HomeMy WebLinkAbout2024-11-06 Policy & Services Committee Agenda PacketPOLICY AND SERVICES COMMITTEE
Special Meeting
Wednesday, November 06, 2024
Community Meeting Room & Hybrid
7:00 PM
Policy and Services Committee meetings will be held as “hybrid” meetings with the option to
attend by teleconference/video conference or in person. Information on how the public may
observe and participate in the meeting is located at the end of the agenda. The meeting will be
broadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto,
and streamed to Midpen Media Center https://midpenmedia.org.
VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/94618744621)
Meeting ID: 946 1874 4621 Phone: 1(669)900‐6833
PUBLIC COMMENTS
General Public Comment for items not on the agenda will be accepted in person for up to three
minutes or an amount of time determined by the Chair. General public comment will be heard
for 30 minutes. Additional public comments, if any, will be heard at the end of the agenda.
Public comments for agendized items will be accepted both in person and via Zoom for up to
three minutes or an amount of time determined by the Chair. Requests to speak will be taken
until 5 minutes after the staff’s presentation or as determined by the Chair. Written public
comments can be submitted in advance to city.council@CityofPaloAlto.org and will be provided
to the Council and available for inspection on the City’s website. Please clearly indicate which
agenda item you are referencing in your subject line.
PowerPoints, videos, or other media to be presented during public comment are accepted only
by email to city.clerk@CityofPaloAlto.org at least 24 hours prior to the meeting. Once received,
the Clerk will have them shared at public comment for the specified item. To uphold strong
cybersecurity management practices, USB’s or other physical electronic storage devices are not
accepted.
Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks,
posts, poles or similar/other types of handle objects are strictly prohibited; (2) the items do not
create a facility, fire, or safety hazard; and (3) persons with such items remain seated when
displaying them and must not raise the items above shoulder level, obstruct the view or
passage of other attendees, or otherwise disturb the business of the meeting.
CALL TO ORDER
PUBLIC COMMENT
Members of the public may speak inperson ONLY to any item NOT on the agenda. 13 minutes depending on
number of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard at
the end of the agenda.
ACTION ITEMS
1.Discussion and Recommendation on the Annual Legislative Guidelines and Legislative
Platform. CEQA Status – Not a Project
2.Office of the City Auditor Presentation of ADA Compliance Audit Report
FUTURE MEETINGS AND AGENDAS
Members of the public may not speak to the item(s)
ADJOURNMENT
PUBLIC COMMENT INSTRUCTIONS
Members of the Public may provide public comments to teleconference meetings via email,
teleconference, or by phone.
1. Written public comments may be submitted by email to city.council@cityofpaloalto.org.
2. For in person public comments please complete a speaker request card located on the
table at the entrance to the Council Chambers and deliver it to the Clerk prior to
discussion of the item.
3. Spoken public comments for agendized items using a computer or smart phone will
be accepted through the teleconference meeting. To address the Council, click on the link
below to access a Zoom‐based meeting. Please read the following instructions carefully.
You may download the Zoom client or connect to the meeting in‐ browser. If using
your browser, make sure you are using a current, up‐to‐date browser: Chrome 30 ,
Firefox 27 , Microsoft Edge 12 , Safari 7 . Certain functionality may be disabled in
older browsers including Internet Explorer. Or download the Zoom application onto
your smart phone from the Apple App Store or Google Play Store and enter in the
Meeting ID below.
You may be asked to enter an email address and name. We request that you
identify yourself by name as this will be visible online and will be used to notify you
that it is your turn to speak.
When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will
activate and unmute speakers in turn. Speakers will be notified shortly before they
are called to speak.
When called, please limit your remarks to the time limit allotted. A timer will be
shown on the computer to help keep track of your comments.
4. Spoken public comments for agendized items using a phone use the telephone number
listed below. When you wish to speak on an agenda item hit *9 on your phone so we
know that you wish to speak. You will be asked to provide your first and last name before
addressing the Council. You will be advised how long you have to speak. When called
please limit your remarks to the agenda item and time limit allotted.
CLICK HERE TO JOIN Meeting ID: 946‐1874‐4621 Phone: 1‐669‐900‐6833
Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public
programs, services and meetings in a manner that is readily accessible to all. Persons with
disabilities who require materials in an appropriate alternative format or who require auxiliary
aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at
(650) 329‐2550 (voice) or by emailing ada@cityofpaloalto.org. Requests for assistance or
accommodations must be submitted at least 24 hours in advance of the meeting, program, or
service.
California Government Code §84308, commonly referred to as the "Levine Act," prohibits an
elected official of a local government agency from participating in a proceeding involving a
license, permit, or other entitlement for use if the official received a campaign contribution
exceeding $250 from a party or participant, including their agents, to the proceeding within the
last 12 months. A “license, permit, or other entitlement for use” includes most land use and
planning approvals and the approval of contracts that are not subject to lowest responsible bid
procedures. A “party” is a person who files an application for, or is the subject of, a proceeding
involving a license, permit, or other entitlement for use. A “participant” is a person who actively
supports or opposes a particular decision in a proceeding involving a license, permit, or other
entitlement for use, and has a financial interest in the decision. The Levine Act incorporates the
definition of “financial interest” in the Political Reform Act, which encompasses interests in
business entities, real property, sources of income, sources of gifts, and personal finances that
may be affected by the Council’s actions. If you qualify as a “party” or “participant” to a
proceeding, and you have made a campaign contribution to a Council Member exceeding $250
made within the last 12 months, you must disclose the campaign contribution before making
your comments.
1 Regular Meeting November 06, 2024
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are
available for public inspection at www.CityofPaloAlto.org/agendas.
POLICY AND SERVICES COMMITTEESpecial MeetingWednesday, November 06, 2024Community Meeting Room & Hybrid7:00 PMPolicy and Services Committee meetings will be held as “hybrid” meetings with the option toattend by teleconference/video conference or in person. Information on how the public mayobserve and participate in the meeting is located at the end of the agenda. The meeting will bebroadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto,and streamed to Midpen Media Center https://midpenmedia.org.VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/94618744621)Meeting ID: 946 1874 4621 Phone: 1(669)900‐6833PUBLIC COMMENTSGeneral Public Comment for items not on the agenda will be accepted in person for up to threeminutes or an amount of time determined by the Chair. General public comment will be heardfor 30 minutes. Additional public comments, if any, will be heard at the end of the agenda.Public comments for agendized items will be accepted both in person and via Zoom for up tothree minutes or an amount of time determined by the Chair. Requests to speak will be takenuntil 5 minutes after the staff’s presentation or as determined by the Chair. Written publiccomments can be submitted in advance to city.council@CityofPaloAlto.org and will be providedto the Council and available for inspection on the City’s website. Please clearly indicate whichagenda item you are referencing in your subject line.PowerPoints, videos, or other media to be presented during public comment are accepted onlyby email to city.clerk@CityofPaloAlto.org at least 24 hours prior to the meeting. Once received,the Clerk will have them shared at public comment for the specified item. To uphold strongcybersecurity management practices, USB’s or other physical electronic storage devices are notaccepted.
Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks,
posts, poles or similar/other types of handle objects are strictly prohibited; (2) the items do not
create a facility, fire, or safety hazard; and (3) persons with such items remain seated when
displaying them and must not raise the items above shoulder level, obstruct the view or
passage of other attendees, or otherwise disturb the business of the meeting.
CALL TO ORDER
PUBLIC COMMENT
Members of the public may speak inperson ONLY to any item NOT on the agenda. 13 minutes depending on
number of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard at
the end of the agenda.
ACTION ITEMS
1.Discussion and Recommendation on the Annual Legislative Guidelines and Legislative
Platform. CEQA Status – Not a Project
2.Office of the City Auditor Presentation of ADA Compliance Audit Report
FUTURE MEETINGS AND AGENDAS
Members of the public may not speak to the item(s)
ADJOURNMENT
PUBLIC COMMENT INSTRUCTIONS
Members of the Public may provide public comments to teleconference meetings via email,
teleconference, or by phone.
1. Written public comments may be submitted by email to city.council@cityofpaloalto.org.
2. For in person public comments please complete a speaker request card located on the
table at the entrance to the Council Chambers and deliver it to the Clerk prior to
discussion of the item.
3. Spoken public comments for agendized items using a computer or smart phone will
be accepted through the teleconference meeting. To address the Council, click on the link
below to access a Zoom‐based meeting. Please read the following instructions carefully.
You may download the Zoom client or connect to the meeting in‐ browser. If using
your browser, make sure you are using a current, up‐to‐date browser: Chrome 30 ,
Firefox 27 , Microsoft Edge 12 , Safari 7 . Certain functionality may be disabled in
older browsers including Internet Explorer. Or download the Zoom application onto
your smart phone from the Apple App Store or Google Play Store and enter in the
Meeting ID below.
You may be asked to enter an email address and name. We request that you
identify yourself by name as this will be visible online and will be used to notify you
that it is your turn to speak.
When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will
activate and unmute speakers in turn. Speakers will be notified shortly before they
are called to speak.
When called, please limit your remarks to the time limit allotted. A timer will be
shown on the computer to help keep track of your comments.
4. Spoken public comments for agendized items using a phone use the telephone number
listed below. When you wish to speak on an agenda item hit *9 on your phone so we
know that you wish to speak. You will be asked to provide your first and last name before
addressing the Council. You will be advised how long you have to speak. When called
please limit your remarks to the agenda item and time limit allotted.
CLICK HERE TO JOIN Meeting ID: 946‐1874‐4621 Phone: 1‐669‐900‐6833
Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public
programs, services and meetings in a manner that is readily accessible to all. Persons with
disabilities who require materials in an appropriate alternative format or who require auxiliary
aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at
(650) 329‐2550 (voice) or by emailing ada@cityofpaloalto.org. Requests for assistance or
accommodations must be submitted at least 24 hours in advance of the meeting, program, or
service.
California Government Code §84308, commonly referred to as the "Levine Act," prohibits an
elected official of a local government agency from participating in a proceeding involving a
license, permit, or other entitlement for use if the official received a campaign contribution
exceeding $250 from a party or participant, including their agents, to the proceeding within the
last 12 months. A “license, permit, or other entitlement for use” includes most land use and
planning approvals and the approval of contracts that are not subject to lowest responsible bid
procedures. A “party” is a person who files an application for, or is the subject of, a proceeding
involving a license, permit, or other entitlement for use. A “participant” is a person who actively
supports or opposes a particular decision in a proceeding involving a license, permit, or other
entitlement for use, and has a financial interest in the decision. The Levine Act incorporates the
definition of “financial interest” in the Political Reform Act, which encompasses interests in
business entities, real property, sources of income, sources of gifts, and personal finances that
may be affected by the Council’s actions. If you qualify as a “party” or “participant” to a
proceeding, and you have made a campaign contribution to a Council Member exceeding $250
made within the last 12 months, you must disclose the campaign contribution before making
your comments.
2 Regular Meeting November 06, 2024
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are
available for public inspection at www.CityofPaloAlto.org/agendas.
POLICY AND SERVICES COMMITTEESpecial MeetingWednesday, November 06, 2024Community Meeting Room & Hybrid7:00 PMPolicy and Services Committee meetings will be held as “hybrid” meetings with the option toattend by teleconference/video conference or in person. Information on how the public mayobserve and participate in the meeting is located at the end of the agenda. The meeting will bebroadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto,and streamed to Midpen Media Center https://midpenmedia.org.VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/94618744621)Meeting ID: 946 1874 4621 Phone: 1(669)900‐6833PUBLIC COMMENTSGeneral Public Comment for items not on the agenda will be accepted in person for up to threeminutes or an amount of time determined by the Chair. General public comment will be heardfor 30 minutes. Additional public comments, if any, will be heard at the end of the agenda.Public comments for agendized items will be accepted both in person and via Zoom for up tothree minutes or an amount of time determined by the Chair. Requests to speak will be takenuntil 5 minutes after the staff’s presentation or as determined by the Chair. Written publiccomments can be submitted in advance to city.council@CityofPaloAlto.org and will be providedto the Council and available for inspection on the City’s website. Please clearly indicate whichagenda item you are referencing in your subject line.PowerPoints, videos, or other media to be presented during public comment are accepted onlyby email to city.clerk@CityofPaloAlto.org at least 24 hours prior to the meeting. Once received,the Clerk will have them shared at public comment for the specified item. To uphold strongcybersecurity management practices, USB’s or other physical electronic storage devices are notaccepted.Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks,posts, poles or similar/other types of handle objects are strictly prohibited; (2) the items do notcreate a facility, fire, or safety hazard; and (3) persons with such items remain seated whendisplaying them and must not raise the items above shoulder level, obstruct the view orpassage of other attendees, or otherwise disturb the business of the meeting.CALL TO ORDERPUBLIC COMMENT Members of the public may speak inperson ONLY to any item NOT on the agenda. 13 minutes depending onnumber of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard atthe end of the agenda.ACTION ITEMS1.Discussion and Recommendation on the Annual Legislative Guidelines and LegislativePlatform. CEQA Status – Not a Project2.Office of the City Auditor Presentation of ADA Compliance Audit ReportFUTURE MEETINGS AND AGENDASMembers of the public may not speak to the item(s)
ADJOURNMENT
PUBLIC COMMENT INSTRUCTIONS
Members of the Public may provide public comments to teleconference meetings via email,
teleconference, or by phone.
1. Written public comments may be submitted by email to city.council@cityofpaloalto.org.
2. For in person public comments please complete a speaker request card located on the
table at the entrance to the Council Chambers and deliver it to the Clerk prior to
discussion of the item.
3. Spoken public comments for agendized items using a computer or smart phone will
be accepted through the teleconference meeting. To address the Council, click on the link
below to access a Zoom‐based meeting. Please read the following instructions carefully.
You may download the Zoom client or connect to the meeting in‐ browser. If using
your browser, make sure you are using a current, up‐to‐date browser: Chrome 30 ,
Firefox 27 , Microsoft Edge 12 , Safari 7 . Certain functionality may be disabled in
older browsers including Internet Explorer. Or download the Zoom application onto
your smart phone from the Apple App Store or Google Play Store and enter in the
Meeting ID below.
You may be asked to enter an email address and name. We request that you
identify yourself by name as this will be visible online and will be used to notify you
that it is your turn to speak.
When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will
activate and unmute speakers in turn. Speakers will be notified shortly before they
are called to speak.
When called, please limit your remarks to the time limit allotted. A timer will be
shown on the computer to help keep track of your comments.
4. Spoken public comments for agendized items using a phone use the telephone number
listed below. When you wish to speak on an agenda item hit *9 on your phone so we
know that you wish to speak. You will be asked to provide your first and last name before
addressing the Council. You will be advised how long you have to speak. When called
please limit your remarks to the agenda item and time limit allotted.
CLICK HERE TO JOIN Meeting ID: 946‐1874‐4621 Phone: 1‐669‐900‐6833
Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public
programs, services and meetings in a manner that is readily accessible to all. Persons with
disabilities who require materials in an appropriate alternative format or who require auxiliary
aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at
(650) 329‐2550 (voice) or by emailing ada@cityofpaloalto.org. Requests for assistance or
accommodations must be submitted at least 24 hours in advance of the meeting, program, or
service.
California Government Code §84308, commonly referred to as the "Levine Act," prohibits an
elected official of a local government agency from participating in a proceeding involving a
license, permit, or other entitlement for use if the official received a campaign contribution
exceeding $250 from a party or participant, including their agents, to the proceeding within the
last 12 months. A “license, permit, or other entitlement for use” includes most land use and
planning approvals and the approval of contracts that are not subject to lowest responsible bid
procedures. A “party” is a person who files an application for, or is the subject of, a proceeding
involving a license, permit, or other entitlement for use. A “participant” is a person who actively
supports or opposes a particular decision in a proceeding involving a license, permit, or other
entitlement for use, and has a financial interest in the decision. The Levine Act incorporates the
definition of “financial interest” in the Political Reform Act, which encompasses interests in
business entities, real property, sources of income, sources of gifts, and personal finances that
may be affected by the Council’s actions. If you qualify as a “party” or “participant” to a
proceeding, and you have made a campaign contribution to a Council Member exceeding $250
made within the last 12 months, you must disclose the campaign contribution before making
your comments.
3 Regular Meeting November 06, 2024
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are
available for public inspection at www.CityofPaloAlto.org/agendas.
POLICY AND SERVICES COMMITTEESpecial MeetingWednesday, November 06, 2024Community Meeting Room & Hybrid7:00 PMPolicy and Services Committee meetings will be held as “hybrid” meetings with the option toattend by teleconference/video conference or in person. Information on how the public mayobserve and participate in the meeting is located at the end of the agenda. The meeting will bebroadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto,and streamed to Midpen Media Center https://midpenmedia.org.VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/94618744621)Meeting ID: 946 1874 4621 Phone: 1(669)900‐6833PUBLIC COMMENTSGeneral Public Comment for items not on the agenda will be accepted in person for up to threeminutes or an amount of time determined by the Chair. General public comment will be heardfor 30 minutes. Additional public comments, if any, will be heard at the end of the agenda.Public comments for agendized items will be accepted both in person and via Zoom for up tothree minutes or an amount of time determined by the Chair. Requests to speak will be takenuntil 5 minutes after the staff’s presentation or as determined by the Chair. Written publiccomments can be submitted in advance to city.council@CityofPaloAlto.org and will be providedto the Council and available for inspection on the City’s website. Please clearly indicate whichagenda item you are referencing in your subject line.PowerPoints, videos, or other media to be presented during public comment are accepted onlyby email to city.clerk@CityofPaloAlto.org at least 24 hours prior to the meeting. Once received,the Clerk will have them shared at public comment for the specified item. To uphold strongcybersecurity management practices, USB’s or other physical electronic storage devices are notaccepted.Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks,posts, poles or similar/other types of handle objects are strictly prohibited; (2) the items do notcreate a facility, fire, or safety hazard; and (3) persons with such items remain seated whendisplaying them and must not raise the items above shoulder level, obstruct the view orpassage of other attendees, or otherwise disturb the business of the meeting.CALL TO ORDERPUBLIC COMMENT Members of the public may speak inperson ONLY to any item NOT on the agenda. 13 minutes depending onnumber of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard atthe end of the agenda.ACTION ITEMS1.Discussion and Recommendation on the Annual Legislative Guidelines and LegislativePlatform. CEQA Status – Not a Project2.Office of the City Auditor Presentation of ADA Compliance Audit ReportFUTURE MEETINGS AND AGENDASMembers of the public may not speak to the item(s)ADJOURNMENTPUBLIC COMMENT INSTRUCTIONSMembers of the Public may provide public comments to teleconference meetings via email,teleconference, or by phone.1. Written public comments may be submitted by email to city.council@cityofpaloalto.org.2. For in person public comments please complete a speaker request card located on thetable at the entrance to the Council Chambers and deliver it to the Clerk prior todiscussion of the item.3. Spoken public comments for agendized items using a computer or smart phone willbe accepted through the teleconference meeting. To address the Council, click on the linkbelow to access a Zoom‐based meeting. Please read the following instructions carefully.You may download the Zoom client or connect to the meeting in‐ browser. If usingyour browser, make sure you are using a current, up‐to‐date browser: Chrome 30 ,Firefox 27 , Microsoft Edge 12 , Safari 7 . Certain functionality may be disabled inolder browsers including Internet Explorer. Or download the Zoom application ontoyour smart phone from the Apple App Store or Google Play Store and enter in theMeeting ID below.You may be asked to enter an email address and name. We request that youidentify yourself by name as this will be visible online and will be used to notify youthat it is your turn to speak.When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk willactivate and unmute speakers in turn. Speakers will be notified shortly before theyare called to speak.When called, please limit your remarks to the time limit allotted. A timer will beshown on the computer to help keep track of your comments.4. Spoken public comments for agendized items using a phone use the telephone numberlisted below. When you wish to speak on an agenda item hit *9 on your phone so weknow that you wish to speak. You will be asked to provide your first and last name beforeaddressing the Council. You will be advised how long you have to speak. When calledplease limit your remarks to the agenda item and time limit allotted.CLICK HERE TO JOIN Meeting ID: 946‐1874‐4621 Phone: 1‐669‐900‐6833Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its publicprograms, services and meetings in a manner that is readily accessible to all. Persons withdisabilities who require materials in an appropriate alternative format or who require auxiliary
aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at
(650) 329‐2550 (voice) or by emailing ada@cityofpaloalto.org. Requests for assistance or
accommodations must be submitted at least 24 hours in advance of the meeting, program, or
service.
California Government Code §84308, commonly referred to as the "Levine Act," prohibits an
elected official of a local government agency from participating in a proceeding involving a
license, permit, or other entitlement for use if the official received a campaign contribution
exceeding $250 from a party or participant, including their agents, to the proceeding within the
last 12 months. A “license, permit, or other entitlement for use” includes most land use and
planning approvals and the approval of contracts that are not subject to lowest responsible bid
procedures. A “party” is a person who files an application for, or is the subject of, a proceeding
involving a license, permit, or other entitlement for use. A “participant” is a person who actively
supports or opposes a particular decision in a proceeding involving a license, permit, or other
entitlement for use, and has a financial interest in the decision. The Levine Act incorporates the
definition of “financial interest” in the Political Reform Act, which encompasses interests in
business entities, real property, sources of income, sources of gifts, and personal finances that
may be affected by the Council’s actions. If you qualify as a “party” or “participant” to a
proceeding, and you have made a campaign contribution to a Council Member exceeding $250
made within the last 12 months, you must disclose the campaign contribution before making
your comments.
4 Regular Meeting November 06, 2024
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are
available for public inspection at www.CityofPaloAlto.org/agendas.
Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Clerk
Meeting Date: November 6, 2024
Report #:2407-3241
TITLE
Discussion and Recommendation on the Annual Legislative Guidelines and Legislative Platform.
CEQA Status – Not a Project
RECOMMENDATION
Staff recommends that the Policy & Services Committee recommend that City Council approve
the 2025 Federal and State Legislative Guidelines.
BACKGROUND
As part of the City’s state and federal legislative advocacy program, staff and Townsend Public
Affairs, the City’s federal and state legislative advocates, work to identify and analyze potentially
impactful legislation and communicate the City’s public advocacy positions to legislators. The
program is guided by the Advocacy Process Manual1 and a City Council-approved set of
Legislative Guidelines2. The Guidelines provide direction to staff and the City’s legislative
advocates on issues that are important to the City Council and likely to become a legislative issue.
In consultation with the Mayor, staff use the Guidelines to respond to issues throughout the year.
These Guidelines allow for flexible and quick responses to emerging issues in the fast-paced
legislative environment without returning to the City Council each time an issue arises.
The Policy & Services Committee and subsequently the City Council adopt updated Guidelines
annually before the start of the new legislative year. Recommendations from tonight’s Policy &
Services Committee meeting will be taken to the City Council for discussion and adoption in
January 2025.
ANALYSIS
The draft 2025 Legislative Guidelines are included as Attachment A. Recommended updates are
marked in red. Updates reflect topics the City Council has expressed interest in and topics
1 Advocacy Process Manual: https://www.cityofpaloalto.org/files/assets/public/v/1/intergovernmental-
affairs/advocacy-manual-updated-jan-2020.pdf
2 City of Palo Alto’s 2024 Federal and State Legislative Guidelines:
https://www.cityofpaloalto.org/files/assets/public/v/1/city-manager/legislation/adopted-2024-legislative-
guidelines.pdf
Item 1
Item 1 Staff Report
Item 1: Staff Report Pg. 1 Packet Pg. 5 of 36
expected to be prominent in the upcoming legislative year. Some of the topics expected to have
legislative action include:
•expiring tax credits (low-income housing tax credit and child tax credit)
•potential reform to financing tools (tax increment financing and enhanced infrastructure
financing districts)
•possible re-authorization of the cap-and-trade program
•regional transportation ballot measure
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
Item 1
Item 1 Staff Report
Item 1: Staff Report Pg. 2 Packet Pg. 6 of 36
Page 1 of 4
The City of Palo Alto’s 20245 Federal and State Legislative Guidelines
Adopted January 22, 2024
These Guidelines reflect and activate the City Council’s priorities; they do not supplant them.
They work to guide staff and the City’s legislative advocates on issues that are important to the
City Council, and likely to become a legislative issue. These Guidelines are not rank-ordered and
are meant to allow for a flexible and quick response by staff and advocates, without the need to
return to the City Council to seek guidance. The Guidelines work in conjunction with the City
Council-approved Advocacy Process Manual and the City Council action to do “Strategic
Weighing in on Issues of Interest”1 (June 22, 2021 CMR 12344; Minutes). The City Council’s
annual priorities are also guidance for the City’s legislative platform.
The below Foundational Principles represent the ideals that form the core of the City’s policy
agenda. The Legislative Guidelines all rise from and strengthen four foundational principles:
1. Promote Local Fiscal Sustainability:
Support measures that promote fiscal stability, predictability, financial independence, and
preserve the City’s revenue base and maximum control over local government budgeting.
Also protect local revenue sources and prevent unfunded mandates.
2. Support Funding Opportunities:
Protect, seek, and increase funding for programs, projects, and services. Seek opportunities
that allow the City to compete for regional, state and federal funding. Support funding for
programs including, but not limited to, economic development, infrastructure investment,
housing, transportation projects (such as road improvements, rail grade separations,
bicycle and pedestrian safety, multi-modal transportation systems and transit-oriented
development), air quality, water quality and local water reliability, parks and recreation,
historic preservation, natural resources, hazard mitigation, public safety and public health.
3. Preserve Local Control:
Preserve and protect the City’s powers, duties, and discretion to enact and engage in local
processes and policy making concerning local affairs and oppose efforts and legislation
from state and regional bodies that preempt local authority and do not align with City
priorities. Advocate for longer lead times for implementation of new legislation that
adversely impacts Palo Alto. Oppose items that preempt or reduce the authority or ability
of local government to determine how to effectively operate local programs, services,
activities, and governance.
4. Protect the health and safety of the community:
Support policies and funding that enrich the quality of life for the Palo Alto community with
services that provide for a safe, fulfilling, and vibrant life. Support policies that promote
equity.
1 City Council, June 22, 2021; Agenda Item # 7; Staff Report # 12344
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?
id=81546&dbid=0&repo=PaloAlto
Item 1
Attachment A: Draft 2025
Federal and State
Legislative Guidelines
Item 1: Staff Report Pg. 3 Packet Pg. 7 of 36
Page 2 of 4
The City of Palo Alto’s 20245 Federal and State Legislative Guidelines
Adopted January 22, 2024
The Legislative Guidelines create the framework for organizing the City’s policy interests, while
guiding staff and contracted legislative advocateslobbyists in their advocacy efforts on behalf of
the City. The items below provide direction for the City’s efforts when addressing reasonable
government actions.
Item 1
Attachment A: Draft 2025
Federal and State
Legislative Guidelines
Item 1: Staff Report Pg. 4 Packet Pg. 8 of 36
Page 3 of 4
The City of Palo Alto’s 20245 Federal and State Legislative Guidelines
Adopted January 22, 2024
• Supports responsible processing of recyclables once removed from Palo Alto and other
communities, including promoting processing facilities and recyclables markets within
the United States
• Strengthens and modernizes the State and Local electric grids and grid capacity
• Supports the protection of our natural environment, including open space, trees/tree
canopy, and biodiversity
Financial
The City supports government action that:
• Supports the long-term stability of CalPERS and the ability of local governments to mitigate
and manage with flexibility its pension obligations
• Protects the funding sources for the sustainable delivery of City services
• Supports the continued deductibility of tax-exempt municipal bonds and the restoration of
Advance Refunding of Tax-Exempt Municipal Bonds
•Supports the continuance of tax credits available at the federal level to support low-
income individuals in achieving housing affordability and financial stability
• Supports the lowering or maintaining of voter thresholds for local revenue measures
• Supports maximum flexibility for local government in contracting and contract
negotiations
•Supports reforms to local revenue financing tools for the purpose of supporting the
development of affordable housing and public infrastructure
• Supports efforts to attract and retain resources for current and future smaller businesses
in Palo Alto
• Preserves local discretion in the assessment, collection, and usage of development fees
Governance, Transparency, and Human Resources
The City supports government action that:
• Preserves local government’s ability to manage its own employment issues, including, but
not limited to hiring, evaluating, disciplining, and/or terminating and negotiating collective
bargaining agreements with employees’ representatives
• Supports reasonable regulatory efforts surrounding policies regarding cybersecurity,
drones, shared mobility services, returning to Obama-era net neutrality regulations, and
smart city initiatives
•Provides for the incremental and thoughtful integration of artificial intelligence
technologies
• Protects individual privacy and allows the City to safeguard customer information
• Maintain existing records collection and retention requirements
• Promote teleconferencing flexibilities under the Ralph M. Brown Act
• Allows the City to support the collaborative work of regional partners, trade associations,
other local governments and organizations, and Joint Powers Authorities
Item 1
Attachment A: Draft 2025
Federal and State
Legislative Guidelines
Item 1: Staff Report Pg. 5 Packet Pg. 9 of 36
Page 4 of 4
The City of Palo Alto’s 20245 Federal and State Legislative Guidelines
Adopted January 22, 2024
• Provides for the equal treatment of all individuals
Housing
The City supports government action that:
• Supports reasonable housing policies that recognize local autonomy to maintain the local
public process and preserve local government’s ability to determine land use policies and
development standards
• Provides flexible, ongoing funding for (a) affordable housing, (b) homelessness, and (c)
infrastructure (such as parks, utilities, roads, and transit) required to support the increased
housing production and keep pace with local development goals Promotes the
development and enhancement of safe and affordable housing and accessible housing
within the City for all economic segments of the population
• Promotes funding and tax incentives for the identification, acquisition, maintenance,
adaptive reuse, and restoration of historic sites and vacant structures
• Fosters reasonable ratios between jobs and housing
• Supports the development and implementation of efficient and environmentally
sustainable land use and building practices
• Supports the provision of greater lead times for Palo Alto to implement state legislation
when necessary to comply with new land use and housing requirements within the local
context
Public Safety
The City supports government action that:
• Supports efforts which seek to modify policing services, including but not limited to
alternative public safety models and funding to address community mental health
issues, expansion of requirements regarding police data and rules regarding prior
employment information transparency, and expansion of data and communications
including radio encryption
• Provides for greater public safety support resources especially related to organized retail
theft operations
• Reduces weapons-related violence via the enactment of common-sense firearm reforms
• Enhances fire and emergency training and response capabilities. Mitigate fire safety
risks. Advocate for funding and policy to mitigate wildfire risks and funding for fire
services in general as well as funding for emergency services.
• Updates, implements, and refines processes, services, and programs affecting the City.
This includes, but is not limited to, public safety reform efforts and streamlining
reporting mandates
• Support legislation that would address ongoing safety concerns and help prevent acts of
violence motivated by hate, including improving data collection and reporting
Item 1
Attachment A: Draft 2025
Federal and State
Legislative Guidelines
Item 1: Staff Report Pg. 6 Packet Pg. 10 of 36
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Auditor
Meeting Date: November 6, 2024
Report #:2409-3476
TITLE
Office of the City Auditor Presentation of ADA Compliance Audit Report
RECOMMENDATION
The Office of the City Auditor recommends the Policy and Services Committee approve the
results of the ADA Compliance Audit Report.
BACKGROUND
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
was to identify and prioritize risks to develop the annual audit plan.
During the FY23 risk assessment, the OCA identified potential risks related to the City’s
compliance with the Americans with Disabilities Act (ADA).
ANALYSIS
The objective of the ADA Compliance audit was to determine if the City has made
improvements to facilities, programs and services in accordance with the ADA Transition Plan
Update (Plan Update), the purpose of which is to ensure compliance with the Americans with
Disabilities Act (ADA).
The ADA Transition Plan Update was adopted by Palo Alto in 2021 and focuses on making
improvements to physical barriers in existing City facilities and rights-of-way. The Plan Update
presents a vision to improve accessibility in Palo Alto over the next 60 years. Public-rights-of-
way (PROW) improvements are scheduled as part of a 30-year, district-by-district sidewalk,
curb, and gutter repair program. As part of the Plan Update, is a Self-Evaluation Report which
provides recommendations to existing City policies and procedures to ensure all programs,
services, and activities are accessible.
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The OCA assessed the City’s efforts to date to implement the ADA Transition Plan Update
through interviewing key staff and reviewing plans, schedules and other documentation related
to ADA compliance efforts. Audit findings and recommendations focus on three areas of
improvement:
•While the City has made progress on the ADA Transition Plan Update, efforts were
hampered by the pandemic and reductions in staffing and lack adequate tracking and
monitoring;
•ADA requests and grievances made by the public have not been consistently tracked
and monitored; and
•While the City implemented nearly two-thirds of ADA self-assessment
recommendations, there is no formal oversight for completing this work including
determining whether recommendations should be implemented and/or an appropriate
timeframe for completion.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
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Item 2 Staff Report
Item 2: Staff Report Pg. 2 Packet Pg. 12 of 36
October 24, 2024
City of Palo Alto
Office of the City Auditor
ADA Compliance Audit
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Attachment A: ADA
Compliance Audit Report
Item 2: Staff Report Pg. 3 Packet Pg. 13 of 36
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
APPENDICES ............................................................................................................... 19
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Compliance Audit Report
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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 ADA Compliance Audit based on approved
Task Order 4.22 as part of the City’s FY24 Audit Plan. The objective of this audit was to:
Determine whether improvements have been made to make facilities, programs, and services
compliant with the Americans with Disabilities Act (ADA) of 1990 and in accordance with the City of
Palo Alto’s ADA Transition Plan Update (Plan Update).
Report Highlights
(Page 10) While the City has made progress in making ADA Transition Plan
compliance improvements to facilities and streets, these efforts were
hampered by the pandemic, reductions in staffing, and lack adequate
tracking and monitoring.
The ADA Transition Plan includes an “ADA Transition Plan - Implementation
Schedule” for improvements of Public Facilities, Parking, and Parks spanning 60
years. In addition, the ADA Transition Plan includes schedules for “Curb Ramps in
Public Right-of-Way” and “Sidewalks in Public Right-of-Way” spanning 30 years. The
plan is in the beginning stages as the City is in the first 5-year implementation phase.
The OCA examined the spreadsheets that the Public Works Department Engineering
Services Division (PWE) uses to track completed projects. In addition, the OCA
obtained the Adopted Capital Budget FY 2024 and Proposed Capital Budget FY 2025.
The OCA noted the following:
• While progress on curbs and sidewalks was delayed due to pandemic-related
funding and staffing reductions, the City is ramping up its efforts to address
curb and sidewalk repairs in FY2025.
• Progress on facilities is behind schedule as only one of the 14 facilities
scheduled to be updated in Implementation Phase 1, during 2021-2025 was
completed.
• The City’s current progress reports may not reflect actual efforts as they
currently do not track in-progress projects, only completed projects. In addition,
the reports do not appear to be regularly updated.
• Despite the City’s allocation of funds for ADA Compliance, only 9.6 percent
was used in 2022 and 0.2 percent was used in 2023, leaving a significant
portion of the budget unspent.
• The Plan Update does not specify regular reporting of planned progress and
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EXECUTIVE SUMMA
Several factors contributed to Plan Update progress delays including the pandemic,
funding reductions, and staffing shortages. The City has a new rehabilitation cycle
starting with sidewalk districts 1 and 2 in FY 2024, which will increase progress in
sidewalk and curb ramp remediations.
Key Recommendations
We recommend that the City determine whether current staffing levels are adequate
to implement the Plan Update or if outside resources, such as contractors and/or
consultants could be used to enhance the City’s efforts to meet the ADA Transition
Plan Schedule goals and expend the full budget each year.
In terms of reporting, we recommend the City consider developing a more robust
tracking and monitoring system for Plan Update projects and an appropriate schedule
for reporting progress to City Council, residents and other stakeholders. Specifically,
we recommend the City consider tracking and reporting on the following:
• actual vs. planned progress;
• actual expenditures vs. budget; and
• planned vs. in-progress vs. completed projects for the time period in question.
Finding 2:
(Page 14) The City receives ADA requests and grievances several ways. ADA requests can be
submitted online via PaloAlto311 (an online interface for residents to submit a request
or complaint using the City of Palo Alto website), the ADA email inbox, or the ADA
phone number. ADA requests and grievances can also be made directly to a
department or program. Staff indicated that all requests and grievances should be
recorded in the 311 system.
Based on our analysis of 50 ADA requests recorded in the 311 system, it appeared
that 58% of requests were not marked as “Completed” within the required 15 working
days, as stipulated by the City’s ADA Grievances Policy.
It appears the 311 system does not encompass all ADA requests or grievances
received by the City and is not consistently monitored based on lack of documentation
of complaint resolution and several items open past the 15 working day requirement.
This makes it difficult to ensure requests are timely resolved.
In addition, the ADA Grievances Policy appears to be outdated as it has not been
revised or updated since October 1997, uses outdated language to refer to the ADA
Coordinator, and includes an ADA Grievance Procedure Form that may no longer be
applicable.
Finally, the ADA Administrator indicated that there are potential timing and budgetary
constraints related to the ADA administrative function.
Key Recommendations
We recommend that the City consider establishing a centralized procedure and
process for recording and tracking all ADA requests and grievances received by the
City including those received by departments.
Procedures should define roles and responsibilities in addressing and monitoring ADA
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EXECUTIVE SUMMARY
appropriate supporting documentation. ADA requests/complaints should be regularly
reviewed to ensure they are addressed within the designated timeframe per the policy
and the outcome recorded. A periodic reconciliation should also be performed to
ensure all requests/complaints are being captured and appropriately resolved. In
addition, we recommend the City regularly review and revise the ADA grievance policy
to ensure that the documentation reflects the current process and process owners.
The City should also consider if the City of Palo Alto ADA Grievance Procedure Form
is still applicable as the City uses the 311 system to receive ADA grievances.
Finally, we recommend that the City consider whether the ADA Coordinator position is
sufficiently resourced and within the appropriate department.
Finding 3:
(Page 18)
The City has implemented nearly two-thirds of the self-assessment
recommendations but there is no formal oversight for completing this
work including determining whether recommendations should be
implemented and/or an appropriate timeframe for completion.
Plan Update
and procedures using the US Department of Justice (DOJ) ADA Best Practices Took
Kit. After receiving responses from various departments on the DOJ ADA Best
Practices Tool Kit, SZS provided recommendations to City departments. Imbedded
within the Plan Update, the Self-Evaluation Report provided self-evaluation
recommendations to existing City policies and procedures to ensure all programs,
services, or activities are accessible.
The OCA sent a questionnaire to the various City departments subject to
recommendations to determine the status of the recommendation. It appears that
several recommendations have not been implemented and progress is not being
tracked.
The OCA noted the following:
• While many of the recommendations have been implemented or partially
implemented, roughly 35 percent have not.
Recommendations do not appear to be centrally tracked or monitored, and there
appears to be a lack of coordination of efforts between departments in tracking
progress and addressing self-evaluation recommendations that involve more than one
department.
Key Recommendations
We recommend that the City assign oversight of the Plan Update to monitor and track
progress and ensure recommendations are implemented timely.
Per the “Tracking Progress on Remediations” section of the Staff Report included in
the Plan Update, it states that City individuals who are identified to act in furthering the
City’s progress in accessibility will submit progress assessments to Public Works
Engineering or a later designated individual overseeing the City’s overall accessibility.
The progress assessment will provide documentation from the individual on their
team’s progress in implementing recommendations from the Plan Update. The City
should determine if this still applies or if another approach should be implemented.
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Compliance Audit Report
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Introduction
1 These new standards align with the minimum guidelines set by the Access Board and reflect the Department’s legal and practical
experiences in enforcing the ADA since 1991, providing clearer guidance for compliance with the ADA.
2 In 1992, the City hired Schirmer Engineering Corporation to create an ADA Transition Plan to comply with Federal ADA regulations issued
in July 1991.
Objective
Determine whether the City has made improvements to facilities, programs, and
services in accordance with the ADA Transition Plan Update (Plan Update), the
purpose of which is to ensure compliance with the Americans with Disabilities
Act (ADA).
Background Consulting Group (SZS) in 2015 to evaluate and survey all public facilities that
hold City programs, services, or activities. Key drivers for this update were new
ADA Standards1 for Accessible Design which became effective on March 15,
2011, updating the 1990 regulations for state and local government services to
prevent disability discrimination and new facilities and projects for which the City
has taken responsibility since the original ADA Transition Plan was prepared in
19922.
The ADA Transition Plan Update (Plan Update) was adopted by Palo Alto in
2021 and focuses on making improvements to physical barriers in existing City
facilities and rights-of-way (land or property owned by the City). The Plan Update
presents a vision to improve accessibility in the City of Palo Alto over the next 60
years. Public-rights-of-way (PROW) improvements are scheduled as part of a
30-year, district-by-district sidewalk, curb, and gutter repair program. Imbedded
in the Plan Update, SZS developed the Self-Evaluation Report which outlines the
context of having a Transition Plan and provides recommendations to existing
City policies and procedures to ensure all programs, services, and activities are
accessible.
About the Americans with Disabilities Act (ADA)
The Americans with Disabilities Act (ADA), enacted on July 26, 1990, is a
comprehensive law addressing both employment and the provision of goods and
services for persons with disabilities. The ADA addresses all aspects of
accessibility which may include public accommodations in facilities, as well as
policies, procedures, and website accessibility.
Title II of the ADA Standards covers all activities of state and local governments
regardless of the government entity’s size or receipt of Federal funding. Title II
requires that state and local governments give people with disabilities an equal
opportunity to benefit from all of their programs, services, and activities.
Scope Plan Update
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INTRODUCTION
3 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.
current period (audit period).
Methodology
• Interviewed the appropriate individuals to gain an understanding of the
organizational structure, processes, and controls related to ADA
compliance efforts.
• Analyzed policies and procedures as well as the Americans with
Disabilities Act (ADA) of 1990 standards, laws, & regulations to
understand Transition Plan requirements and ADA Title II regulations.
• Evaluated the relevant documents such as the ADA Transition Plan,
which includes the ADA Self-Evaluation Report, the Transition Plan
Schedule, and progress assessment reports.
• Gathered information and reports to assess if projects are on schedule
according to the Transition Plan Schedule, and if there is funding for all
improvements to be made in a timely manner.
• Inquired with departments via a questionnaire to assess progress of self-
evaluation recommendations, how ADA complaints are handled, and how
departments monitor accessibility of programs and services.
• Selected a sample of emails sent to the ADA Coordinator inbox and
reconciled to the 311-system log to assess how issues are
communicated to departments and if the ADA Coordinator is tracking
ADA requests and grievances.
• Analyzed where the ADA Coordinator role resides in surrounding
communities.
• 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 review3. Those standards require that we
plan and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings, observations, and conclusions based on our
audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings, observations, and conclusions based on our audit
objectives.
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INTRODUCTION
Organizational
Strengths demonstrated by the Public Works and the Planning & Development Services
departments, notably the ADA Coordinator and the Assistant Director for the
Engineering Services. We also appreciated the willingness of departments to
participate and respond to our ADA Compliance Questionnaire, including the
Office of the City Clerk, Community Services, Fire, Police, OES,
Communications, Public Works, and Planning & Development.
The Office of the City Auditor greatly appreciates the support of the departments
involved in conducting this audit activity.
Thank you!
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Detailed Analysis
Plan Update
This audit evaluated the City’s ADA compliance efforts based on progress made on
the recommended actions outlined in the planning documents included in the ADA
Transition Plan Update (Plan Update). These planning documents and a brief
description of what they cover are listed below. For more detailed information about
these specific action plans, please see Appendix A.
• Self-Evaluation Report – recommendations related to city programs,
services and prioritization of some facility improvements
• Schedule for Public Facilities, Parking, and Parks – recommended
improvements to City facilities
• Schedule for Public Right-of-Way – recommended improvements for
sidewalks and curbs
• ADA Facility Reports – identify all physical barriers based on accessibility
requirements as established by the ADA and CBC Accessibility provisions
Tracking Progress on Remediations
Public Works has been keeping track of recent remediations from CIP and other
facilities maintenance projects. Due to the lengthy process of completing the Plan
Update, some barriers were removed prior to its finalization. The Public Works
Department Engineering Services Division (PWE) created an Excel system for all
City staff to access, update, and document the progress on barrier removals as
they take place. Project managers are required to enter information pertaining to
the project including which barrier was removed, when it was removed, cost for
removal, and a photo for documentation. Staff will then update the databases
periodically based on the gathered information from departments. Staff will be
looking into a more effective, integrable, electronic means of documenting barrier
removals for the long term.
City staff who are identified to act in furthering the City’s progress in accessibility
will submit progress assessments to PWE or a later designated individual
overseeing the City’s overall accessibility. The progress assessment will be
documentation from the individual on their team’s progress in implementing
recommendations from the Plan Update. The progress assessments will be
submitted annually or when a significant change takes place. The ADA Best
Practices Tool Kit provides a consistent method to track the City’s progress on ADA
accommodations that are not physical barriers in City facilities. Existing examples
of progress documentation include annual updates on the City’s Information
Technology’s progress towards an ADA, WCAG 2.1, and Section 508 compliant
website and an updated review of the ADA Tool Kit self-evaluation questionnaires.
Timeline
The ADA Transition Plan Update Schedules were effective when the plan was
adopted. The Schedule for Public Facilities, Parking, and Parks takes place over 60
years starting in 2021. According to the Staff Report accompanying the Plan
Update, this timeline was chosen based on the current amount of funding in PF-
Plan Update
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DETAILED ANALYSIS
management of facilities such as Cubberley Community Center. The Schedule for
PROW is compiled into a 30-year cycle annual sidewalk, curb, and gutter repair
program, in alignment with the City’s annual Sidewalk, Curb and Gutter Repairs
Project. The City’s determination of all sidewalks and curb ramps being deficient
when compiling the Schedule for PROW ensures all districts are addressed based
on the age of the district. Staff will determine which sidewalks and curb ramps in
each district need to be repaired each year. City staff are currently tracking curb
ramps and sidewalks brought into compliance through the City’s annual
maintenance program and other PWE projects. City staff will also be working with
the Development Center if a curb ramp or sidewalk in the PROW is required to be
fixed with a private development project.
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Compliance Audit Report
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AUDIT RESULTS
Audit Results
While the City
has made
progress on ADA
Transition Plan
compliance
improvements to
facilities and
streets, these
efforts were
hampered by the
pandemic,
reductions in
staffing, and lack
of adequate
tracking and
monitoring
Table 1: ADA Transition Plan – Implementation Schedules
Schedule/Plan Description Timeline
Schedule for Public
Facilities, Parking, and
Parks
based on age,
planned CIP, extent of
60 years
(3 phases divided into
5-year increments)
Curb Ramps in Public
Right-of-Way
Prioritizes curbs and
ramps (divided into 5-year
Sidewalks in Public
Right-of-Way Prioritizes sidewalks (divided into 5-year
The Plan Update contains provisions for making facilities, parks, parking
structures, sidewalk and curbs accessible. Included in the plan are various
implementation schedules (see the table below). The ADA Transition Plan -
Implementation Schedule spans 60 years and is divided into 3 phases made
up of 5-year increments. Currently, The City is in Implementation Phase 1,
Increment 1 (2021-2025).
The city-wide district-by-district sidewalk, curb, and gutter repair program
also uses a 30-year lifecycle and is prioritized based on when the district was
last completed. Each district is surveyed by a Public Works staff member
and if a curb ramp/sidewalk doesn’t meet ADA standards, it is marked for
replacement and included in the next CIP project. Currently, the City is
tasked with completing district 1 and district 2 in 2023-2027.
Progress on the Transition Plan appears to be behind schedule, in part
due to the COVID pandemic.
Due to delays attributed to the pandemic, funding reductions, and staffing
shortages in the Public Works Department Engineering Services (PWE)
Division, progress on the Plan Update has been slow to start.
Facilities
Per the Plan Update, the OCA observed that 14 facilities are scheduled to be
completed during Implementation Phase 1, 2021-2025. Per inspection of the
ADA Facilities Report, an Excel spreadsheet used to track completed
projects, the OCA observed that out of the 3 facilities listed, 2 facilities were
marked as remediated. Only one of the 14 facilities scheduled to be updated
during Implementation Phase 1, 2021-2025 was completed.
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AUDIT RESULTS
4 https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82881&dbid=0&repo=PaloAlto
Curb Ramps and Sidewalks
The OCA observed that District 2 is listed to be completed in 2023-2024 and
District 1 is listed to be completed in 2025-2026. Per inspection of the 2020
ADA Transition Plan Progress worksheet, an Excel spreadsheet used to
track progress of curb ramps and sidewalks updates, it did not appear that
any projects have been completed since 2020. Per discussions with staff,
although some progress has been made since 2020, this has been on a
limited scale and was not tracked.
Although the City appears to be behind on the Plan Update, budget
documents show there are plans to increase efforts on sidewalks and curbs
in the fall of FY25.
Per discussions with staff and inspection of Staff Report #2404-28784, the
City will begin a new rehabilitation cycle starting with sidewalk districts 1 and
2 in FY 2025. The work will involve sidewalk, driveway, curb ramp, curb,
gutter, and asphalt pavement repairs. The scope of work includes the
replacement of approximately 18,468 square feet of concrete sidewalk,
2,136 linear feet of curbs and gutters, and 3,759 square feet of driveways.
Additionally, 84 new curb ramps will be installed, and 33 existing curb ramps
will be retrofitted with truncated domes to conform with ADA requirements.
The current schedule does not track in-progress projects and does not
appear to be regularly updated.
The PWE Division created an Excel tracking system for all City staff to
access, update, and document the progress on barrier removals as they take
place. The OCA obtained the ADA Facilities Report. The Report shows 3
facilities, project completion dates, and barrier IDs to track the remediated
barriers at each facility. The OCA noted the following observations:
•Projects are not marked as remediated in the spreadsheet until all
barriers are removed. Barrier removal was completed for 2 of the 3
projects listed.
•In-progress facilities were not recorded or tracked within the
spreadsheet.
The OCA obtained the 2020 ADA Transition Plan Progress worksheet. The
OCA noted the following observations:
•The worksheet does not show which district streets are located in
making it difficult to align with the ADA Transition Plan schedules.
•In-progress streets were not recorded or tracked in the spreadsheet.
Although there are tracking spreadsheets in place for facility, sidewalk, and
curb improvements per the Plan Update, there did not appear to be current
reporting of in-progress projects or regular periodic updates to the
spreadsheets based on the gathered information from departments. In
addition, there did not appear to be tracking of actual progress compared to
the Plan Update schedules.
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AUDIT RESULTS
5 https://www.cityofpaloalto.org/files/assets/public/v/1/administrative-services/city-budgets/fy-2024-city-budget/adopted/palo-alto-adopted-
capital-budget-book.pdf
6 https://www.cityofpaloalto.org/files/assets/public/v/1/administrative-services/city-budgets/fy-2023-city-budget/adopted-fy23/capital-
budget_final-4-online-version.pdf
7 https://www.cityofpaloalto.org/files/assets/public/v/1/administrative-services/city-budgets/fy-2025-city-budget/proposed-budget/fy-2025-
proposed-capital-budget.pdf
8https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=14970
9 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=1455
Despite the City’s allocation of funds for ADA compliance, it has been
observed that a significant portion of the budget remains unutilized.
The OCA obtained the Adopted Capital Budget FY 2024 5 and FY 20236 and
the Proposed Capital Budget FY 2025 7 from the City of Palo Alto website.
Per observation of the ADA compliance budget for FY 2022 – FY 2024, it
appears that actual expenditures have made up about 9% or less of the
allotted budget for ADA compliance activities.
Table 2: ADA Compliance Capital Budget vs. Actual
Fiscal Adopted Capital Estimated Actual
Expenditures
Percentage
FY 2022 $ 800,328 $ 362,328 $ 77,218 9.6%
FY 2023 $ 919,451 $ 86,900 $ 1,342 0.2%
FY 2024 $ 884,677 $ 84,676 *N/A *N/A
The OCA was unable to obtain actual spending related to ADA compliance
as actual spending of ADA compliance projects currently does not appear to
be tracked or reported on OpenGov (budget platform used by the City that
provides actual spending data). However, there is a Status of Capital
Improvement Program Projects report that goes to Council twice a year to
inform the progress of capital projects. According to the April 22, 2024
Agenda Item 13 8 and May 1, 2023 Agenda Item 13 9, actual expenditures in
2022 and 2023 were $77,218 and $1,342 respectively.
The OCA concluded that the allocated funds have not been fully deployed,
potentially delaying necessary upgrades and improvements. Ensuring that
these funds are effectively used is crucial for meeting ADA standards and
staying in line with the Plan Update Schedule.
The ADA Transition Plan does not specify regular reporting of planned
progress and outcomes.
The OCA noted based on interviews with staff and evaluation of the Plan
Update that the City has not established a regular reporting cycle for Plan
progress or outcomes.
Given the long-range nature of this endeavor, giving regular reporting of
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AUDIT RESULTS
accountable.
Recommendation
full utilization of the budget and evaluate if outside resources, such as
contractors and/or consultants could be used to enhance the City’s efforts to
meet the ADA Transition Plan Schedule goals.
In terms of reporting, we recommend that the City consider developing a
more robust tracking and monitoring system for ADA Transition Plan projects
and consider an appropriate schedule for reporting progress to City Council,
residents and other stakeholders. Specifically, we recommend the City
consider tracking and reporting on the following:
• actual vs. planned progress;
• actual expenditures vs. budget; and
• planned vs. in-progress vs. completed projects for the time period in
question.
Management
Response
Responsible Department(s):
Concurrence: Partially Agree
Target Date: 1st Quarter Calenda Year 2025
Action Plan: Public Works Department will update the Construction
Contract Manual to add a procedure to provide updates to the ADA
Transition Plan tracking as part of the Notice of Completion process for all
Public Works projects. Staff acknowledge the observations regarding the
ADA Transition Plan schedule goals. The implementation schedule shown in
the ADA Transition Plans identified certain facilities to be worked on in each
of the five-year increments, those facilities were intended to be identified as
a guide and not a master plan. Since the ADA Transition Plan was adopted
in June 2021, Public Works Engineering has completed the following
projects that involve ADA improvements as a component of the capital
improvement work:
• Rinconada Park Phase 1 (April 2022),
• Lucie Stern Children’s Theater Seat Replacement (December 2022),
• Lucie Stern Community Theatre Seat Replacement (October 2024),
• Public Safety Building (anticipated completion late 2024),
• Curb Ramps: various street resurfacing projects and
Charleston/Arastradero Corridor Phase 1-3 (completed December
2020 – August 2024),
• Boulware Park (anticipated completion early 2025), and
• FY 2024 Sidewalk ADA Curb Ramp Improvements (anticipated
completion Spring 2025).
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10 Your rights under the Americans with Disabilities Act (ADA) | USAGov
11 https://www.cityofpaloalto.org/City-Hall/Accessibility
Finding 2:
ADA requests and
grievances are
tracked and
monitored
inconsistently.
The City provides several ways for individuals to make ADA requests and
grievances. ADA requests can be submitted online via PaloAlto311 (an
online interface for residents to submit a request or complaint using the City
of Palo Alto website), the ADA email inbox, or the ADA phone number. ADA
requests and grievances can also be made directly to a department or
program. requests and grievances can also be made directly to a
department or program. It should also be noted that the ADA does not
require individuals to submit complaints to the City; the ADA permits
complaints to be filed directly with the federal government 10.
The “Accessibility” section of the City of Palo Alto website 11 provides the
public with the contact information of the City’s ADA Coordinator, including
the ADA Coordinator’s email and phone number. This section provides a
way for individuals to request assistance for persons with disabilities who
need materials in alternative formats, auxiliary aids, or modifications to
policies or procedures in order to access City meetings, programs, or
services. Additionally, it allows individuals to submit feedback, report
accessibility barriers, or file a grievance report through the PaloAlto311
(“311”) system.
All ADA-related requests and grievances are expected to be recorded in the
311 system. ADA requests and grievances are collected and routed
internally to the appropriate department via the 311 system. Once routed to
the appropriate department, a decision is then rendered and communicated
to the requestee. According to the ADA Grievances Policy, a decision will be
rendered in writing within 15 working days from the date the complaint is
received. The chart below shows a breakdown of the types of complaints
received in the 311-system from FY 2023 – FY 2024:
• 72% of 311 system ADA requests or grievances are related to
accessibility barriers.
72%
6%
22%
Types of ADA Requests or Grievances
Accessibility Barrier City Meetings, Programs, or Services Assistance Other
*Analysis performed by OCA in August 2024.
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•
meetings, programs, or services assistance.
• 6% of 311 system ADA requests or grievances are categorized as
“other.”
58% of ADA Requests were not marked as “Completed” within the
required 15 working days
The OCA obtained the ADA request data from the 311 system from FY 2023
to FY 2024. Per our analysis of the 311-system data, it appeared that a total
of 50 ADA requests were recorded from FY 2023 - FY 2024.
The OCA noted the following observations:
• 28 (56%) of all requests received were marked as "Completed."
• 21 (42%) requests were marked as “Submitted.”
• 1 (2%) request was marked as “Received.”
• 29 (58%) requests remained open for more than 15 working days.
• The average days a request remained open was about 170 days.
Per discussion with the ADA Coordinator, "Submitted” is the default status,
“Received” is a status that staff use to acknowledge the ticket and its
contents when routed to a department or kept internally, and “Completed” is
a status that staff use to close out their task and move it to the next task or
close out the ticket when the issue has been addressed.
According to the ADA Coordinator, there has not been adequate staffing or
resources to follow up with departments to confirm if the requests have been
addressed within 15 working days. Although some requests that remained
open may have been addressed, the 311-system data is not updated to
show this.
It appears the 311 system does not include all ADA requests or
grievances received by the City and is not consistently monitored to
ensure requests are adequately resolved.
The OCA took a sample of emails from the ADA Coordinator’s email inbox
to determine if they were appropriately logged in the 311 system and
resolved in accordance with policy. A sample of eight emails was selected
and assessed for whether the request was logged in the 311 System,
whether the request was marked as “complete” aka resolved, and if the
decision was rendered within the 15 working days required by policy.
The OCA documented the following results:
• 3 out of 8 emails selected did not appear to be included in the 311-
system report.
• 4 out of the 5 emails included in the 311-system report appeared to
have been open for more than 15 business days.
• 1 out of the 5 emails included in the 311-system report was marked
as “Submitted” and had been open more than for 228 days.
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•
appear to be evidence of a decision being rendered in writing in the
311 report.
The OCA completed a reconciliation of the email inbox to the 311 system
which should contain all requests and complaints and found that 6 out of 18
ADA request emails received to the ADA inbox from FY 2023 to FY 2024 did
not appear to be included in the 311-system report.
Additionally, based on our survey of departments, it does not appear
departments independently track ADA requests or complaints that are
received directly via email, phone, or in person and these requests may not
be added to the 311 System.
Without a comprehensive and centralized approach for recording and
tracking ADA requests received by the City, ADA requests and grievances
may not be appropriately and efficiently addressed in accordance with the
ADA Grievances Policy.
The Grievance policy in place appears to be outdated.
The City has an ADA Grievance Policy in place which includes a policy
statement, documented procedures of filing a complaint and the appeal
process if the complaint is not resolved to the complainant’s satisfaction,
and a City of Palo Alto ADA Grievance Procedure Form (“ADA Grievance
Procedure Form”).
The OCA inspected the ADA Grievance Policy document and noted the
following observations:
• It appears that the policy has not been revised or updated since
October 1997. The policy uses outdated language such as referring
to the ADA Coordinator as the “Disabilities Act Director” which
appears to no longer apply to the position title.
• Although the ADA Grievance Procedure Form included in the policy
appears to have been updated more recently in January 2016, it
does not appear to reflect the current process. As ADA grievances
are currently reported via the 311 system on the city website rather
than submitting a form, the ADA Grievance Procedure Form may not
be applicable.
There are potential timing and budgetary constraints related to the
ADA administrative function.
The current ADA administrator indicated timing, resources, and staffing
constraints related to administering the program. Staff suggested that this
function might be better placed outside the Planning & Development
Services department.
The OCA completed an assessment of 7 surrounding communities, finding
that the ADA Coordinator and program sits in various departments across
communities with no single department emerging as standard.
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Community
Department in which the ADA Coordinator Role
Resides (Per the Community Website)
Palo Alto Planning & Development Services
San Mateo City Clerk's Office
Mountain View City Manager's Office
Santa Clara Public Works
Los Gatos Community Development
Los Altos Human Resources
Menlo Park City Manager's Office
Sunnyvale Recreation and Community
Recommendation and process for recording and tracking all ADA requests and grievances
received by the City including those received by departments.
Procedures should define roles and responsibilities in addressing and
monitoring ADA requests/complaints and address how requests/complaints
should be logged, routed to the appropriate individual, and tracked for when
and how they are resolved with appropriate supporting documentation. ADA
requests/complaints should be regularly reviewed to ensure they are
addressed within the designated timeframe per the policy and the outcome
recorded. A periodic reconciliation should also be performed to ensure all
requests/complaints are being captured and appropriately resolved. In
addition, we recommend the City regularly review and revise the ADA
grievance policy to ensure that the documentation reflects the current
process and process owners. The City should also consider if the City of
Palo Alto ADA Grievance Procedure Form is still applicable as the City uses
the 311 system to receive ADA grievances.
Finally, we recommend that the City consider whether the ADA Coordinator
position is sufficiently resourced and within the appropriate department.
Management
Response
Planning & Development Services
Concurrence: Agree
Target Date: 1st Quarter Calendar Year 2025
Action Plan: Planning and Development Services will create a guide to
handle ADA requests efficiently. They'll use the 311 system to track these
requests. Based on a review of the volume of ADA requests over time,
additional staff resources may be needed to effectively manage the
workload. PDS will work with other city departments to plan for the next
budget reporting out findings and any recommended changes to the current
organization as needed.
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Finding 3: The City
has implemented
nearly two-thirds
of the self-
assessment
recommendations
but there is no
formal oversight
for completing this
work including
determining
whether
recommendations
should be
implemented
and/or an
appropriate
timeframe for
completion.
Imbedded in the Plan Update, The Self-Evaluation Report provided
recommendations to existing City policies and procedures to ensure all
programs, services, or activities are accessible. As part of the Self-
Evaluation Report, SZS reviewed the City’s policies and procedures using
the DOJ ADA Best Practices Took Kit. After receiving responses from
various departments on the DOJ ADA Best Practices Tool Kit, SZS provided
recommendations to City departments.
The OCA sent a questionnaire to the various City departments to which the
recommendations are addressed to determine if the recommendations have
been implemented, the efforts to date, and if there are plans to implement
the recommendation. The OCA received responses from the following
departments: Public Works, Community Services, Planning & Development,
Communications, City Clerk, Police, Fire, and OES.
Based on responses, it appears several departments have tools in place to
monitor the accessibility of programs and services. For example, the
Communications department has contracted a third-party service to monitor
the accessibility of the City website. In addition, the Library department uses
a third-party service provider for online materials. As part of these services,
the vendor uses Web Content Accessibility Guidelines to ensure
accessibility through tools such as magnification and color contrast which
improve legibility. Lastly, the Community Services department hired a
Therapeutic Recreation & Accessibility Coordinator to accommodate
disability requests.
While many of the recommendations have been implemented or
partially implemented, roughly 35 percent have not.
Based on responses, no one department or office is coordinating or
monitoring implementation of the self-evaluation recommendations. Instead,
departments are tracking implementation on their own. Based on responses,
roughly 35 percent of the 68 self-evaluation recommendations have not
been implemented or partially implemented.
*Analysis performed by OCA in August 2024.
24
16
28
0
5
10
15
20
25
30
No Partially Yes
Questionnaire Responses: Have the Self-Evaluation
Recommendations Been Implemented?
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Recommendations do not appear to be centrally tracked or monitored.
Without a centralized tracking system in place, it is difficult for the City to
determine if recommendations are properly addressed and implemented
and if the City is in compliance with ADA standards. Ensuring compliance is
a key step in making sure the City provides programming and services with
equitable access and avoiding potential legal and reputational
consequences.
Recommendation ADA Transition Plan
monitor and track progress and ensure recommendations are implemented
timely.
Per the “Tracking Progress on Remediations” section of the Staff Report
included in the ADA Transition Plan, it states that City individuals who are
identified to act in furthering the City’s progress in accessibility will submit
progress assessments to Public Works Engineering or a later designated
individual overseeing the City’s overall accessibility. The progress
assessment will provide documentation from the individual on their team’s
progress in implementing recommendations from the ADA Transition Plan.
The City should determine if this still applies or if another approach should
be implemented.
Management
Response
Responsible Department(s):
Concurrence: Agree
Target Date: 1st Quarter Calendar Year 2025
Action Plan: The Public Works Department will lead an effort to coordinate
and track progress specifically seeking to address self-evaluation
recommendations for the City including identifying any recommendations the
City may not recommend pursuing.
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Appendices
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Appendix A: ADA Transition Plan Best practices
The City of Palo Alto City Council Staff Report for the Adoption of ADA Transition Plan Update dated
6/7/2021 provides guidance from the 2010 ADA standards and outlines the considerations for the
ADA Transition Plan, which includes the Self-Evaluation Report and schedules. Information from the
Staff Report 12 is included below.
Americans with Disabilities Act Transition Plan
The development of a Transition Plan is a requirement of both the Americans with Disabilities Act and
for implementation of the Rehabilitation Act of 1973. In addition to fulfilling the requirements of federal
law, adopting the Transition Plan will help the City schedule and track its progress during renovation
projects as a structured checklist. ADA standards have changed since the original 1992 ADA
Transition Plan, as has the City’s roster of public facilities, and an updated plan provides better
guidance to improve overall accessibility in City public buildings and Public Rights-of-Way (PROW).
Based on the 2010 ADA guidance for public facilities, a Transition Plan requires the following:
• Identify physical obstacles in the public agency's facilities that limit the accessibility of its
programs or activities to individuals with disabilities;
• Describe in detail the methods that will be used to make the facilities accessible;
• Specify the schedule for the transition plan; and
• Indicate the official responsible for implementation of the plan.
The final Transition Plan fulfills the requirements listed above and includes the following Documents:
• Self-Evaluation Report
• Schedule for Public Facilities, Parking, and Parks
• Schedule for Public Right-of-Way
• ADA Facility Reports
Self-Evaluation Report
In the Self-Evaluation Report13, SZS Consulting Group outlines what determines a qualified individual
with disabilities and defines programmatic accessibility. SZS Consulting Group reviewed the City’s
policies and procedures using the DOJ ADA Best Practices Took Kit.
The DOJ ADA Best Practices Tool Kit covers the following categories:
• ADA Coordinator
• General Effective Communication Requirements under Title II of the ADA
• 9-1-1 and Emergency Communications Services
• Website Accessibility under Title II of the ADA
• Curb Ramps and Pedestrian Crossings
• Emergency Management under Title II of the ADA
12 https://www.cityofpaloalto.org/files/assets/public/v/2/agendas-minutes-reports/reports/city-manager-reports-cmrs/year-archive/2021/id-
12292.pdf
13 The Self-Evaluation Report includes context and history behind the ADA and requirements for a Transition Plan. Title II of the 2010 ADA
standards applies to state and local government entities, and in Subtitle A, focuses on protecting qualified individuals with disabilities from
discrimination based on disability in programs, services, or activities provided by state and local government entities.
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After receiving responses from various departments on the DOJ ADA Best Practices Tool Kit, SZS
Consulting Group provided recommendations that staff actively started to pursue. These
recommendations apply to a broad group of City departments.
The Self-Evaluation Report also lists functions at each facility in the City that may affect people with
disabilities. For example, most departments include a public-facing counter for transactions and
requests for information. Other important functions that may affect people with disabilities include
information and updates posted on the City website and public meetings such as Council Meetings
and Board meetings. These listed functions educate staff on which City facilities may need to be
prioritized earlier in the Schedule and where City policies may need to be modified to accommodate
people with disabilities.
Schedules
The Schedule for Public Facilities, Parking, and Parks was prioritized based on the age of the facility,
extent of corrective work, budget, planned CIP projects, and public input. In the development of the
first draft of the Schedule for Public Facilities, Parking, and Parks, facilities were assigned a priority by
SZS Consulting Group based on a four-level priority system.
Priority 1 – Points of arrival on site (parking lots, connecting walkways, transportation) or projects that
have been currently budgeted
Priority 2 – Facilities built between 1888 to 2000 that provide programs, services, or
activities by the City
Priority 3 – Facilities built between 2000 to 2016 or facilities with an unknown construction date
Priority 4 – Remaining facilities
SZS Consulting Group also took into consideration the facilities that were used most frequently by the
largest number of people and based on public outreach feedback.
The Schedule for Public Facilities, Parking, and Parks was then further refined based on the type of
facility and extent of work measured by the estimated costs14 to remediate the identified barriers to
accessibility in the facility. One of the staff’s goals was to ensure a relatively even amount of work for
every five-year block.
The Schedule for Public Facilities, Parking, and Parks is seen as an adaptive, living document, and
changes are expected to occur depending on the City’s progress. Several factors can influence the
actual remediation cost such as contracting to complete barriers of the same type. The schedule can
also change substantially if accommodations are requested that reprioritize a building, a change takes
place that ensures programmatic accessibility within a facility, or changes in ownership of a facility.
For example, the City returned ownership of Cubberley Community Center Buildings A, B, I and
portions of Buildings G and M to the Palo Alto Unified School District. This will decrease the estimated
cost of remediation by $314,719, the total estimated costs for identified barriers in the Cubberley
buildings the City does not lease or own.
14 The total estimated cost is generally larger when a facility has a larger area contributed to programs, services, or activities and is older.
For example, although fewer facilities are shown at the end of the Schedule for Public Facilities, Parking and Parks, this is partly due to the
higher estimated cost to remediate these facilities.
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Similar to the Schedule for Public Facilities, Parking, and Parks, the Schedule for PROW considers
the age of the facility. To simplify the process, the City has assumed that all City sidewalks and curb
ramps are deficient15 with respect to ADA.
15 In fact, not all sidewalks and curb ramps are deficient, but this determination creates a simpler schedule since the City is entering a new
cycle of the 30-year district-by-district sidewalk, curb, and gutter repair program. Older districts such as Downtown are prioritized first due to
the older average age of ramps and sidewalks.
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