC) provides additional specific
methodologies that jurisdictions may decide to adopt in whole or in reference to particular sections.
The City of Palo Alto has its own Historic Building Inventory of hundreds of buildings as well as several
Historic Districts and both state and federally designated historic properties. Therefore, the State
Historical Building Code2 is also relevant, as administered by the Division of the State Architect (DSA)
under the Department of General Services. Officially designated historic structures are subject to
different rules for rehabilitation which are generally more flexible and permissive than those in
Chapter 34 of the CBC. Local jurisdictions can specify enhancements for seismic reasons as long as the
justifications and nature of such changes are fully public and documented on record with the State
Historical Building Safety Board.3 A detailed list of key provisions is given on the DSA website4.
Targeted Building Types
Unreinforced Masonry (URM)
Inventories of specific building types have formed the backbone of California seismic policy
towards existing buildings since at least the 1930s, but it was the 1986 Unreinforced Masonry
(URM) Law that firmly established the precedent of using inventories to promote retrofits of
existing seismically vulnerable buildings. Through this policy, in Section 8875 of the California
Government Code, the State Legislature required all 366 local governments in Seismic Zone 4
(the highest hazard level) to inventory their URM buildings, establish some kind of loss-
2 Health and Safety Code, Division 13, Part 2.7, §18950-18961.
3 “Each local agency may make changes or modifications in the requirements contained in the California Historical Building
Code, as described in Section 18944.7, as it determines are reasonably necessary because of local climatic, geological,
seismic, and topographical conditions. The local agency shall make an express finding that the modifications or changes are
needed, and the finding shall be available as a public record. A copy of the finding and change or modification shall be filed
with the State Historical Building Safety Board. No modification or change shall become effective or operative for any
purpose until the finding and modification or change has been filed with the board.” [Health and Safety Code §18959.f.]
4 http://www.dgs.ca.gov/dsa/AboutUs/shbsb/shbsb_health_safety.aspx (Accessed January 23, 2016).
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reduction or remediation program within four years, and report progress to the California
Seismic Safety Commission (CSSC).
Each county or municipality was allowed to design its own program. In general, three main
types of local programs were utilized: 1) mandatory retrofit, 2) voluntary retrofit, and 3) notice
to owners that the structure is a URM building. When retrofits were encouraged or required,
the local government set the standards to be met. Palo Alto already had an inventory and
program in place for URMs at the time the law was passed, and thus it was mainly subject to
the reporting requirements.
Mandatory signage was later required and is another controversial aspect of the State’s
approach to URM buildings. Section 8875.8 of the Government Code increased enforcement
efforts on the requirement for warning placards to be posted at the entrances to un-retrofitted
URM buildings. In 2006, URM building owners had posted 758 signs (see Figure 1 for required
text); almost all jurisdictions report the signage had no noticeable effects (CSSC, Status of the
Unreinforced Masonry Building Law, 2006).
Figure 1: URM sign example text.
Reviews of the URM Law by the CSSC have shown it to be a success over the long term. In 2006
(the last comprehensive state survey available), compliance with the policy was 93%, and over
70% of identified URM buildings have been either retrofitted or demolished (CSSC, Status of the
Unreinforced Masonry Building Law, 2006). More than half (52%) of affected jurisdictions
adopted a mandatory program, which has proven by far to be the most effective type. Eighty-
seven percent of identified properties have been retrofitted or demolished in jurisdictions with
mandatory programs, compared to thirteen to 25 percent in jurisdictions with other program
types.
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Some of the URM law’s influences are subtler. The state URM law is credited with creating
greater awareness among community leaders and increasing practical experience and capacity
to address seismic policy implementation in local jurisdictions. It set the precedent of
preserving “local choice” in how to address the problems of seismically-vulnerable existing
buildings. This law also brought some public attention to the issue, through exposure to
warning signs at building entrances. In jurisdictions with highly effective programs, the URM
law likely set the stage for greater willingness to adopt stronger, more proactive approaches for
other building types.
Targeted Building Uses
Hospitals
Palo Alto is host to at least two major hospitals, the Palo Alto Veteran’s Administration Hospital
and the Lucile Packard Children’s Hospital, as well as a number of urgent care clinics and other
health care facilities, for instance related to Stanford Hospital. State-mandated seismic
minimums and upgrade requirements for hospitals were put in place in 1973 through SB 1953
and periodically amended since. The Office of Statewide Health Planning & Development
(OSHPD) develops guidelines, administers the program, and oversees compliance.
Extraordinary resources have been spent to upgrade and develop new hospitals in response to
SB1953, resulting in major improvements to both seismic safety and in patient care (OSHPD,
2005). However, progress has been slower than hoped, in part because of the costs of achieving
the high levels of performance that the law demands but also because of program complexity
and organizational difficulties in managing upgrade programs. A comprehensive study of SB
1953 implementation showed that even organizational leaders highly motivated to reduce risk
in the context of strict mandates were not always able to achieve timely progress (Alesch,
2012).
Public Schools
Following the 1933 Long Beach quake that rendered over 230 Southern California schools
unsafe, the Field Act was passed to require higher seismic design minimums in new public
school construction. The 1939 Garrison Act required school districts to retrofit or replace pre-
Field Act schools. However, many schools did not comply until the mid-1970s.The Division of
the State Architect (DSA) oversees this program, and since 2002 has done tracking via the “AB
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300 List.” 5 Further detail about Field Act implementation statewide can be found in formal
state reports (See, e.g., CSSC, 2009).
The status of approximately six Palo Alto area schools that have buildings on the “AB 300 List,”
could be relevant to future policy development efforts depending on the extent to which the
city relies on schools in its emergency response plans. Functioning schools are also known to
play a large role in resumption of local business activity as part of recovery.
Essential Services Buildings
State law recognizes that buildings that house mission-critical jurisdictional services and
administrative functions should be safe and functional after a major local event. Palo Alto is
required by the California Essential Services Building Seismic Safety Act of 1986 to follow
enhanced regulations during the design, rehabilitation, and construction of essential service
facilities, defined as fire stations, police, California Highway Patrol, or sheriff offices, or any
buildings used in part or whole to conduct emergency communications and operations. As with
hospitals, the DSA develops and maintains the design and construction requirements and tracks
compliance for this law.
Land Use, Zoning, and Real Estate Disclosure Requirements
General Plan Requirements
According to the State Planning and Zoning Law, Palo Alto and other California jurisdictions
have been required since 1971 to address earthquake vulnerabilities in their General Plans,
currently in the Safety Element.6 The Governor’s Office of Planning and Research (OPR)
provides General Plan Guidelines for what jurisdictions must do in creating and implementing
their plans, mostly recently in 2011.7 Typical earthquake-related provisions focus on avoiding
development in hazardous areas (for instance near known faults) and adoption of zoning and
use requirements that can reduce hazards (such as creation of retention and recharge basins to
lessen the impacts of storms).
Palo Alto’s last General Plan was adopted over ten years ago. Since 2008, staff have been
reviewing and updating different elements in turn. An analysis should be undertaken of any
relevant earthquake hazard-related aspects in it, and care should be taken to align and
integrate future mitigation program efforts with the City’s updated General Plan, which is
5 http://www.documents.dgs.ca.gov/dsa/ab300/AB_300_List.pdf (Accessed January 23, 2016). List described as up to date
as of Thursday, September 10, 2015.
6 Government Code §65300-65303.4.
7 https://www.opr.ca.gov/docs/complete_pzd_2011.pdf (Accessed, March 6, 2016).
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currently in development. As of 2016, Palo Alto is working on a comprehensive update to be in
effect through 2020 to 2030. More detail is available on a city website designed specifically as
part of a highly engaged community involvement process.8
Zoning
Palo Alto is on the list of California cities that contain some areas designated by the state as an
“Earthquake Fault Zone” (Hart, 2010). The California Geological Survey (CGS) under the
California Department of Conservation (DOC) oversees implementation of the Alquist-Priolo
Earthquake Fault Zoning Act of 1972, a particularly important legacy policy in understanding
California earthquake risk management policy. The CGS regularly conducts and updates studies
that identify active faults. Buildings within an “Earthquake Fault Zone” face additional planning,
use, and disclosure obligations. Additionally, the 1990 Hazards Mapping Act gave DOC
responsibility for mapping areas prone to liquefaction, earthquake-induced landslides, and
amplified ground shaking. Within these mapped Zones of Required Investigation, geotechnical
investigations to identify hazards and formulate mitigation measures are required before
permitting most development.
Small Residential Real Estate Mandates and Disclosures
All sellers of real property in Palo Alto are required to disclose certain facts about the building
location and its condition related to earthquake hazards. These requirements began with the
Natural Hazards Disclosure Act of 1990, which has detailed provisions for what sellers of real
property are obligated to do and what kinds of information they must provide prior to point of
sale. Requirements are more extensive when the property being sold lies within one or more of
the state-mapped hazard areas, including landslides, liquefaction, and Earthquake Fault
Zones.”9
Since 1993, all sellers of residential properties of four units or less must under Government
Code Section 8897.1-8897.5:
o Inform the buyer about known home weaknesses related to earthquake risk;
o Properly strap the water heater;
o If the home was built before 1960, deliver a copy to the buyer of the Homeowner’s
Guide to Earthquake Safety10 brochure produced by the CSSC (The real estate agent is
holds responsibility for this requirement being met);
8 http://www.paloaltocompplan.org/ (Accessed January 23, 2016).
9 http://www.conservation.ca.gov/cgs/rghm/ap/Pages/disclose.aspx (Accessed January 20, 2016).
10 Available at: http://www.seismic.ca.gov/pub/CSSC_2005_HOGreduced.pdf (Accessed February 1, 2016).
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o Deliver to buyers a Natural Hazards Disclosure Form telling buyers whether the home is
in an Earthquake Fault Zone or in a Seismic Hazard Zone; and,
o Complete and deliver to buyers a Residential Earthquake Hazards Report.
A similar document called the Commercial Property Owners Guide to Earthquake Safety11
makes recommendations for commercial property buyers and sellers at the time of sale. The
only requirement is that sellers must deliver a copy of the booklet to a buyer, “as soon as
practicable before the transfer,” (Government Code, Section 8893.2) if the property was built
before 1975 and has precast (tilt-up) concrete or reinforced masonry walls and wood-frame
floors or roofs.
Palo Alto currently features links to both the aforementioned guides on its Building Department
website.
Legal Obligations to Tenants
California case law in Green v. Superior Court (1974, 10 Cal.3d 616) established that a rental unit
must be “fit to live in,” or “habitable.” In legal terms, “habitable” means that the rental unit is
appropriate for occupation by human beings and that it substantially complies with state and
local building and health codes that materially affect tenants’ health and safety (CA Civil Code
§1941, 1941.1).
At time of writing, no common law precedents could be identified regarding thresholds related
to seismic risk that would be actionable for tenants to reasonably claim breach of a landlord’s
implied warranty of habitability. California law is broad by stating that “other conditions may
make a rented property not habitable” (CA Civil Code §1941, 1941.1). For example, a rented
property may not be habitable if it does not substantially comply with building and housing
code standards that materially affect tenants' health and safety (CDCA, 2012). This could be a
lead or mold hazard, sanitation issues, or an endangering nuisance, but also potentially if the
building is substandard because of a structural hazard.
In seeking to develop any new programs, Palo Alto should consider conducting a legal analysis
of this important but untested aspect of seismic mitigation policy. Some housing and tenant
rights groups have asserted that soft-story and other generally accepted seismic vulnerabilities
may constitute a deficiency that a landlord has an obligation to repair, regardless of whether
the local jurisdiction has required such work. Citizen complaints of this nature surfaced in
Berkeley for instance in 2008 to 2010 (personal communication, 2010 with Jay Kelekian, City of
Berkeley Rent Stabilization Board President).
11 Available at: http://www.seismic.ca.gov/pub/CSSC_2006-02_COG.pdf (Accessed February 1, 2016).
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Special Earthquake-Related State-Level Entities and Programs
Following are a few more important state-level entities and resources of which Palo Alto can take
advantage.
California Seismic Safety Commission (CSSC)
The California Seismic Safety Commission (CSSC), established in 1975, advises the Governor,
Legislature, and state and local governments on aspects of earthquake vulnerability and policy.
Its staff offer technical assistance to cities in developing and carrying out seismic related
programs. The CSSC is responsible for maintaining a five-year California Earthquake Loss
Reduction Plan to establish strategy and coordination for state and local government actions to
mitigate earthquake hazards. The most recent statewide Loss Reduction Plan was published in
2013 (CSSC, 2013). It contains detailed lists of policy issues and recommendations that, while
comprehensive, prioritized, and sensible, have had limited traction owing to lack of elected
official leadership and budget. Other duties include tracking progress on the state URM law and
deriving policy lessons from earthquake events. Several CSSC publications are among the best
resources for evaluating local mitigation programs.
California Earthquake Authority (CEA)
The California Earthquake Authority (CEA) is a privately-funded, publically managed non-profit
entity that provides private insurance policies to homeowners and renters. Eligibility includes
homes of four units or less through participating insurers. The earthquake insurance take-up
rate statewide is around ten percent. As of January 2016, CEA-affiliated underwriters can now
offer a premium discount up to 20% for mitigation investments made. The number of small
residential buildings in Palo Alto whose owners carry earthquake insurance is not known, but
those that do or that purchase it from hereon could be eligible for this discount. Palo Alto
could potentially work to make sure this benefit is better advertised and utilized by building
owners.
Additionally, a substantial portion of CEA’s annual premium intake is legislatively required to be
spent on efforts to achieve mitigation in one-to-four unit homes throughout the state. These
funds have been invested in research as well as an important new mitigation grant program for
small residential houses called Earthquake Brace and Bolt, which is further described in the
Financial Incentives section on the California Residential Mitigation Program. Currently,
enrollment for cities is closed but expansion is planned in the future.
Governor’s Office of Emergency Services
Formerly known as the California Emergency Management Agency, the Governor’s Office of
Emergency Services (Cal-OES) coordinates statewide emergency preparedness and response
activities. Palo Alto might have untapped opportunities to train City employees at CAL-OES’s
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Specialized Training Institute.12 For instance, they have an “Essential Emergency Services
Concepts – Earthquakes.”
Financial Provisions, Tax Code, and Other Incentive Policies
The potential difficulty of affording retrofit work is universally recognized as a barrier for public and
private owners alike. A variety of reports have attempted to catalog incentive, financing and in-kind
assistance options that are relevant to city earthquake and resilience programs (See e.g., ABAG, 1992;
ATC, 2010; ABAG, 2014; MMC, 2015).
This section highlights a few key pieces of enabling state legislation and federal tax programs that
jurisdictions such as Palo Alto could utilize. Specific examples of how different jurisdictions have used
specific financing and incentive programs are analyzed in the Task 3 Report.
General Obligation, Special District, and Mello-Roos District Bonds
Palo Alto is allowed to take on general obligation bond debt to help pay for retrofit or
construction of new public buildings and to generate funds for providing loans to private
owners for seismic work if doing so constitutes a compelling public purpose (Government Code
§43600-43638; Government Code §29900-29930).
Advocates have also speculated that communities might be able to use the Mello-Roos
Community Facilities Act of 1982 (Government Code §53311-53317.5). This act allows localities
in California to create special Capital Facilities Districts that can sell bonds to generate funds for
infrastructure and community facilities and then levy additional property taxes on the real
property owners in that district. Such taxes are not subject to Proposition 13 restrictions on
property tax increases. Covered services may include streets, water, sewage and drainage,
electricity, infrastructure, schools, parks and police protection in old or newly developing areas.
The tax paid is used to make the payments of principal and interest on the bonds.
Historic Property Tax Reductions
Palo Alto has many historic structures and may be able to take advantage of the Mills Act of
1972,13 which gives local governments the authority to enter into contracts with owners who
restore and maintain historic properties. In exchange, the property owners could get significant
property tax savings. Although cumbersome, St. Helena, California is one example of a city that
used this tool to help owners of unreinforced masonry buildings to seismically retrofit (ABAG,
unpublished soft-story report, 2015).
12 See: http://www.caloes.ca.gov/cal-oes-divisions/california-specialized-training-institute (Accessed February 1, 2016).
13 California Government Code, Article 12, §50280-50290, California Revenue and Taxation Code, article 1.9, §439-439.4.
Further information available at: http://www.ohp.parks.ca.gov/?page_id=21412 (Accessed February 1, 2016).
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Limits on Increases on Property Tax for Seismic Retrofit Costs
Existing state tax law (California Revenue and Taxation Code §74.5) provides that the cost of
an earthquake retrofit should not increase the property assessment used to determine the
amount of property taxes. The extent to which building owners take advantage of this benefit is
unknown and might be low because of requirements to submit specific information to their
County Assessor’s Office prior to conducting retrofit work. Many Assessors’ Offices do not have
forms for this purpose and their staff is not trained to process this benefit. At this time, it is not
known how Santa Clara County manages this issue. Palo Alto could potentially work to make
sure this benefit is better advertised and truly available to building owners.
Property Assessed Clean Energy (PACE) Financing
New financing programs are starting to exist that could help owners in Palo Alto who might
have difficulty securing financing on their own for a seismic retrofit. Based on the Property
Assessed Clean Energy (PACE) model first pioneered for solar improvements, owners can apply
for 100 percent financing for seismic retrofit work at competitive fixed rates over the useful life
of the improvements, to be repaid over up to 20 years with an assessment added to the
property’s tax bill. The levy stays with the building upon sale and costs can be shared with
tenants. Both Berkeley and San Francisco are participating in the open access AllianceNRG
Program14 that offer residential property owners this financing solution primarily for
sustainability upgrades and seismic strengthening projects for soft-story construction are also
eligible. The AllianceNRG program is offered through California’s Statewide Community
Development Authority (CSCDA) and partnerships with additional communities are now being
offered state-wide since 2015.
After the concept was launched in Berkeley in 2008, PACE programs stalled in 2010 the
country's two biggest home lenders, Fannie Mae and Freddie Mac, decided not to
underwrite mortgages for PACE customers because it added too much risk in the event of
a default because the PACE loan took precedence over the mortgage. Anecdotally,
jurisdictions have had some difficulties implementing this type of program for energy
improvements.15 Challenges include setting up this complex financing instrument which has
heavy involvement of third parties, barriers to owners that want to refinance, and barriers to
the transfer of a PACE-financed properties to a new owner.
14 https://www.alliancenrg.com/retail/ (Accessed January 20, 2016).
15 See e.g., http://www.voiceofsandiego.org/topics/science-environment/some-homeowners-looking-to-move-must-deal-
with-a-change-of-pace/ (Accessed February 2, 2016.
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California Residential Mitigation Program (CRMP)
Palo Alto and other cities can benefit if the citizens can stay in their homes and “shelter in
place” following a major local quake. One new important effort on this front is the California
Residential Mitigation Program (CRMP). It was formed in August 2011 to carry out mitigation
programs to assist California homeowners who wish to seismically retrofit their houses. CRMP’s
goal is to provide grants and other types of assistance and incentives for these mitigation
efforts. The California Residential Mitigation Program is a joint-exercise-of-powers entity (JPA)
formed by two core members: the California Earthquake Authority (a public instrumentality of
the State of California known as CEA) and the Governor’s Office of Emergency Services (Cal-
OES). CRMP is a legally separate entity from its members.
The first of these programs, Earthquake Brace + Bolt: Funds to Strengthen Your Foundation
(EBB)16 was launched as a pilot project in September 2013 in selected zip codes only. EBB offers
a cash grant up of to $3,000 for qualifying bolts or sill anchoring installment. Homeowners must
register and be accepted into the program, with a cap on the number of participants. The
current registration window was open from January 20 to February 20, 2016. Participation is
determined by lottery if more applications are received than funds are available. At present, no
Palo Alto zip codes are in the program. The selection of the specific neighborhoods and zip
codes was based upon analysis of U.S. Census data identifying areas of high seismicity and
having a concentration of owner-occupied homes built in 1979 or earlier. According to personal
communications with CEA mitigation program representatives, Palo Alto zip codes are not likely
to be prioritized highly owing to the modest number of very old single family homes.
Federally Mandated Municipal Obligations and Opportunities
Even though the focus of this review is California, two particularly relevant federal programs for Palo
Alto are described below. As with the state, no centralized governmental authority exists at the federal
level to regulate issues of seismic safety. Instead, authorities and strategies are widely distributed
among agencies at the local, state, and federal levels. For instance, the Department of Housing and
Urban Development operates several initiatives related to safer homes and resilient communities,17
and the General Services Administration must confront seismic risk concerns as it manages most
federal facilities. The federal role is concentrated in FEMA and principally focused on emergency
response and recovery, although mitigation is also addressed.
16 https://www.earthquakebracebolt.com/ (Accessed January 23, 2016)
17 See, e.g., the Smart Growth America Resilience States program, http://www.smartgrowthamerica.org/resilience/
(Accessed February 1, 2016).
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Local Hazard Mitigation Planning Under the Disaster Management Act
The federal Disaster Management Act of 2000 (DMA) and subsequent amendments specify
that local jurisdictions and states must have approved Hazard Mitigation Plans in place in order
to be eligible for aid following Stafford Act Disaster declarations and a variety of other benefits.
The State of California Multi-Hazard Mitigation Plan of 201318 is a comprehensive source of
information about state level requirements, mitigation strategies, as well as local and state
progress and opportunities for coordination (CSSC, 2013b).
Palo Alto current complies with the DMA through its participation in the 2011 Santa Clara
County’s Office of Emergency Services Annex to a 2010 region-wide “umbrella” Local Hazard
Mitigation Plan (LHMP) created by the Association of Bay Area Governments (ABAG). To create
the plan, representatives from County departments, private sector businesses, stakeholders,
and thirteen of the fifteen incorporated cities in Santa Clara County collaborated in identifying
and prioritizing potential and existing hazards. Mitigation objectives were identified and
prioritized and specific action steps are listed, many of which have been taken. Palo Alto is
currently preparing its contributions for updates to the Santa Clara County LHMP which must
be completed, submitted to the state, and approved by June 2017. The LHMP process creates
an opportunity to build synergies between an updated seismic program and other mitigation
efforts city and county-wide.
Federal Emergency Management Agency (FEMA) Pre-Disaster Mitigation Grants
Cities such as Palo Alto are eligible to apply to the Pre-Disaster Mitigation (PDM) Grant
Program19, created by Section 203 of the federal Robert T. Stafford Disaster Relief and
Emergency Assistance Act, funded annually by Congressional appropriation. The program aims
to assist States, territories, Federally-recognized tribes, and local communities in implementing
a sustained pre-disaster natural hazard mitigation program. Cities must submit a detailed
application during an open window to an annual competition. This program awards planning
and project grants as well as providing assistance in raising public awareness about reducing
future losses before disaster strikes. The program works on a 75%/25% cost share between
FEMA and the local jurisdiction, respectively, with a maximum grant of $3 million. Cities can
submit applications for multiple projects. Palo Alto could apply for support for future projects
ranging from updating city owned structures, direct financing or grants to a private class of
buildings or specific important structure.
18Available at: http://hazardmitigation.calema.ca.gov/docs/SHMP_Final_2013.pdf (Accessed February 1, 2016).
19 http://www.fema.gov/hazard-mitigation-grant-program (Accessed January 15, 2016).
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The disaster occurrence that opens a funding availability window does not necessarily have to
affect Palo Alto directly. For instance, any California jurisdiction with an active LHMP was
permitted to propose projects based on the Presidential Disaster Declaration for the 2015
Valley and Butte fires.
Finally, if City of Palo Alto employees have not already taken advantage of it, training
opportunities are available at the FEMA Emergency Management Institute in Maryland.20
3. LEGISLATIVE LEADERSHIP AND RECENT DEVELOPMENTS
Palo Alto citizens are represented in the state Senate by Jerry Hill (D) and in the Assembly by Rich
Gordon (D), 24th District, both with terms ending in 2016. High earthquake exposure throughout
coastal California has led legislators from a variety of districts to author legislative proposals. Most
recently, leadership has come from elected officials Nazarian, Chiu, and Monning.
Several different committees in the California Assembly and Senate have jurisdiction over issues
related to seismic safety and mitigation, building codes, and earthquake-related programs. In the
Assembly, the Committee on Housing and Community Development has jurisdiction over building
standards, common interest developments, eminent domain, farm worker housing, homeless
programs, housing discrimination, housing finance (including redevelopment), housing, natural disaster
assistance and preparedness, land use planning, mobile homes/manufactured housing, and rent
control. The Assembly Committee on Local Government has authority over a range of General Plan,
city finance, and housing policies. The most relevant Senate committee is Transportation and Housing,
which governs issues such as transfer of ownership, financing districts, manufactured housing, building
codes and standards, and common interest developments.
Through these committees, legislators have considered several pieces of legislation related to
earthquake mitigation in recent years. This review identified around ten such pieces of legislation
debated in the 2013 to 2015 California legislative sessions, including passed, pending, vetoed or never
fully heard bills (see Appendix B). Three key legislative proposals of interest to Palo Alto are briefly
described here.
Vetoed: Seismic Mitigation Tax Credits
In the most recent session, Assembly Member Adrin Nazarian (District 46 in the San Fernando
Valley) has sponsored legislation to create a state-wide seismic mitigation tax credit. The 2015
version AB 428 passed the legislature but was vetoed by the Governor based on funding
availability, lack of technical and administrative capacity in the Franchise Tax Board, and the
20 https://training.fema.gov/emi.aspx (Accessed February 1, 2016).
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program’s potential complexity. The law would create a first-come first serve state tax credit
equal to 30 percent of a “qualified taxpayer’s” “qualified costs” incurred for “seismic retrofit
construction.”
Pending: Permissions to Expand CEA Insurance Mitigation Discounts
CEA was active in promoting legislation last year to empower the CRMP to offer grants for small
residential retrofit work. Currently pending are AB 1429 (Chiu) and AB 1440 (Nazarian) that will
provide $3 million dollars to the CRMP for expanding its current EBB program.
Dead: Soft-Story and Older Concrete Mitigation Program Authorization
AB 2181 (Bloom)21 would authorize each city, city and county, or county to require that owners
assess the earthquake hazard of soft story residential buildings and older concrete residential
buildings. It includes older concrete residential buildings constructed prior to the adoption of
building codes that ensure ductility, and to initiates programs to inform owners, residents and
the public about such dangers. There is no state law that forbids such programs, but this law if
passed would remove any ambiguity that such programs are permitted and further justify local
actions to that effect.
4. CONCLUSIONS
Palo Alto is affected by numerous California laws and regulations related to seismically vulnerable
structures, dating from the 1930s to the present day. The requirements relate to many aspect of the
city’s built environment, including:
Code minimums for new construction;
Standards for seismic rehabilitation, including special provisions for historic properties;
Special programs and expectations for certain classes of use such as hospitals and public
schools, and essential facilities;
Mandatory and voluntary unreinforced masonry programs;
Mandated zoning and land use planning requirements that restrict use and add
requirements;
Grant and insurance programs available to one to four unit dwellings;
Financing authorities such as issuance of general obligation bonds and provisions for
handling of property taxes for the costs of needed seismic retrofit; and
21 http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140AB2181 (Accessed February 1, 2016.
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Real estate disclosure requirements.
Beyond some recent and pending efforts related to funding small residential mitigation grant programs
and Earthquake Early Warning, there is no apparent momentum at this time for new statewide
initiatives. That being said, Palo Alto can take any of several actions listed below to make sure it is
complying with and taking the greatest possible advantage of existing state laws and programs. For
example:
Palo Alto could confirm that all its URM buildings maintain the required signage.
Palo Alto could investigate the status of the approximately six Palo Alto area schools that
have buildings on the State’s “AB 300 List” related to the Garrison Act.
Palo Alto could identify and review the status of public facilities covered under the Essential
Services Building Seismic Safety Act and review its policies for guiding future planning for or
rehabilitation of such structures.
Palo Alto could take advantage of the current update process for its Local Hazard Mitigation
Plan to develop a strong, coherent, shared vision for how the city is going to address
earthquake risk, and encourage jurisdictions and special districts nearby to do the same.
Resources from FEMA Hazard Mitigation Grants and knowledgeable partners such as the
Association of Bay Area Governments may be available to assist in this effort.
Palo Alto could work carefully to incorporate the most up-to-date assessment of local
earthquake vulnerabilities as it revises the Safety Element of its General Plan.
Palo Alto could make sure its employees have taken advantage of the best available state and
federal emergency management training programs that are relevant to earthquake disasters
and recovery.
Palo Alto could develop partnerships and devote resources to more fully realizing the benefits
of statewide offerings of tax relief and requirements regarding real estate disclosure in
private sales. These policies aim to empower buyers and sellers to be better informed and able
to make better mitigation decisions for themselves but may be carried out incorrectly and are
under-enforced. Palo Alto could, for instance, work to make sure building owners apply for
relief from any property assessment increases that would otherwise result from investing in an
earthquake retrofit.
Palo Alto could seek closer ties to the California Earthquake Authority to help in promoting
mitigation and insurance coverage for one to four unit homes. CEA has recently been one of
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the lead entities in offering policy ideas and grant funding for earthquake mitigation of small
residential structures.
Palo Alto could evaluate whether it contains any vulnerable historic properties that might be
eligible for tax credits under the Mills Act. This Act provides the most significant direct source
of financial support from the state for local seismic retrofitting.
Palo Alto could investigate the issue of seismic habilitability minimums for suspected
earthquake vulnerable buildings. Legal uncertainty exists about whether tenants are already
entitled under current state law to request that their landlord upgrade a structure for being
“substandard.”
Palo Alto could join with fellow jurisdictions in advocating for changes in state law to
promote seismic mitigation.
Palo Alto could develop partnerships and devote resources to bringing more awareness
among its citizens about low cost or free ways to become more aware and prepared for
disasters more broadly. Cal-OES and many other state and non-profit institutions offer free
online tools such as http://myhazards.caloes.ca.gov/ to help citizens understand their risks and
take private action.
The power to address unmet seismic safety and recovery concerns clearly rests in the hands of cities,
counties, and special districts. If it so chooses, Palo Alto has legal authority to widen and/or strengthen
its structural mitigation program. Based on what state laws allow and in some cases recommends, this
review revealed the following non-exhaustive list of policy directions Palo Alto could pursue going
forward:
1. Palo Alto could implement measures to energize and raise the effectiveness of its current
program (outlined in City of Palo Alto Municipal Code 16.40), for instance by offering
additional or larger incentives or devoting more resources to program visibility and
implementation. Making the current program more effective would likely require additional
funding sources. Other jurisdictions are experimenting with some success in using tools such as
the new state-wide PACE financing program. Palo Alto could investigate opportunities to
establish special Mello-Roos or Mills Act districts to help finance local seismic mitigation.
2. Palo Alto could expand its voluntary seismic mitigation program to address one or more
combinations of additional building types, occupancy levels, or uses. The State Legislature has
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formally passed advisory legislation that encourages jurisdictions to adopt policies for building
types like soft-story and older concrete.22
3. Palo Alto could create mandatory screening or evaluation measures for one or more
vulnerable building types such as soft-story buildings or older concrete structures. Local
precedents for these approaches exist and are described and discussed in a separate Task 3
report.
4. Palo Alto could make its current voluntary URM program mandatory. Mandatory URM
programs in the State have been on average three times more effective than voluntary ones.
5. Palo Alto could create a program that mandates seismic retrofits for one or more additional
(non-URM) vulnerable building types. The State Legislature has formally passed legislation that
authorizes cities to adopt rehabilitation requirements for such programs This is important
because cities must reference acceptable standards that state clearly how owners can comply
with the requirement to retrofit.
6. Palo Alto could craft a program that combines any or all of the above measures. The Task 3
report shows that most leading local earthquake programs involve a customized mixture of
goals, requirements, and features.
7. Palo Alto could continue the status quo current program. Nothing under current state law
requires Palo Alto to change its current approach.
The City of Palo Alto is currently gathering up to date earthquake risk information about its building
stock and engaging its citizens and local experts in order to develop and evaluate specific policy
alternatives. The ultimate goal is to recommend to city leaders the best possible policy directions for
Palo Alto moving forward.
22 Health and Safety Code §19160-19168 http://www.leginfo.ca.gov/cgi-bin/displaycode?section=hsc&group=19001-
20000&file=19160-19168
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5. REFERENCES CITED
ABAG. (1992). Seismic Safety Incentive Programs: A Handbook for City Governments. Association of Bay Area
Governments, Oakland.
ABAG. (2014). Soft-Story Housing Improvement Plan for the Cit of Oakland. Oakland. Retrieved from
http://resilience.abag.ca.gov/wp-content/documents/OaklandSoftStoryReport_102914.pdf
Alesch, D. J. (2012). Natural Hazard Mitigation Policy: Implementation, Organizational Choice, and Contextual
Dynamics. New York, NY: Springer Business Science.
ATC. (2010). Here Today—Here Tomorrow: The Road to Earthquake Resilience in San Francisco. Community
Action Plan for Seismic Safety, Redwood City. Retrieved from
http://sfgov.org/esip/sites/default/files/FileCenter/Documents/9757-atc522.pdf
CDCA. (2012). California Tenants: A Guide to Residential Tenants’ and Landlords’ Rights and Responsibilities.
Retrieved January 16, 2016, from http://www.dca.ca.gov/publications/landlordbook/catenant.pdf
CSSC. (2006). Status of the Unreinforced Masonry Building Law. California Seismic Safety Commission,
Sacramento.
CSSC. (2009). The Field Act and its Relative Effectiveness in Reducing Earthquake Damage in Public Schools
Appendices. California Seismic Safety Commission, Sacramento.
CSSC. (2013). California Earthquake Loss Reduction Plan / Pre-Earthquake Economic Recovery. California Seismic
Safety Commission, Sacramento.
CSSC. (2013). California Enhanced State Multi-Hazard Mitigation Plan. Sacramento: California Seismic Safety
Commission.
Hart, W. A. (2010). Special Publication 42 (Fault-Rupture Hazard Zones in California)y. Retrieved from
http://www.conservation.ca.gov/cgs/rghm/ap/Pages/affected.aspx
MMC. (2015). Developing Pre-Disaster Resilience based on Public and Private Incentivization. National Institute
of Building Sciences, Multihazard Mitigation Council of the Center on Fire, Insurance, and Real Estate.
OSHPD. (2005). California's Hospital Seismic Safety Law: History, Implementation and Progress. Sacramento.
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CHAPTER III
LOCAL PROGRAM BEST PRACTICES ASSESSMENT
Executive Summary
This chapter summarizes the status of local seismic safety and mitigation programs in California
with the purpose of informing Palo Alto’s effort to update its own approach. It has been
prepared per Task 3 of the Consulting Agreement between Rutherford + Chekene and the City
of Palo Alto. The content builds on the state-level policy review presented in Chapter II. The
scope of Task 3 is to:
Review present best practices among jurisdictions and agencies in this area that require
seismic retrofitting and provide incentives, and deliver a brief summary.
Provide a concise and practical written summary of what other jurisdictions and counties
have done legislatively and programmatically to increase awareness about, assess, and
motivate mitigation of seismically vulnerable buildings, both listing and helpfully classifying
various approaches that have been used.
The process of creating this review included search and review of published and online reports
and materials, several phone interviews with community leaders as well as local and state
government staff, and development of insights from the consulting team based on their
experiences in this arena.
Palo Alto is currently laying a solid foundation for future program development by investing in
new inventory and risk information as well as community outreach and internal staff
discussions. In doing so, it is joining a group of leading coastal California coastal jurisdictions
such as Berkeley, Oakland, San Francisco, and Los Angeles that have recently stepped up their
earthquake risk reduction efforts. While there is much learning and information sharing going
on, each jurisdiction has developed their own customized policy package, and there is no single
best model that Palo Alto can straightforwardly adopt. Existing local approaches differ widely in
the following ways:
Policy mechanisms used to achieve progress;
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Scope of targeted building types or uses addressed;
Prioritization and compliance timeframes; and
Types of incentives offered.
Policy mechanisms in use range all the way from inventory only to mandatory retrofit with
timeframes under five years. In between are more gradual approaches such as voluntary
retrofit advocacy, incentives, provisions that make building deficiencies more visible to the
public (disclosure measures), and mandatory screening and evaluation requirements. An
important policy decision is whether any mandated actions are implemented on a fixed
timeline or triggered at sale or at some renovation cost threshold.
Targeted building types and characteristics also vary. The most commonly addressed building
type is unreinforced masonry (URM) construction due to state law SB 547, as discussed in the
Task 2 report. Over half of URM programs in the state require mandatory retrofit, often but not
always with a time frame on the order of ten to twenty years. By 2006, seventy percent of all
identified URMs were either demolished or retrofit. Retrofit rates are on average three times
higher in jurisdictions with mandatory retrofit compared to voluntary programs. Jurisdictions
used a wide variety of both financial and policy incentives to assist URM owners. Some
voluntary URM programs, including Palo Alto’s, coupled with incentives, have achieved similar
rates of success to mandatory programs.
Newer programs have focused on soft-story wood frame buildings, including ten Bay Area
jurisdictions and most recently Los Angeles as of 2015. Soft-story wood frame building
programs also range in requirements from notification only to mandatory retrofit, but several
jurisdictions have innovatively used intermediate mandatory screening and evaluation phases
to further assess risk exposure and determine the final set of buildings that will be affected by
retrofit requirements. Soft-story wood frame programs have largely been supported in the local
community. Even voluntary soft-story wood frame programs can be effective at motivating
retrofit action; one fourth of the soft-story wood frame buildings in the City of Berkeley were
voluntarily retrofit within a few years after a mandatory evaluation ordinance was
implemented. Compliance timeframes in soft-story wood frame programs tend to be short, on
the order of two to seven years.
A comparatively small number of southern California jurisdictions have acted to address older
concrete buildings, including Los Angeles, Burbank, Santa Monica, and Long Beach. Nonductile
concrete frame and tilt-up concrete structures in particular are known to pose serious risks.
Programs aimed at older concrete range from voluntary guidelines to mandatory evaluation
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and full retrofit requirements. Timeframes here vary greatly, from years to decades.
Information about the implementation and outcomes of these few programs is very limited.
Coming out of this local program review, alternative policy approaches for Palo Alto’s
consideration include:
Option 1: Status Quo. In this option, the existing ordinance with its mandatory evaluation,
voluntary retrofit approach remains in place without changes. Floor area ratio bonuses are
(were) available and could continue to be offered.
Option 2: Increase Scope, but Retrofit Remains Voluntary. Additional categories of structures
are added to the mandatory evaluation requirements. These could include any or all of the
building types discussed above, potentially also using additional location, use, or occupancy
criteria.
Option 3: Similar to Option 2, but Additional Disclosure Measures are Incorporated. This
option would be similar to Option 2, but with increased use of disclosure measures such as
prominently posting the building list on the City website, notifying tenants, requiring signage,
and/or recording notice on the property title.
Option 4: Increase Scope, Some Categories are Voluntary and a Few Categories are
Mandatory, with Enforcement by Trigger Threshold
This option builds on Option 3, but retrofitting would be required for some building types at
whenever future time a building is sold or undergoes substantial renovation above a set
threshold.
Option 5: Increase Scope, Some Categories are Voluntary and a Few Categories are
Mandatory, with Enforcement by a Fixed Timeline
This option would be similar to Option 4, but retrofitting is required according to a fixed
timeline. Timelines and enforcement emphasis could vary depending on tiers or priority
groupings to motivate prompt action for the most vulnerable or socially important structures.
Option 6: Increase Scope, but More Categories are Mandatory
This alternative is similar to Option 5, but retrofitting would be required for additional
categories on a fixed timeline. Palo Alto can also make its programs more stringent over time.
Explicit phasing has been successful in jurisdictions like Berkeley and San Francisco for
generating political consensus and enhancing administrative feasibility.
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Other program features and implementation factors should be considered in designing a future
program. Palo Alto will need to decide whether location, occupancy type, and/or number of
occupants should be included in the scope or just the timeline categories. Whether and which
incentives to offer is an important issue from a political and economic feasibility perspective,
one that affected community members will want to see inclusively addressed. The community
should also be involved in discussing which if any disclosure measures are considered necessary
and appropriate, such as signage.
Additionally, based on the work of cities such as Berkeley, San Francisco, and Los Angeles, Palo
Alto has a variety of opportunities to expand and better connect its earthquake mitigation
program efforts to other city efforts in support of community resilience goals more broadly. For
instance, Palo Alto could encourage building occupancy and resumption program like San
Francisco, encourage or fund installation of strong motion instruments, or pursue special
programs or requirements for cell phone towers, facades, private schools, and/or post-
earthquake shelter facilities. Several leading local program models and planning resources for
these types of efforts are introduced in Appendix D.
1. INTRODUCTION
This document is meant to be a resource and guide for the Palo Alto community and city
leadership as they weigh program needs and options for seismic mitigation policymaking going
forward. It offers comprehensive information on many topics so readers with different
backgrounds can advance their understanding, along with summary tables and conclusions
specific to Palo Alto’s present effort.
The approach taken was to document and assess existing and proposed programs that a
selected set of other jurisdictions are using to address earthquake vulnerabilities in local
buildings. This was done using analysis of city websites and documents, search and review of
published and online reports, several phone interviews with local officials and engineering
profession leaders, and development of insights from the consulting team based on their
experiences in this area.
Focusing on a selected set of jurisdictions was appropriate for several reasons. First, relatively
few jurisdictions are developing leading earthquake mitigation programs, and those are the
most informative models to draw upon. Second, data about jurisdictional programs is very
limited. Much of the information that does exist is anecdotal, and it was not within the scope of
this review to collect comprehensive new data or to cover a large number of jurisdiction
programs statewide or in other countries. Finally, this review emphasizes classification of
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similarities and distinctions among a range of leading jurisdiction earthquake structural
mitigation efforts. Policies related to wider earthquake hazard science and awareness,
emergency management, and longer term recovery programs that have local relevance are
briefly mentioned, but are also beyond the scope of this report.
Following this introduction, Section 2 describes and compares a range of existing local policies
and programs. The information is organized by key features (for instance, the types of buildings
regulated, the kinds of requirements imposed on them, and the types of incentives offered).
Section 3 presents summary conclusions for Palo Alto. Figures throughout and two appendices
provide further detail on a range of program elements. Formal recommendations for Palo Alto
will evolve after completion of other project tasks, and through the process of Advisory Group
and City staff discussions.
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2. ANALYSIS OF POLICY FEATURES AND OUTCOMES OF LOCAL SEISMIC RISK MITIGATION PROGRAMS
This section analyzes the state of local earthquake policymaking in California by presenting
major types, similarities, and differences in program features. The word “features” indicates
here a wide array of program nuances, including but going well beyond the characteristics of
the buildings being targeted and the basic policy mechanism used, namely voluntary or
mandatory retrofit requirements. Woven throughout are examples of jurisdictional programs
that exemplify certain of these features and distinctions, along with discussion of program
outcomes and effectiveness. Analyzing programs this way highlights options and key factors
that Palo Alto should consider and tradeoffs it may need to confront in developing its own
seismic mitigation strategy going forward.
Much innovation in local earthquake risk reduction policy is happening in California from which
Palo Alto can learn. This is particularly true in the case of soft-story wood frame residential
buildings,23 for which mandatory retrofit ordinances are now in place in Fremont, San
Francisco, Berkeley, and Los Angeles. However, what makes one program different from or
more successful than others cannot be understood simply by identifying the types of structures
addressed. Also important are the specific set of requirements that owners must comply with,
the timeframes in which requirements must be carried out, and the types and sizes of the
incentives offered.
Comprehensive, summary information to inform this review are rare. In-depth California
Seismic Safety Commission URM reports cover every city and county for URM law compliance
up to 2006. But beyond URM programs, data to support this assessment was limited and largely
anecdotal because comprehensive research on seismic mitigation programs is rare. An
23 “Soft-story” refers to a condition where one of the stories in a multi-story building, usually a parking level that
doesn’t require partitions for functionality, is weaker and/or too flexible compared to the story above it. Another
acronym sometimes used is “Soft-, Weak-, or Open-Front” buildings, or SWOFs. During strong ground shaking,
concentration of damage in the soft or weak story can significantly increase the chance of collapse or damage
sufficient to render the building unusable after the event. Many communities are concerned with soft-story wood
frame buildings. Most of this type of construction can be found in apartment buildings built in the 1960s and
1970s with first floor garage openings and some mixed-use properties with ground floor commercial space. In that
era, the safety risks of soft-stories were not yet fully understood. Vast numbers of these buildings exist in California
communities that grew substantially prior to the 1980s and 90s when building code changes were introduced.
Findings related to evaluating and improving soft-story wood frame performance can be found in FEMA P-807,
available at: https://www.fema.gov/media-library/assets/documents/32681 (Accessed February 3, 2016).
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Association of Bay Area Governments (ABAG) survey that collected program information from
one third of California jurisdictions in the 1990s documented a wide variety of program
implementation, effectiveness, and incentive approaches; however, its information is now
significantly out of date. Policies of certain leading jurisdictions have been studied in depth at
various windows in time, such as Palo Alto ) (Herman et al, 1990), Berkeley (Rabinovici, 2012;
Chakos, 2002), Oakland (Olson, 1999), and Los Angeles (Comerio, 1992). These studies reveal
how unique and complicated local earthquake mitigation programs can be, not just in format
but also implementation. Outcomes cannot be understood without considering the local
building stock and economic context, concurrent policy developments, political support, local
government resources and administrative capacity, how policy features are combined,
community engagement strategies used, and emphasis put on enforcement.
At the outset, Palo Alto’s unique current program and historic role in the evolution of
earthquake mitigation program design should be recognized. Its 1986 law was among the first
to require owners of suspected hazardous properties to have a qualified engineer evaluate
their buildings. In addition, Palo Alto’s Seismic Hazards Identification Program (Chapter 16.42)
addressed three categories of buildings: URM buildings (Category 1), structures built before
1935 with over 100 occupants (Category 2); and structures built before August 1976 with over
300 occupants (Category 3). This demonstrates how occupancy level and year built can also be
used in combination with other factors as the basis for inclusion in a program. The mandatory
evaluation reports for these structures were due in 1990. The September 2014 status of
affected properties is shown in Table 1.
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Table 1: Status as of September 2014 of properties included under Palo Alto’s current earthquake
risk reduction ordinance.
Category I – Category II – Category III –
All Categories URM over 1900
sq.ft. and over
six occupants
Built before 1935
and over 100
occupants
Built before
8/1/76 and over
300 occupants
Retrofit 22 13 5 40
Demolished 14 2 5 21
Demolition
Proposed 0 0 4 4
Exempt 1 0 0 1
No Change 10 4 9 23
Totals 47 19 23 89
Source: 12/9/14 City of Palo Alto Policy and Services Committee staff report.
Palo Alto’s decision to focus on these three categories grew out of a broader earthquake risk
assessment effort going on at that time. City leaders initiated a comprehensive search of paper
records and a street walk-style inventory of a wide variety of seismically-vulnerable building
types in 1984. They then engaged the community in a deliberative process to assess risk and
determine priorities among building types and policy approaches (Herman, Russell, et al. 1990;
CSSC 2006).
The following section describes alternative ways different jurisdictions have chosen which
buildings to target.
Scope: Targeted Structural Systems, Year Built, and Other Characteristics
The primary feature that varies among jurisdictional programs is the types and characteristics
of the structures that are addressed. As discussed in the Task 2 report, California’s earthquake
policy history started in the 1930s with laws that increased design requirements for buildings
related to one particular use—public schools, and banned new construction of one particular
structural system or type—buildings with unreinforced masonry (URM) load bearing walls.
Much later in the 1970s and 80s, both state and local new laws were passed targeting URMs
built before 1933, certain locations (e.g., hazard zoning with prohibitions or heightened
evaluation and design scrutiny for new construction or rehabilitation in those zones), a wider
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set of uses (e.g., hospitals and essential services buildings) and additional structural types (e.g.,
older concrete buildings and manufactured homes).
The choices jurisdictions make about which buildings to target are closely tied to the legal basis
underlying earthquake mitigation policymaking. Laws that impose added burdens or
responsibilities on certain properties or people must clearly specify which buildings are
applicable and justify why for those particular buildings have been selected. A compelling,
documentable, and actionable public purpose must exist to invoke a jurisdiction’s police
powers and responsibility for public wellbeing.
The central rationale for regulating seismically vulnerable structures is safety; a strong case for
government intervention exists where there is an unacceptably high likelihood of collapse or
damage that could lead to human entrapment, injury, or death. Technical research, evidence,
and evolving standards of practice in structural engineering must exist for this to be considered
reasonable. Once a new practice becomes embedded in a model building code, construction to
former code standards is no longer allowed. Jurisdictions review permits and inspect
construction work in progress, but lax compliance cannot entirely be ruled out.
For any particular structural system, year built (or age) is the most commonly used risk
indicator because it reflects the building code version that was in effect when a structure was
first constructed. What was once considered an acceptable construction practice may become
obsolete or even be considered negligent years later. Code updates are usually made on a
three-year cycle to keep up with changes in construction practices, technologic advancements,
and improved understanding how buildings perform under loads, but adoption by jurisdictions
can be uneven and lag behind many years.
Jurisdictions must also address which code year built they will use as inclusion criteria for their
earthquake mitigation programs. Benchmarking to newer standards may be justified if it
reaches more buildings that could experience significant damage in an earthquake, but a larger
percent of building owners and tenants will be affected. Code changes are also proposed based
on lessons learned from practical experience over time, in this case from earthquake
performance outcomes in jurisdictions all around the world.
Unreinforced Masonry Buildings
URM buildings have been a concern for collapse and falling debris hazard ever since the
1933 Long Beach earthquake, after which new construction of URM structures in
California was outlawed. The most significant contemporary law addressing a specific
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building type is the 1986 state legislation (Senate Bill 547). This state mandate, also
summarized in the Task 2 report, required jurisdictions to identify and adopt programs
for addressing existing URM buildings. Several jurisdictions (most prominently Long
Beach, Los Angeles, Santa Cruz, Palo Alto, and San Francisco) had existing URM building
ordinances and programs in place prior to the state mandate. Counties and
municipalities were allowed to craft their own approach, resulting in a wide range of
strategies.
In general, three main types of local programs were utilized: 1) mandatory retrofit, 2)
voluntary retrofit, and 3) notice to owners that the structure is a URM building. When
retrofits were encouraged or required, the local government set the standards to be
met. More than half (52%) of affected jurisdictions adopted a mandatory program,
which has proven by far to be the most effective type. Eighty-seven percent of identified
properties have been retrofitted or demolished in jurisdictions with mandatory
programs, compared to thirteen to 25 percent in jurisdictions with other program types.
Reviews of the URM Law by the CSSC have shown it to be a success over the long term.
In 2006 (the last comprehensive state survey available), Compliance with the policy is
nearly universal at 93%, and over 70% of identified URM buildings have been either
retrofitted or demolished (CSSC, 2006). A comprehensive review of URM program
formats throughout the Western United States is available from FEMA and the California
Seismic Safety Commission (FEMA, 2009; CSSC, 2006).
Older Concrete Buildings
Older concrete structures (built pre-1970s and in some cases pre-1990s) exemplify the
importance and difficulties of using code year as an indicator of seismic risk. Public
awareness of older concrete risks may be lower than for soft-story wood frame
buildings, but they are common in large numbers in the Western US and throughout
California. The Concrete Coalition,24 a network of engineers, research organizations, and
policymakers, estimates that there are as many as 17,000 non-ductile concrete buildings
in California (Concrete Coalition, 2011). The societal importance of older concrete
structures can be significant, as they often have higher occupancies and are widely used
for residential tall buildings, commercial, or even critical service facilities.
24 Information about the Coalition can be found at the organization’s website: http://www.concretecoalition.org/,
Accessed March 18, 2016.
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Poorly performing concrete structures can have devastating effects for occupants,
owners, and communities, as numerous major quakes in California and abroad have
demonstrated. The 1971 Sylmar earthquake brought down several concrete structures,
killing 52, and the 1994 Northridge earthquake wrecked even more, including a Bullock's
department store and Kaiser medical office. In the 2011 quake in Christchurch, New
Zealand, two concrete office towers collapsed killing 133 people. Many of the 6,000
people killed in the 1995 earthquake in Kobe, Japan, were in concrete buildings.
A scenario report for the San Francisco Bay Area estimates that older concrete buildings
in a repeat 1906-level event would contribute a large portion of the predicted deaths
and injuries (ABAG, 1999). Also at risk are investors, the survival of occupying
businesses, and livelihoods. Neighborhoods can be at risk too if a district has a high
concentration of older concrete buildings, as they may be blighted or loose functionality
or economic viability after an event.
Older concrete buildings of concern have a variety of features and are not always easy
to characterize. One issue is nonductile (essentially too brittle, insufficiently reinforced)
concrete, prior to enforcement of ductile concrete codes in the 1970s. Another is tilt-up
structures, where a concrete is poured on the ground, cured, and then lifted (or “tilted”)
up and connected to roof and floor framing where the ties between the roof and wall
and floors and walls are often inadequate.
Vulnerable concrete structures can be difficult to spot and often complex to retrofit
(ATC, 2012). These are factors in why only a small number of California jurisdictions
have adopted policies for older concrete (Table 2). The City of Los Angeles (Building
Code Divisions 91 and 96) recently required evaluation and upgrade if needed for
nonductile concrete structures and since Northridge has required triggered upgrading
on pre-1976 tilt-ups. City of Santa Monica (Municipal Code 8.80) requires evaluation and
upgrade if needed for nonductile concrete structures, along with other structural types.
In 2014 Santa Monica hired the engineering firm Degenkolb to inventory buildings that
might be subject to its requirements—a first step in reviving efforts that had been
stalled for more than 20 years.25 Two jurisdictions, Long Beach (Chapter 18.71) and
Burbank, have taken the approach of providing voluntary guidance. Burbank’s program
addresses older reinforced concrete and concrete frame buildings with masonry infill.
25 http://www.latimes.com/local/lanow/la-me-ln-santa-monica-will-hire-quake-engineers-to-id-all-vulnerable-
buildings-20140527-story.html (Accessed March 20, 2016).
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Table 2: Summary table of local programs for addressing older concrete building vulnerabilities.
Jurisdiction
Number
of Older
Concrete
Buildings
Program
Type
Targeted
Building
Characteristics
Deadline
for
Screening
Deadline
for
Evaluation
Deadline
for
Completion
Los Angeles Unknown
(Concrete
Coalition
inventory*
= 1500)
Mandatory
evaluation
leading to
mandatory
retrofit
Pre-1976 tilt-
ups and
nonductile
concrete
3 years 10 years 25 years
Santa Monica Unknown
(Concrete
Coalition
estimate*
= 173)
Mandatory
evaluation
leading to
mandatory
retrofit
Pre-1978
nonductile
concrete.
n/a 275 days Deadlines
vary from 1
to 4 years
after
evaluation
report
submission,
depending
on priority
tiers. **
Long Beach Unknown
(Concrete
Coalition
estimate*
= 396)
Voluntary
guidance
Nonductile
concrete
n/a
Burbank Unknown
(Concrete
Coalition
estimate*
= 132)
Voluntary
guidance
Commercial
pre-1977
reinforced
concrete and
concrete frame
buildings with
masonry infill
n/a
* Source: (Concrete Coalition, 2011).
** Santa Monica’s Building Type definitions are: Type I: building that are vital in the event of an
emergency; Type II: >100 occupants; Type Ill: 20 - 100 occupants; Type IV: < 20 occupants.
Soft-Story Wood Frame Buildings
Wood frame soft-story buildings are a good example of a vulnerable building type that
gained widespread attention after performing poorly in specific earthquake events. In
October 1989, the hazard and widespread presence of this building type were made
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evident by the dramatic and costly collapses and fires in the San Francisco Marina
District in the Loma Prieta earthquake. Then again, in the Northridge event in 1994,
widespread damage and several high profile collapses occurred. The Northridge-
Meadows apartment complex collapse that led to sixteen deaths in particular captured
media, public, and expert attention.
Following these events, soft-story residential buildings started to be viewed as not just a
threat to the owner’s pocketbook but to the surrounding community; tenant safety and
local recovery could also be at stake. Given their prevalence, losing hundreds of soft-
story apartment buildings could have large impacts on community. For example, soft-
story buildings constituted about half (7,700) of the 16,000 housing units rendered
uninhabitable in the Bay Area by the 1989 Loma Prieta Earthquake and over 34,000 of
the housing units rendered uninhabitable by the Northridge Earthquake in 1994 (ABAG,
2003). Table 3 describes a wide range of local efforts to address soft-story wood frame
buildings, highlighting key program features and distinctions (many of which are
discussed in later sections regarding prioritization, timing, and policy mechanisms).
Attachment F
Seismic Risk Assessment Study December 21, 2016
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Table 3: Summary of local soft-story wood frame policy efforts showing key distinguishing program features.
(Sources: Rabinovici, 2012; ABAG, 2016).
Jurisdiction Year
Number
of Soft-
story
Buildings
Program
Type
Targeted Building
Characteristics Priorities or Tiers
Deadline
for
Evaluation
Deadline
for
Permit
Deadline
for
Completion
Los Angeles 2015 unknown
Mandatory
Evaluation
leading to
Mandatory
Retrofit
Pre-1978 wood-
frame structures
with soft, weak or
open front first
floor conditions
with two or more
stories and five or
more units. Only
enforcement is
prioritized by
tiers.
Priority I - Buildings
containing 16 or more
dwelling units.
1 year 2 years 7 years
Priority II - Buildings with
three stories or more,
containing fewer than 16
dwelling units.
Priority III - Buildings not
falling within the
definition of Priority I or II.
Oakland 2015 1,380 Mandatory
Screening
(passed
2009)
leading to
Mandatory
Retrofit
Pre-1985 multi-
family wood
frame structures
with five or more
units
n/a
Attachment F
Table 3 (continued).
Seismic Risk Assessment Study December 21, 2016
Final Report Page 39
Jurisdiction Year
Number
of Soft-
story
Buildings
Program
Type
Targeted Building
Characteristics Priorities or Tiers
Deadline
for
Evaluation
Deadline
for
Permit
Deadline
for
Completion
Berkeley 2014 310 (at
time of
2005
ordinance)
Mandatory
evaluation
law (2005)
leading to
mandatory
retrofit
(2014)
Multi-family wood
frame structures
with five or more
units
n/a 2 years
(under
previous
soft-story
evaluation
ordinance)
2 years 4 years
San Francisco 2013 2,800
Mandatory
evaluation
leading to
mandatory
retrofit
Wood frame
construction with
five or more
residential units
and two or more
stories with
permit for
construction
submitted prior to
January 1, 1978
and five or more
units
Tier I - Any building
containing educational,
assembly, or residential
care facility uses (Building
Code Occupancy E, A,
R2.1, R3.1, or R4)
1.5 years 2.5 years 4.5 years
Tier II - Any building
containing 15 or more
dwelling units
2.5 years 3.5 years 5.5 years
Tier III - Any building not
falling within another tier
3.5 years 4.5 years 6.5 years
Tier IV - Any building
containing ground floor
commercial uses (Building
Code Occupancy B or M),
or any building in a
mapped liquefaction zone
4.5 years 5.5 years 7.5 years
Attachment F
Table 3 (continued).
Seismic Risk Assessment Study December 21, 2016
Final Report Page 40
Jurisdiction Year
Number
of Soft-
story
Buildings
Program
Type
Targeted Building
Characteristics Priorities or Tiers
Deadline
for
Evaluation
Deadline
for
Permit
Deadline
for
Completion
Alameda 2011 70 Mandatory
evaluation
Five or more units n/a 2 years
Fremont 2005 22 Mandatory
retrofit
Apartment house
with more than
ten units or more
than two stories
Group 1 - Apartment
house with more than ten
units or more than two
stories
n/a 2 years 4 years
Group II - Apartment
house with ten or less
units and fewer than three
stories high
n/a 2.5 years 5 years
Attachment F
Seismic Risk Assessment Study December 21, 2016
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Public Purpose, Occupancy, Location, and Other Considerations
Another stated goal of seismic mitigation laws is to promote continuity of vital services
related to the community’s social and economic viability. In addition to direct safety
concerns, this further justifies targeting special uses and buildings that affect larger
numbers of people such as schools, critical public buildings, and hospitals. Beyond
critical community functions, however, it is less obvious where to draw the line between
public and private risks and benefits. How many people need to live or work in a
building before a suspected earthquake vulnerability becomes something an owner or
tenant should not be allowed to make decisions about on their own?
The answer involves some sense of proportionality. In other words, local governments
tend to seek a reasonable balance between the number of building owners that will
need to comply and the burden of compliance, with the public benefits that will be
achieved (which we can assume to be protection of health and preservation of
community functionality). That is a key reason why buildings with higher occupancy or
higher residential unit total are sometimes targeted. Such buildings not only have more
human beings that work or live in them, but the fate of the buildings also has a larger
impact on local housing availability, parking, and other community impacts. For
instance, most existing soft-story wood frame programs are targeted at multifamily
buildings with five or more residential units (see Table 3). Larger structures are also
presumably worth more, so the owner is more likely to have sufficient equity in the
property or cash flow to make capital upgrades.
A structure’s number of stories may also relate to the degree of risk or perceptions of
public importance. Problematically, more stories may not always translate into higher
risk; for example, two-story soft-story buildings may not necessarily be less dangerous
compared to three story ones, depending on the materials used and the positioning of
occupied units (Bonowitz and Rabinovici, 2012).
A good example of a program that uses location or zoning as part of its targeting is Palo
Alto’s Municipal Code Chapter 18.18.070 Floor Area Bonuses incentive. The incentive is
only available for buildings in Commercial Downtown (CD) District, which has sub-zones
based on CD-C Commercial, CD-S Service, and CD-N Neighborhood designations. Zoning
benefits are different for each of these designations, the square footage, and also if the
building in question is historic property.
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Seismic Risk Assessment Study December 21, 2016
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Ownership structure is another potential scoping issue, for instance, whether
condominiums should be included.26 The City of Berkeley did not include condominiums
in its soft-story wood frame building ordinance, but the jurisdictions of San Francisco
and Fremont did. Condominiums often face additional barriers in both voluntary and
mandatory retrofit policy settings, because homeowner association policies and
practices can make it difficult to agree on what should be done and to obtain financing.
Anecdotally, in Palo Alto and elsewhere, properties where a majority of owners want to
retrofit have not been able to accomplish that work because of hold-out members that
do not want to proceed or pay an additional assessment in order for the association to
be able to afford it. The overall influence on retrofit behavior of either including or
excluding condominiums is not known.
A final point that should be noted about program scope is that some properties that would
otherwise be subject to a law can be classified as exempt for certain reasons. For instance, most
jurisdictional ordinances offer exemptions for buildings that have had significant recent
renovations or retrofit upgrades that addressed the hazardous condition. Some jurisdictions
explicitly include protocols for hardship provisions such as extended timelines that might be
made available for individual or institutional owners that can demonstrate an unusual degree of
difficulty raising sufficient funds to comply.
Timelines, Pacing, and Prioritization
For several reasons, jurisdictions find it useful to both prioritize and pace their earthquake
program efforts. Time is a powerful ally and policy variable. Once a jurisdiction commits to the
idea of a new program, timeframes can be used to make implementation manageable and
soften the economic impacts of the program on city staff and budgets, on owners, and on the
local economy. Retrofitting is also a process that cannot be sped up beyond a certain point.
Design, arrangement of financing, and completion of retrofit work can be an arduous process,
naturally taking from months to years. Lengthier time windows allow owners to plan for how to
comply in the way that works best for them. Longer time frames can also work to the
advantage of jurisdictions, which rarely have sufficient administrative capacity, political will,
and community tolerance to take on multiple seismic risk issues simultaneously over a short
26 Keep in mind that condominium status can change. The City of Berkeley decided not to include condominium
properties on its Suspected High Hazard Building list. However, owners in some apartment buildings in the process
of being converted to condominium status when needing complying with the law experienced difficulty getting
loans (Rabinovici, 2012).
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Seismic Risk Assessment Study December 21, 2016
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period of time. Following are several examples of how different jurisdictions have used timing
as part of their program structure.
Trigger-Enforced Timing
Some jurisdictions have opted to require earthquake retrofit to be done only when the
property is sold and/or an owner submits plans for renovation, additions, or
rehabilitation that meets certain criteria, for instance 50% of the assessed value. This is
similar to triggers for energy upgrading, sewer lateral replacement for single family
homes, modifications for Americans with Disabilities Act compliance, or sprinkler and
other fire code changes.
A jurisdiction taking this approach does not need to inventory vulnerable structures in
advance and may be able to do project reviews at current staffing levels. However,
there are several downsides. Owners may resent encountering these potentially
substantial “surprise” costs when initiating a project, and might strategically manipulate
project valuation to avoid needing to comply, resulting in lower fees for the city. For
those owners that are aware of the provisions, potentially important non-seismic
renovation work that would have been done otherwise might be postponed as a result
of increased project cost and complexity. Most importantly, critical safety and resilience
retrofit work might go decades without being done.
Proactively-Enforced Timing with Phasing and/or Prioritization
Proactive enforcement means that a jurisdiction identifies, notifies, and actively seeks to
help owners participate or comply in a program. It is common when these programs
include mandates to use a variety of time frames for buildings with different
characteristics. For instance, Los Angeles’s 2015 ordinance requires compliance for soft-
stories within seven years and older concrete within 25 years. Another common
strategy is to classify buildings of a single targeted structural type into tiers or priority
levels among a particular type of building, for instance based on age, number of
stories, unit totals, or occupancy. Compliance can then be mandated sooner in order
from most to least serious in terms of estimated risk and social importance. Time frames
for soft-story programs, for instance, commonly relax deadlines by about one year per
tier (See Deadlines by programs in Table 3). Both of these phasing approaches allows
jurisdictions to set a feasible administrative pace and put an early focus on buildings
with vulnerabilities and characteristics that most affect the public.
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An overall pacing strategy can also be used to phase implementation of a larger set of
resilience policies and programs that go beyond different building types to address
other aspects of community earthquake vulnerability. For instance, San Francisco
mandated soft-story wood frame building retrofitting, then mandated its 120 private
schools to do seismic evaluations of their buildings regardless of structure type,27 and
then embarked on efforts to assess and create programs for poorly anchored façades
and unreinforced masonry chimneys.
All three approaches – 1) phasing and compliance time frames that differ for structures,
2) in different priority tiers, 3) within a multifaceted comprehensive plan – were used in
recommendations from San Francisco’s decade-long Community Action Plan for Seismic
Safety (CAPSS) project (ATC, 2010). Figure 2 shows an earlier version of how San
Francisco thought about address different building types and uses more or less quickly
and with gradually increasing requirements.
Later, these concepts were embedded into the jurisdiction’s policies as part of San
Francisco’s 30-year Earthquake Safety Implementation Plan (SF ESIP, 2011). That plan
represents a commitment by the city to phase in additional efforts over this extended
period, and deliberately addressed a wide range of vulnerable structure types, uses, or
occupancy combinations considered important to community resilience (e.g., private
schools, façades). Additional advantages of long time frames are to allow more time for
detailed studies or research if needed, for political or community consensus to develop,
and give owners ample notice of bigger changes to come.
27 Ordinance text available at: http://sfgov.org/esip/sites/default/files/FileCenter/Documents/12716-
Ordinance%20No%20202-14%20Private%20Schools%20EQ%20Evaluation.pdf (Accessed February 3, 2016).
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Figure 2: Excerpt of Table 5 from the summary San Francisco CAPSS Project report (ATC, 2010)
showing recommended timelines for prioritizing and phasing different kinds of efforts to address
a variety of building types and uses.
Note: Categories represented in rows are not mutually exclusive. For instance, some private school
facilities may be located in a house of worship or historic structures.
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Seismic Risk Assessment Study December 21, 2016
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Policy Mechanisms and Requirements
In addition to creating a set of targeting and eligibility criteria, jurisdictions can use a variety of
methods to motivate appropriate seismic upgrades to be done. Requiring owners to do retrofit
work is only one approach. Other tools range from simple notification, disclosure measures,28
offering incentives, voluntary retrofit initiatives, and mandated screenings or evaluations, each
of which is described below in more detail. Another major distinction is whether a jurisdiction
implements requirements only when triggered during rehabilitation projects that meet certain
criteria, or proactively, such as doing an inventory to identify affected properties and imposed
deadlines.
Figure 3 provides definitions of a spectrum of policy mechanisms that have been used. This
view corrects the false impression that jurisdictional programs have to be either “voluntary” or
“mandatory.” In reality, most jurisdictions create a policy package that combines several
approaches. Furthermore, that package can evolve over time as more and more buildings are
upgraded, new information or technical recommendations become available, or with changes
in the political or economic climate.
Inventory
Identifying the number and locations of buildings of concern is an essential first step to
finding out which buildings are the most vulnerable and how significant those issues
may be for the community. Many jurisdictions launch their earthquake program
development process with a special-purpose, one-time discovery effort meant to
compile data about potentially seismic at-risk properties and to gauge the scope of the
issues faced by the community. This can be difficult and time consuming, and
jurisdictions often rely on outside consultants or professional organizations and
academic volunteers for assistance. Existing property databases generally contain less
than complete information to be able to draw conclusions, and some relevant
information may only exist in paper form. Street-walks, side walk surveys, or visits to a
selected sample of properties are common.
It is important to distinguish early investigation and risk analysis efforts that might
involve only a subset of properties from the development of an exhaustive list of
properties meeting certain criteria that could be officially noticed or subjected to a
28 Disclosure policies are designed to increase the transparency and openness surrounding an issue of social
importance. Examples include mandatory disclosure to tenants, freedom of information requirements, public
signage, searchable online listing, or official notice placed on a title or deed. These are described in Table .
Attachment F
Seismic Risk Assessment Study December 21, 2016
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particular ordinance. The City of Berkeley is one jurisdiction that used a list created by
staff and consultants as the basis for determining which properties should be included
on that city’s suspected hazardous properties list. Other cities have instead chosen to
put buildings on an initial suspected hazard list based on zoning, number of units, or
other generally available criteria.
Palo Alto’s current investigation into updating its seismic risk management program
involves review of digital records, paper records, and side walk surveys. The side walk
survey portion includes approximately half of the buildings of interest. A similar
detailed field effort would be needed on the remaining portion of buildings to develop a
comprehensive inventory list.
No inventory list will be perfect, so no matter which approach is used, some kind of
appeal, confirmation, or screening processes are needed before granting any
exemptions or enforcing requirements. Depending on the building type, issues of
improper inclusion or exclusion from a list may be more or less likely. For example,
rapid visual determination is easier for wood frame soft-story conditions, but it would
be hard for even an experienced engineer to identify a steel moment frame, braced
frame building, or a concrete frame building when the structural elements are hidden
from view by architectural finishes.
Attachment F
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Figure 3: Diagram showing a spectrum of mitigation policy approaches ranging from least to most stringent.
Inventory Only Notify Only Voluntary
Retrofit
Disclosure
Approaches
Mandatory
Screening
Mandatory
Evaluation
Mandatory
Retrofit
Staff, consultants,
and/or a volunteer
organization has
created an
inventory of one or
more suspected
hazard building
types, but the list is
not officially
released to the
public or acted
upon.
An inventory exists
and a policy has
been established to
notify owners if
their property is on
a suspected hazard
building list.
Owners of
properties on a
publically available
list are formally
encouraged to
retrofit, possibly by
offering of technical
assistance, financial
help, or policy
incentives.
Properties on a
publically available
list are subject to
one or more
methods of forced
information
sharing, such as
tenant notification,
public signage, or
recorded notice on
the property title.
Owners of
properties on a
publically available
list are required to
submit a form
within a fixed time
window that is filled
out by a licensed
building
professional.
Typically, the goal is
to determine
whether the
property has certain
characteristics that
might associate
with risk.*
Owners of
properties on a
publically available
list are required
submit within a
fixed time window a
formal evaluation
completed by a
licensed engineer.
Typically, a
determination is
then made about
whether the
property has certain
risk features.*
Owners of
properties on a
publically available
list are required to
complete a retrofit
by a certain date.
This step may be
implemented
following a
screening or
evaluation phase.*
* Note: Implementation and enforcement might be either: 1) triggered by sale or a significant work threshold or 2) via a proactive compliance timeline.
Increasingly Stringent
Attachment F
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Notification
Once an inventory is created, a jurisdiction either by default or deliberately chooses
whether or not to make that list public or take further actions. Some jurisdictions have
created a list then not acted on it for a decade or more. For example, in the case of soft-
story wood frame buildings, Santa Clara County’s list has remained dormant since 2003,
and nine years passed between the creation of a list and when the City of Berkeley
passed its soft-story ordinance.
The most basic step is to notify owners that their property is on some kind of suspected
earthquake hazard list. This is currently the URM policy of a small number of California
jurisdictions, and the soft-story wood frame policy in the jurisdictions of San Leandro,
Sebastapol, and Richmond. Available data about notification only programs shows them
to have little impact; for instance, seven percent of URM properties in jurisdictions with
this type of program are retrofit as of 2006 (CSSC, Status of the Unreinforced Masonry
Building Law, 2006).
Little evidence exists about potential liability and market value impacts from becoming a
“listed” earthquake vulnerable building. However, concern exists that mere creation of a
list could have negative impacts if it becomes public (see more about Disclosure
Approaches below). A Freedom of Information Act (FOIA) filing (for instance, by a
journalist or citizen) could be used to compel a jurisdiction to reveal a list that has
remained dormant. This happened in the case of Los Angeles with the Concrete
Coalition’s inventory of suspected concrete structures.29 Experts in the earthquake field
believe that media coverage of the list contributed to eventual passage of that city’s
mandatory evaluation ordinance in 2015, which included concrete structures. In sum,
notification programs may have several downsides for owners while offering little in
terms of on the ground risk reduction for the community.
Voluntary Retrofit
Following an inventory and notification process, or even after a mandatory screening or
evaluation phase (see below), jurisdictions can choose to let owners decide whether or
not to retrofit their building. Simply urging building owners that own a potentially
earthquake vulnerable building may be enough to lead some to voluntarily retrofit.
29 Key Los Angeles Times articles can be found at: http://graphics.latimes.com/me-earthquake-concrete/ and
http://www.latimes.com/local/lanow/la-me-ln-concrete-buildings-list-20140125-story.html (Accessed April 11,
2016).
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Retrofit rates for jurisdictions with voluntary URM retrofit programs averaged 16% in
2006 (CSSC, Status of the Unreinforced Masonry Building Law, 2006), and likely much
lower than that for soft-stories (though no systematic data currently exist).
Jurisdictions that take a voluntary route often do so because they have a small number
(presumably less socially-significant set) of vulnerable buildings. Another factor can be a
sense that public support is lacking among decision makers, residents, or other
stakeholders for mandatory requirements, perhaps because of local economic
conditions that would make it difficult for owners to afford or get financing. The
anticipated cost of the retrofit work can also come into play, as it can be more palatable
to require owners to make investments that are a smaller share of the building’s overall
value.
Despite perceptions of politically feasibility and some measurable voluntary retrofit
response, programs without mandates are almost always much less effective at actually
reducing earthquake risk in the community in a significant way. Several factors appear
to contribute to the handful of voluntary programs that have worked well. First and
foremost, voluntary programs vary in the level of resources devoted, sustained effort,
and set of complementary measures taken by the jurisdiction. The more dedicated a
jurisdiction is to having a successful voluntary program, the more likely it is to have one.
One tactic is to provide case by case assistance to owners in taking steps over time, a
tactic sometimes used by jurisdictions with a small number of affected buildings.
Another is to offer significant financial or policy incentives (examples of which are
discussed below). On the public awareness front, providing educational materials that
explain the risks to an owner and to the broader community and the benefits of
protecting their financial investment may help.
Another thing that can make voluntary programs more successful is to threaten to
institute a mandatory program in the future. Historically, many jurisdictions did adopt a
voluntary URM program first, and then shifted to mandates later on. In the past five
years, this has also happened with soft-story wood frame policies in the case of
Oakland, San Francisco, and Berkeley. An explicit multi-phased approach was
particularly effective in Berkeley, where one fourth of building owners affected by a
mandatory evaluation requirement invested in a voluntary retrofit within the first two
years. Owner interviews showed this was partly because they wanted to get a head start
on later mandates that appeared inevitable (Rabinovici, 2012).
Attachment F
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Disclosure Approaches
Notification and many voluntary programs are based on the idea that information and
communication by themselves can influence the opinions and actions of owners,
renters, and buyers. Officially publicizing a city’s concerns about deficiencies of a
specific building type could, for instance, change public opinion about the resale or
rental value of listed properties, an owner’s eligibility for refinancing or future loan
terms, or the cost of purchasing earthquake insurance.
Jurisdictions have used a variety of techniques to motivate attention to seismic risk
concerns. As discussed in the Task 2 report, mandatory disclosure at time of sale is a
key part of state laws for pre-1960 homes in earthquake fault zones (CSSC, 2005). The
most prominent policy is the state requirement for signage on all URM buildings. Similar
signage has been required since 2007 on soft-story wood frame buildings in the City of
Berkeley (Figure 4), and non-complying soft-story wood frame buildings in San Francisco
Figure 5.
In Oakland, Berkeley, and San Francisco tenants must be notified in writing, and official
notices are recorded on the deed for all listed soft-story wood frame buildings.
Attachment F
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Figure 4: Photo of the warning sign mandated to be posted on buildings on the City of Berkeley’s
Suspected Earthquake Hazard Building List (Photo: S. Rabinovici, 2011).
Attachment F
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Figure 5: Required placard for soft-story wood frame buildings that failed to comply on time with
the mandatory screening phase of San Francisco's mandatory retrofit program.
Attachment F
Seismic Risk Assessment Study December 21, 2016
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In the case of soft-story wood frame buildings, leading jurisdictions have also put a
public, sometimes searchable list of affected properties on a jurisdiction’s website,
based on the idea that renters should be entitled to easily accessible information before
they sign a lease. Such lists include the street address and potentially also the
compliance status of the property. Owner names or contact information are not given,
although anyone could search for that information through public permit and property
records. Table 4 describes each of these tools in more detail and gives examples of use
as well as advantages and disadvantages.
What all these measures have in common is that they make seismic risk issues more
transparent and visible to affected members of the public. Disclosure is different than
and goes beyond general public awareness. These measures are also meant to inform
people about specific seismically vulnerable buildings, with the idea that it might change
offering prices, mortgage availability and terms, rental or purchase decisions, or even
whether someone wants to enter or stay very long in a building. In theory, as owners,
tenants, bankers, and potential buyers become more informed, they can better
incorporate seismic risk in their mitigation decisionmaking and assessment of property
values.
Evidence suggests that notification, notices, and public lists can and do influence beliefs
and behavior. For example, some soft-story wood frame condominium owners in
Berkeley reported difficulty refinancing (Rabinovici, 2012). Even perception of market
awareness can change opinions, even if there is little to no documented impact. In
Berkeley, some owners said the worried at first about reduced demand or market price
for units in their buildings and this motivated them to retrofit; however, these same
owners years later did not report experiencing any problems with tenant recruitment or
lost rental income (Rabinovici, 2012).
Earthquake warning signage was a prominent part of the state’s URM program
requirements; however, there is little evidence to show that such warnings are
effective. A study of California Proposition 61 carcinogen and reproductive health
warnings suggests that signs are not very powerful and become less influential on
behavior over time as people become used to them. Some building users may even be
personally annoyed by warning signs, because it reminds them of a risk that they can
personally do little about. Some owners of soft-story wood frame buildings in Berkeley
Attachment F
Seismic Risk Assessment Study December 21, 2016
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reported having tenants that actively complained about or repeatedly ripped the
required warning signs off the walls (Rabinovici, 2012).
Attachment F
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Table 4: Description of disclosure approaches used in local earthquake risk reduction programs.
Name Description Examples of Use Advantages Costs, Issues or Concerns
Mandatory Disclosure
at Time of Sale
Sellers of property are required
to disclose features that could
relate to earthquake
performance.
California Earthquake
Fault Zone disclosure;
Sellers of pre-1960
homes are required to
fill out to the best of
their knowledge and
provide buyers with
Residential
Earthquake Hazards
Report.
Empowers buyers to be
aware of any known
existing hazard issues.
Anecdotally, many buyers do
not pay enough attention to
these disclosures, which occur
during emotional, busy
decisionmaking periods. They
may not seek expert
information to interpret the
reported information. It is also
possible that sellers shirk on
the disclosure requirements if
buyers do not know that they
are supposed to receive them.
Difficult to enforce.
Recorded Notice on
Deed
Jurisdictions can record on the
property title or deed the fact
that the building is subject to
additional requirements
related to its earthquake
vulnerable status.
For soft-story wood
frame: Oakland,
Berkeley, and San
Francisco.
Relatively low cost for
jurisdictions to implement.
Empowers buyers but also
mortgage companies to be
aware of any known
existing hazard issues.
Anecdotally, it is not clear how
many buyers or mortgage
companies pay attention to
these notices. Such notices are
primarily effective only at time
of sale or refinance.
Attachment F
Table 4 (continued)
Seismic Risk Assessment Study December 21, 2016
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Name Description Examples of Use Advantages Costs, Issues or Concerns
Public Listing of
Affected Properties
Jurisdictions that operate web
sites to describe their
programs can feature a full list
of property addresses,
potentially also including also
the compliance status of the
property. In general, owner
names are not listed, though
that information is available if
a member of the public
searched for it separately.
For soft-story wood
frame: Oakland,
Berkeley, and San
Francisco.
Relatively low cost for
jurisdictions to implement.
Could be used by tenants
and buyers when
searching for properties,
thus empowering well-
informed market
negotiations over pricing.
Website information needs to
be updated on a regular basis
in order to be perceived as fair
and useful. Public lists work
better if the property
addresses are searchable,
rather than static (e.g., on a
pdf).
External Signage Jurisdictions that operate web
sites to describe their
programs can feature a full list
of property addresses,
potentially also including the
compliance status of the
property. Some lists are
searchable, while others are
static.
California state
requires a sign on all
URM buildings. Similar
signage has been
required since 2007
on soft-story wood
frame buildings in the
City of Berkeley.
Advocates argue that signs
are justified based on the
public's right to know. The
physical presence and
repeated viewing of
signage may make the
issue more salient for
visitors, employees, lease
holders, and owners alike.
Owners may view the signs as
stigmatizing or threatening to
property value or business
revenues, but anecdotally, it is
not clear how much visitors,
employees, residents, and
other users of a building pay
attention to signage when
entering or leaving a property.
Attachment F
Table 4 (continued)
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Name Description Examples of Use Advantages Costs, Issues or Concerns
Tenant Notification Owners are required to present
straightforward, standardized
information about the listed
status of the property. Some
jurisdictions require proof of
notification (e.g., tenant
signature) to be returned and
kept on file with the city.
For soft-story wood
frame: Oakland,
Berkeley, and San
Francisco.
Tenant notification may be
more influential than
signage because it is
personalized and the
information is delivered at
a useful time in that
person's decision process.
Advocates claim that
tenant notification is
justified based on the
public's right to know.
To be effective, tenant
notification should be required
to occur well before the
potential tenant is ready to
sign the lease.
Earthquake
Performance Rating
Systems
Owners can be either
encouraged or required to
have their building rated on a
standardized scale that
classifies expected building
performance in an earthquake
in an easier to understand
format, for instance from one
to five stars. Viable rating
systems exist for many building
types.
The City of Los
Angeles in 2015
officially launched a
voluntary effort to
encourage owners to
rate their properties
using the US
Resiliency Council
system and pledged to
rate its own public
buildings as well.
Rating system use is
common for institutions
like universities and
hospitals. Mechanisms for
implementing
performance ratings for
commercial use have
recently matured and are
now viable. Ratings have
the potential to inform
owner, renter and buyer
decisions, creating a
market effect.
Obtaining a rating potentially
adds cost to a design project.
Ratings systems such as USRC’s
are relatively new and not yet
widely implemented.
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An advantage of disclosure measures is they tend to be relatively inexpensive for jurisdictions
to administer. Up to date website posting of the list of affected properties and their compliance
status encourages people to visit the site as needed over time, people see signs every time they
enter or exit, and properties may exchange hands many times. Eventually, a tipping point in
community awareness and opinion about a class of properties can occur, as it did in the case of
Berkeley for soft-story wood frame buildings.
The use of positive disclosure remains an untapped potential influence on market value of
retrofitted properties as well as owners’ retrofit decisions. This review did not identify any city
programs that have taken the positive approach of recognizing or rewarding owners or
announcing buildings that have been retrofit. One recent development is the existence of viable
earthquake rating systems. In November 2015, the non-profit US Resiliency Council30 launched
a non-profit credentialing and verification service through which owners can obtain externally
checked, state-of-the-art assessment of the expected safety levels, repair costs, and time to
regain function for their property. USRC ratings have the potential to play the same kind of role
that the US Green Building Council did in promoting sustainable design, both for new
construction and for retrofits.
USRC’s system has already been adopted one California jurisdiction’s policy. Los Angeles Mayor
Eric Garcetti cited USRC ratings in that city’s Resilience by Design report (City of Los Angeles,
2015), asking building owners to voluntarily use it, pledging to educate the public about seismic
performance rating systems and how the information can be used, and announcing the
intention to use it or some similar system to rate all city-owned buildings.
Mandatory Screening
Screening programs help jurisdictions collect more information about targeted potentially
vulnerable buildings in a community, usually as a first step to later more stringent requirements
for the subset that are found to have features indicating significant deficiencies. With relatively
low cost and difficulty for owners, the jurisdiction can both make the issue visible and filter out
properties that do not meet the eligibility or targeting criteria, thereby reducing the
burdensome handling of errors and omission at a later stage. They also help jurisdictions
determine the overall scope of the problem—how many buildings exist that have certain risk
characteristics and how significant of a threat they pose in aggregate. This can help build the
case for further legislation.
30 The organization’s website is: www.usrc.org (Accessed April 13, 2016).
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For soft-story wood frame buildings, Oakland was a pioneer of the mandatory screening
approach. An inventory of multifamily apartment buildings was created in 2008 with the help of
volunteers and non-engineers under a contract with ABAG. This survey identified 24,273
residential units in 1,479 buildings with five or more units, between two and seven stories, built
prior to 1991, that had wide open spaces for parking or commercial uses on the ground floor
(ABAG, 2014). Spot testing suggested the list might have error rates that could potentially
undermine future program effectiveness, and might be politically unacceptable (personal
communication, Jeannie Perkins, 2008). Therefore, in 2009 the City passed ordinance Number
12966 which declared these buildings “potential soft-story buildings” and mandated submittal
of a Level 1 Screening–Non-Engineered Analysis. The screening had to be performed by a
registered design professional, licensed contractor or certified inspector, to provide some
assurance of accuracy regarding features that might related to risk. Anecdotally, the cost to
owners for this was generally around $200 to $500. This can be summarized as a rule-in
screening approach.
Persons involved with analyzing Oakland’s program (personal communication, Danielle
Hutchings-Mieler, 2011) concluded that many owners were confused, compliance was lower
than hoped, and exemptions may have been given without adequate quality control of the
reported data. This later contributed to the decision to incorporate mandatory evaluation
phase when the city of Oakland was ready to move towards a mandatory retrofit program. In
other words, a less than satisfactory implementation of a screening phase can slow down
progress towards and increase the effort required in future retrofit programming.
In its approach to soft-story wood frame buildings, San Francisco opted for a screening phase to
weed out obviously non-affected properties, for instance those misidentified as having the
correct number of units, stories, or first floor uses (primarily focusing on ruling out
inappropriately included properties). Similar to Oakland, the screening had to be performed by
a registered design professional, such as a licensed contractor, engineer, or architect.
Compliance in filing screening forms by the initial deadline was 98%, a success which was
helped by a suite of outreach activities including four waves of post card reminders, a retrofit
fair, a weekly updated website, an advisory group process, and multiple public meetings. The
compliance postcards used took advantage of real-time information sharing to “nudge” owners
to respond, such as mentioning how many other owners had already taken action by that point
(see Figure 6).
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Figure 6: Front and back of a compliance reminder postcard sent to affected owners in the City of San
Francisco’s soft-story wood frame program.
Mandatory Evaluation
In the 1980s, Palo Alto was an early innovator with the technique of requiring owners of certain
buildings in a community to file a formal engineering evaluation (Herman et. al., 1990). Because
a licensed engineer (or structural engineer) must perform this work, such evaluations are
approximately an order of magnitude more expensive than screenings. Evaluation costs for
soft-story wood frame buildings in Berkeley, for example, were approximately $2,000 to $5,000
(Rabinovici, 2012). However, evaluation costs may vary substantially for other building types
that are more difficult to assess, in other jurisdictions, and/or where evaluation requirements
are more extensive or complex.
Evaluation programs are costlier for jurisdictions to administrate than screening programs for a
variety of reasons, but provide several advantages. Jurisdictions typically give owners more
time to comply longer, owners need more guidance on how to comply, and there is increased
need for processing time and more qualified reviewer labor. In Berkeley, report review was
contracted out to plan checkers for a flat fee of $583 per evaluation report, and this did not
cover jurisdiction staff time.
On the benefits side, evaluations offer greater hope of achieving tangible risk reduction. As
noted, a remarkable one in four soft-story wood frame building owners voluntarily retrofit in
the wake of mandatory evaluation policy implementation in Berkeley, which meant over 2,000
of its residents now live in buildings that likely would not have been retrofitted otherwise.
Interviews with soft-story wood frame owners in Berkeley also showed that many considered
mandatory evaluation more fair than a voluntary retrofit program because it “leveled the
playing field” (Rabinovici, 2012). Rather than having retrofit practices in their community
determined ad hoc, all owners of similar properties were now being treated alike.
However, the benefits of mandatory evaluation are undeniably uncertain and dependent on
whether community circumstances are conducive to create a significant voluntary retrofit
effect (Figure 7).
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Figure 7: Graph showing a seven-fold increase in permit applications in the four years immediately
following passage of Berkeley’s 2005 mandatory evaluation law for soft-story wood frame buildings.
Mandatory Retrofit
Through California’s URM law, hospital, and school programs as well as soft-story wood frame
buildings at the local scale, there is clear precedent for imposing earthquake retrofit work to be
done for certain buildings. This is the most effective type of program for ensuring that on the
ground risk reduction will be done. As discussed in the Task 2 report, on average over four
times as many URM building cases have been retrofit in California in mandatory programs
(70%) compared to voluntary ones (16%). However, because mandatory programs require all
buildings to be addressed, owners with the most marginal properties cannot avoid taking
action, in some cases leading to higher demolition rates (Comerio, 1992). In the case of URM
buildings, mandatory retrofit programs did have higher demolition rates than voluntary
programs, 17% compared to 8% respectively (CSSC, Status of the Unreinforced Masonry
Building Law, 2006).
Depending on the program timeline, it may take years to decades for tangible risk reduction to
be realized. Retrofit projects naturally occur in steps, and can only be carried out as quickly as
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financing, contracting, any tenant relocation, or construction logistics allow. Thus, compliance
periods for mandatory retrofit programs need to be longer than for mandatory screening or
evaluation programs. For URM buildings, many jurisdictions tended to set deadlines of ten
years or more, followed by generous extensions. For soft-story wood frame programs,
jurisdictions have given owners one to three years for first steps such as appeals, hiring an
engineer, complete an acceptable engineering report, or submit a permit application and
retrofit plan. Following that, owners are typically given another one to three years to complete
construction (see Table 3), in part to secure financing, time to work around planned vacancies,
and for adequate design. Longer timelines or exemptions can be offered for complex buildings
that may require costlier or innovative engineering solutions (for instance, historic properties).
Again, this is where phasing or tiers can be helpful.
Another difficult aspect of retrofit programs (even voluntary ones) is that jurisdictions need to
set specific expectations for what constitutes an acceptable retrofit. Jurisdictions have handled
this in a variety of ways. Retrofit ordinances typically directly reference one or more particular
standards (or equivalent criteria). The table of soft-story wood frame programs (Table 3) shows
that five or more standards have been referenced recently and several jurisdictions reference
more than one, which can increase compliance ambiguity and the level of reviewer skill
required but also an engineer’s discretion to use the one most appropriate for their client’s
situation.
Also at issue is how much and how far a building’s vulnerabilities should be retrofit. For
instance, in the case of soft-story wood frame buildings, a retrofit can be designed to address
only the first story weaknesses, rather than all seismic vulnerabilities that are identified.
Jurisdictions such as San Francisco and Berkeley have chosen this route, in part because it
lessened political resistance to creating a mandate and addressed the most severe deficiencies.
Other deficiencies above the first story may remain and may lead to damage in an earthquake.
In the case of mandatory evaluation or retrofit programs, owners and their engineers will also
need guidance about how to prepare an acceptable evaluation, and how to submit a
concurrent retrofit permit application. Owners in Berkeley realized a major financial advantage
to paying their engineer to do both an evaluation for the jurisdiction and a full set of retrofit
plans at the same time (Rabinovici, 2012), so having clear retrofit standards in place already
was a major boon to those owners.
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The potentially negative effects on public safety and on owners of choosing a longer
compliance timeline should be noted. Earthquakes can occur at any time, so a program that
offers longer compliance windows in effect allows people in the community to spend more
time using and owning buildings that the jurisdiction has deemed unacceptable in the long run.
Also, real liability consequences may exist for owners that delay in doing mandated retrofit
work, even before an accepted compliance window has elapsed. A California Appellate court
awarded $2 million to family members of two women who died in a URM collapse in the 2003
San Simeon earthquake.31 In doing so, the court rejected the defendant’s claim that they had
no duty to retrofit the building until 2018, the deadline established by the San Louis Obispo
mandatory retrofit ordinance.
Incentives
To complement any of the above program formats, jurisdictions can offer either financing- or policy-
oriented incentives. Many ways exist to encourage and ease the path for owners to complete either
voluntary or required retrofit work, or even to help them submit timely screening forms or engineering
reports. Financial incentives and tools provide monetary assistance, either directly to an owner or via
the jurisdiction. Financial incentives include measures such as tax credits, tax rebates, grants, or fee
waivers that make a retrofit less expensive to complete. Financial tools (e.g., special low-interest
financing programs) provide a mechanism for an owner to obtain the necessary funding, potentially at
lower cost or paid back in ways other than for a traditional loan. Policy incentives are meant to
encourage private funding of mitigation, and include for example expedited review, exemptions,
development bonuses, or technical assistance. These measures offer owners indirect but potentially
valuable benefits as they take each mitigation steps.
Figure 8 provides a summary list of potential incentive types, while Appendix C gives details about
example uses, advantages, and disadvantages of each.
A group of agencies completed an inventory of jurisdiction incentive strategies using a survey of
California local governments in the mid-90s (ABAG, Seismic Retrofit Incentive Programs: A Handbook
for Local Governments, 1996). Though outdated and only 35% of contacted jurisdictions participated,
the report summarizes the types of URM and other earthquake programs that different jurisdictions
adopted and the kinds of assistance that owners could receive. The researchers also did interviews to
collect detailed information about fifteen illustrative cases at the time, including Palo Alto.
31See press coverage: http://calcoastnews.com/2010/06/court-finds-paso-robles-business-owners-liable-for-earthquake-
deaths/ Accessed April 13, 2016.
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FINANCIAL TOOLS AND INCENTIVES
(mechanisms that make financing
more accessible or directly reduce
project costs)
POLICY INCENTIVES
(mechanisms that deliver indirect
benefits to owners)
CO
S
T
A
N
D
I
M
P
L
E
M
E
N
T
A
T
I
O
N
D
I
F
F
I
C
U
L
T
Y
Hi
g
h
e
r
L
o
w
e
r
Waivers or Reductions of Building
Department Fees
Exemption from Future Retrofit
Requirements
Pass Through of Retrofit Costs to
Tenants (for jurisdictions with rent
control)
Expedited Permits, Inspections, and
Reviews
Property-Assessed Financing Loans
(PACE)
Exemptions or Relief from Standards
or Non-Conforming Conditions
Subsidized or Special Term Loans Condominium Conversion Assistance
Real Estate Transfer Tax Rebates Technical Assistance for Retrofit
Projects
Special District or Historic Designation
Tax Reductions
Zoning Incentives (e.g., relief from use
restrictions)
Tax Credits Transfer of Development Rights (TDR)
Grants Density or Intensity Bonuses (e.g.,
Floor Area Bonus)
General Obligation or Special Purpose
Bonds
Figure 8: Types of financial incentives and tools as well as policy incentives that have been used in local
earthquake risk reduction programs in California, in approximate order top to bottom from lowest to
highest cost and difficulty of implementation.
Several points stand out in the ABAG report regarding incentive use and effectiveness. First, most
jurisdictions offer a number of different incentives, rather than just one approach. This makes sense
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because building and owner circumstances vary widely; what may help one owner might be irrelevant
or inappropriate for another and vice versa. Second, jurisdictions have taken widely different
approaches with incentives, from offering almost nothing to offering substantial loans and grants.
Jurisdictions tend to come up with incentive offerings closely tailored to their own goals and
circumstances, based on economic conditions, building stock vulnerabilities, political will, and other
factors. As a result, there is no single best incentive package to offer.
Another key point is that creation and operation of incentive programs is intense and must be locally
customized. Extensive community education and involvement are required to assess needs, design and
advertise the incentive offerings, and to help owners take advantage of them. Guiding community
members through the mitigation process is time consuming and difficult, usually requiring at least one
full time staff member who also has to coordinate with staff across several departments. That means
the personalities, technical skills, and political savvy of the internal team will be critical, and likely
variable over time, due to natural staff and political turnover issues.
The effectiveness of different incentive approaches, individually or in packages, has not been
systematically studied. Both ABAG and the San Francisco CAPSS project have produced high level lists
of potential incentive tools (ABAG, 2014; Samant & Tobin, 2008) but do not specify which tools are
being used where and to what effect. Many listed approaches are rarely or no longer being used. All
the variety makes it difficult to draw overall conclusions as to which incentives have worked “best”
where and why.
3. IMPLICATIONS AND POTENTIAL POLICY DIRECTIONS FOR PALO ALTO
Palo Alto is a medium sized, compact city with a diverse population and vibrant local economy. Nested
in the heart of Silicon Valley, the cost of living and development pressures are high, and space for
growth is limited. A high degree of interconnectedness with surrounding communities and a dynamic
natural environment is also evident.
As a community, Palo Alto cannot ignore its proximity to several major faults and the fact that it has
many different vulnerable building types. The estimated losses in a major event are significant.
Fortunately, Palo Alto has a legacy of proactive policy leadership in addressing earthquake risks, and a
relatively high degree of citizen and local government capacity. The potential benefits from retrofitting
are large. City leaders, by investing this year in risk assessment and a policy development dialog, have
demonstrated their capability and will to act.
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This review found no simple best local earthquake mitigation policy model for Palo Alto to follow. Each
of the jurisdictions mentioned in this report has crafted, often over a decade or more, a unique
package of measures suited to their own local economic, social, political, and risk realities. Palo Alto
must do the same.
In developing its own strategy, Palo Alto can learn from this variety among local mitigation programs. It
can build on the successful framework of its own existing program while also combining and tailoring
new elements that are working for other jurisdictions.
Choosing Goals and Desired Outcomes
One way to measure success is in relation to program goals and resource realities. From that
standpoint, each of the programs mentioned in this report is successful to some degree.
Some jurisdictions set out to do what they could with limited resources, progressing only the first steps
of developing an earthquake mitigation program. The City of Richmond, for example, developed an
inventory, hosted a community meeting, and notified owners as part of creating a very low cost
voluntary approach to soft-story wood frame buildings. The good news is that by doing so, it achieved
meaningful progress relative to jurisdictions that have done nothing. Public leaders and the broader
community are more aware, city reputation and visibility have been enhanced, and city staff are now
better connected to a network of local earthquake professionals that can help facilitate future action if
and when that becomes possible. The bad news is that Richmond has been stymied so far by the
departure of key staff, limited jurisdictional resources, and the limited resources of its soft-story wood
frame building owners and tenants; a more aggressive retrofit program is not realistic until an outside
source of funding is found.
At the other extreme, a few leading jurisdictions set out to comprehensively assess earthquake
vulnerabilities and risk reduction opportunities community-wide through a lengthy, relatively
expensive, and collaboratively-informed processes. San Francisco and more recently Los Angeles are
the most prominent users of this approach, producing in-depth reports and resilience plans intended
to guide city efforts for decades. Importantly, these plans encompass many city activities and roles,
types of buildings and building uses, different phases of the disaster cycle, and explicitly seek to
connect earthquake mitigation efforts to a host of other community resilience concerns, from sea level
rise to water supply reliability to telecommunications operations (Several leading local program models
and planning resources for these types of efforts are introduced in Appendix D).
In between are jurisdictions where program goals are either narrower in scope with more vigorous
requirements (such as the City of Fremont’s mandatory retrofit program for soft-stories) or wider
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scope with less vigorous requirements (such as the City of Santa Monica, which mandates retrofits for
soft-story wood frame buildings and nonductile older concrete structures but only when triggered by a
substantial renovation).
The City of Berkeley took a phased, relatively aggressive approach to soft-stories, but has yet to put in
place a program to address the 50 or so tilt-up concrete structures it has identified. Oakland is also
somewhat unique in being a larger city that has mandated soft-story retrofits without initially taking a
comprehensive approach. However, both Berkeley and Oakland benefited first from substantial
volunteer professional involvement and later from sizeable, multi-year Rockefeller Foundation 100
Resilient Cities grants. Through the early help of both volunteers and consultants, Berkeley and
Oakland laid the groundwork for mandatory programs that likely helped to attract the additional
philanthropic attention and assistance. Berkeley has now produced, and Oakland is on its way to
producing, a comprehensive resilience assessment and plan similar to what was done by San Francisco
and Los Angeles.
In this light, Palo Alto is currently in the “middle” group in terms of its scope and requirements for
seismic safety compared to other leading jurisdictions. Palo Alto set new policy precedents in the
1980s with its community engagement, mandatory evaluation, and voluntary retrofit programs for
three different categories of structures. However, this only addressed a small subset of its overall
vulnerable building stock. By investing in data collection and community discussions this year, Palo Alto
is now poised to move forward into a new position of seismic policy leadership.
It is critical to first clarify community values and goals before designing a program to try to achieve
them. All stakeholders should be invited to participate in discussions of what matters most to the City
and the people who live, work, and invest in it. Common broad goals include increased public safety,
reduced private property damage, and reduced downtime and displacement of businesses, consumers,
and residents. However, addressing of different building types may advance these goals to different
degrees and with different levels of certainty and speed. For instance, addressing soft-story wood
frame housing may have little direct benefit for local businesses but would reduce renter
displacement. Retrofit of older concrete structures might address concerns about provision of basic
services after an event, but would have little or no benefit for housing.
If the goal is to achieve the greatest reduction in losses, Palo Alto should address building types known
to be potentially hazardous that occur in large numbers. Once community discussions lead to a sense
of priorities and preferences, trade-offs and alternatives for pursuing each goal can be understood and
considered.
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Wherever Palo Alto chooses to focus, it should strategically combine policy features to promote risk
reduction. As this report revealed, regardless of scope, the most effective programs use a package of
measures to tip the balance away from the status quo by publicizing and increasing the consequences
of not retrofitting while also publicizing, easing the costs, and increasing the benefits of retrofitting.
Potential Policy Directions
Coming out of this local program review is a list of alternative approaches for Palo Alto to consider:
Option 1: Status Quo
In this option, the existing ordinance with its mandatory evaluation, voluntary retrofit approach
remains in place without changes. This covers 89 buildings and has three categories: Category I—
unreinforced masonry (except for under 1,900 sf with 6 residents), Category II—built before 1/1/1935
with 100 or more occupants, and Category III—built before 8/1/1976 with 300 or more occupants. As
of 12/9/14, City records indicated that sixty-six of the buildings had been either retrofit, demolished,
planned to be demolished, or found exempt, while 23 remained unaddressed. Evaluation was
mandatory, and owner funded but retrofit is voluntary. The list is publically available by request, but
not advertised. Floor area ratio bonuses are (were) available.
Option 2: Increase Scope, but Retrofit Remains Voluntary
Additional categories of structures would be added to the mandatory evaluation requirements. Palo
Alto can consider programs for soft-story wood frame buildings, older concrete buildings, older tilt-up
buildings, and older steel moment frame buildings. Precedents exist for programs addressing each of
these structural types that pose well-identified, publicly important risks. Completion of an evaluation
report could be separated into different timelines, for instance three to ten years, depending on
degree of hazard. Palo Alto could also use location, occupancy type, and/or number of occupants as
criteria in defining the scope or compliance timelines.
Option 3: Similar to Option 2, but Additional Disclosure Measures are Incorporated
This option would be similar to Option 2, but the list of buildings and status could be prominently
posted on City website, tenants could be notified, signage could be required, and/or a recorded notice
could be added to the property title. These options enhance transparency with the public and reward
owners that retrofit by increasing the perceived benefits of retrofitting among potential tenants and
buyers. Relatively inexpensive measures like these have been shown to be effective in increasing public
awareness and motivating greater consideration of earthquake risk in private decisionmaking,
including voluntary retrofits.
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Option 4: Increase Scope, Some Categories are Voluntary and a Few Categories are Mandatory, with
Enforcement by Trigger Threshold
This option builds on Option 3, but retrofitting would be required for some building types at whenever
future time a building is sold or undergoes substantial renovation above a set threshold.
Option 5: Increase Scope, Some Categories are Voluntary and a Few Categories are Mandatory, with
Enforcement by a Fixed Timeline
This option would be similar to Option 4, but retrofitting is required according to a fixed timeline.
Timelines and enforcement emphasis could vary depending on tiers or priority groupings to motivate
prompt action for the most vulnerable or socially important structures. In some cases, longer time
frames are adopted for some building types such as older concrete, to ease the burden on owners and
allow for technical advancement in retrofit techniques.
Option 6: Similar to Option 5, but More Categories are Mandatory
This alternative is similar to Option 5, but retrofitting would be required for additional categories. Palo
Alto can also make its programs more stringent over time. Explicit phasing has been successful in
jurisdictions like Berkeley and San Francisco for generating political consensus and enhancing
administrative feasibility.
This array of options can be also be shown in diagram format (Figure 9), which shows how a number of
jurisdictions in this report have positioned themselves in terms of the relative strength of their
requirements and the number and scope of the building types addressed.
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Figure 9: Diagram showing alternative policy directions for Palo Alto in the context of other jurisdictional
earthquake mitigation programs.
When considering options, Palo Also leaders and community members should keep in mind the
following additional findings from this review:
Mandating retrofit is the surest way to achieve risk reduction.
Jurisdictions are increasingly using disclosure measures to motivate retrofits in both voluntary
and mandatory programs, and such approaches have been shown to be powerful and relatively
low cost to implement.
Many mandatory programs use intermediate mandatory screening and/or evaluation phases to
better gauge the risk and filter out properties that need not comply before implementing
retrofit requirements.
Fixed timelines allow a jurisdiction to prioritize and control the pace of risk reduction, provide a
predictable planning horizon for owners.
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Incentive Options and Considerations
By offering a strategic set of incentives and devoting a steady, adequate program budget, Palo Alto can
create a program that eases the financial and logistical burdens on owners and provides adequate
technical assistance to support retrofit project completion. Small incentives are meaningful and helpful
to owners, while larger incentives may be critical for a subset of owners that face particularly complex
or costly projects.
Palo Alto has several traits that could make policy incentives (non-monetary assistance) particularly
effective. One is a relatively manageable number of affected buildings for some building types. This
means city staff might be able to provide high quality assistance to owners in complying and taking
advantage of any special programs. Palo Alto is a highly desirable locale with a highly educated, real
estate savvy population, and robust real estate market. Palo Alto has experience using policy incentives
in the past, so staff and many owners are familiar with them.
Despite limited data on their use or effectiveness, incentives can be politically important and provide a
variety of benefits. Below are some specific ways incentives could play a role in Palo Alto’s future
program and some steps that Palo Alto can take to create a package of incentives effectively tailored to
its own goals and circumstances.
It is good to offer small incentives to all owners because it fosters positive interest in the
program and builds community good will. Modest incentives, on the order of a few
hundred dollars, help acknowledge the public value that is being created by the efforts
undertaken by owners. For example, offering fee waivers is a gesture that owners will
appreciate, if not expect. Expedited permitting is likely to be viewed similarly, because time
equates with money. Policy incentives tend to be in the direct control of the City to
implement, and are often cost-effective and very helpful for owners in smoothing the path
and easing the hassle of doing retrofit work.
Incentives are especially important to the outcomes of voluntary programs. Incentives
play slightly different roles in mandatory compared to voluntary programs. In the case of
mandated upgrades, incentives essentially ease the burden of doing what has to be done or
to make it happen more quickly. In the case of, voluntary programs, the goal of incentives is
to motivate retrofit work to occur that might not have otherwise. In this way, incentive
offerings are more critical to the degree of risk reduction achieved in the case of voluntary
programs, and to political viability, perceptions of program fairness, and speed of risk
reduction achieved in the case of mandatory programs. Bottom line, in the case of URMs, a
small number of voluntary programs with substantial incentives have achieved similar
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success compared to mandatory programs. With soft-story wood frame buildings, voluntary
programs in the absence of incentives alone have not been enough to motivate retrofit
work to be done. An exception is for owners in financial hardship, where incentives are
most meaningful in mandatory programs.
Design the incentive strategy to match the circumstances of the locally targeted building
stock. FAR bonuses are likely irrelevant for soft-story wood frame buildings which are
seldom renovated to include more units or changes of use, but relaxing of parking
requirements or special provisions for condominiums may help. Mixed-used and historic
buildings may require deeper financial assistance when they face high costs associated with
retrofitting due to complex design issues, ADA compliance, and imposed restrictions on
changes in use.
Take time to assess actual need for incentives and the types that will make the most
difference to affected Palo Alto owners. Larger policy incentives like FAR bonuses can be
very effective, especially in higher income, higher growth communities like Palo Alto. In
contrast, larger financial incentives can be difficult to orchestrate and have not always been
as necessary or useful as hoped. Surprisingly, jurisdictions have sometimes found they have
to “sell” incentives programs to owners. Certain strategies tend to be very challenging and
costly to get the incentive to work compared to the amount of good they seem to do. Such
may be the case with PACE financing,32 as seen through the experiences of San Francisco
and Berkeley for soft-story wood frame buildings. When private market capital is
affordable, loan programs may not be needed or utilized. Use of larger, more complex
incentive instruments in general increases the amount of hand holding that is needed and
the amount of time until retrofits are completed.
Consider offering larger incentives to only those owners or properties that qualify or meet
certain social importance or hardship criteria. Interviews in Berkeley (Rabinovici 2012)
showed that soft-story wood frame building owners were open to the possibility of need-
based financial help. They did not want financing programs to reward ignorance or risky
business practices, but as long as the criteria are clear and the process is fair and
transparent, many expressed support for programs that would help fellow owners that are
truly burdened or in need. There was also support for using social or resilience importance
as part of the criteria for special financing eligibility.
32 Information about San Francisco’s PACE program can be found at: http://www.sfgov.org/esip/seismic-retrofit-financing
Accessed April 11, 2016. Information about Berkeley’s PACE programs can be found at: http://www.ci.berkeley.ca.us/PACE/
(Accessed May 2, 2016.)
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Integrate incentives as seamlessly as possible into the overall compliance process.
Incentives work best when they are delivered in a timely way, right when people are already
making important property or financial decisions. One notable example is the City of
Berkeley’s transfer tax rebate for single family home seismic improvements, which is
available retroactively two years before through two years after time of sale. Another is
Palo Alto’s floor area ratio (FAR) bonus for retrofit of designated vulnerable structures,
which allowed owners the chance to plan in additional space at the same time a retrofit is
being designed.
Beyond money, it will be important to offer technical assistance, and this can be very
helpful and even critical for some owners and engineers. Retrofitting is not a simple
process, and ironically it can become even harder for an owner if it happens as part of a
jurisdictional program that requires or is intended to encourage it. Obtaining financing,
especially through special programs, may also require intense staff effort.
Beware of the timing and costs of seeking public support for new bond financing. In
Berkeley, attempts were made to make a pool of funds available to owners through a
transfer tax increase measure on the November 2002 ballot, but it failed to get the required
two thirds vote. Participants in retrospect considered the campaign poorly run, but the
state of the local economy probably played more of a role than any decrease in support for
mandatory retrofit in concept.
Consider creation of formal cost-sharing arrangements between tenants and owners. Part
of the financial equation surrounding any upgrade work is the owner’s ability to capitalize
on the value added to the structure. In the case of rent control, the rate for pass through of
capital improvements is a matter of law. Jurisdictions like Oakland, Berkeley, and San
Francisco have negotiated cost-sharing arrangements ranging from 50 to 100% that allow
owners to increase rents up to a certain percent of the retrofit cost, over a specified time
period (usually 10 years). Even though Palo Alto does not have a rent control ordinance, it
could establish a permitted amortization schedule into any new retrofit law, which could
lessen the impact for tenants of any resulting rent increases.
Disclosure Measure Options
With relatively modest expense for a jurisdiction, disclosure measures can inform the populace and
leverage social and market awareness to amplify program effectiveness. In effect, signage, tenant
notification, internet lists, and other disclosure tactics make more transparent both useful risk
information and the policies a city is using to address risk.
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Public perception of disclosure policies has been on balance positive but not without critique. On the
one hand, revealing property addresses that are subject to an ordinance can be thought of as making
more accessible information that is already public. It spares all parties of going through the time and
hassle of formal information requests. It is also consistent with a philosophy of the public’s right to
know, and may be legally protective for both owners and jurisdictions against accusations that
important risk information is being held back. On the other hand, the media has at times portrayed
signage as a shaming device, though this may depend on a sign or placard’s particular graphic design
and wording. Soft-story wood frame owners in Berkeley described the overall suite of disclosure
measures imposed there as a “scarlet letter.”
San Francisco included disclosure practices as part of its first “nudging” phase in their program plan. In
essence, before and in complement to implementing mandates, San Francisco’s plan called for trying
to increase understanding in the real estate market empower tenants, buyers, and even owners (who
could now more credibly and prominently claim credit for early compliance, retrofitting ahead of
schedule, or voluntarily taking extra steps).
Evidence about the effectiveness of disclosure, either together with other policy requirements or
separately, is quite limited. In at least one case, voluntary retrofit programs combined with disclosure
measures have achieved significant risk reduction. Berkeley’s mandatory soft-story evaluation program
had several prominent disclosure features and resulted in a 25% voluntary retrofit rate in the first four
years (Rabinovici, 2012).
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4. REFERENCES AND RESOURCES
ABAG. (1996). Seismic Retrofit Incentive Programs: A Handbook for Local Governments.
ABAG. (1999). Preventing the Nightmare. Oakland, CA.
ABAG. (2014). Soft-Story Housing Improvement Plan for the Cit of Oakland. Oakland. Retrieved from
http://resilience.abag.ca.gov/wp-content/documents/OaklandSoftStoryReport_102914.pdf
ATC. (2010). Here Today—Here Tomorrow: The Road to Earthquake Resilience in San Francisco. Community
Action Plan for Seismic Safety, Redwood City. Retrieved from
http://sfgov.org/esip/sites/default/files/FileCenter/Documents/9757-atc522.pdf
ATC. (2012). ATC 78-1: Evaluation of the Methodology to Select and Prioritize Collapse Indicators in Older
Concrete Buildings. Redwood City, CA.
Bonowitz, D. (2012). Soft-Story Risk Reduction: Lessons from the Berkeley Data. EERI, Oakland, CA.
Bonowitz, D., & Rabinovici, S. (2012). Soft-Story Risk Reduction: Lessons from the Berkeley Data. EERI, Oakland,
CA.
Chakos, A. P. (2002). Making It Work in Berkeley: Investing in Community Sustainability. Natural Hazards Review,
3(2), 55-67.
City of Los Angeles. (2015). Resilience by Design. Los Angeles.
Comerio, M. (1992). Impacts of the Los Angeles Retrofit Ordinance on Residential Buildings. Earthquake Spectra,
8(1), 9-94.
Concrete Coalition. (2011). The Concrete Coalition and the California Inventory Project: An Estimate of the
Number of Pre-1980 Concrete Buildings in the State.
CSSC. (2005). Homeowner’s Guide to Earthquake Safety . Sacramento, CA.
CSSC. (2006). Status of the Unreinforced Masonry Building Law. California Seismic Safety Commission,
Sacramento.
FEMA. (2009). Unreinforced Masonry Buildings and Earthquakes: Developing Successful Risk Reduction
Programs.
Herman, F., Russell, J., Scott, S., & Sharpe, R. (1990). Earthquake Hazard Identification and Voluntary Mitigation:
Palo Alto's City Ordinance. California Seismic Safety Commission 90-05, Sacramento, CA.
NIST. (2015). Community Resilience Planning Guide Volume 1. National Institute of Building Sciences. Retrieved
from http://www.nist.gov/el/resilience/upload/NIST-SP-1190v1.pdf
Olson, R. S. (1999). Some Buildings Just Can't Dance: Politics, Life Safety, and Disaster. Stamford, CN : Jai Press
Inc.
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Rabinovici, S. (2012). Motivating Private Behavior with Public Programs: Insights from a Local Earthquake
Mitigation Ordinance. Berkeley, CA: University of California Berkeley.
Samant, L., & Tobin, T. (2008). Memo to the Advisory Committee on Incentives to Encourage Seismic Retrofits:
Options for San Francisco”. San Francisco, CA. 5 Sept. 2008. San Francisco, CA: Community Action Plan
for Seismic Safety.
SF ESIP. (2011). Community Action Plan for Seismic Safety, San Francisco Earthquake Implementation Plan (ESIP)
Workplan 2012-2042. San Francisco, CA.
SPUR. (2008). The Resilient City: Defining What San Francisco Needs from Its Urban Resilience Strategy. San
Francisco, CA.
SPUR. (2011). Safe Enough to Stay: What will it take for San Franciscans to live safely in their homes after an
earthquake? San Francisco, CA.
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CHAPTER IV.
BUILDING INVENTORY FOR LOSS ESTIMATE
One of the first steps in the study was to develop a digital inventory of buildings in Palo Alto that
includes all the information necessary to build the exposure model for the loss estimate. Information
sources used to develop the inventory included county tax assessor files, City GIS files, a survey done
by the Palo Alto Fire Department and San Jose State University of soft-story wood frame buildings, field
notes from the building department files of selected buildings when the 1986 ordinance was being
developed, Google Earth and Street View visual reviews, and an extensive sidewalk survey.
The Santa Clara County tax assessor’s files, which included 21,187 parcels of real estate in the City of
Palo Alto, were used as a starting point to develop the building inventory. The 15,198 parcels
designated as single family or two-family residences were first removed, as these were excluded from
the study, leaving 5,989 parcels of interest. A parcel is not always equivalent to a building. On one
hand, there are some sites where there is one owner and one tax parcel, but there are multiple
buildings. Sometimes, it is easy to distinguish the separate buildings from an application like Google
Earth or Street View as there is sufficient separation between the structures; in other cases, a field
survey is needed when the seismic separation is small (or not present). On the other hand,
condominiums can be a single structure, but have multiple owners and thus multiple separate
taxpayers and parcel numbers. For the 3,630 residential parcels with three or more units, we found
1,324 distinct buildings. Of the remaining 5,989 – 3,630 = 2,359 tax parcels, we found that 961 tax
parcels were identified as “possessory interest.” They are used at the city-owned Palo Alto airport for
administration of property taxes for concessionaires and for other purposes at other locations in the
city, and they do not represent buildings. When they were removed, there were 1,398 non-residential
buildings. They were combined with the 1,324 residential buildings for a total of 2,722 buildings.
The assessor’s data typically included parcel number (APN), year built, occupancy type, square footage,
and number of stories. These data were supplemented with ArcGIS shape files of building and parcel
outline from City GIS files, providing the geospatial location of each parcel (by latitude/longitude).
In addition to this information, the exposure model requires basic data on structural system needed to
classify each building into a Hazus Model Building Type. For some buildings, this information was
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available from earlier inventory efforts, including a select set of inventory forms used in developing the
current seismic mitigation program, and a survey by SJSU and the City’s Fire Department of soft-story
wood frame buildings. However, for many buildings no structural system could be assigned based on
available records.
The field survey was used to assign the seismic force-resisting system (using the basic FEMA Model
Building Type classification system), and to confirm and supplement information acquired from the
digital files for number of stories, occupancy (using the Hazus occupancy categories), building area, and
year built. In addition, buildings were surveyed for vertical and plan irregularities.
After the sidewalk surveys and additional quality assurance refinements, we identified a total of 2,632
buildings in the study group for Palo Alto. This included 66 buildings subject to Palo Alto’s current
seismic mitigation ordinance, because 23 of the original 89 buildings subject to the ordinance have
been demolished.
Not all buildings were field surveyed and not all key attributes needed for loss estimation were
available for all buildings. For buildings that were not surveyed and were missing information, the
missing attributes were developed using statistical comparisons with buildings that were surveyed on a
sector by sector basis. A multi-step procedure was developed to fill in other missing attributes based
on the best available comparative information. For example, buildings with missing occupancy and
number of stories were assigned occupancies and number of stories with the same distribution of
occupancies for surveyed buildings in that sector. For buildings with missing square footage data, the
median values in the sector for residential and non-residential buildings were used. In assigning
missing seismic force-resisting system information and year built, some rules were applied based on
typical building practices. As a result, while the information for buildings that were not surveyed may
not be fully accurate at the individual building level, the overall data set is seen as sufficiently
representative for the type of loss estimates used in the project and relative comparisons made
between different building types that are discussed ahead.
In addition to the information discussed above, a replacement cost had to be established for each
building. Standard 2014 RS Means Replacement Cost values included in the loss estimation software
(Hazus) used were reviewed as a starting point, but not considered representative for Palo Alto. R+C
and Vanir Construction Management prepared adjustments to RS Means values to capture 2016 data
and local factors. These were reviewed by a task group of the City’s project Advisory Group that
included local design professionals and developers familiar with the local cost climate. The group
recommended an increase of the values in general, and identified target values for selected common
occupancies. Based on these recommendations, R+C updated the values and Vanir reviewed them and
revised the non-targeted occupancies for estimating consistency. The resulting replacement costs are
shown in Table 5, and were used in the loss calculations. It is noted that resulting costs are 1.7-2.6
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times the RS Means-based Hazus default values (2014 cost data), and that costs are intended to be
representative of averages across the town.
Table 5: Average $/SF replacement building cost by Hazus occupancy class.
Occupancy Class RS
Means
2014
Average
Palo
Alto
Cost1
[$/SF]
Market
Factor
for
Palo
Alto
Escalation
Factor
from 2014
costs to
2016 costs
Demo &
Minimal
Sitework
(5’
around
building)
[$/SF]
Soft Cost
Premium2
Average
2016
Palo
Alto
Cost w/
Soft
Costs
[$/SF]
Multiplier
(Replaced
with Soft
Costs / RS
Means)
Multi Family, duplex $130.75 40% 10% $17.50 20% $263 2.01
Multi Family,
triplex/quad
$114.94 40% 10% $17.50 20% $233 2.03
Multi Family, 5-9 units $206.41 40% 10% $17.50 20% $402 1.95
Multi Family, 10-19
units
$194.12 40% 10% $17.50 20% $380 1.96
Multi Family, 20-49
units
$212.26 40% 10% $17.50 20% $413 1.95
Multi Family, 50+ units $199.90 40% 10% $17.50 20% $390 1.95
Temporary Lodging $217.83 40% 10% $17.50 20% $424 1.94
Institutional Dormitory $234.44 50% 14% $25.00 20% $511 2.18
Nursing Homes $238.07 50% 12% $25.00 20% $510 2.14
Retail Trade $121.66 80% 10% $17.50 20% $310 2.55
Wholesale Trade $118.13 60% 10% $17.50 20% $$270 2.29
Personal & Repair
Services
$143.47 60% 10% $17.50 20% $324 2.26
Professional/Technical/
Business Services
$194.52 65% 12% $17.50 20% $452 2.33
Banks $281.88 40% 12% $25.00 20% $560 1.99
Hospitals $372.59 50% 14% $35.00 20% $807 2.16
Medical Office/Clinics $267.85 20% 10% $17.50 20% $445 1.66
Entertainment/Recreation $248.61 25% 12% $25.00 20% $448 1.80
Theaters $186.45 35% 12% $25.00 20% $368 1.98
Parking $84.59 20% 10% $17.50 20% $155 1.83
Heavy $144.71 25% 10% $17.50 20% $260 1.80
Light $118.13 25% 10% $17.50 20% $216 1.83
Food/Drugs/Chemicals $229.48 30% 12% $17.50 20% $422 1.84
Metal/Minerals
Processing
$229.48 30% 12% $17.50 20% $422 1.84
High Technology $229.48 40% 14% $17.50 20% $461 2.01
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Table 5: Average $/SF replacement building cost by Hazus occupancy class.
Occupancy Class RS
Means
2014
Average
Palo
Alto
Cost1
[$/SF]
Market
Factor
for
Palo
Alto
Escalation
Factor
from 2014
costs to
2016 costs
Demo &
Minimal
Sitework
(5’
around
building)
[$/SF]
Soft Cost
Premium2
Average
2016
Palo
Alto
Cost w/
Soft
Costs
[$/SF]
Multiplier
(Replaced
with Soft
Costs / RS
Means)
Construction $118.13 30% 10% $17.50 20% $224 1.89
Church $118.13 50% 12% $25.00 20% $268 2.27
Agriculture $199.08 10% 12% $17.50 20% $315 1.58
General Services $152.63 40% 10% $17.50 35% $341 2.23
Emergency Response $259.52 40% 14% $25.00 35% $593 2.28
Schools/Libraries $193.00 40% 12% $25.00 35% $442 2.29
Colleges/Universities $214.91 60% 12% $25.00 35% $554 2.58
Notes:
1. RS Means average cost includes RS Means default location factors to adjust national average to Palo Alto of 15%
for residential and 11% for commercial.
2. Soft costs include architect and engineer design fees, testing and inspection, utility connection fee, permits, and an
allowance for owner change order contingency.
3. Costs are intended to be representative of average in Palo Alto across the town, including downtown areas together
with other areas in the city.
4. Costs were previously prepared following a 3/7/2016 discussion with the Palo Alto Seismic Risk Program Advisory
Group Technical Advisory Committee. Table includes minor updates based on internal review between Rutherford
+ Chekene and Vanir Construction Management to achieve improved relative ratios between different occupancy
types.
Table 6 shows how the number and aggregate value of Palo Alto’s buildings is distributed by structural
system, using the FEMA Model Building Type classification system for structural system. The table is
sorted by aggregate building value. Wood frame buildings make up about 60% of the number of
buildings, and represent 35% of the total value. About 20% of the buildings are concrete, and they
represent over 40% of the total value. Of the remaining 20%, about two-thirds are masonry buildings,
and one-third steel. However, the steel buildings represent about twice the value of the masonry
buildings.
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Table 6: Distribution of number of buildings, building area, and building value by Model Building
Type.
Model Building Type Number of
Buildings
Aggregate Square
Feet (1,000)
Aggregate Building
Value ($M)
Concrete shear wall (C2) 318 9,699 4,082
Concrete tilt-up (PC1) 242 8,054 3,368
Wood frame larger residential (W1A) 331 8,403 3,232
Wood frame commercial/industrial (W2) 307 6,209 2,369
Steel braced frame (S2) 50 3,116 1,391
Wood frame smaller residential (W1) 898 3,821 1,278
Steel moment frame (S1) 75 3,005 1,242
Reinforced masonry, wood floor (RM1) 285 2,806 1,209
Reinforced masonry, concrete floor (RM2) 30 574 211
Steel light metal frame (S3) 41 533 177
Precast concrete frame (PC2) 5 334 125
Concrete moment frame (C1) 18 325 117
Steel frame with concrete shear walls (S4) 13 162 72
Unreinforced masonry bearing wall (URM) 9 274 15
Concrete with masonry infill (C3) 8 26 8
Steel frame with masonry infill (S5) 2 6 3
Totals 2,632 47,346 18,899
The study group can be further divided into age groups separated by significant milestones in building
code implementation. The following age groups were selected: pre-1927, 1927-1961, 1962-1976, 1977-
1997, and 1998 until now. The milestones reflected include the first earthquake code in Palo Alto in
1926, adoption of the 1961 Uniform Building Code (UBC) and associated higher forces, code changes in
the 1976 UBC following the 1971 San Fernando Earthquake, and code changes in the 1998 UBC
following the 1994 Northridge Earthquake. Figure 10 shows a histogram of the year built of the
buildings in the study group.
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Figure 10: Distribution of year built of buildings in study group with significant changes in the building
design practice.
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CHAPTER V.
VULNERABLE BUILDING CATEGORIES
One of the important tasks in the risk assessment study was to identify potentially vulnerable building
categories specific to Palo Alto using the building inventory that was developed early in the risk
assessment study. Potentially vulnerable structural system types were identified based on experience
in past earthquake events, knowledge of milestones when improvements in seismic code requirements
were made in Palo Alto, rankings in prominent seismic risk assessment tools such as the 2015 edition
of FEMA P-154 Rapid Visual Screening of Buildings for Potential Seismic Hazards, results from past
seismic risk assessment studies in California communities, and engineering judgment. The building
categories were then evaluated in analytical loss estimate studies described ahead which helped to
confirm the selected categories as appropriate for Palo Alto. Key building vulnerability metrics include
the risk of deaths and injuries, the cost of damage, and the extent of downtime or loss of use. Buildings
in the identified vulnerable building categories tend to perform poorly with respect to all three of
these metrics though the relative degree of vulnerability to each factor varies.
Community resilience is improved if residents have homes that remain usable after an earthquake
event, and if businesses can still operate. From a program perspective, the consultant team and
Advisory Group believe the greatest reduction in losses and the largest benefit to community resilience
will come from seismically retrofitting building types know to be both potentially hazardous and
present in significant numbers in Palo Alto.
In addition to the three categories already in Palo Alto’s seismic hazard identification ordinance
(Categories I, II, and III below), five additional categories of vulnerable building types were identified.
All five categories meet the criteria of being potentially hazardous and having a significant presence in
Palo Alto. The eight categories and the approximate number of buildings included in each category are
as follows:
Category I: Constructed of unreinforced masonry, except for those small than 1,900 square feet
with six or few occupants (10 remaining buildings in Palo Alto);
Category II: Constructed prior to January 1, 1935 containing 100 or more occupants (4
remaining buildings);
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Category III: Constructed prior to August 1, 1976 containing 300 or more occupants (9
remaining buildings);
Category IV: Pre-1977 soft-story wood frame (294 buildings);
Category V: Pre-1998 tilt-up concrete (99 buildings);
Category VI: Pre-1977 concrete soft-story (37 buildings);
Category VII: Pre-1998 steel moment frame (35 buildings);
Category VIII: Other pre-1977 concrete construction (170 buildings).
The loss estimate discussed ahead in Chapter VIII confirmed that the potential reduction in losses from
retrofitting is significant for these categories.
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CHAPTER VI.
CONCEPTUAL SEISMIC RETROFITTING OF REPRESENTATIVE
VULNERABLE BUILDINGS
Retrofit was considered for all buildings that have not already been retrofitted and were either
constructed before 1961 or between 1962 and the “benchmark” year with a soft story. A “benchmark”
year is when the code requirements for that building type became similar to those currently in place.
Buildings built after a benchmark year are assumed not to have significant seismic deficiencies and are
typically not seismically retrofitted. Consistent with typical practice, the performance of the retrofitted
buildings in an earthquake is assumed to be less than that of newly constructed buildings.
For estimating the cost of retrofit for the improved buildings, Rutherford + Chekene developed
conceptual designs for Model Building Types that represent a significant number and value of Palo
Alto’s building stock, as well as a significant loss and loss reduction after retrofit. This process identified
wood frame (W1, W1A, W2), steel moment frame (S1), concrete shear wall (C2), concrete tilt-up (PC1),
and reinforced masonry (RM1) and unreinforced masonry (URM) as appropriate candidates. For each
Model Building Type, the age, square footage and number of stories were reviewed to identify a
“prototype” building. In cases where the prototype building was not representative of more than two-
thirds of the total number of buildings, it was judged that multiple prototypes should be considered.
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Figure 11: Retrofit scheme for Large Multi-family Soft-Story Wood Frame Building.
For example, for the W1A Model Building Type there were a significant number of two-story and three-
story buildings with a significant difference in average square footage. Therefore, a two-story and a
three-story prototype building were developed to represent this Model Building Type. Eventually this
led to the 12 prototype buildings shown in Table 7.
Based on a review of buildings of size similar to the prototypes, representative floor plans were
developed. A conceptual retrofit was then shown on the floor plans. An example of a conceptual
retrofit for the W1A prototype building is shown in Figure 11 from a 2000 brochure by Rutherford +
Chekene for the City of San Jose entitled “Practical Solutions for Improving the Seismic Performance of
Buildings with Tuckunder Parking.” The retrofit elements were keyed to representative details in 2006
FEMA 547 Techniques for the Seismic Rehabilitation of Existing Buildings, and a written description of
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collateral impacts was developed as well to provide sufficient detail to allow a rough order of
magnitude cost estimate to be prepared. The conceptual retrofit designs, description of collateral
impacts, and referenced details are included in Appendix E.
The cost estimators of Vanir Construction Management used the conceptual designs to estimate a
range of probable cost to implement the retrofits. The retrofit costs for each prototype building are
shown in Table 7. These costs include hard costs, which are the costs the owner pays the contractor,
plus a design contingency as these are conceptual retrofits. The estimate further includes soft costs,
representing architect and engineer design fees, testing and inspection costs, permit fees, and an
owner change order contingency.
Considered costs do not include hazardous material abatement, costs associated with performing the
work while occupants are using the building, triggered accessibility upgrades, cost premiums
associated with retrofit of a historic building, tenant relocation or business interruption during
construction, project management, renovation, financing, repair of existing conditions, and legal fees.
These costs are more variable and project and site specific, and are typically not included in loss
estimates for this type of study. A detailed breakdown of estimated cost is included in Appendix F
The retrofit costs were extrapolated to Model Building Types not represented by a prototype retrofit
as shown in the fifth column of Table 7.
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Table 7: Conceptual retrofit cost.
Retrofit
Prototype
Model Building Type Stories Square
Feet
Used for
Model
Building
Types
Used
for
Square
Feet
Average
Retrofit
Cost
($/SF)
1 Wood frame smaller
residential (W1)
2 5,320 W1 All 12
2 Wood frame larger
residential (W1A)
2 9,500 W1A < 15,000 11
3 Wood frame larger
residential (W1A)
3 30,000 W1A ≥ 15,000 6
4 Wood frame
commercial/industrial (W2)
2 10,000 W2 All 14
5 Steel moment frame (S1) 2 43,900 S1, S2, S3 All 10
6 Concrete shear wall (C2) 1 5,000 C1, C2, S4,
PC2
< 10,000 50
7 Concrete shear wall (C2) 2 17,280 C1, C2, S4,
PC2
≥ 10,000 40
8 Concrete tilt-up (PC1) 1 18,435 PC1 < 25,000 29
9 Concrete tilt-up (PC1) 2 38,400 PC1 ≥ 25,000 21
10 Reinforced masonry, wood
floor (RM1)
1 2,750 RM1, RM2 < 5,000 74
11 Reinforced masonry, wood
floor (RM1)
2 8,150 RM1, RM2 ≥ 5,000 46
12 Unreinforced masonry
bearing wall (URM)
1 5,000 URM, S5,
C3
All 110
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CHAPTER VII.
LOSS ESTIMATING FINDINGS FOR EXISTING BUILDING STOCK
Hazus is a geographic information system (GIS) based, standardized, nationally applicable multi-hazard
loss estimation methodology and software tool. It is used by local, state, and federal government
officials for preparedness, emergency response, and mitigation planning. FEMA has recently released
the latest version of Hazus (Hazus 3.1) which includes building inventory data reflecting 2010 census
data for residential structures and costs to 2014. Rather than using the embedded inventory data for
Palo Alto, which are estimated from census data, a detailed earthquake risk assessment of the
individual buildings in the study group was conducted using the Hazus Advanced Engineering Building
Module (AEBM).
Direct loss is calculated through a complex process in Hazus. In essence, the engine consists of a large
database of “fragility functions”. These fragility functions describe the probability of exceeding
threshold damage levels as a function of a seismic demand parameter. For example, spectral
displacement is linked to slight, moderate, extensive and complete damage states to describe the
performance of a structural system. The estimated level of damage for the level of ground shaking
under consideration is then used to assign the costs to repair or replace the damage to the building’s
structural and nonstructural systems and contents (the loss). Each Hazus fragility function represents a
combination of Model Building Type, number of stories, and seismic design level.
Analyses were conducted for two specific earthquake scenarios developed by the United States
Geological Survey (USGS), a major M7.9 San Andreas Fault event, and a strong M6.7 San Andreas Fault
event.
The USGS has developed a suite of ShakeMap earthquake scenarios for different faults around
California. In the San Francisco Bay Area, they include events of different magnitude on a number of
faults, such as various segments of the San Andreas Fault and the Hayward Fault. The largest scenario
is a M7.9 event on the San Andreas Fault which represents a repeat of the 1906 earthquake. In this
scenario, all four segments (Santa Cruz Mountains, Peninsula, North Coast, and Offshore) of the San
Andreas Fault are assumed to rupture. There is a M7.2 event on the Peninsula segment with an
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epicenter somewhat south of Palo Alto. In addition to the scenarios, a ShakeMap of the 1989 Loma
Prieta earthquake which had an epicenter southwest of Palo Alto is also available.
In reviewing the available scenarios, the repeat of the 1906 earthquake provided a desirable, easy to
communicate upper bound scenario. Since the 1989 Loma Prieta event did relatively little damage to
buildings in Palo Alto (though there was substantial damage to some of the older buildings at nearby
Stanford University), it was judged to be too small to provide meaningful information for policy choices
in Palo Alto. Most of the Hayward Fault scenarios also produce small to moderate shaking in Palo Alto.
Review of the M7.2 San Andreas scenario found that it produced relatively similar peak ground
acceleration and short period spectral accelerations to those of the M7.9 scenario. Tom Holzer, an
engineering geologist with the USGS, is a member of the project Advisory Group. With his help and the
ShakeMap team at USGS, two other scenarios were developed between the M7.2 scenario and the
Loma Prieta earthquake. These are a M6.9 scenario and a M6.7 scenario on the Peninsula segment of
the San Andreas with an epicenter directly adjacent to downtown Palo Alto.
In the end, the M6.7 scenario was selected in addition to the M7.9 scenario. The M6.7 scenario
provided values somewhat smaller than the M7.9 scenario event, values large enough to be
meaningful, and is a magnitude size commonly used in USGS communications. It also has a
substantially lower equivalent return period from the M7.9 scenario.
Contour plots for the short period spectral acceleration for the two M6.7 and M7.9 scenarios are
shown in Figure 12.
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Figure 12: Predicted short period spectral acceleration in vicinity of Palo Alto (city boundary shown) for
two selected San Andreas Fault scenarios.
Table 8 summarizes the total loss calculated by Hazus for the as-is condition for the two earthquake
scenarios. The results show that the estimated losses to Palo Alto buildings and contents in a M6.7
scenario will be significant, on the order of $1.2 billion. Though ground shaking in the M7.9 scenario is
only about 25% larger than it is in the M6.7 scenario, overall building and content losses double to $2.4
billion. Average building damage and content damage also approximately double with a M7.9 event.
The difference in the number of buildings that are heavily damaged with the larger earthquake is more
pronounced with a 12-fold increase from the M6.7 to the M7.9 scenarios. This is shown in the fourth
column of Table 8 as the number of buildings with a damage ratio exceeding 20%.
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Table 8: Total losses for study group in as-is condition.
Earthquake
Scenario
Building
Value1
($B)
Content
Value2
($B)
Number
of Bldgs
with
Damage
Ratio ≥
20%3
Estimated
Building
Damage4
($B)
Estimated
Content
Damage4
($B)
Total
Building
and
Content
Damage
($B)
M7.9 18.9 17.3 224 1.7 0.7 2.4
M6.7 18.9 17.3 19 0.8 0.4 1.2
Ratio of M7.9/M6.7 2 2 2
Notes:
1. Building value is the complete replacement cost for the building, and includes the
structure, architectural, mechanical, electrical, and plumbing components (e.g.,
ceilings and lighting).
2. Content value includes the complete replacement cost of furniture and equipment
that is not integral with the structure (e.g., computers and other supplies). They
are estimated as a percent of structure replacement value, dependent on
occupancy.
3. Damage ratio is defined as the cost of repairing damage divided by the
replacement cost of the building.
4. Estimated building and content damage cost is the cost associated with repair and
replacement of the building and its content.
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To put the loss from building damage in context, the average annual valuation of Palo Alto construction
permits was $400M between 2013 and 2016 (which represents a boom period). The total loss in a
major M7.9 earthquake represents more than four years’ worth of construction, and the total loss in a
strong M6.7 earthquake represents more than two years worth of construction.
It should be noted that these losses do not include the effects of lives lost and business disruption, or
the ripple effects in the local economy or real estate market, and that much of this loss will not be
insured.
Table 9 breaks out the estimated loss and damage ratio for various model building types, and it can be
seen that it depends on the metric used which building type is considered the poorest performer.
Looking at the total loss alone, concrete bearing wall buildings and commercial wood frame buildings
are responsible for the highest total loss. This tracks well with the earlier finding that these structural
systems are the most prevalent ones. If we look at the highest average building damage ratio instead,
buildings with unreinforced masonry bearing walls and unreinforced masonry infills are the most prone
to damage. However, not very many of them exist in Palo Alto, and as a result they do not represent
much of the aggregate loss. It is therefore important to look at multiple metrics when deciding which
buildings are the most vulnerable and significant to the community as a whole.
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Table 9: Top three vulnerable building types ranked by total loss, average damage ratio, and number
of severely damaged buildings.
Building Type Number
of
Buildings
Building
Value
($M)
M7.9 EQ
Total
Building
+ Content
Losses
($M)
M7.9
EQ
Average
Building
Damage
Ratio
M7.9
EQ
Number
of Bldgs
with
Damage
Ratio ≥
20%
Concrete shear wall (C2) 318 4,082 477 14% 75
Concrete tilt-up (PC1) 242 3,368 365 12% 32
Wood frame commercial/industrial (W2) 307 2,369 216 9% 9
Steel frame with masonry infill (S5) 2 3 1 38% 1
Unreinforced masonry bearing wall (URM) 9 15 4 29% 9
Concrete frame with masonry infill (C3) 8 8 2 29% 6
Concrete shear wall (C2) 318 4,082 477 14% 75
Concrete tilt-up (PC1) 242 3,368 365 12% 32
Steel moment frame (S1) 75 1,242 130 18% 27
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CHAPTER VIII.
LOSS ESTIMATING FINDINGS WITH BUILDINGS RETROFITTED
A second Hazus AEBM run was done assuming a retrofitted building stock. For this run, it was assumed
that a building would be retrofitted if it has not already been retrofitted and is either constructed
before 1961 or between 1962 and the benchmark year with a soft story. The Hazus model was rerun
with the updated fragilities simulating retrofit.
Table 10 shows the resulting total losses and damage ratios. Though total losses are still significant,
comparing the results of Table 10 with Table 8 shows a reduction in total loss of 45% for the M7.9
scenario, and 33% for the M6.7 scenario. In other words, aggregate loss to the community if all
considered properties were retrofit could be reduced by one third in a very plausible event and almost
halved in a much larger event.
Another important improvement is the reduction of the number of buildings with more than 20%
damage. The M7.9 scenario shows a reduction from 224 buildings to 6 buildings, meaning that the
probability of building collapse and resulting injuries and fatalities has become very low.
Finally, the damage and loss of the M7.9 scenario remain approximately two times the amount
sustained in the M6.7 scenario. This suggests that the retrofit has a similar impact for both levels of
ground shaking.
Table 10: Total losses after retrofitting.
Earthquake
Scenario
Building
Value
($B)
Content
Value
($B)
Estimated
Building
Damage
($B)
Number
of Bldgs
with
Damage
Ratio ≥
20%
Estimated
Content
Damage
($B)
Total
Building
&
Content
Damage
($B)
M7.9 18.9 17.3 0.9 6 0.5 1.3
M6.7 18.9 17.3 0.5 0 0.3 0.8
Ratio of M7.9/M6.7 2 - 2 2
Table 11 breaks out the reduction in total loss by model building type for the M7.9 scenario, and shows
the associated retrofit cost. The average reduction in loss varies by building type, with URM buildings
showing the highest reduction in loss after retrofit of 80%, and steel braced frames showing an 18%
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reduction at the low end. On average, the retrofit costs are on the order of the damage reduction for
this scenario, though by building type the average damage reduction (loss avoided) divided by retrofit
cost ranges from 0.14 for steel light frame buildings to almost eight for reinforced masonry buildings.
Wood frame and concrete buildings are responsible for the largest reduction in total loss, with wood
frame construction representing over 20% of the loss reduction, and concrete buildings over 50%.
It should be noted that the data in Table 11 also includes buildings that were not retrofitted. As a
result, further parsing of the data is needed to better understand which buildings are responsible for
the most loss, and those that can be improved more cost-effectively.
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Table 11: Comparison of retrofit benefits and costs by Model Building Type.
Model Building Type M7.9 EQ
Average
Damage
($/SF)
M7.9 EQ
Total
Damage
Reduction
($1,000)
Average
Damage
Reduction
($/SF)
Retrofit
Cost
($/SF)
Wood frame smaller residential (W1) 16 13,775 4 12
Wood frame larger residential (W1A) 25 61,317 7 6-11
Wood frame commercial/industrial (W2) 50 160,155 26 14
Steel moment frame (S1) 62 76,150 25 10
Steel braced frame (S2) 44 24,222 8 10
Steel light metal frame (S3) 108 38,163 72 10
Steel frame with concrete shear walls (S4) 101 11,118 69 40-50
Steel frame with masonry infill (S5) 247 695 121 110
Concrete moment frame (C1) 55 8,045 25 40-50
Concrete shear wall (C2) 70 336,574 35 40-50
Concrete frame with masonry infill (C3) 120 865 34 110
Concrete tilt-up (PC1) 68 218,491 27 21-29
Precast concrete frame (PC2) 21 0 0 21-29
Reinforced masonry, wood floor (RM1) 59 87,697 31 46-74
Reinforced masonry, concrete floor (RM2) 35 3,727 6 46-74
Unreinforced Masonry Bearing Wall (URM) 23 5,216 19 110
Totals 51 1,046,210 22
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Table 12 shows those buildings types that may be considered good candidates for a retrofit program.
Although representing only about 15% of the total inventory, these buildings are responsible for over
30% of the total loss. This is reflected in the considerably higher than average loss (fourth column of
Table 12). The benefit of retrofit is also considerable for this group of buildings, as they are responsible
for over 50% of the reduction in loss. Additionally, the cost to retrofit them is only a fraction of the
losses avoided in a major event, ranging from a third for the concrete buildings to a tenth for the steel
frames. Note that these values are based on conceptual retrofits. Actual retrofit costs for individual
buildings would vary substantially, and the steel moment frame benefit-to-cost ratio is higher than
expected by engineering judgment. This is caused in part by a comparatively low retrofit cost for this
Model Building Type.
Table 12: Comparison of benefits and costs by selected Model Building Type, date and
characteristics.
Model Building Type Number
of
Buildings
Total
SF
(1,000)
M7.9 EQ
Average
Loss by
Building
($/SF)
M7.9 EQ
Average
Loss
Avoided
by
Retrofit
($/SF)
Average
Cost to
Retrofit
($/SF)
(Average
Loss
Avoided)
/
(Average
Retrofit
Cost)
Pre-1977 wood frame soft-story
(W1, W1A, W2)
294 3,690 66 46 12 4
Pre-1998 tilt-up
(PC1)
99 3,078 106 71 23 3
Pre-1977 concrete soft-story
(C1, C2, C3)
37 842 149 108 42 3
Pre-1998 steel moment frame
(S1)
35 690 152 110 10 11
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CHAPTER IX.
REVIEW OF PAST SEISMIC RETROFITS
To gain a better understanding of the quality of the retrofits and identify relevant issues to updating
Palo Alto’s seismic risk mitigation program, a sample of the submitted engineering studies and building
retrofit drawings was reviewed.
Ten buildings were selected, so that their permit history could be reviewed and documents could be
retrieved from the archives of the Building Department. They were distributed over the three existing
hazardous buildings categories, and also included soft-story wood frame buildings. Records were
retrieved for four Category I buildings (to reflect the higher number of these), two Category II
buildings, two Category III buildings, and two soft-story wood frame buildings.
The City tracked permit numbers for the retrofit projects in their “hazardous buildings” database. Even
so, it proved difficult to retrieve associated documents. After careful review of the City’s records, some
archived documents showing structural modifications were retrieved. The type of documents available
varied from building to building. In about half of the cases, plans were available, and in the other half,
the documents consisted of calculations with sketches.
For one of the Category I buildings, plans showing a comprehensive retrofit were available. The 2001
California Building Code was referenced for seismic design. In a second case, the retrieved plans show
retrofit of a section of the building that appears to be intended to improve the original retrofit. It was
unclear if other sections of the building were improved in a similar fashion. In the third case, structural
calculations were provided. It is unclear what criteria were used, as the 1991 UCBC is used for certain
elements and the regular UBC seismic load calculations for global loading. The set of plans retrieved for
the last building is for a tenant improvement that appears to have been constructed a few years after
the original seismic retrofit. Interestingly, the structural engineer referenced the 1977 UBC as the
seismic design criteria. The building is identified on the plans as a concrete building, rather than a URM
building.
For the Category II buildings, in one case only the permit application worksheet was available; in the
other case there were detailed calculations and sketches (no construction documents). The permit
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application for the first building indicates that shear walls were added as part of a voluntary seismic
upgrade. The sketches for the second building indicated that the retrofit was designed to mitigate the
deficiencies identified in the evaluation report. It references both elements and loads from the earlier
study.
For the Category III buildings, it appears that in both cases the projects were driven by modifications or
additions to the existing building. Since no plans were archived, and the calculations could not be easily
followed, it was not clear if the existing building was fully evaluated and if all deficiencies found in the
original evaluation report were addressed.
In 2003, the Collaborative for Disaster Mitigation at San Jose State University completed an “Inventory
of Soft-First Story Multi-Family Dwellings in Santa Clara County”. According to the report the City of
Palo Alto had 130 soft-first story multi-family buildings including 1,263 residential units housing 3,158.
The list of addresses from the San Jose State University report was updated with information from the
City of Palo Alto Fire Department, and resulted in a reduced list of 108 addresses. According to this list,
which was included in a recent Staff Report to Palo Alto’s Policy and Services Committee33, six buildings
were improved voluntarily. Two sets of plans were retrieved and reviewed; in one case the plans
improved two buildings with the same plan as a mirror image. One of the permits was issued in 2006
and one in 2009. It appears that in both cases the buildings were of a more recent vintage, as plans
show that existing plywood shear walls are present. On both sets of plans design criteria were
referenced, with one building referring to the 2001 California Building Code, and one Appendix Chapter
A4 of the 2006 International Existing Building Code.
Review of the submitted engineering studies and building retrofit drawings identified the following
relevant needs for future seismic risk mitigation programs:
Clear identification of retrofit design intent, scope, and limitations, also for voluntary retrofits;
Identification of existing structural systems;
Decision on requirements for buildings that have had partial seismic retrofits completed, and
may have remaining seismic deficiencies.
33 Policy and Services Committee Staff Report 5293, Discussion of Updating the Seismic Safety Chapter of the Municipal
Code for Hazardous Buildings, December 9, 2014, available online at
https://www.cityofpaloalto.org/civicax/filebank/documents/44945 (accessed 12/21/2016)
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CHAPTER X.
ADDITIONAL RECOMMENDED PROGRAM FEATURES
In addition to expansion of the building categories included within the City’s seismic risk mitigation
program and refinement of disclosure measures and incentive options, a number of other program
features are recommended. They are described in the following:
Use the current inventory, taking note of its limitations: The inventory developed for the effort
to date involved use of digital information and field surveys. A complete field survey of all
buildings in Palo Alto was outside the scope of the project. However, the inventory that has
been developed is an excellent resource. The first step in any future ordinance will involve
notification of building owners that they may be subject to the requirements of the ordinance.
Those buildings that were field surveyed and fall within the scope of the ordinance can be
notified using the existing inventory. For the remaining buildings, additional field survey is
recommended. This would be a rapid visual assessment and could be conducted by City staff or
outside consultants.
Use an initial screening form phase: Typically, as part of the notification process, a screening
form of about one-page in length is sent, and the owner is required to have a design
professional, such as a structural engineer or architect, complete the form for a relatively
nominal cost to confirm whether or not the building actually is subject to the City’s ordinance.
Some buildings may appear from a rapid visual assessment to be one of the building categories
covered, but upon closer review they are exempt. This approach has been taken in many
communities in the past, and thus sample forms are available that can be easily tailored for
Palo Alto.
Clearly specify seismic evaluation and retrofit scope: The seismic evaluation (and retrofit)
methodology for each building category will need to be defined after the building categories
included in the updated ordinance are determined. Industry consensus standards exist and
cover the vulnerable building categories identified for Palo Alto. These include the 2015
International Existing Building Code (IEBC) and 2014 ASCE 41-13 Seismic Evaluation and Retrofit
of Existing Buildings. Both are currently being updated by groups of engineers and building
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officials. For soft-story wood frame buildings, there is also the 2012 FEMA P-807 Seismic
Evaluation and Retrofit of Multi-Unit Wood-Frame Buildings with Weak First Stories. For steel
moment frame buildings, there is also the 2000 FEMA 351 Recommended Seismic Evaluation
and Upgrade Criteria for Existing Welded Moment Resisting Steel Structures. ASCE 41 has three
tiers of evaluation: Tier 1, Tier 2, and Tier 3. Tier 1 is primarily a screening tool. As a minimum
standard, Tier 2 is recommended. Table 13 provides recommended evaluation and retrofit
standards.
Table 13: Recommended Evaluation and Retrofit Standards
Category Description Evaluation and Retrofit Standards
I Unreinforced masonry IEBC Appendix Chapter A1
II Built before 1/1/35 with 100
or more occupants
ASCE 41
III Built before 8/1/76 with 300
or more occupants
ASCE 41
IV Pre-1977 soft-story wood
frame
IEBC Appendix Chapter A4, ASCE 41, or FEMA P-807
V Pre-1998 tilt-up IEBC Appendix Chapter A2 and ASCE 41
VI Pre-1977 soft-story concrete ASCE 41
VII Pre-1998 steel moment
frame
ASCE 41, or FEMA 351
VIII Other pre-1977 concrete ASCE 41
Provide detailed evaluation report submittal requirements: Minimum submittal requirements
for evaluation reports will need to be defined. The above evaluation and retrofit standards
provide some guidance but a short clear set of requirements will be beneficial. This will include
such items as address, construction date, size, number of stories above and below grade,
owner, occupancy type, structural system type, the location and features of the primary
structural system, the extent of field review, material properties, the evaluation criteria and
methodology used, whether the structure meets the evaluation criteria, identified seismic
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deficiencies if it does not. The current ordinance requires identification of retrofit measures to
address seismic deficiencies. Even in a voluntary program, it is recommended that this be
continued to help owners, tenants, and the City better understand what is necessary to
mitigate the issues that exist.
Specify how past partial retrofits will be handled: In the past, some buildings have had partial
seismic retrofits where only selected portions of the seismic force-resisting system have been
upgraded, and some seismic deficiencies may still exist in these structures. If mandatory retrofit
requirements are implemented that provide for comprehensive retrofitting of the full seismic
load path, there may be buildings with previous partial retrofits that do not fully comply and
need remaining deficiencies to be addressed. This will be identified in the seismic evaluation
report.
Update both new and existing building permit submittal requirements: Review of City records
found that basic information such as the building structural system, date of construction, and
retrofit standard used (where applicable) are not readily available. It is recommended that
submittals for permit for both new buildings and existing building renovations require this
information. For structural systems, both the categorization found in ASCE 41 and the ASCE 7
Table 12.2-1 is recommended. This will allow the city to have a much better understanding of
its building stock and its expected performance in an earthquake.
Write a new ordinance or set of ordinances to update the program: After the Council has
provided direction and the above issues have been addressed, an updated ordinance will need
to formally be written. This can be done by City staff, but will likely benefit from the
involvement of an appropriately experienced structural engineering consultant.
Carefully address program management and interdepartmental coordination needs: To
successfully manage Palo Alto’s updated Seismic Risk Mitigation Program, an effective
management plan is needed so that progress is monitored by the City and community intent is
achieved. It will include a realistic list of information that can be easily input, summarized, and
tracked in digital records such as the submittal requirements recommended above and that can
be used to link the seismic risk program data to other digital records such as assessor files or
GIS systems; quality assurance procedures for checking information; clearly defined roles and
responsibilities; timelines and requirements for reporting of information internally and
externally; procedures for gathering, assessing and implementing community feedback and
suggestions; and links between the seismic risk mitigation program and activities that will occur
following an earthquake, such as postearthquake safety evaluation.
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Delineate department and key staff responsibilities: For Palo Alto’s updated Seismic Risk
Mitigation Program, City staff will be responsible for several categories of activities.. These will
include the basic activities such as managing the notification and inventory process, reviewing
evaluation reports and plan checking retrofit construction documents, and field inspections of
retrofit work. Less obvious activities will include evaluating requested exceptions to the
program or alternative means of compliance; managing feedback from design professionals,
owners, and the public; tying pre-earthquake retrofitting to post-earthquake safety evaluations
records; and managing post-earthquake safety evaluation, repair, and recovery plans.
Depending on the scale of the updated program, it is possible that addition staff members or
consultants will be needed to handle the work flow. The City may also benefit from an
appropriately experienced structural engineer to provide advice on technical and program
management issues, particularly as the program moves to final definition and then to initial
implementation. Later, as is done in some communities, it may be desirable to create volunteer
review boards of local structural engineers who review questions on the evaluation and retrofit
criteria and provide the city with technical opinions that staff can use.
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CHAPTER XI.
QUESTIONS TO GUIDE COUNCIL DELIBERATIONS AND POTENTIAL
ISSUES FOR FUTURE STUDY
1. QUESTIONS TO HELP GUIDE COUNCIL DELIBERATIONS
Preferred policy directions were developed with the Advisory Group and staff as discussed in Chapter I
and include expansion of the building categories currently covered by the City’s ordinance, movement
toward mandatory requirements for some categories, additional disclosure measures and use of
incentives to increase the effectiveness and likelihood of compliance and of success. To help the
Council in its deliberations, a series of questions are given here. They are similar to questions and
issues discussed by the Advisory Group.
1. Does the Council wish to expand the current seismic hazard program to cover more vulnerable
building categories?
2. If so, which of the building categories in Table 1 should be included? The Advisory Group proposed
that the existing Categories I-III, plus the Categories IV-VII, be included as follows. The categories
are:
a. Category I: Constructed of unreinforced masonry, except for those smaller than 1,900 square
feet with six or fewer occupants (in the current ordinance)
b. Category II: Constructed prior to January 1, 1935 containing 100 or more occupants (in the
current ordinance)
c. Category III: Constructed prior to August 1, 1976 containing 300 or more occupants (in the
current ordinance)
d. Category IV: Pre-1977 soft-story wood frame
e. Category V: Pre-1998 tilt-up concrete
f. Category VI: Pre-1977 concrete soft-story
g. Category VII: Pre-1998 steel moment frame
An eighth category (Category VIII other older nonductile concrete buildings) was discussed, but
because of the lack of inexpensive analytical methods for reliably identifying the worst of these
buildings, inclusion of this building category in an updated ordinance is not recommended at this
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time. Such buildings could be included in the future when the engineering community has
developed appropriate analytical methods.
3. In addition to mandatory initial evaluation requirements, should one or more of the categories of
buildings be subject to mandatory retrofit requirements? The Advisory Group had a consensus on
mandatory requirements for renovation for unreinforced masonry buildings and there was strong
support among many members for other categories such as soft-story wood frame buildings and tilt-
up buildings, particularly those with high occupancies.
4. Should the City develop a trigger mechanism based on sale or substantial renovation where seismic
retrofit is required? If so, which building categories should be subject to a trigger mechanism?
There was support among some Advisory Group members for a trigger mechanism for some building
categories, such as tilt-up industrial buildings, particularly those that are being converted to office
buildings and increasing the occupant load and thus exposure to seismic risk.
5. What public disclosure or notice measures of the need for retrofitting a building should be pursued?
The Advisory Group supported website listing and tenant notification, but there was low support for
placing notices on property titles or for signage or placing placards on the outside of buildings.
Other possibilities include encouraging earthquake performance rating systems and disclosing them
to the public or developing such a rating system for city-owned buildings.
6. What incentive measures to encourage property owners undertake a structural retrofit should be
pursued?
The Advisory Group supported incentives for fee waivers, expedited permitting, and property-
assessed financing tools. There was minimal interest in deep financial assistance such as establishing
a special district or passing of bond measure to assist property owners financially. . Opinions were
split on the use of transfer of development rights, floor area ratio bonuses, and parking exemptions.
8. How much time do you feel is reasonable for property owners of at risk buildings in the community
to: a) prepare the initial structural evaluation reports for regulated buildings; and b), to complete
mandatory structural retrofits to their buildings?
2. POTENTIAL ISSUES FOR FUTURE STUDY AND CONSIDERATION
For some issues, based in part on Advisory Group discussions, additional information may be beneficial to help
develop a strategy and to better understand potential impacts on key stakeholders and community concerns.
Some of these issues are primarily economic and were outside the scope of the current study. The City Council
may wish to direct staff and/or outside consultants to investigate some of these items in more detail as the
seismic risk management program effort proceeds. These issues include the following:
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• Occupants and tenants
– How much would a typical retrofit add to the monthly rent of a multifamily soft-story wood
frame apartment tenant?
– Would some tenants be unable to afford a rent increase and seek housing elsewhere in Palo
Alto or move outside the city (and if so, how many might be displaced)?
– If soft-story wood frame apartments in Palo Alto are retrofitted in time before the next major
earthquake, how much less displacement of residents would occur as a result of the
earthquake?
– What categories of buildings are most important to address in order to help maintain the
commercial viability and vitality of the City’s core business districts and tax base?
• Property owners, developers, and business owners
– What are the characteristics of property owners that would be affected?
– How might small businesses be affected compared to larger ones?
– How many property owners are in need of lower cost capital or other substantial financial
assistance to fund retrofitting?
• Impacts of Seismic Restoration on Retention of Historic Structures in the City
– Insure that the review of initial seismic evaluations identify those structures that are listed in the
City’s Historic Inventory and flag them for attention during subsequent review.
– Develop a clear process for reviewing proposed seismic retrofits to historic structures that is
coordinated among responsible city departments and is consistent with current regulations and
Community policies.
– Seek out retrofit alternatives that are consistent with the Historic Building Code, historic
characteristics of the structure, and provide the most risk reduction.
• City departmental resources and budgets
– What would be the loss in revenue to the Building Department if fee waivers were offered?
– What would be the staffing and budgetary needs over time to administer an expanded program
that addresses additional building types?
– What kinds of interdepartmental cooperation and staff resources in other departments are
necessary to ensure effective implementation and coordination with other city planning and
public safety efforts?
Attachment F
Seismic Risk Assessment Study December 21, 2016
Final Report Page 110
• Overall community economic health
– What kind of benefits could accrue to Palo Alto in terms of maintaining community function and
ability to recover if various building categories are retrofitted in time before the next major
earthquake?
• Other related issues
– It was brought up in the Advisory Group that the Building Department needs flexibility and
authority to take steps to get tough seismic mitigation projects done. One idea was to grant the
Building Official the ability to classify certain projects (with well-specified criteria) as warranting
a kind of “seismic safety” or “earthquake resilience” fast tracking, with city departments
agreeing to coordinate on a specified accelerated project review timeframe.
– Although outside the formal scope of this planning effort, several Advisory Group members
commented that it would be desirable for the City to do some kind of assessment of any
earthquake mitigation needs in public buildings and facilities serving the City.
– Advisory group members recommended the community be informed of Palo Alto’s overall
potential seismic risk by providing a summary of potential impacts on the City’s website,
including the expected performance of vulnerable buildings.
– The group also had a high degree of support for recommending that the City initiate and nest
future earthquake mitigation programs within a broader disaster or community resilience
initiative, as cities such as Los Angeles, Berkeley, and San Francisco have done. This could be
incorporated into the update of the City’s Comprehensive Plan Safety Element. There was
insufficient time in the project’s six advisory group meetings to consider potential initiatives to
assess risks for cell phone towers, water supply, facades, private schools, post-earthquake
shelter facilities, and/or other assets important to community recovery.
Attachment F
City of Palo Alto (ID # 8395)
City Council Staff Report
Report Type: Action Items Meeting Date: 11/13/2017
City of Palo Alto Page 1
Summary Title: Comp Plan Update: Final Approval and Certification of FEIR
Title: PUBLIC HEARING: Adopt a Resolution Certifying the Final
Environmental Impact Report (EIR) for the Comprehensive Plan Update, a
Resolution Adopting Findings Pursuant to the California Environmental
Quality Act (CEQA) Related to Significant Environmental Impacts, Mitigation
Measures and Alternatives, a Statement of Overriding Considerations and a
Mitigation Monitoring and Reporting Program, and a Resolution Adopting
the Updated Comprehensive Plan Dated June 30, 2017 with Desired
Corrections and Amendments, Which Comprehensively Updates and
Supersedes the City's 1998-2010 Comprehensive Plan, Except for the Housing
Element Adopted in November 2014. (This is the third public hearing; the
first hearing was on October 23, 2017, continued to October 30, 2017 and
further continued to November 13, 2017.)
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the City Council take the following actions:
1. Receive and consider the Planning & Transportation Commission (PTC) report and
recommendations regarding the Comprehensive Plan Update and adopt a motion
thanking the PTC and identifying specific changes to the June 30, 2017 Comprehensive
Plan Update desired as a result of the Commission’s work; (This recommendation was
completed October 30, 2017 and changes resulting from the Council’s actions have
been included in Attachment A.)
2. Adopt a resolution (Attachment B) certifying that the Council has reviewed and
considered the Comprehensive Plan Update Final Environmental Impact Report (EIR)
dated August 30, 2017, the Final EIR has been completed in compliance with the
California Environmental Quality Act (CEQA), and the Final EIR reflects the independent
judgment and analysis of the City of Palo Alto;
City of Palo Alto Page 2
3. Adopt a resolution (Attachment C) making required CEQA findings, including findings
related to significant environmental impacts, mitigation measures and alternatives,
adoption of a statement of overriding considerations, and adoption of a mitigation
monitoring and reporting program (MMRP);
4. Adopt a resolution (Attachment D) adopting the updated Comprehensive Plan dated
June 30, 2017 with the specific corrections and changes included in Attachment A,
comprehensively updating and superseding the 1998-2010 Comprehensive Plan in its
entirety, except for the Housing Element adopted in 2014 which will remain part of the
Comprehensive Plan;
5. Direct staff to prepare and disseminate electronic and paper copies of the updated
Comprehensive Plan with appropriate formatting, illustrations, and acknowledgements;
and
6. Direct staff to return to Council for another review of the implementation chapter of the
Comprehensive Plan in 2018 and in the interim, prioritize the following implementing
actions to bring forward to Council on future agendas in the near term:
A. Adoption of an Updated Transportation Impact Fee Ordinance;
B. Adoption of Comprehensive Plan Implementing Ordinance #1 amending Title 18
(Zoning Ordinance) of the Municipal Code to support the production of new
housing and the preservation of existing units;
C. Initiation of a Coordinated Area Plan for the North Ventura area (also referred to
as the Fry’s site); and
D. Initiation of discussions with Stanford University about the potential for
developing housing in the Stanford Research Park, Stanford Shopping Center,
and Stanford University Medical Center vicinity.
Note: This is the third hearing for consideration of these recommendations. The Council has
previously considered these items on October 23, 2017 and October 30, 2017.
The August 30, 2017 Final EIR is available at: http://www.paloaltocompplan.org/eir/ and the
June 30, 2017 the Comprehensive Plan Update is available at:
http://www.paloaltocompplan.org/wpcontent/uploads/2017/07/PACompPlan_June30_PTC_we
breduced.pdf. Hard copies of both documents are also available for review at the Planning
Department and at local libraries. The Planning Department is located on the 5th floor of City
Hall at 250 Hamilton Avenue in Palo Alto.
Copies of the City Council packet for October 23, 2017 can be found here:
http://www.cityofpaloalto.org/civicax/filebank/documents/59856, A supplemental memo
prepared for October 30, 2017 can be found here:
http://www.cityofpaloalto.org/civicax/filebank/documents/60034.
City of Palo Alto Page 3
Executive Summary
The City has been working on a comprehensive update to its general plan, the Palo Alto 1998-
2010 Comprehensive Plan, for many years and the City Council will have an opportunity to
complete this effort at tonight’s meeting.
Overall, the Citizens Advisory Committee (CAC) and the Council have crafted a Comprehensive
Plan Update that seeks to preserve the vision and values of the current Comprehensive Plan,
while updating its goals, policies, and programs to reflect the world of today. The updates are
aimed at:
Land Use & Community Design
stimulating housing through a host of implementation programs, supplementing policies
and programs in the City’s Housing Element;
making the non-residential development cap apply citywide and focusing it on
office/R&D development only so square footage converted from another use like
warehouse or retail to office/R&D development will count against the cap;
preserving ground floor retail and limiting the displacement of existing retail;
ensuring regular coordination with Palo Alto Unified School District regarding land use
and development;
recognizing and incorporating the goals of other recent planning efforts, such as the
Urban Forest Master Plan and the Parks, Trails, Open Space and Recreation Master Plan;
guiding operation and improvements at the Palo Alto Airport, which was transitioned
from the County to the City in recent years;
Transportation
reducing reliance on single occupant vehicles (SOV), making alternatives to the
automobile more convenient, and addressing the needs of transit-dependent
communities;
establishing specific quantitative goals for trip reduction from new development
prioritizing Caltrain grade separations;
recognizing the State-mandated transition from Level of Service (LOS) to Vehicle Miles
Travelled (VMT)as a methodology for analyzing traffic impacts under CEQA, while
preserving LOS as a methodology for ensuring Comprehensive Plan consistency;
Natural Environment
establishing a new focus on connected ecosystems, consistent with the Parks, Trails,
Open Space and Recreation Master Plan;
recognizing open space, the urban forest, and a healthy natural environment as
contributors to public health;
City of Palo Alto Page 4
seeking opportunities for adding open space, including connections between Skyline
Ridge and San Francisco Bay;
addressing climate changes and climate adaption;
ensuring resilient supply and management of water in Palo Alto, including additional
policies to protect groundwater as a resource and to respond to drought;
encouraging energy efficiency, energy conservation, and renewable energy sources;
Safety
updating policies on natural and man-made threats and hazards, with a focus on
preparedness;
expanding policies on community safety and emergency management;
Community Services & Facilities
perpetuating policies about new and existing parks and public open spaces;
adding new policies and programs specifically tailored to the needs of youth and of
seniors;
sustaining the health and well-being of residents, consistent with the Council’s Heathy
Cities, Healthy Communities resolution;
Business and Economics
promoting a comprehensive approach to fiscal sustainability;
supporting the small local-serving businesses, start-ups, non-profit organizations, and
professional services that make up Palo Alto’s business diversity.
The updated Comprehensive Plan will serve as the City’s “constitution,” with policies that will
inform development and implementation of land use regulations and infrastructure
investments for many years to come. The updated Plan also contains implementation programs
that are intended to advance the goals and policies of the Plan, and that may be reexamined
and reprioritized by the City Council on a regular basis.
On October 23 and 30, the City Council considered a report and recommendations from the PTC
as well as changes and corrections identified by staff for incorporation in the Comprehensive
Plan. At tonight’s meeting, the Council will consider any additional text changes to the plan and
adoption of three resolutions: the first would certify the Final EIR (Attachment B), the second
would adopt required CEQA findings (including a “statement of overriding considerations” and
a mitigation monitoring and reporting program), and the third would adopt the Comprehensive
Plan Update with the desired changes and adjustments identified by the Council and included in
Attachment E. Staff is also asking for direction to prepare and disseminate electronic and paper
copies of the plan, as well as direction to return to Council for an in depth discussion of the
Implementation Chapter and to identify a handful of near term implementation priorities.
City of Palo Alto Page 5
Background
The City’s current Comprehensive Plan, Embracing the New Century, Palo Alto 1998-2010
Comprehensive Plan, was adopted in 1998 and sets goals, policies, and programs related to
land use and development issues, including transportation, housing, natural resource,
community services, and safety.
The proposed Comprehensive Plan Update contains chapters or “elements” that address topics
required by State law, as well as optional elements and topics. This relationship is shown in
Table 1. The Plan includes a total of seven Elements; two are optional. All of these draft
elements are based on the existing Comprehensive Plan, revised to reflect the City Council’s
direction regarding vision and goals, as well as input from the PTC’s proposed revisions and
public input. The elements included in the June 30, 2017 draft Comprehensive Plan Update are
the product of hundreds of hours of work by the Council, the PTC, the Citizens Advisory
Committee (CAC), CAC subcommittees, staff, and consultants.
Table 1. State-Mandated and Palo Alto Comprehensive Plan Elements
State-Mandated Element Comprehensive Plan Element
Land Use Land Use & Community Design
Circulation Transportation
Housing Housing (adopted 2014 – not part of PTC review)
Open Space
Conservation
Noise
Natural Environment
Safety Safety
Optional Elements
Business & Economics
Community Services & Facilities
Note: The previous Safety Element Goals, Policies and programs were part of the 1998 Natural
Environment Element. The Comprehensive Plan also includes Governance and Implementation
chapters, as well as an introduction and glossary.
Source: Planning & Community Environment, September 2017
The City Council recognized the need to update the Plan and initiated the update in 2006. The
PTC then spent close to six years working on the Comprehensive Plan Update (from 2008 to
2014), ultimately sending its recommendation to the City Council in April of 2014. Upon
receipt of the PTC’s recommendations, the City Council adopted a schedule and strategy for
“reframing” the long-running update to include expanded community engagement and a full
evaluation of alternatives, cumulative impacts and mitigation strategies. A community-wide
Summit was attended by over 350 people in May 2015, and was followed by creation of the
City of Palo Alto Page 6
CAC to engage in further community dialog and inform the Council’s deliberations.
Between July 2015 and May 2017, the full CAC met 23 times to review elements of the
existing Comprehensive Plan, review recommendations advanced by the PTC, and receive and
review community input. The CAC also formed subcommittees to discuss each Element, as
well as a Sustainability subcommittee that considered sustainability-related issues in several
Elements. There were a total of 29 meetings of CAC subcommittees. All CAC meetings were
noticed and open to the public and included time for public comment. The CAC forwarded its
recommended draft Comprehensive Plan Update to the Council on May 16, 2017. All meeting
materials and minutes from CAC meetings are available here:
http://www.paloaltocompplan.org/cac/citizens-advisory-committee/
In addition, the City Council met independently to review elements of the existing
Comprehensive Plan, review recommendations advanced by the PTC and the CAC, and receive
and review community input. The City Council discussed the Comp Plan goals and vision
statements, EIR scenarios, and draft Elements at 24 meetings since 2010. City Council
agendas, staff reports, and other relevant materials for Comp Plan discussion items are
available here: http://www.paloaltocompplan.org/city-council/
On June 12, 2017, the City Council referred the Comprehensive Plan Update Draft to the PTC for
review and a recommendation within 90 days. The draft Plan that was sent to the PTC (referred
to in this report as the “June 30, 2017 Draft Plan”) reflects the Citizens Advisory Committee’s
(CAC) May 16, 2017 recommendations to the Council and incorporates changes based on
Council’s review up to and including the Council meeting on June 12th. At the June 14, 2017
PTC meeting, the PTC passed a motion to focus its 90 day review on the Land Use and
Transportation Elements of the Comprehensive Plan Update. The PTC completed its review and
recommendations on these two Elements on September 27, 2017, within the 90 day period.
The Commission’s report and recommendations were considered by the Council on October 23
and 30.
The Comprehensive Plan Update cannot be adopted until the City complies with the California
Environmental Quality Act (CEQA), a State law requiring California agencies to identify the
significant environmental impacts of their actions and describe feasible measures that can be
taken to avoid or mitigate those impacts. Concurrent with the preparation of the
Comprehensive Plan Update, the City has prepared what is referred to as a “program-level” EIR
(CEQA Guidelines Section 15168), which assesses the potential cumulative impacts of
development that may occur during the life of the plan, considers potential alternatives, and
identifies mitigation measures that should be adopted to reduce or avoid significant impacts.
This is the same level of environmental analysis that was prepared for the existing 1998-2010
Palo Alto Comprehensive Plan.
City of Palo Alto Page 7
Discussion
With the remaining actions requested, the City Council will consider any final changes to the
text of the Comprehensive Plan Update for addition to Attachment A, address CEQA
requirements and adopt a new general plan for the City of Palo Alto. Once adopted, the plan
would constitute a policy framework to guide decisions about land use and development,
transportation, and infrastructure for the next 13 to 15 years. Each requested action is
described briefly below, with a focus on any unresolved issues.
The List of Corrections and Amendments
Attachment A includes an updated list of corrections and changes to the June 30, 2017 Draft of
the Comprehensive Plan reflecting the Council’s direction to staff on October 30, 2017. These
changes incorporate the PTC’s recommendations and correct mistakes, clarify wording, and
shift some programs to policies, primarily to be consistent with the Final EIR mitigation
measures. All of these changes were accepted by the City Council on October 30, 2017.
In the course of the Council’s discussion on October 30, the Council discussed “community
indicators”, which are metrics used to monitor community characteristics over time in order to
evaluate the effectiveness of policies about growth management and other things. A series of
community indicators were recommended for inclusion in the Comprehensive Plan by the CAC
in September 2016 and considered by the Council in January 2017. At that time, the Council
decided not to include the community indicators, however the PTC recently recommended
their reinstatement and at their meeting on October 30, 2017, the Council agreed on five that
should be included. These are reflected in Item 9 in Attachment A.
The complete list of indicators recommended by the CAC in September 2016 and considered by
the Council in January 2017 is provided at the Council’s request in Table 2, below. Those
marked with a “*” were selected for inclusion in the Comprehensive Plan by Council motion on
October 30, 2017. The table also indicates which metrics are currently reported on.
Table 2. Community Indicators Recommended by the Comprehensive Plan CAC on September
20, 2016 (with additional annotations)
Measure Metric CAC
Recommended
Monitoring
Frequency
Does Staff
Report On
Already?
Greenhouse Gas Emissions* 80% below 1990 emissions by 2030
(S/CAP goal)
At least every 2
years
Yes, Earth Day
Report
Vehicle Miles Traveled (VMT)
per Capita*
5% decrease per year At least every 2
years
Yes, Earth Day
Report
Percent of Commute Trips to
Employment Centers by
50% trips by SOV, based on employee
survey responses
Annually No (TMA and
SRP report)
City of Palo Alto Page 8
Measure Metric CAC
Recommended
Monitoring
Frequency
Does Staff
Report On
Already?
Single Occupant Vehicle
(SOV)
Number of Commute Trips to
Employment Centers
40% below ITE standards for Downtown
and 30% below ITE standards for SRP.
Annually No
Corridor Travel Times Typical PM peak hour travel time along
2 major north-south corridors and 2
major east-west corridors
At least every 2
years
No
Commercial District Parking
Overflow into
Neighborhoods
Non-resident parking on sampled
residential neighborhood streets
Annually No
Air Pollutant Levels Maximum 24-hour concentrations of
criteria pollutants identified by the Bay
Area Air Quality Management District,
as reported at the monitoring stations
closest to Palo Alto
Annually Redwood City
Monitoring
Station data
available
Groundwater Contamination Acres of City underlain by shallow
groundwater contamination
Every 4 years Data is not
readily
available
Jobs/Housing Balance
(Expressed as a Ratio of Jobs
to Employed Residents)*
Ratio of jobs to employed residents Every 4 years Yes
Housing Cost Burden Percentage of owners and renters
paying more than 50% of household
income for housing
Every 4 years Every 8 years
as part of
Housing
Element
Update
Affordability of Housing
Stock
Number of housing units affordable to
moderate-income, low-income, and
very-low-income households
Every 4 years Every 8 years
as part of
Housing
Element
Update
Economic Diversity Percentage of households at various
household income levels [see Fig. 2-3 in
adopted 2015 HE]
Every 4 years Every 8 years
as part of
Housing
Element
Update
Below Market Rate (BMR)
Units*
Number of units Every 4 years Annually as
part of report
to HCD.
Progress toward Housing
Element goals*
Annual Report to State Housing and
Community Development Department
Annually Annually as
part of report
to HCD.
Existing Resident Number of existing units demolished Every 4 years Data on
City of Palo Alto Page 9
Measure Metric CAC
Recommended
Monitoring
Frequency
Does Staff
Report On
Already?
Displacement demolished
units is
available
Unoccupied Homes Number of homes vacant/unoccupied
for longer than 3 months per year
Annually No
Age Diversity Percentage of population in various age
cohorts
Every 4 years Census Data
every 5 years
PAUSD Class Size Class size Annually No – but can
report school
enrollment
PAUSD Satisfaction with
Schools
Satisfaction ratings as reported by
Strategic Plan Survey
Annually Data is
available
Park Acreage per Capita Ratio of district and neighborhood parks
per 1,000 population
Every 4 years No – Data can
be developed
by staff
Urban Tree Canopy Canopy cover – percent of city covered
by trees
Every 4 years No – Estimate
could be
developed by
staff
Infrastructure or Acres
Affected by Sea Level Rise
Number of key facilities, major
infrastructure, and/or acres of land
within the City limits directly affected by
sea level rise
Every 4 years No
Wastewater Reuse Percent of wastewater recycled Every 4 years No
Impermeable Surfaces and
Stormwater Infiltration in
Urbanized Area
(Need to determine how this can be
measured) Decrease in impervious
surface
Every 4 years No –Staff will
begin tracking
in 2018
*Indicates that these items were selected for inclusion in the Comprehensive Plan Update by motion of the City
Council on October 30, 2017.
Source: Comp Plan CAC, September 2016 with annotations indicating measures included in the
Comprehensive Plan Update by City Council Motion October 30, 2017.
On October 30, 2017, the Council also requested that City staff recommend up to three
additional indicators for inclusion in the Comprehensive Plan. Staff will provide these
recommendations in an “at places” memo prior to the Council’s discussion on November 13th.
EIR Certification
Preparation of an EIR is a time-consuming process, involving many steps, each of which takes
considerable time. In the case of the Comprehensive Plan Update EIR, the process began with
issuance of a Notice of Preparation (NOP) in mid-2014. At that time, the Comprehensive Plan
Update project was described as an update of the existing plan to include themes related to
City of Palo Alto Page 10
sustainability and other Council priorities, updated transportation infrastructure improvements,
and goals, policies and programs developed through a community review process. The CEQA
process, which evaluated several planning scenarios in detail, was used in part to help inform
the development of the specific policies in the Comprehensive Plan Update. The entire process,
including City Council sessions to discuss the EIR and EIR scenarios is summarized in Table 3,
below.
Table 3. City Council EIR Review – Key Dates
Date Action
July 28, 2008 City Council and Planning & Transportation Commission held a
joint study session on the work program for the Comp Plan and
EIR
May 30, 2014 Notice of Preparation issued for the Draft EIR
August 4, 2014 City Council scoping session on the Draft EIR
August 6, 2014 City Council continued scoping session on the Draft EIR
January 19, 2016 City Council and Citizens Advisory Committee held a joint study
session on the Draft EIR; City Council discussed two new Comp
Plan scenarios (Scenarios 5 & 6) for analysis in the EIR
February 5 to June 8, 2016 124-day Public comment period for the February 2016 Draft EIR
February 8, 2016 City Council continued discussion of Scenarios 5 & 6
May 16, 2016 City Council provided staff with basic parameters for Scenarios
5 & 6
June 6, 2016 City Council public comment hearing on the February 2016
Draft EIR
January 30, 2017 City Council directed staff to develop a preferred scenario for
inclusion in the Final EIR and defined some of its characteristics
(regarding housing sites, non-residential development cap,
transportation investments, etc.)
February 10 to March 31,
2017
49-day Public comment period for the Supplement to the Draft
EIR
March 20, 2017 City Council public comment hearing on the Supplement to the
Draft EIR
August 30, 2017 Final EIR transmitted to the PTC and City Council. Made
available at libraries, City Hall and to commenters.
September 27, 2017 PTC recommended that the City Council certify the Final EIR.
Source: Planning & Community Environment, September 2017
The Final EIR was published in late August 2017 and was available for PTC review in September
along with its review of the Comprehensive Plan Update. The Final EIR responds to comments
on the February 2016 Draft EIR and the Supplement to the Draft EIR, describes the “preferred
City of Palo Alto Page 11
scenario” based on the Council’s input on March 27, 2017 and May 1, 2017, and presents
revisions to the February 2016 Draft EIR and the Supplement to the Draft EIR.
For a good summary of the EIR’s conclusions, please see Table 1-3, Summary of Impacts and
Mitigation Measures, in the Final EIR. This table is reprinted from the Supplement to the Draft
EIR with revisions resulting from the public review process. Where changes have been made,
they are shown in strikethrough and underline. As shown in Table 1-3, several adjustments
have been made to the mitigation measures in the EIR. Most of these revisions are to ensure
that implementation of mitigation measures is consistent with the policy approach arrived at
through the Comprehensive Plan Update process. None of these revisions weaken the
effectiveness of mitigation measures.
The approach that the City has taken to include policies in the plan to mitigate impacts
identified in the CEQA process is a standard best practice for program-level EIRs that evaluate
general plans. By doing so, the plan becomes largely “self-mitigating” because decisions that
are made subsequent to plan adoption are evaluated for conformity with the plan and thus
must adhere to policies that are protective of the environment. As explained further below,
the CEQA findings in Attachment C provide a detailed crosswalk between the EIR mitigation
measures and the plan policies, showing which policies and programs effectuate the required
mitigation and where additional actions (i.e. not just plan policies) are needed.
Chapter 2 of the Final EIR includes a good summary of the Preferred Alternative and a
comparison to other EIR scenarios (See Table 2-4). The Preferred Alternative, or the preferred
project, grew out of a planning process built around multiple different alternatives or
“scenarios” used to test various policy ideas being considered by the CAC, the City Council, and
the community. As Chapter 2 of the Final EIR indicates, elements of the Preferred Alternative
have been part of the community conversation about the Comprehensive Plan Update and part
of the EIR’s analysis from the very beginning. By analyzing multiple alternatives at an equal
level of detail, the City went above and beyond what is required by CEQA and by using the
alternatives analysis to craft the final preferred alternative, the City used CEQA as it was meant
to be used – as an integral part of its decision making process (California Government Code
Section 21006).
The City received 29 comment letters on the February 2016 Draft EIR and 18 letters on the
Supplement to the Draft EIR, as well as oral comments made during public meetings. Chapter 5
of the Final EIR provides responses to every comment received on the EIR. Chapter 5 of the
Final EIR also contains three “master responses” that provide comprehensive responses to
common topics that arose in the comments received:
Master Response 1 addresses comments related to the merits of the Comp Plan Update,
as opposed the EIR analysis. Because CEQA does not require the Final EIR to respond to
City of Palo Alto Page 12
comments on the merits of the proposed project, Master Response 1 explains how the
City considers these non-CEQA comments.
Master Response 2 addresses comments that requested that the EIR analysis include
recent cumulative projects and plans in nearby jurisdictions that have been proposed or
approved since the Notice of Preparation (NOP) for the Comprehensive Plan EIR was
issued. The response explains that the EIR analysis is based on regional projections that
are large enough to accommodate planned and approved projects in the region through
the year 2030.
Master Response 3 addresses comments regarding the EIR’s analysis of impacts to
schools. The response corrects and supplements information presented in the
Supplement to the Draft EIR and responds to specific comments from the School District
and others on the scope and conclusions of the analysis.
A brief summary of EIR-related comments received at the October 30, 2017 Council meeting
has been included with responses as Attachment G.
To ensure that the EIR is responsive to concerns regarding potential impacts to schools, the City
has coordinated with the Palo Alto Unified School District (PAUSD) at various junctures in the
EIR process. Master Response 3 summarizes the information received from the public and
PAUSD during the EIR’s public review period. Since preparing the Final EIR, the City has also
received additional data from the PAUSD regarding school capacity (see Attachment F). The
updated capacity data is intended to capture factors that lower the effective capacity of
schools, and varies from the capacity data presented in the EIR as follows: elementary school
capacity is lower than presented in the EIR by approximately 1,000 students, middle school
capacity is the same as presented in the EIR, and high school capacity is lower by 100 students.
This reduced capacity data is important for planning purposes but does not substantively affect
the conclusions of the EIR, which as required by State statute, concludes that the payment of
school fees would offset and mitigate potential impacts to schools. Importantly, the City
Council has addressed the issue of school impacts as a policy matter by including a related
policy in the draft Plan:
Policy L-2.11: Ensure regular coordination between the City and PAUSD on land
development activities and trends in Palo Alto, as well as planning for school facilities
and programs. Under State law, impacts on school facilities cannot be the basis for
requiring mitigation beyond the payment of school fees or for denying development
projects or legislative changes that could result in additional housing units. The City will,
however, assess the reasonably foreseeable environmental impacts of development
projects that result in new school construction or enrollment.
Under CEQA, the City Council must consider and “certify” the Final EIR prior to making a
City of Palo Alto Page 13
decision on the plan itself. The Resolution in Attachment B would accomplish this and certify
that the EIR: (1) has been completed in compliance with CEQA, (2) was presented to the Council
and reviewed and considered by them prior to making a decision on the project, and (3) reflects
the City’s independent judgement and analysis. Certifying the EIR does not commit the City to
any specific course of action, but makes it possible for the Council to consider adoption of the
Comprehensive Plan Update itself.
As the Council is aware, CEQA anticipates the potential that agencies will approve projects with
significant and unavoidable impacts, and allows agencies to do so if they adopt findings that the
project’s benefits outweigh the impacts; this is referred to in CEQA as a statement of overriding
considerations. These findings are included in Attachment C, and are necessitated because the
actions and development contemplated under the Comprehensive Plan Update will have
significant and unmitigable impacts related to: contributions of air pollutants to a region that is
in “non-attainment” for ozone and particulates; contributions to traffic congestion at area
intersections; contributions to traffic congestion at freeway ramps; and transit delays due to
traffic congestion. In all cases, the City is proposing to implement mitigation measures, and is
conservatively concluding that the impact will remain significant even after mitigation. As
noted in the proposed findings, these conclusions would be the same for virtually any plan (and
any planning scenario) proposed in the region if it were analyzed using the same thresholds of
significance. In other words, there is no getting away from the fact that we live in a congested
region and that any programmatic EIR that fairly examines cumulative growth over a period of
time will conclude there are unmitigable impacts.
CEQA Findings
Under CEQA, the City Council must also make certain “findings” as part of a decision to
undertake a project for which an EIR has been prepared. The Resolution in Attachment C
contains these findings, which include:
Findings concerning significant impacts and mitigation measures,
Findings concerning the infeasibility of alternatives,
A statement of overriding considerations, and
Adoption of a mitigation monitoring and reporting program (MMRP).
The findings concerning significant impacts and mitigation measures summarize each impact
identified in the EIR, describe the applicable mitigation measures, and state the findings on the
significance of each impact after imposition of the mitigation measures.
The findings concerning the infeasibility of alternatives explain that there are no feasible
alternatives that would substantially lessen the significant impacts of the project and the
City of Palo Alto Page 14
statement of overriding considerations states that there are specific project benefits that
outweigh the significant and unavoidable impacts.
The MMRP is a program spells out how the City will implement and monitor measures that the
EIR incorporates to mitigate or avoid significant environmental effects. In many cases, these
mitigation measures are being implemented by adopting Comprehensive Plan policies that
specifically address the impact identified. For example, policies in the plan regarding land use
compatibility ensure that future developments -- and future capital projects -- are designed to
ensure compatibility and these policies will be implemented as these future projects are
reviewed for conformance with the adopted Comprehensive Plan. In some cases, the
mitigation measures are implemented by making changes to the City’s CEQA procedures or
sections of the Municipal Code and the MMRP provides a timeline for these actions.
The June 30, 2017 Comprehensive Plan Update
On June 12, 2017, City Council referred the current draft of the Comprehensive Plan Update to
the PTC for review and a recommendation. The June 30, 2017 draft Plan reflects the Citizens
Advisory Committee (CAC) May 16, 2017 recommendations to the Council and incorporates
changes based on Council review.
Following Council adoption of the Comprehensive Plan, staff and consultants will create the
final Comprehensive Plan by making any substantive changes to Plan that are directed by
Council motion, including the corrections and changes listed in Attachment E if or as directed by
the City Council. As noted in the recommendation section, above, staff also recommends non-
content (formatting) revisions to create the final Plan. These non-content revisions include:
A graphically rich cover
An Acknowledgement section
An index
Formatting clean-ups, such as updating the footer on each page to say “Adopted [date]”
Agency Consultation
A key part of any general plan update consists of consultation with State and regional agencies
and Native American tribes, as required by various sections of the California Government Code.
Consistent with these requirements, staff provided notice to Native American Tribes in early
February, and copies of the Safety and Natural Environment Elements to State agencies in early
August 2017. Notice to adjacent cities, LACFO, PAUSD, and other agencies were provided in
late-September.
All periods for agency comments (45-days in some cases and 90 days in others) will close prior
to the Council’s hearing on November 13, 2017. In staff’s experience, the City may receive last
City of Palo Alto Page 15
minute comments from one or more agency that require immediate responses or revisions. If
this is the case, staff will provide a recommendation for the Council’s consideration.
The City recently received a letter with comments from San Francisco Public Utilities
Commission (SFPUC), which is included as Attachment E. Staff will provide a response and
recommend additional language for inclusion in the Comprehensive Plan in an “at places”
memo prior to the City Council meeting on November 13th.
Implementation Priorities
The Implementation Chapter of the Comprehensive Plan repeats implementation programs
included in all Elements of the Plan and the City Council has reviewed the programs in that
context. The implementation table also identifies the lead department or agency for each
program, as well as each item’s relative priority and level of effort. These notations
(department, relative priority, level of effort) have not been previously reviewed by the City
Council and currently reflect relative priorities as they were identified by the CAC. While the
City Council’s input on this Chapter is welcome as part of plan adoption, the Chapter is intended
to be reviewed and revised on an annual basis. Staff’s recommendation is to (1) schedule a
separate, in depth discussion of the table in 2018, and (2) identify a few key priorities that the
City Council would like to prioritize in the interim. The Implementation Chapter is a key
mechanism to link the Comprehensive Plan to Palo Alto’s budget process. The priorities, timing
and resource estimates in this chapter are intended to be modified depending on the city’s
budget, available staff resources and other changes over time and do not require a
Comprehensive Plan Amendment.
The PTC is scheduled to review and provide a report on this chapter before the end of the year
and the Council will have an opportunity for in depth review upon receipt of the PTC’s annual
report.
The specific interim actions that staff recommends that the City Council prioritize include:
1. consideration of an updated nexus study and Transportation Impact Fee ordinance by
the Finance Committee and the Council;
2. consideration of the first of several implementing ordinances to amend the Zoning
Ordinance to address Comprehensive Plan programs, prioritizing programs related to
housing production and preservation (for example, incentives for small units, preserving
cottage clusters, minimum densities in multifamily zoning districts, etc.);
3. consideration of actions necessary to initiate a Coordinated Area Plan for the North
Ventura (aka Fry’s) area; and
4. initiation of discussions with Stanford University about the potential for developing
housing in the Stanford Research Park, Stanford Shopping Center, and Stanford
University Medical Center vicinity.
City of Palo Alto Page 16
These items are recommended for prioritization based on individual Councilmember
statements during hearings on the Comprehensive Plan and the EIR, and the Council as a whole
may alter these immediate priorities or defer discussion on them if desired. Many communities
follow adoption of a new general plan with an update of their zoning ordinance. Staff
recommends Palo Alto address necessary changes with a series of ordinances addressing
different subjects, with the first one focusing on housing. If Council wishes to take an alternate
approach, staff will need to return with a detailed scope and cost estimate.
Policy Implications
The Comprehensive Plan is the City’s “constitution” when it comes to land use and
development issues, including transportation and the protection of the environment. The
Comprehensive Plan Update has been crafted by the Citizens Advisory Committee, Planning and
Transportation Commission, and the City Council to perpetuate the overall vision and values of
the current plan, while updating some of its goals, policies, and implementation programs.
Resource Impact
The Comprehensive Plan Update has been a time consuming and costly project for the City.
Current contracts are sufficient to complete the project in accordance with the current
schedule, which envisions plan adoption before Thanksgiving and publication (searchable pdf
and hard copies) thereafter. Additional budgetary resources – and a contract amendment --
would be required if the City Council wishes staff to work with the consultants to develop an
interactive, on-line “users guide” as originally envisioned.
Timeline/Next Steps
Tonight’s hearing is the third and final hearing scheduled for plan adoption. If the Council
cannot complete the requested actions this evening, staff requests that a special hearing be
scheduled to do so before Thanksgiving. Only the requested direction regarding future
implementation tasks may be deferred to 2018 without resulting in an extended delay because
of a new State law (SB 1000) effective January 1, 2018 that would require revisions to the Draft
Plan to address environmental justice.
Environmental Review
A Final Environmental Impact Report (EIR) has been prepared and is proposed for certification.
The Final EIR responds to substantive comments on the Draft EIR and the Supplement to the
Draft EIR and describes the “preferred scenario” based on the Council’s input this spring.
Following certification of the Final EIR, the City Council will consider adoption of CEQA findings,
including adoption of mitigation measures, a statement of overriding considerations, and a
mitigation monitoring and reporting program (MMRP).
Attachments:
City of Palo Alto Page 17
Attachment A: Council Approved Comp Plan Revisions (DOCX)
Attachment B: EIR Resolution (PDF)
Attachment C: Comp Plan EIR CEQA Findings (PDF)
Attachment D: Comp Plan Updated Resolution (PDF)
Attachment E: 10/31/17 SFPUC Comments on Draft Comp Plan (PDF)
Attachment F: Public Letters to Council (PDF)
Attachment G: Responses to EIR Comments from October 30, 2017_Final (DOCX)
Attachment A: Comp Plan Revisions Based on Council Actions on October 30, 2017
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1 Program L1.3.1Policy L-1.4: Commit to creating an inventory of below market rate
housing for purchase and rental. Work with neighbors, neighborhood associations,
property owners and developers to identify barriers to infill development of below
market rate and more affordable market rate housing and to remove these barriers, as
appropriate. Work with these same stakeholders to identify sites and facilitate
opportunities for below market rate housing and housing that is affordable.
PTC Priority 1
2
Move the following policies and programs from the Business and Economics Element to
the Land Use Element under Goal L-4, and re-number both Elements accordingly:
Policy B-2.1: Support local-serving retail, recognizing that it provides
opportunities for local employment, reduced commute times, stronger
community connections and neighborhood orientation.
Program B4.2.1: Revise zoning and other regulations as needed to encourage
the preservation of space to accommodate small businesses, start-ups and
other services.
Program B4.2.2: Consider planning, regulatory, or other incentives to
encourage property owners to include smaller office spaces in their buildings
to serve small businesses, non-profit organizations, and independent
professionals.
Program B4.6.2: Study the overall viability of ground-floor retail requirements
in preserving retail space and creating an active street environment, including
the types of locations where such requirements are most effective.
PTC Priority 2
1 For PTC Priority and PTC Consensus Comments, see the October 23, 2017 Council staff report and Attachment A, available here:
http://www.cityofpaloalto.org/civicax/filebank/documents/61486
For Errata table, see Attachment E of the October 23, 2017 Council staff report, available at the link above.
For original proposed revisions in response to PTC Priority and PTC Consensus Comments and the Errata, see Table X in the October 30, 2017 Council staff report, available
here: http://www.cityofpaloalto.org/civicax/filebank/documents/61767
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Program B4.6.3: Maintain distinct neighborhood shopping areas that are
attractive, accessible and convenient to nearby residents.
3 New Program L2.4.8: Identify development opportunities for BMR and more affordable
market rate housing on publicly-owned properties in a way that is integrated with and
enhances existing neighborhoods.
PTC Priority 3
4 New Program L4.6.2: Study the feasibility of converting parts of University Avenue to a
pedestrian zone. PTC Priority 5
5 New Program T1.2.5: Pursue full participation of Palo Alto employers in the TMA. PTC Priority 6
6 This will be accomplished through the changes to Program L1.3.1, now Policy L-1.4, in
comment PTC Priority 1 above. PTC Priority 7
7 Policy L-1.21: Maintain and strengthenprioritize Palo Alto’s varied residential
neighborhoods while sustaining the vitality of its commercial areas and public facilities.
Move and renumber Policy L-1.1 to L-1.2. No change to policy content.
PTC Priority 8
8 Revise the Introduction page I-2 as follows:
MAINTAINING AND ENHANCING COMMUNITY CHARACTER
The community treasures the special qualities of the city, including its historic buildings,
pedestrian scale, high-quality architecture, thriving urban forest and beautiful streets
and parks. Maintaining the physical qualities of the city is an overarching consideration,
incorporated in all parts of the Plan. The Land Use and Community Design Element
includes specific provisions to maintain Palo Alto’s best features in residential
neighborhoods, commercial centers, and employment districts, and enhance and
improve those areas where these features are lacking. Future land use decisions will
encourage sustainable development, preserve neighborhoods, foster inviting
pedestrian-scale commercial centers and distinct employment districts, and focus infill
within the Urban Service Area.
In addition, see revisions proposed in response to PTC Consensus 1 (to place more
PTC Priority 10
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emphasis on creating neighborhoods) and PTC Priority 2 (to strengthen policies
supporting walkable neighborhoods to ensure that space for professional and personal
services as well as retail uses is available)
9
Add a targeted list of Community Indicators:
MEASURE METRIC
RECOMMENDED
MONITORING
FREQUENCY
Greenhouse Gas
Emissions
80% below 1990
emissions by 2030
(S/CAP goal)
Annually as part of Earth
Day Report
Vehicle Miles Traveled
(VMT) per Capita Decrease year over year Annually as part of Earth
Day Report
Jobs/Housing Balance
(Expressed as a Ratio of
Jobs to Employed
Residents)
Ratio of jobs to
employed residents Every 4 years
Below Market Rate
(BMR) Units Number of units
Annually as part of report
to California Dept. of
Housing and Community
Development (HCD)
Progress toward Housing
Element goals
Annual Report to State
Housing and Community
Development
Department
Annually as part of report
to California Dept. of
Housing and Community
Development (HCD)
PTC Priority 11
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10 Revise Land Use Element Introduction on Page L-1:
The Land Use and Community Design Element … includes policies and programs
intended to balance natural resources with future community needs in a way that
makes optimal use of available land, to create attractive buildings and public spaces
that reinforce Palo Alto’s sense of place and community, to preserve and enhance
quality of life and services in Palo Alto neighborhoods and districts, to support thriving
commercial areas that meet the needs of local residents, and to maintain Palo Alto's
role in the success of the surrounding region.
Revise Policy L-1.6: Use coordinated area plans to guide development, such as to create
or enhance cohesive neighborhoods in areas of Palo Alto where significant change is
foreseeable. Address both land use and transportation, define the desired character
and urban design traits of the areas, identify opportunities for public open space, parks
and recreational opportunities, address connectivity to and compatibility with adjacent
residential areas; and include broad community involvement in the planning process.
[NEW POLICY] [L8]
Revise Policy L-2.3: As a key component of a diverse, inclusive community, allow and
encourage a mix of housing types and sizes, integrated into neighborhoods and
designed for greater affordability, particularly smaller housing types, such as studios,
co-housing, cottages, clustered housing, accessory dwelling units and senior housing.
[(Previous Policy L-13) (Combined with [L47], which is also about encouraging small
units/mix of types)] [L18]
Revise Policy L-2.4: Use a variety of strategies to stimulate housing, near retail,
employment, and transit, in a way that connects to and enhances existing
neighborhoods. [NEW POLICY] [L19]
PTC Consensus 1
11 Revise Transportation Element narrative, page T-2:
Technology has a role to play, whether providing up-to-the-minute information to
inform choices or in delivering new and better modes of travel. Improvements to the
bicycling and pedestrian environment will help encourage more people to bike and
walk on a regular basis. However, the Transportation Element does not rely on future
technological innovations to solve local congestion. Facilitating a shift to alternative
modes of transportation will require creative collaboration among transit agencies,
employers and local jurisdictions as well as residents and commuters themselves.
Revise Policy T-1.3: Reduce GHG and pollutant emissions associated with
transportation by reducing VMT and per-mile emissions through increasing transit
options, supporting biking and walking, and through the use of zero-emission vehicle
technologies to meet City and State goals for GHG reductions by 2030.
PTC Consensus 3
12 Add a new bullet to Program T1.2.2:
Ensure a stable, sustained funding source to support implementation of TDM
measures.
PTC Consensus 6
13 Policy T-6.6: Use engineering, enforcement and educational tools to improve traffic
safety for all users on City roadways.
Program T6.6.2: Continue to provide educational programs for children and adults, in
partnership with community-based educational organizations, to promote safe walking
and the safe use of bicycles, including the City-sponsored bicycle education programs in
the public schools and the bicycle traffic school program for juveniles.
PTC Consensus 8
14 New Policy: Coordinate proactively with the California HSR Authority and Caltrain to
minimize negative impacts and maximize benefits to Palo Alto from any future HSR
service through Palo Alto.
PTC Consensus 9
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15 Add inside front cover:
General City Information: (650) 329-2100
Planning & Community Environment Department: (650) 329-2442
http://www.cityofpaloalto.org/iwantto/
http://www.cityofpaloalto.org/services/paloalto311/
Errata 1
16 Table of Contents:
A foot note shall be added: “The Housing Element is incorporated into the
Comprehensive Plan and can be found at:
http://www.cityofpaloalto.org/civicax/filebank/documents/37935.
Errata 2
17 Regional Commercial Designation:
Regional/Community Commercial: Larger shopping centers and districts that have a
wider variety of goods and services than the neighborhood shopping areas. They rely
on larger trade areas and include such uses as department stores, bookstores,
furniture stores, toy stores, apparel shops, restaurants, theaters and non-retail services
such as offices and banks. Examples include Stanford Shopping Center, Town and
Country Village and University Avenue/Downtown. Non-retail uses such as medical and
dental offices and software development may also locate in this designation; software
development may also locate Downtown. Examples include Stanford Shopping Center,
Town and Country Village and University Avenue/Downtown. In some locations,
residential and mixed use projects may also locate in this category. Non-residential
FARs range from 0.35 to 2.0.
Errata 3
19 Map L-3: City Structure : See revised map L-3 Errata 4
19 Map L-6: Land Use Designations:
Modify the land use designation for the former Hyatt Rickey’s site to remove the Hotel
Overlay (see attached map), so that the property is designated only Multifamily
Residential.
Errata 5
20 Revise page L-2:
The success of the programs in the Natural and Urban Environment and Safety
Elements is are largely dependent on land use decisions that protect the environment
as well as people and property.
Errata 6
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21 Reword Program L-2.4.2 to read: Allow housing on the El Camino Real frontage of the
Stanford Research Park and at Stanford Shopping Center, provided that adequate
parking and vibrant retail is maintained and no reduction of retail square footage
results from the new housing.
Reword Program L-2.4.3 to read: Allow housing on the El Camino Real frontage of the
Stanford Research Park. Explore multi-family housing elsewhere in the Stanford
Research Park and near Stanford University Medical Center (SUMC).
Errata 7
22 Move Policy L-2.9 to become Policy L-4.2 Preserve ground-floor retail, limit the
displacement of existing retail from neighborhood centers and explore opportunities to
expand retail.
Put Programs L4.1.1 and L4.1.2 under this policy and renumber them program LL4.2.1
and L4.2.2
Errata 8
23 Program L4.8.1: Prepare a coordinated area plan for the Fry's site North Ventura area
and surrounding California Avenue area. The plan should describe a vision for the
future of the Fry's site North Ventura area as a walkable neighborhood with multi‐
family housing, ground floor retail, a public park, creek improvements and an
interconnected street grid. It should guide the development of the California Avenue
area as a well-designed mixed use district with diverse land uses and a network of
pedestrian-oriented streets.
Errata 9
24 Policy L-5.4: Maintain the East Bayshore and San Antonio Road/Bayshore Corridor
areas as diverse business and light industrial districts with the approved East Meadow
Circle Concept Plan (Appendix Y of this Comprehensive Plan).
Errata 10
25 Policy L-6.5: Guide development to respect views of the foothills and East Bay hills from
along public streets corridors in the developed portions of the City.
Errata 11
26 Program L-6.6.1: Modify design standards for mixed use projects to ensure that mixed
use development promotes a pedestrian-friendly relationship to the street, including
elements such as screened parking or underground parking, street-facing windows and
entries, and porches, windows, bays and balconies along public ways, and landscaping,
and trees along the street. Avoid blank or solid walls at street level.
Errata 12
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27 Program L7.8.3 Policy L7.11: For proposed exterior alterations or additions to
designated Historic Landmarks, require design review findings that the proposed
changes are in compliance with the Secretary of the Interior Standards for
Rehabilitation.
Errata 13
28 Policy L-7.17: Require project proponents to meet State codes and regulations
regarding the identification and
protection of archaeological and
paleontological deposits, and unique geologic features.
Errata 14
29 L-9.10 Recognize the urban forest as City infrastructure to be maintained in accordance
with applicable guidelines and requirements. [NEW POLICY] [L138]
Errata 15
30 Revise Transportation Element page T-3:
The use of transportation services is beginning to replace private vehicle ownership in
the region, led by a number of prominent ride sharing and e-hailing car
servicestransportation network companies (like Uber and Lyft) that connect passengers
to drivers in private vehicles.
Revise Glossary page 52:
Transportation Network Companies
Companies that connect passengers (often via websites and phone applications) with
drivers who provide transporation in the driver’s non-commercial vehicle. Also known
as “mobility service provders” or “ridesharing companies.”
Errata 16
31 Revise Program T1.2.2:
Establish a mechanism to monitor the success of TDM measures and track the
cumulative reduction of peak hour motor vehicle trips. TDM measures should
at a minimum achieve the following reduction in peak hour motor vehicle trips,
with a focus on single-occupant vehicle trips. Reductions should be based on
the rates included in the Institute of Transportation Engineers’ Trip Generation
Manual for the appropriate land use category and size:
- 50 45 percent reduction in the Downtown district
- 35 percent reduction in the California Avenue area
Errata 17
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- 30 percent reduction in the Stanford Research Park
- 30 percent reduction in the El Camino Real Corridor
- 20 percent reduction in other areas of the city
Require new development projects to pay a Transportation Impact Fee for all
those daily peak-hour motor vehicle trips that cannot be reduced via TDM
measures. Fees collected would be used for capital improvements aimed at
reducing vehicle trips and traffic congestion.
32 Program T1.12.3: Work with VTA to study the feasibility of, and if warranted provide,
traffic signal prioritization for buses at Palo Alto intersections, focusing first on regional
transit routes. Also, advocate for bus service improvements on El Camino Real such as
queue jump lanes and curbside platforms.
Errata 18
33 Program T2.3.1: When adopting new CEQA significance thresholds for VMT for
compliance with SB 743 (2013), adopt standards for vehicular LOS analysis for use in
evaluating the consistency of a proposed project with the Comprehensive Plan, and
also explore desired standards for MMLOS, which includes motor vehicle LOS, at
signalized intersections for use in evaluating the consistency of a proposed project with
the Comprehensive Plan.
Errata 19
34 GOAL T-4 Protect local streets that contribute to neighborhood character and
provide a range of local transportation options.
Errata 20
35 Program T4.2.1 Policy T4.3: Identify specific improvements that can be used to
discourage drivers from using local, neighborhood streets to bypass traffic congestion
on arterials.
Errata 21
36 Policy T-5.12: To promote bicycle use, increase the number of safe, attractive and well-
designed bicycle parking spaces available in the city, including spots for diverse types of
bicycles and associated equipment, including bicycle trailers, prioritizing heavily
travelled areas such as commercial and retail centers, employment districts,
recreational/cultural facilities, multi-modal transit facilities and ride share stops for
bicycle parking infrastructure.
Errata 22
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37 Program T6.1.1: Follow the principles of the safe routes to schools program to
implement traffic safety measures that focus on safe routes to work, shopping,
downtown, community services, parks and schools including all designated school
commute corridors. [NEW PROGRAM] [T135]
Errata 23
38 Policy T-8.1: Engage in regional transportation planning to reduce congestion and
reduce single-occupant vehicle trips, and advocate for specific transit improvements
and investments, such as Caltrain service enhancements and grade separations,
Dumbarton Express service, enhanced bus service on El Camino Real with queue
jumping and curbside platforms, HOV/HOT lanes and additional VTA bus service.
Program T8.6.21.2.2: Advocate for improved connectivity to transit to serve workers
who live in the South Bay and work in Palo Alto.
Policy T-8.2 Participate in regional planning initiatives for the rail corridor and
provide a strong guiding voice.
Policy T-8.3 Collaborate effectively with and engage in regional partnerships and
solutions with a range of stakeholders, including regional agencies, neighboring
jurisdictions and major employers, on issues of regional importance such as traffic
congestion, reduced reliance on single-occupant vehicles and sustainable
transportation.
Program T8.3.1: Continue to participate in regional efforts to develop technological
solutions that make alternatives to the automobile more convenient and thereby
contribute to reducing congestion.
Policy T-8.4: Coordinate with local and regional agencies and Caltrans to support
regional efforts to maintain and improve transportation infrastructure in Palo Alto,
including the Multi-Modal Transit Center.
Policy T-8.5 Support the efforts of MTC to coordinate transportation planning and
Errata 24
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services for the Mid-Peninsula and the Bay Area that emphasize alternatives to the
automobile.
Policy T-8.6: Advocate for efforts by Caltrans and the Valley Transportation Authority to
reduce congestion and improve traffic flow on existing freeway facilities consistent with
Statewide GHG emissions reduction initiatives. (Comp Plan Draft EIR Mitigation
Measure Trans-3b)]
Program T8.6.1: Advocate for provision of a new southbound entrance ramp to
Highway 101 from San Antonio Road, in conjunction with the closure of the
southbound Charleston Road on-ramp at the Rengstorff Avenue interchange in
Mountain View.
Policy T-8.7: Support the application of emerging freeway information, monitoring and
control systems that provide non-intrusive driver assistance and reduce congestion.
(Comp Plan Draft EIR Mitigation Measure Trans-3b)]
Policy T-8.8: Where appropriate, support the conversion of existing traffic lanes to
exclusive bus and HOV lanes or Express/HOT lanes on freeways and expressways,
including the Dumbarton Bridge, and the continuation of an HOV lane from Redwood
City to San Francisco. (Comp Plan Draft EIR Mitigation Measure Trans-3b)]
Policy T-8.9: Support State and federal legislation to reduce motor vehicle emissions,
noise and fuel consumption.
Policy T-8.10: Support plans for intra-county and transbay transit systems that link Palo
Alto to the rest of Santa Clara County and adjoining counties. Ensure that these
systems and enhancements do not adversely impact the bay.
Program T8.10.1: Work with regional transportation providers, including BART and
Caltrain, to improve connections between Palo Alto and the San Francisco
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International Airport and Norman Y. Mineta San Jose International Airport.
Policy T-8.11: Support regional bicycle and pedestrian plans, to complete including
development of the Bay Trail, and the Bay-to-Ridge Trail, and the Santa Clara County
Countywide Bicycle System.
Policy T-8.12 Support the development of the Santa Clara County Countywide
Bicycle System, and other regional bicycle plans.
39 Program N4.7.2 Policy N-4.9: Work with neighboring jurisdictions and regional agencies
to protect groundwater.
Errata 25
40 Program N5.1.2 Policy N-5.5: Support the Bay Area Air Quality Management District
(BAAQMD) in its efforts to achieve compliance with existing air quality regulations by
continuing to require development applicants to comply with BAAQMD construction
emissions control measures and health risk assessment requirements.
Errata 26
41 NEW POLICY N-5.5: Mitigate potential sources of toxic air contaminants through siting
or other means to reduce human health risks and meet the Bay Area Air Quality
Management District’s applicable threshold of significance. When siting new sensitive
receptors such as schools, day care facilities, parks or playgrounds, medical facilities
and residences within 1,000’ of stationary sources of toxic air contaminants or
roadways used by more than 10,000 vehicles per day, require projects to consider
potential health risks and incorporate adequate precautions such as high-efficiency air
filtration into project design.
Errata 27
42 Program N6.12.1: Continue working to reduce noise associated with operations of the
Palo Alto Airport. Also, eEnsure compliance with the land use compatibility standards
for community noise environments, shown in Table N-1, by prohibiting incompatible
land use development within the 60 dBA CNEL noise contours of the airport.
Errata 28
43 Program N6.11.1: For larger development projects that demand intensive construction
periods and/or use equipment that could create vibration impacts, such as the
Stanford University Medical Center or major grade separation projects, require a
vibration impact analysis, as well as formal, ongoing monitoring and reporting of noise
Errata 29
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levels, throughout the entire construction process, pertinent to industry standards.
The monitoring plan should identify hours of operation and could include information
on the monitoring locations, durations and regularity, the instrumentation to be used
and appropriate noise control measures to ensure compliance with the noise
ordinance. [(NEW PROGRAM)(Comp Plan Draft EIR Mitigation Measure NOISE-1c, 5a)]
[N152]
44 Safety Element narrative , page S-12:
UTILITIES
In Palo Alto, utility services are provided by The City of Palo Alto Utilities (CPAU), a city-
owned utility. Today, CPAU provides six services that include electric, fiber optic, natural
gas, water and wastewater services. Initially formed in 1896 with the installation of a
water supply system, CPAU expanded between the years 1898 and 1917 to include
wastewater, electric, and natural gas distribution services; in 1996 it began to provide
fiber optic services. Through its mission to provide safe, reliable, environmentally
sustainable and cost effective services to Palo Alto residents, CPAU offers cost-effective
service rates to residents and re-invests proceeds to support other City community
services and facilities. For example, CPAU provides financial support to the Palo Alto
library and parks system, as well as to support police and fire protection services.
Errata 30
45 Program S-1.10.3: Implement the mitigation strategies and guidelines provided by the
LHMP, including those that address evolving hazards resulting from climate change.
Errata 31
46 Program S-2.8.3 Policy S-2.9: Partner with appropriate agencies to expand flood zones
as appropriate due to sea level rise, changes in creek channels, street flooding or storm
drain overload due to increased likelihood of extreme storm events caused by climate
change.
Errata 32
47 Glossary, page 26:
Infill: Development of individual vacant lots or underused lots leftover vacant
properties within areas that are already developed in built up sites or areas.
Errata 33
Not Yet Approved
170901 jb Lee/Planning/LongRange/Comp Plan
Resolution No _____
Resolution of the Council of the City of Palo Alto Certifying Adequacy of the Final
Environmental Impact Report for the City of Palo Alto Comprehensive Plan Update in
Accordance with the California Environmental Quality Act
RECITALS
A. The City of Palo Alto, a chartered municipal corporation (“City”) has prepared that
certain comprehensive update to its general plan, entitled “Our Palo Alto 2030” (referred to herein
as the “Comprehensive Plan Update”), proposed for approval and adoption by the City Council.
B. Approval of the Comprehensive Plan Update would constitute a project under the
provisions of the California Environmental Quality Act of 1970, together with related state
implementation guidelines promulgated thereunder (“CEQA”).
C. The City, in compliance with CEQA, prepared an Environmental Impact Report (EIR)
to provide an assessment of the potential environmental consequences of adopting and
implementing the proposed Comprehensive Plan Update and associated zoning amendments. The
environmental review process under CEQA commenced and was undertaken concurrently with the
preparation and consideration of the Comprehensive Plan Update.
D. A Draft Environmental Impact Report (“Draft EIR”) for the Comprehensive Plan
Update was prepared analyzing four alternatives (also referred to as “scenarios”) in equal level of
detail, and was circulated for public review from February 5, 2016 to June 8, 2016. The City held
several public hearings to receive comments on the Draft EIR.
E. During the Comprehensive Plan development and review process, the City Council
directed the evaluation of two additional alternatives or scenarios, which were subsequently
analyzed in a Supplement to the Draft EIR that was circulated for public review from February 10,
2017 to March 31, 2017, during which time the City Council and Planning and Transportation
Commission held additional public hearings to receive comments on the Draft EIR and the
Supplement.
F. Through its review of the Citizens Advisory Committee’s recommendations over
several duly noticed public hearings, the City Council identified the parameters of the preferred
alternative for the Comprehensive Plan Update.
G. A Final Environmental Impact Report was prepared, which Final Environmental
Impact Report is comprised of the Draft EIR dated February 5, 2016, together with the Supplement
to the Draft EIR dated February 10, 2017, and the Final Environmental Impact Report dated August
30, 2017 (collectively, all of said documents are referred to herein as the “Final EIR”).
H. Prior to the adoption of this Resolution, the Planning and Transportation
Commission of the City of Palo Alto, on September 27, 2017, reviewed the Final EIR prepared for
the Comprehensive Plan Update (also sometimes referred to herein as the “Project”), held a public
hearing, and recommended to the City Council that it certify and find the Final EIR was completed in
accordance with the requirements of CEQA.
Not Yet Approved
170901 jb Lee/Planning/LongRange/Comp Plan
I. Public notice was duly given that on October 23, 2017 at 5:00 p.m. in the Council
Chambers at City Hall, 285 Hamilton Avenue, Palo Alto, California, the Council would hold a public
hearing where interested persons could appear, be heard, and present their views with respect to
the proposed Comprehensive Plan Update and the Final EIR, and at the noticed date and time, the
Council gave all persons full opportunity to be heard and to present their views with respect to the
proposed Comprehensive Plan Update and the Final EIR.
J. The Council is the decision-making body for adoption of the proposed
Comprehensive Plan Update.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PALO ALTO AS
FOLLOWS:
The City Council (hereinafter the “Council”), in the exercise of its independent judgment as
the decision-making body for the City of Palo Alto as Lead Agency, makes and adopts the following
findings and certifications in compliance with the requirements of CEQA:
1. The Council has independently reviewed and considered the Final EIR.
2. The Council does hereby find and certify that the Final EIR has been prepared and
completed in compliance with CEQA.
3. The Council does hereby find and certify that the Final EIR reflects the City of Palo Alto’s
independent judgment and analysis.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
__________________________ _____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
__________________________ _____________________________
Assistant City Attorney City Manager
_____________________________
Director of Planning and
Community Environment
Not Yet Approved
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 1
Resolution No _____
Resolution of the Council of the City of Palo Alto Making Certain
Findings Concerning Significant Environmental Impacts, Mitigation
Measures and Alternatives, Adopting a Mitigation Monitoring and
Reporting Program, and Adopting a Statement of Overriding
Considerations for the Comprehensive Plan Update, For Which an
Environmental Impact Report Was Prepared in Accordance with the
California Environmental Quality Act
RECITALS
A. The City of Palo Alto, a municipal corporation (“City”) has prepared that certain
comprehensive update to its general plan, entitled “Our Palo Alto 2030” (referred to herein as
the “Comprehensive Plan Update”), proposed for approval and adoption by the City Council.
B. Approval of the Comprehensive Plan Update would constitute a project under the
provisions of the California Environmental Quality Act of 1970, together with related state
implementation guidelines promulgated thereunder (“CEQA”).
C. The City Council, in compliance with CEQA, prepared an Environmental Impact
Report (EIR) to provide an assessment of the potential environmental consequences of
adopting and implementing the proposed Comprehensive Plan Update and associated zoning
amendments.
D. The environmental review process under CEQA commenced and was undertaken
concurrently with the preparation and consideration of the Comprehensive Plan Update, which
included the participation of a Citizens Advisory Committee (“CAC”) that met for almost two
years and hearings before the City Council to consider the CAC recommendations. This process
allowed the Comprehensive Plan Update to take into account any potential environmental
impacts identified in the EIR and include policies to address those impacts.
E. A Draft Environmental Impact Report (“Draft EIR”) for the Comprehensive Plan
Update was prepared analyzing four alternatives (also referred to as “scenarios”) in equal level
of detail. The Draft EIR was circulated for public review from February 5, 2016 to June 8, 2016,
during which time the City held several public hearings to receive comments on the Draft EIR.
F. During the Comprehensive Plan development and review process, the City Council
directed the evaluation of two additional alternatives or scenarios, which were subsequently
analyzed in a Supplement to the Draft EIR that was circulated for public review from February
10, 2017 to March 31, 2017, during which time the City Council and Planning and
Transportation Commission held additional public hearings to receive comments on the Draft
EIR and the Supplement.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 2
G. After receiving the CAC’s recommendations on the Comprehensive Plan Update, the
City Council identified the parameters of the preferred alternative through several public
hearings.
H. A Final Environmental Impact Report was prepared, which Final Environmental
Impact Report is comprised of the Draft EIR dated February 5, 2016, together with the
Supplement to the Draft EIR dated February 10, 2017, and the Final Environmental Impact
Report dated August 30, 2017 (collectively, all of said documents are referred to herein as the
“EIR”).
I. Prior to the adoption of this Resolution, the Planning and Transportation
Commission of the City of Palo Alto, on September 27, 2017, reviewed the EIR prepared for the
Comprehensive Plan Update (also sometimes referred to herein as the “Project”), held a public
hearing, and recommended to the City Council that it certify and find the Final EIR was
completed in accordance with the requirements of CEQA.
J. On ___________, the Council held a duly noticed public hearing on the
Comprehensive Plan Update and EIR, and certified the EIR in accordance with CEQA by
adoption of Resolution No. _______.
K. The Council is the decision-making body for adoption of the proposed
Comprehensive Plan Update.
L. CEQA requires that in connection with approval of a project for which an
environmental impact report has been prepared that identifies one or more significant
environmental effects of the project, the decision-making body of a public agency make certain
findings regarding those effects.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PALO ALTO AS
FOLLOWS:
The City Council, in the exercise of its independent judgment, makes and adopts the following
findings to comply with the requirements of CEQA, including Sections 15091, 15092, and 15093
of the CEQA Guidelines, based upon the entire record of proceedings for the Project. All
statements set forth in this Resolution constitute formal findings of the City Council, including
the statements set forth in this paragraph and in the recitals above.
1. The City Council was presented with, and has independently reviewed and analyzed the
EIR and other information in the record and has considered the information contained
therein prior to acting upon and approving the Project, and bases the findings stated
below on such review.
2. The EIR provides an adequate basis for considering and acting upon the Comprehensive
Plan Update Project. The City Council has considered all of the evidence and arguments
presented during consideration of the Project and the Final EIR. In determining whether
the Project may have a significant impact on the environment, and in adopting the
findings set forth herein, the City Council certifies that it has complied with Public
Resources Code Sections 21081, 21081.5, and 21082.2.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 3
3. The City Council agrees with the characterization of the EIR with respect to all impacts
initially identified as “less than significant” and finds that those impacts have been
described accurately and are less than significant as so described in the Final EIR. This
finding does not apply to impacts identified as significant or potentially significant that
are reduced to a less than significant level by mitigation measures included in the EIR.
The disposition of each of those impacts and the mitigation measures adopted to
reduce them are addressed specifically in the findings below.
4. The Mitigation Monitoring and Reporting Program (MMRP) includes all mitigation
measures adopted with respect to the Project and explains how and by whom they will
be implemented and enforced.
5. The EIR considers a reasonable range of potentially feasible alternatives, sufficient to
foster informed decision making, public participation and a reasoned choice, in
accordance with CEQA.
6. The Final EIR contains responses to comments received on a Draft EIR and a Supplement
to the Draft EIR. The Final EIR also contains corrections and clarifications to the text and
analysis of the Draft EIR and Supplement to the Draft EIR, where warranted. The City
Council does hereby find that such changes and additional information are not
significant new information under CEQA because such changes and additional
information do not indicate that any of the following would result from approval and
implementation of the Project: (i) any new significant environmental impact or
substantially more severe environmental impact (not already disclosed and evaluated in
the DEIR and Supplement to the Draft EIR), (ii) any feasible mitigation measure
considerably different from those analyzed in the Draft EIR and Supplement to the Draft
EIR that would lessen a significant environmental impact of the Project has been
proposed and would not be implemented, or (iii) any feasible alternative considerably
different from those analyzed in the DEIR and the Supplement to the Draft EIR that
would lessen a significant environmental impact of the Project has been proposed and
would not be implemented. The City Council does find and determine that recirculation
of the Final EIR for further public review and comment is not warranted or required
under the provisions of CEQA.
7. The City Council does hereby make the following findings with respect to significant
effects on the environment of the Project, as identified in the EIR, with the
understanding that all of the information in this Resolution is intended as a summary of
the full administrative record supporting the EIR, which full administrative record should
be consulted for the full details supporting these findings.
I. STATUTORY REQUIREMENTS FOR FINDINGS
Significant effects of the Comprehensive Plan Update project were identified in the Draft EIR
and the Supplement to the Draft EIR. CEQA §21081 and CEQA Guidelines §15091 require that
the Lead Agency prepare written findings for identified significant impacts, accompanied by a
brief explanation of the rationale for each finding. Less than significant effects (without
mitigation) of the project were also identified in the Draft EIR and the Supplement to the Draft
EIR. CEQA does not require that the Lead Agency prepare written findings for less than
significant effects.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 4
CEQA requires that the Lead Agency adopt mitigation measures or alternatives, where feasible,
to avoid or mitigate significant environmental impacts that would otherwise occur with
implementation of the project. Project mitigation or alternatives are not required, however,
where substantial evidence in the record demonstrates that they are infeasible or where the
responsibility for modifying the project lies with another agency. Specifically, CEQA Guidelines
§15091 states:
(a) No public agency shall approve or carry out a project for which an EIR has been certified
which identifies one or more significant environmental effects of the project unless the
public agency makes one or more written findings for each of those significant effects,
accompanied by a brief explanation of the rationale for each finding. The possible
findings are:
(1) Changes or alterations have been required in, or incorporated into, the project
which avoid or substantially lessen the significant environmental effect as identified
in the final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another
public agency and not the agency making the finding. Such changes have been
adopted by such other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including
provision of employment opportunities for highly trained workers, make infeasible
the mitigation measures or project alternatives identified in the final EIR.
The “changes or alterations” referred to in §15091(a)(1) above, that are required in, or
incorporated into, the project which mitigate or avoid the significant environmental effects of
the project, may include a wide variety of measures or actions as set forth in Guidelines
§15370, including avoiding, minimizing, rectifying, or reducing the impact over time, or
compensating for the impact by replacing or providing substitute resources.
II. FINDINGS ON SIGNIFICANT IMPACTS AND MITIGATION MEASURES
Pursuant to Public Resources Code Section 21081 and CEQA Guidelines Section 15091, the City
Council hereby makes these findings with respect to the potential for significant environmental
impacts from adoption and implementation of the Comprehensive Plan Update and Zoning
Code amendments ("proposed project") and the means for mitigating those impacts. For the
purpose of these findings, the term “Environmental Impact Report” (EIR) means the Draft EIR,
Supplement to the Draft EIR, and Final EIR documents collectively, unless otherwise specified.
These findings do not attempt to describe the full analysis of each environmental impact
contained in the EIR. Instead, the findings provide a summary description of each impact,
describe the applicable mitigation measures identified in the EIR and adopted by the City, and
state the findings on the significance of each impact after imposition of the adopted mitigation
measures. A full explanation of these environmental findings and conclusions can be found in
the EIR. These findings hereby incorporate by reference the discussion and analysis in the EIR
that support the EIR's determinations regarding significant project impacts and mitigation
measures designed to address those impacts. The facts supporting these findings are found in
the record as a whole for the project.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 5
In making these findings, the City ratifies, adopts, and incorporates into these findings the
analysis and explanation in the EIR, and ratifies, adopts, and incorporates into these findings
the determinations and conclusions of the EIR relating to environmental impacts and mitigation
measures, except to the extent that any such determinations and conclusions are specifically
and expressly modified by these findings.
Aesthetics
Impact AES-1: Implementation of the proposed Plan would have the potential to substantially
degrade the existing visual character or quality of the area and its surroundings.
Mitigation Measure AES-1: To ensure that increased residential densities would not degrade
the visual character or quality of the area, the proposed Plan shall include policies that achieve
the following:
High-quality building and site design.
Compatibility with the neighborhood and adjacent structures.
Enhancement of existing commercial centers.
Requirements for landscaping and street trees.
Preservation and creation of a safe and inviting pedestrian environment.
Appropriate building form, massing, and setbacks.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively ensure
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy L-2.12: Encourage new development and redevelopment to incorporate greenery and
natural features such as green rooftops, pocket parks, plazas and rain gardens.
Policy L-3.1: Ensure that new or remodeled structures are compatible with the
neighborhood and adjacent structures.
Policy L-4.5: Maintain and enhance the University Avenue/Downtown area as a major
commercial center of the City, with a mix of commercial, civic, cultural, recreational and
residential uses. Promote quality design that recognizes the regional and historical
importance of the area and reinforces its pedestrian character.
Policy L-4.7: Maintain Stanford Shopping Center as one of the Bay Area’s premiere regional
shopping centers. Promote bicycle and pedestrian use and encourage any new development
at the Center to occur through infill.
Policy L-4.8: Maintain the existing scale, character and function of the California Avenue
business district as a shopping, service and office center intermediate in function and scale
between Downtown and the smaller neighborhood business areas.
Policy L-4.10: Recognize and preserve Town and Country Village as an attractive retail center
serving Palo Altans and residents of the wider region. Future development at this site should
preserve its existing amenities, pedestrian scale and architectural character while also
improving safe access for bicyclists and pedestrians and increasing the amount of bicycle
parking.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 6
Policy L-4.15: Encourage maximum use of Neighborhood Centers by ensuring that the
publicly maintained areas are clean, well-lit and attractively landscaped.
Policy L-5.2: Provide landscaping, trees, sidewalks, pedestrian path and connections to the
citywide bikeway system within Employment Districts. Pursue opportunities to include
sidewalks, paths, low water use landscaping, recycled water and trees and remove grass turf
in renovation and expansion projects.
Policy L-6.1: Promote high-quality design and site planning that is compatible with
surrounding development and public spaces.
Policy L-6.2: Use the Zoning Ordinance, design review process, design guidelines and
Coordinated Area Plans to ensure high quality residential and commercial design and
architectural compatibility.
Policy L-9.3: Treat residential streets as both public ways and neighborhood amenities.
Provide and maintain continuous sidewalks, healthy street trees, benches and other
amenities that promote walking and “active” transportation.
Policy T-3.7: Encourage pedestrian-friendly design features such as sidewalks, street trees,
on-street parking, gathering spaces, gardens, outdoor furniture, art and interesting
architectural details.
Policy T-3.8: Add planting pockets with street trees to provide shade, calm traffic and
enhance the pedestrian realm.
Policy T-6.1: Continue to make safety the first priority of citywide transportation planning.
Prioritize pedestrian, bicycle and automobile safety over motor vehicle level of service at
intersections and motor vehicle parking.
Policy N-2.8: Require new commercial, multi-unit and single-family housing projects to
provide street trees and related irrigation systems.
The incorporation of relevant policies into the proposed Plan ensures that future development
and capital improvements under the proposed Plan would avoid significant degradation of the
existing visual character and quality.
Resulting Significance: Less than Significant
Impact AES-4: Implementation of the proposed Plan would have the potential to substantially
shadow public open space (other than public open streets and adjacent sidewalks) between
9:00 a.m. and 3:00 p.m. from September 21 to March 21.
Mitigation Measure AES-4: The City shall amend its local CEQA guidelines to require
development projects of a certain size or location to prepare an analysis of potential
shade/shadow impacts. The analysis shall focus on potential impacts to public open spaces
(other than public streets and adjacent sidewalks) between 9:00 a.m. and 3:00 p.m. from
September 21 to March 21. The analysis shall identify whether the project would shadow open
spaces during these times, explain how the project meets City design requirements and other
City policy goals, and describe ways to mitigate substantial shade and shadow impacts through
feasible building and site design features.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 7
Rationale for Finding: Mitigation Measure AES-4 would amend the City’s local CEQA guidelines
to require project-level analysis of potential shade/shadow impacts, as well as measures to
mitigate potential impacts through feasible building and site design features. Implementation
of this mitigation measure would ensure the future development projects and capital
improvement projects that are subject to CEQA would disclose and avoid potential
shade/shadow impacts to the extent feasible.
Resulting Significance: Less than Significant
Air Quality
Impact AIR-1: Without inclusion of air quality policies, implementation of the proposed Plan
could conflict with or obstruct implementation of the applicable air quality plan.
Mitigation Measure AIR-1: To ensure consistency with the 2010 Bay Area Clean Air Plan, the
proposed Plan shall include policies that achieve the following:
Reduction in emissions of particulates from automobiles, manufacturing, construction
activity, and other sources (e.g., dry cleaning, wood burning, landscape maintenance).
Support for regional, State, and federal programs that improve air quality.
Support for transit, bicycling, and walking.
Mix of uses (e.g., housing near employment centers) and development types (e.g., infill) to
reduce the need to drive.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively ensure
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy L-1.1: Limit future urban development to currently developed lands within the urban
service area. The boundary of the urban service area is otherwise known as the urban
growth boundary. Retain undeveloped land west of Foothill Expressway and Junipero Serra
as open space, with allowances made for very low-intensity development consistent with
the open space character of the area. Retain undeveloped land northeast of Highway 101 as
open space.
Policy L-2.1: Maintain a citywide structure of Residential Neighborhoods, Centers and
Employment Districts. Integrate these areas with the City’s and the region’s transit and
street system.
Policy L-2.2: Enhance connections between commercial and mixed use centers and the
surrounding residential neighborhoods by promoting walkable and bikeable connections
and a diverse range of retail and services that caters to the daily needs of residents.
Policy L-2.3: As a key component of a diverse, inclusive community, allow and encourage a
mix of housing types and sizes designed for greater affordability, particularly smaller housing
types, such as studios, cohousing, cottages, clustered housing, accessory dwelling units and
senior housing.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 8
Policy L-2.4: Use a variety of strategies to stimulate housing near retail, employment, and
transit.
Policy L-2.6: Create opportunities for new mixed use development consisting of housing and
retail.
Policy T-1.1: Take a comprehensive approach to reducing single-occupant vehicle trips by
involving those who live, work and shop in Palo Alto in developing strategies that make it
easier and more convenient not to drive.
Policy T-1.6: Encourage innovation and expanded transit access to regional destinations,
multi-modal transit stations, employment centers and commercial centers, including
those within Palo Alto through the use of efficient public and/or private transit options such
as rideshare services, on-demand local shuttles and other first/last mile connections.
Policy T-1.16: Promote bicycle use as an alternative way to get to work, school, shopping,
recreational facilities and transit stops.
Policy T-1.19: Provide facilities that encourage and support bicycling and walking.
Policy T-5.12: To promote bicycle use, increase the number of safe, attractive and well-
designed bicycle parking spaces available in the city, including spots for diverse types of
bicycles and associated equipment, including trailers, prioritizing heavily travelled areas such
as commercial and retail centers, employment districts, recreational/cultural facilities, multi-
modal transit facilities and ride share stops for bicycle parking infrastructure.
Policy T-6.1: Continue to make safety the first priority of citywide transportation planning.
Prioritize pedestrian, bicycle and automobile safety over motor vehicle level of service at
intersections and motor vehicle parking.
Policy N-5.1: Support regional, State, and federal programs that improve air quality in the
Bay Area because of its critical importance to a healthy Palo Alto.
Policy N-5.2: Support behavior changes to reduce emissions of particulates from
automobiles.
Policy N-5.3: Reduce emissions of particulates from, manufacturing, dry cleaning,
construction activity, grading, wood burning, landscape maintenance, including leaf blowers
and other sources.
The incorporation of relevant policies into the proposed Plan ensures that future development
projects and capital improvement projects under the proposed Plan will support emissions
reductions, support air quality improvement programs, support alternative modes of transport,
and support reduced driving. In this way, Mitigation Measure AIR-1 would support BAAQMD’s
implementation of control measures in the 2010 Bay Area Clean Air Plan.
Resulting Significance: Less than Significant
Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard;
contribute substantially to an existing or project air quality violation; and/or result in a
cumulatively considerable net increase of any criteria pollutant for which the Project region is
nonattainment under an applicable federal or State ambient air quality standard (including
releasing emissions which exceed quantitative thresholds for ozone precursors).
Mitigation Measure AIR-2a: The City shall amend its local CEQA Guidelines and Municipal Code
to require, as part of the City’s development approval process, that future development projects
to comply with the current BAAQMD basic control measures for reducing construction
emissions of PM10 (Table 8-2, Basic Construction Mitigation Measures Recommended for All
Proposed Projects, of the BAAQMD CEQA Guidelines).
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 9
Mitigation Measure AIR-2b: The City shall amend its local CEQA Guidelines to require that,
prior to issuance of construction permits, development project applicants that are subject to
CEQA and have the potential to exceed the BAAQMD screening-criteria listed in the BAAQMD
CEQA Guidelines prepare and submit to the City of Palo Alto a technical assessment evaluating
potential project construction-related air quality impacts. The evaluation shall be prepared in
conformance with BAAQMD methodology in assessing air quality impacts. If construction-
related criteria air pollutants are determined to have the potential to exceed the BAAQMD
thresholds of significance, as identified in the BAAQMD CEQA Guidelines, the City of Palo Alto
shall require that applicants for new development projects incorporate mitigation measures
(Table 8-3, Additional Construction Mitigation Measures Recommended for Projects with
Construction Emissions Above the Threshold, of the BAAQMD CEQA Guidelines or applicable
construction mitigation measures subsequently approved by BAAQMD) to reduce air pollutant
emissions during construction activities to below these thresholds. These identified measures
shall be incorporated into all appropriate construction documents (e.g., construction
management plans) submitted to the City.
Mitigation Measure AIR-2c: To ensure that development projects that have the potential to
exceed the BAAQMD screening criteria air pollutants listed in the BAAQMD CEQA Guidelines
reduce regional air pollutant emissions below the BAAQMD thresholds of significance, the
proposed Plan shall include policies that require compliance with BAAQMD requirements,
including BAAQMD CEQA Guidelines.
Mitigation Measure AIR-2d: Implement Mitigation Measures TRANS-1a and TRANS-1b. In
addition, to reduce long-term air quality impacts by emphasizing walkable neighborhoods and
supporting alternative modes of transportation, the proposed Plan shall include policies that
achieve the following:
Enhanced pedestrian and bicycle connections between commercial and mixed-use centers.
Finding: Changes or alterations have been required in, or incorporated into, the proposed
project, which avoid or substantially lessen the significant environmental effect identified in the
EIR, but not to a level of less than significant. There are no additional feasible mitigation
measures and no feasible alternatives that avoid this significant effect, as further addressed in
Section III, Findings Concerning Alternatives.
Rationale for Finding: The City is located in a region that is in “nonattainment” for ozone and
particulates. While the mitigation measures listed below would reduce emissions of these
pollutants, they cannot eliminate Palo Alto’s contribution to regional air quality problems.
Mitigation Measure AIR-2a would require adherence to the current BAAQMD basic control
measures for reducing construction emissions of PM10.
Mitigation Measure AIR-2b would require implementation of BAAQMD-approved mitigation
measures, if future development projects in Palo Alto could generate construction exhaust
emissions in excess of the BAAQMD significance thresholds. An analysis of emissions generated
from the construction of specific future projects under the proposed Plan would be required to
evaluate emissions compared to BAAQMD’s project-level significance thresholds during
individual environmental review.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 10
To implement Mitigation Measure AIR-2c, the proposed Plan includes Policy N-5.2 and would
apply to future development projects and capital improvements projects that are subject to
CEQA. Policy N-5.2 states: “Support the Bay Area Air Quality Management District (BAAQMD) in
its efforts to achieve compliance with existing air quality regulations by continuing to require
development applicants to comply with BAAQMD construction emissions control measures and
health risk assessment requirements.”
Through Mitigation Measure TRANS-1a and proposed Policy L-2.2, the City would ensure that
future development projects and capital improvement projects: “Enhance connections between
commercial and mixed use centers and the surrounding residential neighborhoods by
promoting walkable and bikeable connections and a diverse range of retail and services that
caters to the daily needs of residents.” However, , analysis of post-mitigation conditions in the
Supplement to the Draft EIR shows that implementation of transportation mitigation measures
would nominally reduce emissions but would not reduce emissions below BAAQMD’s project-
level thresholds, which, based on BAAQMD guidance, are generally used to determine if a
project generates a substantial increase in emissions. Therefore, no additional mitigation
measures are available and the impact is considered significant and unavoidable.
Resulting Significance: Significant and Unavoidable
Impact AIR-3: Implementation of the proposed Plan would expose sensitive receptors to
substantial concentrations of air pollution.
Mitigation Measure AIR-3a: The City of Palo Alto shall update its CEQA Procedures to require
that future non-residential projects within the city that: 1) have the potential to generate 100 or
more diesel truck trips per day or have 40 or more trucks with operating diesel-powered TRUs,
and 2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, nursing
homes), as measured from the property line of a proposed project to the property line of the
nearest sensitive use, shall submit a health risk assessment (HRA) to the City of Palo Alto prior
to future discretionary project approval or shall comply with best practices recommended for
implementation by the BAAQMD.
The HRA shall be prepared in accordance with policies and procedures of the State Office of
Environmental Health Hazard Assessment and the Bay Area Air Quality Management District. If
the HRA shows that the incremental cancer risk exceeds the BAAQMD significance thresholds,
the applicant will be required to identify and demonstrate that mitigation measures are capable
of reducing potential cancer and non-cancer risks to an acceptable level, including appropriate
enforcement mechanisms.
Mitigation measures and best practices may include but are not limited to:
Restricting idling on-site beyond Air Toxic Control Measures idling restrictions, as feasible.
Electrifying warehousing docks.
Requiring use of newer equipment and/or vehicles.
Restricting off-site truck travel through the creation of truck routes.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 11
Mitigation measures identified in the project-specific HRA shall be identified as mitigation
measures in the environmental document and/or incorporated into the site development plan
as a component of a proposed project.
Mitigation Measure AIR-3b: To ensure that new industrial and warehousing projects with the
potential to generate new stationary and mobile sources of air toxics that exceed the BAAQMD
project-level and/or cumulative significance thresholds for toxic air contaminants and PM2.5
listed in the BAAQMD CEQA Guidelines reduce emissions below the BAAQMD thresholds of
significance, amend the City’s CEQA guidelines to require compliance with BAAQMD
requirements.
Mitigation Measure AIR-3c: The proposed Plan shall include policies to mitigate potential
sources of toxic air contaminants through siting or other means to reduce human health risks
and meet the Bay Area Air Quality Management District’s applicable threshold of significance.
Policies shall also require that new sensitive land use projects (e.g., residences, schools,
hospitals, nursing homes, parks or playgrounds, and day care centers) within 1,000 feet of a
major stationary source of TACs and roadways with traffic volumes over 10,000 vehicles per day
consider potential health risks and incorporate adequate precautions, such as high-efficiency air
filtration, into project design.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measures AIR-3a and AIR-3b would ensure that mobile
sources of TACs not covered under BAAQMD permits are considered during subsequent project-
level environmental review and development of individual projects would be required to
achieve the incremental risk thresholds established by BAAQMD. Mitigation Measures AIR-3c
would ensure that potential health risks are considered for new sensitive land uses sited near
potential sources of toxic air contaminants, and that adequate precautions are incorporated
into such projects. The proposed Plan includes Policy N-5.5 to ensure exposure to pollutants and
resulting health risks are considered during the siting of sensitive land uses: “Mitigate potential
sources of toxic air contaminants through siting or other means to reduce human health risks
and meet the Bay Area Air Quality Management District’s applicable threshold of significance.
When siting new sensitive receptors such as schools, day care facilities, parks or playgrounds,
medical facilities and residences within 1,000’ of stationary sources of toxic air contaminants or
roadways used by more than 10,000 vehicles per day, require projects to consider potential
health risks and incorporate adequate precautions such as high-efficiency air filtration into
project design.”
Resulting Significance: Less than Significant
Impact AIR-4: Implementation of the proposed Plan could create or expose a substantial
number of people to objectionable odors unless policies are integrated into the proposed
Plan.
Mitigation Measure AIR-4: To reduce odor impacts, the proposed Plan shall include policies
requiring:
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 12
Buffers, mechanical, and other mitigation methods to avoid creating a nuisance.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes Policy N-5.4 to ensure that future
development projects and capital improvement projects do not result in objectionable odors:
“All potential sources of odor and/or toxic air contaminants shall be adequately buffered, or
mechanically or otherwise mitigated to avoid odor and toxic impacts that violate relevant
human health standards.” This policy, along with CEQA review of projects using BAAQMD’s odor
screening distances and compliance with BAAQMD Regulation 7, would ensure that odor
impacts are minimized and reduced to a less-than-significant level.
Resulting Significance: Less than Significant
Cultural Resources
Impact CULT-1: Implementation of the proposed Plan could adversely affect a historic
resource listed or eligible for listing on the National and/or California Register, or listed on the
City’s Historic Inventory.
Mitigation Measure CULT-1: To ensure the protection of potentially historic resources, the
proposed Plan shall include policies that achieve the following:
Process for reviewing proposed demolition or alteration of potentially historic buildings.
Protection of archaeological resources.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the policies that collectively support
implementation of this mitigation measure. For example:
Policy L-7.2: If a proposed project would substantially affect the exterior of a potential
historic resource that has not been evaluated for inclusion into the City’s Historic Resources
Inventory, City staff shall consider whether it is eligible for inclusion in State or federal
registers prior to the issuance of a demolition or alterations permit. Minor exterior
improvements that do not affect the architectural integrity of potentially historic buildings
shall be exempt from consideration. Examples of minor improvements may include repair or
replacement of features in kind, or other changes that do not alter character-defining
features of the building.
Policy L-7.14: Protect Palo Alto’s archaeological resources, including natural land formations,
sacred sites, the historical landscape, historic habitats and remains of settlements here
before the founding of Palo Alto in the 19th century.
The incorporation of relevant policies into the proposed Plan ensures that the potential historic
resources would be considered for inclusion on State and federal registers prior to demolition or
alteration, and that archaeological resources would be protected. Through implementation of
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 13
these measures, the City would ensure the ongoing protection of potential historic and
archaeological resources that have not already been identified and protected.
Resulting Significance: Less than Significant
Impact CULT-2: Implementation of the proposed Plan could eliminate important examples of
major periods of California history or prehistory.
Mitigation Measure CULT-2: Implement Mitigation Measure CULT-1.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Through implementation of Mitigation Measure CULT-1, the City would
maintain processes and procedures to ensure the ongoing protection of historic and
archaeological resources, including important examples of California’s history and prehistory.
Resulting Significance: Less than Significant
Impact CULT-3: Implementation of the proposed Plan could cause damage to an important
archaeological resource as defined in Section 15064.5 of the CEQA Guidelines.
Mitigation Measure CULT-3: Implement Mitigation Measure CULT-1. In addition, to ensure that
future development would not damage archaeological resources, the proposed Plan shall
include policies that achieve the following:
Archaeological surveys and mitigation plans for future development projects.
Developer compliance with applicable regulations regarding the identification and
protection of archaeological and paleontological deposits, and unique geologic features.
Appropriate tribal consultation and consideration of tribal concerns.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy L-7.15: Appropriate tribal consultation and consideration of tribal concerns.
Policy L-7.16: Archaeological surveys and mitigation plans for future development projects.
Policy L-7.17: Developer compliance with applicable regulations regarding the identification
and protection of archaeological and paleontological deposits, or unique geologic features.
The incorporation of relevant policies into the proposed Plan ensures that the City would
require archaeological surveys and mitigation plans for future development projects and capital
improvement projects that are subject to CEQA review, as well as compliance with
archaeological protection regulations and tribal consultation. Implementation of these policies
would avoid significant impacts to archaeological resources. In addition, through
implementation of Mitigation Measure CULT-1, the City would maintain processes and
procedures to ensure the ongoing protection of archaeological resources.
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Resulting Significance: Less than Significant
Impact CULT-5: Implementation of the proposed Plan would have the potential to directly or
indirectly destroy a unique paleontological resource or site or unique geologic feature.
Mitigation Measure CULT-5: Implement Mitigation Measure CULT-3.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measure CULT-3 would incorporate policies into the proposed
Plan to require compliance with paleontological protection regulations. These policies would
ensure that future development projects and capital improvement projects subject to CEQA
would avoid significant impacts to paleontological resources and unique geologic features.
Resulting Significance: Less than Significant
Impact CULT-7: Implementation of the proposed Plan, in combination with past, present, and
reasonably foreseeable projects, would result in significant cumulative impacts with respect
to cultural resources.
Mitigation Measure CULT-7: Implement Mitigation Measures CULT-1 and CULT-3.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Through implementation of Mitigation Measure CULT-1, the City would
maintain processes and procedures to ensure the ongoing protection of historic and
archaeological resources. These processes and procedures would protect historic and
archaeological resources. Mitigation Measure CULT-3 would incorporate policies into the
proposed Plan to require archaeological surveys and mitigation plans for future development
projects and capital improvement projects, as well as compliance with archaeological and
paleontological protection regulations and tribal consultation. These policies would ensure that
future projects avoid significant impacts to archaeological and paleontological resources and
that the City’s contribution to potential cumulative impacts to historic, archaeological, and
paleontological resources would be reduced to a less-than-significant level.
Resulting Significance: Less than Significant
Greenhouse Gas Emissions
Impact GHG-3: The proposed Plan would expose people or structures to the physical effects of
climate change, including but not limited to flooding, extreme temperatures, public health,
wildfire risk, or other impacts resulting from climate change, requiring mitigation.
Mitigation Measure GHG-3: To address the potential impacts associated with exposing people
to the effects of climate change, the proposed Plan shall include policies that achieve the
following:
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 15
Monitoring and response to flooding risks caused by climate change-related changes to
precipitation patterns, groundwater levels, sea level rise, tides, and storm surges.
Cooperative planning with federal, State, regional, and local public agencies on issues
related to climate change (including sea level rise and extreme storms).
Preparation of response strategies to address sea level rise, increased flooding, landslides,
soil erosion, storm events, and other events related to climate change.
Implementation of adaptive strategies to address impacts of sea level rise on Palo Alto’s
levee system.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure. For example:
Policy N-4.12: Encourage Low Impact Development (LID) measures to limit the amount of
pavement and impervious surface in new development and increase the retention,
treatment and infiltration of urban stormwater runoff. Include LID measures in major
remodels, public projects and recreation projects where practical.
Policy N-8.2: With guidance from the City’s Sustainability and Climate Action Plan (S/CAP)
and its subsequent updates and other future planning efforts, reduce greenhouse gas
emissions from City operations and from the community.
Policy N-8.4: Continue to work with regional partners to build resiliency policy into City
planning and capital projects, especially near the San Francisco Bay shoreline, while
protecting the natural environment.
Program N8.4.1: Prepare response strategies that address sea level rise, increased flooding,
landslides, soil erosion, storm events and other events related to climate change. Include
strategies to respond to the impacts of sea level rise on Palo Alto’s levee system.
Policy S-1.9: Design Palo Alto’s infrastructure system to protect the life and safety of
residents, ensure resiliency in the face of disaster and minimize economic loss, including in
the context of climate change and sea level rise.
Program S1.10.3: Implement the mitigation strategies and guidelines provided by the LHMP,
including those that address evolving hazards resulting from climate change.
Policy S-2.9: Prohibit new habitable basements in the development of single-family
residential properties within 100-year flood zones of the FEMA-designated Special Flood
Hazard Area.
Policy S-2.10: Monitor and respond to the risk of flooding caused by climate change-related
changes to precipitation patterns, groundwater levels, sea level rise, tides and storm surges.
Policy S-2.11: Support regional efforts to improve bay levees.
Program S2.11.1: Work cooperatively with the Santa Clara Valley Water District and the San
Francisquito Creek Joint Powers Authority to provide flood protection from high tide events
on San Francisco Bay, taking into account the impacts of future sea level rise, to provide one
percent (100-year) flood protection from tidal flooding, while being sensitive to preserving
and protecting the natural environment.
Program S2.11.2: Work with regional, State, and federal agencies to develop additional
adaptive strategies to address flood hazards to existing or new development and
infrastructure, including environmentally sensitive levees.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 16
The incorporation of relevant policies into the proposed Plan ensures that the City considers the
impact of climate change when making future decisions about development projects and capital
improvement projects. The programs listed above illustrate ways the City is engaging in planning
and strategies to reduce the risks associated with the effects of climate change. The policies and
programs collectively ensure that the City reduces potential climate change hazards to the
extent feasible.
Resulting Significance: Less than Significant
Hydrology
Impact HYD-2: The proposed Plan could substantially degrade or deplete ground water
resources or interfere substantially with groundwater recharge such that there would be a net
deficit in aquifer volume or a lowering of the local groundwater table level.
Mitigation Measure HYD-2: To reduce potential impacts associated with construction
dewatering the proposed Plan shall include policies that achieve the following:
Avoidance of the impacts of basement construction for single-family homes on the
natural environment and safety.
Conservation of subsurface water resources.
Construction techniques and recharge strategies to reduce subsurface and surface water
impacts.
Monitoring of dewatering and excavation projects.
Cooperation with other jurisdictions and regional agencies to protect groundwater.
Protection of groundwater as a natural resource.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure. For example:
Policy L-3.5: Avoid negative impacts of basement construction for single-family homes on
adjacent properties, public resources and the natural environment.
Policy N-4.7: Ensure regulation of groundwater use to protect it as a natural resource and to
preserve it as a potential water supply in the event of water scarcity.
Policy N-4.8: Conserve and maintain subsurface water resources by exploring ways to reduce
the impacts of residential basement dewatering and other excavation activities.
Program N4.8.1: Research and promote new construction techniques and recharge
strategies developed to reduce subsurface and surface water impacts and comply with City
dewatering policies.
Program N4.8.2: Explore appropriate ways to monitor dewatering for all dewatering and
excavation projects to encourage maintaining groundwater levels and recharging of the
aquifer where needed.
The incorporation of relevant policies into the proposed Plan ensures that the City would
continue to work to reduce the environmental effects associated with construction dewatering,
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 17
including impacts to adjacent properties and subsurface water resources. The programs listed
above illustrate the City commitment to advancing these policies. Implementation of Mitigation
Measure HYD-2 would also ensure cooperation with other agencies to protect groundwater
resources and would reduce impacts to groundwater resources to a less-than-significant level.
Resulting Significance: Less than Significant
Land Use
Impact LAND-1: The proposed Plan could adversely change the type or intensity of existing or
planned land use patterns in the area.
Mitigation Measure LAND-1: To ensure that the intensity of future development would not
adversely change the land use patterns or affect the livability of Palo Alto neighborhoods, the
proposed Plan shall include policies that achieve the following:
Strengthening of residential neighborhoods.
Vitality of commercial areas and public facilities.
High-quality building and site design.
Architectural compatibility of new development.
Compatible infill development.
Avoidance of abrupt changes in the scale of development where residential districts abut
more intense uses.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy L-1.2: Maintain and strengthen Palo Alto’s varied residential neighborhoods while
sustaining the vitality of its commercial areas and public facilities.
Policy L-1.3: Infill development in the urban service area should be compatible with its
surroundings and the overall scale and character of the city to ensure a compact, efficient
development pattern.
Policy L-3.1: Ensure that new or remodeled structures are compatible with the
neighborhood and adjacent structures.
Policy L-6.1: Promote high-quality design and site planning that is compatible with
surrounding development and public spaces.
Policy L-6.2: Use the Zoning Ordinance, design review process, design guidelines and
Coordinated Area Plans to ensure high quality residential and commercial design and
architectural compatibility.
Policy L-6.7: Where possible, avoid abrupt changes in scale and density between residential
and non-residential areas and between residential areas of different densities. To promote
compatibility and gradual transitions between land uses, place zoning district boundaries at
mid-block locations rather than along streets wherever possible.
Policy L-9.4: Maintain and enhance existing public gathering places and open spaces and
integrate new public spaces at a variety of scales.
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Policy L-9.6: Create, preserve and enhance parks and publicly accessible, shared outdoor
gathering spaces within walking and biking distance of residential neighborhoods.
The incorporation of relevant policies into the proposed Plan ensures that the City will require
development and capital improvements allowed under the proposed Plan to achieve high-
quality design, architectural compatibility, and context-sensitive building design, strengthening
residential and commercial areas and avoiding adverse effects associated with the type or
intensity of land use patterns.
Resulting Significance: Less than Significant
Impact LAND-2: The proposed Plan would allow development that could be incompatible with
adjacent land uses or with the general character of the surrounding area, including density
and building height.
Mitigation Measure LAND-2: Implement Mitigation Measure LAND-1. In addition, to further
reduce potential impacts to visual character and ensure compatibility with adjacent land uses,
the proposed Plan shall include policies that achieve the following:
Use of City procedures, plans, and requirements to ensure high-quality building design and
architectural compatibility.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy L-6.2: Use the Zoning Ordinance, design review process, design guidelines and
Coordinated Area Plans to ensure high quality residential and commercial design and
architectural compatibility.
Policy L-6.7: Where possible, avoid abrupt changes in scale and density between residential
and non-residential areas and between residential areas of different densities. To promote
compatibility and gradual transitions between land uses, place zoning district boundaries at
mid-block locations rather than along streets wherever possible.
The incorporation of relevant policies into the proposed Plan ensures that the City will require
development projects and capital improvement projects to provide appropriate land use
transitions and adhere to design requirements for compatibility and high-quality design, and to
avoid adverse effects associated with incompatible land uses, effectively avoiding adverse
effects associated with the intensity of planned land uses.
Resulting Significance: Less than Significant
Impact LAND-5: The proposed Plan could physically divide an established community.
Mitigation Measure LAND-5: To avoid potential impacts from physically dividing an established
community, the proposed Plan shall include policies that achieve the following:
Enhanced connections to and from parks, schools, and community facilities for all users.
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Safe and convenient pedestrian, bicycle, and transit connections between residential areas
and commercial centers.
Cooperation with other agencies to improve circulation connections.
Grade separation of rail crossings.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy L-1.6: Use coordinated area plans to guide development in areas of Palo Alto where
significant change is foreseeable. Address both land use and transportation, define the
desired character and urban design traits of the areas, identify opportunities for public open
space, parks and recreational opportunities, address connectivity to and compatibility with
adjacent residential areas; and include broad community involvement in the planning
process.
Policy L-2.2: Enhance connections between commercial and mixed use centers and the
surrounding residential neighborhoods by promoting walkable and bikeable connections
and a diverse range of retail and services that caters to the daily needs of residents.
Policy T-1.17: Require new office, commercial and multi-family residential developments to
provide improvements that improve bicycle and pedestrian connectivity as called for in the
2012 Palo Alto Bicycle + Pedestrian Transportation Plan.
Policy T-1.21: Maintain pedestrian- and bicycle-only use of alleyways Downtown and in the
California Avenue area where appropriate to provide connectivity between businesses and
parking and transit stops, and consider public art in the alleyways as a way to encourage
walking.
Policy T-3.2: Enhance connections to, from and between parks, community centers,
recreation facilities, libraries and schools for all users.
Policy T-3.13: Work with Caltrans, Santa Clara County and VTA to improve east and west
connections in Palo Alto and maintain a circulation network that binds the city together in
all directions.
Policy T-3.15: Pursue grade separation of rail crossings along the rail corridor as a City
priority.
Policy T-8.12: Support the development of the Santa Clara County Countywide Bicycle
System, and other regional bicycle plans.
The incorporation of relevant policies into the proposed Plan ensures that future development
projects and capital improvement projects will enhance connections with community facilities,
improve safety for non-automotive connections, address grade separation of rail crossings, and
involve cooperation with other agencies to improve circulation. City action consistent with
these policies would improve accessibility throughout the city and ensure that established
communities are not physically divided.
Resulting Significance: Less than Significant
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Noise
Impact NOISE-1: Implementation of the proposed Plan would have the potential to cause the
average 24-hour noise level (Ldn) to increase by 5.0 decibels (dB) or more in an existing
residential area, even if the Ldn would remain below 60 dB.
Mitigation Measure NOISE-1a: To ensure that average 24-hour noise levels associated with
long-term operational noise would not increase by 5.0 decibels (dB) or more in an existing
residential area, the proposed Plan shall include policies that achieve the following:
Location of land uses in areas with compatible noise environments.
Use of the guidelines in the “Land Use Compatibility for Community Noise Environment”
table in the proposed Plan to evaluate the compatibility of proposed land uses with existing
noise environments.
Clear guidelines for maximum outdoor noise levels in residential areas.
Adherence to the interior noise requirements of the State of California Building Standards
Code (Title 24) and the Noise Insulation Standards (Title 25).
Inclusion of a noise contour map in the proposed Plan.
Reduction of noise impacts of development on adjacent properties.
Evaluation of noise impacts on existing residential, open space, and conservation land.
Requirement for new projects in the Multiple Family, Commercial, Manufacturing, or
Planned Community districts to demonstrate compliance with the Noise Ordinance.
Mitigation Measure NOISE-1b: To reduce potential impacts to new land uses from aircraft
noise, the proposed Plan shall include policies that achieve the following:
Compliance with the airport-related land use compatibility standards for community noise
environments.
Prohibition of incompatible land use development within the 60 dBA CNEL noise contours of
the Palo Alto airport, as established in the adopted County of Santa Clara Airport Land Use
Commission Comprehensive Land Use Plan (CLUP) for the Palo Alto Airport.
Mitigation Measure NOISE-1c: To reduce potential impacts to new land uses from railway noise,
the proposed Plan shall include policies that achieve the following:
Minimization of noise spillover from rail-related activities into adjacent residential or noise-
sensitive areas.
Building design that reduces impacts from noise and ground borne vibrations associated
with rail operations.
Guidelines for interior noise levels.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy N-6.1: Encourage the location of land uses in areas with compatible noise
environments. Use the guidelines in Table N-1 to evaluate the compatibility of proposed
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 21
land uses with existing noise environments when preparing, revising, or reviewing
development proposals. Acceptable exterior, interior and ways to discern noise exposure
include:
The guideline for maximum outdoor noise levels in residential areas is an Ldn of 60 dB.
This level is a guideline for the design and location of future development and a goal for
the reduction of noise in existing development. However, 60 Ldn is a guideline which
cannot necessarily be reached in all residential areas within the constraints of economic
or aesthetic feasibility. This guideline will be primarily applied where outdoor use is a
major consideration (e.g., backyards in single-family housing developments, and
recreational areas in multiple family housing projects). Where the City determines that
providing an Ldn of 60 dB or lower outdoors is not feasible, the noise level in outdoor
areas intended for recreational use should be reduced to as close to the standard as
feasible through project design.
Interior noise, per the requirements of the State of California Building Standards Code
(Title 24) and Noise Insulation Standards (Title 25), must not exceed an Ldn of 45 dB in
all habitable rooms of all new dwelling units.
Policy N-6.2: Noise exposure(s) can be determined from (a) the noise contour map included
in this plan, (b) more detailed noise exposure studies, or (c) on area-specific or project-
specific noise measurements, as appropriate.
Policy N-6.5: Protect residential and residentially-zoned properties from excessive and
unnecessary noise from any sources on adjacent commercial or industrial properties.
Policy N-6.7: While a proposed project is in the development review process, the noise
impact of the project on existing residential land uses, public open spaces and public
conservation land should be evaluated in terms of the increase in existing noise levels for
the potential for adverse community impact, regardless of existing background noise levels.
If an area is below the applicable maximum noise guideline, an increase in noise up to the
maximum should not necessarily be allowed.
Policy N-6.8: The City may require measures to reduce noise impacts of new development
on adjacent properties through appropriate means including, but not limited to, the
following:
Orient buildings to shield noise sensitive outdoor spaces from sources of noise.
Construct noise walls when other methods to reduce noise are not practical and when
these walls will not shift similar noise impacts to another adjacent property.
Screen and control noise sources such as parking lots, outdoor activities and mechanical
equipment, including HVAC equipment.
Increase setbacks to serve as a buffer between noise sources and adjacent dwellings.
Whenever possible, retain fences, walls or landscaping that serve as noise buffers while
considering design, safety and other impacts.
Use soundproofing materials, noise reduction construction techniques, and/or
acoustically rated windows/doors.
Include auxiliary power sources at loading docks to minimize truck engine idling.
Control hours of operation, including deliveries and trash pickup, to minimize noise
impacts.
Policy N-6.9: Continue to require applicants for new projects or new mechanical equipment
in the Multifamily, Commercial, Manufacturing or Planned Community districts to submit an
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 22
acoustical analysis demonstrating compliance with the Noise Ordinance prior to receiving a
building permit.
Policy N-6.12: Ensure compliance with the airport related land use compatibility standards
for community noise environments, shown in Table N-1, by prohibiting incompatible land
use development within the 60 dBA CNEL noise contours of the Palo Alto airport.
Policy N-6.13: Minimize noise spillover from rail related activities into adjacent residential or
noise-sensitive areas.
Policy N-6.14: Reduce impacts from noise and ground borne vibrations associated with rail
operations by requiring that future habitable buildings use necessary design elements such
as setbacks, landscaped berms and soundwalls to keep interior noise levels below 45 dBA
Ldn and ground-borne vibration levels below 72 VdB.
Mitigation Measure NOISE-1a incorporates policies into the proposed Plan to require adherence
to noise guidelines, reduce potential noise impacts for adjacent properties, ensuring that long-
term operational noise in residential areas would not increase by unacceptable levels.
Mitigation Measure NOISE-1b would incorporate policies into the proposed Plan to require
compliance with airport-related compatibility standards and prohibit development within the
60 dBA CNEL noise contour of the Palo Alto Airport, ensuring that new sensitive receptors are
not exposed to unacceptable levels of noise from operation of the Palo Alto Airport.
Mitigation Measure NOISE-1c would incorporate policies into the proposed Plan to address
impacts associated with rail operations and require interior noise level guidelines and vibration
impact analyses, ensuring that new construction near the rail corridor is adequate to address
railway noise and vibration, to the extent feasible.
Resulting Significance: Less than Significant
Impact NOISE-2: Implementation of the proposed Plan would have the potential to cause the
Ldn to increase by 3 dB or more in an existing residential area, thereby causing the Ldn in the
area to exceed 60 dB.
Mitigation Measure NOISE-2: Implement Mitigation Measures NOISE-1a, NOISE-1b, and
NOISE-1c.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c would be
implemented by including policies in the proposed Plan to ensure that noise levels in residential
areas would not increase by unacceptable levels and ensure that new noise sources would be
controlled and/or mitigated so as to comply with City standards.
Resulting Significance: Less than Significant
Impact NOISE-3: Implementation of the proposed Plan would have the potential to cause an
increase of 3 dB or more in an existing residential area where the Ldn currently exceeds 60 dB.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 23
Mitigation Measure NOISE-3: Implement Mitigation Measures NOISE-1a, NOISE-1b, and
NOISE-1c.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c would be
implemented by including policies in the proposed Plan to ensure that noise levels in residential
areas would not increase by unacceptable levels and would ensure that new noise sources
would be controlled and/or mitigated so as to comply with City standards.
Resulting Significance: Less than Significant
Impact NOISE-4: Implementation of the proposed Plan would have the potential to result in
indoor noise levels for residential development to exceed an Ldn of 45 dB.
Mitigation Measure NOISE-4a: Implement Mitigation Measure NOISE-1a.
Mitigation Measure NOISE-4b: The Land Use Noise Compatibility Guidelines established in the
1998 Comprehensive Plan shall be maintained.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measure NOISE-1a would be implemented by including
policies in the proposed Plan to ensure that long-term operational noise in residential areas
would not increase by unacceptable levels by maintaining the City’s Land Use Noise
Compatibility Guidelines, which would be used to evaluate new development projects and
capital improvement projects.
Resulting Significance: Less than Significant
Impact NOISE-5: Implementation of the proposed Plan would have the potential to expose
persons to or generate excessive ground-borne vibration or ground-borne noise levels.
Mitigation Measure NOISE-5a: To ensure that future development would not result in
significant construction-related vibration impacts, the proposed Plan shall include policies that
limit the hours of construction around sensitive receptors, and require formal, ongoing
monitoring and reporting throughout the construction process for larger development projects,
as well as the use of pertinent industry standards and City guidelines to avoid significant
vibration impacts during construction or operations.
Mitigation Measure NOISE-5b: Implement Mitigation Measure NOISE-1c.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 24
Rationale for Finding: The proposed Plan includes the following policy and program that
collectively ensure implementation of this mitigation measure during the course of
development proposals and capital improvement projects:
Policy N-6.11: Continue to prioritize construction noise limits around sensitive receptors,
including through limiting construction hours and individual and cumulative noise from
construction equipment.
Program N6.11.1: For larger development projects that demand intensive construction
periods and/or use equipment that could create vibration impacts, such as the Stanford
University Medical Center or major grade separation projects, require a vibration impact
analysis, as well as formal, ongoing monitoring and reporting of noise levels throughout the
entire construction process, pertinent to industry standards. The monitoring plan should
identify hours of operation and could include information on the monitoring locations,
durations and regularity, the instrumentation to be used and appropriate noise control
measures to ensure compliance with the noise ordinance.
The incorporation of this policy and program into the proposed Plan requires vibration analyses
and vibration mitigation plans, as well as limits for vibration around vibration-sensitive
receptors.
Resulting Significance: Less than Significant
Impact NOISE-6: Implementation of the proposed Plan would have the potential to expose
people to noise levels in excess of established State standards.
Mitigation Measure NOISE-6: Implement Mitigation Measures NOISE-4a and NOISE-4b.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measure NOISE-1a would be implemented by including
policies in the proposed Plan to ensure that new land uses would be reviewed for compatibility
with their surroundings and would not increase noise by unacceptable levels, and Mitigation
Measure NOISE-4b would be implemented by maintaining the City’s Land Use Noise
Compatibility Guidelines in the proposed Plan.
Resulting Significance: Less than Significant
Impact NOISE-7: Implementation of the proposed Plan would have the potential to result in
the exposure of persons to or generation of noise levels in excess of standards established in
the local General Plan or noise ordinance, or applicable standards of other agencies.
Mitigation Measure NOISE-7: Implement Mitigation Measures NOISE-1a, NOISE-1b, NOISE-1c,
NOISE-4a, and NOISE-4b.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 25
Rationale for Finding: Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c would be
implemented by including policies in the proposed Plan to ensure that residential areas would
not be affected by new noise sources and would maintain the City’s Land Use Noise
Compatibility Guidelines.
Resulting Significance: Less than Significant
Impact NOISE-8: Implementation of the proposed Plan could result in a potentially substantial
temporary or periodic increase in ambient noise levels in the project vicinity above levels
existing without the project.
Mitigation Measure NOISE-8: To ensure that future development would not result in significant
impacts to sensitive receptors from construction noise, the proposed Plan shall include policies
that achieve the following:
Construction noise limits around sensitive receptors.
Monitoring and reporting plans for construction noise levels of larger development projects.
Noise control measures to ensure compliance with the noise ordinance.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the following policy and program that
collectively ensure implementation of this mitigation measure during the course of
development proposals and capital improvement projects:
Policy N-6.11: Continue to prioritize construction noise limits around sensitive receptors,
including through limiting construction hours and individual and cumulative noise from
construction equipment.
Program N6.11.1: For larger development projects that demand intensive construction
periods and/or use equipment that could create vibration impacts, such as the Stanford
University Medical Center or major grade separation projects, require a vibration impact
analysis, as well as formal, ongoing monitoring and reporting of noise levels throughout the
entire construction process, pertinent to industry standards. The monitoring plan should
identify hours of operation and could include information on the monitoring locations,
durations and regularity, the instrumentation to be used and appropriate noise control
measures to ensure compliance with the noise ordinance.
The incorporation of this policy and program into the proposed Plan limits construction noise
around sensitive receptors, requires monitoring and reporting plans for construction noise of
larger development projects, and requires noise control measures, reducing temporary or
periodic increases to ambient noise levels to less-than-significant levels.
Resulting Significance: Less than Significant
Impact NOISE-11: Implementation of the proposed Plan, in combination with past, present, and
reasonably foreseeable projects, may result in significant cumulative impacts with respect to
noise.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 26
Mitigation Measure NOISE-11a: Implement Mitigation Measure NOISE-1c.
Mitigation Measure NOISE-11b: To address overall community noise impacts from train noise
to the extent such noise is within the City’s control and in excess of established State and/or City
standards, the proposed Plan shall include policies that achieve the following:
Efforts to develop and implement technological methods to reduce train whistle noise from
Caltrain.
Evaluation of at-grade rail crossings as potential Quiet Zones based on Federal Railroad
Administration (FRA) rules and guidelines.
Grade separation of rail crossings as a City priority.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that would collectively
implement this mitigation measure during the course of development proposals and capital
improvement projects. For example:
Policy T-3.15: Pursue grade separation of rail crossings along the rail corridor as a City
priority.
Policy N-6.13: Minimize noise spillover from rail related activities into adjacent residential or
noise-sensitive areas.
Program N6.13.1: Encourage the Peninsula Corridors Joint Powers Board to pursue
technologies and grade separations that would reduce or eliminate the need for train
horns/whistles in communities served by rail service.
Program N6.13.2: Evaluate changing at-grade rail crossings so that they qualify as Quiet
Zones based on Federal Railroad Administration (FRA) rules and guidelines in order to
mitigate the effects of train horn noise without adversely affecting safety at railroad
crossings.
The incorporation of these policies and programs into the proposed Plan ensures the City’s
focus on methods to reduce train whistle noise from Caltrain, evaluation of at-grade crossings as
potential Quiet Zones, and the prioritization of grade separation. In addition, Mitigation
Measure NOISE-1c would address new sources of noise in existing residential areas.
Implementation of Mitigation Measures NOISE-1c and NOISE-11b would minimize the
possibility for community-wide ambient noise increases due to cumulative sources to the extent
feasible. After implementation of the new policies and mitigation measures, impacts from
cumulative noise increases would be considered less than significant.
Resulting Significance: Less than Significant
Public Services
Impact PS-7: Implementation of the proposed Plan would result in an adverse physical impact
from the construction of additional parks and recreation facilities in order to maintain
acceptable performance standards.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 27
Mitigation Measure PS-7: To address the potential physical impacts of park
construction/improvement, the Comprehensive Plan Update shall include policies that achieve
the following:
Evaluation and mitigation of the construction impacts associated with park and recreational
facility creation and expansion.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the following policy that ensures
implementation of this mitigation measure during the course of development proposals and
capital improvement projects:
Policy N-1.13: Evaluate and mitigate the construction impacts associated with park and
recreational facility creation and expansion.
The incorporation of this policy into the proposed Plan requires evaluation and mitigation of
construction impacts associated with the creation or expansion of park and recreational
facilities. Facility construction projects developed consistent with this policy would avoid
adverse physical impacts to the extent feasible.
Resulting Significance: Less than Significant
Impact PS-8: Implementation of the proposed Plan would have the potential to result in
substantial cumulative adverse physical impacts associated with the provision of new or
physically altered parks and recreational facilities, need for new or physically altered parks
and recreation facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios or other performance objectives.
Mitigation Measure PS-8: Implement Mitigation Measure PS-7.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Implementation of Mitigation Measure PS-7 would ensure that facility
construction projects developed consistent with referenced policies would avoid adverse
physical impacts to the extent feasible. Therefore, the creation of new parkland would not
contribute to potential significant cumulative impacts associated with new park construction.
Resulting Significance: Less than Significant
Transportation
Impact TRANS-1: Implementation of the project would cause an intersection to drop below its
motor vehicle level of service standard, or deteriorate operations at representative
intersections that already operate at a substandard level of service.
Mitigation Measure TRANS-1a: Adopt a programmatic approach to reducing motor vehicle
traffic, with the goal of achieving no net increase in peak-hour motor vehicle trips from new
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 28
development, with an exception for uses that directly contribute to the neighborhood character
and diversity of Palo Alto (such as ground-floor retail and below-market-rate housing). The
program should, at a minimum, require new development projects above a specific size
threshold to prepare and implement a Transportation Demand Management (TDM) Plan to
achieve the following reduction in peak-hour motor vehicle trips from the rates included in the
Institute of Transportation Engineers’ Trip Generation Manual for the appropriate land use
category and size. These reductions are deemed aggressive, yet feasible, for the districts
indicated.
45 percent reduction in the Downtown district
35 percent reduction in the California Avenue area
30 percent reduction in the Stanford Research Park
30 percent reduction in the El Camino Real Corridor
20 percent reduction in other areas of the city
TDM Plans must be approved by the City and monitored by the property owner or the project
proponent on an annual basis. The Plans must contain enforcement mechanisms or penalties
that accrue if targets are not met and may achieve reductions by contributing to citywide or
employment district shuttles or other proven transportation programs that are not directly
under the property owner’s control.
Mitigation Measure TRANS-1b: Require new development projects to pay a Transportation
Impact Fee for all those peak-hour motor vehicle trips that cannot be reduced via TDM
measures. Fees collected would be used for capital improvements aimed at reducing motor
vehicle trips and motor vehicle traffic congestion.
Mitigation Measure TRANS-1c: The proposed Plan shall include policies to ensure collaboration
with regional agencies and neighboring jurisdictions, and identification and pursuit of funding
for rail corridor improvements and grade separation. Policies shall support grade separation of
rail crossings along the rail corridor as a City priority, and the undertaking of studies and
outreach necessary to advance grade separation of Caltrain to become a “shovel ready” project.
Mitigation Measure TRANS-1d: Consistent with State requirements, the City shall adopt a
Multimodal Improvement Plan to address impacts to Congestion Management Program
facilities. In addition, the proposed Plan shall include policies to engage in regional
transportation planning and advocate for specific transit improvements and investments, such
as Caltrain service enhancements and grade separations, Dumbarton Express service, enhanced
bus service on El Camino Real with queue-jump lanes and curbside platforms, high-occupancy
vehicle (HOV)/high-occupancy toll (HOT) lanes, and additional VTA bus service.
Mitigation Measure TRANS-1e: The proposed Plan shall include policies to encourage the
PAUSD to analyze decisions regarding school assignments to reduce peak-period motor vehicle
trips to and from school sites.
Finding: Palo Alto is located in a dynamic region with a transportation network that is often
quite congested. In this context, even small changes over time can contribute to significant
traffic congestion. Changes or alterations have been required in, or incorporated into, the
proposed project, which avoid or substantially lessen the significant environmental effect
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 29
identified in the EIR, but not to a level of less than significant. There are no additional feasible
mitigation measures and no feasible alternatives that avoid this significant effect, as further
addressed in Section III, Findings Concerning Alternatives.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure during the course of the City’s review of
development proposals and capital improvement projects. For example:
Program T1.2.2: Formalize TDM requirements by ordinance and require new developments
above a certain size threshold to prepare and implement a TDM Plan to meet specific
performance standards. Require regular monitoring/reporting and provide for enforcement
with meaningful penalties for noncompliance. The ordinance should also:
Establish a list of effective TDM measures that include transit promotion, prepaid transit
passes, commuter checks, car sharing, carpooling, parking cash-out, bicycle lockers and
showers, shuttles to Caltrain, requiring TMA membership and education and outreach to
support the use of these modes.
Allow property owners to achieve reductions by contributing to citywide or employment
district shuttles or other proven transportation programs that are not directly under the
property owner’s control.
Provide a system for incorporating alternative measures as new ideas for TDM are
developed.
Establish a mechanism to monitor the success of TDM measures and track the
cumulative reduction of peak hour motor vehicle trips. TDM measures should at a
minimum achieve the following reduction in peak hour motor vehicle trips, with a focus
on single-occupant vehicle trips. Reductions should be based on the rates included in
the Institute of Transportation Engineers’ Trip Generation Manual for the appropriate
land use category:
- 50 percent reduction in the Downtown district
- 35 percent reduction in the California Avenue area
- 30 percent reduction in the Stanford Research Park
- 30 percent reduction in the El Camino Real Corridor
- 20 percent reduction in other areas of the city
Require new development projects to pay a Transportation Impact Fee for all those peak-
hour motor vehicle trips that cannot be reduced via TDM measures. Fees collected would
be used for capital improvements aimed at reducing vehicle trips and traffic congestion.
Policy T-2.6: Work with PAUSD to ensure that decisions regarding school assignments are
analyzed to reduce peak period motor vehicle trips to and from school sites.
Policy T-3.15: Pursue grade separation of rail crossings along the rail corridor as a City
priority.
Program T3.15.1: Undertake studies and outreach necessary to advance grade separation of
Caltrain to become a “shovel ready” project and strongly advocate for adequate State,
regional and federal funding for design and construction of railroad grade separations.
Policy T-8.1: Engage in regional transportation planning and advocate for specific transit
improvements and investments, such as Caltrain service enhancements and grade
separations, Dumbarton Express service, enhanced bus service on El Camino Real with
queue jumping and curbside platforms, HOV/HOT lanes and additional VTA bus service.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 30
Policy T-8.2: Participate in regional planning initiatives for the rail corridor and provide a
strong guiding voice.
Implementation of the TDM measures and other measures to reduce driving under Mitigation
Measures TRANS-1a through TRANS-1e would result in a lower auto mode share, higher
number of transit trips, lower VMT, and lower VMT per capita compared to pre-mitigation
conditions. However, affected intersections are operating close to or below LOS standards under
existing conditions, so even small increases in traffic at these intersections would trigger
impacts.
Under Mitigation Measure TRANS-1d, the City will prepare and adopt a Multimodal
Improvement Plan to address impacts to Congestion Management Program (CMP) facilities. The
EIR identifies significant impacts at three intersections included in the County’s CMP: El Camino
Real (State Route 82) at San Antonio Road (in Mountain View) (referred to as Intersection #8 in
the EIR analysis), Foothill Expressway/Junipero Serra Boulevard at Page Mill Road (Intersection
#9), and Foothill Expressway at Arastradero Road (Intersection #10). VTA’s Congestion
Management Agency (CMA) guidelines state that, “Deficiency plans should be prepared by the
Member Agency in which the deficient CMP System facility or set of facilities is located.”
Multimodal Improvement Plan requirements will be met for these three intersections as
follows:
Intersection #8 (El Camino Real at San Antonio Road) is located in Mountain View and Los
Altos. Therefore, planning for the intersection is not under the jurisdiction of the City of Palo
Alto. The City of Mountain View is currently drafting a Multimodal Improvement Plan that
includes this intersection and can and should adopt the Multimodal Improvement Plan when it
is complete. As required by VTA, acting as the Congestion Management Agency (“CMA”), the
City of Palo Alto will participate in development of this Multimodal Improvement Plan.
Intersection #9 (Foothill Expressway/Junipero Serra Boulevard at Page Mill Road) is located
within the city but is under the County’s jurisdiction. This intersection was grandfathered in with
an automobile LOS of F in 1991. Freeway segments and congestion management program
(CMP) intersections that operated at LOS F when monitoring began in 1991 are considered
exempt from meeting the CMP standard. Therefore, it is exempt from the requirement to
prepare a Multimodal Improvement Plan.
Intersection #10 (Foothill Expressway at Arastradero Road) is located within the city but is
under the County’s jurisdiction. The City of Palo Alto will be adopting a new Transportation
Nexus Study and Transportation Impact Fee shortly after adoption of the Comprehensive Plan
Update and the certification of the Comprehensive Plan Update EIR. This nexus study, and
impact fee calculation, will address the City’s share of a full grade-separation at this
intersection. Preliminary designs and cost estimates for this grade-separation project have been
developed by the Santa Clara County Department of Roads and Airports. With the construction
of this project, this intersection should operate at an acceptable level of service, and no longer
require the development of a Multimodal Improvement Plan.
All of the above traffic mitigation measures would reduce, but not eliminate, Impact TRANS-1.
Resulting Significance: Significant and Unavoidable
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 31
Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to
drop below its level of service standard, or deteriorate operations that already operate at a
substandard level of service.
Mitigation Measure TRANS-3a: The City shall require new development projects to prepare and
implement TDM programs, as described in TRANS-1a. TDM programs for worksites may include
measures such as private bus services and free shuttle services to transit stations geared
towards commuters.
Mitigation Measure TRANS-3b: The proposed Comprehensive Plan shall include policies that
advocate for efforts by Caltrans and the Valley Transportation Authority to reduce congestion
and improve traffic flow on existing freeway facilities consistent with Statewide GHG emissions
reduction initiatives.
Policies shall support the application of emerging freeway information, monitoring, and control
systems that provide non-intrusive driver assistance and reduce congestion.
Policies shall support, where appropriate, the conversion of existing traffic lanes to exclusive bus
and high-occupancy vehicle (HOV)/high-occupancy toll (HOT) lanes on freeways and
expressways, including the Dumbarton Bridge, and the continuation of an HOV lane from
Redwood City to San Francisco.
Finding: Palo Alto is located in a dynamic region with a transportation network that is often
quite congested. In this context, even small changes over time can contribute to significant
traffic congestion. Changes or alterations have been required in, or incorporated into, the
proposed project, which avoid or substantially lessen the significant environmental effect
identified in the EIR, but not to a level of less than significant. There are no additional feasible
mitigation measures and no feasible alternatives that avoid this significant effect, as further
addressed in Section III, Findings Concerning Alternatives.
Rationale for Finding: The proposed Plan includes policies that collectively ensure
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy T-8.6: Advocate for efforts by Caltrans and the Valley Transportation Authority to
reduce congestion and improve traffic flow on existing freeway facilities consistent with
Statewide GHG emissions reduction initiatives.
Policy T-8.7: Support the application of emerging freeway information, monitoring and
control systems that provide non-intrusive driver assistance and reduce congestion.
Policy T-8.8: Where appropriate, support the conversion of existing traffic lanes to exclusive
bus and HOV lanes or Express/HOT lanes on freeways and expressways, including the
Dumbarton Bridge, and the continuation of an HOV lane from Redwood City to San
Francisco.
The TDM measures called for in Mitigation Measures TRANS-1a and TRANS-3b, which include a
TDM mitigation program and other measures, would reduce but not eliminate the impacts on
freeway segments.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 32
Resulting Significance: Significant and Unavoidable
Impact TRANS-6: Implementation of the project would impede the operation of a transit
system as a result of congestion.
Mitigation Measure TRANS-6: The proposed Comprehensive Plan shall include policies to
collaborate with transit agencies in planning for and implementing convenient, efficient,
coordinated, and effective bus service.
Finding: Palo Alto is located in a dynamic region with a transportation network that is often
quite congested. In this context, even small changes over time can contribute to significant
traffic congestion. Changes or alterations have been required in, or incorporated into, the
proposed project, which avoid or substantially lessen the significant environmental effect
identified in the EIR, but not to a level of less than significant. There are no additional feasible
mitigation measures and no feasible alternatives that avoid this significant effect, as further
addressed in Section III, Findings Concerning Alternatives.
Rationale for Finding: The proposed Plan includes the following policy that ensures
implementation of this mitigation measure:
Policy T-1.12: Collaborate with transit agencies in planning and implementing convenient,
efficient, coordinated and effective bus service in Palo Alto that addresses the needs of all
segments of our population.
The incorporation of this policy into the proposed Plan ensures that the City would pursue
methods to give priority to buses and transit facilities. Even with implementation of Mitigation
Measure TRANS-6, congestion at all intersections and on all roadway segments where buses
operate would not be eliminated.
Resulting Significance: Significant and Unavoidable
Impact TRANS-8: Implementation of the project would create the potential demand for
through traffic to use local residential streets.
Mitigation Measure TRANS-8: The proposed Comprehensive Plan shall include policies to
identify specific improvements that can be used to discourage drivers from using local,
neighborhood streets to bypass traffic congestion on arterials.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the following policy that ensures
implementation of this mitigation measure:
Policy T-4.3: Identify specific improvements that can be used to discourage drivers from
using local, neighborhood streets to bypass traffic congestion on arterials.
Implementation of Mitigation Measure TRANS-8 would ensure that the City pursues
improvements to reduce the use of local streets as bypass routes to avoid congestion on
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 33
arterials. The EIR notes that implementation of traffic calming is highly site-specific, depending
on the physical characteristics of the street, the circulation pattern of a neighborhood, and
whether the residents support specific measures, among many other factors. It is not possible
at the Comprehensive Plan level to determine where traffic calming measures would be
appropriate or feasible or which specific measures should be implemented along a given
roadway or at a given intersection.
Resulting Significance: Less than Significant
Impact TRANS-9: Implementation of the project would create an operational safety hazard.
Mitigation Measure TRANS-9: Implement Mitigation Measure TRANS-8.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Under Mitigation Measure TRANS-8, the City would pursue
improvements to reduce the use of local streets as bypass routes to avoid congestion on
arterials. Implementation of this mitigation measure would ensure that safety hazards
associated with through traffic are reduced to a less-than-significant level.
Resulting Significance: Less than Significant
Utilities
Impact UTIL-15: Without the adoption of policies to promote recycling and conservation, the
proposed Plan could potentially fall out of compliance with federal, State, and local statutes
and regulations related to solid waste.
Mitigation Measure UTIL-15: To ensure that future development would comply with applicable
solid waste regulations, the proposed Plan shall include policies that achieve the following:
Ninety-five percent landfill diversion by 2030, and ultimately zero waste.
Reduced solid waste generation.
Use of reusable, returnable, recyclable, and repairable goods, through enforcement of the
2016 Plastic Foam Ordinance expansion.
Enhanced recycling and composting programs for all waste generators.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy S-3.8: Strive for 95 percent landfill diversion by 2030, and ultimately zero waste, by
enhancing policies and programs for waste reduction, recycling, composting and reuse.
Policy S-3.9: Reduce solid waste generation through requiring salvage and reuse of building
materials, including architecturally and historically significant materials.
Policy S-3.11: Encourage the use of reusable, returnable, recyclable and repairable goods,
and discourage the use of single use plastic water bottles and extended polystyrene
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 34
(Styrofoam), through enforcement of the City’s 2016 Plastic Foam Ordinance expansion and
continued incentives, education and responsible City purchasing policies.
The incorporation of relevant policies into the proposed Plan ensures the City’s ongoing
commitment to recycling and conservation in compliance with federal, State, and local laws.
Implementation of Mitigation Measure UTIL-15 would ensure that the City complies with
applicable solid waste regulations.
Resulting Significance: Less than Significant
Impact UTIL-17: The proposed Plan would not result in a substantial increase in natural gas
and electrical service demands that would require the new construction of energy supply
facilities and distribution infrastructure or capacity enhancing alterations to existing facilities.
However, without the adoption of policies in support of energy efficiency and conservation,
the proposed Plan would result in a potentially significant impact, requiring mitigation.
Mitigation Measure UTIL-17: To ensure that future development would maximize energy
efficiency and conservation the proposed Plan shall include policies that achieve the following:
Maximized conservation and efficient use of energy.
Continued procurement of carbon-neutral energy.
Investment in cost-effective energy efficiency and energy conservation programs.
Provision of public education programs addressing energy conservation and efficiency.
Use of cost-effective energy conservation measures in City projects and practices.
Adherence to State and federal energy efficiency standards and policies.
Consideration of a transition to a carbon-neutral natural gas supply.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure. For example:
Policy N-7.1: Continue to procure carbon neutral energy for both long-term and short-term
energy supplies, including renewable and hydroelectric resources, while investing in cost-
effective energy efficiency and energy conservation programs.
Policy N-7.4: Maximize the conservation and efficient use of energy in new and existing
residences and other buildings in Palo Alto.
Program N7.4.1: Continue timely incorporation of State and federal energy efficiency
standards and policies in relevant City codes, regulations and procedures and higher local
efficiency standards that are cost-effective.
Program N7.4.3: Incorporate cost-effective energy conservation measures into construction,
maintenance and City operation and procurement practices.
Program N7.4.5: Continue to provide public education programs addressing energy
conservation and efficiency.
Program N7.7.1: Evaluate the potential for a cost-effective plan for transitioning to a
completely carbon-neutral natural gas supply.
Policy N-7.8: Support opportunities to maximize energy recovery from organic materials
such as food scraps, yard trimmings and residual solids from sewage treatment.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 35
Policy S-3.10: Continue to implement the City’s Environmentally Preferred Purchasing policy
and programs to reduce waste, toxic product use, resource consumption and to maximize
energy efficiency.
The incorporation of relevant policies and programs into the proposed Plan ensures that the
City will continue its ongoing commitment to energy efficiency and conservation.
Implementation of Mitigation Measure UTIL-17 would ensure that the City is engaging in
planning to reduce natural gas and electricity demands in order to reduce potential impacts
associated with the construction of energy supply facilities.
Resulting Significance: Less than Significant
III. FINDINGS CONCERNING ALTERNATIVES
Significant and Unavoidable Impacts
CEQA provides that decision-makers should not approve a project as proposed if there are
feasible alternatives or feasible mitigation measures that would substantially lessen the
significant impacts of the project (CEQA Section 21002). The EIR identified feasible mitigation
measures that would reduce several of the potentially significant impacts to less than
significant, as further set forth in the Section II findings above. However, the following impacts
in the EIR remain significant after mitigation (i.e., significant and unavoidable) and no feasible
mitigation or project alternative is identified to reduce impact to less than significant:
1. Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard;
contribute substantially to an existing or project air quality violation; and/or result in a
cumulatively considerable net increase of any criteria pollutant for which the Project region
is nonattainment under an applicable federal or State ambient air quality standard
(including releasing emissions which exceed quantitative thresholds for ozone precursors).
2. Impact TRANS-1: Implementation of the project would cause an intersection to drop below
its motor vehicle level of service standard, or deteriorate operations at representative
intersections that already operate at a substandard level of service.
3. Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to
drop below its level of service standard, or deteriorate operations that already operate at a
substandard level of service.
4. Impact TRANS-6: Implementation of the project would impede the operation of a transit
system as a result of congestion.
All of these significant and unavoidable impacts arise from Palo Alto’s place within a growing
region where traffic increases are projected due to forces well beyond the City’s control.
Evaluations of virtually any long-range plan developed in this region would reach similar
conclusions using the thresholds of significance relied upon in the City’s environmental
documents. And even if the City does not update its Comprehensive Plan (as represented by
EIR Scenario 1), these impacts would remain significant and unavoidable after the City’s best
efforts at mitigation.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 36
In compliance with CEQA, the following findings address whether there are any feasible
alternatives or any additional feasible mitigation measures available that would reduce the
significant and unavoidable impacts identified in the EIR for the proposed project to less than
significant.
Project Alternatives
CEQA requires that an EIR "describe a range of reasonable alternatives to the project, or to the
location of the project, which would feasibly attain most of the basic objectives of the project
..." (CEQA Guidelines Section 15126.6(a)). “If a project alternative will substantially lessen the
significant environmental effects of a proposed project, the decision-maker should not approve
the proposed project unless it determines that specific economic, legal, social, technological, or
other considerations, ... make the project alternative infeasible.” (CEQA Sections 21002 and
21081(a)(3), and CEQA Guidelines Section 15091(a)(3).) The City Council hereby makes these
findings with respect to alternatives. The project objectives are set forth in Chapter 3 of the
Supplement to the Draft EIR.
As explained in Chapter 2 of the Final EIR and referenced sections of the February 2016 Draft
EIR and the Supplement to the Draft EIR, the City has assessed a “range of reasonable
alternatives” throughout the environmental document, in the form of four planning scenarios
(in the Draft EIR), two additional planning scenarios (in the Supplement to the Draft EIR), and a
hybrid “preferred scenario” (in the Final EIR).
In addition, Chapter 6 of the February 2016 Draft EIR and Supplement to the Draft EIR discuss a
“No Growth Scenario” and an “Environmentally Superior Alternative,” and both the Draft EIR
and the Supplement to the Draft EIR discuss alternatives considered and rejected, with an
explanation as to why certain concepts were not carried forward for detailed analysis.
As further set forth below, the City Council has considered all of the possible alternatives
(including the planning scenarios) identified and analyzed in EIR and has elected to adopt the
preferred scenario described in Chapter 2 of the Final EIR. None of the other scenarios and
alternatives would eliminate the significant impacts identified above, and the City finds that
doing so would be infeasible for specific economic, social, or other considerations pursuant to
CEQA Sections 21002 and 21081(a)(3), and CEQA Guidelines Section 15091(a)(3). For CEQA
purposes, “feasible” means capable of being accomplished in a successful manner within a
reasonable period of time, taking into account economic, environmental, social, technological,
and legal factors. (CEQA Section 21061.1, CEQA Guidelines Section 15364.)
1. No Project Alternative (Scenario 1)
CEQA Guidelines Section 15126.6(e) requires that a "No Project Alternative" be evaluated as
part of an EIR. Scenario 1 represents a “Business as Usual” scenario that approximates what is
expected to occur if the 1998 Comprehensive Plan is not updated and the proposed Plan is not
adopted. Thus Scenario 1 represents the “no project alternative” required by CEQA Guidelines
Section 15126.6(e).
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 37
Scenario 1 would be expected to result in less residential development than the preferred
scenario, but would result in a higher increase in employment than the preferred scenario. As
shown in Table 1-3 of the Supplement to the Draft EIR, Scenario 1 would not avoid any of the
significant and unavoidable impacts identified for the scenarios. Scenario 1 would also not
include any of the policy adjustments included in the June 30, 2017 Draft of the Comprehensive
Plan Update, new innovations in housing or new approaches to address the high cost of housing
or high jobs-to-employed-residents balance in the city. Under Scenario 1, the Comprehensive
Plan would also not be updated to include new policies related to climate change,
transportation demand management (TDM), and transit-oriented development. Without
policies to address these key issues, Scenario 1 would not fully achieve the City’s objectives to
updates the vision for Palo Alto’s future to reflect current conditions and anticipated trends.
Finding: The City Council considered a No Project Alterative and declines to adopt it because it
does not reduce the project’s significant and unavoidable impacts and is inconsistent with
several of the project objectives including:
Provide a legally adequate Comprehensive Plan that updates the vision for Palo Alto’s future
to reflect current conditions and anticipated trends.
Establish performance standards to ensure that future development contributes to and does
not detract from Palo Alto’s quality of life.
Identify needed roadway improvements to address congestion related to future
development.
Enable resiliency and adaptation to respond to the consequences of climate change.
Support Palo Alto’s leadership in relationships with neighboring jurisdictions and State and
regional agencies.
A comprehensive plan is intended to be an integrated, internally consistent and compatible
statement of city policies. State law requires that comprehensive plans be periodically reviewed
and revised as necessary (Government Code Sections 65040.5, 65300, 65300.5). Retaining the
current comprehensive plan, last comprehensively updated in 1998, without an update to
reflect changes in the City’s vision for its development and preservation would not be consistent
with State planning law. For all of these reasons, this alternative is infeasible, as supported by
the administrative record for the proposed project.
2. No Growth Scenario
Appendix H of the Supplement to the Draft EIR provides a discussion and analysis of a “No
Growth Scenario,” conducted as a purely hypothetical exercise to highlight the extent to which
the proposed Plan’s significant and unavoidable impacts result from regional growth outside of
Palo Alto. The No Growth Scenario analysis assumes that the proposed Plan is not adopted and
that no growth in population, employment, or square footage would occur in Palo Alto by 2030
beyond the amount of development existing in 2014, plus new growth permitted by fall 2016.
Although the No Growth Scenario would result in less development than the preferred scenario,
as discussed in Appendix H of the Supplement to the Draft EIR, the No Growth Scenario would
not avoid any of the significant and unavoidable impacts identified for the project. This
illustrates that, even if Palo Alto were to put measures in place to halt future growth entirely,
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 38
the surrounding region would continue to grow, and as a result many of the impacts identified
in the EIR would still occur.
The No Growth Scenario is purely hypothetical and would not include strategies to address
housing needs, climate change goals, or TDM strategies. Therefore, the No Growth Scenario
would not meet the project objectives. Moreover, it is infeasible to implement, as it would be
impractical and/or illegal for the City to prevent existing residents from adding to their
households or families, and stopping residential growth would violate State housing laws that
require local governments to participate in “accommodat[ing] the housing needs of Californians
of all economic levels” (California Government Code Section 65580 et seq.). In terms of job
growth, while the City could conceivably prevent development of additional non-residential
square footage, it would be very difficult to stop employers from adding new employees to
existing buildings, and such a moratorium would create intense demand for office space in Palo
Alto, increasing commercial rents and creating pressure for non-residential uses such as
retail/service business and lower-rent office uses to convert to high-rent, tech-based office and
research and development (R&D) uses.
Finding: The City Council considered the No Growth Scenario and declines to adopt it because it
is infeasible, does not reduce the project’s significant and unavoidable impacts, and is
inconsistent with several of the project objectives, including:
Provide a legally adequate Comprehensive Plan that updates the vision for Palo Alto’s future
to reflect current conditions and anticipated trends.
Guide future land use and development decisions and assist staff and decision-makers in
balancing sometimes competing interests.
Address the needs of a changing population and accommodate additional housing.
Establish performance standards to ensure that future development contributes to and does
not detract from Palo Alto’s quality of life.
Reduce the impacts of cars on the environment and improve options for pedestrians,
bicyclists, and transit-users.
Preserve existing single-family neighborhoods while allowing the development of diverse
types of housing affordable to all members of the community.
Identify needed roadway improvements to address congestion related to future
development.
Enable resiliency and adaptation to respond to the consequences of climate change.
Enable the City to deliver top-quality community services to all residents.
Retain existing businesses, maintain vital commercial areas, and attract quality new
businesses.
Support Palo Alto’s leadership in relationships with neighboring jurisdictions and State and
regional agencies.
For all of these reasons, this alternative is infeasible, as supported by the administrative record
for the proposed project.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 39
3. Hybrid Alternative
Chapter 6 of the February 2016 Draft EIR and Supplement to the Draft EIR provide a discussion
of a “Hybrid Alternative.” The discussion of the Hybrid Alternative explains that the scenario
adopted by the City as the Comprehensive Plan Update would not be expected to be identical
to any of the scenarios analyzed in the February 2016 Draft EIR and Supplement to the Draft
EIR, but would rather draw from the scenarios and combine components of various scenarios.
The discussion also explains that the Hybrid Alternative would be developed based, in part, on
the data and analysis that the February 2016 Draft EIR and Supplement to the Draft EIR provide.
Based on the EIR’s conclusions, the Supplement to the Draft EIR states that a Hybrid Alternative
would likely be one that combines the moderate rates of housing growth in Scenarios 3 and 5
with the sustainability initiatives tested in Scenarios 4 through 6. The Supplement to the Draft
EIR did not predict the number of jobs that would be included in the Hybrid Alternative, but did
explain that a lower level of job growth, such as under Scenario 5, would result in fewer GHG
emissions.
Overall, the Hybrid Alternative would have impacts similar to those of Scenarios 1 through 6.
Aesthetics, land use, and population/housing impacts would be similar to Scenarios 3 and 5 if
housing sites along San Antonio and South El Camino are eliminated and replaced by higher
densities on existing sites closer to transit and services, and if growth control measures are
similar to those adopted by the City Council on an interim basis in 2015. The Hybrid Alternative
would also have similar less-than-significant impacts to Scenario 2, 3, or 5 in the topic areas of
biological resources, cultural resources, geology, hazardous materials, hydrology, public services,
and utilities. The Hybrid Alternative could further reduce the transportation, air quality, noise,
and greenhouse gas emission impacts associated with Scenario 3 by incorporating some of the
sustainability features included in Scenarios 4 through 6 to reduce traffic and vehicle miles
traveled.
Although, as with Scenarios 1 through 6, proposed mitigation measures could address some of
the Hybrid Alternative’s impacts related to transportation, air quality, and noise, some impacts
related to transportation and air quality, although reduced, would remain significant even after
mitigation measures are applied. The Hybrid Alternative contemplates lower levels of job
growth than the preferred scenario, but it also includes lower rates of housing growth than the
preferred scenario, so the Hybrid Alternative would be expected to result in a higher jobs-to-
employed-residents ratio than the preferred scenario, and therefore would not meet the City’s
goals to reduce this ratio.
Finding: The City Council considered the Hybrid Alternative and declines to adopt it because it
does not reduce the project’s significant and unavoidable impacts and it does not promote as
well as the preferred scenario the City’s policy goals and objectives of accommodating
anticipated housing growth and improving the City’s jobs to housing (employed resident)
imbalance, all as supported by the administrative record for the proposed project.
4. Planning Scenarios 2 Through 6
Scenarios 2 through 6 in the Draft EIR and the Supplement to the Draft EIR are part of the
reasonable range of alternatives the City has considered because they present different ways
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 40
that the City could plan for its future and vary in terms of the housing and employment
projected to occur by the horizon year of 2030. The preferred scenario that has been selected
for adoption shares many characteristics with these other planning scenarios, and was
developed by the City Council based on extensive community input and deliberations. As
described in Chapter 2 of the Final EIR, the preferred scenario is essentially a hybrid of the
other Scenarios, and represents the evolution of a long public planning process.
There are not substantial differences in the number or extent of environmental impacts among
the scenarios evaluated in the February 2016 Draft EIR and Supplement to the Draft EIR. While
the majority of potential impacts could be mitigated to a less-than-significant level, all of the
scenarios would result in the same significant and unavoidable impacts to air quality and
transportation, and the preferred scenario would result in the same significant and unavoidable
impacts. However, there are differences of degree among the scenarios, as described below.
A. Scenario 2
Although similar to the preferred scenario, Scenario 2 would result in slightly lower motor
vehicle trips than the preferred scenario. Scenario 2 would also result in a lower level of
population and jobs growth. Therefore, Scenario 2 would result in lower greenhouse gas and air
quality emissions than the preferred scenario. However, Scenario 2 would result in a greater
jobs/housing imbalance than the preferred scenario and would not meet the City’s goal to
expand housing options as well as the preferred scenario.
B. Scenario 3
Scenario 3 would result in more motor vehicle trips than the preferred scenario. Scenario 3
would result in a level of population growth equal to the lower end of the preferred scenario,
and a higher level of job growth. Therefore, Scenario 3 would result in higher levels of
greenhouse gas and air quality emissions than the preferred scenario. Overall, Scenario 3 would
result in a greater jobs/housing imbalance than the preferred scenario and would not meet the
City’s sustainability goals as well as the preferred scenario.
C. Scenario 4
Scenario 4 would result in lower motor vehicle trips than the preferred scenario. Scenario 4
would result in a level of population growth equal to the higher end of the preferred scenario,
and a higher level of job growth. Overall, due to its lower motor vehicle trips, Scenario 4 would
be expected to result in lower greenhouse gas and air quality emissions than the preferred
scenario. However, Scenario 4 would result in a greater jobs/housing imbalance than the
preferred scenario, which would conflict with City goals.
D. Scenario 5
Scenario 5 would result in the fewest motor vehicle trips of all the scenarios (including the
preferred scenario). Scenario 5 would result in a level of population growth equal to the lower
end of the preferred scenario, and less jobs growth than the preferred scenario. Overall,
Scenario 5 would result in a similar jobs/housing balance as the preferred scenario (slightly
higher than the preferred scenario within the city but lower within the city plus Sphere of
Influence). In addition, Scenario 5 would include the sustainability measures of Scenarios 4 and
6. Overall, due to its lower motor vehicle trips, lower overall growth, and similar jobs/housing
balance, Scenario 5 would be expected to result in lower greenhouse gas and air quality
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 41
emissions than the preferred scenario. By combining the rigorous sustainability initiatives of
Scenarios 4 and 6 with the modest housing growth of Scenario 3 and low job growth of Scenario
6, Scenario 5 would be the environmentally preferred scenario. However, Scenario 5 would not
meet the City’s goals to expand housing options.
E. Scenario 6
Scenario 6 would result in lower motor vehicle trips than the preferred scenario. Scenario 6
would result in more population growth and less jobs growth than the preferred scenario and
would achieve the lowest jobs-to-employed-residents ratio of all the scenarios (including the
preferred scenario). In addition, Scenario 6 would include the sustainability measures of
Scenarios 4 and 5. Overall, due to its lower motor vehicle trips and jobs/housing balance,
Scenario 6 would be expected to result in lower greenhouse gas and air quality emissions than
the preferred scenario. Scenario 6 would have the highest population growth of any scenario,
exceeding regional projections and resulting in the greatest demand for schools, parkland, and
services provided to residents. As a result, Scenario 6 would not meet the project objective
regarding service delivery as well as the preferred scenario.
Finding: The City Council considered Scenarios 2 through 6 and declines to adopt any of these
scenarios. Scenario 3 would not reduce the project’s significant and unavoidable impacts.
Scenarios 2, 4, 5, and 6 would somewhat lessen, but would not avoid, the project’s significant
and unavoidable impacts, but are less responsive to the project objectives than the preferred
scenario, particularly to the objective to address the needs of a changing population,
accommodating additional housing, and enabling delivery of top-quality community services to
all residents.
IV. STATEMENT OF OVERRIDING CONSIDERATIONS
The City Council of the City of Palo Alto adopts and makes the following Statement of
Overriding Considerations regarding the significant, unavoidable impacts of the Project and the
anticipated benefits of the Project.
General. The City is considering approval of the Comprehensive Plan Update 2030 (“proposed
project”).
CEQA requires decision-makers to balance the economic, legal, social, technological or other
benefits of a proposed project against its unavoidable impacts when determining whether to
approve the project. If the specific benefits of a project outweigh the unavoidable adverse
environmental effects, those effects may be considered acceptable, and the agency must state
the specific reasons to support the action in a “statement of overriding considerations”
supported by substantial evidence in the record. (CEQA Guidelines Section 15903). Pursuant
to CEQA Guidelines Section 15093, the City Council must adopt a Statement of Overriding
Considerations for the significant and unavoidable impacts of the project in connection with
approval of the project. The City Council believes that many of the unavoidable environmental
effects identified in the EIR will be substantially lessened by mitigation measures adopted with
the EIR and implemented with future development and actions taken under the project. Even
with mitigation, the City Council recognizes that the implementation of the project carries
with it significant and unavoidable environmental effects, as identified in the EIR.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 42
Adoption of the June 30, 2017 Draft of the Comprehensive Plan Update 2030, with the specific
changes included in the City Council’s resolution, would result in the following significant and
unavoidable impacts:
5. Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard;
contribute substantially to an existing or project air quality violation; and/or result in a
cumulatively considerable net increase of any criteria pollutant for which the Project region
is nonattainment under an applicable federal or State ambient air quality standard
(including releasing emissions which exceed quantitative thresholds for ozone precursors).
6. Impact TRANS-1: Implementation of the project would cause an intersection to drop below
its motor vehicle level of service standard, or deteriorate operations at representative
intersections that already operate at a substandard level of service.
7. Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to
drop below its level of service standard, or deteriorate operations that already operate at a
substandard level of service.
8. Impact TRANS-6: Implementation of the project would impede the operation of a transit
system as a result of congestion.
Overriding Considerations
The City Council has carefully considered each significant unavoidable project impact in
reaching its decision to approve the project. Even with mitigation, the City Council recognizes
that implementation of the project carries with it unavoidable adverse environmental effects,
as identified in the EIR. The City Council specifically finds that, to the extent that the identified
significant adverse impacts for the project have not been reduced to acceptable levels through
feasible mitigation or alternatives, there are specific economic, legal, social, technological, or
other benefits, including region-wide or statewide environmental benefits that outweigh the
project’s significant unavoidable impacts and support approval of the project. Any one of these
benefits as set forth below is sufficient to justify approval of the project. The substantial
evidence supporting the various benefits is in the record as a whole.
The following statement identifies the reasons why, in the City’s judgment, specific benefits of
the project outweigh the significant and unavoidable effects. The City finds that each of the
project benefits discussed below is a separate and independent basis for these findings. The
reasons set forth below are based on the Final EIR and other information in the administrative
record.
Economic Benefits
1. The proposed Plan strengthens strategies to preserve retail.
2. The proposed Plan includes a cumulative “cap” on the amount of new office/research and
development (R&D) space that would allow up to 1.7 million square feet of new office/R&D
uses over the life of the plan.
3. The proposed Plan allows the City to remain a competitive and innovative business
destination.
Legal Benefits
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 43
1. The proposed Plan updates sections of the City’s Comprehensive Plan that are required by
State law, and the State recommends that local jurisdictions update their plans every
10 years.
Social Benefits
1. The proposed Plan was developed to reflect community priorities and concerns, with
extensive input from the general public, a Citizens Advisory Committee, the Planning and
Transportation Commission, and the City Council.
2. The proposed Plan responds to community concerns about housing affordability and
availability.
3. The proposed Plan would allow a balance of development that would help to reduce the
City’s jobs/housing imbalance.
4. The proposed Plan would preserve existing parks, recreational facilities, and open space
areas.
5. The proposed Plan would protect and preserve existing residential neighborhoods.
Technological Benefits
1. The proposed Plan supports Caltrain modernization, including electrification.
Environmental Benefits
1. The proposed Plan updates the City’s policy framework to address important contemporary
environmental issues, including as climate change and greenhouse gas emissions.
2. The proposed Plan includes a program to formalize transportation demand management
(TDM) requirements.
3. The proposed Plan would protect and enhance the urban forest as natural infrastructure.
4. The proposed Plan concentrates growth in existing corridors and nodes, and thereby results
in fewer impacts from the construction of new infrastructure and reduces vehicle miles
traveled per capita, which translates into air quality and greenhouse gas emissions benefits
and increases in resources and energy efficiency.
5. The proposed Plan includes policies that encourage conservation of water and energy
resources in conformance with the City’s sustainability goals.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 44
V. MITIGATION MONITORING AND REPORTING PROGRAM
Attached to this Resolution as Exhibit A and incorporated and adopted as part of this
Resolution herein is the Mitigation Monitoring and Reporting Program (“MMRP”) for the
Project required under Public Resources Code Section 21081.6. The MMRP identifies impacts
of the Project, corresponding mitigation, timing for implementation, and designation for
responsibility for mitigation implementation and monitoring.
VI. LOCATION AND CUSTODIAN OF RECORDS
The documents and other materials that constitute the record of proceedings on which the City
Council based the foregoing findings and approval of the Project are located at the Department
of Planning and Community Environment, 285 Hamilton Avenue, Palo Alto, CA 94301. The
official custodian of the record is the Planning and Community Environment Director at the
same address.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST: APPROVED:
______________________________ _________________________________
City Clerk Mayor
APPROVED AS TO FORM: _________________________________
City Manager
_______________________________
Assistant City Attorney _________________________________
Director of Planning and Community
Environment
PLACEWORKS 1
Mitigation Monitoring and Reporting Program
This Mitigation Monitoring and Reporting Program (MMRP) for the City of Palo Alto is intended to ensure
the implementation of mitigation measures identified as part of the environmental review for the proposed
project. The proposed project is the adoption and implementation of an updated Comprehensive Plan for
the City of Palo Alto, along with associated amendments to the City of Palo Alto Zoning Code. The MMRP
includes the following information:
A list of mitigation measures.
The timing for implementation of each mitigation measure.
The agency responsible for monitoring implementation.
The monitoring action and frequency.
The City of Palo Alto must adopt this MMRP, or an equally effective program, if it adopts the City of Palo
Alto Comprehensive Plan Update and associated Zoning Code amendments with the mitigation measures
that were adopted or made conditions of project adoption.
EXHIBIT A
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
2 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Aesthetics and Visual
Resources
AES-1: Implementation of
the proposed Plan would
have the potential to
substantially degrade the
existing visual character or
quality of the area and its
surroundings.
AES-1: To ensure that increased residential densities
would not degrade the visual character or quality of
the area, the proposed Plan shall include policies
that achieve the following:
High-quality building and site design.
Compatibility with the neighborhood and
adjacent structures.
Enhancement of existing commercial centers.
Requirements for landscaping and street trees.
Preservation and creation of a safe and inviting
pedestrian environment.
Appropriate building form, massing, and setbacks.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
Planning and
Community
Environment
(PCE)
Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AES-4: Implementation of
the proposed Plan would
have the potential to
substantially shadow public
open space (other than
public open streets and
adjacent sidewalks) between
9:00 a.m. and 3:00 p.m.
from September 21 to
March 21.
AES-4: The City shall amend its local CEQA guidelines
to require development projects of a certain size or
location to prepare an analysis of potential
shade/shadow impacts. The analysis shall focus on
potential impacts to public open spaces (other than
public streets and adjacent sidewalks) between 9:00
a.m. and 3:00 p.m. from September 21 to March 21.
The analysis shall identify whether the project would
shadow open spaces during these times, explain how
the project meets City design requirements and
other City policy goals, and describe ways to mitigate
substantial shade and shadow impacts through
feasible building and site design features.
City of Palo Alto
PCE Department
Within twelve
months of
proposed
Comprehensive
Plan adoption
City of Palo Alto
PCE Department
Confirm update of CEQA
guidelines.
Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 3
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Air Quality
AIR-1: Without inclusion of
air quality policies,
implementation of the
proposed Plan could conflict
with or obstruct
implementation of the
applicable air quality plan.
AIR-1: To ensure consistency with the 2010 Bay Area
Clean Air Plan, the proposed Plan shall include
policies that achieve the following:
Reduction in emissions of particulates from
automobiles, manufacturing, construction
activity, and other sources (e.g., dry cleaning,
wood burning, landscape maintenance).
Support for regional, State, and federal programs
that improve air quality.
Support for transit, bicycling, and walking.
Mix of uses (e.g., housing near employment
centers) and development types (e.g., infill) to
reduce the need to drive.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-2: Implementation of
the proposed Plan could
violate an air quality
standard; contribute
substantially to an existing
or project air quality
violation; and/or result in a
cumulatively considerable
net increase of any criteria
pollutant for which the
Project region is
nonattainment under an
applicable federal or State
ambient air quality standard
(including releasing
emissions which exceed
quantitative thresholds for
ozone precursors).
AIR-2a: The City shall amend its local CEQA
Guidelines and Municipal Code to require, as part of
the City’s development approval process, that future
development projects comply with the current
BAAQMD basic control measures for reducing
construction emissions of PM10 (Table 8-2, Basic
Construction Mitigation Measures Recommended
for All Proposed Projects, of the BAAQMD CEQA
Guidelines).
City of Palo Alto
PCE Department
Within twelve
months of
proposed
Comprehensive
Plan adoption
City of Palo Alto
PCE Department
Confirm update of CEQA
guidelines and Municipal Code.
Once
AIR-2b: The City shall amend its local CEQA
Guidelines to require that, prior to issuance of
construction permits, development project
City of Palo Alto
PCE Department
Within twelve
months of
proposed
City of Palo Alto
PCE Department
Confirm update of CEQA
guidelines.
Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
4 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
applicants that are subject to CEQA and have the
potential to exceed the BAAQMD screening-criteria
listed in the BAAQMD CEQA Guidelines prepare and
submit to the City of Palo Alto a technical
assessment evaluating potential project
construction-related air quality impacts. The
evaluation shall be prepared in conformance with
BAAQMD methodology in assessing air quality
impacts. If construction-related criteria air pollutants
are determined to have the potential to exceed the
BAAQMD thresholds of significance, as identified in
the BAAQMD CEQA Guidelines, the City of Palo Alto
shall require that applicants for new development
projects incorporate mitigation measures (Table 8-3,
Additional Construction Mitigation Measures
Recommended for Projects with Construction
Emissions Above the Threshold, of the BAAQMD
CEQA Guidelines or applicable construction
mitigation measures subsequently approved by
BAAQMD) to reduce air pollutant emissions during
construction activities to below these thresholds.
These identified measures shall be incorporated into
all appropriate construction documents (e.g.,
construction management plans) submitted to the
City.
Comprehensive
Plan adoption
AIR-2c: To ensure that development projects that
have the potential to exceed the BAAQMD screening
criteria air pollutants listed in the BAAQMD CEQA
Guidelines reduce regional air pollutant emissions
below the BAAQMD thresholds of significance, the
proposed Plan shall include policies that require
compliance with BAAQMD requirements, including
BAAQMD CEQA Guidelines.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-2d: Implement Mitigation Measures TRANS-1a
and TRANS-1b. In addition, to reduce long-term air
quality impacts by emphasizing walkable
neighborhoods and supporting alternative modes of
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 5
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
transportation, the proposed Plan shall include
policies that achieve the following:
Enhanced pedestrian and bicycle connections
between commercial and mixed-use centers.
AIR-3: Implementation of
the proposed Plan would
expose sensitive receptors
to substantial
concentrations of air
pollution.
AIR-3a: The City of Palo Alto shall update its CEQA
Procedures to require that future non-residential
projects within the city that: 1) have the potential to
generate 100 or more diesel truck trips per day or
have 40 or more trucks with operating diesel-
powered TRUs, and 2) are within 1,000 feet of a
sensitive land use (e.g., residential, schools,
hospitals, nursing homes), as measured from the
property line of a proposed project to the property
line of the nearest sensitive use, shall submit a
health risk assessment (HRA) to the City of Palo Alto
prior to future discretionary project approval or shall
comply with best practices recommended for
implementation by the BAAQMD.
The HRA shall be prepared in accordance with
policies and procedures of the State Office of
Environmental Health Hazard Assessment and the
Bay Area Air Quality Management District. If the HRA
shows that the incremental cancer risk exceeds the
BAAQMD significance thresholds, the applicant will
be required to identify and demonstrate that
mitigation measures are capable of reducing
potential cancer and noncancer risks to an
acceptable level, including appropriate enforcement
mechanisms.
Mitigation measures and best practices may include
but are not limited to:
Restricting idling on-site beyond Air Toxic Control
Measures idling restrictions, as feasible.
Electrifying warehousing docks.
Requiring use of newer equipment and/or
vehicles.
City of Palo Alto
PCE Department
Within twelve
months of Plan
adoption
City of Palo Alto
PCE Department
Confirm update of CEQA
Procedures.
Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
6 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Restricting off-site truck travel through the
creation of truck routes.
Mitigation measures identified in the project-specific
HRA shall be identified as mitigation measures in the
environmental document and/or incorporated into
the site development plan as a component of a
proposed project.
AIR-3b: To ensure that new industrial and
warehousing projects with the potential to generate
new stationary and mobile sources of air toxics that
exceed the BAAQMD project-level and/or cumulative
significance thresholds for toxic air contaminants
and PM2.5 listed in the BAAQMD CEQA Guidelines
reduce emissions below the BAAQMD thresholds of
significance, amend the City’s CEQA guidelines to
require compliance with BAAQMD requirements.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-3c: The proposed Plan shall include policies to
mitigate potential sources of toxic air contaminants
through siting or other means to reduce human
health risks and meet the Bay Area Air Quality
Management District’s applicable threshold of
significance. Policies shall also require that new
sensitive land use projects (e.g., residences, schools,
hospitals, nursing homes, parks or playgrounds, and
day care centers) within 1,000 feet of a major
stationary source of TACs and roadways with traffic
volumes over 10,000 vehicles per day consider
potential health risks and incorporate adequate
precautions, such as high-efficiency air filtration, into
project design.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-4: Implementation of
the proposed Plan could
create or expose a
substantial number of
people to objectionable
odors unless policies are
AIR-4: To reduce odor impacts, the proposed Plan
shall include policies requiring:
Buffers, mechanical, and other mitigation
methods to avoid creating a nuisance.
Implementation is complete with the
adoption and implementation of the
policies and programs in the
proposed Comprehensive Plan
Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 7
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
integrated into the proposed
Plan.
Cultural Resources
CULT-1: Implementation of
the proposed Plan could
adversely affect a historic
resource listed or eligible for
listing on the National
and/or California Register, or
listed on the City’s Historic
Inventory.
CULT-1: To ensure the protection of potentially
historic resources, the proposed Plan shall include
policies that achieve the following:
Process for reviewing proposed demolition or
alteration of potentially historic buildings.
Protection of archaeological resources.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
CULT-2: Implementation of
the proposed Plan could
eliminate important
examples of major periods
of California history or
prehistory.
CULT-2: Implement Mitigation Measure CULT-1. See Mitigation Measure CULT-1.
CULT-3: Implementation of
the proposed Plan could
cause damage to an
important archaeological
resource as defined in
Section 15064.5 of the CEQA
Guidelines.
CULT-3: Implement Mitigation Measure CULT-1. In
addition, to ensure that future development would
not damage archaeological resources, the proposed
Plan shall include policies that achieve the following:
Archaeological surveys and mitigation plans for
future development projects.
Developer compliance with applicable regulations
regarding the identification and protection of
archaeological and paleontological deposits, and
unique geologic features.
Appropriate tribal consultation and consideration
of tribal concerns.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
CULT-5: Implementation of
the proposed Plan would
have the potential to directly
or indirectly destroy a
unique paleontological
resource or site or unique
CULT-5: Implement Mitigation Measure CULT-3.
See Mitigation Measure CULT-3.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
8 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
geologic feature.
CULT-7: Implementation of
the proposed Plan, in
combination with past,
present, and reasonably
foreseeable projects, would
result in significant
cumulative impacts with
respect to cultural
resources.
CULT-7: Implement Mitigation Measures CULT-1 and
CULT-3.
See Mitigation Measures CULT-1 and CULT-3.
Greenhouse Gas Emissions and Climate Change
GHG-3: The proposed Plan
would expose people or
structures to the physical
effects of climate change,
including but not limited to
flooding, extreme
temperatures, public health,
wildfire risk, or other
impacts resulting from
climate change, requiring
mitigation.
GHG-3: To address the potential impacts associated
with exposing people to the effects of climate
change, the proposed Plan shall include policies that
achieve the following:
Monitoring and response to flooding risks caused
by climate change-related changes to
precipitation patterns, groundwater levels, sea
level rise, tides, and storm surges.
Cooperative planning with federal, State,
regional, and local public agencies on issues
related to climate change (including sea level rise
and extreme storms).
Preparation of response strategies to address sea
level rise, increased flooding, landslides, soil
erosion, storm events, and other events related
to climate change.
Implementation of adaptive strategies to address
impacts of sea level rise on Palo Alto’s levee
system.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 9
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Hydrology and Water Quality
HYD-2: The proposed Plan
could substantially degrade
or deplete ground water
resources or interfere
substantially with
groundwater recharge such
that there would be a net
deficit in aquifer volume or a
lowering of the local
groundwater table level.
HYD-2: To reduce potential impacts associated with
construction dewatering the proposed Plan shall
include policies that achieve the following:
Avoidance of the impacts of basement
construction for single-family homes on the
natural environment and safety.
Conservation of subsurface water resources.
Construction techniques and recharge strategies
to reduce subsurface and surface water impacts.
Monitoring of dewatering and excavation
projects.
Cooperation with other jurisdictions and regional
agencies to protect groundwater.
Protection of groundwater as a natural resource.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
Land Use and Planning
LAND-1: The proposed Plan
could adversely change the
type or intensity of existing
or planned land use patterns
in the area.
LAND-1: To ensure that the intensity of future
development would not adversely change the land
use patterns or affect the livability of Palo Alto
neighborhoods, the proposed Plan shall include
policies that achieve the following:
Strengthening of residential neighborhoods.
Vitality of commercial areas and public facilities.
High-quality building and site design.
Architectural compatibility of new development.
Compatible infill development.
Avoidance of abrupt changes in the scale of
development where residential districts abut
more intense uses.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
LAND-2: The proposed Plan
would allow development
that could be incompatible
with adjacent land uses or
with the general character of
LAND-2: Implement Mitigation Measure LAND-1. In
addition, to further reduce potential impacts to
visual character and ensure compatibility with
adjacent land uses, the proposed Plan shall include
policies that achieve the following:
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
10 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
the surrounding area,
including density and
building height.
Use of City procedures, plans, and requirements
to ensure high-quality building design and
architectural compatibility.
LAND-5: The proposed Plan
could physically divide an
established community.
LAND-5: To avoid potential impacts from physically
dividing an established community, the proposed
Plan shall include policies that achieve the following:
Enhanced connections to and from parks, schools,
and community facilities for all users.
Safe and convenient pedestrian, bicycle, and
transit connections between residential areas and
commercial centers.
Cooperation with other agencies to improve
circulation connections.
Grade separation of rail crossings.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
Noise
NOISE-1: Implementation of
the proposed Plan would
have the potential to cause
the average 24-hour noise
level (Ldn) to increase by 5.0
decibels (dB) or more in an
existing residential area,
even if the Ldn would remain
below 60 dB.
NOISE-1a: To ensure that average 24-hour noise
levels associated with long-term operational noise
would not increase by 5.0 decibels (dB) or more in
an existing residential area, the proposed Plan shall
include policies that achieve the following:
Location of land uses in areas with compatible
noise environments.
Use of the guidelines in the “Land Use
Compatibility for Community Noise Environment”
table in the proposed Plan to evaluate the
compatibility of proposed land uses with existing
noise environments.
Clear guidelines for maximum outdoor noise
levels in residential areas.
Adherence to the interior noise requirements of
the State of California Building Standards Code
(Title 24) and the Noise Insulation Standards (Title
25).
Inclusion of a noise contour map in the proposed
Plan.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 11
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Reduction of noise impacts of development on
adjacent properties.
Evaluation of noise impacts on existing
residential, open space, and conservation land.
Requirement for new projects in the Multiple
Family, Commercial, Manufacturing, or Planned
Community districts to demonstrate compliance
with the Noise Ordinance.
NOISE-1b: To reduce potential impacts to new land
uses from aircraft noise, the proposed Plan shall
include policies that achieve the following:
Compliance with the airport-related land use
compatibility standards for community noise
environments.
Prohibition of incompatible land use development
within the 60 dBA CNEL noise contours of the
Palo Alto airport, as established in the adopted
County of Santa Clara Airport Land Use
Commission Comprehensive Land Use Plan
(CLUP) for the Palo Alto Airport.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-1c: To reduce potential impacts to new land
uses from railway noise, the proposed Plan shall
include policies that achieve the following:
Minimization of noise spillover from rail-related
activities into adjacent residential or noise-
sensitive areas.
Building design that reduces impacts from noise
and ground borne vibrations associated with rail
operations.
Guidelines for interior noise levels.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-2: Implementation of
the proposed Plan would
have the potential to cause
the Ldn to increase by 3 dB or
more in an existing
residential area, thereby
NOISE-2: Implement Mitigation Measures NOISE-1a,
NOISE-1b, and NOISE-1c.
See Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
12 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
causing the Ldn in the area to
exceed 60 dB.
NOISE-3: Implementation of
the proposed Plan would
have the potential to cause
an increase of 3 dB or more
in an existing residential
area where the Ldn currently
exceeds 60 dB.
NOISE-3: Implement Mitigation Measures NOISE-1a,
NOISE-1b, and NOISE-1c.
See Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
NOISE-4: Implementation of
the proposed Plan would
have the potential to result
in indoor noise levels for
residential development to
exceed an Ldn of 45 dB.
NOISE-4a: Implement Mitigation Measure NOISE-1a. See Mitigation Measure NOISE-1a.
NOISE-4b: The Land Use Noise Compatibility
Guidelines established in the 1998 Comprehensive
Plan shall be maintained.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-5: Implementation of
the proposed Plan would
have the potential to expose
persons to or generate
excessive ground-borne
vibration or ground-borne
noise levels.
NOISE-5a: To ensure that future development would
not result in significant construction-related
vibration impacts, the proposed Plan shall include
policies that limit the hours of construction around
sensitive receptors, and require formal, ongoing
monitoring and reporting throughout the
construction process for larger development
projects, as well as the use of pertinent industry
standards and City guidelines to avoid significant
vibration impacts during construction or operations.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-5b: Implement Mitigation Measure NOISE-1c. See Mitigation Measure NOISE-1c.
NOISE-6: Implementation of
the proposed Plan would
have the potential to expose
people to noise levels in
excess of established State
standards.
NOISE-6: Implement Mitigation Measures NOISE-4a
and NOISE-4b.
See Mitigation Measures NOISE-4a and NOISE-4b.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 13
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
NOISE-7: Implementation of
the proposed Plan would
have the potential to result
in the exposure of persons
to or generation of noise
levels in excess of standards
established in the local
General Plan or noise
ordinance, or applicable
standards of other agencies.
NOISE-7: Implement Mitigation Measures NOISE-1a,
NOISE-1b, NOISE-1c, NOISE-4a, and NOISE-4b.
See Mitigation Measures NOISE-1a, NOISE-1b, NOISE-1c, NOISE-4a, and NOISE-4b.
NOISE-8: Implementation of
the proposed Plan could
result in a potentially
substantial temporary or
periodic increase in ambient
noise levels in the project
vicinity above levels existing
without the project.
NOISE-8: To ensure that future development would
not result in significant impacts to sensitive
receptors from construction noise, the proposed
Plan shall include policies that achieve the following:
Construction noise limits around sensitive
receptors.
Monitoring and reporting plans for construction
noise levels of larger development projects.
Noise control measures to ensure compliance
with the noise ordinance.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-11: Implementation
of the proposed Plan, in
combination with past,
present, and reasonably
foreseeable projects, may
result in significant
cumulative impacts with
respect to noise.
NOISE-11a: Implement Mitigation Measure NOISE-
1c.
See Mitigation Measure NOISE-1c.
NOISE-11b: To address overall community noise
impacts from train noise to the extent such noise is
within the City’s control and in excess of established
State and/or City standards, the proposed Plan shall
include policies that achieve the following:
Efforts to develop and implement technological
methods to reduce train whistle noise from
Caltrain.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
14 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Evaluation of at-grade rail crossings as potential
Quiet Zones based on Federal Railroad
Administration (FRA) rules and guidelines.
Grade separation of rail crossings as a City
priority.
Public Services and
Recreation
PS-7: Implementation of the
proposed Plan would result
in an adverse physical
impact from the
construction of additional
parks and recreation
facilities in order to maintain
acceptable performance
standards.
PS-7: To address the potential physical impacts of
park construction/improvement, the Comprehensive
Plan Update shall include policies that achieve the
following:
Evaluation and mitigation of the construction
impacts associated with park and recreational
facility creation and expansion.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
PS-8: Implementation of the
proposed Plan would have
the potential to result in
substantial cumulative
adverse physical impacts
associated with the
provision of new or
physically altered parks and
recreational facilities, need
for new or physically altered
parks and recreation
facilities, the construction of
which could cause significant
environmental impacts, in
order to maintain acceptable
service ratios or other
performance objectives.
PS-8: Implement Mitigation Measure PS-7. See Mitigation Measure PS-7.
Transportation and Traffic
TRANS-1: Implementation of TRANS-1a: Adopt a programmatic approach to City of Palo Alto Within six City of Palo Alto Confirm program adoption. Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 15
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
the project would cause an
intersection to drop below
its motor vehicle level of
service standard, or
deteriorate operations at
representative intersections
that already operate at a
substandard level of service.
reducing motor vehicle traffic, with the goal of
achieving no net increase in peak-hour motor vehicle
trips from new development, with an exception for
uses that directly contribute to the neighborhood
character and diversity of Palo Alto (such as ground-
floor retail and below-market-rate housing). The
program should, at a minimum, require new
development projects above a specific size threshold
to prepare and implement a Transportation Demand
Management (TDM) Plan to achieve the following
reduction in peak-hour motor vehicle trips from the
rates included in the Institute of Transportation
Engineers’ Trip Generation Manual for the
appropriate land use category and size. These
reductions are deemed aggressive, yet feasible, for
the districts indicated.
45 percent reduction in the Downtown district
35 percent reduction in the California Avenue
area
30 percent reduction in the Stanford Research
Park
30 percent reduction in the El Camino Real
Corridor
20 percent reduction in other areas of the city
TDM Plans must be approved by the City and
monitored by the property owner or the project
proponent on an annual basis. The Plans must
contain enforcement mechanisms or penalties that
accrue if targets are not met and may achieve
reductions by contributing to citywide or
employment district shuttles or other proven
transportation programs that are not directly under
the property owner’s control.
PCE Department,
Transportation
Division
(responsible for
program
adoption)
months of
proposed
Comprehensive
Plan adoption
PCE Department
Project
applicants
(responsible for
TDM plans)
Prepare TDM
Plan, if required,
prior to issuance
of occupancy
permits.
City of Palo Alto
PCE Department
Property owner
or project
proponent
Review and approve TDM Plans.
Monitor enforcement of TDM
Plans consistent with Palo Alto
Municipal Code Section
18.34.040(d)(4)
Once
Annually
TRANS-1b: Require new development projects to pay
a Transportation Impact Fee for all those peak-hour
City of Palo Alto
PCE Department
Ongoing
City of Palo Alto
PCE Department
Verify collection of fees. Ongoing
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
16 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
motor vehicle trips that cannot be reduced via TDM
measures. Fees collected would be used for capital
improvements aimed at reducing motor vehicle trips
and motor vehicle traffic congestion.
TRANS-1c: The proposed Plan shall include policies
to ensure collaboration with regional agencies and
neighboring jurisdictions, and identification and
pursuit of funding for rail corridor improvements and
grade separation. Policies shall support grade
separation of rail crossings along the rail corridor as
a City priority, and the undertaking of studies and
outreach necessary to advance grade separation of
Caltrain to become a “shovel ready” project.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-1d: Consistent with State requirements, the
City shall adopt a Multimodal Improvement Plan to
address impacts to Congestion Management
Program facilities. In addition, the proposed Plan
shall include policies to engage in regional
transportation planning and advocate for specific
transit improvements and investments, such as
Caltrain service enhancements and grade
separations, Dumbarton Express service, enhanced
bus service on El Camino Real with queue-jump lanes
and curbside platforms, high-occupancy vehicle
(HOV)/high-occupancy toll (HOT) lanes, and
additional VTA bus service.
City of Palo Alto
PCE Department,
Transportation
Division
(responsible for
Multimodal
Improvement
Plan)
See “Monitoring
Action” notes
regarding
Multimodal
Improvement
Plans.
City of Palo Alto
PCE Department
Three CMP intersections would
be affected by this impact.
Intersection #8 (El Camino Real
at San Antonio Road) is located in
Mountain View and Los Altos.
The City of Mountain View is
currently drafting a Multimodal
Improvement Plan that includes
this intersection. The City of Palo
Alto shall participate in
development of this Multimodal
Improvement Plan. The other
two intersections will not require
Multimodal Improvement Plans.
Intersection #9 (Foothill
Expressway/Junipero Serra
Boulevard at Page Mill Road) is
grandfathered in with an
automobile LOS of F and is
therefore exempt from meeting
the CMP standard. For
Intersection #10 (Foothill
Expressway at Arastradero Road),
the City shall make a fair share
Ongoing
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 17
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
contribution toward a full grade
separation project. With the
construction of the grade-
separation project, this
intersection should operate at an
acceptable level of service, and
no longer require the
development of a Multimodal
Improvement Plan. The City shall
monitor the progress of the
grade separation project and
confirm with the County and VTA
that no Multimodal Improvement
Plan is required following its
completion.
Policy implementation is complete
with the adoption and
implementation of the policies in the
proposed Comprehensive Plan
Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-1e: The proposed Plan shall include policies
to encourage the PAUSD to analyze decisions
regarding school assignments to reduce peak-period
motor vehicle trips to and from school sites.
City of Palo Alto
PCE Department
Ongoing, as part
of regular
collaboration and
communication
with the Palo
Alto Unified
School District
City of Palo Alto
PCE Department
Confirm communication. Ongoing
TRANS-3: Implementation of
the project would cause a
freeway segment or ramp to
drop below its level of
service standard, or
deteriorate operations that
already operate at a
substandard level of service.
TRANS-3a: The City shall require new development
projects to prepare and implement TDM programs,
as described in TRANS-1a. TDM programs for
worksites may include measures such as private bus
services and free shuttle services to transit stations
geared towards commuters.
See Mitigation Measure TRANS-1a.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
18 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
TRANS-3b: The proposed Comprehensive Plan shall
include policies that advocate for efforts by Caltrans
and the Valley Transportation Authority to reduce
congestion and improve traffic flow on existing
freeway facilities consistent with Statewide GHG
emissions reduction initiatives.
Policies shall support the application of emerging
freeway information, monitoring, and control
systems that provide non-intrusive driver assistance
and reduce congestion.
Policies shall support, where appropriate, the
conversion of existing traffic lanes to exclusive bus
and high-occupancy vehicle (HOV)/high-occupancy
toll (HOT) lanes on freeways and expressways,
including the Dumbarton Bridge, and the
continuation of an HOV lane from Redwood City to
San Francisco.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-6: Implementation of
the project would impede
the operation of a transit
system as a result of
congestion.
TRANS-6: The proposed Comprehensive Plan shall
include policies collaborate with transit agencies in
planning for and implementing convenient, efficient,
coordinated, and effective bus service.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-8: Implementation of
the project would create the
potential demand for
through traffic to use local
residential streets.
TRANS-8: The proposed Comprehensive Plan shall
include policies to identify specific improvements
that can be used to discourage drivers from using
local, neighborhood streets to bypass traffic
congestion on arterials.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-9: Implementation of
the project would create an
operational safety hazard.
TRANS-9: Implement Mitigation Measure TRANS-8. See Mitigation Measure TRANS-8.
Utilities and Service Systems
UTIL-15: Without the
adoption of policies to
promote recycling and
conservation, the proposed
UTIL-15: To ensure that future development would
comply with applicable solid waste regulations, the
proposed Plan shall include policies that achieve the
following:
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 19
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Plan could potentially fall
out of compliance with
federal, State, and local
statutes and regulations
related to solid waste.
Ninety-five percent landfill diversion by 2030, and
ultimately zero waste.
Reduced solid waste generation.
Use of reusable, returnable, recyclable, and
repairable goods, through enforcement of the
2016 Plastic Foam Ordinance expansion.
Enhanced recycling and composting programs for
all waste generators.
UTIL-17: The proposed Plan
would not result in a
substantial increase in
natural gas and electrical
service demands that would
require the new
construction of energy
supply facilities and
distribution infrastructure or
capacity enhancing
alterations to existing
facilities. However, without
the adoption of policies in
support of energy efficiency
and conservation, the
proposed Plan would result
in a potentially significant
impact, requiring mitigation.
UTIL-17: To ensure that future development would
maximize energy efficiency and conservation the
proposed Plan shall include policies that achieve the
following:
Maximized conservation and efficient use of
energy.
Continued procurement of carbon-neutral
energy.
Investment in cost-effective energy efficiency and
energy conservation programs.
Provision of public education programs
addressing energy conservation and efficiency.
Use of cost-effective energy conservation
measures in City projects and practices.
Adherence to State and federal energy efficiency
standards and policies.
Consideration of a transition to a carbon-neutral
natural gas supply.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
Not Yet Approved
170901 jb Lee/Planning/LongRange
Resolution No _____
Resolution of the Council of the City of Palo Alto Adopting the City of Palo Alto
Comprehensive Plan Update
RECITALS
A. The City Council is authorized by Title 19 of the Palo Alto Municipal Code and state
law to adopt and, from time to time, amend the general plan (known as the Comprehensive
Plan in the City of Palo Alto) governing the physical development of the City of Palo Alto.
B. In 1998, the City Council adopted the Comprehensive Plan entitled, “Embracing the
New Century, Palo Alto 1998-2010 Comprehensive Plan,” which Plan has since been amended
by the Council. This Plan is referred to herein as the “1998 Comprehensive Plan”.
C. Through an extensive and lengthy public process including the convening of a
Citizens Advisory Committee (“CAC”) and numerous public hearings held by the CAC, the
Planning and Transportation Commission and the City Council, the City of Palo Alto has
prepared that certain comprehensive update to the 1998 Comprehensive Plan entitled “Our
Palo Alto 2030,” proposed for approval and adoption by the City Council.
D. In accordance with Title 19 of the Palo Alto Municipal Code, all Comprehensive Plan
amendment proposals are referred to the Planning and Transportation Commission of the City
of Palo Alto for review and recommendation prior to City Council consideration of the
amendments. On June 12, 2017, after receiving the CAC recommendation and holding
additional public hearings, the City Council identified a preferred planning scenario and
forwarded the draft Comprehensive Plan Update to the Planning and Transportation
Commission. The draft Comprehensive Plan Update is referred to herein as the “June 30, 2017
Draft of the Comprehensive Plan Update” which reflects the date that the Plan was transmitted
to the Planning and Transportation Commission.
E. From July 12, 2017 to September 27, 2017, the Planning and Transportation
Commission held five public hearings to consider the draft Comprehensive Plan Update, at
which interested persons were given the opportunity to appear and present their views with
respect to the Comprehensive Plan Update.
F. At the conclusion of the final public hearing on September 27, 2017, the Planning
and Transportation Commission transmitted its recommendations to the City Council on the
proposed Comprehensive Plan Update.
G. Concurrently with the Planning and Transportation Commission review, City staff
prepared a list of minor corrections and clarifications to June 30, 2017 Draft of the
Comprehensive Plan Update (the “Errata”).
H. An original of the proposed Comprehensive Plan Update is on file in the office of the
Director of Planning and Community Environment of the City, with a copy submitted to the City
Council for its consideration.
Not Yet Approved
170901 jb Lee/Planning/LongRange
I. Pursuant to Title 19 of the Palo Alto Municipal Code, public notice was given that on
October 23, 2017, at 5:00 p.m. and November 13, 2017, at 6:00 p.m. in the Council Chambers at
City Hall, 285 Hamilton Avenue, Palo Alto, California, the Council would hold a public hearing
where interested persons could appear, be heard, and present their views with respect to the
proposed Comprehensive Plan Update.
J. The Council held a duly noticed public hearing at the dates and times in Recital I
above and gave all persons full opportunity to be heard and to present their views with respect
to the proposed Comprehensive Plan Update.
K. On __________, the Council reviewed, considered and certified that certain Final
Environmental Impact Report for the proposed Comprehensive Plan Update by Resolution No.
________, and on ___________, the Council adopted adopted related findings by Resolution
No. _________, all in accordance with the California Environmental Quality Act. Both actions
were taken prior to the Council making its determination on the proposed Comprehensive Plan
Update.
L. The Council is the decision-making body for adoption of the proposed
Comprehensive Plan Update.
The Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Public Hearing Draft of the Comprehensive Plan Update dated June
30, 2017 (referred to herein as the “June 30, 2017 Draft of the Comprehensive Plan Update”) is
hereby adopted, subject to the modifications set forth in the Errata document, the
modifications recommended by the Planning and Transportation Commission, and the
additional modifications approved by the Council, all of which modifications are attached
hereto and incorporated herein as Exhibit A. [Exhibit A to be prepared upon Council action on
the Errata, PTC recommendations, and further Council direction at the plan adoption
hearings.]
The Council finds and determines that the Final Environmental Impact Report
adequately evaluated and provides a sufficient basis to approve the Comprehensive Plan
Update including these modifications, and that the modifications, individually and collectively,
do not change any of the conclusions of the Final Environmental Impact Report. The Council
further finds that the modifications, individually and collectively, do not constitute significant
new information under the California Environmental Quality Act (“CEQA”) because such
changes and additional information do not indicate that any of the following would result from
approval and implementation of the Project: (i) any new significant environmental impact or
substantially more severe environmental impact (not already disclosed and evaluated in the
DEIR and Supplement to the Draft EIR), (ii) any feasible mitigation measure considerably
different from those analyzed in the Draft EIR and Supplement to the Draft EIR that would
lessen a significant environmental impact of the Project has been proposed and would not be
implemented, or (iii) any feasible alternative considerably different from those analyzed in the
DEIR and the Supplement to the Draft EIR that would lessen a significant environmental impact
Not Yet Approved
170901 jb Lee/Planning/LongRange
of the Project has been proposed and would not be implemented.
SECTION 2. The Implementation Table attached to the Comprehensive Plan Update
restates the programs in the Comprehensive Plan and identifies the lead department or agency,
the relative prioritization and planned timeframe, and the anticipated level of resources and
effort for their implementation. While the programs are substantive parts of the Comprehensive
Plan Update, the other information in the Implementation Table, including the prioritization of
the programs are not intended to be incorporated as substantive elements and may be modified
by the City Council without a formal amendment to the Comprehensive Plan.
SECTION 3. City staff may perform minor, non-substantive edits to the Comprehensive
Plan Update without additional Council review. These include such things as formatting,
illustrations, and acknowledgements.
SECTION 4. This Comprehensive Plan Update supersedes the adopted 1998
Comprehensive Plan, except for the Housing Element of the Comprehensive Plan adopted by the
Council in November 2014 (“Housing Element”), which remains in full force and effect and is
incorporated into the Comprehensive Plan Update.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
__________________________ _____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
__________________________ _____________________________
Assistant City Attorney City Manager
_____________________________
Director of Planning and
Community Environment
Edwin M. Lee
Mayor
Francesca Vietor
President
Anson Moran
Vice President
Ann Moller Caen
Conirmssioner
Vince Courtney
Commissloner
Ike Kwon
Commissioner
Harlan L Kelly, Jr.
General Manager
San Francisco
Water Sewer
Operator of the Hetch Hetchy Regional Water System
October 31, 2017
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
r 415,554.3155
F 415.554.3161
m 415.554.3488
To: Ms. Elena Lee
Department of Planning and Community Environment
City of Palo Alto
250 Hamilton Avenue, Fifth Floor
Palo Alto, CA 94301
Re: Palo Alto Draft Comprehensive Plan Update
Dear Ms. Lee:
Thank you for the notice of availability and for this opportunity for the San
Francisco Public Utilities Commission (SFPUC), to comment on the Palo Alto
Draft Comprehensive Plan Update (Plan). Also, thank you for taking the time
to explain some aspects of the proposed Plan to SFPUC staff.
Background
The San Francisco Public Utilities Commission manages 63,000 acres of
watershed land and 210 miles of pipeline rights-of-way (ROW) in three Bay
Area counties. These are part of the Hetch Hetchy Regional Water System
providing water to approximately 2.6 million people. The SFPUC monitors and
protects its lands by reviewing proposed projects and activities that may affect
SFPUC lands and infrastructure for consistency with SFPUC policies and
plans.
The City and County of San Francisco (San Francisco), through the SFPUC,
operates three active pipelines within the Palo Alto city limits in two 80-foot
wide ROVVs: Bay District Pipelines (BDPL) 3 and 4, largely along Foothill Blvd.;
and the Palo Alto Pipeline (PAPL), largely along SR 82.The ROW's primary
purpose is to serve as utility corridors for water transmission.
Draft Comprehensive Plan Update Comments
In a telephone conversation with SFPUC staff (Michael Oakes, Land and
Resources Planner) you explained that the Plan does not propose any major
land use changes. The only designation change proposed is for a site to reflect
existing uses (e.g., removing a Hotel overlay). There are no proposed changes
to SFPUC ROW or owned properties. There are also no proposed changes to
the use of SFPUC fee-owned property or easement.
Services of the San Francisco Public Utilities Commission
Draft Palo Alto Comprehensive Plan Update
— SFPUC Comments
Nevertheless, we request that the Final Plan identify the San Francisco
Property as a utility ROW that is primarily used for utility purposes and explain
that SFPUC lands are vital to the operation of a regional water system. The
SFPUC has policies that limit third-party uses and improvements on San
Francisco Property. Please see the attached Interim Water Pipeline ROW Use
Policy and Integrated Vegetation Management Policy for more information
about restrictions on the ROW. The SFPUC would like to underscore that the
San Francisco Property may not be used to "...fulfill a development's open
space, setback, emergency access or other requirements..."1 This prohibition
also includes parking or third-party development requirements. In addition, any
proposed use or improvement on the SFPUC ROW must: 1.) comply with
current SFPUC policies; 2.) be vetted through the SFPUC's Project Review
process (see below for more information); and 3.) be formally authorized by the
SFPUC.
The Final Comprehensive Plan should include policies that address the
importance of regional water utility infrastructure within the Plan area. In
addition, the Final Plan should acknowledge that the SFPUC's approval and
authorization would be required for any activities on its ROW.
SFPUC Real Estate Services (RES)
The SFPUC restricts third-party uses on the SFPUC Property due to the
presence of high-pressure subsurface water transmission lines under the
SFPUC Property. To protect the SFPUC's water infrastructure and operations,
which service the City of Palo Alto, the Final Comprehensive Plan should
recognize the SFPUC Property.
Certain secondary uses by third parties on SFPUC property are allowed under
lease or license agreements. Such secondary use may occur if RES, in
consultation with the SFPUC enterprise having jurisdiction, determines that
such use benefits the SFPUC and if such secondary use does not in any way
interfere with, endanger, or damage existing or future SFPUC operations,
security, or facilities.
The SFPUC prohibits any use that:
• provides aerial utility crossing or overhead transmission lines within the
SFPUC Property;
• cannot be removed promptly, to allow SFPUC construction,
maintenance or emergency repairs of its facilities;
• fulfills Palo Alto's open space, setback, parking, or third-party
development requirements;
• makes the SFPUC Property the sole emergency access to a
neighboring property;
• includes installation of structures, trees or large shrubs on the SFPUC
Property;
Paqe 2
Draft Palo Alto Comprehensive Plan Update
SFPUC Comments
includes installation of utilities, roads, fences, or other improvements
parallel to, rather than across, SFPUC pipelines or electric transmission
lines;
includes the SFPUC Property as part of a transit-oriented development
plan, dedicated rapid transit lane, or transit corridor; or
is inconsistent with any existing or future SFPUC policies, as they may
be amended or modified from time to time.
This list is not exhaustive. The SFPUC retains the right to disallow any use
that, at the SFPUC's sole discretion, may interfere with, endanger or damage
existing or future SFPUC operations, security, or facilities.
Page 3
SFPUC Project Review Process
Proposed projects and other activities on any San Francisco property must undergo the
Project Review Process if the project will include: construction; digging or earth moving;
clearing: installation; the use of hazardous materials; other disturbance to watershed and
ROW resources; or the issuance of new or revised leases, licenses and permits. This
review is done by the SFPUC's Project Review Committee (Committee).
The Project Review Committee is a multidisciplinary team with expertise in natural
resources management, environmental regulatory compliance, engineering, water quality
and real estate. Projects and activities are reviewed by the Committee for:
1. Conformity with the Alameda and Peninsula Watershed Management Plans;
2. Consistency with our Environmental Stewardship Policy; Real Estate
Guidelines; Interim ROW Use Policy; other policies and best management
practices;
3. Compliance with the California Environmental Quality Act (CEQA) and
environmental regulations including mitigation, monitoring and reporting plans.
In reviewing a proposed project, the Project Review Committee may conclude that
modifications or avoidance and minimization measures are necessary. Large and/or
complex projects may require several project review sessions to review the project at
significant planning and design stages.
Please notify all property owners and/or developers that, to the extent their proposals will
involve the development or use of the San Francisco Property, such proposals are first
subject to the SFPUC's Project Review Process. The proposal must first be vetted in
Project Review, and then the project sponsor must receive authorization from the SFPUC
pursuant to a final executed lease or revocable license before they can use or make any
changes to the SFPUC ROW. To initiate the Project Review process, a project sponsor
must download and fill out a Project Review application at
http://www.sfwater.org/ProjectReview. Please address completed applications and any
Draft Palo Alto Comprehensive Plan Update
— SFPUC Comments
questions to Michael Oakes, Land and Resources Planner, in the SFPUC's Natural
Resources and Lands Management Division at moakessfwater.org.
Page 4
Sincerely, ..
k,t) JtsulA--Li
oanne Wilson
Senior Land and Resources Planner
Natural Resources and Lands Management Division / Water Enterprise
San Francisco Public Utilities Commission
1657 Rollins Rd.
Burlingame, CA 94010
Attachments: 1.) SFPUC Interim Water Pipeline ROW Use Policy
2.) ROW Integrated Vegetation Management Policy
C: Rosanna Russell, SFPUC Real Estate Services Director
' SFPUC Guidelines for the Real Estate Services Division, Section 2.0.
City of Palo Alto | City Clerk's Office | 11/1/2017 12:50 PM
1
Carnahan, David
From:Mj Wolf <mimi.wolf@gmail.com>
Sent:Tuesday, October 31, 2017 9:48 AM
To:Council, City; lchiapella@juno.com
Subject:Re: comp plan update
Thank you!
On Mon, Oct 30, 2017 at 12:09 AM lchiapella@juno.com <lchiapella@juno.com> wrote: Dear City Council:
It is difficult to understand the proposed comp plan update without considering Stanford's GUP.
These are two different plans that drastically impact Palo Alto.
Who is coordinating these plans?
How are the combined impacts being addressed?
Who pays for the parking problems, traffic congestion, and housing shortage?
Sincerely,
Lynn Chiapella
--
M. Wolf
650.245.6434
“It seems to me that the good lord in his Infinite wisdom gave us three things to make life bearable- hope, jokes, and dogs. But the greatest of these was dogs.”
---Robyn Davidson
City of Palo Alto | City Clerk's Office | 11/1/2017 12:50 PM
2
Carnahan, David
From:amy sung <amyconnect@gmail.com>
Sent:Monday, October 30, 2017 7:02 PM
To:Council, City
Cc:Kniss, Liz (internal); DuBois, Tom; Filseth, Eric (Internal); Fine, Adrian; Holman, Karen;
Kou, Lydia; Scharff, Gregory (internal); Tanaka, Greg; Wolbach, Cory; Amy Sung
Subject:Letter to Council to certify EIR Report and adopt the Comp Plan as presented
Dear Palo Alto City Council, I am writing to you as a homeowner, a resident of Palo Alto, and a community volunteer
to urge you to adopt the Comprehensive Plan as presented before you tonight.
The Palo Alto Comprehensive Plan – or “Comp Plan, as it’s commonly known -- has been decades in the making
and is long overdue. Through numerous iterations, The Citizen’s Action Committee (CAC) began its work in May
2015, painstakingly conducted monthly committee and subcommittee meetings to examine and rework the Plan-
Elements by Elements, Goals by Goals, Polices by Polices, Programs by Programs, and down to the language
dissected and evaluated until the body of 25 members could agree on. In areas where agreements could not be
reached, options were documented to capture the core arguments. The result is a product of vigorous discussions
and passionate debates under open and transparent processes governed by the Brown’s Act, moderated by co-
chairs of Dan Garber and Arthur Keller, and delivered by a diverse group of involved residents- architects,
economist, retired CEOs, Realtors, engineers, neighborhood presidents, plus liaisons from PAUSD, Stanford, and
PTC, and devoted staff and many more. Two years later, before you tonight is that product, A COMPREHENSIVE
PLAN draft. It’s a GOOD plan, not perfect, but that’s just a characteristic of democracy; give and take and
compromise. It’s the Plan that will guide our city into the future until 2030.
I urge you to adopt the plan because we have work to do. Urgently. But those tasks can not be done until the Plan is
approved and certified by this body. You are all being elected to this body because you want to do something for
this community. The community has asked clearly and loudly that the number one concern in our city is HOUSING.
Today, you can act on your campaign promises and your intention of wanting to do something by approving this
Plan.
Again, I urge the Council to tackle urging tasks of Housing and Transportation. And if I could boldly suggest, the two
sides of a coin will now be: H (head) is for Housing and T (tail) is for Transportation. Furthermore, housing should be
a solution of our traffic calming.
HOUSING, HOUSING, HOUSING. It’s a cry for help that the current home affordability is 29% statewide. It’s saying
that two out of three cannot afford to buy a home at median price. Housing crisis is real and hurting not just the
economically disadvantaged but across ALL INCOME spectrum. Our infill development is the best way to combat
GHG and prevent urban sprawl while preserving and creating green space. How we can accomplish that is to pierce
through the height limit of 50 feet in selected areas such as University Ave in downtown area, Fry’s site, and CAL
Ave through Comprehensive Area Plans. We need to craft a zoning plan to achieve ALL levels of affordability with
an accountable density bonus matrix.
TRANSPORTATION. Placing housing where the transit hubs are is no different than having neighborhood schools
to which students walk and bike.
Palo alto is:
- the second largest Caltrain trip stops after San Francisco,
- the steady increase in high school bike counts,
City of Palo Alto | City Clerk's Office | 11/1/2017 12:50 PM
3
- and since 2000, Palo Alto has a higher percentage of residents who walk or bike to work than the County,
State, or nation.
- Palo Alto also saw drive to work alone shrunk from by 10% from 75% to 65% since 2000.
Therefore, Construct housing at where it is needed and wanted together with the TDM and TMA is the logical next
step to further calm the traffic.
In closing, I want to circle back to the call in the Summit 2015 under the leadership of the then Mayor Karen Holman,
and here I quote- “What is the Future for Palo Alto?” it went on to say that “The Pressures of regional growth and
change mean that doing nothing—that is, not updating the current Comprehensive Plan—is simply not an option.
So the time to act is now. You have before you a PLAN ready to be adopted and then focus attention towards
implementation.
Thanks you for your time and deliberations,
Amy Sung
Walter Hays Dr, Palo Alto
Responses to Comments Received October 30, 2017
Regarding the Comprehensive Plan EIR*
*Please see the video from October 30, 2017 for the full content of comments paraphrased here.
Responses supplement those already provided in the Final EIR and prior staff reports. Page 1
Comment 1: Where can I find the specific contribution of our City to regional air pollution?
(Councilmember Holman)
Response 1: Please see Supplement to the Draft EIR p. 4.2-16. Table 4.2-8 quantifies emissions of
criteria air pollutants from EIR scenarios 1-6. Emissions associated with the preferred scenario
described in the Final EIR would fall within this range.
Comment 2: The plan and EIR should address noise from flight operations at Palo Alto Airport as well as
exposure of Palo Alto residents to airplane noise generally. (Ms. Porter)
Response 2: Flight operations at Palo Alto Airport are addressed in the Comprehensive Plan.
Specifically, Policy L-10.1 is a new policy that would “[o]perate Palo Alto Airport (PAO)… at its current
level of operation” and states that “PAO should remain limited to a single runway and minor expansion
shall only be allowed in order to meet federal and State design and safety standards.” Policy L-10.3 is an
additional new policy to “[m]inimize the environmental impacts associated with PAO operations,
including…noise” and is supported by new Program L10.3.1 to establish and implement a system for
processing, tracking, and reporting noise complaints regarding local airport operations on an annual
basis.” Potential impacts from PAO flight operations are assessed in Section 4.10 of the Draft EIR and the
Supplement to the Draft EIR (see p. 4.10-32 of the Draft EIR and p. 4.10-6 of the Supplement to the Draft
EIR). The analysis determined that noticeable increases in noise from flight operations at the airport are
not anticipated by 2030, but there could be a problem if sensitive land uses locate too close to the
airport. This resulted in mitigation (Mitigation Measure Noise 1b), which has been included in the Draft
Comprehensive Plan Update within Policy N-6.1. Noise exposure associated with flight operations from
San Francisco and San Jose Airports are not directly relevant in the CEQA context for the proposed Comp
Plan Update, however they are important policy issues and are addressed in Policies N-6.12 and L-10.3
in the June 30, 2017 Draft Comprehensive Plan Update.
Comment 3: The Notice of Preparation (NOP) was issued too long ago for that to serve as the baseline
of the EIR. (Ms. Keehn)
Response 4: As indicated in Chapter 5 of the Final EIR (Master Response 2), use of the date the NOP
was published is a standard practice and based on the State CEQA Guidelines (Section 15125(a)). Also,
as indicated in Master Response 2 and the response to Mr. Ross’s comments from October 23, 2017, the
EIR includes a robust cumulative analysis based on regional projections that are large enough to
encompass more recent development proposals in surrounding jurisdictions.
Comment 5: Mitigation Measure Hydro2 should address groundwater impacts on adjacent structures.
(Ms. Nigenda)
Response 5: As indicated in the response to Ms. Proctor and Ms. Vrhel from October 23, 2017, language
about impacts to adjacent structures was removed from the EIR mitigation measure because of the
CEQA significance threshold being used, which considers whether the project would "substantially
degrade or deplete ground water resources or interfere substantially with groundwater recharge such
that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level."
Nonetheless, this language remains in Comp Plan Policy L-3.5: “Avoid negative impacts of basement
Responses to Comments Received October 30, 2017
Regarding the Comprehensive Plan EIR*
*Please see the video from October 30, 2017 for the full content of comments paraphrased here.
Responses supplement those already provided in the Final EIR and prior staff reports. Page 2
construction for single-family homes on adjacent properties, public resources and the natural
environment.” In other words, the CEQA threshold in question is focused on impacts to groundwater
depletion rather than damage to adjacent properties, so the mitigation language has been refined
accordingly. However, damage to private properties is an important issue in Palo Alto and would be
addressed in a new Comp Plan policy going forward.
Comment 6: There are more desirable alternatives that have not been studied in the EIR. For example,
we could have studied alternatives with less or no non-residential development. (Mr. Levinsky)
Response 6: The EIR evaluated a reasonable range of alternatives, including alternatives with less job
growth than the preferred scenario. In this way, the EIR has meet the requirements of the law. In
addition, the Supplement to the Draft EIR Appendix H included a hypothetical “no growth” scenario in
which no new jobs or residents located in Palo Alto by the year 2030. This analysis showed that even
with no growth in Palo Alto, traffic conditions are expected to worsen and is referenced several times in
the Supplement to the Draft EIR (see p. 4.13-17 about intersection Level of Service for example).
Comment 7: Traffic impacts of the plan are unacceptable. (Mr. Ng)
Response 7: See response to Comment 6 above. Traffic conditions are expected to deteriorate due to
growth elsewhere in the region no matter what happens in Palo Alto. Also, results of the analysis of
Scenario 1 in the EIR indicate that conditions would be worse if the City continued to operate under the
current Comprehensive Plan rather than adopting the update currently proposed. This is because the
update and Preferred Scenario contain enhanced office/R&D growth limits and a new emphasis on
housing rather than non-residential growth.
TO:
FROM:
DATE:
CITY OF
PALO
ALTO
HONORABLE CITY COUNCIL
JAMES KEENE, CITY MANAGER
NOVEMBER 13, 2017
10
SUBJECT: AGENDA ITEM NUMBER 10-PUBLIC HEARING: ADOPT A RESOLUTION
CERTIFYING THE FINAL ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE
COMPREHENSIVE PLAN UPDATE, A RESOLUTION ADOPTING FINDINGS
PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
RELATED TO SIGNIFICANT ENVIRONMENTAL IMPACTS, MITIGATION MEASURES
AND ALTERNATIVES, A STATEMENT OF OVERRIDING CONSIDERATIONS AND A
MITIGATION MONITORING AND REPORTING PROGRAM, AND A RESOLUTION
ADOPTING THE UPDATED COMPREHENSIVE PLAN DATED JUNE 30, 2017 WITH
DESIRED CORRECTIONS AND AMENDMENTS, WHICH COMPREHENSIVELY
UPDATES AND SUPERSEDES THE CITY'S 1998-2010 COMPREHENSIVE PLAN,
EXCEPT FOR THE HOUSING ELEMENT ADOPTED IN NOVEMBER 2014. (THIS IS
THE THIRD PUBLIC HEARING; THE FIRST HEARING WAS ON OCTOBER 23, 2017,
CONTINUED TO OCTOBER 30, 2017 AND FURTHER CONTINUED TO NOVEMBER
13, 2017.)
At the Comprehensive Plan discussion on October 30, 2017, the Council voted to include a
handful of community "indicators" in the Comprehensive Plan Update and asked staff to return
with a recommendation for up to three additional indicators. This memo provides that
recommendation as well as recommended text changes to address comments received from
the San Francisco Public Utilities Commission (SFPUC) and the Santa Clara Valley Water District
(SCVWD).1 We have also recommended an expanded narrative about the City's utilities for
inclusion in the Safety Element.
If the Council agrees with these recommendations, staff requests that Council adopt a motion
to add these items to the list in Attachment A of your staff report for November 13, 2017.
Attachment A is referenced in the proposed resolution adopting the Comprehensive Plan
Update.
1 The SFPUC letter is included as Attachment E to the staff report. The SCVWD letter is attached to this memo.
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I. Recommendation Regarding Community Indicators
Change Item 9 in Attachment A to add a policy under Goal 1 of the Land Use and Community
Design Element and the additional community indicators as follows (Additions to Attachment A
are underlined):
Policy L-1: (exact numbering to be added) The City will monitor key community
indicators on a regular basis to determine whether the policies of this plan and the
efforts of the Palo Alto residents and businesses are effective at promoting livability.
Suggested indicators and monitoring frequency are listed in Table L-(exact numbering
to be added).
Table L--(exact numbering to be added)
Communitv Metrics
RECOMMENDED
MONITORING
MEASURE METRIC FREQUENCY
Greenhouse Gas Emissions 80% below 1990 emissions Annually as part of Earth Day Report by 2030 (S/CAP cioal)
Vehicle Miles Traveled (VMT) Decrease year over year Annually as part of Earth Day Report per Capita
Jobs/Housing Balance Ratio of jobs to employed (Expressed as a Ratio of Jobs to Every 4 years
Employed Residents) residents
Annually as part of report to California
Below Market Rate (BMR) Units Number of units Dept. of Housing and Community
Development (HCD)
Progress toward Housing Annual Report to State Annually as part of report to California
Element goals Housing and Community Dept. of Housing and Community
Development Department Development IHCDl
Change in PM Qeak hour
Traffic Volumes on City Streets traffic volumes at 10 Every 2 vears reQresentative local
intersections
Percent of residents who live
Availability of Parks within one half mile of a city Every 4 years
oark
Changes in student
PAUSD School Enrollments enrollment at 1:1ublic Annually elementary, middle, and high
schools
II. Recommendation Regarding Sf PUC & SCVWD Comments
In Goal L-9 of the Land Use Element, add the following Policy and Program (additions to the
June 30, 2017 Draft Comprehensive Plan Update are underlined):
Policy L-9.13: Recognize the importance of regional infrastructure, such as the Regional
Water Utility Infrastructure owned by the Sf PUC.
2 of5
o Program L9.13.1: Coordinate with regional utility providers on activities that
would impact their infrastructure and right of way.
In Goal N-3 and N-4 of the Natural Environment Element, incorporate the following changes to
the existing two policies and one program (additions to the June 30, 2017 Draft Comprehensive
Plan Update are underlined):
Policy N-3.1: All creeks are valuable resources for natural habitats, connectivity,
community design, and flood control, and need different conservation and
enhancement strategies. Recognize the different characteristics along creeks in Palo
Alto, including natural creek segments in the city's open space and rural areas, primarily
west of Foothill Expressway; creek segments in developed areas that retain some
natural characteristics; and creek segments that have been channelized. Pursue
opportunities to enhance riparian setbacks along urban and rural creeks as properties
are improved or redeveloped.
Program N3.3.2: Examine the development regulations of the Stream Corridor
Protection Ordinance, with stakeholder involvement to establish appropriate setback
requirements that reflect the varying natural and channelized conditions along creeks
east of Foothill Expressway. Ensure that opportunities to provide an enhanced riparian
setback along urban creeks as properties are redeveloped or improved are included in
this evaluation. •
Policy N-4. 7.1: Aevocate for Support and participate in the work of the SCVWD to
prepare and update a high-quality groundwater management plan that will address
groundwater supply and quality, including, as appropriate:
~ An understanding of subsurface hydrology.
~ Strategies to reduce depletion ..
~ Opportunities to recharge groundwater, including through use of re.cycled water and
extracted gro~ndwater.
~ Methods to ensure that uncontaminated, toxin-free groundwater is used in a
manner that benefits the community, for example in irrigation of parks, street
cleaning and dust suppression.
~ An approach to metering extracted groundwater.
Ill. Recommendation Regarding the Location and Extent of Utilities
Replace the text in item 44 of Attachment A with the following (additions to Attachment A are
underlined). This text would be added to the Safety Element narrative on page S-12 of the June
30, 2017 Draft Comprehensive Plan Update.
3 of5
UTILITIES
In Palo Alto, utility services are provided throughout the City by The City of Palo Alto
Utilities (CPAU), a city-owned utility. Today, CPAU provides six services that include
electric, fiber optic, natural gas, water and wastewater services. Initially formed in 1896
with the installation of a water supply system, CPAU expanded between the years 1898
and 1917 to include wastewater, electric, and natural gas distribution services; in 1996 it
began to provide fiber optic services. Through its mission to provide safe, reliable,
environmentally sustainable and cost effective services to Palo Alto residents, CPAU
offers cost-effective service rates to residents and re-invests proceeds to support other
City community services and facilities. For example, CPAU provides financial support to
the Palo Alto library and parks system, as well as to support police and fire protection
services.
The City's electric utility receives electricity at a single connection point with PG&E's
transmission system. From there the electricity is delivered to customers through nearly
470 miles of distribution lines, of which 223 miles (48%) are overhead lines and 245
miles (52%) are underground. The City also maintains six substations, roughly 2,000
overhead line transformers, 1,075 underground and substation transformers, and the
associated electric services (which connect the distribution lines to the customers'
homes and businesses). These lines, substations, transformers, and services, along with
their associated poles, meters, and other associated electric equipment, represent the
vast majority of the infrastructure used to deliver electricity in Palo Alto.
To deliver gas from the receiving stations to its customers, the City owns 210 miles of
gas mains (which transport the gas to various parts of the city) and 23,400 gas services
(which connect the gas mains to the customers' gas lines). These mains and services,
along with their associated valves, regulators, and meters, represent the vast majority of
the infrastructure used to deliver gas in Palo Alto.
To deliver water to its customers, the utility owns roughly 233 miles of mains (which
transport the water from the SFPUC meters at the city's borders to the customer's
service laterals and meters), eight wells (to be used in emergencies), five water storage
reservoirs (also for emergency purposes) and several tanks used to moderate pressure
and deal with peaks in flow and demand (due to fire suppression, heavy usage times,
etc.). These represent the vast majority of the infrastructure used to distribute water in
Palo Alto.
To collect wastewater from its customers and deliver it to the Regional Water Quality
Control Plant, CPAU owns roughly 18,100 sewer laterals (which collect wastewater from
customers' plumbing systems) and 217 miles of sewer mains (which transport the waste
to the treatment plant). These laterals and mains, along with the associated manholes
and cleanouts, represent the vast majority of infrastructure used to collect wastewater
in Palo Alto.
4of5
The City manages a commercial fiber optics service with a 42 mile fiber back bone
consisting of roughly 6,000 route-miles of fiber. 232 commercial buildings are connected
to the fiber optic network. Roughly 30% of the fiber route is overhead and 70%
underground.
The City's storm drain system drains four primary watersheds. It is separate from the
sanitary sewer system. Storm water flows directly to creeks and the San Francisco Bay
without treatment. The storm drain system consists of 107 miles of underground
pipelines, 2, 750 catch basins, 800 manholes, and six pump stations.
Director
Planning and Community Environment
5 of5
I
5750 /1lrnaden Expresswoy, Son Jose, CA 95118-361-1 I ('108) 265-2600 I v."NW.voi:c1wo!er.org
November 9, 2017
Ms. Elena Lee
Department of Planning and Community Environment
City of Palo Alto
250 Hamilton Avenue, Fifth Floor
Palo Alto, CA 94301
Fiie: 23113
Various
Subject: City of Palo Alto Draft Comprehensive Plan Update 2030 and Final EIR
Dear Ms. Lee:
Santa Gara VaUey
WcJ.er Distric()
Santa Clara Valley Water District (District) has reviewed the City of Palo Alto's Final Environmental
Impact Report (FEIR) for the draft Comprehensive Plan Update 2030 (Comprehensive Plan). The District
is a special district with jurisdiction throughout Santa Clara County. The District acts as the county's
groundwater management agency, principal water resources manager, flood protection agency and is the
steward for its watersheds, streams and creeks, and underground aquifers.
We appreciate the opportunity to comment on the draft Comprehensive Plan and FEIR. This letter
transmits comments that focus on the areas of interest and expertise of the District.
FEIR
The District is Interested In understanding the differences In projected demand In 2030 between the FEIR
and the 2015 Urban Water Management Plan (UWMP}. In Palo Alto's 2015 UWMP the total projected
water use is 11, 198 acre feet a year in 2030 (Table 16). In the FEIR the projected demand for Scenario 1
(business as usual} is 13, 767 AFY in 2030. From a CEQA perspective, the difference does not matter as
either can be met by Palo Alto's 19, 118 AFY Individual Supply Guarantee from San Francisco PUC. The
Water District Is Interested for our long-range water demand forecasting county wide.
Comprehensive Plan
The District appreciates the policies that the City of Palo Alto (Palo Alto) has included to manage water
resources including water conservation programs and encouraging the use of storm and recycled
water. The District recently approved moving forward with a set of water supply and conservation
projects as part of updating our Water Supply Master Plan; these include leak repair, graywater use, rain
barrels, rain gardens, stormwater capture, and enhancing water efficiency standards In new and
retrofitted developments. The District looks forward to working with Palo Alto on making the best use of
our water resources.
The Comprehensive Plan Program N3.3.1 calls for extending the riparian buffer to 150 feet in natural
areas west of Foothill Boulevard and includes a new Program N3.3.2 to examine setbacks requirements
along more urbanized creeks east of Foothill Expressway. Setbacks from riparian corridors are
necessary to protect the sensitive ecology of riparian corridors, provide adequate space to maintain
creeks and levees, and If necessary, Improve flood protection projects including expanding the channel
area. The Water District encourages Palo Alto to take a long-term perspective in enhancing riparian
setbacks in urban areas by Including a policy In the Management and Enhancement section of the Goal
N-3 to address enhancement of creeks In urban areas. Further, we recommend a program be added
Our mission is to provide Silicon Valley safe, clean water for o heohhy liFe, environment, ond economy.
Ms. Elena Lee
Page2
November 9, 2017
that Includes opportunities to provide an enhanced riparian setback along urban creeks as properties are
redeveloped or improved so that urban creeks can be improved in the future.
The Comprehensive Plan includes Policy N-4. 7 to •Advocate for SCVWD to prepare a high-quality
groundwater management plan that will address groundwater supply and quality, including, as
appropriate:
• An understanding of subsurface hydrology.
• Strategies to reduce depletion.
• Opportunities to recharge groundwater, including through use of recycled water and extracted
groundwater.
• Methods to ensure that uncontaminated, toxin-free groundwater Is used In a manner that benefits
the community, for example In Irrigation of parks, _street cleaning and· dust suppression.
• An approach to metering extracted groundwater. [NEW PROGRAM] [N86]"
The District recommends Program N-4.7.1 be modified to reflect that in November 2016, the District
Board adopted a comprehensive Groundwater Management Plan for the Santa Clara and Llagas
Subbasins that addresses groundwater supply and quality. The plan includes detailed information on
subsurface hydrology and groundwater conditions, and describes strategies and programs to maintain
groundwater levels and storage (including groundwater recharge, recycled water, and water use
measurement) and protect groundwater quality. This plan has been submitted' to the California
Department of Water Resources for compliance with the Sustainable Groundwater Management Act and
is available at: http://www.valleywater.org/WorkArea/linkit.aspx?Linkldentifier=id<em ID=14955.
Additionally, Program N-4.7.1 should include a discussion of Palo Alto's role in these issues.
If you have any questions, you may contact me at (408) 630-2319, or by e-mail at
yarroyo@valleywater.org. Please reference District File No. 23113 on future correspondence regarding
this project.
Sincerely,
Yvonne Arroyo
Associate Engineer
Community Projects Review Unit
Electronic Cc: Ms. Elena Lee, Eiena.Lee@CityofPaloAlto.org
cc: U. Chatwani, S. Tippets, Y. Arroyo, T. Hemmeter, V. De La Piedra, M. Martin, File
City of Palo Alto (ID # 8606)
City Council Staff Report
Report Type: Informational Report Meeting Date: 11/13/2017
City of Palo Alto Page 1
Summary Title: Investment Activity Report
Title: City of Palo Alto Investment Activity Report for the First Quarter, Fiscal
Year 2018
From: City Manager
Lead Department: Administrative Services
Background
The purpose of this report is to inform Council of the City’s investment portfolio status as of the
end of the first quarter; ending September 30, 2017. The City’s investment policy requires that
staff report quarterly to Council on the City’s portfolio composition compared to Council-
adopted policy, portfolio performance, and other key investment and cash flow information.
Discussion
The City’s investment portfolio is detailed in Attachment B. It is grouped by investment type
and includes the investment issuer, date of maturity, current market value, the book and face
(par) value, and the weighted average maturity of each type of investment and of the entire
portfolio.
The par value of the City’s portfolio is $491.9 million; in comparison, last quarter it was $519.8
million. The decline in the portfolio of $27.9 million since the last quarter primarily results from
the prepayment of the City’s annual pensions to the Public Employers’ Retirement System
(PERS) of $22 million and the City’s contribution toward the purchase of the Buena Vista Mobile
Home Park of $14.5 million. By prepaying PERS instead of making payments with each payroll
period, the City expects savings of $813 thousand in PERS payments; however, the savings will
be offset by the loss of approximately $208 thousand in interest income. This results in net
citywide savings of $605 thousand. The saving is a consequence of PERS’ ability to earn interest
earlier and at a higher rate than the City could realize. In addition, seasonality and the timing of
remittances and expenditures affect cash flow. For example, the first quarter has one less
payroll compared to the prior quarter.
The portfolio consists of $22.0 million in liquid accounts and $469.9 million in U. S. government
treasury investments, agency securities, bonds of State of California local government agencies,
bonds of some of the fifty United States, medium-term corporate notes, and certificates of
City of Palo Alto Page 2
deposit. The $469.9 million includes $145.7 million in investments maturing in less than two
years, comprising 31.0 percent of the City’s investment in notes and securities. The investment
policy requires that at least $50 million be maintained in securities maturing in less than two
years.
The current market value of the portfolio is 99.6 percent of the book value. The market value
of securities fluctuates, depending on how interest rates perform. When interest rates
decrease, the market value of the securities in the City’s portfolio will likely increase; likewise,
when interest rates increase, the market value of the securities will likely decrease.
Understanding and showing market values is not only a reporting requirement, but essential to
knowing the principal risks in actively buying and selling securities. It is important to note,
however, that the City’s practice is to buy and hold investments until they mature so changes in
market price do not affect the City’s investment principal. The market valuation is provided by
Union Bank of California, which is the City’s safekeeping agent. The average life to maturity of
the investment portfolio is 3.87 years compared to 3.81 years last quarter.
Investments Made During the First Quarter
During the first quarter, $22.8 million of government agency securities with an average yield of
1.2% percent matured. During the same period, government securities totaling $15.0 million
with an average yield of 2.5% percent were purchased. The expectation is interest rates and
City’s portfolio’s average yield will gradually rise. The City’s short-term money market and pool
account decreased by $20.1 million compared to the fourth quarter. Investment staff
continually monitors the City’s short term cash flow needs and adjusts liquid funds to meet
them.
Availability of Funds for the Next Six Months
Normally, the flow of revenues from the City’s utility billings and General Fund sources is
sufficient to provide funds for ongoing expenditures in those respective funds. Projections
indicate receipts will be $240.2 million and expenditures will be $220.8 million over the next six
months, indicating an overall growth in the portfolio of $19.4 million.
As of September 30, 2017, the City had $22.0 million deposited in the Local Agency Investment
Fund (LAIF) and a money market account that could be withdrawn on a daily basis. In addition,
investments totaling $32.6 million will mature between October 1, 2017 and March 31, 2018.
On the basis of the above projections, staff is confident that the City will have more than
sufficient funds or liquidity to meet expenditure requirements for the next six months.
Compliance with City Investment Policy
During the first quarter, staff complied with all aspects of the investment policy except for the
requirement “A maximum of 30 percent of the par value of the portfolio shall be invested in
securities with maturities beyond five years”; the actual for the first quarter is 30.5 percent. Per
the Investment Policy, this does not constitute a violation since it’s a result of timing associated
with a major cash outflow. The Buena Vista Mobile Home Park payment of $14.5 million in the
City of Palo Alto Page 3
latter part of September caused the portfolio decrease to result in this policy limit overage;
without this payment, the actual would have been within the policy limit at 29.6 percent. The
limit it expected to be restored in December 2017.
Per the Investment Policy “Where the Investment Policy specifies a percentage limitation for a
particular category of investment, that percentage is applicable only at the date of purchase. A
later increase or decrease in a percentage resulting from a change in the portfolio’s assets or
values shall not constitute a violation of that restriction. As soon as possible, percentage
limitations will be restored as investments mature in each category.”
Attachment C lists the major restrictions in the City’s investment policy compared with the
portfolio’s actual performance.
Investment Yields
Interest income on an accrual basis for the first quarter was $2.5 million. As of September 30,
2017, the yield to maturity of the City’s portfolio was 2.00 percent. The rising interest rate is
expected to gradually increase the portfolio’s yields. The City’s portfolio yield of 2.00 percent
compares to LAIF’s average yield for the quarter of 1.08 percent and an average yield on the
two-year and five-year Treasury bonds during the first quarter of approximately 1.50 percent
and 1.81 percent, respectively.
Yield Trends
In September 2017, the Federal Open Market Committee (FOMC) maintained the federal funds
and discount rates at 1.25 and 1.75 percent, respectively. FOMC’s September report expected
the national economy to be impacted by the hurricanes in the near short term but not over the
medium term. The other outlook remains consistent with the prior (recent) quarter reports, the
FOMC continues to cite strengthening consumer spending, improving labor market and
moderate economic growth with inflation rising but still remaining below the FOMC’s long-term
goal of 2 percent. They do expect a short-term boost to inflation due to the hurricanes (e.g. due
to higher gasoline prices). Business spending is picking up. The FOMC expects future rate
increase to be gradual and dependent on the economic outlook. Though the continued
expectation is rates will rise, factors that could keep a lid on rate increases include: low
inflation, weak wage growth, and domestic and global economic weakness.
Funds Held by the City or Managed Under Contract
Attachment A is a consolidated report of all City investment funds, including those not held
directly in the investment portfolio. These include cash in the City’s regular bank account with
US Bank and Wells Fargo. (A description of the City’s banking relationships can be found in City
Council Staff Report ID # 7858.) The bond proceeds, reserves, and debt service payments being
held by the City’s fiscal agents are subject to the requirements of the underlying debt
indenture. The trustees for the bond funds are U.S. Bank and California Asset Management
Program (CAMP). Bond funds with U.S. Bank are invested in federal agency and money market
mutual funds that consist exclusively of U.S. Treasury securities. Bond funds in CAMP are
City of Palo Alto Page 4
invested in banker’s acceptance notes, certificates of deposit, commercial paper, federal
agency securities, and repurchase agreements. The most recent data on funds held by the fiscal
agent is as of September 30, 2017.
Fiscal Impact
This is an information report.
Environmental Review
This information report is not a project under the California Environmental Quality Act;
therefore, an environmental review is not required.
Attachments:
Attachment A: Consolidated Report of Cash Management
Attachment B: Investment Portfolio
Attachment C: Investment Policy Compliance
Book Value Market Value
City Investment Portfolio (see Attachment B)497,285,101$ 495,204,398$
Other Funds Held by the City
Cash with Wells Fargo Bank 1,721,403 1,721,403
(includes general and imprest accounts)
Cash with US Bank 4,833,047 4,833,047
(includes general and imprest accounts)
Petty/Working Cash 12,578 12,578
Total - Other Funds Held By City 6,567,028 6,567,028
Funds Under Management of Third Party Trustees *
US Bank Trust Services **
1995 Utility Revenue Bonds
Debt Service Fund 11 11
1999 Utility Revenue Bonds
Debt Service Fund 6 6
2002 Downtown Parking Impvt. (Taxable) Certificates of Participation
Reserve Fund 237,417 237,417
2009 Water Revenue Bonds (Build America Bonds)
Project, Debt Service, Reserve, Cost of Issuance Funds 2,596,959 2,596,959
2010 General Obligation Bonds
Debt Service 30 30
2011 Utility Revenue Refunding Bonds
Debt Service, Reserve, and Cost of Issuance Funds 1,479,524 1,479,524
2013 General Obligation Bonds
Debt Service 12 12
California Asset Management Program (CAMP) ***
2012 University Ave. Parking Refunding Bonds
Reserve Fund 2,563,600 2,563,600
2013 General Obligation (Library) Bond
Project Fund 612,734 612,734
Total Under Trustee Management 7,490,293 7,490,293
GRAND TOTAL 511,342,421$ 509,261,718$
* These funds are subject to the requirements of the underlying debt indenture.
** U.S. Bank investments are in money market mutual funds that exclusively invest in U.S. Treasury securities.
*** CAMP investments are in money market mutual fund which invest in bankers acceptance, certificate of deposit,
commercial paper, federal agency securities, and repurchase agreements.
First Quarter, Fiscal Year 2017-18
(Unaudited)
(Debt Service Proceeds)
Attachment A
Consolidated Report of Cash Management
City of Palo Alto Cash and Investments
City of Palo Alto City of Palo Alto
Administration Svcs. Dept.
250 Hamilton Ave., 4th Floor
Palo Alto, CA 94301
(650)329-2362
September 30, 2017
Fund ALL - Portfolio Listings
Investments by Fund
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket ValueCUSIPInvestment #Issuer
PurchaseDate Book Value
YTM
360
YTM
365
Managed Pool Accounts
Fidelity Investments158 3,836,122.60SYS158 10.01007/01/2015 3,836,122.60 0.009 0.0103,836,122.60
Local Agency Investment Fund159 18,209,987.06SYS159 11.11007/01/2015 18,192,543.19 1.094 1.11018,209,987.06
Subtotal and Average 22,046,109.66 22,046,109.66 22,028,665.79 0.906 0.919 1
Negotiable CD's
Comenity Capital Bank1183 NCD 245,000.0020033ABE5 05/03/2018 2141.00005/03/2013 245,161.70 0.986 1.000245,000.00
American Federal Bank1476 NCD 245,000.0002600ADE4 09/30/2022 1,8252.45009/30/2015 246,896.30 2.418 2.451245,000.00
Allegiance Bank - Texas1844 NCD 245,000.0001748DAW6 09/29/2022 1,8242.05009/29/2017 242,270.70 2.022 2.051245,000.00
Alpine Bank1525 NCD 245,000.0002082CBG4 08/16/2023 2,1452.40002/16/2016 245,448.35 2.367 2.400245,000.00
American City Bank1692 NCD 245,000.00025140BC7 03/30/2021 1,2761.45009/30/2016 240,511.60 1.429 1.449245,000.00
American Eagle Bank1371 NCD 245,000.0002554BCE9 05/28/2019 6041.85008/26/2014 245,984.90 1.825 1.850245,000.00
American National Bank1766 NCD 245,000.0002772JAC4 08/04/2021 1,4032.05004/04/2017 245,759.50 2.023 2.051245,000.00
American State Bank OSCE1805 NCD 245,000.00029733BX9 05/30/2024 2,4332.30005/30/2017 241,844.40 2.270 2.301245,000.00
American Express Centurion Bk1178 NCD 245,000.0002587DMV7 05/02/2018 2131.10005/02/2013 245,161.70 1.084 1.100245,000.00
American Express Centurion Bk1333 NCD 245,000.0002587CAC4 07/10/2019 6471.95007/10/2014 245,923.65 1.923 1.950245,000.00
Barclays Bank / Delaware1187 NCD 245,000.0006740AZB8 04/30/2018 2110.70005/07/2013 246,374.45 0.690 0.699245,000.00
Bankers Bank1776 NCD 245,000.0006610RAM1 04/19/2021 1,2961.90004/19/2017 244,615.35 1.875 1.901245,000.00
Bank of Wisconsin Dells1696 NCD 245,000.00065847DH5 10/12/2021 1,4721.50010/12/2016 240,369.50 1.480 1.500245,000.00
Bank of Grove1821 NCD 245,000.0006246PBP9 12/29/2021 1,5502.00006/29/2017 244,461.00 1.974 2.001245,000.00
Bankers Bank of the West1421 NCD 245,000.0006610TDB8 12/30/2019 8201.85012/29/2014 246,832.60 1.824 1.850245,000.00
Belmont Savings Bank1280 NCD 245,000.00080515AT6 11/13/2018 4081.55005/13/2014 245,673.75 1.528 1.550245,000.00
Bar Harbor Bank & Trust1377 NCD 245,000.00066851SG2 08/27/2019 6951.75008/27/2014 245,308.70 1.726 1.750245,000.00
Bank Champaign1477 NCD 245,000.0006607ABD2 09/30/2022 1,8252.50009/30/2015 245,313.60 2.467 2.501245,000.00
Texas Exchange Bank1796 NCD 245,000.0088241TBM1 05/20/2022 1,6922.25005/22/2017 245,837.90 2.220 2.251245,000.00
Bank of Deerfield1396 NCD 245,000.00061785CM1 09/30/2020 1,0952.20009/30/2014 247,092.30 2.171 2.201245,000.00
Bank of Holland Michigan1302 NCD 245,000.00062649ZV3 05/21/2019 5971.70005/21/2014 246,428.35 1.677 1.701245,000.00
Frontier Bank Madison NE1498 NCD 245,000.0035907XCL9 11/22/2021 1,5132.00011/20/2015 244,791.75 1.974 2.001245,000.00
Bank West1472 NCD 245,000.00063615AX6 09/16/2022 1,8112.25009/16/2015 244,713.35 2.220 2.251245,000.00
Apex Bank1693 NCD 245,000.0003753XAN0 09/30/2022 1,8251.70009/30/2016 238,215.95 1.676 1.700245,000.00
BMO Harris Bank1783 NCD 245,000.0005581WNY7 10/28/2022 1,8532.25004/28/2017 244,522.25 2.220 2.251245,000.00
BMW Bank of North America1807 NCD 245,000.0005580AJK1 06/16/2020 9891.85006/16/2017 245,012.25 1.824 1.850245,000.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 2
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Negotiable CD's
Beneficial Bank1680 NCD 245,000.0008173QBR6 09/13/2021 1,4431.50009/12/2016 240,322.95 1.479 1.500245,000.00
BankFirst1767 NCD 245,000.0006644QAA9 04/13/2022 1,6552.00004/13/2017 243,485.90 1.973 2.001245,000.00
BankWest, Inc.1380 NCD 150,000.0006652CEY3 09/16/2019 7151.90009/15/2014 150,598.50 1.873 1.900150,000.00
Bofi Federal Bank1381 NCD 50,000.0009710LAF2 08/30/2022 1,7942.25008/25/2014 49,739.50 2.493 2.52749,387.09
Bofi Federal Bank1382 NCD 100,000.0009710LAE5 08/08/2022 1,7722.35008/25/2014 100,047.00 2.592 2.62898,780.03
Bofi Federal Bank1402 NCD 100,000.0009710LAF2 08/30/2022 1,7942.25010/21/2014 99,479.00 2.462 2.49698,906.10
Banco Poplar North America1478 NCD 245,000.0005965GVP8 10/07/2020 1,1022.25010/07/2015 247,445.10 2.219 2.250245,000.00
Bridgewater Bank Bloom MN1393 NCD 245,000.00108622EA5 09/24/2019 7231.85009/24/2014 245,730.10 1.825 1.850245,000.00
Business Bank1531 NCD 245,000.0012325EHA3 02/10/2021 1,2281.55002/10/2016 241,949.75 1.530 1.551245,000.00
Worlds Foremost Bank1387 NCD 200,000.00981571AT9 09/04/2019 7032.10009/04/2014 201,188.00 2.072 2.101200,000.00
Campbell County Bank1307 NCD 245,000.00134204BZ8 05/30/2019 6061.65005/30/2014 246,472.45 1.628 1.650245,000.00
Cathay Bank1194 NCD 245,000.00149159HS7 04/30/2018 2111.00005/14/2013 244,779.50 0.987 1.000244,999.71
Commercial Bank - Alma1772 NCD 245,000.00201282HM5 04/21/2022 1,6632.05004/21/2017 243,939.15 2.023 2.051245,000.00
CBC National Bank1571 NCD 245,000.0012480LDV6 04/15/2021 1,2921.50004/15/2016 241,283.35 1.479 1.500245,000.00
Celtic Bank1362 NCD 245,000.0015118RJW8 08/20/2019 6881.90008/20/2014 246,418.55 1.875 1.901245,000.00
Central State Bank1538 NCD 245,000.0015524EAA2 02/16/2022 1,5991.70002/16/2016 240,947.70 1.678 1.701245,000.00
First Iowa State Bank1840 NCD 245,000.00320636AC7 01/31/2022 1,5831.90007/31/2017 243,152.70 1.876 1.902245,000.00
Charter Bank Eau Claire1811 NCD 245,000.0016116PHU8 06/13/2022 1,7162.10006/13/2017 243,980.80 2.071 2.100245,000.00
CIBM Bank1809 NCD 245,000.0012545JAM7 06/16/2022 1,7192.10006/16/2017 243,953.85 2.072 2.101245,000.00
CIT Bank1175 NCD 245,000.0017284CCN2 04/24/2018 2051.20004/24/2013 244,892.20 1.183 1.200245,000.00
Citizens Deposit Bank1677 NCD 245,000.0017453FBP6 08/24/2021 1,4231.40008/24/2016 240,220.05 1.380 1.400245,000.00
Citizens State Bank1541 NCD 250,000.0017670BAQ1 02/17/2023 1,9651.75002/19/2016 242,810.00 1.727 1.751250,000.00
Cumberland Federal Bank FSB1813 NCD 245,000.0023062KBH4 07/07/2022 1,7402.10007/07/2017 243,745.60 2.072 2.101245,000.00
Enerbank USA1246 NCD 245,000.0029266NYZ4 01/30/2020 8512.05001/30/2014 246,565.55 2.021 2.050245,000.00
City National Bk of Metropolis1791 NCD 245,000.0017801GBQ1 05/16/2022 1,6882.00005/15/2017 243,157.60 1.972 2.000245,000.00
Community State Bank1536 NCD 245,000.0020404YBQ7 02/24/2022 1,6071.95002/24/2016 243,446.70 1.924 1.951245,000.00
Country Bank of New York1799 NCD 245,000.0022230PBN9 05/26/2022 1,6982.10005/26/2017 244,157.20 2.072 2.101245,000.00
Capital One Bank USA NA1384 NCD 250,000.00140420NR7 09/04/2019 7031.80009/04/2014 251,437.50 1.775 1.800250,000.00
Capital One Bank USA NA1457 NCD 245,000.0014042E5M8 08/12/2020 1,0462.30008/12/2015 247,866.50 2.268 2.300245,000.00
Community Bank Pasadena1627 NCD 245,000.00203507BA5 06/15/2021 1,3531.55006/16/2016 241,871.35 1.529 1.550245,000.00
Commuincity Finl Svcs Bank1530 NCD 245,000.0020364ABA2 02/17/2021 1,2351.60002/17/2016 242,322.15 1.579 1.601245,000.00
Commerce Bank - Geneva1816 NCD 245,000.0020056QQK2 06/21/2021 1,3592.00006/21/2017 245,374.85 1.973 2.001245,000.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 3
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Negotiable CD's
Commercial Bank1369 NCD 245,000.0020143PDB3 05/20/2019 5961.85008/19/2014 245,987.35 1.824 1.850245,000.00
Commerce State Bank1797 NCD 245,000.0020070PJA6 05/23/2022 1,6952.00005/22/2017 243,086.55 1.972 2.000245,000.00
Community State Bank, IA1471 NCD 245,000.0020404MAN1 09/12/2022 1,8072.25009/11/2015 244,752.55 2.224 2.255245,000.00
Cornerstone Bank1757 NCD 245,000.00219232CN3 03/10/2022 1,6212.10003/10/2017 244,857.90 2.072 2.101245,000.00
Discover Bank / Delaware1176 NCD 245,000.00254671NJ5 05/01/2018 2121.15005/01/2013 245,164.15 1.134 1.150245,000.00
Dollar Bank FSB1756 NCD 245,000.0025665QAV7 03/08/2022 1,6192.05003/08/2017 244,353.20 2.021 2.050245,000.00
East Boston Savings Bank1463 NCD 245,000.0027113PAL5 08/24/2020 1,0581.90008/24/2015 245,093.10 1.876 1.902245,000.00
TBK Bank SSB1812 NCD 245,000.0087219RBK9 06/23/2022 1,7262.10006/23/2017 243,873.00 2.072 2.101245,000.00
Ever Bank1454 NCD 245,000.0029976DZK9 07/30/2020 1,0332.00007/30/2015 245,857.50 1.972 2.000245,000.00
Farmer's and Merchants Bank1360 NCD 250,000.00308702BQ1 02/16/2021 1,2342.20008/15/2014 252,177.50 2.169 2.200250,000.00
First Bank of Highland1330 NCD 245,000.00319141BV8 07/03/2019 6401.85007/03/2014 245,377.30 1.824 1.850245,000.00
First Business Bank1250 NCD 245,000.0031938QF25 02/19/2020 8712.00002/19/2014 246,251.95 1.972 2.000245,000.00
FirstBank Puerto Rico1768 NCD 245,000.0033767A2C4 04/07/2022 1,6492.10004/07/2017 244,600.65 2.072 2.101245,000.00
First Choice Bank / NJ1297 NCD 245,000.00319464AR4 05/28/2019 6041.70005/28/2014 246,470.00 1.677 1.701245,000.00
State Bank of Fenton (MI)1283 NCD 245,000.00856188AU1 02/15/2019 5021.65005/15/2014 245,227.85 1.630 1.653245,000.00
First Federal S&L Bank1626 NCD 245,000.0032018YAW8 06/22/2023 2,0901.80006/22/2016 239,112.65 1.776 1.800245,000.00
1st Financial Bank1485 NCD 245,000.0032022RFD4 03/16/2022 1,6272.10010/19/2015 244,799.10 2.120 2.150244,488.96
Flushing Bank1413 NCD 245,000.0034387ABA6 12/10/2018 4351.80012/10/2014 245,357.70 1.776 1.801245,000.00
First Internet Bank1834 NCD 245,000.0032056GCQ1 07/14/2022 1,7472.05007/14/2017 243,098.80 2.023 2.051245,000.00
First General Bank1222 NCD 245,000.00320337AR9 07/03/2018 2751.30007/03/2013 244,965.70 1.282 1.300245,000.00
First Eagle National Bank1400 NCD 245,000.0032008JAG8 10/15/2021 1,4752.45010/17/2014 251,661.55 2.416 2.449245,000.00
First Oklahoma Bank1838 NCD 245,000.00335857BF4 07/26/2022 1,7592.10007/26/2017 243,552.05 2.072 2.101245,000.00
Farmers & Merchant Bank1735 NCD 245,000.0030781TBD9 01/18/2022 1,5702.05001/18/2017 244,786.85 2.021 2.050245,000.00
First National Bank of America1391 NCD 240,000.0032110YEF8 08/03/2022 1,7672.35009/09/2014 240,931.20 2.665 2.703236,325.13
First Nationnal Bank / KS1537 NCD 245,000.00334342BU5 02/26/2021 1,2441.55002/26/2016 241,890.95 1.530 1.551245,000.00
The FNB of Mcgregor1480 NCD 245,000.0032112UBW0 09/30/2021 1,4602.00010/01/2015 245,208.25 1.972 1.999245,000.00
First Nat. Bank of Park Falls1473 NCD 245,000.0032114RAQ9 09/17/2021 1,4472.20009/17/2015 245,142.10 2.171 2.201245,000.00
First Premier Bank1255 NCD 245,000.0033610RNX7 03/08/2021 1,2542.50003/07/2014 249,566.80 2.465 2.500245,000.00
Franklin Synergy Bank1771 NCD 103,000.0035471TCV2 01/31/2022 1,5832.00004/04/2017 102,649.80 1.975 2.003103,000.00
First Merchants Bank1351 NCD 245,000.0032082BDH9 08/06/2019 6741.90008/06/2014 246,467.55 1.873 1.900245,000.00
Community First Bank1555 NCD 250,000.0020369JAA9 03/17/2022 1,6281.70003/17/2016 245,540.00 1.677 1.700250,000.00
Farmer's & Merchant's SVG Bank1551 NCD 245,000.00308863AH2 02/26/2021 1,2441.55002/29/2016 245,034.30 1.528 1.550245,000.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 4
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Negotiable CD's
First Neighbor Bank, NA1469 NCD 245,000.0033581VAF6 09/03/2021 1,4332.40009/03/2015 249,877.95 2.367 2.400245,000.00
First Savings Bank Northwest1335 NCD 245,000.0033621JAB4 07/18/2019 6551.80007/18/2014 245,102.90 1.776 1.801245,000.00
First National Bank of Elkhart1801 NCD 245,000.00321130AB2 05/31/2022 1,7032.10005/31/2017 244,066.55 2.072 2.101245,000.00
First Northeast Bank1779 NCD 245,000.0033583FAA0 10/19/2022 1,8442.10004/19/2017 242,775.40 2.072 2.101245,000.00
First State Bank1366 NCD 245,000.0033648RAT6 08/20/2019 6881.85008/20/2014 246,465.10 1.825 1.851245,000.00
First State Bank - Dequeen1824 NCD 245,000.00336460CH1 04/29/2022 1,6712.00006/30/2017 243,329.10 1.973 2.000245,000.00
First State Bank of Purdy1475 NCD 248,000.0033646TAE7 04/13/2022 1,6552.35009/25/2015 248,820.88 2.321 2.353247,982.84
First State Community Bank1819 NCD 245,000.0033708UCF4 06/30/2022 1,7332.10006/30/2017 243,804.40 2.071 2.100245,000.00
First Western Bank & Trust1770 NCD 245,000.0033749VAM0 04/07/2022 1,6492.00004/07/2017 243,544.70 1.973 2.001245,000.00
Fox Chase Bank1305 NCD 245,000.0035137QAV6 06/06/2019 6131.70006/06/2014 246,470.00 1.677 1.700245,000.00
Gold Coast Bank1375 NCD 245,000.0038058KDA1 08/05/2019 6731.80009/04/2014 246,291.15 1.775 1.800245,000.00
GE Capital Bank1184 NCD 245,000.0036161TJR7 05/03/2018 2141.00005/03/2013 244,581.05 0.986 1.000245,000.00
GE Capital Bank1262 NCD 245,000.0036157PXV6 03/22/2021 1,2682.65003/21/2014 250,828.55 2.613 2.650245,000.00
Goldman Sachs Bank USA1177 NCD 245,000.0038147JEC2 05/01/2018 2121.15005/01/2013 244,804.00 1.134 1.150245,000.00
Happy State Bank1683 NCD 245,000.00411394AN9 09/16/2021 1,4461.50009/16/2016 240,394.00 1.500 1.520245,000.00
HSBC Bank1564 NCD 245,000.0040434AR84 10/07/2021 1,4672.00004/07/2016 244,973.05245,000.00
Dubuque Bank & Trust1372 NCD 245,000.00263849BD2 08/21/2019 6891.90008/21/2014 246,418.55 1.873 1.900245,000.00
Investors Community Bank1765 NCD 245,000.0046147USQ4 09/23/2022 1,8182.20003/24/2017 244,066.55 2.172 2.202245,000.00
International Bank1841 NCD 245,000.0045906ABP1 07/29/2022 1,7622.10007/31/2017 243,481.00 2.072 2.101245,000.00
Industrial & Com Bk of China1773 NCD 245,000.0045581EAC5 04/12/2022 1,6542.15004/12/2017 245,083.30 2.121 2.151245,000.00
Interaudi Bank1808 NCD 245,000.0045842PAK7 06/10/2024 2,4442.50006/09/2017 244,806.45 2.465 2.500245,000.00
Iroquois Federal Sav Loan Asso1535 NCD 245,000.0046355PBV9 08/12/2020 1,0461.60002/12/2016 243,091.45 1.578 1.600245,000.00
Investors Bank1460 NCD 245,000.0046176PEJ0 08/25/2020 1,0592.00008/25/2015 247,866.50 1.972 2.000245,000.00
Inst. for Sav in Newburyport1455 NCD 245,000.0045780PAN5 07/30/2021 1,3982.30007/31/2015 249,397.75 2.269 2.301245,000.00
Iowa State Bank1343 NCD 250,000.0046256YAB5 07/23/2019 6601.80007/23/2014 251,455.00 1.775 1.800250,000.00
JP Morgan Chase BAnk NA1200 NCD 245,000.0048124JD39 12/05/2018 4301.25006/05/2013 244,154.75 1.232 1.250245,000.00
Kansas State Bank Manhattan1798 NCD 245,000.0050116CAX7 05/31/2024 2,4342.50005/31/2017 244,840.75 2.465 2.500245,000.00
Key Bank1785 NCD 245,000.0049306SYB6 05/18/2020 9601.75005/17/2017 244,487.95 1.726 1.750245,000.00
Lakeside Bank1686 NCD 245,000.0051210SLR6 09/18/2023 2,1781.80009/16/2016 237,409.90 1.775 1.800245,000.00
LCA Bank Corporation1306 NCD 245,000.00501798FJ6 05/30/2019 6061.65005/30/2014 246,467.55 1.627 1.650245,000.00
Leader Bank1364 NCD 245,000.0052168UCN0 08/22/2019 6902.00008/22/2014 245,154.35 1.973 2.001245,000.00
Legends Bank1533 NCD 245,000.0052465JGM3 02/11/2022 1,5941.70002/12/2016 247,788.10 1.678 1.701245,000.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 5
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Negotiable CD's
Live Oak Banking Company1671 NCD 245,000.00538036CH5 08/19/2021 1,4181.40008/19/2016 240,327.85 1.381 1.400245,000.00
Luana Savings Bank1367 NCD 245,000.00549103QA0 09/07/2021 1,4372.25009/05/2014 247,562.70 2.219 2.250245,000.00
Machias Savings Bank1358 NCD 245,000.00554479DN2 08/28/2019 6961.80008/28/2014 246,509.20 1.776 1.801245,000.00
Marathon Savings Bank1818 NCD 245,000.0056585YAA8 06/28/2022 1,7312.05006/28/2017 243,265.40 2.023 2.051245,000.00
Mascoma Savings Bank1319 NCD 248,000.0057461PAG1 01/15/2019 4711.80006/20/2014 249,254.88 1.627 1.650248,461.64
MB Financial Bank NA1730 NCD 245,000.0055266CUF1 01/13/2022 1,5652.10001/13/2017 245,333.20 2.072 2.101245,000.00
Mercantile Bank of Michigan1793 NCD 245,000.0058740XZF0 05/12/2022 1,6842.10005/12/2017 244,274.80 2.071 2.100245,000.00
Mechanics Coop Bank1803 NCD 245,000.00583626AC0 05/26/2022 1,6982.05005/26/2017 243,598.60 2.023 2.051245,000.00
Medallion Bank - Salt Lake1238 NCD 245,000.0058403BJ31 01/10/2019 4661.85001/10/2014 246,202.95 1.825 1.850245,000.00
Merrick Bank1464 NCD 245,000.0059013JHE2 08/20/2020 1,0541.90008/20/2015 245,107.80 1.876 1.902245,000.00
Merchants National Bank OH1534 NCD 245,000.00588806AV1 02/17/2022 1,6001.80002/17/2016 247,111.90 1.776 1.801245,000.00
Mid-Country Bank1810 NCD 245,000.0059565QCG8 06/14/2022 1,7172.05006/14/2017 243,424.65 2.023 2.051245,000.00
Mid-Missouri Bank1806 NCD 245,000.0059541KBL0 06/10/2022 1,7132.05006/12/2017 243,446.70 2.023 2.051245,000.00
Mifflinburg Bank & Trust Co.1321 NCD 132,000.00598580AB4 04/30/2019 5761.65006/20/2014 132,765.60 1.627 1.649132,000.00
Marlin Business Bank1483 NCD 245,000.0057116AKU1 10/21/2020 1,1161.75010/21/2015 247,484.30 1.727 1.751245,000.00
Municipal Trust and Savings1800 NCD 245,000.00625925AP7 05/02/2024 2,4052.35005/22/2017 242,858.70 2.317 2.349245,000.00
Mutual One Bank1407 NCD 250,000.0062847HAA7 11/21/2019 7811.85011/21/2014 251,897.50 1.825 1.850250,000.00
MY Safra Bank FSB1467 NCD 245,000.0055406JAL6 09/03/2020 1,0681.90009/03/2015 247,922.85 1.873 1.900245,000.00
NBT Bank1322 NCD 156,000.00628779FJ4 06/06/2019 6131.80006/20/2014 156,906.36 1.775 1.799156,000.00
NBT Bank1373 NCD 94,000.00628779FN5 08/20/2019 6882.10008/20/2014 94,542.38 2.071 2.10094,000.00
Customers Bank1388 NCD 250,000.0023204HCA4 09/10/2019 7092.10009/10/2014 251,430.00 2.071 2.100250,000.00
NCB Savings Bank1344 NCD 245,000.00628825JL6 07/25/2019 6621.80007/25/2014 245,588.00 1.775 1.800245,000.00
National Bank Commerce1607 NCD 245,000.00633368DY8 05/11/2023 2,0481.80005/11/2016 242,194.75 1.776 1.800245,000.00
Nebraska State Bank & Trust1466 NCD 245,000.0063969ABL7 08/26/2022 1,7902.25008/26/2015 250,091.10 2.220 2.251245,000.00
Lake Sunapee Bank FSB1309 NCD 245,000.00510868AG7 06/05/2019 6121.75006/05/2014 246,470.00 1.727 1.750245,000.00
Northern Bank & Trust MA1814 NCD 245,000.0066476QBX5 06/29/2022 1,7322.10006/29/2017 243,806.85 2.072 2.101245,000.00
Connectone Bank1355 NCD 245,000.0020786AAT2 08/13/2019 6811.85008/13/2014 246,467.55 1.824 1.850245,000.00
Bank of Northern Michigan1298 NCD 245,000.0006414TNW9 05/21/2020 9632.00005/21/2014 247,699.90 1.972 2.000245,000.00
Northfield Bank1365 NCD 245,000.0066612AAA6 08/12/2019 6801.85008/13/2014 246,376.90 1.824 1.850245,000.00
Northstar Bank1326 NCD 245,000.0066704MEG2 07/18/2019 6551.75007/18/2014 246,474.90 1.727 1.751245,000.00
National Bank of NY City1312 NCD 245,000.00634116CB1 06/18/2019 6251.65006/18/2014 246,428.35 1.627 1.650245,000.00
Oostburg State Bank1532 NCD 245,000.00683430BU5 02/09/2021 1,2271.55002/09/2016 246,347.50 1.530 1.551245,000.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 6
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Negotiable CD's
Williamette Valley Bank1524 NCD 245,000.00969294BY2 02/06/2023 1,9542.10002/04/2016 246,225.00 2.072 2.101245,000.00
Orrstown Bank1465 NCD 245,000.00687377DR9 08/20/2020 1,0542.00008/20/2015 245,139.65 1.974 2.002245,000.00
South Ottumwa Savings Bank1851 NCD 245,000.00839145AA7 09/29/2022 1,8242.05009/29/2017 242,270.70 2.022 2.051245,000.00
Peoples United Bank1378 NCD 245,000.0071270QGB6 08/27/2019 6951.95008/27/2014 246,416.10 1.923 1.950245,000.00
Ponce De Leon Federal Bank1795 NCD 245,000.00732333AH2 05/26/2022 1,6982.10005/26/2017 244,140.05 2.072 2.101245,000.00
Parkside Financial Bank1833 NCD 245,000.0070147ACE2 03/15/2023 1,9912.10007/19/2017 242,184.95 2.072 2.101245,000.00
Peapack-Gladstone Bank1275 NCD 245,000.00704692AK8 04/17/2019 5631.80004/17/2014 246,413.65 1.776 1.801245,000.00
Planters Bank1363 NCD 245,000.0072741PCU9 08/20/2021 1,4192.50008/20/2014 240,518.95 2.467 2.501245,000.00
Prime Alliance Bank1331 NCD 245,000.0074160NED8 07/11/2019 6481.70007/11/2014 246,430.80 1.677 1.701245,000.00
Park National Bank1395 NCD 250,000.00700654AV8 03/26/2019 5412.10009/26/2014 250,617.50 2.070 2.099250,000.00
Providence Bank1445 NCD 245,000.00743738BQ8 02/25/2022 1,6082.10002/26/2015 250,811.40 2.072 2.101245,000.00
Peoples State Bank, WI1304 NCD 245,000.00712515GY5 05/23/2019 5991.70005/23/2014 246,425.90 1.676 1.700245,000.00
Private Bank & Trust Co.1293 NCD 245,000.0074267GUN5 11/21/2018 4161.65005/21/2014 245,703.15 1.627 1.650245,000.00
Ohio Valley Bank1338 NCD 250,000.00677721CE0 07/23/2019 6601.80007/23/2014 251,502.50 1.776 1.801250,000.00
Reliance Savings Bank1636 NCD 245,000.0075950XAD1 06/22/2021 1,3601.45006/22/2016 241,837.05 1.430 1.450245,000.00
Sallie Mae Bank1350 NCD 245,000.00795450SC0 07/30/2019 6672.05007/30/2014 246,465.10 2.021 2.050245,000.00
State Bank Definace1233 NCD 245,000.00855736CX0 07/19/2018 2911.65007/19/2013 245,776.65 1.628 1.650245,000.00
State Bank of India1390 NCD 245,000.00856284Z98 09/11/2019 7102.15009/11/2014 246,445.50 2.120 2.150245,000.00
State Bank of Texas1230 NCD 245,000.00856528CG7 07/17/2018 2891.60007/17/2013 245,071.05 1.578 1.600245,000.00
Security National Bank1499 NCD 245,000.00814414AC2 11/19/2021 1,5102.00011/19/2015 244,816.25 1.974 2.001245,000.00
Security State Bank1774 NCD 245,000.0081489TAS5 04/07/2022 1,6492.10004/07/2017 244,605.55 2.072 2.101245,000.00
Somerset Trust Company Bank1616 NCD 245,000.00835104BL3 06/12/2023 2,0801.80006/10/2016 239,171.45 1.776 1.800245,000.00
Bank of New England1704 NCD 245,000.00063847AW7 10/19/2021 1,4791.50010/19/2016 239,818.25 1.480 1.500245,000.00
Bell State Bank & Trust1223 NCD 245,000.0007815AAG2 06/28/2018 2701.30006/28/2013 244,960.80 1.282 1.300245,000.00
Security Bank1777 NCD 245,000.00814107AQ1 04/19/2022 1,6612.00004/19/2017 243,427.10 1.973 2.001245,000.00
Sterns Bank NA1221 NCD 245,000.00857894NG0 06/28/2018 2701.30006/28/2013 244,980.40 1.282 1.300245,000.00
Stockman Bank1557 NCD 245,000.0086128QBX5 03/30/2023 2,0062.00003/30/2016 244,377.70 1.973 2.000245,000.00
Third Federal Savings and Loan1242 NCD 245,000.0088413QAF5 10/22/2018 3861.75001/22/2014 245,830.55 1.726 1.750245,000.00
Thomasville Natl Bank1266 NCD 245,000.00884693BJ0 04/12/2021 1,2892.40004/11/2014 250,929.00 2.367 2.400245,000.00
Crossfirst Bank of Leawood1804 NCD 245,000.0022766ABF1 06/09/2023 2,0772.15006/09/2017 242,466.70 2.121 2.151245,000.00
Toyota Financial Savings Bank1740 NCD 245,000.0089235MHU8 02/12/2024 2,3252.65002/10/2017 245,460.60245,000.00
Traverse City State Bank1820 NCD 245,000.00894333FF5 06/28/2022 1,7312.00006/28/2017 242,719.05 1.972 2.000245,000.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 7
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Negotiable CD's
UBS Bank USA1815 NCD 250,000.0090348JBR0 01/20/2022 1,5722.25006/15/2017 251,825.00 2.219 2.249250,000.00
United Community Bank GA1749 NCD 245,000.0090984P5A9 03/01/2022 1,6122.05003/01/2017 244,416.90 2.021 2.050245,000.00
Uinta Bank1639 NCD 245,000.00903572BC8 12/26/2023 2,2771.70006/24/2016 238,296.80 1.676 1.700245,000.00
United Bankers' Bank1379 NCD 245,000.00909557EA4 04/29/2019 5751.80008/29/2014 245,803.60 1.776 1.800245,000.00
United Community Bank1694 NCD 245,000.0090983WBD2 03/28/2022 1,6391.60009/29/2016 240,171.05 1.577 1.599245,000.00
Unity Bank1529 NCD 245,000.0091330ABF3 02/26/2021 1,2441.60002/26/2016 246,421.00 1.579 1.601245,000.00
Valley Central Savings Bank1422 NCD 245,000.0091944RAF5 12/30/2019 8201.85012/29/2014 246,832.60 1.824 1.850245,000.00
Washington Trst Westerly1345 NCD 245,000.00940637GJ4 07/31/2019 6681.90007/31/2014 246,467.55 1.873 1.900245,000.00
Webster Bank NA1252 NCD 245,000.0094768NJM7 02/12/2019 4991.90002/12/2014 246,060.85 1.873 1.900245,000.00
Northwest Bank1308 NCD 245,000.0066736AAK5 05/29/2019 6051.65005/29/2014 246,472.45 1.628 1.650245,000.00
Western State Bank1392 NCD 245,000.0095960NJA6 03/26/2020 9072.10009/26/2014 246,778.70 2.071 2.100245,000.00
Washington First Bank1745 NCD 245,000.00940727AH3 02/23/2022 1,6062.05002/23/2017 244,470.80 2.021 2.050245,000.00
Wells Fargo Bank1656 NCD 245,000.009497486H5 06/30/2021 1,3681.60006/30/2016 241,815.00 1.578 1.600245,000.00
Woodford State Bank1459 NCD 245,000.00979424AA6 07/29/2022 1,7622.35008/12/2015 249,704.00 2.317 2.349245,000.00
Washington County Bank1842 NCD 245,000.0093754PAN7 05/11/2022 1,6832.05008/11/2017 243,745.60 2.021 2.050245,000.00
Zions First National Bank1417 NCD 250,000.0098970TU79 12/10/2019 8001.90012/08/2014 250,370.00 1.873 1.899250,000.00
Subtotal and Average 48,419,331.50 48,426,000.00 48,401,086.60 1.857 1.883 1,225
Medium Term Notes
Apple, Inc.1342 MTN 2,000,000.00037833AQ3 05/06/2019 5822.10007/15/2014 2,015,840.00 1.982 2.0102,002,717.22
Apple, Inc.1461 MTN 750,000.00037833AX8 02/07/2020 8591.55008/13/2015 746,295.00 1.980 2.008742,310.52
Apple, Inc.1497 MTN 1,500,000.00037833BD1 05/06/2020 9482.00011/05/2015 1,507,710.00 1.854 1.8791,504,464.47
Apple, Inc.1543 MTN 700,000.00037833BS8 02/23/2021 1,2412.25002/23/2016 705,635.00 2.140 2.169701,767.83
Alphabet (Google) Inc.1657 MTN 100,000.0002079KAA5 05/19/2021 1,3263.62507/11/2016 105,778.00 1.271 1.288108,201.19
Alphabet (Google) Inc.1658 MTN 946,000.0038259PAB8 05/19/2021 1,3263.62507/11/2016 1,000,659.88 1.271 1.2881,023,583.26
Alphabet (Google) Inc.1660 MTN 1,500,000.0002079KAA5 05/19/2021 1,3263.62507/12/2016 1,586,670.00 1.238 1.2551,624,862.71
Alphabet (Google) Inc.1734 MTN 871,000.0002079KAA5 05/19/2021 1,3263.62501/11/2017 921,326.38 2.012 2.040918,748.99
Johnson & Johnson1411 MTN 2,000,000.00478160BM5 12/05/2019 7951.87511/24/2014 2,011,100.00 1.874 1.9001,998,961.02
Johnson & Johnson1418 MTN 1,500,000.00478160BM5 12/05/2019 7951.87512/08/2014 1,508,325.00 1.824 1.8501,500,771.57
Johnson & Johnson1624 MTN 1,000,000.00478160BS2 03/01/2021 1,2471.65006/07/2016 991,510.00 1.530 1.5511,003,161.62
Microsoft Corporation1448 MTN 2,000,000.00594918AV0 02/12/2020 8641.85002/12/2015 2,009,100.00 1.785 1.8102,001,776.61
Microsoft Corporation1496 MTN 2,000,000.00594918BG8 11/03/2020 1,1292.00011/05/2015 2,011,420.00 1.913 1.9402,003,463.40
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 8
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Medium Term Notes
Microsoft Corporation1515 MTN 900,000.00594918BG8 11/03/2020 1,1292.00001/07/2016 905,139.00 1.887 1.913902,282.93
Stanford University1336 MTN 300,000.00854403AC6 05/01/2019 5774.75007/10/2014 314,097.00 1.966 1.993312,424.12
Stanford University1347 MTN 150,000.00854403AC6 05/01/2019 5774.75007/24/2014 157,048.50 1.896 1.922156,384.86
Stanford University1349 MTN 225,000.00854403AC6 05/01/2019 5774.75007/25/2014 235,572.75 1.895 1.921234,582.88
Stanford University1419 MTN 105,000.00854403AC6 05/01/2019 5774.75012/11/2014 109,933.95 1.893 1.920109,490.64
Subtotal and Average 18,849,955.84 18,547,000.00 18,843,160.46 1.789 1.814 980
Federal Agency Issues - Coupon
Federal Agricultural Mortgage1028 3,000,000.0031315PPC7 02/21/2019 5081.79002/21/2012 3,012,930.00 1.765 1.7903,000,000.00
Federal Agricultural Mortgage1031 2,000,000.0031315PQC6 09/06/2018 3401.55003/06/2012 2,003,480.00 1.528 1.5502,000,000.00
Federal Agricultural Mortgage1052 1,500,000.0031315PTW9 04/10/2019 5561.87004/10/2012 1,505,010.00 1.844 1.8701,500,000.00
Federal Agricultural Mortgage1123 Call 1,500,000.0031315PQL6 11/29/2021 1,5202.00011/29/2012 1,494,975.00 1.972 2.0001,500,000.00
Federal Agricultural Mortgage1130 1,500,000.0031315PPX1 07/05/2022 1,7382.20012/13/2012 1,510,590.00 1.930 1.9571,515,752.42
Federal Agricultural Mortgage1134 750,000.0031315PB32 11/21/2022 1,8772.00012/19/2012 743,227.50 2.081 2.110746,189.42
Federal Agricultural Mortgage1136 1,500,000.0031315PTY5 12/27/2019 8171.48012/27/2012 1,491,765.00 1.395 1.4151,502,067.77
Federal Agricultural Mortgage1137 1,500,000.0031315PUE7 12/27/2022 1,9132.18001/04/2013 1,494,825.00 2.165 2.1961,498,873.28
Federal Agricultural Mortgage1138 740,000.0031315PEY1 12/30/2019 8204.50001/04/2013 787,582.00 1.514 1.535786,574.61
Federal Agricultural Mortgage1139 500,000.0031315PWN5 06/01/2021 1,3393.84001/04/2013 531,565.00 1.946 1.973531,390.88
Federal Agricultural Mortgage1141 1,500,000.0031315PUE7 12/27/2022 1,9132.18001/08/2013 1,494,825.00 2.195 2.2251,496,799.74
Federal Agricultural Mortgage1142 1,200,000.0031315PTW9 04/10/2019 5561.87001/09/2013 1,204,008.00 1.400 1.4201,207,850.87
Federal Agricultural Mortgage1143 451,000.0031315PPC7 02/21/2019 5081.79001/09/2013 452,943.81 1.372 1.392453,381.27
Federal Agricultural Mortgage1144 1,500,000.0031315PUE7 12/27/2022 1,9132.18001/23/2013 1,494,825.00 2.111 2.1411,502,738.76
Federal Agricultural Mortgage1147 2,595,000.0031315PUE7 12/27/2022 1,9132.18001/28/2013 2,586,047.25 2.199 2.2292,588,925.14
Federal Agricultural Mortgage1152 2,000,000.0031315PPF0 01/30/2019 4861.32002/11/2013 1,995,260.00 1.220 1.2372,002,121.95
Federal Agricultural Mortgage1155 1,500,000.0031315PPF0 01/30/2019 4861.32002/21/2013 1,496,445.00 1.262 1.2801,500,763.18
Federal Agricultural Mortgage1160 1,500,000.0031315PQM4 03/06/2018 1560.94003/07/2013 1,498,980.00 0.925 0.9371,500,012.59
Federal Agricultural Mortgage1163 1,500,000.0031315PQM4 03/06/2018 1560.94003/08/2013 1,498,980.00 0.987 1.0011,499,614.66
Federal Agricultural Mortgage1179 1,500,000.0031315PXM6 05/02/2018 2130.85005/02/2013 1,496,130.00 0.864 0.8771,499,768.25
Federal Agricultural Mortgage1186 1,450,000.0031315PXH7 01/09/2019 4652.10005/01/2013 1,461,701.50 1.055 1.0701,468,382.73
Federal Agricultural Mortgage1199 1,500,000.0031315PZZ5 03/09/2018 1590.77005/15/2013 1,496,970.00 0.961 0.9751,498,683.79
Federal Agricultural Mortgage1209 1,500,000.0031315PZZ5 03/09/2018 1590.77005/30/2013 1,496,970.00 1.151 1.1671,497,465.24
Federal Agricultural Mortgage1224 1,500,000.0031315PC98 06/12/2018 2541.18006/21/2013 1,497,975.00 1.549 1.5701,496,081.12
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 9
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Federal Agricultural Mortgage1225 1,500,000.0031315PC98 06/12/2018 2541.18006/21/2013 1,497,975.00 1.575 1.5971,495,816.67
Federal Agricultural Mortgage1226 1,500,000.0031315PC98 06/12/2018 2541.18006/25/2013 1,497,975.00 1.783 1.8081,493,744.87
Federal Agricultural Mortgage1243 1,500,000.0031315PQT9 03/06/2020 8871.41001/15/2014 1,489,080.00 2.462 2.4961,463,474.39
Federal Agricultural Mortgage1244 1,500,000.0031315P3G2 09/09/2020 1,0742.80001/15/2014 1,531,530.00 2.635 2.6721,505,124.27
Federal Agricultural Mortgage1256 1,500,000.0031315PXH7 01/09/2019 4652.10003/05/2014 1,512,105.00 1.702 1.7261,506,810.91
Federal Agricultural Mortgage1257 300,000.0031315PTU3 03/09/2021 1,2554.16003/06/2014 321,435.00 2.574 2.609314,528.47
Federal Agricultural Mortgage1258 1,500,000.0031315P6P9 03/05/2024 2,3473.40003/07/2014 1,568,445.00 3.325 3.3721,502,267.05
Federal Agricultural Mortgage1259 1,500,000.0031315P6P9 03/05/2024 2,3473.40003/10/2014 1,568,445.00 3.424 3.4711,494,206.95
Federal Agricultural Mortgage1264 1,500,000.0031315PK40 03/26/2021 1,2722.50003/26/2014 1,525,530.00 2.495 2.5301,498,543.30
Federal Agricultural Mortgage1265 1,800,000.0031315PJ67 02/28/2019 5151.70003/28/2014 1,804,842.00 1.784 1.8091,797,362.74
Federal Agricultural Mortgage1271 1,000,000.0031315P4B2 01/30/2024 2,3123.46004/09/2014 1,051,490.00 3.297 3.3431,006,215.45
Federal Agricultural Mortgage1279 1,250,000.0031315PPX1 07/05/2022 1,7382.20004/23/2014 1,258,825.00 2.889 2.9301,211,614.02
Federal Agricultural Mortgage1399 500,000.0031315PVF3 04/03/2020 9151.47510/15/2014 497,580.00 1.857 1.882495,164.58
Federal Agricultural Mortgage1406 1,500,000.0031315PA58 11/20/2019 7801.31011/07/2014 1,490,160.00 1.854 1.8801,482,649.78
Federal Agricultural Mortgage1408 2,000,000.0031315PM22 11/20/2019 7801.84011/20/2014 2,009,260.00 1.814 1.8402,000,000.00
Federal Agricultural Mortgage1410 1,500,000.0031315PM22 11/20/2019 7801.84011/20/2014 1,506,945.00 1.848 1.8731,498,974.67
Federal Agricultural Mortgage1423 1,500,000.0031315PZ85 12/23/2019 8131.85012/23/2014 1,503,810.00 1.851 1.8761,499,151.22
Federal Agricultural Mortgage1427 675,000.0031315P2C2 05/05/2021 1,3122.51001/09/2015 686,913.75 2.110 2.140683,346.90
Federal Agricultural Mortgage1428 404,000.0031315PL23 03/27/2024 2,3693.33001/09/2015 418,701.56 2.540 2.575421,492.54
Federal Agricultural Mortgage1433 1,604,000.0031315PD89 06/12/2023 2,0802.61001/22/2015 1,614,377.88 2.269 2.3011,629,531.93
Federal Agricultural Mortgage1447 1,450,000.0031315PD89 06/12/2023 2,0802.61002/09/2015 1,459,381.50 2.377 2.4101,464,864.80
Federal Agricultural Mortgage1452 1,000,000.003130H0AJ2 03/01/2022 1,6122.15003/05/2015 1,005,190.00 2.120 2.1501,000,000.00
Federal Agricultural Mortgage1552 Call 1,500,000.003132X0EU1 01/27/2026 3,0402.93002/26/2016 1,468,320.00 2.831 2.8701,506,367.86
Federal Agricultural Mortgage1554 Call 1,500,000.003132X0EU1 01/27/2026 3,0402.93003/02/2016 1,468,320.00 2.878 2.9181,501,260.59
Federal Agricultural Mortgage1576 1,000,000.0031315PZS1 01/24/2023 1,9412.13004/06/2016 1,001,450.00 1.839 1.8641,013,158.91
Federal Agricultural Mortgage1580 474,000.0031315PEM7 08/04/2025 2,8644.35004/08/2016 533,306.88 2.296 2.328541,196.17
Federal Agricultural Mortgage1595 1,500,000.0031315P2J7 05/01/2024 2,4043.30004/21/2016 1,560,885.00 2.084 2.1121,607,289.65
Federal Agricultural Mortgage1604 1,500,000.0031315P2J7 05/01/2024 2,4043.30004/26/2016 1,560,885.00 2.159 2.1891,600,032.89
Federal Agricultural Mortgage1617 500,000.0031315PUE7 12/27/2022 1,9132.18005/26/2016 498,275.00 1.844 1.870507,588.54
Federal Agricultural Mortgage1655 1,500,000.0031315PQT9 03/06/2020 8871.41007/01/2016 1,489,080.00 0.992 1.0051,514,427.59
Federal Agricultural Mortgage1663 510,000.0031315PQT9 03/06/2020 8871.41007/21/2016 506,287.20 1.135 1.150513,134.69
Federal Agricultural Mortgage1665 2,000,000.003132X0BH3 07/15/2022 1,7482.38007/25/2016 2,011,520.00 1.499 1.5202,078,437.99
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 10
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Federal Agricultural Mortgage1681 1,750,000.003132X0BG5 06/15/2020 9881.75008/24/2016 1,746,920.00 1.136 1.1521,777,616.38
Federal Agricultural Mortgage1698 1,500,000.003132X0EQ0 01/25/2021 1,2121.55010/03/2016 1,482,840.00 1.256 1.2741,513,305.56
Federal Agricultural Mortgage1710 1,500,000.0031315PRA9 02/03/2026 3,0474.81010/18/2016 1,746,060.00 2.131 2.1601,798,719.19
Federal Agricultural Mortgage1736 Call 1,000,000.003130H0BL6 01/01/2027 3,3793.20001/19/2017 1,000,040.00 3.156 3.2001,000,000.00
Federal Agricultural Mortgage1755 1,000,000.003132X0PX3 02/23/2022 1,6062.10002/23/2017 1,002,430.00 2.034 2.0631,001,533.66
Federal Agricultural Mortgage1758 1,500,000.003132X0PX3 02/23/2022 1,6062.10003/02/2017 1,503,645.00 2.085 2.1141,499,072.53
Federal Agricultural Mortgage1769 1,500,000.003132X0RS2 04/06/2022 1,6482.07504/06/2017 1,501,395.00 2.046 2.0751,500,000.00
Federal Agricultural Mortgage1781 1,000,000.003132X0QG9 02/22/2021 1,2401.90004/12/2017 1,000,630.00 1.781 1.8051,003,062.16
Federal Agricultural Mortgage1784 Call 1,500,000.003132X0QC8 02/23/2027 3,4323.25004/27/2017 1,500,945.00 3.200 3.2451,500,535.13
Federal Agricultural Mortgage1788 1,000,000.003132X0NZ0 01/03/2022 1,5552.10005/04/2017 1,000,780.00 1.938 1.9651,005,456.44
Federal Agricultural Mortgage1789 Call 1,000,000.003130H0BN2 05/01/2027 3,4993.20005/11/2017 996,450.00 3.156 3.2001,000,000.00
Federal Agricultural Mortgage1792 Call 1,500,000.003132X0QC8 02/23/2027 3,4323.25005/09/2017 1,500,945.00 3.201 3.2451,500,000.00
Federal Agricultural Mortgage1794 Call 1,000,000.003132X0MM0 12/22/2026 3,3693.37505/10/2017 1,002,810.00 3.244 3.2891,006,714.90
Federal Agricultural Mortgage1817 1,000,000.0031315PPX1 07/05/2022 1,7382.20006/14/2017 1,007,060.00 1.908 1.9341,011,972.59
Federal Agricultural Mortgage1830 1,500,000.003132X0UA7 06/29/2022 1,7321.88006/29/2017 1,494,555.00 1.903 1.9301,496,612.47
Federal Agricultural Mortgage1831 1,000,000.003132X0UA7 06/29/2022 1,7321.88006/29/2017 996,370.00 1.923 1.949996,850.64
Federal Agricultural Mortgage1850 Call 1,500,000.003130H0BR3 09/01/2027 3,6223.05009/28/2017 1,487,895.00 3.008 3.0501,500,000.00
Federal Agricultural Mortgage839 1,500,000.0031315PEY1 12/30/2019 8204.50012/30/2009 1,596,450.00 4.438 4.5001,500,000.00
Federal Agricultural Mortgage923 1,500,000.0031315PNM7 12/28/2017 883.15012/28/2010 1,508,520.00 3.106 3.1501,500,000.00
Federal Agricultural Mortgage942 1,500,000.0031315PTU3 03/09/2021 1,2554.16003/09/2011 1,607,175.00 4.103 4.1601,500,000.00
Federal Farm Credit Bank1092 1,500,000.003133EAUF3 06/14/2019 6211.50006/14/2012 1,497,540.00 1.479 1.5001,500,000.00
Federal Farm Credit Bank1205 575,000.0031331JQM8 06/04/2018 2463.40005/23/2013 583,481.25 1.045 1.060583,821.29
Federal Farm Credit Bank1206 950,000.0031331YW63 06/12/2018 2544.90005/23/2013 973,455.50 1.045 1.060974,701.06
Federal Farm Credit Bank722 2,000,000.0031331YCJ7 10/30/2017 294.90010/30/2007 2,006,700.00 4.832 4.9002,000,000.00
Federal Farm Credit Bank725 2,000,000.0031331YHQ6 12/15/2017 754.62512/12/2007 2,014,880.00 4.561 4.6242,000,000.00
Federal Farm Credit Bank903 1,000,000.0031331JN90 09/29/2020 1,0942.87509/29/2010 1,025,640.00 2.835 2.8751,000,000.00
Federal Farm Credit Bank918 2,000,000.0031331J5F6 12/16/2020 1,1723.62512/16/2010 2,107,640.00 3.575 3.6252,000,000.00
Federal Farm Credit Bank .1181 Call 1,500,000.003133EA4J4 10/11/2018 3751.15004/30/2013 1,496,625.00 1.137 1.1531,499,943.40
Federal Farm Credit Bank .1189 Call 1,500,000.003133ECMF8 04/24/2018 2050.98005/06/2013 1,497,315.00 0.986 1.0001,499,829.70
Federal Farm Credit Bank .1227 1,500,000.003133ECTM6 07/02/2018 2741.90007/02/2013 1,508,145.00 1.873 1.9001,500,000.00
Federal Farm Credit Bank .1241 500,000.003133ECRH9 06/06/2023 2,0742.45001/09/2014 505,910.00 3.383 3.430476,374.12
Federal Farm Credit Bank .1526 625,000.003133EAA65 07/26/2023 2,1242.12501/27/2016 622,118.75 2.024 2.052627,445.07
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 11
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Federal Farm Credit Bank .1563 500,000.0031331XSS2 03/14/2022 1,6255.16003/17/2016 564,050.00 1.876 1.902568,233.77
Federal Farm Credit Bank .1565 Call 1,000,000.003133EFT98 03/28/2025 2,7352.62003/28/2016 985,210.00 2.596 2.632999,167.59
Federal Farm Credit Bank .1582 Call 1,500,000.003133EF3D7 04/21/2025 2,7592.54004/21/2016 1,474,065.00 2.505 2.5401,500,000.00
Federal Farm Credit Bank .1584 Call 1,500,000.003133EF3D7 04/21/2025 2,7592.54004/21/2016 1,474,065.00 2.505 2.5401,500,000.00
Federal Farm Credit Bank .1585 Call 1,500,000.003133EF4A2 04/19/2022 1,6611.92004/19/2016 1,482,645.00 1.893 1.9201,500,000.00
Federal Farm Credit Bank .1591 Call 1,500,000.003133EF2D8 04/13/2026 3,1162.64004/19/2016 1,477,680.00 2.603 2.6391,500,000.00
Federal Farm Credit Bank .1593 250,000.003133EC4L5 11/23/2021 1,5141.61004/21/2016 245,422.50 1.558 1.580250,294.77
Federal Farm Credit Bank .1596 1,000,000.003133ECPF5 05/13/2022 1,6851.87504/21/2016 990,220.00 1.578 1.6001,012,049.88
Federal Farm Credit Bank .1598 Call 1,000,000.003133EFX44 10/05/2022 1,8302.05004/22/2016 990,910.00 2.021 2.0491,000,000.00
Federal Farm Credit Bank .1603 Call 1,930,000.003133EFYV3 02/17/2026 3,0612.82004/26/2016 1,916,277.70 2.722 2.7601,938,407.39
Federal Farm Credit Bank .1606 Call 1,605,000.003133EFYF8 02/10/2025 2,6892.73004/28/2016 1,599,254.10 2.621 2.6571,612,529.80
Federal Farm Credit Bank .1609 Call 1,000,000.003133EF6T9 05/12/2025 2,7802.47005/12/2016 981,350.00 2.436 2.4701,000,000.00
Federal Farm Credit Bank .1615 1,000,000.003133EC7D0 12/13/2024 2,6302.12505/13/2016 979,620.00 1.930 1.9561,011,089.40
Federal Farm Credit Bank .1623 Call 1,500,000.003133EGEB7 06/09/2026 3,1732.57006/09/2016 1,465,500.00 2.534 2.5701,500,000.00
Federal Farm Credit Bank .1630 Call 1,000,000.003133EF2D8 04/13/2026 3,1162.64006/13/2016 985,120.00 2.522 2.5571,006,161.36
Federal Farm Credit Bank .1634 Call 1,000,000.003133EF2D8 04/13/2026 3,1162.64006/16/2016 985,120.00 2.489 2.5241,008,685.33
Federal Farm Credit Bank .1638 Call 2,000,000.003133EGGR0 06/22/2026 3,1862.50006/22/2016 1,947,900.00 2.582 2.6182,000,000.00
Federal Farm Credit Bank .1641 Call 1,500,000.003133EGHN8 06/30/2025 2,8292.42006/30/2016 1,473,285.00 2.386 2.4201,500,000.00
Federal Farm Credit Bank .1647 Call 1,500,000.003133EGJH9 01/06/2025 2,6542.24007/06/2016 1,467,210.00 2.209 2.2401,500,000.00
Federal Farm Credit Bank .1650 1,500,000.003133EGKM6 07/06/2020 1,0091.00007/06/2016 1,464,285.00 0.986 1.0001,500,000.00
Federal Farm Credit Bank .1659 500,000.0031331XSS2 03/14/2022 1,6255.16007/08/2016 564,050.00 1.215 1.232584,200.59
Federal Farm Credit Bank .1664 Call 1,500,000.003133EGFB6 06/16/2025 2,8152.36007/25/2016 1,460,025.00 2.309 2.3411,501,950.56
Federal Farm Credit Bank .1675 Call 1,500,000.003133EGQA6 11/08/2023 2,2291.85008/09/2016 1,439,190.00 1.859 1.8851,497,031.65
Federal Farm Credit Bank .1679 Call 1,350,000.003133EGQH1 08/10/2026 3,2352.14008/18/2016 1,275,898.50 2.110 2.1391,350,000.00
Federal Farm Credit Bank .1701 Call 1,625,000.003133EGXB6 10/05/2026 3,2912.14010/06/2016 1,531,123.75 2.154 2.1841,619,141.15
Federal Farm Credit Bank .1705 Call 1,000,000.003133EGYL3 10/17/2025 2,9382.09010/17/2016 956,270.00 2.061 2.0901,000,000.00
Federal Farm Credit Bank .1782 500,000.0031331XHX3 12/21/2021 1,5425.05004/12/2017 560,750.00 1.884 1.910563,099.80
Federal Farm Credit Bank .1787 900,000.003133EEVD9 03/25/2024 2,3672.30005/04/2017 893,331.00 2.274 2.306899,652.86
Federal Farm Credit Bank .1822 500,000.003133EDWX6 10/07/2024 2,5632.91006/21/2017 516,345.00 2.143 2.172523,783.45
Federal Farm Credit Bank .1826 Call 1,000,000.003133EHGK3 04/24/2025 2,7622.85006/22/2017 1,000,000.00 2.798 2.8361,000,000.00
Federal Farm Credit Bank .1843 445,000.003133ED6R8 11/07/2022 1,8632.93009/14/2017 463,093.70 1.870 1.896467,231.06
Federal Farm Credit Bank .1845 Call 506,000.003133EFYK7 02/08/2023 1,9562.29009/14/2017 501,461.18 2.260 2.291505,949.84
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 12
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Federal Farm Credit Bank .1846 Call 1,500,000.003133EHZL0 09/20/2027 3,6412.92009/20/2017 1,487,460.00 2.880 2.9201,500,000.00
Federal Farm Credit Bank .1848 Call 1,000,000.003133EGCR4 06/01/2023 2,0692.07009/18/2017 988,780.00 2.135 2.165994,942.23
Federal Farm Credit Bank .1849 Call 1,000,000.003133EHTZ6 08/09/2027 3,5992.95009/18/2017 997,160.00 2.909 2.9491,000,000.00
Federal Home Loan Bank1012 2,000,000.00313376BR5 12/14/2018 4391.75012/16/2011 2,007,200.00 1.725 1.7492,000,000.00
Federal Home Loan Bank1039 1,500,000.003133782M2 03/08/2019 5231.50003/08/2012 1,500,645.00 1.574 1.5961,498,045.86
Federal Home Loan Bank1041 1,500,000.00313378LA7 02/25/2022 1,6082.33003/20/2012 1,518,945.00 2.298 2.3301,500,000.00
Federal Home Loan Bank1049 1,500,000.00313378VG3 05/22/2019 5981.85004/09/2012 1,504,815.00 1.824 1.8501,500,000.00
Federal Home Loan Bank1058 1,500,000.003133792L2 10/20/2017 191.23004/20/2012 1,500,165.00 1.213 1.2301,500,000.00
Federal Home Loan Bank1068 1,500,000.00313379BL2 12/29/2017 891.25004/30/2012 1,500,435.00 1.232 1.2501,500,000.00
Federal Home Loan Bank1073 2,000,000.00313379EC9 11/18/2020 1,1442.00005/18/2012 2,015,100.00 1.972 2.0002,000,000.00
Federal Home Loan Bank1125 1,500,000.00313381C94 12/13/2019 8031.25011/30/2012 1,488,300.00 1.196 1.2121,501,174.07
Federal Home Loan Bank1126 Call 750,000.00313381DA0 12/05/2022 1,8912.19012/05/2012 740,092.50 2.165 2.195749,805.83
Federal Home Loan Bank1127 1,500,000.00313381GB5 11/30/2018 4251.00011/30/2012 1,493,130.00 0.986 1.0001,500,000.00
Federal Home Loan Bank1131 1,500,000.00313381C94 12/13/2019 8031.25012/13/2012 1,488,300.00 1.232 1.2491,500,000.00
Federal Home Loan Bank1135 1,500,000.00313376BR5 12/14/2018 4391.75012/19/2012 1,505,400.00 1.075 1.0901,511,496.60
Federal Home Loan Bank1140 1,500,000.00313376BR5 12/14/2018 4391.75001/08/2013 1,505,400.00 1.117 1.1321,510,739.86
Federal Home Loan Bank1146 Call 212,500.00313381DA0 12/05/2022 1,8912.19001/25/2013 209,692.88 2.201 2.232212,081.59
Federal Home Loan Bank1154 1,500,000.003133XRFZ8 06/08/2018 2504.75002/21/2013 1,534,275.00 1.020 1.0351,537,106.73
Federal Home Loan Bank1156 1,315,000.003133XHRJ3 12/10/2021 1,5315.00002/25/2013 1,476,192.70 1.825 1.8501,474,517.96
Federal Home Loan Bank1157 2,000,000.003133XSR59 12/14/2018 4393.75002/25/2013 2,054,280.00 1.128 1.1442,060,465.37
Federal Home Loan Bank1168 530,000.003133XSR59 12/14/2018 4393.75003/11/2013 544,384.20 1.165 1.182545,778.68
Federal Home Loan Bank1182 Call 1,500,000.00313381C29 06/04/2018 2461.05004/30/2013 1,497,195.00 1.039 1.0541,499,960.25
Federal Home Loan Bank1204 Call 557,958.01313383EP2 06/20/2018 2621.25006/20/2013 557,941.27 1.232 1.250557,958.01
Federal Home Loan Bank1212 1,500,000.00313379DT3 06/08/2018 2501.25006/05/2013 1,499,625.00 1.222 1.2391,500,108.91
Federal Home Loan Bank1213 2,000,000.00313379DT3 06/08/2018 2501.25006/06/2013 1,999,500.00 1.191 1.2082,000,556.93
Federal Home Loan Bank1216 Call 1,500,000.00313382Y98 05/16/2018 2271.00006/12/2013 1,496,520.00 1.412 1.4321,496,099.92
Federal Home Loan Bank1217 Call 1,000,000.00313382FP3 03/20/2018 1701.00006/12/2013 998,200.00 1.372 1.391998,229.34
Federal Home Loan Bank1228 1,500,000.00313373UU4 06/08/2018 2502.75007/01/2013 1,514,805.00 1.605 1.6271,511,057.45
Federal Home Loan Bank1240 1,500,000.00313371U79 12/11/2020 1,1673.12501/09/2014 1,564,155.00 2.615 2.6511,520,572.63
Federal Home Loan Bank1248 1,500,000.003130A0J27 01/07/2020 8282.22001/23/2014 1,520,115.00 2.194 2.2251,499,834.44
Federal Home Loan Bank1253 1,500,000.003130A12B3 03/13/2020 8942.12502/24/2014 1,515,090.00 2.095 2.1241,500,000.00
Federal Home Loan Bank1261 1,500,000.00313382K69 03/12/2021 1,2581.75003/13/2014 1,497,930.00 2.418 2.4511,466,841.80
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 13
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Federal Home Loan Bank1267 1,500,000.00313370US5 09/11/2020 1,0762.87504/02/2014 1,550,895.00 2.271 2.3031,523,346.05
Federal Home Loan Bank1270 200,000.00313379EC9 11/18/2020 1,1442.00004/08/2014 201,510.00 2.263 2.295198,294.35
Federal Home Loan Bank1272 550,000.00313379EC9 11/18/2020 1,1442.00004/09/2014 554,152.50 2.263 2.295545,307.48
Federal Home Loan Bank1278 325,000.003133XTYY6 06/14/2019 6214.37504/22/2014 340,382.25 1.889 1.916337,897.78
Federal Home Loan Bank1314 1,500,000.00313379EE5 06/14/2019 6211.62506/04/2014 1,502,475.00 1.700 1.7241,497,576.79
Federal Home Loan Bank1318 1,500,000.00313379EE5 06/14/2019 6211.62506/16/2014 1,502,475.00 1.774 1.7991,495,767.52
Federal Home Loan Bank1324 Call 1,250,000.003133836A4 05/22/2019 5980.80006/24/2014 1,232,087.50 1.766 1.7911,230,570.21
Federal Home Loan Bank1332 1,500,000.003130A2FH4 06/14/2019 6211.75007/02/2014 1,504,770.00 1.686 1.7101,500,970.07
Federal Home Loan Bank1577 1,500,000.003130A7Q73 12/08/2021 1,5291.53004/08/2016 1,475,220.00 1.450 1.4701,503,585.77
Federal Home Loan Bank1583 Call 1,690,000.003130A7RS6 04/27/2026 3,1302.65004/27/2016 1,655,084.60 2.619 2.6551,689,275.65
Federal Home Loan Bank1587 Call 1,500,000.003130A7TA3 04/28/2023 2,0352.07004/28/2016 1,474,650.00 2.041 2.0701,500,000.00
Federal Home Loan Bank1605 1,000,000.00313382K69 03/12/2021 1,2581.75004/27/2016 998,620.00 1.490 1.5111,007,891.49
Federal Home Loan Bank1619 500,000.003133827D9 02/08/2021 1,2261.75006/02/2016 498,980.00 1.476 1.496504,086.69
Federal Home Loan Bank1620 400,000.003133XDVS7 12/11/2020 1,1675.25006/02/2016 443,028.00 1.461 1.481446,408.89
Federal Home Loan Bank1628 Call 1,500,000.003130A8F99 06/15/2026 3,1792.58006/15/2016 1,459,470.00 2.544 2.5801,500,000.00
Federal Home Loan Bank1632 Call 2,000,000.003130A8J46 06/29/2026 3,1932.52006/29/2016 1,946,062.00 2.485 2.5202,000,000.00
Federal Home Loan Bank1633 Call 1,363,636.273130A8J79 12/27/2024 2,6442.35006/27/2016 1,320,340.82 2.317 2.3501,363,636.27
Federal Home Loan Bank1635 Call 1,500,000.003130A8JG9 06/22/2023 2,0902.07006/22/2016 1,479,555.00 2.041 2.0701,500,000.00
Federal Home Loan Bank1637 Call 909,091.003130A8J79 12/27/2024 2,6442.35006/27/2016 880,227.36 2.317 2.350909,091.00
Federal Home Loan Bank1640 Call 1,500,000.003130A8JX2 06/29/2026 3,1932.54006/29/2016 1,471,920.00 2.505 2.5401,500,000.00
Federal Home Loan Bank1643 Call 1,500,000.003130A8HF3 09/23/2025 2,9142.44006/23/2016 1,464,615.00 2.430 2.4641,497,412.61
Federal Home Loan Bank1644 Call 1,500,000.003130A8HT3 12/29/2025 3,0112.47006/29/2016 1,500,060.00 2.451 2.4851,498,346.77
Federal Home Loan Bank1648 Call 1,500,000.003130A8J46 06/29/2026 3,1932.52006/29/2016 1,459,546.50 2.425 2.4591,500,393.50
Federal Home Loan Bank1649 250,000.003130A0EN6 12/10/2021 1,5312.87506/28/2016 259,435.00 1.232 1.249266,413.84
Federal Home Loan Bank1651 Call 1,500,000.003130A8MQ3 10/12/2022 1,8371.87507/12/2016 1,477,395.00 1.849 1.8751,500,000.00
Federal Home Loan Bank1652 Call 980,000.003130A8F99 06/15/2026 3,1792.58006/29/2016 953,520.40 2.524 2.560981,491.98
Federal Home Loan Bank1661 Call 1,000,000.003130A8SJ3 11/01/2024 2,5882.15008/01/2016 972,160.00 2.120 2.1501,000,000.00
Federal Home Loan Bank1662 Call 1,500,000.003130A8R54 07/28/2023 2,1261.80007/28/2016 1,451,700.00 1.795 1.8201,498,366.09
Federal Home Loan Bank1667 Call 1,500,000.003130A8VP5 08/23/2024 2,5182.00008/23/2016 1,449,690.00 1.972 2.0001,500,000.00
Federal Home Loan Bank1668 Call 1,500,000.003130A8VN0 11/17/2023 2,2381.94008/17/2016 1,446,720.00 1.913 1.9401,500,000.00
Federal Home Loan Bank1690 Call 1,000,000.003130A94L2 09/02/2026 3,2582.12509/15/2016 950,590.00 2.129 2.158997,314.47
Federal Home Loan Bank1695 Call 1,500,000.003130A9N64 10/06/2026 3,2922.15010/06/2016 1,450,095.00 2.120 2.1501,500,000.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 14
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Federal Home Loan Bank1697 Call 1,000,000.003130A9N64 10/06/2026 3,2922.15010/06/2016 966,730.00 2.131 2.161999,098.61
Federal Home Loan Bank1699 500,000.003133827E7 02/06/2023 1,9542.13010/05/2016 500,905.00 1.578 1.600513,418.46
Federal Home Loan Bank1700 Call 1,500,000.003130A9P62 10/13/2026 3,2992.20010/13/2016 1,446,525.00 2.169 2.2001,500,000.00
Federal Home Loan Bank1702 Call 2,000,000.003130A9PT2 10/26/2026 3,3122.23010/26/2016 1,879,940.00 2.199 2.2302,000,000.00
Federal Home Loan Bank1706 Call 310,000.003130A9PT2 10/26/2026 3,3122.23010/26/2016 291,390.70 2.214 2.245309,623.26
Federal Home Loan Bank1707 Call 1,000,000.003130A9RH6 10/20/2026 3,3062.30010/20/2016 965,080.00 2.270 2.302999,818.94
Federal Home Loan Bank1709 Call 1,000,000.003130A9RH6 10/20/2026 3,3062.30010/20/2016 965,080.00 2.271 2.302999,773.68
Federal Home Loan Bank1713 Call 2,000,000.003130A9XC0 11/17/2026 3,3342.36011/17/2016 1,913,160.00 2.327 2.3602,000,000.00
Federal Home Loan Bank1716 Call 1,500,000.003130A9XC0 11/17/2026 3,3342.36011/17/2016 1,434,870.00 2.361 2.3931,495,892.50
Federal Home Loan Bank1717 Call 1,500,000.003130AA2Z0 11/23/2026 3,3402.69011/23/2016 1,470,240.00 2.653 2.6901,500,000.00
Federal Home Loan Bank1718 Call 205,000.003130AA2Z0 11/23/2026 3,3402.69011/23/2016 200,932.80 2.682 2.720204,508.85
Federal Home Loan Bank1719 Call 1,500,000.003130A7C29 02/24/2026 3,0682.75011/16/2016 1,487,565.00 2.712 2.7491,500,000.00
Federal Home Loan Bank1720 Call 1,500,000.003130AAAZ1 12/14/2026 3,3612.90012/14/2016 1,470,645.00 2.860 2.9001,500,000.00
Federal Home Loan Bank1724 Call 800,000.003130AAEX2 12/28/2021 1,5492.15012/28/2016 798,288.00 2.120 2.150800,000.00
Federal Home Loan Bank1727 1,000,000.003130AABG2 11/29/2021 1,5201.87512/16/2016 1,000,820.00 2.168 2.198987,249.78
Federal Home Loan Bank1741 Call 315,000.003130AAAZ1 12/14/2026 3,3612.90001/27/2017 308,835.45 3.008 3.050311,259.25
Federal Home Loan Bank1751 Call 325,000.003130A8HF3 09/23/2025 2,9142.44002/15/2017 317,333.25 2.836 2.875315,057.39
Federal Home Loan Bank1752 Call 250,000.003130A7C29 02/24/2026 3,0682.75002/15/2017 247,927.50 2.958 3.000245,429.21
Federal Home Loan Bank1763 1,910,000.003133XHRJ3 12/10/2021 1,5315.00003/10/2017 2,144,127.80 2.150 2.1802,123,315.77
Federal Home Loan Bank1780 1,000,000.00313378CR0 03/11/2022 1,6222.25004/12/2017 1,013,050.00 1.903 1.9301,013,485.59
Federal Home Loan Bank1823 Call 1,500,000.003130ABJW7 06/27/2024 2,4612.55006/27/2017 1,476,345.00 2.515 2.5501,500,000.00
Federal Home Loan Bank1847 Call 500,000.003130A7TA3 04/28/2023 2,0352.07009/18/2017 491,550.00 2.131 2.161497,615.45
Federal Home Loan Bank1860 Call 500,000.003130AAWE4 03/08/2022 1,6192.22009/28/2017 501,552.08 2.116 2.146501,552.08
Federal Home Loan Bank1861 Call 800,000.003130ABAF3 05/11/2027 3,5093.00009/29/2017 800,000.00 2.958 2.999800,000.00
Federal Home Loan Bank822 3,000,000.003133XUMS9 09/13/2019 7124.50008/12/2009 3,167,760.00 4.437 4.4993,000,000.00
Federal Home Loan Bank940 2,000,000.003133X0PF0 08/15/2018 3185.37502/17/2011 2,069,840.00 3.423 3.4702,029,025.80
Federal Home Loan Bank992 2,000,000.00313371ZX7 12/08/2017 682.62509/13/2011 2,005,320.00 1.526 1.5472,003,806.91
Fed. Home Loan Mortgage Corp.1036 1,500,000.003137EABA6 11/17/2017 475.12503/01/2012 1,507,590.00 1.227 1.2441,507,156.40
Fed. Home Loan Mortgage Corp.1106 1,500,000.003134G3A91 08/22/2019 6901.40008/22/2012 1,495,995.00 1.380 1.4001,500,000.00
Fed. Home Loan Mortgage Corp.1113 1,500,000.003134G3L73 12/26/2019 8161.50009/26/2012 1,497,060.00 1.479 1.5001,500,000.00
Fed. Home Loan Mortgage Corp.1153 1,500,000.003137EADP1 03/07/2018 1570.87502/11/2013 1,497,870.00 0.960 0.9731,499,377.71
Fed. Home Loan Mortgage Corp.1166 1,500,000.003137EADN6 01/12/2018 1030.75003/15/2013 1,498,245.00 0.948 0.9621,499,130.07
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 15
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Fed. Home Loan Mortgage Corp.1273 2,000,000.003134G45T1 12/10/2021 1,5312.00004/10/2014 2,001,160.00 2.564 2.6001,954,642.52
Fed. Home Loan Mortgage Corp.1277 1,000,000.003134G45T1 12/10/2021 1,5312.00004/22/2014 1,000,580.00 2.643 2.680974,366.77
Fed. Home Loan Mortgage Corp.1282 300,000.003134G3A91 08/22/2019 6901.40005/01/2014 299,199.00 1.914 1.941297,092.12
Fed. Home Loan Mortgage Corp.1286 300,000.003134G35V8 03/13/2020 8941.65005/02/2014 299,889.00 2.053 2.082297,021.84
Fed. Home Loan Mortgage Corp.1287 300,000.003134G3U40 11/21/2019 7811.45005/02/2014 299,100.00 1.938 1.965296,879.94
Fed. Home Loan Mortgage Corp.1291 1,000,000.003134G3K58 03/19/2020 9001.50005/06/2014 996,280.00 2.041 2.070986,820.79
Fed. Home Loan Mortgage Corp.1292 1,000,000.003134G44G0 05/22/2020 9641.50005/06/2014 995,420.00 2.091 2.120984,699.21
Fed. Home Loan Mortgage Corp.1301 1,000,000.003134G3L73 12/26/2019 8161.50005/13/2014 998,040.00 1.945 1.972990,051.90
Fed. Home Loan Mortgage Corp.1352 1,000,000.003134G43G1 05/07/2019 5831.20007/25/2014 994,880.00 1.765 1.790990,989.20
Fed. Home Loan Mortgage Corp.1678 Call 1,000,000.003134GAEF7 09/29/2021 1,4591.65009/29/2016 989,120.00 1.627 1.6501,000,000.00
Fed. Home Loan Mortgage Corp.1828 Call 1,500,000.003134GBNX6 05/28/2021 1,3352.00006/28/2017 1,495,665.00 1.969 1.9961,500,000.00
Fed. Home Loan Mortgage Corp.1835 Call 1,500,000.003134GBXU1 07/27/2022 1,7602.25007/27/2017 1,495,065.00 2.219 2.2501,500,000.00
Fed. Home Loan Mortgage Corp.1836 Call 1,000,000.003134GBXU1 07/27/2022 1,7602.25007/27/2017 996,710.00 2.219 2.2501,000,000.00
Fed. Home Loan Mortgage Corp.1837 Call 1,000,000.003134GBXU1 07/27/2022 1,7602.25007/27/2017 996,710.00 2.234 2.265999,276.67
Federal National Mortgage Asso1023 2,590,000.003136FPXN2 11/24/2017 542.30001/25/2012 2,594,403.00 1.406 1.4262,593,186.18
Federal National Mortgage Asso1035 2,000,000.0031398ALG5 01/23/2018 1144.37703/01/2012 2,018,140.00 1.388 1.4082,017,665.60
Federal National Mortgage Asso1048 2,000,000.003136G0AW1 10/16/2020 1,1112.35004/16/2012 2,036,920.00 2.317 2.3502,000,000.00
Federal National Mortgage Asso1059 2,000,000.003136G0DU2 04/30/2020 9422.00004/30/2012 2,012,940.00 1.972 2.0002,000,000.00
Federal National Mortgage Asso1061 1,500,000.003136G0EC1 04/30/2020 9422.05004/30/2012 1,513,770.00 2.021 2.0501,500,000.00
Federal National Mortgage Asso1066 2,000,000.003136G0FJ5 10/30/2020 1,1252.00004/30/2012 2,016,600.00 1.972 2.0002,000,000.00
Federal National Mortgage Asso1118 500,000.003136FPXN2 11/24/2017 542.30010/18/2012 500,850.00 0.927 0.940500,975.20
Federal National Mortgage Asso1149 1,500,000.003135G0TG8 02/08/2018 1300.87501/31/2013 1,498,005.00 1.019 1.0341,499,181.91
Federal National Mortgage Asso1174 1,500,000.003135G0WJ8 05/21/2018 2320.87504/15/2013 1,496,160.00 0.905 0.9171,499,597.88
Federal National Mortgage Asso1190 Call 1,000,000.003135G0XD0 05/21/2018 2321.00005/21/2013 997,150.00 0.996 1.010999,936.11
Federal National Mortgage Asso1191 Call 2,000,000.003135G0XA6 05/21/2018 2321.03005/21/2013 1,996,060.00 1.015 1.0302,000,000.00
Federal National Mortgage Asso1197 1,500,000.003135G0WJ8 05/21/2018 2320.87505/21/2013 1,496,160.00 0.986 1.0001,498,834.28
Federal National Mortgage Asso1210 Call 1,500,000.003135G0XK4 05/25/2018 2361.05005/30/2013 1,497,585.00 1.035 1.0501,500,000.00
Federal National Mortgage Asso1214 Call 1,500,000.003135G0XD0 05/21/2018 2321.00006/07/2013 1,495,725.00 1.262 1.2791,497,408.63
Federal National Mortgage Asso1268 1,500,000.003136FTR43 08/28/2020 1,0622.00004/08/2014 1,513,335.00 2.172 2.2021,491,799.26
Federal National Mortgage Asso1276 1,000,000.003136G0U58 04/30/2021 1,3071.75004/16/2014 999,270.00 2.364 2.397978,787.96
Federal National Mortgage Asso1288 250,000.003136G0M57 04/09/2021 1,2861.75005/02/2014 249,090.00 2.452 2.486244,073.86
Federal National Mortgage Asso1290 1,000,000.003136G0Y70 01/30/2019 4861.08005/05/2014 994,930.00 1.633 1.656992,656.27
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 16
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Federal Agency Issues - Coupon
Federal National Mortgage Asso1315 1,200,000.003136G0YK1 08/28/2019 6961.50006/05/2014 1,198,704.00 1.815 1.8401,192,600.98
Federal National Mortgage Asso1317 1,000,000.003136G02P5 04/29/2019 5751.20006/12/2014 995,280.00 1.765 1.790991,122.53
Federal National Mortgage Asso1546 Call 1,000,000.003136G3AN5 03/16/2021 1,2621.50003/16/2016 996,490.00 1.978 2.0061,000,000.00
Federal National Mortgage Asso1654 1,000,000.003136G0EG2 04/23/2021 1,3002.28006/30/2016 1,014,410.00 1.171 1.1871,037,703.97
Federal National Mortgage Asso1669 Call 1,350,000.003136G3XZ3 07/28/2021 1,3961.50007/28/2016 1,325,187.00 1.505 1.5261,348,709.06
Federal National Mortgage Asso1687 Call 1,050,000.003136G36A8 09/27/2024 2,5532.00009/27/2016 1,014,069.00 1.972 2.0001,050,000.00
Federal National Mortgage Asso1715 500,000.0031364CCC0 04/30/2026 3,1337.12511/10/2016 666,130.00 2.367 2.400680,357.82
Tennessee Valley Authority1132 500,000.00880591EL2 02/15/2021 1,2333.87512/14/2012 533,080.00 1.596 1.618535,503.62
Tennessee Valley Authority1133 1,010,000.00880591EN8 08/15/2022 1,7791.87512/14/2012 1,004,677.30 1.893 1.9201,007,982.13
Tennessee Valley Authority1145 1,500,000.00880591EL2 02/15/2021 1,2333.87501/23/2013 1,599,240.00 1.647 1.6691,603,945.09
Tennessee Valley Authority1170 1,500,000.00880591EC2 04/01/2018 1824.50003/25/2013 1,523,835.00 0.913 0.9261,526,132.59
Tennessee Valley Authority1260 1,160,000.00880591EL2 02/15/2021 1,2333.87503/12/2014 1,236,745.60 2.427 2.4611,210,556.55
Tennessee Valley Authority1508 1,000,000.00880591CJ9 11/01/2025 2,9536.75011/20/2015 1,303,600.00 2.807 2.8461,273,097.93
Tennessee Valley Authority1519 750,000.00880591ER9 09/15/2024 2,5412.87501/15/2016 776,715.00 2.564 2.600762,754.75
Tennessee Valley Authority1589 775,000.00880591CJ9 11/01/2025 2,9536.75004/18/2016 1,010,290.00 2.337 2.3701,019,293.57
Tennessee Valley Authority1703 1,490,000.00880591EN8 08/15/2022 1,7791.87510/07/2016 1,482,147.70 1.538 1.5601,511,758.17
Tennessee Valley Authority1714 1,250,000.00880591CJ9 11/01/2025 2,9536.75011/10/2016 1,629,500.00 2.317 2.3501,648,717.73
Tennessee Valley Authority954 2,000,000.00880591CU4 12/15/2017 756.25005/23/2011 2,020,420.00 2.624 2.6612,013,455.34
Subtotal and Average 340,629,495.97 337,637,185.28 339,297,093.42 2.039 2.067 1,505
Treasury Securities - Coupon
U.S. Treasury1201 TB 2,000,000.00912828UJ7 01/31/2018 1220.87505/16/2013 1,998,060.00 0.779 0.7902,000,553.82
U.S. Treasury1237 TB 2,000,000.00912828SD3 01/31/2019 4871.25001/07/2014 1,995,700.00 1.682 1.7051,988,400.84
U.S. Treasury1284 TB 1,500,000.00912828TH3 07/31/2019 6680.87505/02/2014 1,484,355.00 1.726 1.7501,477,145.46
U.S. Treasury1285 TB 1,500,000.00912828TN0 08/31/2019 6991.00005/02/2014 1,486,815.00 1.755 1.7801,478,732.73
U.S. Treasury1289 TB 1,500,000.00912828SX9 05/31/2019 6071.12505/05/2014 1,492,380.00 1.692 1.7161,485,942.44
U.S. Treasury1299 TB 1,500,000.00912828SX9 05/31/2019 6071.12505/13/2014 1,492,380.00 1.654 1.6771,486,845.83
U.S. Treasury1316 TB 1,500,000.00912828TC4 06/30/2019 6371.00006/10/2014 1,488,570.00 1.687 1.7111,482,247.75
U.S. Treasury1761 TB 1,500,000.00912828J43 02/28/2022 1,6111.75003/09/2017 1,492,620.00 2.071 2.1001,478,114.77
Subtotal and Average 12,877,983.64 13,000,000.00 12,930,880.00 1.599 1.621 649
Municipal Bonds
Acalanes Union High School Dis1494 MUN 1,000,000.00004284B38 08/01/2021 1,4002.38110/30/2015 1,004,320.00 2.120 2.1501,008,276.00
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 17
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Municipal Bonds
Antelope Valley Community Coll1790 MUN 220,000.0003667PFL1 08/01/2022 1,7652.60805/09/2017 221,511.40 2.266 2.298223,065.25
Burlingame School District1548 MUN 730,000.00121457EQ4 08/01/2025 2,8616.23802/24/2016 826,454.90 3.557 3.606856,572.43
Carlsbad Unified School Dist .1547 MUN 300,000.00142665DH8 08/01/2021 1,4004.58402/24/2016 323,562.00 2.130 2.159326,169.07
Carlsbad Unified School Dist .1556 MUN 1,250,000.00142665DH8 08/01/2021 1,4004.58403/04/2016 1,348,175.00 2.138 2.1681,358,524.80
Carlsbad Unified School Dist .1753 MUN 350,000.00142665DH8 08/01/2021 1,4004.58402/17/2017 377,489.00 2.317 2.350378,315.13
Carlsbad Unified School Dist .1857 MUN 305,000.00142665DJ4 08/01/2026 3,2265.23409/27/2017 349,026.75 2.850 2.890360,361.06
Cerritos Community College Dis1523 MUN 500,000.00156792GV9 08/01/2021 1,4002.78101/27/2016 507,610.00 2.012 2.040513,365.27
Fremon Union High School Distr1646 MUN 525,000.00357172VA0 02/01/2026 3,0456.08006/28/2016 625,343.25 2.994 3.035641,311.90
State of Georgia1613 MUN 500,000.00373384RU2 10/01/2022 1,8263.57005/17/2016 529,565.00 1.878 1.904539,138.62
State of Georgia1645 MUN 365,000.00373384W69 02/01/2023 1,9493.25006/27/2016 381,425.00 1.898 1.925389,108.82
State of Georgia1666 MUN 1,825,000.003733844V5 02/01/2025 2,6802.37507/29/2016 1,798,957.25 1.972 1.9991,870,929.92
State of Georgia1691 MUN 385,000.00373384RU2 10/01/2022 1,8263.57009/26/2016 407,765.05 1.630 1.653420,046.91
State of Georgia1775 MUN 250,000.00373384RX6 10/01/2025 2,9224.00004/10/2017 275,060.00 2.739 2.777271,659.00
State of Hawaii1685 MUN 1,045,000.00419792DA1 10/01/2026 3,2873.15010/19/2016 1,049,556.20 2.431 2.4651,101,779.73
State of Hawaii1852 MUN 225,000.00419791YP7 02/01/2022 1,5844.80009/21/2017 247,864.50 2.071 2.100250,023.84
City of Los Angeles1748 MUN 1,000,000.00544351KS7 09/01/2023 2,1612.64002/14/2017 1,008,860.00 2.784 2.8231,001,608.57
State of Maryland1689 MUN 485,000.005741925C0 03/01/2022 1,6124.30009/16/2016 528,868.25 1.534 1.555541,272.37
State of Maryland1762 MUN 1,000,000.00574193NC8 03/15/2022 1,6262.25003/22/2017 1,004,320.00 2.219 2.2501,000,000.00
Mtn. View-Whisman School Dist.1348 MUN 500,000.0062451FFK1 08/01/2021 1,4002.97307/24/2014 510,550.00 2.893 2.933503,860.94
Marin Community College Dist.1858 MUN 500,000.0056781RGU5 08/01/2027 3,5913.27209/28/2017 513,950.00 2.791 2.830518,839.03
Mt. San Antonio Community Coll1489 MUN 1,335,000.00623040GX4 08/01/2023 2,1304.10310/26/2015 1,433,282.70 2.490 2.5251,445,926.32
State of Ohio1550 MUN 1,500,000.00677522HZ0 05/01/2021 1,3081.57003/09/2016 1,466,520.00 1.548 1.5691,500,000.00
State of Ohio1688 MUN 800,000.00677522JB1 05/01/2023 2,0382.11009/13/2016 787,616.00 1.764 1.788813,467.34
State of Ohio1742 MUN 2,000,000.00677522JB1 05/01/2023 2,0382.11001/31/2017 1,969,040.00 2.485 2.5201,957,852.53
State of Ohio1832 MUN 900,000.006775207G7 04/01/2024 2,3744.97106/30/2017 1,029,789.00 2.416 2.4501,035,127.06
State of Oregon1682 MUN 570,000.0068609BGH4 05/01/2022 1,6732.50008/29/2016 576,976.80 1.528 1.550593,664.49
Palo Alto Unified School Dist.1192 MUN 2,000,000.00697379UE3 08/01/2021 1,4002.44105/10/2013 2,020,340.00 2.031 2.0602,026,723.81
Palo Alto Unified School Dist.1193 MUN 1,800,000.00697379UE3 08/01/2021 1,4002.44105/13/2013 1,818,306.00 2.031 2.0601,824,050.63
Palo Alto Unified School Dist.1195 MUN 1,990,000.00697379UE3 08/01/2021 1,4002.44105/15/2013 2,010,238.30 2.051 2.0802,015,176.60
Palo Alto Unified School Dist.1437 MUN 200,000.00697379UE3 08/01/2021 1,4002.44101/27/2015 202,034.00 2.041 2.070202,646.96
Palo Alto Unified School Dist.1610 MUN 1,000,000.00697379UE3 08/01/2021 1,4002.44105/12/2016 1,010,170.00 1.528 1.5501,032,674.93
Palo Alto Unified School Dist.1684 MUN 600,000.00697379UD5 08/01/2020 1,0352.29109/02/2016 606,306.00 1.290 1.308616,236.03
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 18
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Municipal Bonds
City & County of San Francisco1441 MUN 360,000.00797646NL6 06/15/2022 1,7184.95002/09/2015 398,268.00 2.416 2.450398,533.31
City & County of San Francisco1509 MUN 1,000,000.00797646NC6 06/15/2025 2,8145.45011/27/2015 1,176,750.00 3.067 3.1101,154,950.25
City & County of San Francisco1711 MUN 2,105,000.00797646T48 06/15/2025 2,8142.29011/01/2016 2,025,367.85 2.219 2.2492,110,831.75
City & County of San Francisco1712 MUN 245,000.00797646T55 06/15/2026 3,1792.39011/01/2016 234,031.35 2.376 2.410244,616.53
City & County of San Francisco1839 MUN 230,000.00797646T48 06/15/2025 2,8142.29007/14/2017 221,299.10 2.682 2.720223,181.18
San Jose Unified School Dist.1435 MUN 580,000.00798186C83 08/01/2023 2,1302.50001/29/2015 574,130.40 2.663 2.700573,989.56
San Mateo Union High School Dt1516 MUN 245,000.00799017KT4 09/01/2019 7002.19301/08/2016 246,876.70 1.775 1.800246,776.76
San Mateo Union High School Dt1518 MUN 180,000.00799017KV9 09/01/2021 1,4312.72001/19/2016 182,701.80 2.046 2.075184,268.91
State of Tennessee1673 MUN 1,000,000.00880541XY8 08/01/2026 3,2262.11608/25/2016 955,990.00 1.923 1.9501,013,258.89
State of Tennessee1674 MUN 1,650,000.00880541XX0 08/01/2025 2,8612.06608/25/2016 1,589,775.00 1.893 1.9201,667,244.91
State of Tennessee1676 MUN 700,000.00880541XX0 08/01/2025 2,8612.06608/25/2016 674,450.00 1.893 1.920707,316.02
State of Texas1482 MUN 920,000.00882723PP8 10/01/2021 1,4612.58910/14/2015 935,750.40 1.864 1.890944,212.93
State of Texas1586 MUN 1,000,000.00882722KA8 10/01/2023 2,1915.64304/19/2016 1,071,510.00 3.339 3.3851,118,800.00
State of Texas1592 MUN 235,000.00882722JZ5 10/01/2022 1,8265.50304/21/2016 251,546.35 3.047 3.090260,525.86
State of Texas1621 MUN 500,000.00882723A41 10/01/2020 1,0961.77706/07/2016 497,380.00 1.450 1.470504,440.93
State of Texas1625 MUN 485,000.00882722KC4 10/01/2025 2,9225.91306/09/2016 521,927.90 3.831 3.885550,468.75
State of Texas1708 MUN 110,000.00882722VJ7 04/01/2022 1,6433.67310/19/2016 116,202.90 1.825 1.850118,544.88
State of Texas1855 MUN 250,000.00882723EN5 08/01/2025 2,8613.83209/22/2017 261,325.00 2.747 2.785268,279.16
University of California1340 MUN 1,875,000.0091412GSB2 07/01/2019 6381.79607/14/2014 1,875,768.75 2.007 2.0351,867,570.09
University of California1356 MUN 425,000.0091412GGU3 05/15/2020 9573.34807/31/2014 440,504.00 2.281 2.313435,732.68
University of California1368 MUN 250,000.0091412GGT6 05/15/2019 5913.04808/08/2014 255,687.50 1.982 2.010253,993.10
University of California1383 MUN 955,000.0091412GSB2 07/01/2019 6381.79608/27/2014 955,391.55 1.972 2.000951,757.16
University of California1414 MUN 750,000.0091412GSB2 07/01/2019 6381.79611/28/2014 750,307.50 1.923 1.950748,073.41
University of California1420 MUN 1,500,000.0091412GSB2 07/01/2019 6381.79612/12/2014 1,500,615.00 1.943 1.9701,495,646.89
University of California1481 MUN 260,000.0091412GQB4 05/15/2020 9571.99510/08/2015 260,548.60 1.824 1.850260,942.06
State of Utah1622 MUN 750,000.00917542QT2 07/01/2020 1,0043.28906/07/2016 778,192.50 1.430 1.450786,698.98
State of Utah1731 MUN 770,000.00917542QR6 07/01/2024 2,4654.55401/04/2017 844,736.20 2.904 2.944844,559.55
State of Vermont1456 MUN 2,000,000.00924258TT3 08/15/2023 2,1444.25008/06/2015 2,052,540.00 3.275 3.3202,095,097.07
State of Washington1672 MUN 250,000.0093974DHW1 08/01/2022 1,7652.74008/08/2016 256,315.00 1.504 1.524263,978.98
State of Washington1721 MUN 515,000.0093974CPH7 08/01/2022 1,7654.63612/05/2016 570,789.95 2.465 2.500564,281.10
State of Washington1778 MUN 1,500,000.0093974CPG9 08/01/2021 1,4004.58604/12/2017 1,638,030.00 2.081 2.1101,635,371.85
State of Washington1802 MUN 485,000.0093974CRC6 08/01/2024 2,4964.66905/23/2017 548,748.40 2.416 2.450552,035.81
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
September 30, 2017
Par Value
Days To
Maturity
Maturity
Date
Current
RateMarket Value
Fund ALL - Portfolio Listings
Investments by Fund Page 19
CUSIP Investment #Issuer
Purchase
Date Book Value YTM
360
YTM
365
Municipal Bonds
West Valley-Mission Community1479 MUN 250,000.0095640HBT4 08/01/2024 2,4966.09010/01/2015 269,202.50 4.030 4.086278,469.86
Subtotal and Average 54,462,224.53 52,285,000.00 53,703,512.55 2.251 2.283 1,889
Total Investments and Average 497,285,101.14 491,941,294.94 495,204,398.82 1.973 2.001 1,411
Portfolio CPA
AP
Run Date: 10/30/2017 - 13:46 FI (PRF_FI) 7.1.1
Report Ver. 7.3.3a
1 General Investment Guidelines:
a) The max. stated final maturity of individual securities in the portfolio should be 10 years.Full Compliance
b) A max. of 30 percent of the par value of the portfolio shall be invested in securities with maturities
beyond 5 years. (See staff report for explanation of actual percentage limit overage)30.50%
c) The City shall maintain a minimum of one month's cash needs in short term investments.Full Compliance
d) At least $50 million shall be maintained in securities maturing in less than 2 years.
Plus two managed pool accounts which provide instant liquidity:
- Local Agency Investment Fund (LAIF) - maximum investment limit is $65 million $18.2 million
- Fidelity Investments
e) Should market value of the portfolio fall below 95 percent of the book value, report this fact within a
reasonable time to the City Council and evaluate if there are risk of holding securities to maturity.99.58%
d) Commitments to purchase securities newly introduced on the market shall be made no more than three (3)
working days before pricing.Full Compliance
f) Whenever possible, the City will obtain three or more quotations on the purchase or sale of
comparable securities (excludes new issues, LAIF, City of Palo Alto bonds, money market
accounts, and mutual funds).Full Compliance
2 U.S. Government Securities:Full Compliance
a) There is no limit on purchase of these securities.
b) Securities will not exceed 10 years maturity.
3 U.S. Government Agency Securities:Full Compliance
a) There is no limit on purchase of these securities except for:
Callable and Multi-step-up securities provided that:
- The potential call dates are known at the time of purchase;Full Compliance
- the interest rates at which they "step-up" are known at the time of purchase; and Full Compliance
- the entire face value of the security is redeemed at the call date.Full Compliance
- No more than 25 percent of the par value of portfolio.23.81%
b) Securities will not exceed 10 years maturity.
4 Bonds of the State of California Local Government Agencies Full Compliance
a)Having at time of investment a minimum Double A (AA/AA2) rating as provided by a nationally 10.63%
recognized rating service (e.g., Moody’s and/or Standard and Poor’s).
b)May not exceed 20 percent of the par value of the portfolio.
5 Certificates of Deposit:Full Compliance
a) May not exceed 20 percent of the par value of the portfolio;
b) No more than 10 percent of the par value of the portfolio in collateralized CDs in any institution.
c) Purchase collateralized deposits only from federally insured large banks that are rated by
a nationally recognized rating agency (e.g. Moody's, Standard & Poor's, etc.).
d) For non-rated banks, deposit should be limited to amounts federally insured (FDIC)
e) Rollovers are not permitted without specific instruction from authorized City staff.
6 Banker's Acceptance Notes:None Held
a) No more than 30 percent of the par value of the portfolio.
b) Not to exceed 180 days maturity.
c) No more than $5 million with any one institution.
$145.7 million
$3.8 million
2.64%
Attachment C
Investment Policy Compliance
As of September 30, 2017
Investment Policy Requirements
Compliance
Check
Attachment C
Investment Policy Compliance
As of September 30, 2017
Investment Policy Requirements
Compliance
Check
7 Commercial Paper:None Held
a) No more than 15 percent of the par value of the portfolio.
b) Having highest letter or numerical rating from a nationally recognized rating service.
c) Not to exceed 270 days maturity.
d) No more than $3 million or 10 percent of the outstanding commercial paper of any one institution,
whichever is lesser.
8 Short-Term Repurchase Agreement (REPO):None Held
a) Not to exceed 1 year.
b) Market value of securities that underlay a repurchase agreement shall be valued at 102 percent or
greater of the funds borrowed against those securities.
9 Money Market Deposit Accounts Full Compliance
a) Liquid bank accounts which seek to maintain a net asset value of $1.00.
10 Mutual Funds:None Held
a) No more than 20 percent of the par value of the portfolio.
b) No more than 10 percent of the par value with any one institution.
11 Negotiable Certificates of Deposit (NCD):Full Compliance
a) No more than 10 percent of the par value of the portfolio.9.84%
b) No more than $5 million in any one institution.FDIC Insured
12 Medium-Term Corporate Notes:Full Compliance
a) No more than 10 percent of the par value of the portfolio.3.76%
b) Not to exceed 5 years maturity.
c) Securities eligible for investment shall have a minimum rating of AA from a nationally recognized
rating service.
d) No more than $5 million of the par value may be invested in securities of any single issuer, other
than the U.S. Government, its agencies and instrumentality.
e) If securities owned by the City are downgraded by either rating agencies to a level below AA it
shall be the City's policy to review the credit situation and make a determination as to whether
to sell or retain such securities.
13 Prohibited Investments:
a) Reverse Repurchase Agreements
b) Derivatives as defined in Appendix B of the Investment Policy
14 All securities shall be delivered to the City's safekeeping custodian, and held in the name of the
City, with the exception of :
- Certificates of Deposit, Mutual Funds, and LAIF
Full Compliance
None Held
Full Compliance