HomeMy WebLinkAboutStaff Report 2510-5338CITY OF PALO ALTO
CITY COUNCIL
Monday, November 03, 2025
Council Chambers & Hybrid
4:30 PM
Agenda Item
2.Approval of three reports: the City of Palo Alto Community Wildfire Protection Plan, the
Emergency Preparedness: Wildfire Audit Report by the City Auditor (as recommended by
the Policy and Services Committee), and Adopt a Resolution Approving the City of Palo
Alto Emergency Operations Plan. CEQA status: not a Project Presentation
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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Office of Emergency Services
Meeting Date: November 3, 2025
Report #:2510-5338
TITLE
Approval of three reports: the City of Palo Alto Community Wildfire Protection Plan, the
Emergency Preparedness: Wildfire Audit Report by the City Auditor (as recommended by the
Policy and Services Committee), and Adopt a Resolution Approving the City of Palo Alto
Emergency Operations Plan. CEQA status: not a Project
RECOMMENDATION
Staff recommend that the City Council
1. Adopt a resolution approving the City of Palo Alto Emergency Operations Plan (EOP),
2. Approve the City of Palo Alto Community Wildfire Protection Plan (CWPP) and authorize
submittal to the County of Santa Clara, and
3. Approve the Emergency Preparedness: Wildfire Audit Report by the City Auditor (as
recommended by the Policy & Services Committee).
EXECUTIVE SUMMARY
This report is the culmination of a series of sessions for the public, the Council, and multi-
agency planning activities regarding wildfires and emergency preparedness topics. Palo Alto is
not unique in facing wildfire risks due to climate change, prolonged drought, and human
activity in the wildland-urban interface (WUI), and conducts planning, mitigation, and other
activities in accordance with best management practices and as part of larger, regional efforts,
as described below.
The revised Emergency Operations Plan (EOP) and Community Wildfire Protection Plan are
included in this report for Council approval.
The Office of Emergency Services (OES) is dedicated to safeguarding the residents,
businesses, and visitors of Palo Alto through comprehensive and effective emergency
management. The Emergency Operations Plan (EOP) is a foundational tool in this effort,
providing the City with a structured approach to respond to a variety of potential
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hazards, including natural disasters, technological incidents, and human-caused
emergencies. The last EOP was adopted in 2016.
The CWPP provides one wildfire management plan for the community that combines
the historic Foothills Fire Management Plan (FFMP) first established in 1982 and the
Santa Clara County Fire Department developed multi-jurisdictional Community Wildfire
Protection Plan (CWPP) that establishes strategic goals for these more detailed
community level fire-planning efforts.
The April 8, 2025 meeting of the Policy & Services Committee, a recommendation was
made to have the Council approve the audit findings on wildfire preparedness
completed by BakerTilly, the City’s Auditor.
The Approval of the audit was pulled from the Consent Calendar on June 16, 2025; staff has
bundled these topics and work efforts to enable a more comprehensive view of emergency
preparations with a focus on wildfire preparedness.
BACKGROUND
The topics of emergency planning and wildfire preparedness, specifically, have been a
longstanding priority for the City and there has been a concerted effort to review these plans
and update. This item is part of a series of items on the topic of wildfire preparedness.1 The
calendar below provides a summary of engagements and Council / Commission actions
discussing fire services, wildfire activities, emergency services planning, and utilities activities.
March, California Fire Marshal updated wildfire risk maps for public comment (released on
City webpage 3/26)
Finance Committee reviewed Fire Department Staffing Options on April 12, continuing
discussion from November 2024 exploring changes to enhance fire and ambulance service
delivery.
Policy & Services review of Emergency Preparedness - Wildfire Audit on April 83.
June, City Council adopted additional fire staffing and capital funding to advance additional
wildfire fuel reduction in the City’s Open Space Preserves as part of the FY 2026 Budget.
City Council received the finished updated Community Wildfire Protection Plan /
Foothills Fire Management Plan Update 2025 as an Informational Item in June 20254.
1 News Story: Wildfire Preparedness Public Discussion, April 28, 2025, https://www.paloalto.gov/News-
Articles/City-Manager/Palo-Alto-Begins-Wildfire-Preparedness-Public-Discussions
2 Finance Committee, April 1, 2025, Agenda Item #3,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=7399&meetingTemplateType=2&comp
iledMeetingDocumentId=13598
3 Policy & Services Committee Meeting 4/8/2025 Staff Report #2410-3635:
https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=52961
4 City Council, June 9, 2025, Information item,
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=c1aa0e08-9818-47b4-9085-
ebc4ceb1eb17
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The CWPP is posted here:
https://cityofpaloalto.primegov.com/viewer/preview?id=7981&type=2
June, City Council held annual hearing on properties assessed for Weed Abatement
work.
The Utilities Advisory Commission reviewed and approved the utilities Wildfire Mitigation
Plan at its June 4, 2025 meeting9.
City Council adopted the ordinance approving the newly revised Fire Hazard Severity Zone
map designations released by the State on August 11, 202510.
On August 18, 2025, Council approved11 a five-year contract with the Santa Clara County
Fire Safe Council (FSC) for fuel reduction addressing Audit Recommendation #4.
The City maintains various wildfire protection plans and strategies and takes a regional
approach to planning efforts. Coordination and alignment with County and State agencies is
key to ensuring responsible agencies can work together in an emergency. Mutual aid
agreements with neighboring jurisdictions to enhance firefighting capabilities during large-scale
incidents are critical to incident response as no single agency has the resources to respond to a
wildfire incident independently. Below is a list of the City’s primary emergency plans relevant to
wildfires:
Emergency Operations Plan Basic Plan (EOP)
Wildland Urban Interface (WUI) Fire Response Annex
Local Hazard Mitigation Plan (LHMP)
Foothills Fire Management Plan (FFMP) / Santa Clara County Community Wildfire
Protection Plan (CWPP)
City of Palo Alto Utilities (CPAU) Wildfire Mitigation Plan
Emergency Operations Plan:
The Emergency Operations Plan (EOP) ”Basic Plan” is the primary emergency planning
document and does not including the various annexes and subplans such as the Community
Wildfire Protection Plan. The EOP is an essential guidance document for City staff, key partners,
and the community. The City’s Office of Emergency Services (OES) is responsible for the review,
revision, management, and distribution of the EOP. In accordance with Municipal Code Section
2.12.080, the EOP basic plan requires 1) review by the Emergency Services Council (ESC) and
Palo Alto/Stanford Citizen Corps Council (CCC) and 2) adoption by the City Council.
9 Utilities Advisory Commission Meeting 6/4/2025 Staff Report #2501-4077:
https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=61768
10 City Council, August 11, 2025,
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=736fe7fa-b476-4738-a03a-e2efa564facb
11 City Council, August 18, 2025, https://cityofpaloalto.primegov.com/portal/item/?meetingItemId=b05aa9e6-
5dab-4cf9-9b12-dd73292fda3a
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Under the California Government Code 8610, local jurisdictions with an accredited disaster
council are required to develop and maintain an EOP to facilitate coordinated and effective
emergency response. The EOP incorporates organizational structures, policies, and procedures
for delivering emergency services, as well as the legal authorities and references that govern
emergency management in Palo Alto. Palo Alto has had an accredited disaster council since
1947 and as such has maintained a Council-adopted EOP since that time.
The Office of Emergency Services is responsible for reviewing emergency plans to ensure
adherence to the law and to guidance such as the FEMA Comprehensive Preparedness Guide
(CPG) 101. On October 7, 2024, the revision to the Local Hazard Mitigation Plan was adopted by
City Council.15 The LHMP identifies and prioritizes potential and existing hazards across
jurisdictional borders and identifies mitigation projects to reduce the impacts on Palo Alto to
our hazards. See www.paloalto.gov/lhmp. Generally, it is advisable to update EOPs after each
LHMP revision cycle, since hazard identification is a required step in the EOC update process.
Community Wildfire Protection Plan (inclusive of the former Foothills Fire Management Plan):
The City developed a Foothills Fire Management Plan (FFMP) in 1982 that provides the planning
framework for fire control activities for the City and the Palo Alto Foothills Area which
comprises the predominant wildland urban interface (WUI) area for the community. This plan
addresses a broad range of integrated activities and planning documents to address and
mitigate the impacts of fire hazards in the area west of Foothills Expressway to the City limits of
Palo Alto. The City has updated this plan three times: in 1997, 2009, and 2017. City of Palo
Alto Staff Report #8030 (10/16/2017) includes an overview of this process.16
Also in 2017, the Santa Clara County Fire Department developed a multi-jurisdictional
Community Wildfire Protection Plan (CWPP) to establish strategic goals for these more detailed
community level fire-planning efforts. This included a Palo Alto jurisdictional annex that
accompanied this plan, but apart from the FFMP.
During the County’s substantive 2023 CWPP update process, the City made the decision to
integrate the FFMP with the CWPP to provide one wildfire management plan for the
community which addresses the long-standing history of the FFMP while meeting the best
management practices of the CWPP format.
Emergency Preparedness - Wildfire Audit:
Baker Tilly, in its capacity serving as the Office of the City Auditor (OCA), performed a citywide
risk assessment that assessed a wide range of risk areas, including strategic, financial,
operational, compliance, technological, and reputation risks. The purpose of the assessment
15 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=14437
16 https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=77526
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was to identify and prioritize risks to develop the annual audit plan. Recognizing the need for
an independent assessment of the City's wildfire preparedness, BakerTilly conducted an audit in
alignment with its 2024 Risk Assessment and subsequent Council approved workplan.
ANALYSIS
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A summary of these reports are discussed below. As noted in the prior section, emergency
planning and preparedness for wildfires is included in over six planning documents, two of
which are recommended for approval in this report.
Emergency Operations Plan (EOP) Attachment A & B
Departmental Roles and Responsibilities – Clear definitions of the duties and
responsibilities of various city departments and personnel during emergencies
activations.
Public Alert and Warning Systems – Enhanced protocols for communicating with the
public and neighboring jurisdictions during a crisis.
Emergency Management Phases – Detailed descriptions of the phases of emergency
management: mitigation, preparedness, response, and recovery.
Emergency Declarations – Procedures for declaring states of emergency, including
the associated legal and operational implications.
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federal emergency management standards: e.g., National Incident Management System
(NIMS), Standardized Emergency Management System (SEMS), the Incident Command
System (ICS), etc. City staff will initiate an update process for related internal plans,
procedures, and other documents to align with this new EOP. This effort will also coincide
with the transition from the current Emergency Operations Center in the Palo Alto Civic
Center to the new Public Safety Building (PSB).
Foothills Fire Management Plan / Community Wildfire Protection Plan (CWPP) (linked here:
https://cityofpaloalto.primegov.com/viewer/preview?id=7981&type=2)
Describes the planning environment
Discusses actions taken since the previous update
Provides an updated wildfire risk hazard assessment
Recommends new fuel treatment actions
Includes public education and outreach efforts
Lists wildfire mitigation projects the City will endeavor to complete
Identifies vegetation treatment standards and methods
19.
Emergency Preparedness – Wildfire Audit (Attachment C)
19 Santa Clara County CWPP, https://www.sccfd.org/santa-clara-county-community-wildfire-protection-plan/
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procedures as well as FEMA and CAL FIRE standards and best practices to complete this audit
work. The BakerTilly Audit Report highlights two findings:
FISCAL/RESOURCE IMPACT
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STAKEHOLDER ENGAGEMENT
Emergency Operations Plan: The Emergency Operations Plan (EOP) was reviewed during the
February 6, 2025, Internal Stakeholder meeting, where representatives from all City
departments reviewed the draft and provided feedback regarding edits and general questions.
The primary outcome of this meeting was to ensure that departmental roles and
responsibilities were clearly defined and accurately reflected for use in an emergency scenario.
Foothills Fire Management Plan / Community Wildfire Protection Plan (CWPP): The City
hosted a public presentation on the CWPP/FFMP on 25 June 2024 as part of the City’s annual
Wildfire Preparedness Community Meeting in which participants received an update on this
plan and an opportunity to ask questions about it.
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ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by CEQA because reviewing and
approving audit findings and emergency response plans are an organizational or administrative
activity of government that will not result in direct or indirect physical changes in the
environment. CEQA Guidelines section 15378(b)(5).
ATTACHMENTS
Attachment A: Resolution Adopting the Emergency Operations Plan
Attachment B: City of Palo Alto Emergency Operations Plan
Attachment C: Emergency Preparedness – Wildfire Audit Report
Foothills Fire Management Plan / Community Wildfire Protection Plan (CWPP) linked here:
https://cityofpaloalto.primegov.com/viewer/preview?id=7981&type=2)
APPROVED BY:
Kenneth Dueker, OES Chief & Kiely Nose, Assistant City Manager
NOT YET APPROVED Attachment A
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027060225
Resolution No.
Resolution of the Council of the City of Palo Alto Adopting the City of Palo
Alto 2025 Emergency Operations Plan (EOP)
R E C I T A L S
A. The City of Palo Alto has developed an updated Emergency Operations Plan
(EOP) in order to help coordinate resources to make our community safer and better prepared
to deal with all hazards.
B. The Palo Alto/Stanford Citizen Corps Council is part of the Emergency Services
Council as provided by Palo Alto Municipal Code section 2.12.030(a)(5), stating that
members include "[s]uch representatives of civic, business, labor, veterans, professional or
other organizations having an official emergency responsibility, as may be appointed by the
[City Manager] with the advice and consent of the city council."
C. Per Palo Alto Municipal Code section 2.12.080, the Citizen Corps Council and the
Emergency Services Council recommend that the City Council adopt the new 2025 EOP.
The City Council of the City of Palo Alto hereby RESOLVES as follows:
SECTION 1. The City Council hereby adopts the 2025 Emergency Operations Plan
(EOP), attached hereto and incorporated by reference.
SECTION 2. The City Council hereby consents to the updated Palo Alto/Stanford
Citizen Corps Council (CCC) membership list.
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NOT YET APPROVED Attachment A
2
027060225
SECTION 3. The Council finds that this is not a project under the California
Environmental Quality Act and, therefore, no environmental impact assessment is necessary.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
City Attorney or designee City Manager
Director of Emergency Services
Director of Administrative Services
City of Palo Alto
Emergency Operations Plan
EMERGENCY OPERATIONS PLAN
City of Palo Alto Emergency Operations Plan
EMERGENCY OPERATIONS PLAN
March 2025
City of Palo Alto
Office of Emergency Services
275 Forest Avenue | Palo Alto, CA 94301
www.cityofpaloalto.org/oes
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EXECUTIVE SUMMARY ........................................................................................................................................... II
AUTHORITY, APPROVAL, IMPLEMENTATION & DISTRIBUTION ............................................................................. III
EOP ADOPTION RESOLUTION ................................................................................................................................ IV
RECORD OF CHANGES ........................................................................................................................................... VI
RECORD OF DISTRIBUTION .................................................................................................................................. VII
DEPARTMENT ROLES AND RESPONSIBILITIES ......................................................................................................... 1
1.0 REFERENCES ..................................................................................................................................................... 9
BASIC PLAN .......................................................................................................................................................... 10
2.0 INTRODUCTION ....................................................................................................................................... 10
3.0 CONCEPT OF OPERATIONS ...................................................................................................................... 13
4.0 EMERGENCY MANAGEMENT ORGANIZATION ......................................................................................... 18
5.0 WHOLE COMMUNITY APPROACH .................................................................................................................. 20
6.0 EMERGENCY MANAGEMENT PHASES ............................................................................................................. 23
7.0 EMERGENCY OPERATIONS CENTER ......................................................................................................... 29
8.0 EMERGENCY DECLARATIONS ................................................................................................................... 34
9.0 PUBLIC INFORMATION ............................................................................................................................ 35
10.0 CONTINUITY OF GOVERNMENT .................................................................................................................... 37
11.0 PLAN DEVELOPMENT AND MAINTENANCE .................................................................................................. 39
GLOSSARY AND ABBREVIATIONS ......................................................................................................................... 40
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E XECUTIVE S UMMARY
The Emergency Operations Plan (EOP) outlines how the City of Palo Alto—its government, stakeholder
agencies, community groups, business community, and residents—coordinate its response to major
emergencies and disasters. This plan is regularly reviewed and updated by staff and approved by the City
Council.
The EOP identifies operational strategies and plans for managing inherently complex and potentially
catastrophic events. City assets, resources, and departments are potentially vulnerable and may become
overwhelmed. A primary goal of the EOP is to promote flexibility whenever possible based on good
judgment and common sense. This document facilitates emergency response and short-term recovery
functions for emergencies and disasters that are outside of the expected capabilities of normal City
operations.
Palo Alto has officially adopted and integrated the following emergency management, response, and
coordination systems:
• Incident Command System (ICS)
• Standardized Emergency Management System (SEMS)
• National Incident Management System (NIMS)
• National Response Framework (NRF)
This EOP addresses the following phases of emergency management:
• Preparedness
• Response
• Recovery
• Mitigation
The City has adopted a “whole community” approach that actively promotes the inclusion and integration
of community partners, neighbors, residents, people with disabilities and access and functional needs,
people with language or cultural differences, and other stakeholders in all phases of emergency
management planning. Through such collaboration, the City will be better prepared to meet the needs of
its residents and daytime populace alike.
The City’s Emergency Operations Center (EOC) provides a centralized location where emergency
management coordination and decision-making can be supported during a critical incident, major
emergency, disaster, or significant event. When activated, the EOC provides support for critical tasks
related to communications, coordination, resource management, and executive leadership.
If Palo Alto determines that the effects of an emergency are beyond the capability of local resources or
may become so, then a local emergency can be proclaimed. There are specific circumstances where the
City of Palo Alto can proclaim an emergency even if not beyond capabilities, for example during COVID-
19 and severe storms the City proclaimed an emergency. A local proclamation of emergency allows the
City Manager and staff to take measures necessary to protect and preserve public health and safety and
support requests for county, state, and federal assistance. A proclamation also provides City staff with
additional powers and authorities to increase the speed and effectiveness of City response activities.
City of Palo Alto
Emergency Operations Plan
iii
The Palo Alto EOP provides an all-hazard approach to enable Palo Alto EOC staff and City employees
managing emergency incidents and planned events. This plan is divided into three sections:
Basic Plan -- presents the planning assumptions, policies, and concept of operations that guide the
responsibilities for emergency preparedness, response, recovery, and mitigation for Palo Alto.
Annexes – Hazard specific and functional applications of the EOP
A UTHORITY , A PPROVAL , IMPLEMENTATION & D ISTRIBUTION
This Emergency Operations Plan is sanctioned under the authority of the Palo Alto Municipal Code (Palo
Alto Municipal Code, 2024) and issued under the authority of the City Manager acting as the statutory
Director of Emergency Services. This plan applies to the operations and management of the City of Palo
Alto and its respective departments and agencies.
This document shall be the official all-hazards Emergency Operations Plan for the City of Palo Alto and
shall supersede all previous plans for this purpose. Nothing in this plan shall be construed in a manner
that limits good judgment and common sense in matters not foreseen.
This plan is approved by the City Manager for the City of Palo Alto and adopted by the City Council. The
delegation of authority for specific modifications that may be made to the plan without the senior official’s
signature is the Office of Emergency Services Chief. Copies of the plan will be subsequently distributed
electronically to each City Department, the EOC, and EOC section chiefs.
City of Palo Alto
____________________________________________________________________________
Ed Shikada, City Manager Date
iv
EOP A DOPTION R ESOLUTION
City of Palo Alto
Emergency Operations Plan
v
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RECORD OF C HANGES
PLAN CHANGES / UPDATES
Date Change Updated by Department
With the input from key stakeholders, City of Palo Alto’s Office of Emergency Services is responsible
for maintaining, reviewing, and updating this Emergency Operations Plan. Collaborative plan
revisions and updates are essential to ensure accuracy and validity of the EOP, therefore any plan
changes and updates will be captured in the table below.
City of Palo Alto
Emergency Operations Plan
vii
R ECORD OF D ISTRIBUTION
The City of Palo Alto’s EOP is posted online with the City’s Office of Emergency Services maintaining the
primary copy.
DISTRIBUTION LIST
Name Department / Agency Date of Delivery Number of
Copies
Disclosure Exemptions
While sections of this document may be available for public review, other portions may contain sensitive
information relevant to the emergency response operation of the City of Palo Alto. Portions that include
information with significant implications on City, county, state and /or national security or are otherwise
exempt from public disclosure are placed in attachments in accordance with the provisions of the
California Public Records Act § 7920 et seq.
Adherence to the Plan (EOP)
Information provided in this plan is guidance and not policy. Decisions and directions about the most
appropriate approach and course of action for response and recovery may be influenced by numerous
factors and will be determined based on the best information available at the time.
1
DEPARTMENT ROLES AND RESPONSIBILITIES
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
City Council • ESF 5
Management
State ESF 5
• Empower City Manager in their role as
Director of Emergency Services
• Through the City Manager, provide policy-
level guidance, direction, and decisions
related to the incident(s)
• Liaison with County Board of Supervisors
• Reinforce public information and community
engagement efforts as needed
• Convene or represent the City at public
meetings as needed
• Review potential or threatened litigation as
needed
• Review and approve proclamation of local
emergency
• Review requirements for special legislation
and development of policy
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
The City of Palo Alto’s departments may be called upon for the departments’ capabilities and resources to respond to and recover from an
emergency or disaster. The lead and support roles are outlined in the table below. It is important to note that lead and support roles will vary
depending on the emergency or disaster. For example, the lead agency for wildfire response is the Palo Alto Fire Department while the
Community Services Department may play a support role in firefighting by utilizing the Community Services Open Space Rangers. There are
corresponding City annexes and plans that each department can refer to before and during an emergency to familiarize themselves with
emergency functions. Additional information on roles and responsibilities, EOC activation authorities, and procedures can be found in the Palo
Alto EOC Manual.
The Emergency Support Functions listed in the following table are aligned with the State of California Governor’s Office of Emergency Services
Emergency Support Functions (ESFs). For more information on CAL OES ESFs, please visit CAL OES Emergency Support Functions.
2
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
City Attorney and City
Clerk
• ESF 5
Management
State ESF 5
• Assess City operations and provide legal
counsel as needed
• Review potential or threatened litigation as
needed
• Facilitate and administer proclamations of
local emergencies
• Oversee and ensure preservation of Vital City
documents and records
• Facilitate public meetings as needed
• Institute Emergency Stand-By Council when
necessary
• Assist the City Manager as liaison to City
Council
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Policies, Emergency
Plans (DEPs) and other related
procedures
City Manager
• ESF 15 Public
Information
State ESF 15
• Director of Emergency Services
(City Manager or designee)
• Establish EOC operational priorities
• Authorize proclamations of local
emergencies
• Approve public information release
• Guide public warnings and alerts
• Primary liaison to City Council
• Develop and maintain communication with
other government bodies
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Recovery Annex (TBP)
• Emergency Public Information and
Warning Annex (TBP)
City of Palo Alto
Emergency Operations Plan
3
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Office of Emergency Services
• ESF 1-18
State ESF
Functions 1-13,
15-18
Federal ESF 14
• Manage emergency management
program and operations including
managing and facilitating the City’s
EOC
• Coordinate incident management and
response efforts
• Develop plans, procedures, and
agreements to assist incident response
• Conduct EOC action planning
• Lead Emergency Management Mutual
Aid
• All
Planning and Development
Services Department
• ESF 3
Construction and
Engineering
State ESF 3
• Staff the Plans Section during EOC
Activations
• Building Inspection and Code
Enforcement
• Building Damage Assessment
• Emergency Repair Permitting
• Employ GIS and Analytics within
capabilities
• Community Planning support during
recovery phase
• Establish Local Assistance Center when
directed
• Damage Assessment Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Recovery Annex (TBP)
Administrative Services
Department/Finance
Department
• ESF 7 Resources
State ESF 7
• ESF 14 Recovery
Federal ESF 14
• Staff the Finance and Administration
Section during EOC activations
• Finance & Revenue Services
• Provide emergency procurement
assistance
• Anticipate and track financial resources
• Damage Assessment Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
4
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Administrative Services
Department/Finance
Department
for staff, mutual aid requests,
volunteers
• Develop financial mechanisms,
procurement applications and
contracts to facilitate procurement
• Oversee staff timekeeping
• Oversee compensations and claims
• Provide fiscal oversight and tracking of
expenses
• Oversee coordination for Public
Assistance efforts with FEMA.
Procedures
• Recovery Annex
• Multi Agency Coordination
(MAC) Plan
Fire Department
• ESF 4 Fire and
Rescue
State ESF 4
• ESF 10 Hazardous
Materials
• State ESF 10
• Staff the Operations Section During
EOC Activations
• May augment the Plans Section during
EOC activations
• Orchestrate all firefighting and fire
rescue operations
• Direct EMS operations
• Coordinate for Fire and EMS mutual aid
resources
• Conduct hazardous material response
operations
• Enhance emergency public warning
and alerts when necessary
• Aid in evacuation and re-entry
operations
• Enhance damage assessment efforts
• Provide incident planning and
management support as needed
• Lead Fire Mutual Aid
• Damage Assessment Annex
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
• Multi Agency Coordination
(MAC) Plan
• Emergency Public Information
and Warning Annex (TBP)
• Airport Emergency Plan
• Evacuation Annex
(Draft in production)
• Continuity of Operations
Plan/Continuity of
Governance
• Department Emergency Plans
(DEPs) and other related
procedures
City of Palo Alto
Emergency Operations Plan
5
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Human Resources
• ESF 8 Public Health
and Medical
Federal ESF 8
• Staff the Finance and Administration
Section during EOC activations
• Manage City Disaster Service Workers
• Manage Human Resources related
matters
• Provide risk management and
employee safety oversight.
• Assess employee needs) Screen and
track spontaneous volunteers
• Compensation and Claims
procedures
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
Information Technology
Department
• ESF 2
Communications
State ESF 2
• ESF 18 Cybersecurity
State ESF 8
• Staff the Logistics Section during EOC
activations
• Protect, restore, and sustain cyber and
information technology resources
• Oversee and manage
telecommunication infrastructure
• Provide additional technology support
as needed
• Communications Annex (TBP)
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Cybersecurity Annex
(Draft in production)
Community Services
Department
• ESF 6 Care and
Shelter
State ESF 6
• Staff and assist the Operations Section
during EOC Activations
• Manage emergency care and shelter
operations
• Support infrastructure restoration
• Assist in debris clearance from public
rights of way
• Facilitate evacuation and re-entry
operations
• Mass Care and Shelter Annex
• Damage Assessment Annex
• Recovery Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
6
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Police Department
• ESF 2
Communications
State ESF 2
• ESF 13 Law
Enforcement
• State ESF 13
• Staff the Operations Section During
EOC Operations
• Conduct law enforcement operations
• Enhance emergency public warning and
alerts
• Facilitate evacuation and re-entry
operations
• Provide access and control to affected
areas
• Provide facility and resource security
• Enforce curfew as directed
• Provide public safety and security
assistance
• Provide traffic control
• Oversee Law Enforcement Mutual Aid
• Communications Annex (TBP)
• Evacuation Annex
(Draft in production)
• Emergency Public Information
and Warning (TBP)
• Mass Care and Shelter Annex
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
Animal Control Division
• ESF 6 Care and
Shelter
• State ESF 6
• ESF 11 Food and
Agriculture
• State ESF 11
• Assess the status of animal care needs
• Determine status of available shelters
for animal care populations (pets, large
animals, livestock)
• Determine need of veterinary services
• Provide animal support services
• Mass Care and Shelter Annex
• Department Emergency Plans
(DEPs) and other related
procedures
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
Library
• ESF 6 Care and
Shelter
State Level ESF 6
• ESF 15 Public
Information
• State ESF 15
• Enhance community care and shelter
efforts with library facility and
personnel resources
• Establish community call center when
directed and in partnership with IT and
CMO
• Department Emergency Plans
(DEP) and other related
procedures
City of Palo Alto
Emergency Operations Plan
7
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Public Works
• ESF 1 Transportation
State ESF 1
• ESF 3 Construction
and Engineering
State ESF 3
• Staff the Operations Section during
EOC Activations
• Conduct infrastructure protection,
emergency repair, and restoration
• Communicate movement
operation/restrictions (traffic and
access)
• Conduct debris clearance and manage
debris operations
• Conduct flood fight operations
• Provide engineering services
• Coordinate with state agencies on
state-controlled highways and roads
• Manage city facilities
• Maintain, repair, and restore
wastewater collection infrastructure
• Assist in damage assessment efforts
• Assist in evacuation and re-entry
operations
• maintain, repair, and operate Regional
Water Quality Control Plant
• Manage and respond to issues
affecting storm water system
• Maintain backup generators
• Oversee Public Works Mutual
Assistance
• Local Energy Assurance Plan
• Damage Assessment Annex
• Evacuation Annex
(Draft in production)
• Emergency Public Information and
Warning
• Airport Emergency Plan
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
8
AGENCY/DEPARTMENT ROLES RESPONSIBILITIES PA Corresponding Annex/Plan
Utilities
• ESF 3 Construction
and Engineering
State Level ESF 3
• ESF 12 Utilities
• Assist the Operations Section during EOC
Activations
• Conduct utilities infrastructure protection,
emergency repair, and restoration
• Enhance public warnings and alerts
• Provide utilities engineering services
• Maintain, repair, and restore electric,
water, gas, wastewater collection, and fiber
infrastructure
• Conduct utility damage assessment efforts
• Provide potable water in support of care
and shelter operations
• Coordinate with regional water supplies
and neighboring water utilities
• Coordinate with Pacific Gas & Electric for
the restoration of PG&E electrical and gas
transmission and distribution services to
the Utilities
• Oversee Utilities Mutual Assistance
• Local Energy Assurance Plan
• Damage Assessment Annex
• Evacuation Annex
(Draft in production)
• Emergency Public Information
and Warning
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
• Electric Utility Wildfire Mitigation
Plan
Office of
Transportation
• ESF 1
Transportation
State Level ESF 1
• Assist the Planning Section during EOC
Activations
• Develop road condition information for PD,
FD, Department of Transportation, Public
Works, RACES, Utilities, County of Santa
Clara, American Red Cross, Media
• Assist in transportation planning to support
operational objectives
• Assist in coordination of regional resources
as needed
• Evacuation Annex
(Draft in production)
• Continuity of Operations
Plan/Continuity of Governance
(COOP/COG)
• Department Emergency Plans
(DEPs) and other related
procedures
• Hazard Specific Annexes
(Storm/Flood, Earthquake,
Terrorism, Fire, HazMat)
City of Palo Alto
Emergency Operations Plan
9
1.0 REFERENCES
The following are the references used in developing the plan.
1.1 Local Authorities and References
• City of Palo Alto Municipal Code
• City of Palo Alto
• Santa Clara County Office of Emergency Management
• Santa Clara County Emergency Operations Plan
• The Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan, including the Palo Alto Local
Hazard Mitigation Plan Annex
1.2 State Authorities and References
• California Government Code
• California Emergency Services Act 2023
• California Disaster Assistance Act
• California Code of Regulations
• California Governor’s Office of Emergency Services
o Standardized Emergency Management Systems Guidelines
o Cal OES EOP Crosswalk (2024) local government
o State of California Emergency Operations Plan
o California Disaster and Civil Defense Master Mutual Aid Agreement
o Orders and Regulations that may be promulgated by the Governor during a State of
Emergency or a State of War Emergency
o California-Federal Emergency Operations Center Guidelines: Integrating Federal Disaster
Response Assistance with California’s Standardized Emergency Management System
1.3 Federal Authorities and References
• National Fire Protection Association (NFPA)
• Federal Emergency Management Agency (FEMA) / Department of Homeland Security
• Robert T. Stafford Disaster Relief and Emergency Assistance Act, PL 100-707
• Pets Evacuation and Transportation Standards Act of 2006
• National Incident Management System (NIMS)
• National Response Framework (NRF)
• Developing and Maintaining Emergency Operations Plans Comprehensive Preparedness Guide
(CPG-101)
• Homeland Security Presidential Directives (5, 8)
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BASIC PLAN
2.0 I NTRODUCTION
The EOP serves as the core planning document for Palo Alto’s emergency management activities. The
responsibilities of City departments, groups, and staff are outlined in the EOP Basic Plan and associated
annexes. To ensure adequate preparedness, City departments should actively participate in preparedness
and planning activities including the development of departmental plans and necessary policies and
procedures to fulfill assigned roles and obligations during an emergency.
As outlined in federal planning guidance, FEMA’s Comprehensive Planning Guide 101 (CPG-101), the City’s
emergency management program and the EOP embrace and implement the “whole community”
approach to emergency management. The city recognizes the role of non-governmental organizations
(NGOs), community-based organizations (CBO), faith-based organizations (FBO), private-sector
businesses, educational institutions, and other stakeholders before, during and after disasters. The EOP is
intended to reflect the wide variety of support that may be required by residents, visitors, and businesses,
including people with disabilities and people with access or functional needs. Consideration for people
with disabilities, access or functional needs is implemented in the City’s emergency planning.
Internal and external stakeholders and non-government organization (NGOs) agencies will need to
collaborate with the City’s Emergency Operations Center (EOC) and among one another, including in
circumstances where normal telecommunications may be impaired. By understanding the elements of
this plan, the City and such organizations can facilitate that process.
Members of the community should be aware of the potential risks and hazards that are present and the
responsibility to stay informed, make an emergency plan, and build an emergency kit.
2.1 Purpose
The purpose of this EOP is to provide and outline the framework, concepts, and policies of Palo Alto’s
emergency procedures and operations to ensure effective management and coordination of the City’s
response to emergencies and disasters. It identifies roles and responsibilities for various staff members
and departments regarding preparedness, response, recovery, and mitigation activities. This plan serves
as a foundational document for other related City plans, as well as a reference document for other
government and non-government organizations and entities. It is intended to be used in concert with
other related plans, such as mitigation, recovery, and continuity of operations. This EOP complies with
current federal, state, and local laws and regulations and incorporates best practices.
2.2 Goals and Objectives
The overall objective of emergency management is to ensure the effective coordination of plans, policies,
response forces, and resources in preparing for and responding to situations associated with natural
disasters, technological incidents and human-caused (deliberate) attacks, including national security
emergencies. To fulfill its responsibilities, the emergency management organization will accomplish the
following objectives during an emergency/disaster:
City of Palo Alto
Emergency Operations Plan
11
GOAL 1
Save Lives
• Objective 1.1: Prepare and disseminate emergency public information to alert, warn, and inform the
public.
• Objective 1.2: Provide effective life safety measures.
GOAL 2
Incident Stabilization and Restoration of Essential Services
• Objective 2.1: Maintain overall coordination/support of emergency response and recovery operations.
• Objective 2.2: Coordinate and liaise with appropriate federal, state, and other local government agencies,
as well as applicable segments of private sector entities and volunteer agencies.
• Objective 2.3: Establish priorities and resolve conflicting demands for support.
• Objective 2.4: Provide accurate documentation and records required for cost recovery efforts.
• Objective 2.5: Provide for the rapid resumption of impacted businesses and community
services.
2.3 Scope
The EOP applies to any significant emergency association with any hazard or threat, natural, technical, or
human-caused, which may affect the City and result in a planned, coordinated response effort by City
government. While all City resources may be called upon as needed, specific departmental responsibilities
are outlined in the EOP Basic Plan and associated annexes. To ensure the City is adequately prepared, all
City departments are required to actively participate in preparedness and planning activities to include
the development and review of departmental plans, policies, procedures, resource information and
contact information as necessary to fulfill their assigned roles and obligations.
GOAL 3
Protection of Property and the Environment
• Objective 3.1: Provide effective response efforts to reduce property loss and damage to the
environment.
12
For the purpose of this EOP:
2.4 Limitations
While many of the elements outlined in the EOP are designed for flexibility and can be utilized as needed
to address several emergency and non-emergency events, some activities require special activation or a
formal disaster declaration (proclamation) by the City Council. Similarly, the EOP is not meant to outline
procedures for routine incidents or minor emergencies which are adequately addressed through existing
processes.
The EOP identifies operational strategies and plans for managing inherently complex and potentially
catastrophic events. Assets, resources, and departments are potentially vulnerable and may become
overwhelmed. Deviations from the organizational and response structures outlined in the EOP may be
required, based upon evolving needs and available resources.
The EOP is an operational plan and does not address or manage response tactics. Tactics are managed by
the various departments in their respective field operations protocols and procedures.
The EOP is designed to promote flexibility whenever possible and is not intended to limit the use of good
judgment and common sense in matters not foreseen or adequately addressed by elements of the EOP
and its associated annexes or plans.
2.5 Situation / Hazard Assessment
Technological hazards, human-caused incidents, and natural hazards are identified in the City’s Threats
and Hazards Identification Risk Assessment and Hazard Mitigation Plan. The City’s current Hazard
Mitigation Plan Annex identifies the following as the high and medium natural hazards for the City:
Hazard Type Probability
Heavy Rain / Severe Storm Highly Likely
High Wind Highly Likely
o The City refers to the physical location and geo-political boundaries and space
described as the City of Palo Alto
o The City of Palo Alto refers to the political entity, a municipality in the northern portion
of Santa Clara County
o The County refers to the County of Santa Clara and its geo-political boundaries.
o Event refers to a preplanned or anticipated activity that require City resources from
others – government, private sector, and/or community organization. These gatherings
may draw large crowd which could make them vulnerable in the case of a natural or
human caused emergency.
o Incident refers to an unplanned occurrence – natural, technological, or human caused
which requires a response to safeguard life and property.
City of Palo Alto
Emergency Operations Plan
13
Extreme Heat Highly Likely
Wildfire Highly Likely
Earthquake Likely
2.6 Planning Assumptions
Planning assumptions are considered information accepted by planners as being true to provide a
planning framework in the absence of facts. Palo Alto OES planners have made the following assumptions
in preparing the Emergency Operation Plan:
• Palo Alto is susceptible to several hazards and risks that may result in critical incidents which may
include natural, technological, or human caused.
• Emergencies may occur at any time with little or no warning and may exceed the capabilities of
local, state, and federal governments, and the private sector in the affected areas.
• All City departments will participate in planning and preparedness activities as available.
• City personnel will be adequately trained to perform the emergency roles to which they are
assigned; however, some employees may not be trained but will have to perform a role due to
extenuating circumstances.
• The City’s EOC may be partially or fully activated to support operations during critical incidents.
• The City of Palo Alto is primarily responsible for emergency action within their municipality and
plans to commit all available resources to save lives, minimize injuries to persons, and minimize
damage to property and the environment.
• City departments will participate during a significant emergency or disaster; however, personnel
may be unavailable or unable to report to work.
• Palo Alto will utilize SEMS, ICS, and NIMS in emergency response and management of operations.
• The City will commit their resources to a reasonable degree before requesting mutual aid
assistance.
• Non-essential City operations will likely be reduced or cancelled to prioritize resources.
• Following a major disaster or catastrophic incident, Palo Alto may have to rely on their own
resources to be self-sustaining until mutual aid is available.
• Transportation infrastructure may be disrupted and access to critical facilities may be blocked.
• Critical infrastructure and utilities (natural gas, water, electricity, sanitary sewer, garbage,
recycling, communications, among others) may be severely impacted.
• Residents, businesses, and other entities may need to be self-sufficient for one week or more.
• Reasonable accommodations will be made for people with disabilities and/or access and
functional needs, but additional planning, resources, and support may be required during
emergencies.
3.0 C ONCEPT OF O PERATIONS
In accordance with state and federal laws and guidance, the City of Palo Alto officially adopted and
integrated the following emergency management, response, and coordination systems into the current
emergency management operations:
14
Collectively, the congruent operational systems outline how critical incidents, emergency, and disasters
will be coordinated in the field across all levels of government – local, county, regional, state, and federal.
3.1 Field-Level Coordination
As mandated by both SEMS and NIMS, Palo Alto utilizes the Incident Command System (ICS) to manage
response activities in the field. ICS provides for common terminology, processes, and position titles, while
allowing the delegation of functions (or tasks) to subordinate positions to promote proper span of control
and unity of command. ICS is applicable to any size incident and is designed to scalable as the needs of an
incident expand or contract. When utilized, the standardization of ICS principles and nomenclature can
integrate large numbers of personnel from disparate organizations.
3.2 Local, Regional, and State-Level Coordination
3.2.1 Standardized Emergency Management System (SEMS)
SEMS is intended to standardize response in emergencies and is intended to be flexible and adaptable to
the needs of the emergency responders. SEMS forms the foundation of emergency management
organization throughout the State of California and its use is required by all jurisdictions. SEMS requires
agencies use basic principles and components of emergency management including Incident Command
System, multi-agency coordinator, operational area concept and established mutual aid systems. Local
government must use SEMS to be eligible for state funding of response-related personnel costs. SEMS
utilizes five organizational tiers which are activated as need be and they consist of: field response, local
government, operational area, regional, and the state. Palo Alto has incorporated the use of SEMS into its
emergency management program.
D IAGRAM 3.2.1
• Incident Command System
• Standardized Emergency Management System
• National Incident Management System NIMS
City of Palo Alto
Emergency Operations Plan
15
3.2.2 Multi-Agency Coordination System (MACS)
The Multi-Agency Coordination System (MACS) is a part of NIMS and provides the basic architecture for
facilitating the allocation of resources, incident prioritization, coordination, and integration of multiple
agencies for large-scale incidents and emergencies. A MAC group is made up of administrators or
designees authorized to represent or commit agency resources and funds. MAC groups do not have direct
involvement in the incident(s) and may function virtually. The principal functions and responsibilities
associated with MACS include:
Examples of a MAC Group include San Francisquito Multi-Agency Coordination Group (SFC MAC), policy
groups (elected or appointed officials), emergency management committees (emergency managers, first
responders and allied agencies), or multiagency committees such as Incident Management Teams or
Emergency Management Planning Committees.
3.2.3 Field Response
Field response includes on-scene activities and coordination, consistent with ICS, to make tactical
decisions in direct response to the emergency of disaster. The field response is managed through an
Incident Command Post (ICP). Resource requests and situation reports are routed from the field to the
next SEMS organizational level, either through participating response agencies or the local EOC if
activated.
• Situation awareness / assessment
• Incident priority determination
• Critical resource acquisition and allocation
• Anticipating / identifying future resource requirements
• Coordinating policy issues
• Providing strategic coordination
• Joint Information Systems
16
3.2.4 Local Government
The City of Palo Alto, as a local government, retains the
responsibility and authority for managing response
activities within its jurisdiction. To support these efforts,
the City may activate its EOC and Departments may
activate respective Department Operations Center
(DOC). The EOC provides agency coordination, provides
logistical support, establishes common operating
procedures, identifies overarching priorities, and
prioritizes available resources. Additionally, the EOC
coordinates with Santa Clara County Operational Area
(OA) / County EOC. The Local Government Incident
Management Levels graphic derives from the Santa Clara
County’s Emergency Operation Plan (Santa Clara County
OEM Emergency Operations Plan 2017) and describes
the local government incident management levels.
3.2.5 Operational Area
The Operational Area (OA) provides response coordination for all political subdivisions within the county’s
jurisdiction. The OA coordinates response activities within the county’s jurisdiction through the County
EOC, if activated. The OA serves as a link to the regional level and other OAs within the region.
Palo Alto is part of the Santa Clara County Operational Area and coordinates with the Santa Clara County
Office of Emergency Management (OEM). The City participates in Santa Clara County OA planning and
during a critical incident, coordinates with the OA, through either the Santa Clara County OEM or the
Santa Clara County EOC, if activated.
3.2.6 Regional
The State of California is divided into three regions that each maintains
Regional Emergency Operations Centers to coordinate resource requests, support
mutual aid, and promote situational awareness between their respective OAs. The
City of Palo Alto and Santa Clara County are in the Coastal Region.
3.2.7 State
The Governor, through California Governor’s Office of Emergency Services (Cal OES) and
its Mutual Aid Regions, will coordinate statewide operations to include the provision of
mutual aid and other support to local jurisdictions and the redirection of essential supplies
and other resources as required. Santa Clara County is part of the OES Coastal Region. Requests
that exceed the capabilities of the Operational Area will be forwarded to the Region.
The Cal OES Director, assisted by State agency directors, their staff, and volunteer agency staff will
constitute the State emergency management staff.
Coastal Region
D IAGRAM 3.2.4 1
City of Palo Alto
Emergency Operations Plan
17
3.2.8 Mutual Aid
The California Mutual Aid System operates within the framework of the California Master Mutual Aid
Agreement and under the authority of the California Emergency Services Act. The system allows for the
mobilization of resources to and from emergency response agencies, local governments, operational
areas, regions, and the state with the intent to provide requesting agencies with adequate resources.
Mutual aid is utilized by primary response disciplines:
• Fire and Rescue
• Law Enforcement
• Coroner / Medical Examiner
• Emergency Management
• Medical & Health
Mutual Aid
Response Discipline Coordinating Agency Mutual Aid Elements Included
Fire and Rescue Cal OES Fire and Rescue Branch
Fire and Rescue Mutual Aid
Urban Search and Rescue Mutual Aid
Hazardous Material Mutual Aid
Law Enforcement Cal OES Law Enforcement
Branch
Law Enforcement Mutual Aid
Search and Rescue Mutual Aid
Coroner/Medical
Examiner
Cal OES Law Enforcement
Branch Coroner/Medical Examiner Mutual Aid
Emergency
Management
Cal OES Emergency
Management
Emergency Management Mutual Aid
CalWARN
Water/Wastewater Agency Response Network
Medical and
Health
California Emergency Medical
Services Authority Disaster Medical and Health Mutual Aid
Public Works Cal Waste/Wastewater Agency
Response Network (CalWARN) Public Works Mutual Aid
Utilities
California Utilities Emergency
Association (CUEA)
California Water/Wastewater
Agency Response Network
(CalWARN)
Electric, Natural Gas, Water and Wastewater
Utilities
Water and Wastewater Utilities
The California Mutual Aid System includes six mutual aid regions to facilitate the coordination and flow of
mutual aid requests. As part of the Cal OES Coastal Region, Palo Alto, and the Santa Clara (County)
Operational Area are part of Mutual Aid Region II.
The system includes several discipline-specific mutual aid systems that operate through designated
mutual aid coordinators at the Operational Area, regional, and State levels. Mutual aid requests are
18
coordinated within their geographic area before unfilled requests are forwarded to the next level. Mutual
aid requests that do not fall into one of the discipline-specific mutual aid systems are handled through the
emergency services mutual aid system and by emergency management staff at the local government,
operational area, regional, and state levels.
3.3 National Incident Management System
Issued on February 28, 2003, the Homeland Security Presidential Directive-5 (HSPD-5) requires all Federal
departments and agencies to make the adoption of National Incident Management System (NIMS) by
State, tribal, and local organizations, a condition for Federal preparedness grants, contracts, and other
preparedness activities. NIMS provides a comprehensive national framework for incident management
applicable at all jurisdictional levels and across all functional disciplines. Most NIMS requirements are
applicable to the City of Palo Alto, including the adoption of Incident Command System (ICS). Additional
elements of NIMS outline coordination between federal agencies and the use of federal assets and
resources.
NIMS is built on the following three components:
3.4 National Response Framework
The National Response Framework (NRF) is built upon the premise that incidents are typically handled at
the lowest jurisdictional level. The NRF provides the framework for federal interaction with state, local,
tribal, private sector, and non-governmental entities in the context of domestic incident management to
ensure timely and effective federal support.
4.0 E MERGENCY M ANAGEMENT O RGANIZATION
The City’s Municipal Code (Palo Alto Municipal Code, 2024) outlines the purpose of emergency services
for the preparation and carrying out of plans for the protection of people and property within respective
city in the event of an emergency; the direction of the emergency organization; and the coordination of
the emergency functions with all other public agencies, corporations, organizations, Emergency Operation
Centers, Department Operation Centers, city departments, volunteers, and affected persons. “All officers
and employees of this city, together with those volunteer forces enrolled to aid them during an
emergency, and all groups, organizations and persons who may by agreement or operation of law,
including persons impressed into service under the provisions of Section 9.28.060, be charged with duties
incident to the protection of life and property in this city during such emergency, shall constitute the
emergency organization of the city.” (Palo Alto Municipal Code, 2024)
4.1 Director of Emergency Services
The Municipal Code defines the Office of Emergency Services (OES) as a public safety department. The
Director of the Office of Emergency Services (OES Chief) is also the statutory Assistant Director of
Emergency Services. By title and code, the City Manager is the Director of Emergency Services. The
• Resource Management
• Command and Coordination, including the Incident Command System
• Communications and Information Management
City of Palo Alto
Emergency Operations Plan
19
Director of Emergency Services assists in coordinating the City’s overall response and recovery operations.
The Director of Emergency Services also acts as the City government’s key representative and lead agent
for day-to-day emergency management, with powers delegated through the Municipal Code to:
1. Direct coordination and cooperation of services and staff of the emergency organization of the
City, and resolve questions of authority and responsibility that may arise between them; and
2. Represent the City in all dealings with public or private agencies on matters pertaining to
emergencies.
To achieve this mandate, OES leads or coordinates planning, intelligence, and coordination, not only
internally but also with allied agencies such as Stanford University, the private sector, and the community
to promote, coordinate, and advance the four phases of emergency management: preparedness,
response, recovery, and mitigation.
4.2 Emergency Services Council
The City’s Municipal Code 2.12.030 (Palo Alto
Municipal Code, 2024) establishes an Emergency
Services Council. The organization chart depicts
Palo Alto’s Emergency Services Council.
The City’s Municipal Code 2.12.040 (Palo Alto
Municipal Code, 2024) establishes the powers
and duties of the emergency services council. The
Emergency Services Council is empowered to
develop and recommend for adoption by the City
Council such emergency and mutual-aid plans
and agreements, ordinances, resolutions, rules,
and regulations that are necessary to implement
these plans and agreements. The council shall
meet when called by the chairman (Mayor) or
when absent by the vice chairman (Director of
Emergency Services).
General powers and duties of director of
emergency services is listed in the City’s
Municipal Code 2.12.50 (Palo Alto Municipal
Code, 2024):
(a) There is hereby created the office of emergency services. The city manager shall be the director of
emergency services.
(b) There is hereby created the position of assistant director of emergency services who shall be
appointed by the director.
Palo Alto Emergency Services Council Organization Chart
D IAGRAM 4.2 1
20
(c) The director and assistant director are hereby empowered to:
(Ord. 2641 § 1 (part) 1971: Ord. 2146 (part), 1963: prior code § 2.1005)4.3 City
Employees
One of the greatest resources for the City of Palo Alto is its employees. California Government Code
designates that all public employees are Disaster Services Workers (DSW) (State of California, 2013). Any
employee of the City of Palo Alto may be assigned to perform activities which promote the protection of
public health and safety or the preservation of lives and property within their routine levels of training
proficiency. Such assignments may require services at locations, times, and under conditions that are
significantly different than normal work assignments and may continue into the recovery phase of
emergency.
4.4 Santa Clara County Office of Emergency Management
Santa Clara County Office of Emergency Management provides Operational Area (OA) coordination during
disasters and emergencies and assists jurisdictions with preparedness, mitigation, recovery, and response
efforts.
Santa Clara County OA is the next SEMS level to provide the City with support and resources during and
after an emergency or disaster.
5.0 W HOLE C OMMUNITY A PPROACH
Palo Alto’s ability to respond and recover from significant emergencies and major disasters is highly
dependent upon planning for the unique needs and specific requirements of the residents and non-
resident, commuters, and visitors. To further identify and meet these needs, a “Whole Community”
approach has been adopted to include and integrate community partners, neighbors, and other
stakeholders in all phases of emergency management. Through these collaborative efforts, Palo Alto will
become more resilient and better prepared to meet the needs of its residents, and any daytime
population increase, those with disabilities, access and functional needs and cultural consideration. The
1. Request the city council to proclaim the existence or threatened existence of a "local
emergency" if the city council is in session, or to issue such proclamation if the city council is not
in session, subject to ratification by the city council within seven days thereafter or the
proclamation shall have no further force or effect.
2. Request the Governor to proclaim a "state of emergency" when in the opinion of the director,
the resources of the area or region are inadequate to cope with the emergency upon request by
proper authority.
3. Control and direct the effort of the civil emergency organization of the city for the
accomplishment of the purposes of this chapter.
4. Direct coordination and cooperation of services and staff of the emergency organization of the
city, and resolve questions of authority and responsibility that may arise between them; and
5. Represent the city in all dealings with public or private agencies on matters pertaining to
emergencies as defined herein.
City of Palo Alto
Emergency Operations Plan
21
City will include the Whole Community Approach when preparing for, responding to, recovering from,
and mitigating against major emergencies and disasters.
5.1 Residents
Residents of Palo Alto play a fundamental role in emergency management by ensuring that they are
prepared for emergencies and disasters. In most disasters, City residents will be the first to respond—
family members caring for one another, neighbor helping neighbor. In a major disaster, residents may not
have access to City services for days. Individual preparedness will ensure that the City’s limited resources
can go where they are most needed.
The City recommends that all residents prepare for disaster by taking first aid and CPR training,
maintaining disaster supplies of food and water, and safekeeping personal documentation (e.g., personal
identification and individual medical records). These actions will better prepare residents to evacuate or
shelter-in-place for up to a week. Those families or residents with disabilities and others with access and
functional needs may require additional personal planning before, during, and after an emergency to
accommodate their need for assistance with communication, maintaining health and medical supplies,
independence, support and safety, or transportation.
5.2 Community Organization/ Volunteer Groups
OES develops structures to link non-governmental organizations (NGOs), residents, and
businesses to the Incident Command System (ICS). Elements of this include the
restructured Emergency Services Volunteers (ESV) program which is a unified structure
that includes Amateur Radio Emergency Services (ARES), Radio Amateur Civil Emergency
Services (RACES), Block Preparedness Coordinators (BPCs), and Community Emergency
Response Team (CERT) volunteers. (Emergency Volunteers – City of Palo Alto, CA)
The Block Preparedness Coordinator is a grass roots program that trains volunteers to build
social networks in our neighborhoods, deter crimes, and prepare for emergencies. During
activation, BPCs check on their neighbors, identify and report critical problems to their
Neighborhood Preparedness Coordinators (NPCs), and assist in getting resources on the
scene.
CERT Basic Training is a national program designed to help prepare Palo Alto residents to help themselves,
their families, and their neighbors in the event of a disaster.
Community Emergency Response Team – City of Palo Alto, CA
Palo Alto's Auxiliary Communications Services (ACS) supplements
emergency communications with volunteer staff. Both licensed and
unlicensed volunteers can serve in one or more functions across
administrative, management, technical, or operational areas in both ARES and RACES.
(Auxiliary Communications Services – City of Palo Alto, CA)
22
The Palo Alto/Stanford Citizen Corps Council (CCC) serves to harness the power of individuals, businesses,
and organizations through education, training, and volunteer service. Volunteers who assist and/or
support emergency efforts may be required to undergo a screening process and/or background check.
Volunteer programs determine the policies, procedures, and protocols for functionality and operations
during incidents and events.
5.3 Private Sector
Palo Alto has a vibrant business community that includes traditional retail, recreational, entertainment,
and corporate businesses. The City engages with the private sector to better understand their needs,
identify resources, and develop partnerships. Many of the City’s private sector partners address
preparedness planning internally to minimize business disruptions and to support the wellbeing of their
employees and offer their resources and technical capabilities to the larger community. The City
acknowledges this valuable support and will continue collaborative efforts with the private sector as a
component of the overarching emergency management program. In its efforts to engage the private
sector, the City may solicit agreements, arrangements, memorandums of understanding and the like with
various business and or business groups, such as the Chamber of Commerce. The nature of these
relationships and roles and responsibilities will be outlined in any provisions and/or documents.
5.4 People with Disabilities
People with disabilities often require additional planning and support to ensure they receive equal access
and coverage as required under the Stafford Act as well as other state and federal legislation such as the
Americans with Disabilities Act (ADA) of 1990. Covered disabilities are not always apparent and may
include impairments of mobility, vision, and hearing as well as some cognitive disorders and mental
illnesses. For more information on assisting people with disabilities in an emergency scenario please visit
the Earthquake preparedness page: Be Ready for the Next Big Earthquake – City of Palo Alto, CA. To meet
the needs of these individuals, Palo Alto is committed to supporting efforts and activities designed to
improve and validate capabilities in support of people with disabilities, including but not limited to:
• Notifications and warning procedures
• Evacuation, transportation and sheltering considerations
• Accommodations for service animals
• Accessibility to information
• Maintaining independence
• Effective communication
• Transportation
• Supervision
• Medical care
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5.5 Individual with Access & Functional Needs
In addition to people with disabilities, Palo Alto recognize that additional support may be necessary to
support those with access and functional needs (State of Cailifornia , 2019). These are not necessarily
related to a specific condition, diagnosis, impairment and are based upon functional areas such as:
Individuals with access and functional needs may not have access to support networks outside of their
immediate communities or be able to self-evacuate. As a result, they may have additional needs before,
during, and after an incident. Those with functional needs often include children, the elderly, tourists, and
other segments of the population, such as:
5.6 Consideration for Pets and Animals
In 2006, the federal government passed the Pets Evacuations and Transportation Standards (PETS) Act as
an amendment to the Stafford Act. The PETS Act directs state and local emergency preparedness plans
address the needs of individuals with pets and companion animals during a disaster or emergency.
American Red Cross procedures allow for assigned service animals to accompany individuals.
Palo Alto works to include consideration for the needs of pets and companion animals in plans as
appropriate. Santa Clara County Society for the Prevention of Cruelty to Animals (SPCA) maintains shelters
including mobile ones for various pets and can be potentially
located near a designated shelter. Throughout Santa Clara County
there are numerous individuals and organizations (farms, ranches,
and others) with large animals such as horses, cattle, sheep, goats,
and/or pigs. Owners should make appropriate preparations (e.g.,
sheltering, transporting) in advance for their animals before an
actual disaster occurs.
6.0 E MERGENCY M ANAGEMENT P HASES
Emergency management is divided into various phases with each
of these phases bending into the next one. There is no clear
demarcation of when one phase starts and another one ends.
Elements from each phase may be used to support or augment
elements from another phase.
• People with disabilities
• People living in institutionalized settings
• People from other cultures
• People with limited English proficiency
• People without transportation
• People who are economically disadvantaged
• Women who are pregnant
D IAGRAM 6.1
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6.1 Preparedness Phase
The preparedness phase involves activities undertaken in advance of an emergency. These activities
develop operational capabilities and effective responses to a disaster. These activities focus on
maintaining or improving capabilities that will be used in the response or recovery phases. Preparedness
actions might include mitigation activities, emergency/disaster planning, training, exercises, and public
education. Preparedness encompasses the whole community and promotes collaboration amongst
businesses, residents, agencies, and departments to achieve the common goal of disaster preparedness.
Members of the emergency management organization should prepare checklists detailing assignments,
notification rosters, resource lists and other useful documents. Personnel should be acquainted with these
documents through periodic training and reviews.
6.1.1 Planning
Emergency planning includes a wide variety of plans at the strategic, operational, and tactical levels.
Strategic plans include the EOP and many of its associated hazard-specific or functional annexes, while
operational and tactical planning includes more detailed information such as standard operating
procedures (SOP), checklists, personnel assignments, notification rosters, resource lists, and forms.
All City departments are required to participate in the development of relevant strategic and operational
plans while ensuring that internal tactical planning is sufficient to meet the needs of their outlined roles
and assigned objectives. This includes the development of department-specific SOPs required to meet the
objectives outlined for each department.
6.1.2 Training
Training is an essential component of preparedness and impacts the ability to respond to and recover
from a critical incident.
The City facilitates trainings and regularly communicates opportunities to the whole community, City staff,
and fire staff members. Additionally, the City prioritize trainings that promote staff understanding and
familiarity with the following concepts:
• Identification and prioritization of essential services
• Establishment, promulgation, and maintenance of orders of succession
• Identification of delegation of authority
• Identification of continuity of communication
• Identification and maintenance of continuity of facilities
• Maintenance of vital records
• Establishment of process of reconstruction
• Development of an effective test, training, and exercise program to support continuity efforts
• Development of a Continuity of Operations Plan (COOP) – detailed and comprehensive
information is contained in the COOP plan; the COOP Plan should be used in concert with the
EOP
City of Palo Alto
Emergency Operations Plan
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The City Manager and OES are responsible for ensuring that the staff members assigned to the EOC are
adequately trained and competent to fulfill their designated responsibilities. Staff members are
encouraged to engage in on-going emergency management training to be familiar with current plans and
guidance and capable of fulfilling the EOC role to which they are assigned.
6.1.3 Exercises
Exercises are a primary tool for assessing preparedness and identifying areas for improvement. They are
a valuable method to validate plans and train personnel. Palo Alto incorporates guidance from the
Homeland Security Exercise and Evaluation Program (FEMA, Homeland Security Exercise and Evaluation
Program (HSEEP), 2020) in the development of its exercises.
A variety of exercises and trainings are used to assess capabilities and prioritize future planning and
training needs. By simulating potential response and recovery scenarios, Palo Alto can validate existing
plans and determine where additional training might be needed. The City’s Emergency Management
Team will develop a Training and Exercise Program that incorporates a building block approach in the
development of planned exercises to facilitate increasing awareness and knowledge.
6.1.4 Public Awareness & Education
The Palo Alto Fire Department, the Palo Alto Police Department, and other City departments and their
partners promote public awareness and education to strengthen overall preparedness, awareness, and
community resilience. By providing community education, outreach, training, and coordination, the City
increases the ability of community members and organizations to adequately prepare for and meet their
own needs. By promoting self-reliance and preparedness, the city reduces the overall burden on resources
and competing needs that may arise during critical incidents.
Public Education is an essential tool to teach residents how to prepare for, react to and recover from a
major emergency or disaster. Residents can visit: Palo Alto Emergency Preparedness; Be Ready for the
Next Big Earthquake ; and Stay Informed – City of Palo Alto, CA to learn more about how to prepare for,
respond to, and recover from a disaster.
Residents should take advantage of various emergency preparedness information and resources from
City, County, State, and Federal governments among other sources and incorporate recommended
practices into their regular routines.
• Incident Command System (ICS)
• California Standardized Emergency Management System (SEMS)
• National Incident Management System (NIMS)
• California Disaster Service Worker (DSW) [CA Government Code 3101]
• EOC Functions
• EOP Orientation
• Department individual training and certifications
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6.2 Response Phase
The response phase includes any actions taken immediately before, during, or directly after a critical
incident to minimize the potential or existing impacts of the incident.
6.2.1 Pre-Event
Some incidents may provide sufficient warning to allow for pre-event or precautionary measures.
Depending on the likelihood of significant impacts, pre-event response may include:
• Public warning
• Evacuations
• Resource Mobilization
• Staging
• Mutual Aid Requests
• Proclamation of a Local Emergency
6.2.2 Emergency Response
Emergency response activities are actions taken during or immediately after a critical incident to reduce
or minimize actual impacts. While these activities are often associated with traditional response units –
fire, law enforcement, emergency medical service (EMS), and public works and utilities – the size and
complexity may require support from additional governmental agencies, non-government organizations
(NGOs), businesses, community and faith-based organizations and other partners.
During emergency responses, some incidents may escalate beyond the capabilities of field operation
management that may necessitate the need for additional support and coordination requiring the
activation of a Department Operations Center (DOC). When an incident, or multiple incidents exceed the
capabilities of a DOC, or when multiple department DOCs have been activated and more coordinated
efforts are needed, the EOC should be activated.
When coordinating emergency response activities and prioritizing needs and objectives, the following
hierarchy is utilized:
Emergency response may include activities related to short-term recovery and often overlaps with long-
term recovery operations.
6.2.3 Prolonged Emergency
In addition to continuing life and property protection; operations, mass care, relocation, public
information, situation analysis, status and damage assessment operations will be initiated.
1. Life Safety
2. Incident Stabilization
3. Protection of property and infrastructure and restoration of essential services
4. Reduce impacts to the environment
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6.3 Recovery Phase
The Recovery Phase includes short and long-term activities focused on returning the community to pre-
incident or improved conditions. In some situations, when a disaster declaration has been made, recovery
activities may include the critical task of identifying, documenting and quantifying response and recovery
costs eligible for reimbursement. The City of Palo Alto’s Damage Assessment Plan includes more detailed
information on recovery operations within the city.
The Recovery Phase may begin during the Response Phase or as directed by the EOC Director. Depending
on the incident the recovery process may be short or be a sustained operation lasting several years. A
comprehensive recovery plan may provide more detailed actions for a prolonged recovery period. A
separate and detailed Recovery Plan would contain specific procedures and protocols, roles, and
responsibilities. The EOP is intended to be used mostly during the response phase of an incident; it is not
intended to be a comprehensive recovery plan. The following actions may assist and facilitate recovery
efforts:
6.3.1 Short-term Recovery
Short-term recovery operations begin during the response phase and may include activities such as the
restoration of essential services, rapid debris removal, and the re-establishment of City services.
6.3.2 Long-term Recovery
Long-term recovery operations are often required to address extensive damage to infrastructure or
widespread devastation. Activities include the restoration and reconstruction of public facilities and
disaster response cost recovery.
The recovery period has major objectives that may overlap with other phases of the emergency
management cycle, including:
• Reinstatement of family and individuals’ autonomy
• Provision of essential public services
• Permanent restoration of private and public property
• Conducting damage assessments
• Assessing housing needs – both support and solutions
• Issuing permits for repairs and demolition
• Debris removal
• Opening roadways and transportation routes
• Restoring utilities – water, electricity, gas, communications, sewer, internet, cable
• Opening local assistance centers (LAC)
• Restart government functions
• Coordinating efforts with Santa Clara County OEM
• Working with local businesses to restore operations
• Coordinating with County, State and Federal officials regarding financial recovery for the City
• Coordinate with County Public Health efforts for disasters that included health issues
• Identify and prioritize essential functions and services
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• Identification of residual hazards
• Plans to mitigate future hazards
• Recovery of costs associated with response and recovery efforts
• Coordination of state and federal, private, and public assistance
As the immediate threat to life, property, and environment subsides, the rebuilding of Palo Alto will begin
through various recovery activities. Long-term planning efforts, including public safety and infrastructure
sustainability, are included in the Palo Alto General Plan. Recovery activities involve the restoration of
services to the public and rebuilding the affected area(s). Examples of recovery activities may include:
• Restoring all utilities
• Establishing and staffing Local Assistance Centers (LACs) and Disaster Assistance Centers (DACs)
• Applying for state and federal assistance programs
• Conducting hazard mitigation analysis
• Identifying residual hazards
• Determining recovery costs associated with response and recovery
Depending on the severity of the disaster, sheltering activities could be short -term or long-term. Palo Alto
will open shelters using the American Red Cross-National Survey System (NSS) as well as County guidance.
6.3.3 Damage Assessment
Damage Assessment activities involve identifying, recording, compiling, and analyzing damage
information to determine the type of recovery assistance needed. Following major disasters, Preliminary
Damage Assessments (PDAs) are used to determine preliminary eligibility for certain state and federal
financial assistance and reimbursement programs. Damage Assessments require the coordination of
multiple city departments.
6.3.4 Disaster Assistance Programs
If the disaster is significant enough to warrant a gubernatorial and a presidential disaster declaration,
additional state and federal assistance may become available. A local disaster proclamation does not
automatically warrant the provisions of state or federal assistance. The City will have to qualify for these
additional resources. If determined to be eligible, the City and its residents may be able to participate in
state and federal disaster assistance programs for the following:
• Individuals – may be eligible for loans and grants for housing assistance programs (for
homeowners and renters), and uninsured disaster-related necessitates (including personal
property, medical, dental, and transportation expenses). Other Robert T. Stafford Disaster Relief
and Emergency Assistance Act (Stafford Act) programs include crisis counseling, disaster
unemployment assistance, and legal services, may be available.
• Businesses – may be eligible for low-interest loans to assist with uninsured physical damaged
through the United States Small Business Administration (SBA).
• Government – assistance may be available through state assistance under the California Disaster
Assistance Act (CDAA), as well as sever federal programs including the FEMA Public Assistance
(PA) Grant Program, and the Hazard Mitigation Grant Program (HMGP).
• Non-profit Organizations - assistance may be available through the state CDAA, as well as several
federal programs including FEMA PA Grant Program for eligible non-profit organizations.
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6.3.5 Recovery Documentation
Documentation is the key to recovering eligible response and recovery costs. Damage assessment
documentation will be critical in establishing the basis for eligibility of disaster assistance programs.
Various state and federal assistance programs require several types of documentation for eligible costs
and in addition to structural damage, may include staff time, equipment, and materials utilized in
response to the incident. To support the maximum recovery of eligible reimbursement, City departments
must identify and support internal mechanisms for tracking and documenting appropriate costs.
6.3.6 After Action Report
As part of the recovery phase, and in accordance with SEMS, the State of California requires any city
declaring a local emergency for which the governor proclaims a state of emergency, to complete and
transmit an after-action report to the California Office of Emergency Services (Cal OES) within 90 days of
the close of the incident period. The after-action report should include the following information:
6.4 Mitigation Phase
The Mitigation Phase includes actions and measures taken to reduce or eliminate the degree of long-
term risk from natural and technological hazards. Whereas preparedness activities increase the City’s
ability to respond to the impacts of a hazard, mitigation activities reduce the potential for those impacts
in the future, thereby reducing overall risk.
Numerous mitigation activities are available and may include the implementation, augmentation, or
promotion of the following:
• Building and Safety Codes
• Disaster/Fire/Flood Insurance
• Land Use Planning and Management
• Hazard Research and Analysis
• Land and Repetitive Loss Acquisition
• Monitoring and Inspection
• Public Outreach and Education
• Relocation
• Risk Mapping
• Safety Codes, Statutes, and Ordinances
• Tax Incentives and Disincentives
• Seismic Strengthening or Retrofitting
The City participates in local and regional mitigation activities such as the development of risk
assessments and mitigation plans. Further, the City’s Comprehensive Plan (General Plan) includes
mitigation aspects and elements. This information is located on the City’s website.
7.0 E MERGENCY O PERATIONS C ENTER
Palo Alto operates an Emergency Operations Center (EOC) that provides a centralized location where
emergency management coordination and decision-making occur and can support field operations during
30
critical incident, major emergency, or disaster. When activated, the EOC provides support for several
critical tasks related to communication, coordination, resource management, and executive leadership.
7.1 EOC Locations
The primary EOC location is: 250 Sherman Ave. Palo Alto, CA 94306
The alternate EOC location is: 3201 East Bayshore Rd, Palo Alto, CA 94303 (Municipal Services Center)
Alternate locations are used when the primary EOC would or might be unsafe or unusable.
Situations and circumstances may arise in which staffing an in-person EOC fully or partially may be
impractical or unwise, such as with the recent COVID-19 pandemic. Alternative staffing options may be
considered and implemented and may include remote, virtual, or a combination of in-person and remote.
Staff will be provided with appropriate tools, equipment, and training to perform their assigned
responsibilities. The City’s Director of Emergency Services will determine if alternate options will be
implemented.
7.2 Activations & Deactivation
The EOC equipment is maintained by Palo Alto OES staff and may be used for coordination and monitoring
activities at any time without the need for a formal activation. However, depending upon the need and
circumstances, an official EOC activation may be appropriate to support several activities, including:
The activation level and significance of the incident/event will determine who assumes the role of EOC
Director. The City Manager would usually assume the role of EOC Director during a full activation.
For incidents or events that extend beyond an operational period (e.g., 12 hours) the City Manager may
designate an alternate or replacement. This person could be the assistant city manager or one of the
emergency services chiefs.
7.2.1 DOC Activation
A Department Operations Center (DOC) may activate at the discretion of the senior department decision
maker, or the department executive leader based upon current or impending conditions that may alter
normal operations for a temporary period of time. DOCs may also activate in support of EOC and field
operations during a disaster.
A DOC is a centralized location or hub dedicated to coordinating a specific department or agency’s internal
incident management and response during emergencies.
7.2.2 EOC Activation Authority
The following municipal positions have the authority to activate the City’s EOC:
• Field response (disaster or major emergency)
• Pre-planned events (conventions, parade, city-wide event)
• Local proclamation of emergency
• Governor’s declaration of emergency
• Presidential declaration of a national emergency
• State of War
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Individuals serving in an acting role or empowered to act on behalf the above positions may activate the
EOC.
As situations and conditions warrant, Director of Emergency Services will communicate appropriate
information to the City Council of escalating or anticipated incidents or events which may have a
significant impact on Palo Alto and efforts being made to address the situation.
EOC activation may occur based upon escalating incidents or in anticipation of an incident or event.
Activation of multiple DOCs may warrant the activation of the EOC. DOC commanders should be
communicating with respective department heads of current and projected situation status.
7.2.3 EOC Activation Levels
When the EOC is activated, the City will notify the Santa Clara County OEM.
The City may also establish Departmental Operations Centers (DOCs) for specific departments (e.g.,
Utilities, Public Works, or IT) as required to support field operations and coordinate other functions within
their respective departments. Activation of multiple DOCs may warrant or necessitate the activation of
the EOC.
EOC activation levels are scalable based in the evolving needs and may include full or partial staffing as
required. See table below:
• Palo Alto City Manager, Assistant City Manager, or designee
o Palo Alto Police Chief or designee
• Palo Alto Fire Chief or designee
• Palo Alto OES Chief, Emergency Services Coordinator, or designee
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Similarly, the deactivation of the EOC will be scalable based on the decreasing needs of Palo Alto.
Appropriate EOC functions and roles will be deactivated as the situation allows and as directed by the EOC
Director.
7.3 EOC Communication & Coordination
The EOC has the capability to communicate and coordinate with field personnel, incident commanders,
DOCs, external stakeholders, volunteer community groups, and other government agencies.
Coordination with field elements from the EOC may be coordinated through relevant DOCs or directly
with an Incident Commander. If a DOC is not activated, the Incident Commander may communicate
Level Operational Status
(Minimum Positions)
Trigger
Event/Situation
(examples include but
not limited to)
Activities
Level 1
Full Staffing
as needed
All positions
(as required)
• Large Winter
Storm
• Terrorist incident
• Major Earthquake
• Regional Disaster
• Major Wildland
Fire in Urban
interface
• Situational Analysis
• Public Information
• Response Coordination
• Resource Coordination
• Logistics Support
• Recovery Operations
• Sustained Operations
• Reporting to State
Level 2
Partial Staffing
Management, EOC
Section Chiefs
Branches/Divisions/Units
Liaison/Agency reps
• Large scale
evacuations
• 2+ incident sites
• Severe Weather
Warning
• Earthquake with
minor damage
• Major scheduled
event
• Situational Analysis
• Public Information
• Response Coordination
• Resource Coordination
• Logistics Support
• Reporting to State
Level 3
Minimal
Staffing
EOC Coordinator
• Small incident or
event
• One site
• Potential threat of:
o Flood
o Severe storm
• Escalating incident
• Situational Analysis
• Public Information
• Response Coordination
• Resource Coordination
• Reporting to State
TABLE 7.2.3
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directly with their department specific representative, sometimes located in the Operations Section of
the EOC.
The EOC will communicate and coordinate with the Santa Clara County EOC, when activated, or County
OEM, and other cities in the Operational Area. Affected cities will provide situational awareness and
relevant resource status to the County EOC.
Communication may be by cell phone, internet, or other viable means.
Additionally, the EOC may communicate with designated volunteer community groups through
alternative methods such as amateur radios.
7.4 EOC Structure – Hierarchy of Command and Span-of-Control
The essential ICS functions in SEMS and NIMS are identified as “sections” in the EOC:
All other functions are organized as branches, groups, or units within these sections. Only functional
elements that are required to meet current objectives will be activated. Below is a sample ICS chart that
can be expanded or scaled back based on the size and extent of an incident or event.
C HART 7.4
MANAGEMENT
OPERATIONS PLANNING LOGISTICS FINANCE
Legal
PIO
Safety
o Management—Responsible for overall emergency policy and management coordination; other
responsibilities of the management staff include public information, EOC safety and security,
legal review of proclamations and other similar actions, and liaising with other agencies.
o Operations—Responsible for supporting operations, coordinating emergency response efforts
and shelter operation support.
o Planning—Responsible for collecting, evaluating, and disseminating information; assists in
developing emergency action plan; responsible for collecting all documentation material;
planning also includes intelligence-gathering such as weather information.
o Logistics—Responsible for providing facilities, services, personnel, equipment, materials, and
resources.
o Finance—Responsible for financial expenditures, records, and other administrative aspects.
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Management of personnel within the EOC will be accomplished through the assignment of section chiefs
(general staff) to the operations, planning, logistics, and finance functions. Section chiefs report to the
EOC Director in the Management Section. Management staff consists of such positions as safety, legal,
public information officer (PIO), liaison, among others. See the Palo Alto EOC Manual for position
descriptions.
7.5 Emergency Action Plans
At local, operational area, regional and state levels, the use of EOC action plans (EAP) provide designated
personnel with knowledge of the objectives to be attained and the steps required for achievement. Action
plans give direction and provide a basis for measuring achievement of objectives and overall system
performance in the EOC. The EOC Director will determine and direct the drafting of EAPs. The Planning
Section shall be responsible for overseeing EAPs development and drafting.
8.0 E MERGENCY D ECLARATIONS
8.1 Local Proclamation
California Government Code allows a local emergency to be proclaimed by a city council or designed
official by city council.
If the City of Palo Alto determines that the effects of an emergency are, or may become, beyond the
capability of local resources, a local emergency can be proclaimed. The Palo Alto City Council has
empowered the City Manager and the Director of Emergency Services to issue a proclamation of local
emergency when the City Council is not in session. Such a proclamation of local emergency is invalid after
seven days, unless ratified by the City Council. Proclamations must be made within ten (10) days of
occurrence to qualify for assistance under the California Disaster Assistance Act and must be renewed
every 14 days. Palo Alto Municipal Code and the California Disaster Assistance Act specify the
requirements for proclaiming and, when necessary, maintaining, a local emergency. Compliance to the
California Disaster Assistance Act (CDAA) (State of California, 2015) is required for the City to qualify for
assistance.
A local proclamation of emergency allows the City Manager and the Director of Emergency Services to
take measures necessary to protect and preserve public health and safety and may trigger certain
reimbursement opportunities.
8.2 State of Emergency
After a proclamation of a local emergency, the governing body, having determined that local resources
are not sufficient to mitigate the situation, may request by letter or resolution that the Governor proclaim
a state of emergency in the area to fully commit state and mutual aid assistance and provide resources to
assist local government.
To support its request for a gubernatorial proclamation, it is essential that the City forward an estimate
of damage and financial loss to Cal OES through the Santa Clara County OEM as quickly as possible.
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Estimates of loss are an important part of the criteria that Cal OES considers when deciding to proclaim a
state of emergency and request a Presidential Declaration of Emergency or Disaster. A copy of the request
for a Governor’s proclamation, with the following supporting data, must be forwarded, to the Santa Clara
County OEM Director for transmission to the Cal OES Director:
Cal OES prepares a recommendation as to the action that should be taken by the Governor. If the action
recommends a Governor’s proclamation, Cal OES prepares the proclamation.
The Governor may also proclaim a state of emergency without a local request if the safety of persons and
property in the state are threatened by conditions of extreme peril, or emergency conditions are beyond
the emergency response capacity and capabilities of local authorities. Local damage assessment
documentation and submission may be required for reimbursement.
8.3 State of War Emergency
In addition to a State of Emergency, the Governor can proclaim a State of War Emergency whenever the
state or the nation is attacked by an enemy of the United States, or upon receipt by the state of a warning
from the federal government indicating that such an enemy attack is probable or imminent. The provisions
of the Governor granted under a State of War Emergency are the same as those granted under a State of
Emergency.
8.4 Presidential Declaration
Following the proclamation of a state of emergency, the Cal OES Director may recommend that the
Governor request a Presidential Declaration of a major disaster under the authority of Public Law 93-288.
The Governor’s request to the president is submitted through the FEMA. Supplementary justification data
may be required to accompany the state and local proclamations and Initial Damage Estimate.
9.0 P UBLIC I NFORMATION
During a major emergency, disaster, or significant event providing residents and the public with useful
and updated information is essential. The EOC PIO will oversee messaging during an EOC activation. If
the EOC is not activated, then either the lead department or City’s PIO will be responsible.
9.1 Alerts and Notifications
During an incident, the City will utilize various communication tools to disseminate information and
directions to its residents. Notifications may be coordinated with neighboring agencies and/or the County.
Recognizing that some residents may have limited access or functional needs, the City will strive to
address communication in various forms. Communication tools include but not limited to:
• Copy of the local emergency proclamation
• Initial damage estimate summary that estimates the severity and extent of the damage
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• City Notification System - ALERTSCC
o A county-wide community alert and notification system that allows
the City of Palo Alto to quickly provide critical information and
instructions to subscribers using registered cell phones, emails, or
landline phones through a reverse 9-1-1 function. Registration can
be completed at http://www.alertscc.gov/ or by texting your zip
code to 888777.
• Connect With Us – City of Palo Alto, CA
o Palo Alto PD publishes news releases, traffic advisories, urgent updates, community news,
power outage notifications, and other important safety information on Nixle.
o Important City updates are shared on Nextdoor, X (Twitter), and Facebook.
• Local news and radio stations participating in the Emergency Alert System.
• Volunteer and neighborhood groups and community or faith-based organizations.
Public education can be a useful tool to prepare residents in advance of incidents – how to prepare for,
react to, and recover from various situations.
9.2 Joint Information System
The Joint information System (JIS) is the broad mechanism that organizes, integrates, and coordinates
information to ensure timely, accurate, accessible, and consistent messaging activities across multiple
jurisdictions and/or disciplines with the private sector and non-governmental organizations (NGOs). It
includes the plans, protocols, procedures, and structures used to coordinate and share public information.
Federal, State, tribal, territorial, regional, local, and private sector PIOs and established Joint Information
DIAGRAM 9.2
City of Palo Alto
Emergency Operations Plan
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Centers (JIC) at each level of SEMS are critical elements of the JIS. The County / Operational Area may
orchestrate JIS activities for larger or countywide incidents and events.
9.3 Joint Information Center
The Joint Information Center (JIC) is the central location that facilitates the operations of the JIS during an
emergency. This location supports personnel with public information responsibilities from multiple
agencies, departments, and other local governments. They perform critical emergency information
functions, crisis communications, and public affairs functions.
A JIC is established at a suitable location to provide for effective management of Public Information
functions. When activated, the JIC is staffed by personnel trained to conduct Public Information activities,
including coordinating inter-jurisdictional media releases and management of rumor control and
community communications functions. Regardless of where the JIC is established, Public Information
functions will continue to be centrally managed from the EOC, when activated.
10.0 C ONTINUITY OF G OVERNMENT
Continuity of Government (COG) is an essential function of emergency management and is vital during an
emergency/disaster situation. Continuity of government is defined as the preservation, maintenance, or
reconstitution of the civil government's ability to carry out its constitutional responsibilities. All levels of
government share a constitutional responsibility to preserve the life and property of their citizens. The
California Government Code and the Constitution of California provide the authority for state and local
government to reconstitute itself in the event incumbents are unable to serve.
A major emergency or disaster could result in great loss of life and property, including the death or injury
of key government officials. At the same time, there could be partial or complete destruction of
established seats of government, and the destruction of public and private records essential to continued
operations of government and industry.
In the aftermath of a major emergency, law and order must be preserved and essential government
services must be maintained. To this end, it is particularly essential that local units of government continue
to function.
10.1 Continuity Planning
Disasters or major emergencies have the potential to disrupt or interrupt critical and essential City
services that are vital to the health and welfare of its residents. Planning for such possibilities addresses
the continuation of government and succession of officers.
10.2 Line of Succession
The lines of succession for essential City positions are listed below. These individuals will assume
authority until relieved. This list does not include all City departments.
38
Primary City Position Alternate
Mayor o Vice Mayor
City Manager o Assistant City Manager
City Attorney o Assistant City Attorney
Director Planning and Development
o Assistant Director Planning & Community
o Environment Chief Building Official
Police Chief
o Assistant Chief of Police
o Police Captains
Fire Chief
o Deputy Fire Chief, Operations
o Deputy Fire Chief, Administration
OES Chief o Emergency Services Coordinator
Public Works Director
o Assistant Director
o Assistant Director Sustainability Climate Action
Director Information Technology/Chief
Information Officer
o Manager Information Technology
Chief Financial Officer
o Assistant Director Administrative Services
City Clerk o Deputy City Clerk
Director Community Services o Assistant Director Community Services
Director of Utilities o Utilities Chief Operating Officer
City Council o Emergency Standby Council
10.3 Essential Facilities-Alternate Government Facilities
In the event an alternate location is needed to perform the day-to-day governmental functions, staff will
be notified to report to one of several identified governmental facility locations, or other remote locations,
where those functions can be carried out. Based upon current conditions and situation status, the
alternate location will be determined by the department head or senior City official.
City of Palo Alto
Emergency Operations Plan
39
10.4 Preservation of Vital Records
City leadership will require certain vital records during a disaster. Vital Records are the documents
required to continue the mission of City departments and agencies during and after a disaster. The records
will assist in providing services both to internal City departments and external customers, such as citizens,
contractors, other government entities. Example documents may include:
• Public Records
• Computer system back-ups/servers
• Order of Succession Ordinances or Resolutions
• Plans, policies, and procedures for critical processes
• Payroll information
• Contracts and leases
• Legal and financial records
• Insurance documents
Protection of, and access to, these and other vital records requires planning and is coordinated by the
Palo Alto City Clerk. Each City department is responsible for identifying vital records, coordinating with
the City Clerk, and assigning internal responsibility for their preservation. Internet and server/client-based
software systems also serve as vital records because of the data they host. These systems also require a
similar level of planning for remote access as well as system interruptions.
1 1 .0 P LAN D EVELOPMENT AND M AINTENANCE
The OES has delegation of authority by City Manager to review, revise, manage, and distribute the EOP.
The Chief may delegate this assignment to another public safety staff member or members.
The EOP’s Basic Plan is subject to periodic formal approval by the City Council, whereas the Annexes are
revised as needed and are not subject to formal review and City Council approval.
The EOP Basic Plan will be reviewed every five years by the City’s Office of Emergency Services. The Basic
Plan may be modified at any time because of a post-incident or post-exercise evaluation, or changes in
responsibilities, laws, guidance, or regulations. Changes to the Basic Plan would require readoption by the
City Council.
40
G LO SSARY AND A BBREVIATIONS
Activate: At a minimum, a designated official of
the emergency response agency that implements
SEMS as appropriate to the scope of the
emergency and the agency’s role in response to
the emergency.
ADA: American with Disabilities Act
After Action Report (AAR): A report covering
response actions, application of SEMS,
modifications to plans and procedures, training
need, and recovery activities. After action reports
are required under SEMS after any emergency
that requires a declaration of an emergency.
Reports are required within 90 days.
Agency: An agency is a division of government
with specific function, or a non-governmental
organization (e.g., private contractor, business,
etc.) which offers a particular kind of assistance. In
ICS, agencies are defined as jurisdictional (having
statutory responsibility of incident mitigation); or
assisting by providing resources.
Agency Representative: An individual assigned to
an incident or to an EOC from an assisting or
cooperating agency who has delegated authority
to make decisions on matters affecting that
agency’s participation at the incident or at the
EOC.
American Red Cross: A nationwide volunteer
agency that provides disaster relief to individuals
and families.
Available Resources: Incident-based resources
that are available for immediate assignment.
Cal OES: The California Governor’s Office of
Emergency Services.
Care and Shelter: A phase of operations that
meets the food, clothing, and shelter needs of
people on a mass care basis.
CBO: Community based organization
CDAA: California Disaster Assistance Act
CERT: Community Emergency Response Team – a
volunteer group organized by a local government
to assist during an emergency and/or disaster.
Chain of Command: A series of management
positions in order of authority.
Continuity of Government (COG): All measures
that may be taken to ensure the continuity of
essential functions of governments in the event of
emergency conditions, including line-of-
succession for key decision makers.
COOP: Continuity of Operations Plan
Coordination: The process of systematically
analyzing a situation, developing relevant
information, and informing appropriate command
authority of viable alternatives for selection of the
most effective combination of available resources
to meet specific objectives.
Cultural competence: The ability to understand,
value, communicate with, and effectively interact
with people across cultures to ensure that the
needs of all community members are addressed,
with priority given to “culturally diverse
communities.” “Cultural competence” includes,
but is not limited to, being respectful and
responsive to the cultural and linguistic needs of
diverse population groups.
Culturally diverse communities: Includes, but is
not limited to, race and ethnicity, including
indigenous peoples, communities of color, and
immigrant and refugee communities; gender,
including women; age, including the elderly and
youth; sexual and gender minorities; people with
disabilities; occupation and income level including
low-income individuals and the unhoused;
education level; people with no or limited or no
English language proficiency; as well as geographic
location.
Damage Assessment: The process utilized to
determine the magnitude of damage and the
unmet needs of individuals, businesses, the public
City of Palo Alto
Emergency Operations Plan
41
sector, and the community caused by a disaster or
emergency event.
Dam Failure: Part or complete collapse of a dam
causing downstream flooding.
Declaration: The formal action by the President to
make a State eligible for major disaster or
emergency assistance under the Robert T.
Stafford Disaster Relief and Emergency Assistance
Act, PL 3-288, as amended (the Stafford Act).
Declaration Process: When a disaster strikes, local
authorities and individuals request help from
private relief organizations and their State
government, which give all assistance possible. If
assistance is beyond their capability, the Governor
requests a Presidential declaration of a major
disaster or an emergency.
Delegation of Authority: A statement provided to
the Incident Commander by the Agency Executive
delegating authority and assigning responsibility.
The Delegation of Authority can include
objectives, priorities, expectations, constraints
and other considerations or guidelines as needed.
Department Operations Center (DOC): A location
used by a distinct discipline, such as fire, medical,
hazardous materials, or a unit, such as
Department of Public Works, Department of
Health, or local water district to manage and
coordinate their departmental response functions
in a disaster. Department operations centers may
be used at all SEMS levels above the field
response level, depending upon the impact of the
emergency.”
Disaster: A sudden calamitous emergency event
bringing great damage loss or destruction.
DSW: Disaster Service Worker [CA Gov code 3100
– 3109]
Emergency: A condition of disaster or of extreme
peril to the safety of persons and property caused
by such conditions as air pollution, fire, flood,
hazardous material incident, storm, epidemic,
riot, drought, sudden and severe energy shortage,
plant or animal infestations or disease, the
Governor’s warning of an earthquake or volcanic
prediction, or an earthquake or other conditions.
EOC Action Plan (EAP): Similar to an IAP;
developed by the Planning Section to provide
operational planning direction for the EOC.
EMS: Emergency Medical Service
Emergency Operations Center (EOC): A location
from which centralized emergency management
can be performed. EOC facilities are established
by an agency or jurisdiction to coordinate the
overall agency or jurisdictional response and
support to an emergency.
Emergency Operations Plan (EOP): The plan that
each jurisdiction has and maintains for responding
to relevant threats and hazards that defines the
emergency management organization, structure,
and coordination.
Essential Facilities: Facilities that are essential for
maintaining the health, safety, and overall
wellbeing of the public following a disaster (e.g.,
hospitals, police and fire department buildings,
utility facilities, etc.). May also include buildings
that have been designated for use as mass care
facilities (e.g., schools, churches, etc.).
Evacuation: Organized, phased, and supervised
withdrawal, dispersal, or removal of people from
dangerous or potentially dangerous areas, and
their reception and care in safe areas.
Exercise: Maneuver or simulated emergency
condition involving planning, preparation, and
execution; carried out for the purpose of testing,
evaluating, planning, developing, training, and/or
demonstrating emergency management systems
and individual components and capabilities, to
identify areas of strength and weakness for
improvement of an emergency operations plan
(EOP).
FBO: Faith based organization.
Federal: Of or pertaining to the Federal
Government of the United States of America.
42
Federal Emergency Management Agency (FEMA):
This agency was created in 1979 to provide a
single point of accountability for all Federal
activities related to disaster mitigation and
emergency preparedness, response, and recovery.
First Responder: This term refers to individuals
whose organizations specific and primary
responsibility is to respond to life safety incidents.
Hazard: Natural or man-made source of danger or
difficulty to people or property.
Hazardous Material (Hazmat): A substance or
combination of substances, which, because of
quantity, concentration, physical, chemical,
radiological, explosive, or infectious
characteristics, poses a potential danger to
humans or the environment. Generally, such
materials are classed as explosives and blasting
agents, flammable and nonflammable gases,
combustible liquids, flammable liquids and solids,
oxidizers, poisons, disease-causing agents,
radioactive materials, corrosive materials, and
other materials including hazardous wastes.
Hazard Mitigation: A cost-effective measure that
will reduce the potential for damage to a facility
from a disaster event.
Hazard Mitigation Plan (HMP): The plan resulting
from a systematic evaluation of the nature and
extent of vulnerability to the effects of natural
hazards, including the actions needed to minimize
future vulnerability to identified hazards.
HSEEP: Homeland Security Exercise and
Evaluation Program
Incident: An occurrence or event, either human-
caused or by natural phenomena that requires
action by emergency response personnel to
prevent or minimize loss of life or damage to
property and/or the environment.
Incident Action Plan (IAP): The plan developed at
the field response level that contains objectives
reflecting the overall incident strategy and specific
tactical actions and supporting information for the
next operational period. The plan may be oral or
written.
Incident Commander (IC): The individual
responsible for the command of all functions at
the field response level located at the ICP
(Incident Command Post).
Incident Command System (ICS): The nationally
used standardized on-scene emergency
management concept specifically designed to
allow its user(s) to adopt an integrated
organizational structure equal to the complexity
and demands of single or multiple incidents
without being hindered by jurisdictional
boundaries. ICS is the combination of facilities,
equipment, personnel, procedures, and
communications operating within a common
organizational structure, with responsibility for
the management of resources to effectively
accomplish stated objectives pertinent to an
incident.
Joint Information Center (JIC): A facility
established to coordinate all incident-related
public information activities. It is the central point
of contact for all news media at the scene of the
incident. Public information officials from all
participating agencies should collocate at the JIC.
Joint Information System (JIS): Integrates incident
information and public affairs into a cohesive
organization designed to provide consistent,
coordinated, timely information during crisis or
incident operations. The mission of the JIS is to
provide a structure and system for developing and
delivering coordinated interagency messages;
developing, recommending, and executing public
information plans and strategies on behalf of the
IC; advising the IC concerning public affairs issues
that could affect a response effort; and controlling
rumors and inaccurate information that could
undermine public confidence in the emergency
response effort.
Jurisdiction: The range or sphere of authority.
Public agencies have authority at an incident
related to their legal responsibilities and authority
for incident mitigation. Jurisdictional authority at
City of Palo Alto
Emergency Operations Plan
43
an incident can be political/ geographical (e.g.,
special district city, county, state, or federal
boundary lines), or functional (e.g., police
department, health department, etc.)
Local Emergency: The duly proclaimed existence
of conditions of disaster or of extreme peril to the
safety of persons and property within the
territorial limits of a county, city and county, or
city, caused by such conditions as air pollution,
fire, flood, storm, epidemic, riot, or earthquake or
other conditions, other than conditions resulting
from a labor controversy, which conditions are or
are likely to be beyond the control of the services,
personnel, equipment, and facilities of that
political subdivision and required the combined
forces of political subdivisions to combat.
Logistics: Providing resources and other services
to support incident management.
Mitigation: Pre-event planning and actions that
aim to lessen the effects of potential disaster.
Mutual Aid Agreement: Written agreement
between agencies and/or jurisdictions in which
they agree to assist one another upon request, by
furnishing personnel and equipment.
Mutual Aid Region: A subdivision of Governor’s
Office of Emergency Services established to assist
in the coordination of Mutual Aid and other
emergency operations within a geographic area of
the state, consisting of two or more county
(operational) areas. Sonoma County is in Mutual
Aid Region II.
National Incident Management System (NIMS): A
system mandated by HSPD-5 that provides a
consistent nationwide approach for Federal, State,
local, and tribal governments; the private-sector,
and nongovernmental organizations to work
effectively and efficiently together to prepare for,
respond to, and recover from domestic incidents,
regardless of cause, size, or complexity. To
provide for interoperability and compatibility
among Federal, State, tribal, and local capabilities,
the NIMS includes a core set of concepts,
principles, and terminology. HSPD-5 identifies
these as the ICS; Multi-agency Coordination
Systems; training; identification and management
of resources (including systems for classifying
types of resources); qualification and certification;
and the collection, tracking, and reporting of
incident information and incident resources.
National Response Framework (NRF): A plan
mandated by HSPD-5 that integrates Federal
domestic prevention, preparedness, response,
and recovery plans into one all- discipline, all-
hazards plan.
NWS: National Weather Service
Nongovernmental Organization (NGO): An entity
with an association that is based on interests of its
members, individuals, or institutions and that is
not created by a government but may work
cooperatively with government. Such
organizations serve a public purpose, not a private
benefit. Examples of NGOs include faith-based
charity organizations and the American Red Cross.
Office of Emergency Services: an office that
coordinates emergency response and
management and resource support either at the
local, county, or state level. This office may also
be referred to as Emergency Management
Department (EMD) or Department of Emergency
Management (DEM) or Office of Emergency
Management (OEM).
Operational Area: An intermediate level of the
state emergency organization, consisting of a
county and all political subdivisions within the
county’s geographic borders. An operational area
is defined in law (Section 8559, California
Government Code) as an organization (not a
jurisdiction) whose boundaries are those of a
county. This organization is not necessarily a
county government; it could be several cities, or a
city and a county, a county government, or several
county governments, willing to undertake to
coordinate the flow of Mutual Aid and
information within the defined area. The
operational area concept is the backbone of
SEMS.
44
Plan: As used by OES, a document that describes
the broad, overall jurisdictional response to
potential extraordinary emergencies or disasters.
Preparedness: The range of deliberate, critical
tasks and activities necessary to build, sustain,
and improve the operational capability to prevent,
protect against, respond to, and recover from
domestic incidents. Preparedness is a continuous
process. Preparedness involves efforts at all levels
of government and between government and
private- sector and nongovernmental
organizations to identify threats, determine
vulnerabilities, and identify required resources.
Within the NIMS, preparedness is operationally
focused on establishing guidelines, protocols, and
standards for planning, training and exercises,
personnel qualification and certification,
equipment certification, and publication
management.
Prevention: Actions to avoid an incident or to
intervene to stop an incident from occurring.
Prevention involves actions to protect lives and
property. It involves applying intelligence and
other information to a range of activities that may
include such countermeasures as deterrence
operations; heightened inspections; improved
surveillance and security operations;
investigations to determine the full nature and
source of the threat; public health and agricultural
surveillance and testing processes;
immunizations, isolation, or quarantine; and as
appropriate, specific law enforcement operations
aimed at deterring, preempting, interdicting, or
disrupting illegal activity and apprehending
potential perpetrators and bringing them to
justice.
Private Sector: Organizations and entities that are
not part of any governmental structure. It includes
for-profit and not-for-profit organizations, formal
and informal structures, commerce and industry,
and private voluntary organizations.
Public Information Officer (PIO): The individual at
field or EOC level that has been delegated the
authority to prepare public information releases
and to interact with the media. Duties will vary
depending upon the agency and SEMS level.
PAFD: Palo Alto Fire Department
PAPD: Palo Alto Police Department
Recovery: Activities traditionally associated with
providing Federal supplemental disaster recovery
assistance under a Presidential major disaster
declaration. These activities usually begin within
days after the event and continue after the
response activities cease. Recovery includes
individual and public assistance programs that
provide temporary housing assistance, grants and
loans to eligible individuals and government
entities to recovery from the effects of a disaster.
Resources: Personnel and equipment available, or
potentially available, for assignment to incidents
or to EOCs. Resources area described by kind and
type and may be used in tactical support or
supervisory capacities at an incident or at EOCs.
Response: Activities to address the immediate
and short- term effects of an emergency or
disaster. Response includes immediate actions to
save lives, protect property and the environment,
stabilize communities, and meet basic human
needs following an incident. Based on the
requirements of the situation, response assistance
will be provided to an affected State under the
National Response Framework using a partial
activation of selected Emergency Support
Functions (ESF) or full activation of all ESF to meet
the needs of the situation.
Risk: Potential for an unwanted outcome resulting
from an incident, even, or occurrence, as
determined by its likelihood and associated
consequences.
Special District: A unit of local government (other
than a city, county, or city and county) with
authority or responsibility to own, operate or
maintain a project (as defined in California Code
of Regulations 2900(s) for purposes of natural
disaster assistance. This may include a joint
City of Palo Alto
Emergency Operations Plan
45
powers authority established under section 6500
et seq. of the Code.
Stafford Act: Robert T. Stafford disaster Relief and
Emergency Assistance Act, PL 100-707, signed into
law June 23, 1988; amended the Disaster Relief
Act of 1974, and the Sandy Recovery
Improvement Act of 2013.
Standard Operating Procedures (SOP): A set of
instructions having the force of a directive,
covering those features of operations that lends
themselves to a definite or standardized
procedure. Standard operating procedures
support an annex by indicating in detail how a
particular will be carried out.
Standardized Emergency Management System
(SEMS): A system required by California
Government Code for managing response to
multi-agency and multi-jurisdiction emergencies
in California. SEMS consists of five organizational
levels that are activated as necessary: Field
Response, Local Government, Operation Area,
Region, and State.
State of Emergency: The duly proclaimed
existence of conditions of disaster or of extreme
peril to the safety of persons and property within
the state caused by such conditions as air
pollution, fire, flood, storm, epidemic, riot,
TEP: Training and Exercise Plan – a plan that
outlines a schedule of emergency management
and related training courses for EOC and other
support staff as well as a calendar of scheduled
EOC and similar exercises.
THIRA: The Threat and Hazard Identification and
Risk Assessment is a three-step risk assessment
process that helps communities understand their
risks and what they need to do to address those
risks (FEMA).
Threat: An indication of possible violence, harm,
or danger.
Tsunami: Also called a seismic sea wave. It is a
large oceanic wave generated by earthquakes,
submarine volcanic eruptions, or large submarine
landslides in which sudden forces are applied to
the water mass.
Vulnerability: Physical feature or operational
attribute that renders and entity open to
exploitation or susceptible to a given hazard.
Tetra Tech, Inc. | Emergency & Disaster Management Unit
2301 Lucien Way, Suite 120 | Maitland, FL 32751
www.tetratech.com
1
March 31, 2025
City of Palo Alto
Office of City Auditor
Emergency Preparedness - Wildfire Audit
Contents
network of Baker Tilly International Ltd., the members of which are separate and independent legal entities. Baker Tilly US, LLP is a licensed CPA firm that
provides assurance services to its clients. Baker Tilly Advisory Group, LP and its subsidiary entities provide tax and consulting services to their clients and are
not licensed CPA firms.
EXECUTIVE SUMMARY .................................................................................................. 1
INTRODUCTION ............................................................................................................... 4
DETAILED ANALYSIS ..................................................................................................... 7
AUDIT RESULTS.............................................................................................................. 9
APPENDIX A MANAGEMENT RESPONSE MATRIX ......………………………………..25
Executive Summary
Purpose of the Audit
Baker Tilly Advisory Group, LP (Baker Tilly), in its capacity serving as the Office of the City Auditor
(OCA) for the City of Palo Alto (the City), conducted an Emergency Preparedness – Wildfire Audit
based on the approved Task Order 4.25. The objective of this audit was to determine whether the City
is working to prevent wildfire and adequately prepared to respond to wildfire as part of the City’s
emergency management plan.
Report Highlights
(Page 13) programs aimed to prevent and mitigate wildfire risks; we noted some
areas for improvement including enhancing community outreach and
engagement.
• The City of Palo Alto Utilities Department (CPAU) has made significant
investments to reduce wildfire risk:
o Undergrounding distribution lines – the City is in the process of
undergrounding its main distribution line in the Foothills high-risk area
to reduce the potential for wildfire caused by damaged or downed lines.
o Installing weather stations – to collect localized weather data to share
with first responders.
o Public Power Shutoff Procedure – provides guidance for when to de-
energize lines when needed to reduce wildfire risk and communicating
information to the public.
o Formalizing Utility Infrastructure Maintenance Program – CPAU is in
the process of formalizing its utility infrastructure maintenance program
which will help guide and prioritize the utilities maintenance efforts.
o Use of FLIR cameras – to detect electrical hotspots and areas that may
require maintenance.
• The City has several programs to address vegetation management and
improved tracking efforts may increase compliance:
o Line Clearance Program – this program is managed by the Urban
Forestry division of the Public Works Department in collaboration with
CPAU and ensures vegetation is cleared from electrical equipment and
utility lines. OCA noted areas to improve documentation of work
scheduled and performed and overall program guidance.
o Property inspections in the Wildland Urban Interface (WUI) help ensure
properties in high-fire danger areas are cleared of vegetation that could
potentially fuel a wildfire. OCA noted areas for improved tracking and
follow-up for properties that are in violation of the City’s code.
• While the City has partnered with CAL FIRE and is included in Santa Clara
County’s Community Wildfire Protection Plan, community involvement could
EXECUTIVE SUMMARY
wildfire resilience and promotes collaboration between residents, fire
departments and other stakeholders.
• Community education and outreach could be enhanced by policies and
procedures to guide efforts and track and measure their effectiveness.
Key Recommendations
We recommend the City consider the following improvements to enhance its wildfire
prevention efforts:
1. Continue efforts to underground Wildland Urban Interface (WUI) distribution
infrastructure and prioritize, as appropriate, maintenance and possible replacement of
the oldest utility poles should they remain in place.
2. Line Clearance policy documents should be established and or reviewed, updated
and finalized (e.g. Draft Tree and Landscape Technical Manual
3. Continue efforts to better track and monitor property violations in the WUI to
enhance enforcement.
4. Prioritize efforts to establish a Firewise Community including stakeholder
engagement throughout the process
5. Formalize the contract with CAL FIRE to ensure service provision continues into the
future.
6. Ensure wildfire education and outreach plans document coordination efforts
between the Office of Emergency Services (OES), Fire and CPAU to ensure
information is consistently and regularly provided to residents.
(Page 15)
Overall, the City has a strong emergency response plan but should consider if
improvements can be made to evacuation planning, after action report
recommendation implementation, and communication efforts.
• The City has a comprehensive set of emergency response and wildfire plans,
but should consider if evacuation plans could be enhanced and some plans
may require updating and review.
o Overall, OCA found that the City’s plans align with the majority of
Federal Emergency Management Agency (FEMA) guidance; however,
they would be strengthened by incorporating a more comprehensive
revision history and an enhanced review process to ensure that plans
are regularly reviewed and updated. In addition, while the Foothills Fire
Management Plan (FFMP) addresses evacuation routes and ensuring
these routes remain clear for emergency personnel as well as residents
for evacuation, we recommend the City consider additional planning
activities based on the U.S. Department of Homeland Security’s,
Planning Considerations: Evacuation and Shelter-in-Place; Guidance
.
EXECUTIVE SUMMARY
•
implemented a new sign-in process to improve tracking.
• While the City conducts training and after-action reports (AAR) after critical
incidents, efforts to track and implement resulting recommendations could be
improved.
• The City is enhancing its wildfire detection capabilities through the use of gas
monitoring sensors deployed in the Foothills area.
• The City employs several methods for communicating critical information to its
residents during an emergency and should continue to explore methods to
increase participation in the County’s emergency alerting system.
o Based on the alert system sign-up data provided and Santa Clara
County, 17% of Palo Alto residents were registered in the system in
2025.
• While the City has strong relationships with their mutual aid agreement
partners 1, the City does not maintain these agreements in a central repository
for easy tracking and monitoring.
Key Recommendations
We recommend the City consider the following improvements to enhance its Wildfire
response efforts:
1. The City’s emergency plans align with the majority of FEMA guidance; however,
they would be strengthened by incorporating a more comprehensive revision history
and an enhanced review process. The City should also review its evacuation plans
and consider if plans could be enhanced by reviewing best practices in other cities
such as establishing evacuation locations and sheltering agreements with neighboring
communities.
2. City management should more formally track and monitor findings and
recommendations identified during training exercises and in AARs of emergency
incidents to ensure needed improvements are made and issues are timely resolved.
3. Continue to explore ways to increase resident registration in the County’s
emergency alerting system. Opportunities may include partnering with schools,
homeowner associations, and local businesses to disseminate wildfire education
materials and encourage participation in City programs and the County’s emergency
alert system.
4. Determine an appropriate solution for staff to more easily access, track and monitor
the status of all mutual aid agreements, including active dates, renewal deadlines, and
responsible contacts for updates. For example, a centralized tracking system for
mutual aid agreements would provide clarity on the status of each agreement,
preventing lapses in mutual aid coverage and ensuring that expired agreements are
addressed promptly.
1 Mutual aid partners include Los Altos Hills, Santa Clara County, Woodside, Mountain View, and the California
Department of Forestry and Fire protection.
Introduction
The objective of this audit was to determine whether the City is working to
prevent wildfire and adequately prepared to respond to wildfire as part of the
City’s emergency management plan.
Background change, historical land management practices, human activities, and ecological
shifts, all of which impact cities like Palo Alto that are situated near high-risk
wildland-urban interface (WUI) zones. Climate change has intensified the state’s
wildfire risk by driving higher temperatures, wind speeds, and drier conditions,
which extend the fire season and increase the probability of fires. Historical land
management practices, including the suppression of indigenous fire
management techniques and aggressive fire suppression policies in the 20th
century, have led to an accumulation of vegetative fuels. Additionally, logging
practices have left denser forests prone to more intense fires. Human activities—
ranging from infrastructure failures to recreational fires—are the primary sources
of ignition, particularly as urban areas expand into WUI zones, increasing both
the human and economic impact of fires.
In response to wildfire risks, the City of Palo Alto’s Office of Emergency Services
(OES), Fire Department, and City of Palo Alto Utilities (CPAU) are all actively
engaged in wildfire preparedness, prevention, and response efforts, coordinating
resources and community education initiatives to address these risks. The City
works closely with CAL FIRE, regional partners, and neighboring cities to
implement and refine emergency response plans, ensure effective evacuation
routes, and conduct community outreach on wildfire preparedness. Recognizing
the need for a multifaceted approach to wildfire mitigation, the City supports
initiatives that promote sustainable land management practices, encourages
defensible space in WUI zones, and advocates for policies to reduce human-
caused ignitions. By fostering partnerships and promoting proactive wildfire
safety measures, Palo Alto is dedicated to enhancing the city’s resilience against
the growing threat of wildfires in California.
The following table provides an overview of the City’s various planning
documents related to wildfire preparedness and response, as well as their
purpose and when they were last updated.
INTRODUCTION
Table 1: City Emergency Preparedness Plans
Title Purpose Date
Emergency
Operations Plan
Basic Plan (EOP)
The EOP embraces the FEMA "whole community" approach. According to the
EOP, the City has undergone multiple hazard analysis processes per the FEMA
Comprehensive Preparedness Guide 201. The EOP also states the City actively
manages training activities and allocates funding in relation to fluctuating needs,
personnel turnover, and course availability.
January
2016*
Emergency
Operations Center
Manual (EOC)
The EOC wildland fire response is primarily addressed through the EOC
activation, the plan's emphasis extends beyond immediate response to a broader,
proactive strategy. According to the EOC the City prioritizes comprehensive
hazard analysis and ongoing training aligned with state and national standards
such as ICS, SEMS, and NIMS.
July
2021
Wildland Urban
Interface (WUI)
Fire Response
An annex to Palo Alto’s EOP, focusing on WUI fire response. It aligns with state
and national emergency management systems (SEMS and NIMS). The primary
goals are to guide initial response planning, support the development of incident
plans, and ensure coordinated interagency actions.
August
2023
Local Hazard
Mitigation Plan
(LHMP)
The LHMP is part of the larger Santa Clara Operational Area Hazard Mitigation
Plan and has a Palo Alto Annex. The LHMP details potential hazards for Palo Alto
and provides recommended action on the hazards.
October
2024
Foothills Fire
Management Plan
(FFMP)
The FFMP focuses on mitigating wildfire risks in the Foothills area through
targeted vegetation management and strategic planning. The document highlights
accomplishments since the initial 2009 plan, including improved evacuation routes,
prescribed burns, and reduced fire hazards near critical infrastructure. The update
emphasizes ongoing efforts like annual maintenance of treated areas,
collaboration with regional agencies, and leveraging funding opportunities. The
plan includes post-treatment fire behavior analysis, showcasing how vegetation
management efforts have improved emergency access and reduced the likelihood
of wildfire spread.
January
2017
CPAU Wildfire
Mitigation Plan
caused by electric lines and infrastructure. Key strategies include undergrounding
power lines in high-risk areas, such as the Foothills region, updating Public Safety
Power Shutoff (PSPS) protocols, enhanced vegetation management, and the use
of advanced technologies like non-expulsion fuses and remote deenergization
switches. The plan emphasizes collaboration with other departments, such as Fire
and Urban Forestry, to ensure comprehensive wildfire prevention efforts. Regular
inspections, vegetation clearance exceeding regulatory standards, and continuous
monitoring are highlighted as critical components. The plan includes performance
metrics to track the effectiveness of mitigation efforts, ensuring proactive
adjustments where needed.
June
2024
Santa Clara
County
Community
Wildfire Protection
Plan (CWPP)
The Santa Clara County CWPP aims to reduce wildfire risk by establishing
cooperative relationships with federal, state and local stakeholders before an
event occurs and developing pre-attack plans to enhance firefighter readiness and
safety. The CWPP includes annexes which offer information and project
recommendations specific to geographical planning areas. The City of Palo Alto is
included as an annex. Communities are currently updating their annex plans.
August 2016
INTRODUCTION
2 Government auditing standards require an external peer review at least once every three (3) years. The last peer review of the Palo Alto
Office of the City Auditor was conducted in 2017. The Palo Alto City Council approved a contract with Baker Tilly U.S., LLP for internal audit
services for October 2020 through June 2022 with an extension through June 2025. City Council appointed Kate Murdock, Audit Manager in
Baker Tilly’s Risk Advisory practice, as City Auditor in May 2024. As a result of transitions in the Audit Office and peer review delays due to
the COVID pandemic, an external peer review is targeted for 2025. It should be noted that Baker Tilly’s most recent firmwide peer review
was completed in October 2021 with a rating of “Pass”. The scope of that peer review includes projects completed under government
auditing standards. A report on the next firmwide peer review should be available later in 2024.
Scope The OCA evaluated the City’s plans and efforts related to wildfire prevention and
preparedness by assessing related activities and internal controls from FY2023
through FY2024 in the OES, Fire Department, and CPAU.
Methodology
• Interviewed the appropriate individuals to understand the roles and
responsibilities, processes, and controls related to Emergency Preparedness
(Wildfire) activities.
• Analyzed current policies and procedures (P&P) as well as FEMA and CAL
FIRE standards and best practices.
• Evaluated relevant documents such as City of Palo Alto EOC Manual, CPAU
Wildfire Mitigation Plan, FFMP, and various other plans
• Gathered information and reports to assess if current City plans are sufficient
in preventing and responding to wildfire risks.
• Inquired with OES departments for clarification and understanding of
emergency plans.
• Completed audit report of findings, conclusions, and recommendations based
on the supporting evidence gathered
Compliance
Statement accordance with generally accepted government auditing standards, except for
the requirement of an external peer review 2. Those standards require that we
plan and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
Organizational
Strengths demonstrated by the Emergency Preparedness team. We also observed their
willingness to provide and receive feedback regarding the emergency
preparedness process, which includes their receptiveness to process
improvements.
The OCA greatly appreciates the support of the Fire Department, Office of Emergency Services,
City Manager’s Office, and City of Palo Alto Utilities Department in conducting this audit.
Thank you!
DETAILED ANALYSIS
Detailed Analysis
Emergency
Preparedness &
Response
In its publication, Developing and Maintaining Emergency Operations Plans,
FEMA highlights five key areas for communities to address related to Emergency
Preparedness. These include:
• Prevention – reducing risk from human-caused incidents
• Protection – reducing or eliminating the threat to people and critical
infrastructure
• Response – actions taken in the immediate aftermath of an incident
• Recovery – short-term and long-term efforts for rebuilding and revitalizing
the affected community
• Mitigation – structural and non-structural approaches to eliminating or
limiting the hazards presence
This audit report focuses on the first three areas as they relate to the audit
objectives, but recognizes the City has efforts related to recovery and mitigation of
wildfire risks too.
Shared Community Preparedness themes
Additional best practice information comes from the National Incident Management
System (NIMS) and CAL FIRE. NIMS offers guidance on resource management,
mutual aid, and communication during emergency events. CAL FIRE provides
guidance and best practices for wildfire events specific to Fire Hazard Severity
Zones (FHSZ), further described below. Guidance from FEMA, NIMS, and CAL
FIRE all emphasize the importance of the following principles in preparing
communities for emergencies including wildfires. Common themes include:
• Community Engagement: Public education and participation are key to
ensuring communities are informed and involved.
• Response Coordination: Implementing reliable policies for consistent
response across agencies and stakeholders is key to NIMS ICS framework
and mutual aid strategies with FEMA’s planning and CAL FIRE’s
interagency collaboration.
• Training and Communication: Regular drills and clear communication
protocols are critical to ensure preparedness and efficiency during
emergencies.
FEMA offers additional guidance related to wildfire emergency preparedness.
FEMA's best practices, as highlighted in their publication Developing and
Maintaining Emergency Operations Plans. These best practices include:
• Risk Assessment and Planning: Conducting thorough risk assessments
to identify potential wildfire hazards and developing comprehensive
emergency plans that address these risks.
DETAILED ANALYSIS
•Public Information and Warning
information is provided to the public about wildfire risks, evacuation orders,
and safety measures.
NIMS offers important recommendations for departments handling wildfire
emergencies. These best practices include:
• Communication and Information Management: Implementing reliable
communication systems and protocols to ensure timely and accurate
information sharing during wildfire emergencies.
• Incident Command System (ICS): Utilizing the ICS to coordinate
response efforts and manage resources effectively during wildfires.
CAL FIRE offers comprehensive guidance related to wildfire emergency
preparedness. CAL FIRE's best practices provide essential recommendations for
departments handling wildfire emergencies. These best practices include:
• Fire Hazard Severity Zones (FHSZ): Identifying and mapping areas with
varying degrees of fire hazard severity to prioritize resources and mitigation
efforts.
• Evacuation Planning: Developing and regularly updating evacuation plans
to ensure that residents can safely and efficiently evacuate in the event of
wildfire.
Audit Results
City Efforts to Prevent and Protect from Wildfire
the City has
made significant
investments in
and has strong
programs aimed
to prevent and
mitigate wildfire
risks; we noted
some areas for
improvement
including
enhancing
community
outreach and
engagement.
neighboring jurisdictions to prevent and protect the City and its residents
from the risk of wildfire. These risk areas include utility infrastructure
maintenance, vegetation management, and community outreach and
education.
CPAU has made significant investments to reduce wildfire risk
CPAU provides electricity to the entire Palo Alto service area including the
Foothills/Wildland Urban Interface (WUI) Area and prepares and submits a
Wildfire Mitigation Plan to the California Wildfire Safety Advisory Board each
year. CPAU has invested in several projects to reduce wildfire risk including
undergrounding distribution lines and installing weather stations. The Utility
has also developed a Public Safety Power Shutoff (PSPS) procedure.
Undergrounding Distribution Lines
CPAU began the Foothills project to underground distribution lines in the
Foothills high-risk area in 2021. This project, which will be completed in
summer 2025, includes the undergrounding of approximately 49,200 feet of
distribution lines. The project includes undergrounding the main 12470-
voltage distribution line as well as fiber optic cable. Utility distribution lines
pose a significant wildfire risk and undergrounding these lines largely
eliminates this threat as lines cannot be damaged by trees or high winds
which can spark fires by falling on vegetation below.
Based on information provided by CPAU, much of the overhead
infrastructure within the Wildland Urban Interface (WUI), designated as the
High Fire Threat Tier 2 zone, encompassing all city areas west of Highway
280, known as the "Foothills Area" will be undergrounded.
As part of City’s wildfire mitigation strategy, CPAU has prioritized the
undergrounding of its overhead infrastructure in the WUI/Foothills Tier 2
area. The Foothill Fire Mitigation Project includes the following key activities:
• Substructure construction, including the installation of boxes and
pad-mounted equipment
• Cable pulling and line energization
• Decommissioning of overhead poles and equipment
According to CPAU, the Foothill Fire Mitigation Project is estimated to
underground 182 of the total of 203 poles and overhead lines in the high-risk
area. The estimated 21 remaining poles require additional coordination with
pole attachers, and customers prior to either undergrounding or
implementation of additional fire hardening measures. As of March 2025,
CPAU management reported it has completely de-energized and
undergrounded electric lines for 69 of the 182 poles, significantly reducing
the wildfire risk associated with overhead power lines in the area.
3 Red Flag Warning
removed as part of the initial Foothill Fire Mitigation Project.
Table 2: Age of Remaining Poles in WUI
*Analysis conducted by the OCA in March 2025
The OCA saw a range of estimates on how long utility poles can last,
anywhere from 35 to 75+ years depending on conditions and maintenance,
which suggests CPAU should prioritize maintenance and possible
replacement of the oldest poles should they remain in place.
Additionally, CPAU is implementing a multi-year Grid Modernization initiative
that will enhance grid resiliency and reliability of the electric distribution
system by replacing poles, transformers, aerial wires, some cabinets and
underground substructure. The initiative also includes upgrades to two of
their substations, with a target completion by 2032.
Weather Station Installation
CPAU installed weather stations in the Foothills area and at the Utility
Control Center to collect localized weather data which is shared with first-
responder departments to determine if any actions are needed due to
conditions. The Utility also monitors regional conditions and receives red flag
warnings which signal when fire conditions are heightened 3.
Public Safety Power Shutoff Procedure
CPAU has a Public Safety Power Shutoff procedure which provides
4 California Public Resources Code Section 4293
Residents in the Foothills area are notified via email when de-energization is
anticipated and are typically provided with dates and shutoff times.
Forward Looking Infrared (FLIR) Cameras
In addition to visual inspections, CPAU utilizes FLIR Cameras which are
used to detect hotspots where electrical equipment could be overheating
and treat areas before they become a problem. This use of technology helps
enable the City to proactively address maintenance issues.
The City has several programs to address vegetation management and
improved tracking of efforts may increase compliance
Wildfires and their spread are dependent on several conditions, such as fuel
load or the accumulation of vegetation, as well as weather conditions which
determine their severity. The City has several programs and resources
dedicated to managing vegetation including resident assistance programs.
These programs include:
• Line Clearance Program
• Right Tree Right Place
• Property Inspections in the Wildland Urban Interface
• Santa Clara Fire Safe Council CAL FIRE
Line Clearance Program
The City’s Line Clearance Program ensures vegetation is cleared from
electrical equipment and utility lines, patrol to ensure access roads to
facilities remain clear, and right-of-way clearing. The Program, typically
completed via a contract with the Fire Safe Council (FSC), is managed by
the operations division of the Public Works Department in the absence of a
contract with FSC and in collaboration with CPAU. The City’s aim is to
maintain a 10-foot clearance from trees in the Foothills area which is in
accordance with California law 4 and the California Public Utilities
Commission.
According to the City’s Tree Management Plan and interviews with staff, the
entirety of the Foothills area is inspected and cleared each year in the
Spring with a follow-up inspection conducted in the fall. Staff stated that they
have not experienced any resource constraints and major tree trimming
occurs every 3 to 4 years. Compliance is maintained in intervening years
through the biannual inspections and subsequent tree trimming. Tree
trimming activities are tracked using a software program called TreeKeeper.
Staff reported they do not currently track inspections but are working on how
to capture them as a work record in TreeKeeper. The table below shows
how many trees were trimmed in the Foothills area from 2021 to 2024.
Table 3: Number of Trees Trimmed in the
Foothills Area from 2021 to 2024*
*Data analysis conducted by OCA in October 2024
Urban Forestry staff provided the OCA with two guiding documents: Urban
Forest Master Plan and Draft Tree and Landscape Technical Manual. While
the Urban Forest Master Plan provides overall guidance and includes
information on the Line Clearance Program, the Draft Tree and Landscape
Technical Manual provides information on what equipment and what
environmental conditions to consider for conducting tree trimming to reduce
the risk of ignition due to maintenance activities. Staff said that the Manual is
intended as a supporting document to the City’s tree ordinance and its Fire-
Safe Landscapes section provides residents with tree and landscaping
guidance in support of creating a defensible space around one’s home
against wildfire risk.
The OCA noted that this draft manual did not appear to be complete. For
example, there were imbedded notes for staff to determine seasonal criteria
for tree trimming. Overall, while these documents provide good information,
they require updating, completion, and dissemination.
Right Tree Right Place Program
The Right Tree Right Place Program provides resources for residents with
trees that conflict with power lines. The program includes removing trees at
no cost, reimbursement for stump removal and reimbursement for replacing
trees with appropriate tree alternatives.
Property Inspections in the Wildland Urban Interface
The City’s Fire Marshal oversees fire safety inspections of businesses and
properties. These inspections ensure businesses and residents comply with
California Fire Code and keep properties clear of fuel that could increase the
risk of wildfire. When a property is found in violation of the Fire Code, they
are issued a “Notice of Violation” and typically given a month to make
reinspection fees incurred by the City. The City also adopts a Weed
Nuisance Abatement resolution annually and works in coordination with the
County of Santa Clara to address properties with weeds that are deemed a
nuisance and/or fire hazard.
Based on reports analyzed by the OCA, in 2023 there were 133 homes in
Palo Alto’s Wildland Urban Interface (WUI). Inspections were conducted for
104 of these homes and 86 of these passed the first inspection. However, it
appears that only 3 homes were reinspected and 26 homes had outstanding
violations at year-end. Management stated that this report needs to be
cleaned up and there may be less than 133 properties in the Palo Alto WUI.
In 2024, through the third quarter of the year, the City had performed 138
inspections in the WUI.
The City recently began using a new system to track fire inspections and
management reported they are working with the City’s Information
Technology Department to develop more robust reporting capabilities so the
Fire Marshal can more easily track metrics on how many violations have
been issued, how many have been corrected, how many referred to the fire
prevention bureau, etc.
With improved data tracking and reporting capabilities, the City will be able
to better and timelier follow-up with businesses and residents who are not in
compliance with the Fire Code and ensure wildfire risk is reduced.
Santa Clara Fire Safe Council
The City has a short-term contract with Santa Clara Fire Safe Council to
help with roadside clearance work, public education, and pursuing grant
opportunities. Staff stated that the City has introduced the Firewise program
in the past through the Fire Safe Council, but the program has not had much
traction and Palo Alto does not currently have a Firewise Community, a
program that must stem from the impacted residents. The Firewise USA®
program offers a structured approach for communities to enhance their
wildfire resilience and promotes collaboration between residents, fire
departments and other stakeholders. Establishing a Firewise program is also
recommended for Palo Alto in the Santa Clara County Community Wildfire
Protection Plan.
A core principle in Community Wildfire Protection Plans is to include as
many agency representatives and resident leaders in the planning process
as possible. The first goal in FEMA’s Creating a Community Wildfire
Protection Plan is to “Create fire-adapted communities” which includes
pursuing Firewise site recognition, providing information to the community
about fire safety, and reducing risks for home ignition. As stated in the
CWPP, the City should strongly consider working with the local Foothills
community to attain and maintain Firewise USA recognition.
CAL FIRE has provided assistance to the City over the past couple of years
in clearing out vegetation in the Foothills area and including some areas with
Eucalyptus trees. The City does not currently have a formal contract with
CAL FIRE for these services, however, this is something they should
consider ensuring for service provision in the future.
Community Education and Outreach could be improved.
While the City has implemented various programs and trainings to promote
the community's wildfire awareness and prevention efforts, there is room for
improvement. Currently, there is no comprehensive policy or set of
requirements established for the City's overall community outreach and
education efforts to ensure sufficient information and education are provided
to the residents for wildfire prevention and emergency preparedness. As a
result, the City's overall community outreach and education efforts are not
tracked to ensure goals are met.
Limited efforts to measure education and outreach effectiveness
According to management, community outreach and education
responsibilities are shared between Fire Prevention and OES and the
citywide communications team. Staff said efforts were tracked in the past,
but they lost the position responsible for this activity and there are currently
no P&P in place to guide the provision or tracking of education and outreach
efforts. Staff indicated that recent efforts have not been well attended by
residents, making it difficult to assess how engaged and prepared the
community is to prevent and respond to wildfires.
CPAU also performs community education and outreach activities and
includes wildfire information as part of its regular communications with
customers. CPAU employs several methods for communicating with
customers including utility bill inserts, email newsletter, direct mail, social
media, and the CPAU website. While staff provided several examples of
wildfire education efforts, they indicated there is no policy or plan outlining
expectations or responsibilities for outreach and education efforts, how often
they should be performed and/or how to determine what information gets
shared. In accordance with State law, the Utility Wildfire Management Plan
is presented annually in a public meeting to the Utilities Advisory
Commission. Developing a guiding document with appropriate goals and
targets could help ensure the utility consistently communicates with
residents and could aid in tracking the effectiveness of these efforts over
time.
Some residents report a lack of wildfire preparedness education and a
desire for more information related to City prevention efforts
The City of Palo Alto’s Community Survey results from 2023 support the
observations above that the City could improve outreach efforts to
community members. When asked about the quality of Palo Alto’s fire
prevention and education services, 37% of respondents in 2023 answered
“don’t know”, 18% answered “fair” or “poor”, and 45% answered “good” or
nor is the sample size specific to the WUI region.
In 2022, CPAU’s study of Key Account Customers found that 40% indicated
being “very concerned” with future wildfires and a 2023 Residential Electric
Customer Satisfaction Study reported that the second most desired topic of
information (44%) is “what CPAU is doing to prepare for emergencies like
wildfires and earthquakes.”
The City’s Fire Department conducts annual property inspections in the WUI
to detect dangerous conditions that could contribute to or exacerbate wildfire
risk. As noted above, our analysis of the fire inspection log from 2023 shows
that 26 out of an approximate 133 homes in the WUI had outstanding
violations and in 2024 more than 74 homes had violations. Annually
doorhangers are provided to residents in this area. Additional measures
such as education, outreach, and fines may help to reduce violations by
informing residents of the dangers of excess vegetation and any
maintenance or prevention related resources available to them. The Fire
Department does maintain an online wildfire preparedness resource for
community members:
https://www.cityofpaloalto.org/Departments/Fire/Prepare-For-Wildfire-
READY-SET-GO.
Recommendation Wildfire prevention efforts:
1. Continue efforts to underground WUI distribution infrastructure and
prioritize, as appropriate, maintenance and possible replacement of the
oldest poles should they remain in place.
2. Line Clearance policy documents should be established and or reviewed,
updated and finalized (e.g. Draft Tree and Landscape Technical Manual)
3. Continue efforts to better track and monitor property violations in the WUI
to enhance enforcement.
4. Prioritize efforts to establish a Firewise Community including stakeholder
engagement throughout the process
5. Formalize the contract with CAL FIRE to ensure service provision
continues into the future.
6. Ensure wildfire education and outreach plans document coordination
efforts between OES, Fire and CPAU to ensure information is consistently
and regularly provided to residents.
Management
Response
Please see appendix for responses.
City Wildfire Response Plans
Overall, the City
has a strong
emergency
response plan
but should
consider if
improvements
could be made to
evacuation
planning, after
action report
recommendation
implementation,
and
communication
efforts.
mitigating wildfire risks by coordinating closely across its own departments—
such as the OES, Fire Department, CPAU, and Public Works—and with
neighboring jurisdictions. These risk areas include Planning, Training,
Detection, Communication, and Resources.
The City has a comprehensive set of emergency response and
wildfire plans, but the City should consider if evacuation plans
could be enhanced and some plans may require updating and
review
The City has several plans that all work in conjunction with each other to
ensure the City is prepared to response to various disasters and hazardous
conditions. In addition to internal plans, the City is part of Santa Clara
County’s Community Wildfire Protection Plan. We discuss several of the
plans guiding the City’s response approach, below.
The City has 6 plans related to wildfire.
• Overarching Emergency Operation Plans (EOP) which contains the
annexes Emergency Operations Center Manual (EOC),
• Local Hazard Mitigation Plan (LHMP),
• Foothills Fire Management Plan (FFMP),
• Wildland Urban Interface Fire Response (WUI), and
• CPAU Wildfire Mitigation, which is a wildfire plan for the City Utilities
Department.
•
The EOP adopted by city council on January 11, 2016, states that it follows
FEMA's "whole community" approach. The EOP in general follows the
format laid out by FEMA. The revision history and certification of biennial
review on the EOP are blank both on the EOP provided to auditor and on
the City website, indicating that the plan has not been updated or reviewed
in 8 years. The distribution section of the EOP does not adhere to FEMA's
recommended format, which specifies that this section should be presented
as a list. Management has identified that the EOP is currently undergoing
review and update in 2025.
In the EOC, wildland fire response is primarily addressed through the EOC
activation, the plan's emphasis extends beyond immediate response to a
broader, proactive strategy. According to the EOC, the City prioritizes
comprehensive hazard analysis and ongoing training aligned with state and
national standards such as ICS, SEMS, and NIMS.
The LHMP is part of the larger Santa Clara Operational Area Hazard
Mitigation Plan and has a Palo Alto Annex. The LHMP details potential
hazards for Palo Alto and provides recommended actions to prepare for
these hazards. This plan was recently adopted by the City Council in
The FFMP for Palo Alto focuses on mitigating wildfire risks in the Foothills
area through targeted vegetation management and strategic planning. The
document highlights accomplishments since the initial 2009 plan, including
improved evacuation routes, prescribed burns, and reduced fire hazards
near critical infrastructure. The update emphasizes ongoing efforts like
annual maintenance of treated areas, collaboration with regional agencies,
and leveraging funding opportunities. The plan includes post-treatment fire
behavior analysis, showcasing how vegetation management efforts have
improved emergency access and reduced the likelihood of wildfire spread.
There is a monthly meeting with OES, CSD Open Space Division, Fire
Marshal’s Office, Public Works Operations, and Utilities Engineering to
address and discuss current issues within the FFMP. The City is currently in
the process of updating this plan.
The WUI focuses on WUI fire response and provides a concept of
operations in the development of an effective and coordinated response to a
significant wildland urban interface (WUI) Fire. This provides direction for
city departments, community groups, and allied stakeholders ensuring
interagency coordination in accordance with the City’s EOP, the California
Emergency Services Act, the Standardized Emergency Management
System (SEMS), and the National Incident Management System (NIMS).
The CPAU Wildfire Mitigation plan focuses on minimizing the risk of wildfires
caused by electric lines and infrastructure. Key strategies include
undergrounding power lines in high-risk areas, such as the Foothills region,
enhanced vegetation management, and the use of advanced technologies
like non-expulsion fuses and remote deenergization switches. The plan
emphasizes collaboration with other city departments, such as the Fire
Department and Urban Forestry, to ensure comprehensive wildfire
prevention efforts. Regular inspections, vegetation clearance exceeding
regulatory standards, and continuous monitoring are highlighted as critical
components. The plan also includes a performance metrics framework to
track the effectiveness of these mitigation efforts, ensuring proactive
adjustments where needed.
Areas for Improvement
Overall, OCA found that the City’s plans align with the majority of FEMA
guidance; however, they would be strengthened by incorporating a more
comprehensive revision history and an enhanced review process to ensure
that plans are regularly reviewed and updated. In addition, while the FFMP
addresses evacuation routes and ensuring these routes remain clear for
emergency personnel as well as residents for evacuation, we recommend
the City consider the following enhancements based on Homeland
Security’s, Planning Considerations: Evacuation and Shelter-in-Place;
Guidance for State, Local, Tribal, and Territorial Partners, July 2019. This
guidance highlights the following responsibilities for local jurisdictions:
• Setting clear expectations for whole community partners through
education, training and information sessions,
•
the community,
• Identify evacuation shelters within the community and in other
communities working with those neighboring communities to
establish notification and operational procedures,
• Create pre-approved accessible messaging for rapid distribution
regarding incident and shelter in place or evacuation instructions,
• Have a continuity plan to help maintain response operations if
interrupted, and
• Provide real-time mapping and navigation routing systems through
Geographic Information System (GIS).
Homeland Security’s guide also highlights key lessons from past wildfire
emergencies that occurred in Los Angeles County, CA and Larimer County,
Colorado:
• Need for increased coordination for quicker incorporation of GIS
data into analysis
• Identification of the safest evacuation routes combined with the use
of multiple forms of communication to keep residents informed
regarding timing and location of evacuated areas.
• Use of a tiered evacuation approach
o First, direct residents out of an immediate impact zone to an
evacuation point, out of danger, where additional information
is provided,
o Second, if the danger is prolonged, direct residents from the
evacuation point to an evacuation center where water, food
and power resources are available to charge mobile devices,
and
o Third, if overnight or multi-day evacuation is necessary,
direct residents to shelters in nearby communities.
Training
The City monitors training requirements and compliance and
recently implemented a new sign-in process to improve tracking
Fire, OES, and Police all serve critical functions in emergency response with
different training requirements depending on their roles and responsibilities.
In terms of wildfire response training, the Fire Department provides wildfire
training through modules provided by Vector Solutions as part of an annual
fire safety refresher course, RT-130 which is required per the National
Wildfire Coordinating Group (NWCG) for designated positions for all
personnel assigned with Fireline duties. The training is completed before the
start of the Wildland season which typically runs from May to November but
can vary from year to year. A new QR check-in system may have resulted in
as of the writing of this report. There was a total of 77 employees signed up
and as of August 29th, 2024, 71 had completed the required training. Out of
the 6 who had not completed the training, five were due to workers’ comp or
medical issues. Management was unable to provide an explanation of why
the remaining employee’s training was not completed but noted that the
individual received follow-up training to ensure understanding of training
requirements and protocols. Management stated that a new check-in system
is now in place and will help the City more easily track training compliance in
the future.
The OES training primarily covers critical incident response, with minimal
emphasis on wildfires. Finally, the Police Department does not have specific
wildfire training. Instead, they focus on support roles during such incidents,
including using police speakers for warnings, directing traffic, and ensuring
clear roads.
After Action Reports (AAR)
According to The National Wildfire Coordinating Group (NWCG) AARs are
essential for wildland firefighters to learn from mistakes and capitalize on
successes. The objective of the AAR is to immediately identify these
successes and failures. Once they have been recognized, further
exploration allows the team to perfect its skills and be better prepared for
future endeavors. NWCG is a partnership of federal, state, tribal, and local
wildfire management agencies that work together to establish standardized
practices for wildland fire operations in the United States, its primary goal is
to enhance efficiency, safety, and effectiveness in wildland fire management
and response. The NWCG develops training programs, operational guides,
and policy frameworks to ensure consistent and coordinated wildfire
management across jurisdictions. It also serves as a central resource for
promoting best practices, improving interagency collaboration, and
supporting the professional development of fire personnel.
While the City conducts training and AARs after critical incidents,
efforts to track and implement resulting recommendations could be
improved
All the departments come together to engage in tabletop exercises for
training purposes. Departments also work together after critical emergency
incidents to conduct AARs to report their successes and improvement
opportunities. While some AAR recommendations have been implemented
others have not and staff said they do not formally track and monitor the
implementation of recommendations. Areas of improvement noted in training
exercises and in AARs cover various areas such as communication,
recovery and proper use of PPE.
Training Exercises
2024 XSC Readiness Drill
A drill hosted by the County of Santa Clara to provide pre-incident training
on bulldozer, hand crew, and helicopter operations during a wildfire. This
event was attended by county-wide OES departments. Areas of
improvement included:
• Creating clarity around the communications center and coordinating
the process and flow of mutual aid initial attack orders.
Vulcan Forge Tabletop Exercise
The City of Palo Alto Vulcan Forge Tabletop Exercise was intended to
discuss and validate existing procedures. The drill provided an opportunity
for City staff to exercise their role and gain a greater understanding of the
processes and procedures that will occur during wildfire response. Areas of
improvement included:
• The WUI ConOps is lacking specific procedures to reach those with
limited English proficiency or for people with disabilities, and others
with access and functional needs (DAFN)
• Participants didn’t appear to know how best to alert residents who
were experiencing power outages
• The WUI ConOps does not have a procedure for approving PIO to
disseminate to the public
• Define terms such as “mass care” vs. “sheltering” to create clear
understanding of evaluation points, centers, shelters, and the like
• Establish evacuation center and sheltering operation criteria, P&P
and train appropriate staff
• Current plans lack sufficient detail on recovery and relief efforts
• OES needs to create P&P for re-entry and re-population
After Action Reports
PAFD AAR Dish Fire
A fire of unknown origin started near the Stanford Hiking Dish Trail and the
PAFD responded to put out the fire. The fire was in an area of the dish
hiking trail that’s nearest the intersection of lower Reservoir Road and the
Stanford Hiking Dish Trail with the closest gate access being the Gerona
Gate. Areas of improvement included:
• There was a delay in dispatching mutual aid and additional hands-on
training was requested
• Proper PPE must always be worn when responding
OCA’s analysis of training exercise notes and AARs found areas of
improvement are often identified with suggestions for process
5 https://www.cityofpaloalto.org/Departments/Emergency-Services/Emergency-Preparedness
6 https://www.cityofpaloalto.org/Departments/Fire/Prepare-For-Wildfire-READY-SET-GO
monitor these findings and recommendations to better determine if they
should be implemented, what resources may be needed, and to establish an
appropriate timeline for implementation.
The City is enhancing its wildfire detection capabilities through the use
of gas monitoring sensors deployed in the Foothills area
Detection is crucial in wildfire emergencies because it enables early
response, reducing the spread and potential damage of fires by allowing for
quicker containment efforts. Early detection systems, such as remote
sensors and aerial surveillance, are vital for protecting communities and
natural resources, as they help agencies mitigate risks before fires escalate
to dangerous levels.
The City recently set up N5 Sensors which are an advanced gas monitoring
system designed to provide early alerts in the event of a wildfire. In a
collaborative program, the City is partnering with Stanford and Woodside,
with Stanford purchasing 25 N5 sensors and receiving an additional 25 at no
cost. Of these, Palo Alto will receive 12 sensors, while Woodside will receive
13. Each city will cover its own data expenses, estimated at $22,000 per city
for the first two years. Palo Alto received a grant from the Department of
Homeland Security to assist with the expenses. The Fire Safe Council will
handle the sensor installation and program management. Although N5
Sensors will not provide complete coverage across all areas, they are
strategically positioned to enhance early warning capabilities in high-risk
zones. Additionally, the City has explored the use of drones for monitoring,
but concerns over privacy, public perception, and restrictive municipal codes
have made their approval challenging.
Communication
The City employs several methods for communicating critical
information to its residents during an emergency and should continue
to explore methods to increase participation in the County’s
emergency alerting system
The City has established multiple communication channels such as the
City’s website, news releases, social media, and radio announcements to
remind residents of wildfire season and keep them informed of the City’s
events and emergency notifications. City web pages dedicated to general
emergency preparedness 5 and wildfire prevention include CAL FIRE’s
Ready-Set-Go 6 video, Palo Alto Wildfire Planning Map, evacuation
information, a link to sign up for Santa Clara County’s alerting system, and
other resources.
Palo Alto utilizes Everbridge, the mass notification system used throughout
Under California’s emergency management structure, each county operates
as an "Operational Area," giving it independent authority and responsibility
for issuing alerts and warnings within its jurisdiction. Santa Clara County has
been using Everbridge for several years, with trained personnel across
jurisdictions, including staff from Palo Alto’s OES and Police dispatch.
Everbridge is Palo Alto’s primary tool for sending mass alerts in wildfire
situations. There are two main response scenarios: First, if a fire breaks out
within Palo Alto’s jurisdiction, OES will issue an immediate alert after
assessing the fire's location and direction. Second, if a fire starts outside the
area but moves toward Palo Alto, they monitor and notify residents as
needed. Residents can "opt in" to receive these alerts by registering at
alertscc.org. Additionally, Everbridge includes an "all records" list, which
contains duplicates, and includes data from their reverse 911, purchased
cell phone records, white and yellow pages, and data from the prior system,
Blackboard. However, this “all records” list contains duplicates making it
difficult to determine the total number of residents signed up for the service.
For example, an individual might have their information listed in all records
noted above and each record lists them as a separate contact.
Based on the alert system sign-up data provided by Santa Clara County, the
percentage of Palo Alto residents signed up for alerts increased from 15% in
2023 and 2024 to 17% in 2025. Participation among other Santa Clara
County cities in 2025 ranges from 7% to 29%. Some cities may have more
or less of their population occupying WUI areas which may account for some
of the differences in emergency alert adoption.
The OCA recommends the City continue to explore ways to increase
resident participation in this program since it is the City’s primary
communication tool for reaching residents in an emergency.
Resources
The City has seven fire stations. Six fire stations are staffed full-time and the
seventh station provides seasonal coverage in the foothills region during
high-fire danger months. This seventh station is staffed through an interlocal
agreement with Losa Altos Hills and Santa Clara County which specifies a
rotational schedule to ensure coverage.
Mutual aid agreements are essential in wildfire management, enabling
communities to combine resources, expertise, and personnel across
jurisdictions for a more effective and rapid response to large-scale fires.
Wildfires spread quickly and can overwhelm local resources, making support
from neighboring cities, counties, and state agencies critical for containment
and suppression. These agreements establish protocols for communication,
resource sharing, and logistical coordination, which helps reduce response
times and enhances overall operational efficiency. FEMA and CAL FIRE
emphasize that such partnerships strengthen resilience by ensuring that
participating agencies are prepared to respond cohesively to the complex
challenges of wildfire emergencies.
Recommendation
partners, the City does not maintain these agreements in a central
repository for easy tracking and monitoring
Palo Alto has 5 mutual aid agreements for wildfire response, though some
require updates for ongoing effectiveness. The Station 8 agreement remains
active, providing 24/7 monitoring during wildfire season, while the Mutual
Threat Zone operating plan with CAL FIRE establishes guidelines for
resource usage and remains in force until a 30-day termination notice is
issued. Additionally, the agreement among Palo Alto, Santa Clara County,
and Los Altos Hills ensures the availability of nearby resources for
emergencies, continuing unless ended by a 30-day notice. The agreement
with Woodside, which expired sometime in 2019 had no specified end date,
according to the Deputy Fire Chief negotiations for a new contract are
currently underway. The mutual aid agreement with Mountain View is also
expired, though still honored by both cities. The OCA noted that these
agreements are not kept in a central repository which may make it difficult to
track and monitor the status of the agreements.
We recommend the City consider the following improvements to enhance its
Wildfire response efforts:
1. The City’s emergency plans align with the majority of FEMA guidance;
however, they would be strengthened by incorporating a more
comprehensive revision history and an enhanced review process. The City
should also review its evacuation plans and consider if plans could be
enhanced by reviewing best practices in other cities such as establishing
evacuation locations and sheltering agreements with neighboring
communities.
2. City management should more formally track and monitor findings and
recommendations identified during training exercises and in AARs of
emergency incidents to ensure needed improvements are made and issues
are timely resolved.
3. Continue to explore ways to increase resident registration in the County’s
emergency alerting system. Opportunities may include partnering with
schools, homeowner associations, and local businesses to disseminate
wildfire education materials and encourage participation in City programs
and the County’s emergency alert system.
4. Determine an appropriate solution for staff to more easily access, track
and monitor the status of all mutual aid agreements, including active dates,
renewal deadlines, and responsible contacts for updates. For example, a
centralized tracking system for mutual aid agreements would provide clarity
on the status of each agreement, preventing lapses in mutual aid coverage
and ensuring that expired agreements are addressed promptly.
7 CPAU contracts with a third-party vendor to conduct compliance inspections to ensure utility poles and
equipment are well maintained. Visual inspections are conducted annually and a detailed inspection every five
years. Every ten years, the vendor performs an “intrusive inspection” which can include drilling into the poles to
determine their condition. Lines and poles are rated using a 3-point scale from P1 (most serious and needing
immediate attention) to P3 (less urgent). Staff stated that poles rated with a P1 are remediated immediately,
however, the OCA could not assess the timeliness of response based on the reports provided.
Management
Response
Additional
Observation electric Grid Modernization Project, it does not have a formal maintenance
schedule that proactively anticipates and schedules maintenance as the
infrastructure ages. Instead, maintenance issues are addressed on an as
needed basis. Management stated that the Utility is currently behind
schedule in addressing line and pole maintenance due to resource
constraints but is on schedule to complete all Overhead and Underground
facility inspections for 2024.
The OCA has performed a general assessment of CPAU’s line and pole
maintenance program noting some areas for the City to consider. The OCA
analyzed pole data from the Utility’s pole inspection report 7 and noted that
approximately half of the City’s poles are over 40 years old, with some poles
dating back to the 1940’s. 545 of CPAU’s poles are 60 years old or older
and may present age-related maintenance issues. It should be noted that
many of these poles may be scheduled for replacement as part of the Grid
Modernization project.
In addition to the Utility’s pole inspection report, the OCA asked for example
inspection reports for individual pieces of equipment and poles. These
reports are entered into the CPAU Electric Equipment & Maintenance
Database. The audit team noted that for the example reports received, the
previous inspection dates on the forms appeared to be more than 10 years
ago. The OCA recommends the City consider implementing a formal
infrastructure maintenance program as part of its Grid Modernization efforts
to ensure ongoing timely inspection and maintenance in the future.
Appendix A: Management Response Matrix
1. Continue efforts to
underground WUI distribution
infrastructure and prioritize as
appropriate maintenance and
possible replacement of the
oldest poles should they remain
in place.
efforts should continue to underground and harden distribution
infrastructure within the high fire danger area. The City’s Utilities Wildfire
Mitigation Plan, updated and approved annually, prioritizes the
undergrounding of the City’s overhead infrastructure in the high fire
danger area on Arastradero Road. The first phase of the Foothill Fire
Mitigation Project will move powerlines underground and remove
approximately 182 of the total of 203 power poles and overhead
powerlines in the high-risk area. The estimated 21 remaining poles and
associated equipment require additional engineering and coordination
prior to additional fire hardening measures.
The Foothill Fire Mitigation Project includes substructure construction,
including the installation of boxes and pad-mounted equipment; Cable
pulling and line energization; Decommissioning of overhead poles and
equipment.
documents should be
established and or reviewed,
updated, and finalized (e.g.
Draft Tree and Landscape
Technical Manual)
Manual (TLTM), and the recent the public comment period on the
proposed revisions closed March 2025. Comments are under review and
a draft of the TLTM is scheduled for review with the Parks and
Recreation Commission, with a final version expected this year. Staff
agree and plan to establish a line clearing policy for trees and landscape
track and monitor property
violations in the WUI to
enhance enforcement
and at the time of this report has now fully implemented this tool. This
software, specifically designed for fire inspections, will improve
inspection management, including tracking and monitoring of properties
a Firewise Community including
stakeholder engagement
throughout the process
contract with the Fire Safe Council including cost estimates for roadside
clearance and public education resources, i.e. Firewise Community.
PAFD is seeking partnership with Woodside Fire Protection District and
Los Altos Hills Fire District to enhance our presence and efforts towards
public education and will support residents in the pursuit of participation
Finding 1: While the City has made significant investments in and has strong programs aimed to prevent and mitigate wildfire risks; we noted some
areas for improvement including enhancing community outreach and engagement.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
will work with local Foothills community to attain and maintain Firewise
CAL FIRE to ensure service
provision continues into the
future.
Agree understand that operationally this may not be feasible since it would add
administration obligations for an outside agency. The summer of 2025
will be the third year that CAL FIRE assists the City of Palo Alto with
hazardous fuel removal. CAL FIRE provides similar services for multiple
agencies in the county (San Jose, Morgan Hill) without a contract. Staff
will seek this formalization to ensure stability and continuity, though it
may be infeasible if CAL FIRE does not agree to a formal contract. CAL
and outreach plans document
coordination efforts between
Office of Emergency Services
(OES), Fire and CPAU to
ensure information is
consistently and regularly
provided to residents.
Agree Utilities, CMO departments. Staff will look to update the City’s existing plans and
hazard-specific annex documents ensuring communication of information
is consistent and timely, reflecting the practices in place.
The existing EOP identifies communication protocols and responsibilities
in the event of a disaster but could add details to formalize wildfire
preparedness and outreach. The leadership team reviews all scheduled
community events and engagement points on a monthly basis, including
educational events for seasonal events such as floods and wildfires.
A unified wildfire preparedness effort among departments to build
community awareness, offering tools and tips, and sharing online
resources already includes the following: annual door hangers, utility bill
inserts, general emergency services communications such as continued
promotion of AlertSCC, the City’s emergency alert system, annual test of
Alert SCC, and annual community presentations on wildfire
preparedness all available on the ‘Ready, Set, Go!” web resource
referenced in the report. Annually, OES and PAFD host public education
Finding 2: Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning,
training, after action report recommendation implementation, and communication efforts.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
with the majority of FEMA
guidance; however, they would
be strengthened by
incorporating a more
comprehensive revision history
and an enhanced review
process. The City should also
review its evacuation plans and
consider if plans could be
enhanced by reviewing best
practices in other cities such as
establishing evacuation
locations and sheltering
agreements with neighboring
the City’s published emergency plans are timely completed with revision
histories clearly documented, beginning with the current update of the
EOP underway.
The City has evacuation maps available on the OES website and all
public education materials and sessions advise residents of the location
and content of the resources. PAFD and OES continue to utilize
Genasys (formally Zonehaven) software that notifies residents in a
particular zone of evacuation warnings and orders related to natural and
human caused disasters: what is happening, where to evacuate, etc.
which also includes pre-approved messaging in the platform.
more formally track and monitor
findings and recommendations
identified during training
exercises and in emergency
incident AAR recommendations
to ensure needed
improvements are made and
issues are timely resolved
incidents, though the outcomes of these are tracked differently
depending on the nature of the incident or training. For tabletop
exercises, OES regularly conducts citywide AARs for training exercises
and incidents. OES reviews and follows-up on necessary improvements
identified in the AARs, however, to instill further rigor, OES will
implement a post-AAR process review every six months until resolution
of identified action items for final closure.
PAFD routinely conducts AARs following major incidents, which are then
reviewed by executive command staff. Depending on any identified areas
for improvement, such as further training or policy updates, the Deputy
Chief over operations is responsible for ensuring completion of
applicable follow-up steps including additional feedback to departments
increase resident registration in
the County’s emergency
alerting system (AlertSCC).
OES, Fire engagement, notification, and education activities and to increase
AlertSCC sign ups. This is prominent on many pages of the City’s
website, a recurring item in digital newsletters and printed outreach and
Finding 2: Overall, the City has a strong emergency response plan but should consider if improvements could be made to evacuation planning,
training, after action report recommendation implementation, and communication efforts.
Key Recommendation Concurrence
Responsible
Department(s) Action Plan
Target Date
(calendar year)
homeowner associations, and
local businesses to disseminate
wildfire education materials and
encourage participation in City
programs and the County’s
emergency alert system.
message provided at community events through tabling. An annual
AlertSCC test is scheduled citywide to encourage more registrations.
Staff agree that continuing to support participation in this program is
important, and will continue to promote AlertSCC registrations in various
City engagement efforts. Note that the City continues to be ahead when
compared to the Countywide 10% opt-in level. Last year, as a result of
communications efforts, over 7,000 City contacts opted into receive
emergency alerts. Furthermore, staff agree and will continue to partner
with schools, Palo Alto Neighborhoods, and local businesses to share
solution for staff to more easily
access, track and monitor the
status of all mutual aid
agreements, including active
dates, renewal deadlines, and
responsible contacts for
updates. For example, a
centralized tracking system for
mutual aid agreements would
provide clarity on the status of
each agreement, preventing
lapses in mutual aid coverage
and ensuring that expired
agreements are addressed
promptly.
Agree the CA Master Mutual Aid Agreement. This includes a list of mutual aid
response disciplines, coordinating agencies, and specific elements
included, e.g. fire & rescue, search and rescue, emergency
management, etc.
Although current mutual aid agreements for fire services are retained by
the Fire Department in current operations, staff agree that a central
repository of auto-aid agreements will be kept with emergency protocol
documentation as an appendix/reference document, for broader and
more ready accessibility in an emergency. A tracking system is not
needed as all auto aid agreements within Santa Clara County agencies
are current and have no expiration dates. Locally, the Santa Clara
County XSC Mutual Aid Plan is reviewed and updated annually.
San Mateo County fire chiefs are looking at the details of the mutual aid
agreements in the County to review operational impacts countywide. The
auto aid agreements with Woodside Fire Protection District and Menlo
Park Fire, both of which are in San Mateo County, do have end dates
November 3, 2025 www.paloalto.gov/wildland
City Council Meeting
Approval of 1) Community Wildfire
Protection Plan, 2) Emergency
Preparedness: Wildfire Audit
Report, and 3) Emergency
Operations Plan
Agenda Item #2
www.paloalto.gov/wildfire
Topics
•Emergency Operations Plan (EOP)
•Community Wildfire Protection Plan / Foothills Fire Mitigation Plan
•City Auditor Report: “Emergency Preparedness: Wildfire Audit Report”
Staff Presenters
•OES Chief Kenneth Dueker
•Fire Chief Stephen Lindsey
•City Auditor Kate Murdock
Please refer to Staff Report 2510-5338
2
Emergency Operations Plan (EOP)
Recommended Action: Adopt a Resolution
www.paloalto.gov/emergencyplans 3
Emergency Operations Plan (EOP)
•The Emergency Operations Plan (EOP) ”Basic
Plan” is the primary emergency planning
document.
•The EOP is an essential guidance document for
City staff, key partners, and the community.
•The City’s Office of Emergency Services (OES) is
responsible for the review, revision,
management, and distribution of the EOP.
•In accordance with Municipal Code Section
2.12.080, the EOP basic plan requires 1) review
by the Emergency Services Council (ESC) and Palo
Alto/Stanford Citizen Corps Council (CCC) and 2)
adoption by the City Council via resolution.
4
Community Wildfire Protection Plan (CWPP) /
Foothills Fire Management Plan FFMP
Recommended Action: Authorize City Manager to Sign
www.paloalto.gov/emergencyplans 5
Palo Alto’s Wildfire Situation
Define the “Wildland Urban Interface” (WUI):
•West of Foothill Expressway & Junipero Serra Blvd. to Skyline
•Includes Open Space & Parks –natural values
•200+ homes in City limits & Stanford land
•Neighboring cities/towns
•Several million sq. ft of commercial buildings & business
(Stanford Industrial Park)
•Infrastructure: utilities, communications
Standing Objectives:
•Prevent/mitigate fire (ignition, spread, consequences)
•Contain fire to less than 10 acres while also evacuating civilians
•Coordinate limited public safety resources
6
Community Wildfire Protection Plan
The 2025 update includes these primary components:
•Describes the planning environment
•Discusses actions taken since the previous update
•Provides an updated wildfire risk hazard assessment
•Recommends new fuel treatment actions
•Includes public education and outreach efforts →
Know when to go, don’t wait, Evacuate!
•Lists wildfire mitigation projects the City will
endeavor to complete
•Identifies vegetation treatment standards and
methods
7
Treatment Methods, Fuel Reduction
Defensible Space
Fuel management
practices
PAFD WUI Property
Inspections
•Goal is compliance
to reduce
community risk
Defensible Space:
•Your legal
responsibility and
in your self-interest
•Don’t make your
home a “lost
cause”
8
Evacuation Routes
Constraints:
•Narrow, mountain roads; terrain
•Responding fire apparatus conflict with
evacuees
•Communications: cell coverage, power
•Pets, livestock, large animals
•Jurisdictional complexity
Proactive Stance:
•Coordinate among first responders, rangers
•Encourage foothills residents to apply for
Firewise Community certification
•Continue to expand technology for early
warning & community awareness
9
Foothills Fire Early Warning
Current Regional Efforts
•AlertCalifornia.org camera network and other emerging
technology and tools
•N5 wildland smoke sensor network: partnership with
Stanford University and Woodside Fire District
Future Technology
•UAS (drones)
•Additional sensor deployments
•GIS (preplanning)
Wildfires require a multi-agency, multi-discipline approach to prevention, mitigation, response & recovery.
Technology can solve certain early detection challenges, but human organizations must also interoperate.
cameras.alertcalifornia.org
10
Palo Alto’s Wildfire Posture and Partnerships
•Station 8 was built at Foothills Park after the Liddicoat fire in 1985. Location is strategic for rapid
deployment of apparatus, equipment, and resources and mobilization of fire crews
•Operational during high fire season. Crews rotate monthly between County Central Fire and Palo Alto
Fire
•Utilities Wildfire Mitigation Plan adopted annually describes how the utility is to maintain and operate
electrical lines and equipment to mitigate wildfire risk posed by electric lines and equipment
•Hardening of systems: undergrounding of electricity lines and staging of
generators for all water pump stations
•Hills include Local Responsibility Areas
(LRA), State Responsivity Areas (SRA) and
Mutual Threat Zones. (MTZ)
•Regional training and tabletop exercises
with emergency response and utility
partners
11
City Auditor Report
Recommended Action: Approve
www.paloalto.gov/departments/city-auditor
12
13
Key Findings & Recommendations from Baker Tilly's Audit
Findings Recommendations
The City has made significant investments in and has
strong programs aimed to prevent and mitigate wildfire
risks but there is room for improvement including
enhancing community outreach and engagement.
•Prioritize maintenance &replacement of remaining
utility poles in WUI
•Update & finalize line clearance policy
•Better track & monitor WUI property violations
•Formalize contract with CAL FIRE
•Better coordinate education & outreach efforts of OES,
Fire & CPAU
The City has a strong emergency response plan but should
consider possible improvements to evacuation planning,
training, implementation of after-action report
recommendations and communication efforts.
•Incorporate a more comprehensive revision & review
process for emergency plans
•Formally track & monitor findings and
recommendations identified during training exercises
& after-action reports
•Increase resident registration in the County's
emergency alerting system
•Improve access,tracking & monitoring of mutual aid
agreements, expiration dates & key contacts
1
Recommendation
Staff recommend that the City Council
1.Adopt a resolution approving the City of Palo Alto Emergency Operations Plan
(EOP),
2.Approve the City of Palo Alto Community Wildfire Protection Plan (CWPP) and
authorize submittal to the County of Santa Clara, and
3.Approve the Emergency Preparedness: Wildfire Audit Report by the City Auditor
(as recommended by the Policy & Services Committee).
14
15