HomeMy WebLinkAbout2026-08-11 Policy & Services Committee Agenda PacketPOLICY AND SERVICES COMMITTEE
Regular Meeting
Tuesday, August 11, 2026
Council Chambers & Hybrid
6:00 PM
Amended Agenda
Amended agenda items appear below in RED
Councilmember Keith Reckdahl Remote Call In Teleconference Location:
Holiday Inn Huntsville Research Park, 5903 University Drive
Huntsville, Alabama 35806
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1 August 11, 2026
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CALL TO ORDER
IN-PERSON PUBLIC COMMENT
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comments will be heard at the beginning of the agenda and remote comments will be heard at the end of the agenda. In-person
Public Comment is limited to 30 minutes. Additional in-person public comments, if any, will be heard at the end of the agenda.
ACTION ITEMS
1. Office of the City Auditor Presentation of the Junior Museum & Zoo Audit. CEQA Status –
Not a project. Supplemental Report Added
2. Recommend that City Council approve the HSRAP Grant Program expansion
3. Discuss and Provide Feedback on Housing Element Program 6.5: Alternative Housing
Program, Objective B. CEQA Status: Exempt Under CEQA Guidelines Section 15262.
4. Discuss and Recommend Approval of Scope of Work for State and Federal Legislative
Advocacy and Grant Consulting and Compliance Services
FUTURE MEETINGS AND AGENDAS
Members of the public may not speak to the item(s)
VIRTUAL PUBLIC COMMENT
Members of the public may speak to any item NOT on the agenda. 1-3 minutes depending on number of speakers. In-person
comments will be heard at the beginning of the agenda and remote comments will be heard at the end of the agenda. In-person
Public Comment is limited to 30 minutes. Additional in-person public comments, if any, will be heard at the end of the agenda.
ADJOURNMENT
2 August 11, 2026
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3 August 11, 2026
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4 August 11, 2026
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public inspection at www.paloalto.gov/agendas.
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Auditor
Meeting Date: August 11, 2026
Report #:2509-5172
TITLE
Office of the City Auditor Presentation of the Junior Museum & Zoo Audit. CEQA Status – Not a
project.
RECOMMENDATION
The Office of the City Auditor recommends the Policy & Services Committee accept the results
of the Junior Museum & Zoo (JMZ) Audit Report.
BACKGROUND
Baker Tilly Advisory, in its capacity serving as the Office of the City Auditor (OCA), performed a
citywide risk assessment that evaluated a wide range of risk areas, including strategic, financial,
operational, compliance, technological, and reputational risks. The purpose of the assessment
was to identify and prioritize risks to develop the annual audit plan.
During the FY24 risk assessment, the OCA identified operations at the JMZ as a potential area of
risk and included this topic in the FY25 Audit Plan.
ANALYSIS
The objective of the JMZ Audit was to determine if the program is operating effectively and
efficiently to fulfill the program’s mission.
The JMZ is a City-operated children’s science museum and zoological facility managed by the
City’s Community Services Department (CSD). Rebuilt and reopened in November 2021
following a major renovation supported by approximately $25 million in fundraising from the
Friends of the JMZ, the facility housed more than 65 species and approximately 85 animals.
Education is a core component of the JMZ’s mission, with approximately 20 educators,
delivering more than 2,700 inquiry-based science lessons annually to over 24,000 students at
168 schools and community centers. In addition, the JMZ operates popular and in demand
summer camp programs.
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The JMZ is funded primarily through the City’s General Fund, supplemented by admissions,
program fees and ongoing support from the Friends of the JMZ, which has promoted
accessibility, inclusion, and facility enhancement for mor than 50 years. During the audit period,
the JMZ also achieved accreditation from the Association of Zoos and Aquariums (AZA) through
September 2030, reflecting its compliance with the profession’s highest standards and enabling
participation in species exchange programs and other key operational benefits.
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FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
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July 2, 2026
City of Palo Alto
Office of the City Auditor
Junior Museum and Zoo Audit
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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
AUDIT RESULTS ........................................................................................................6
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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 audit of the Junior Museum and Zoo (JMZ)
based on approved Task Order 4.31 as part of the City’s FY25 Audit Plan. The objective of this audit
was to determine if the City’s Junior Museum and Zoo is operating effectively and efficiently to fulfill
the program’s mission.
Report Highlights
(Page 6) community demand, including near-weekly sellouts, high program participation, and
improved ticketing efficiency through the ACME system. However, JMZ does not yet
have a recurring, consolidated performance measurement framework to assess
overall program impact, demand, utilization, customer experience, staffing capacity,
revenue, and administrative workload. As a result, the City has useful data in certain
areas but limited visibility into whether JMZ is meeting community demand, using
resources efficiently, and supporting budget and staffing decisions with complete
performance information.
• The ACME ticketing system improved operations and reportedly reduced daily
entrance duties by about 30%.
• JMZ has useful data in some areas, but does not consistently consolidate key
metrics across attendance, utilization, guest experience, event demand,
revenue, staffing, and workload.
• Some demand indicators are not fully tracked, including birthday party
requests, member no-shows, and guest feedback.
• Staffing and administrative capacity challenges limit JMZ’s ability to track,
analyze, and use data for broader management decisions.
The City and JMZ should establish a recurring framework to measure the JMZ's
demand, results, and operating performance and to inform budget and staffing
decisions. This framework can be built largely by consolidating existing data, since
systems like ACME already capture attendance, ticket sales, and time-slot activity. At
a minimum it should cover visitor demand and access, guest experience, revenue by
source against costs where feasible, program and event demand, and staffing and
administrative workload, with JMZ and Community Services Department (CSD)
leadership reviewing it at least quarterly. As it implements the framework, the City can
also weigh whether dedicated business operations support is warranted, given the
Executive Director's stated future need for a business or analyst role and the already-
stretched administrative capacity.
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EXECUTIVE SUMMARY
Finding 2:
(Page 9)
JMZ’s education program is an area that continues to grow, serves many students
and adults, and receives strong customer satisfaction ratings. However, staffing,
supplies, financial reporting, funder tracking, and program evaluation practices have
not kept pace with this growth. Without stronger resource planning, financial
reconciliation, and performance measurement, management has limited ability to
determine whether the program is financially sustainable, adequately resourced, and
achieving broader outcomes beyond participant satisfaction.
• The education program expanded in FY2025, generating more than $980,000
in revenue, delivering more than 2,700 programs or lessons, and serving more
than 24,000 children and students.
• Staffing and supplies have not kept pace with growth due to part-time turnover,
slow hiring, vacancies, limited administrative capacity, and a supplies budget
that has increased only modestly while participation has more than doubled.
• Financial reporting does not clearly connect program activity to revenue,
expenses, and fiscal year timing, limiting management’s ability to assess cost
recovery and sustainability.
• Survey results show strong satisfaction, but low response rates and limited
outcome-based evaluation make it difficult to determine whether feedback is
representative or whether the program is achieving broader educational goals.
Key Recommendation:
JMZ should develop an integrated education program dashboard linking program
activity, staffing, supplies, revenues, expenses, subsidies, funding sources, and
evaluation results. The dashboard should include workload-based staffing and supply
assumptions, budget-to-actual reporting by program type, reconciliation between
service/revenue reports and financial records. In addition, it should track Friends of
the Museum-funded programs from planning through payment. Finally, survey
response rates and comment trends, and outcome measures tied to curriculum goals
should be consistently tracked and monitored. This would better enable the JMZ to
keep expanding successful programs while better demonstrating whether they are
financially sustainable, adequately staffed, and achieving intended results.
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EXECUTIVE SUMMARY
Finding 3:
(Page 14) regulatory compliance systems, including earning Association of Zoos and Aquariums
(AZA) accreditation, finalizing a veterinary services agreement, and maintaining daily
animal-care reporting. However, OCA identified opportunities to improve consistent
execution and documentation of key safety and compliance controls, including
emergency drills, animal transport, and recordkeeping. Strengthening documentation
and oversight in these areas would help JMZ demonstrate ongoing compliance with
AZA standards and better ensure that safety and animal welfare controls are
operating as intended.
• Emergency drills were not always completed or documented as required,
though JMZ has since developed a checklist to capture drill results, lessons
learned, and corrective actions.
• Animal transport practices should be formalized, including documented vehicle
use expectations, safety training, and procedures for transporting animals,
staff, and education materials.
• Recordkeeping is spread across daily reports and multiple files, making it
difficult to verify that required actions were completed and retained
consistently.
• The City should evaluate whether the semi-open elevator / lift shaft presents a
safety risk and determine whether additional safeguards, such as a full-height
door, gate, or barrier, are needed.
Key Recommendation:
The City and JMZ should establish a centralized safety and compliance tracking
process to document and monitor required animal care, safety, and regulatory
compliance activities, including responsible staff, completion frequency, required
evidence, reviewer sign-off, and corrective actions. The process should include
emergency drill tracking and evaluation, consistent use of the Emergency Drill/Incident
Review Checklist, documentation of lessons learned and follow-up actions, and a
written animal transport policy addressing vehicle use, staff training, animal
containment, trip documentation, and emergency procedures. JMZ and CSD
management should review the tracker at least quarterly to confirm that required
activities are completed, documentation is retained, and corrective actions are
addressed, helping JMZ demonstrate compliance with AZA documentation
expectations and assess whether key controls are operating as intended.
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Introduction
1 Friends of the Palo Alto Junior Museum & Zoo – Friends of the Palo Alto Junior Museum & Zoo
Objective effectively and efficiently to fulfill the program's mission.
Background
the City. The facility was entirely rebuilt and reopened in November 2021,
following a major renovation supported in large part by the Friends of the JMZ 1,
which raised approximately $25 million for the project.
The JMZ operates under the City’s CSD, and the collection includes over 65
species and approximately 85 individual animals, including a live bald eagle held
under a U.S. Fish and Wildlife Service permit.
The JMZ’s education program is one of its largest program areas. It employs
approximately 20 educators and instructors who provide over 2,700 inquiry-
based science lessons across 168 schools and community centers, serving more
than 24,000 students annually. During the summer, staff operate week-long
camp sessions across nine content areas, with a majority selling out in the first
round of applications.
The JMZ is primarily funded through the City’s General Fund, supplemented by
ticket revenue, education program fees, and fundraising by the Friends of the
JMZ, a support organization that has existed for over 50 years and focuses on
accessibility, inclusion, and fundraising for facility improvements and special
programs.
During the audit period, the JMZ successfully obtained accreditation from the
AZA through September 2030. AZA accreditation represents the highest
standard for zoological institutions and enables the JMZ to participate in species
exchange programs, streamline permitting processes, and demonstrate
adherence to leading professional practices.
Scope covering FY 2024 through 2025. The audit included assessing the following
areas: educational activities, financial and program data, staffing and
administrative processes, guest services and cash handling, animal care and
wellbeing, veterinary coverage, emergency preparedness, safety and security,
selected wildlife permits, and governance/oversight considerations.
Methodology
• Interviewed the appropriate individuals to gain an understanding of the
organizational structure, processes, and controls related to JMZ
operations.
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INTRODUCTION
2 Government auditing standards require an external peer review at least once every three (3) years. The last peer review of the Palo Alto
Office of the City Auditor was conducted in 2017. The Palo Alto City Council approved a contract with Baker Tilly U.S, LLP for internal audit
services for October 2020 through June 2022 with an extension through June 2025. City Council appointed Kate Murdock, Senior 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 2026. It should be noted that Baker Tilly’s most recent firmwide
peer review was completed in November 2024 with a rating of “Pass”. The scope of that peer review includes projects completed under
government auditing standards.
regulatory requirements to identify the criteria to be used for evaluation of
control design and effectiveness.
• Conducted an on-site visit to evaluate animal care and veterinary
records, financial management controls, and safety and security
practices, including animal health and wellbeing records, necropsy
reports, daily animal care reports, veterinary documentation, cash
handling procedures, P-card usage, budgeting practices, ticket revenue
management, emergency drill records, education, facility access controls,
and incident reporting systems.
• Completed audit report of findings, conclusions, and recommendations
based on the supporting evidence gathered.
Compliance
Statement accepted government auditing standards, except for the requirement of an
external peer review2. 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.
Organizational
Strengths across all program areas. The education program is a standout asset, serving
tens of thousands of students with high-quality, inquiry-based science instruction.
The JMZ’s successful attainment of AZA accreditation demonstrates its
commitment to operational excellence, industry best practices, and continuous
improvement. The modern facility, rebuilt in 2021, is a valued asset to the Palo
Alto community. We appreciated the participation of JMZ staff in interviews and
their responsiveness to follow-up requests throughout the audit.
The OCA greatly appreciates the support of the CSD in conducting this audit activity.
Thank you!
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Audit Results
JMZ delivers high-
demand mission-
driven programs,
and the City has
an opportunity to
further develop a
formal
performance
measurement
framework to
assess impact,
demand, and
operating results.
live-animal zoo, public attraction, event venue, and community -serving facility. The
JMZ is valued by the community and offers a distinctive experience within the City.
Available operational information indicates strong demand for JMZ services.
Based on OCA’s review of ticket sales, education program participation counts, and
other program data, JMZ has indicators of strong demand across both general
admission and education programming. Guest Services staff reported that JMZ
implemented paid ticketing in 2021, using the ACME ticketing system, and sells out
nearly every weekend. Staff also reported that ACME has saved approximately 30%
of staff time in daily museum entrance duties. The graph below shows the number of
admissions in FY24 and FY25 with total admissions of 128,006 and 120,822
respectively.
Figure 1: JMZ General Admission by Month, FY2024 vs. FY2025
Source: OCA analysis of JMZ general admission data, FY2024–FY2025. FY2025
includes a mid-year transition to the ACME ticketing system in FY2025.
While JMZ has increased use of operational data for decision-making, there are
additional opportunities to improve performance reporting.
JMZ has begun using operational data and business analysis in selected areas. For
example, Guest Services staff can use the ticketing system to track tickets sold by
day or date range, and CSD leadership reported that the City performed an analysis
of staffing models and ticket pricing, which led to an increase in ticket prices.
However, JMZ does not yet have a formal, recurring performance measurement
-
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
At
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d
a
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e
Month (fiscal year: July-June
FY 2024 FY 2025
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AUDIT RESULTS
facilities, and administrative workload.
As a result, the City has useful operational data in specific areas but no recurring,
consolidated view of how the JMZ's programs are performing overall. Through the
ACME system, Guest Services tracks ticket sales by day and date range, but other
demand and utilization signals are not captured.
Staff reported that members book admission up to eight weeks ahead and often do
not attend. Roughly 75% to 80% of booked guests attend, which reduces availability
for non-members, however this pattern is not formally measured. According to the
Assistant Director for CSD, the JMZ also lacks a structured process for collecting
customer feedback, though staff are working to implement one.
Another area where more information would be helpful is in special programming
such as parties and events. According to Guest Services staff, birthday programming
is capped at 16 bookings per month and demand exceeds that capacity. However, at
the time of the audit management reported that they were not consistently tracking
the number of requests for birthday parties so demand for this service remains
unknown. According to birthday party reports from FY24 to 25 there was reduction in
the number of parties from 29 in FY24 to 18 in FY25. This represented a 36.2%
decrease in party-guest attendance and a 63.5% decrease in revenue from $25,148
to $9,170. Guest Services staff indicated this was due to staffing and software issues,
which have since been resolved.
Finally, staff noted that marketing efforts are not tracked and monitored and social
media and website information is not consistently or regularly updated. Increasing
such efforts could help the JMZ continue to expand its services and reach.
According to Guest Services staff, a single position handles contracts, scheduling,
guest services, and program coordination and described the workload as
overwhelming, and staffing has consistently been a challenge. The Executive
Director stated that hiring takes eight months to a year and that the City’s Human
Resources Department often cannot accommodate hiring requests timely. The
Executive Director also identified a future need for a management analyst or director
of business to manage budgets, HR, and contracts and to "acquire, review and
present data to inform strategies JMZ-wide" indicating no dedicated data-analysis
function exists today.
Without a recurring framework consolidating indicators such as attendance, ticket
utilization, customer experience, event demand, revenue, staffing capacity, and
administrative workload, the City has limited ability to tell whether the JMZ is meeting
community demand, using resources efficiently, and achieving intended outcomes, or
supporting informed budget and staffing decisions.
Recommendation to track the JMZ's mission impact, demand, and operating results and to support
budget and staffing decisions. Much of the underlying data already exists in current
systems, the ACME ticketing system, for example, captures attendance, ticket sales,
and time-slot activity, so the framework can be built largely by consolidating and
regularly reviewing existing data rather than acquiring new systems. At a minimum
the framework should include:
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AUDIT RESULTS
•Visitor demand and access measures
Track attendance, ticket sales, sold-out periods, no-show rates, member
reservation activity, non-member ticket availability, walk-ins, time-slot
utilization, and peak versus underutilized periods.
• Guest experience measures
Implement a guest services survey or other structured feedback process to
measure visitor satisfaction, ease of ticketing, accessibility, customer service,
complaints, response times, and recurring service themes.
• Revenue and cost measures
Report revenue by major source, including admissions, memberships, facility
rentals, birthday parties, events, donations, and other earned revenue. Where
feasible, compare revenue to direct costs and staffing requirements.
• Program and event demand measures
Track demand for birthday parties, rentals, special events, animal encounters,
accessibility programs, and other public-facing services, including waitlists,
declined requests, cancellations, and unmet demand.
• Staffing and administrative workload measures
Track vacancies, time to fill positions, part-time staffing reliance, overtime or
coverage gaps, administrative workload, contract volume, customer response
times, and major bottlenecks.
• Quarterly management review
JMZ leadership and CSD management should review the performance
framework at least quarterly and document key trends, decisions, follow-up
items, responsible parties, and target completion dates.
The City should also evaluate whether JMZ needs dedicated business operations
support, such as a management analyst or business manager, to help maintain the
framework, analyze results, support budget development, coordinate contracts and
administrative requirements, and provide JMZ-wide data for decision-making.
Management
Response
Responsible Department(s):Community Services
Concurrence: Agree
Target Date: Q4, FY 2027
Action Plan:
made significant progress in expanding the use of operational data through
implementation of the ACME ticketing system, program participation tracking, and
revenue reporting. Management agrees that consolidating these existing data
sources into a recurring performance dashboard will strengthen strategic decision-
making and support future budget, staffing, and operational planning.
During FY2027, JMZ will formalize a recurring performance measurement framework
by consolidating existing operational data into a management dashboard. The ACME
ticketing system already captures many key performance indicators, including
attendance, ticket sales, sold-out periods, member reservation activity, no-show
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AUDIT RESULTS
visitation periods. JMZ will incorporate these existing metrics into a recurring
dashboard while continuing to expand performance measures as additional data
becomes available.
JMZ is also implementing new visitor and birthday party survey tools to better
measure guest experience and customer satisfaction. Existing waitlists will continue
to be used to assess demand for programs where applicable, and additional tracking
methods will be developed for programs and services where unmet demand is not
currently captured. Together, these enhancements will provide a more
comprehensive understanding of visitor demand, customer experience, operational
performance, and resource needs.
Management also recognizes the value of potential enhanced business and
analytical support. Any future staffing additions will be evaluated and proposed during
the City's annual budget development process and based on organizational priorities
and available resources.
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Finding 2:
Educational
program offerings
continue to
increase but
staffing challenges
and budget
constraints limit
the program’s
ability to meet
demand.
The JMZ education program is expanding and receives strong customer satisfaction
ratings, but the available evidence indicates that its staffing, supply budget, financial
reporting, funder tracking, and program evaluation practices have not kept pace with
that growth. As a result, management has limited ability to determine whether the
program is financially sustainable, sufficiently resourced, and achieving program-wide
outcomes beyond participant satisfaction.
The JMZ education program is a core mission-delivery function and one of the
organization’s major public-facing services. The program continues to expand,
generating more than $980,000 in FY2025 revenue while delivering more than 2,700
programs or lessons across schools and community centers. In FY2025, the program
served more than 24,000 children and students and more than 2,100 adults.
This growth reflects a broader year-over-year increase in education activity almost
every year for the past decade. From FY2024 to FY2025, reported
programs/sessions increased from 2,510 to 2,710, children/students served
increased from 23,197 to 24,525, and revenue increased from $918,356 to $980,553.
Adult participation also increased, rising from 656 adults served in FY2024 to 2,157
in FY2025. Overall, these changes represent increases of approximately 8.0% in
programs/sessions, 5.7% in children/students served, and 6.8% in revenue.
Figure 2: Children and Students Served by JMZ Programs
Source: OCA analysis of Service Reports FY16, FY17, 18, 23, 24, 25
*OCA was not provided with FY19, 20, 21, and 22
However, according to the Director of Education and our analysis, the program’s
staffing and supplies have not kept pace with this growth. The program has 18
science teachers, three are full-time and the remainder are part-time. The program
experiences high turnover in part-time positions and a slow hiring process resulting
in vacancies that remain unfilled for extended periods. Once hired, the Education
Director estimated that new staff take approximately six months to become fully
efficient. In addition, OCA noted that the supplies budget has increased by
approximately $2,000 over 16 years while the number of students served has more
17,911 17,760
12,853
20,927
23,197 24,525
-
5,000
10,000
15,000
20,000
25,000
30,000
FY 2016 FY2017 FY 2018 FY 2023 FY 2024 FY 2025
#
o
f
S
t
u
d
e
n
t
s
Fiscal Year*
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demand, but the current budget does not provide the additional staffing needed to
support that growth.
Figure 3: JMZ Education Program Earned Revenue by Year, 2020–2025
Source: OCA analysis of JMZ financial performance data (earned revenue by
program, 2020–2025).
Based on the available information provided to the OCA there does not appear to be
a way to clearly connect program activity to budget and actual results. The FY2024
service and revenue report identifies $918,356 in education program revenue.
Additional documentation provided to the OCA shows $789,739 in total actual
revenues in the Service and Revenue 2024 report and $1,403,711 in total actual
expenses in the Budget Performance FY2009-25 report for 2024, across the
combined Outreach, Camp, and Baylands cost centers. OCA noted that neither the
2024 service and revenue report nor the Budget Performance FY2008-24 file
provides a complete breakdown that ties education revenue and expense to program
category. According to the Education Director, staff do not have the capacity to
reconcile these figures, in part because payment receipts sometimes miss a fiscal
year's cutoff and are recorded in the following year. The FY2025 Budget
Performance file reflects this, noting that FY2025 revenue includes some FY2024
payments that were not received or processed until FY2025, which further
complicates year-over-year comparison.
Available financial data also shows that education-related activity requires ongoing
subsidy or budget-variance management. Available budget information shows annual
losses of $494,456 in 2020, $750,607 in 2021, $661,057 in 2022, $431,572 in 2023,
$621,346
$312,694
$554,341
$687,645
$789,739
$990,072
$0
$200,000
$400,000
$600,000
$800,000
$1,000,000
$1,200,000
2020 2021 2022 2023 2024 2025
Re
v
e
n
u
e
Year
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temporary salaries of $520,542 compared with a temporary salary budget of
$349,148.
Figure 4: Education Programs — Actual Revenues vs. Actual Expenses
(Outreach, Camp, and Baylands Combined)
Source: OCA analysis of JMZ education program financial data, 2020–2024. Labels
show the annual operating deficit.
The program also relies on Friends-funded support to provide programming for
underserved youth, but the delivery plan has little margin for error. According to
management, Friends of the JMZ provides $163,000 annually for school programs,
after-school programs, and camp scholarships. The Friends-funded Program Delivery
Plan shows a Total Plan of 578 programs, with $160,176 in planned expense against
$163,250 in total funding available, leaving $3,074, or about 1.9%, between planned
expenses and available funding. Management should assess whether this margin is
adequate.
OCA’s analysis of program survey information found strong customer satisfaction
ratings, but response rates could be improved to ensure greater feedback is obtained
for making program adjustments. According to the Director of Education, the
program uses electronic evaluations completed by participants and teachers to
assess and improve program quality. Survey exports for Fall 2024, Winter 2025, and
Spring 2025 family programs show many satisfaction and likelihood-to-recommend
ratings of 5, with positive comments about instructors and program content. Based on
the provided family program survey export, there were 37 satisfaction responses,
with an average satisfaction score of 4.84 out of 5. Based on the 2025 summer camp
survey export, there were 119 satisfaction responses, with an average satisfaction
score of about 4.92 out of 5. However, the survey exports do not show how many
participants were asked to respond, response rates, or whether the responses are
representative of all school, camp, and family program participants. FY2025 service
-$494,456 -$750,607
-$661,057
-$431,572
-$697,561
-$608,162
$0
$200,000
$400,000
$600,000
$800,000
$1,000,000
$1,200,000
$1,400,000
$1,600,000
$1,800,000
2020 2021 2022 2023 2024 2025
Re
v
e
n
u
e
&
E
x
p
e
n
s
e
s
Year
Total Actual Revenues Total Actual Expenses
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3 What is a Good Survey Response Rate? | SurveyMonkey
response rate could help the JMZ better understand which program elements are
working well and which need improvement.
OCA’s assessment of survey comments found many positive comments and
identified some specific service-improvement opportunities. Family program
respondents requested more hands-on science, noted that some children were too
young to fully participate, and asked for programming after noon so transitional
kindergarten children could attend. Camp survey respondents requested expanded
offerings for older children or tweens, additional weeks of Zoo Camp, and more
communication tools such as photos or take-home materials to help families
understand what children did during their camp experience.
While educational programming has continued to expand, the absence of an
integrated management framework linking service growth with staffing capacity,
hiring timelines, supplies, program costs, funding commitments, revenue recognition,
and performance outcomes limits the program’s ability to manage growth effectively.
Staff interviews highlighted growth expectations without corresponding staffing
budget increases, slow hiring, high part-time turnover, supply budget constraints, and
insufficient administrative support.
Without stronger resource planning, financial reconciliation, and performance
measurement, JMZ management cannot determine whether or not education
program growth is sustainable, program costs and revenues are being reported in the
correct categories and fiscal years, subsidies align with management’s intent,
Friends-funded programs are delivered as planned, or high satisfaction ratings reflect
program-wide effectiveness. Although the program continues to provide valued
services, management lacks the information needed to assess cost recovery, staffing
adequacy, customer demand, access goals, and educational outcomes.
Recommendation ties program activity to staffing, supplies, full program costs, revenues, subsidies,
funder commitments, and evaluation results, so management can determine whether
program growth is financially sustainable, sufficiently resourced, and achieving
outcomes beyond participant satisfaction. Much of the underlying data already exists,
in the service and revenue reports, the Budget Performance files, the Friends-funded
Program Delivery Plan, and the program's electronic evaluations, so the framework
can be built largely by consolidating and reconciling existing data rather than
acquiring new systems. At a minimum the framework should include:
• Staffing and supply measures
Establish workload-based staffing and supply assumptions tied to the number
of programs and students served, and track hiring timelines, vacancies, part-
time turnover, and time for new staff to reach full efficiency. Flag where
service volume outpaces current staffing and supply capacity, including the
recurring supplies-budget overage.
• Budget-to-actual and cost measures
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subsidy or deficit for each program area.
• Financial reconciliation measures
Reconcile the service and revenue reports to the financial records, tie
education revenue and expense to program category, and account for
payments that cross fiscal-year cutoffs so activity can be compared
consistently from year to year.
• Funder and Friends-funded program tracking
Track Friends-funded programs from planned to schedule, delivered,
invoiced, and paid, and monitor the delivery plan's remaining margin and any
unresolved implementation items.
• Program evaluation and outcome measures
Capture survey response rates and the share of participants represented,
trend-analyze survey comments to identify recurring service-improvement
themes and add outcome measures tied to curriculum goals , so program
quality is assessed beyond satisfaction ratings.
• Quarterly management review
JMZ leadership and CSD management should review the framework at least
quarterly and document key trends, decisions, follow-up items, responsible
parties, and target completion dates.
Using the information the framework produces, JMZ and CSD management should
evaluate whether current staffing levels, supply budgets, and subsidy levels are
adequate to sustain program growth, and whether adjustments to program scope,
fees, or resources are warranted to align the program's growth with its budget and
mission.
Management
Response
Concurrence: Agree
Target Date: Q4, FY 2027
Action Plan:
Management concurs with the recommendation. The Junior Museum & Zoo's
Education Program has experienced significant growth in recent years, expanding
both the number of participants served, Educators employed, and earned revenue
while maintaining high levels of customer satisfaction. Management agrees that as
the program continues to grow, strengthening performance reporting and resource
planning will better support long-term operational and financial decision-making.
JMZ is already implementing many of the recommended practices by expanding the
use of service reports, financial data, participant evaluations, and Friends -funded
program tracking to better monitor program performance. During FY2027, these
existing data sources will be consolidated into a more integrated education program
management framework that provides improved visibility into staffing capacity, supply
needs, program activity, revenues, expenditures, funding sources, and overall
program performance.
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and the Friends of the Junior Museum & Zoo to improve financial reporting and
reconciliation while recognizing the timing differences that can occur between
program delivery and revenue recognition across fiscal years. JMZ will also continue
evaluating staffing needs, supply budgets, and program demand to help ensure
resources remain aligned with the continued growth of the Education Program.
Resource needs identified as part of this evaluation will be proposed as part of the
annual budget development process.
Participant feedback will continue to be an important component of program
evaluation. JMZ will implement strategies to increase survey participation and further
enhance outcome-based performance measures to support continuous improvement
and demonstrate the educational impact of its programs.
Finding 3:
JMZ has
strengthened
animal care and
regulatory
compliance
systems earning
accreditation this
past year; but
some safety,
animal welfare and
documentation
controls could be
improved
safety, and regulatory compliance systems as evidenced by the AZA Accreditation,
OCA identified several areas where controls should be more consistently executed
and documented.
During the audit period, the JMZ earned AZA accreditation and continued to
strengthen its animal care and safety practices, including finalizing a signed
veterinary services agreement and maintaining daily animal-care reporting. OCA
identified a few opportunities for management to more consistently document
processes and support required reporting.
Emergency Drills
According to the Zoo Director, the JMZ conducts emergency drills twice a year, more
often than the once-a-year minimum in AZA Standard 11.2.5, but OCA found that
some scheduled drills were not completed. OCA also found drills noted but without
the evaluation record the standard requires. AZA Standard 11.2.5 requires that the
four basic emergency drills be recorded and their results evaluated. The JMZ has
since developed an Emergency Drill/Incident Review Checklist that captures key drill
elements. Completing drills as scheduled and retaining the checklist, lessons
learned, and corrective actions will meet this requirement.
Animal Transport and Vehicle Safety
OCA found documentation gaps related to animal transport too. According to the JMZ
Director, animals taken to off-site educational programs are moved in built, mobile
habitats and transported in employees' personal vehicles, as the JMZ shares a single
City vehicle with other facilities. It appears that education staff do not receive safety
training for City vehicle use, and OCA did not identify a documented policy governing
animal transport. Because the education program operates at scale, more than
24,000 students across 150 schools and community centers in FY25, a documented
transport policy and related training would help ensure the safe and consistent
transport of animals, staff, and materials.
Overall Recordkeeping
AZA standards emphasize the importance of documentation, providing that an
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and multiple separate files, and several assessment and documentation practices are
new or recently implemented, so evidence of completed actions may be hard to track
across different documents. When actions are taken but not consistently
documented, the JMZ has limited ability to demonstrate compliance with AZA
standards or to evaluate whether its controls are operating as intended, even where
the underlying practices are sound.
Finally, during the onsite visit, OCA observed a semi-open elevator/lift shaft in the
zoo area. While OCA did not identify any standards or best practices related to these
types of lifts other than regular maintenance, the opening at the top of the lift when it
is on the ground floor could present a safety risk. According to the JMZ Director, the
JMZ has not experienced any incidents and has a maintenance agreement for the lift.
In addition, the Zoo Director stated that staff check the lift each morning to confirm it
is locked. Given the location, the City may wish to evaluate whether additional
safeguards, such as enclosing the lift area or installing a full-height door, gate, or
barrier, are warranted.
Recommendation
The City and JMZ should establish a centralized safety and compliance tracking
process to support consistent execution, documentation, and follow-up of animal
care, safety, and regulatory compliance controls. The process should identify each
required activity, responsible staff member, frequency, required documentation,
completion date, reviewer sign-off, and any corrective action:
• Emergency Drill Tracking
The process should include annual emergency drill tracking and
evaluation, use of the Emergency Drill/Incident Review Checklist,
documentation of lessons learned and corrective actions, and follow-up for
drills that are postponed or not completed.
• Animal Transport Policy
JMZ should also develop a written animal transport policy for off-site
education programs and other animal movements, including requirements
for approved vehicles, personal vehicle use, insurance expectations,
animal containment, temperature or life-support needs, staff training, trip
documentation, and emergency procedures.
• Quarterly Review of T racker
JMZ and CSD management should review the tracker at least quarterly to
confirm that required activities are completed, documentation is retained,
and corrective actions are addressed.
This would help JMZ demonstrate compliance with AZA documentation expectations
and provide management with a more complete view of whether key controls are
operating as intended.
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Management
Response
Responsible Department(s): Community Services
Concurrence: Agree
Target Date: Q2, FY 2027
Action Plan:
Management concurs with the recommendation. The Junior Museum & Zoo has
made significant investments in strengthening its animal care, safety, and regulatory
compliance programs, culminating in the successful achievement of Association of
Zoos and Aquariums (AZA) accreditation in 2025. Management agrees that
continued standardization of documentation and compliance tracking will further
strengthen existing practices and support ongoing compliance.
Since completion of the audit fieldwork, JMZ has implemented an Emergency
Drill/Incident Review Checklist and completed all required emergency drills. The
checklist provides standardized documentation of drill activities, lessons learned, and
any follow-up actions to support ongoing compliance with AZA standards.
Documentation of these completed drills and review checklists has been provided to
the Office of the City Auditor.
JMZ currently maintains written procedures for the transport of animals for off-site
educational programs. Management will review and enhance the existing policy to
incorporate the additional elements identified in the audit to further strengthen
consistency and documentation.
JMZ will also implement a centralized compliance tracking process and conduct
quarterly management reviews to ensure required animal care, safety, and regulatory
compliance activities are completed, documented, and retained, and that any
corrective actions are identified and addressed in a timely manner.
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Manager
Meeting Date: August 11, 2026
Report #:2605-6368
TITLE
Recommend that City Council approve the HSRAP Grant Program expansion
RECOMMENDATION
Staff recommends that the Policy & Services Committee recommend Council approve a
proposed HSRAP+ approach and associated funding levels and timeframe.
EXECUTIVE SUMMARY
This report recommends an expanded Human Services Resource Allocation Process, referred to
as HSRAP+, for the FY 2028-29 funding cycle building from the City Council direction as part of
the FY 2027 budget process. HSRAP+ would create a transparent pathway for nonprofit
programs that address demonstrated community needs but do not fit within existing HSRAP
priorities or other City funding processes.
HSRAP+ builds on Council direction following the suspension of the Nonprofit Partnership
Workplan Phase I pilot in FY 2027, and expressed interest in determining whether HSRAP
funding levels, eligibility, or scope should be modified to better accommodate innovative or
non-human services nonprofit programs serving Palo Alto residents. Core HSRAP funding would
continue to prioritize direct human services for low-income and vulnerable Palo Alto residents,
and HSRAP+ would expand with additional funding appropriation.
Staff recommends considering an additional HSRAP+ allocation of $100,000 to $200,000,
subject to a recommendation by this Committee and Council budget appropriation. The pilot
would align with the regular HSRAP timeline; policy review in FY 2027 and award
recommendations in FY 2028. Committee recommendation is requested on the proposed
model, funding range, and implementation approach before staff returns with refined
recommendations for Human Relations Commission and City Council consideration.
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BACKGROUND
1, the City Council reviewed the purpose of the NPW Phase I
pilot and discussed potential improvements for FY 2027. As part of that discussion, staff
presented an inventory of nonprofit grants and service agreements over $10,000 to provide a
broader overview of City funding relationships with nonprofit organizations beyond Phase I
grants. The inventory illustrated the range and complexity of those relationships, which were
estimated to total approximately $6.6 million in FY 2027 across multiple funding sources.
Council discussion generally reflected interest in a transparent, equitable, and consistent
framework for nonprofit funding, including clearer guidance regarding how different types of
nonprofit requests should be categorized, reviewed, and funded. Multiyear service agreements
are a significant body of work that will be brought to the Committee later this year.
2, Council also recognized the City’s fiscal constraints,
including projected FY 2027 budget pressures. In that context, Council supported proceeding
without additional NPW Phase I grant funding in FY 2027 and indicated that grant and award
funding should, where appropriate, be considered through HSRAP. Council also acknowledged
that some nonprofit requests considered through Phase I may not fit within current HSRAP
eligibility criteria and expressed interest in evaluating whether HSRAP funding levels, eligibility,
or scope should be modified in the future.
1 April 6, 2026, City Council Meeting:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=87042&dbid=0&repo=PaloAlto
2 May 11, 2026, City Council Meeting:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=88043&dbid=0&repo=PaloAlto
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This report presents options for Committee consideration regarding a potential expanded
HSRAP scope, related funding considerations, and an implementation timeline.
ANALYSIS
HSRAP Expansion
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even if those needs fall outside the traditional human services priority categories. This also
provides a pathway for a more varied portfolio of organizations to access City funding. All
proposers must demonstrate that their program responds to an identified community need,
meets the established proposal evaluation criteria, and does not duplicate an existing City-
funded program or established funding mechanism.
HSRAP+ Funding Options
HSRAP
5
5 FY 2026 Nonprofit Service Agreements, Page 9:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=87042&dbid=0&repo=PaloAlto
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staff anticipates recommending Council approval of $998,992 in FY 2028 and $1,027,620 in FY
2029.
HSRAP+
HSRAP+ Funding Option
Item Funding Notes
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HSRAP+
(Proposed FY 2028 additional
allocation for expansion)
$100,000-$200,000 Proposed additional appropriation for
HSRAP+ expansion; calculated based
on last year’s unfunded nonprofit
requests not receiving direct
allocations
Total Available for Grant
Allocation
$1.1 M-$1.2 M
A $100,000-$200,000 allocation would also create a practical starting funding level for
evaluating whether HSRAP+ should continue in future years. It is large enough to support
multiple nonprofit partners or program areas but limited enough to allow staff and the Human
Relations Commission to assess demand, applicant quality, implementation feasibility within
existing resource levels, and community impact before recommending any long-term funding
structure. In addition, establishing HSRAP+ as a separate appropriation would create a clearer
distinction between the City’s longstanding HSRAP funding priorities and proposals that
respond to other identified or emerging community needs.
HSRAP+ Timeline
Consideration of HSRAP+ is well-timed, as the regular HSRAP cycle typically begins in
September. The proposed schedule would incorporate HSRAP+ into the existing HSRAP timeline
without delaying nonprofit awards. The table below compares the current HSRAP timeline with
the proposed HSRAP+ expansion. Key milestones include a proposed joint Policy and Services
Committee/Human Relations Commission meeting in September, Council direction on funding
levels in October, and Policy and Services Committee award recommendations to Council in
May.
This would differ from the current process, in which the Finance Committee typically reviews
and approves HSRAP funding award recommendations as part of the annual budget. The
proposed change reflects the fact that Council’s initial referral was made to the Policy and
Services Committee, and the proposed HSRAP+ framework would be developed as part of that
Committee’s workplan and policy discussion. As a result, it would be appropriate for Policy and
Services to review recommendations related to the structure, criteria, and implementation of
HSRAP+, including how the expanded applicant pool would be evaluated and incorporated into
the City’s broader human services funding framework.
This approach would not eliminate the Finance Committee’s role in the funding process. The
Finance Committee would retain its role through the annual budget review, including the ability
to review and make recommendations on overall HSRAP+ funding levels as part of the City’s
broader budget deliberations. In this way, Policy and Services would provide policy direction
and oversight for the program framework that originated from its referral, while Finance would
continue to have input on the overarching allocation of City funds through the budget.
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Current and Proposed Timeframe
P&S to discuss HSRAP expansion
opportunities
Survey nonprofits & clients on
human service needs
Survey nonprofits & clients on
human service needs
Joint P&S/HRC meeting on HSRAP+
feedback
HRC sets Priority of Needs HRC sets Priority of Needs
Council to approve HSRAP+ funding
levels
Nonprofit engagement on HSRAP
process
Nonprofit engagement on HSRAP+
process
Application period opens
Application period opens
Application period closes Application period closes
Review committee evaluates
applications
HRC recommends awards Review committee evaluates
applications
HRC reviews and recommends awards
Finance Committee reviews HRC
award recommendations
P&S reviews HRC award
recommendations
Council approves HSRAP awards Council approves HSRAP+ awards
Staff seeks Committee direction on the proposed timeframe and feedback on successful
discussion outcomes with the HRC proposed for September 2026.
This discussion does not have a fiscal impact, however a recommendation to Council will impact
FY 2028 budgeting direction.
Community members, nonprofit partners, and service recipients will be surveyed regarding
human service needs and notified of upcoming meetings, including information sessions on the
HSRAP+ pilot. Additionally, the City’s website will be updated to clearly communicate program
changes, key dates and the overall timeline.
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ENVIRONMENTAL REVIEW
APPROVED BY:
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POLICY & SERVICES COMMITTEE
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: August 11, 2026
Report #: 2606-6468
TITLE
Discuss and Provide Feedback on Housing Element Program 6.5: Alternative Housing Program,
Objective B. CEQA Status: Exempt Under CEQA Guidelines Section 15262.
RECOMMENDATION
Staff recommends that the Policy and Services Committee:
1. Receive information regarding Housing Element Program 6.5(B), Alternative Housing
Program.
2. Review and discuss the Planning and Transportation Commission (PTC)'s feedback from
its April 8, 2026, Study Session regarding:
a. Micro housing and senior housing as the preferred housing typologies for further
study and implementation; and
b. Prioritization of locations near existing high-quality transit for these housing
types.
3. Provide comments and/or feedback regarding:
a. The preferred approach for implementing senior housing;
b. The PTC’s direction on implementing micro housing; and
c. Policy level feedback on the preferred implementation strategy and the
identified incentives.
EXECUTIVE SUMMARY
Housing Element1 Program 6.5(B) directs the City to evaluate innovative housing models,
including micro housing, shared housing, and intergenerational housing, to help meet the
housing needs of aging adults, students, and lower-income individuals citywide. The City
1 Housing Element 2023-2031: https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-
services/housing-element/housing-element_2023_2031/palo-alto-housing-element.pdf
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initiated the Alternative Housing Program to evaluate these housing types and identify
potential zoning and policy approaches to facilitate their development.
3 the PTC reviewed the findings from the Alternative
Housing Program Initial Findings Memo (Attachment A) and discussed potential
implementation approaches. The PTC identified micro housing and senior housing as the
preferred housing typologies and indicated a preference for locating these housing types in
areas with access to existing high-quality transit, services, and community amenities.
BACKGROUND
Allow innovative housing structures such as micro housing and new shared and
intergenerational housing models.
Identify appropriate locations in the City to build alternative housing models.
Develop recommendations and zoning amendments to support alternative housing for
City Council consideration.
3 April 8, 2026, PTC Study Session Staff Report:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=87210&dbid=0&repo=PaloAlto
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while supporting the City’s adopted Housing Element goals related to housing choice, aging in
place, affordability, and efficient land use.
State Laws Influencing Alternative Housing
Planning and Transportation Commission Study Session
Micro housing and senior housing as the preferred housing typologies for further study
and implementation.
Areas near existing high-quality transit as the preferred locations for these housing
types.
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Housing Typologies Studied
In order to implement Housing Element Program 6.5 B, staff evaluated four alternative housing
types: micro-housing, shared housing, and intergenerational housing. These housing types
differ in physical form, operational characteristics, and target populations, but share common
policy goals related to affordability, efficient land use, and housing diversity. A detailed analysis
of the housing types researched, examples of researched housing developed in the region, and
the different geographic areas in the City that are best suited for alternative housing types is
discussed in detail in the Attachment.
Micro Housing
Micro housing consists of self-contained dwelling units that are intentionally designed to be
smaller than conventional studio apartments, typically ranging from approximately 250 to 350
square feet. Each unit contains a private bathroom and kitchenette, allowing residents to live
independently while occupying substantially less floor area than a traditional apartment. Unlike
shared housing or Single Room Occupancy (SRO) developments, which generally rely on shared
kitchens, bathrooms, or other common facilities, micro housing functions as an independent
dwelling unit while providing a more compact housing option.
Although micro housing is generally developed as market-rate housing, the reduced unit size
typically results in lower monthly housing costs than larger studio or one-bedroom apartments
because residents lease fewer square feet. Micro housing therefore provides an opportunity to
expand the City's housing choices by creating housing that may be more attainable for smaller
households without requiring public subsidy. Alternatively, micro housing may also be
developed as deed-restricted affordable housing.
Existing Municipal Code regulations were primarily developed around conventional apartment
development and do not specifically accommodate micro housing. Current standards related to
density, floor area ratio (FAR), height, daylight planes, parking requirements, usable open
space, and site coverage may limit the feasibility of developing smaller housing products. The
Alternative Housing Program evaluates whether targeted modifications to these standards
could facilitate construction of micro housing while maintaining appropriate design quality and
neighborhood compatibility.
Single Room Occupancy Housing Units
SRO housing represents another form of alternative housing that has historically provided
smaller and more affordable housing options for one-person households. Unlike micro housing,
SRO developments generally consist of private sleeping rooms with shared kitchens,
bathrooms, or other common facilities, whereas micro housing consists of self-contained
dwelling units with private kitchens and bathrooms. While the Palo Alto Municipal Code does
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not define SROs as a distinct residential use, the City currently permits SRO-type housing
through its existing residential regulations, including provisions governing efficiency dwelling
units, lodging units, and other residential uses, depending on the design and operational
characteristics of the project.
Shared Housing
Intergenerational Housing
Senior Housing
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State law. Independent senior housing may be developed as either market-rate or deed-
restricted affordable housing depending on the project sponsor and available funding sources.
Alternative Housing and Regional Housing Needs Allocation (RHNA)
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on whether residents occupy separate living quarters intended for independent residential
occupancy. The age composition of residents does not affect whether units count toward
RHNA; rather, eligibility is based on the physical characteristics and occupancy of the dwelling
units.
Existing Definitions and Regulations
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requirements of Government Code Section 65915. Eligibility for a density bonus is governed by
State law and does not imply that all senior housing developments are deed-restricted
affordable housing.
ANALYSIS
Potential Implementation Approaches
Approach 1: Adopt Comprehensive Zoning Amendments
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Approach 2: Amend Key Development Standards in Strategic Locations
Integrated and intentional amendment of development standards such as FAR, parking
requirements, minimum usable open space requirements, and maximum site coverage
in targeted locations. Targeted implementation would prioritize areas with existing high-
quality transit, neighborhood-serving commercial uses, employment opportunities, and
community amenities. This approach is consistent with the PTC recommendation that
micro housing be concentrated in transit-accessible locations where reduced parking
demand, walkability, and access to services support smaller housing formats.
Approach 3: Focus on Key Development Standards in Coordination with State Legislation
State laws such as AB 2097 and SB 79 mandate a series of local zoning changes that will
ease the development of alternative housing. The Alternative Housing Program Initial
Analysis identified other development standard that would increase feasibility of micro
housing products (reduced open space requirements and maximum site coverage
standards). The City may consider implementing specific zoning amendments to parcels
in the TOD areas and Housing Opportunity Sites outside the TOD areas identified in the
2023-2031 Housing Element.
While the implementation approaches focus primarily on micro housing, many of the
development standards being evaluated, including parking, floor area ratio (FAR), open space,
and site coverage may also improve the feasibility of other innovative housing products
identified in Housing Element Program 6.5(B). Staff, based on the feedback from the Policy and
Services Committee, may evaluate whether future zoning amendments should also incorporate
regulatory changes that support shared housing and intergenerational housing as market
conditions and community priorities change.
Senior Housing
Market-rate senior housing expands the City's overall housing supply for older adults by
increasing opportunities for residents to downsize while remaining in the community.
Increasing the supply of independent senior housing may also improve housing mobility by
allowing existing residents to transition from larger homes into housing better suited to their
needs.
Affordable senior housing serves lower-income older adults who may otherwise face housing
insecurity or displacement due to increasing housing costs. These projects typically require
public subsidy, tax credit financing, or other affordable housing funding sources in addition to
land use incentives.
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The overlay options described below are intended to establish where independent senior
housing should be encouraged within the City. Regardless of whether the City pursues a fixed or
floating overlay, the Policy and Services Committee may also wish to provide feedback
regarding whether the overlay should apply equally to market-rate and deed-restricted
affordable senior housing or whether certain incentives should be reserved for affordable
developments that provide an additional public benefit.
Option 1: Fixed Senior Housing Overlay
o Clear geographic boundaries.
o Streamlined project review.
o Tailored development standards and incentives within designated areas.
Option 2: Floating Senior Housing Overlay
o Site-specific review of individual proposals.
o Flexibility to evaluate unique site and project opportunities.
o Potential application in a broader range of locations.
o Greater discretionary review.
Potential Standards, Process Improvements, and Incentives
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every project type, and additional evaluation would occur before any amendments are
presented for adoption.
Development Standards
Modified parking standards in areas supported by transit accessibility.
Adjustments to floor area ratio and maximum site coverage.
Flexible usable open space standards that maintain high-quality outdoor amenities. In
the case of Senior Housing, staff may evaluate greater flexibility in how common open
space is designed and programmed to better accommodate the recreational,
accessibility, and social needs of older adults while maintaining overall project livability,
rather than reducing the overall quality of open space in senior housing developments.
Minimum and maximum unit size standards specific to micro housing.
Implementation Tools
Streamlined permit review, where consistent with existing statutory review timelines
and available staffing resources.
Transportation Demand Management (TDM) measures, including transit pass programs
and mobility incentives for senior housing residents.
Financial Incentives
Evaluation of fee reductions or waivers for deed-restricted affordable housing projects
where supported by City policy and available funding.
Feedback Requested
Alternative Housing Types: Confirmation that micro housing and senior housing should
remain the preferred alternative housing typologies for implementation under Housing
Element Program 6.5(B).
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2.Prioritized Locations: Confirmation that implementation efforts should prioritize
locations with existing high-quality transit, neighborhood-serving commercial uses, and
community amenities.
3.Overlay Type: Consideration between a fixed senior housing overlay or a floating senior
housing overlay as the preferred implementation strategy.
4.Zoning Amendments: Direction on next steps to prepare zoning amendments
establishing development standards specific to micro housing, including regulations
related to parking, floor area ratio, site coverage, usable open space, and objective
design standards.
5.Standards/Tools/Incentives: Input on which implementation tools, development
standards, or incentives should be evaluated further before preparation of draft zoning
amendments.
Next Steps
Following Policy and Services Committee discussion, staff will:
1. Develop preferred implementation approach for senior housing based on Committee
feedback.
2. Develop draft zoning code amendments consistent with Housing Element Program
6.5(B).
3. Present proposed zoning amendments to the Architectural Review Board and the
Planning and Transportation Commission in Q3 or Q4 for recommendation to Council.
FISCAL/RESOURCE IMPACT
The recommendation in this report has no fiscal impact. Incorporating feedback from the
Policies and Services Committee is expected to be accommodated within the existing scope and
budget of the Alternative Housing Program, including the current professional services
agreement with Placeworks, Inc. Should the scope expand beyond current assumptions and
additional resources be needed, staff will bring appropriation actions forward for City Council
approval.
The long-term land use decisions will have a marked impact on the financials of the City and its
tax revenues and population service needs. Balancing revenue generating land uses with critical
housing development is important to consider.
STAKEHOLDER ENGAGEMENT
As part of the analysis for the Alternative Housing Program, the project team conducted
interviews with architects, developers, housing advocates, and other practitioners. The
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feedback received was published in March 2026,5 in advance of PTC Study Session. A dedicated
project webpage6 has been launched and is accessible through the City’s website; the webpage
will serve as the primary platform for ongoing project updates.
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
5 Initial Analysis published in March 2026 for PTC Study Session:
https://www.paloalto.gov/files/assets/public/v/2/planning-amp-development-services/long-range-
planning/alternative-housing/program-6.5b_alternative-housing-program_initial-analysis.pdf
6 Project Webpage: https://www.paloalto.gov/Departments/Planning-Development-Services/Housing-Policies-
Projects/Alternative-Housing-Program
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Palo Alto Alternative Housing Program: Initial Analysis
Study Session - Policy and Services Committee
This report was prepared by PlaceWorks, Inc. (consultants for the Alternative Housing Program)
for the City of Palo Alto. It includes background information, analyses, and potential approaches
to the City of Palo Alto Alternative Housing Project (Project). The Project will partially implement
Palo Alto Housing Element (HE) Program 6.5.
This report is composed of the following sections:
Overview and Summary
Defining Alternative Housing
Existing City of Palo Alto Regulations
Other Jurisdictions Approaches and Projects
Challenges to Alternative Housing
Preliminary Zoning Approaches and Incentives
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Overview and Summary
The Alternative Housing Program was initiated in response to Housing Element Program 6.5(B),
which recognizes that Palo Alto’s existing housing stock does not adequately address the needs of
all household types. While the City’s housing inventory is primarily composed of single-family
homes and conventional multifamily apartments, demographic changes, increasing housing
costs, and changing household composition have created demand for a broader range of housing
options that may better serve seniors, single-person households, young professionals, graduate
students, and other residents seeking smaller and more attainable housing choices. The purpose
of this effort is to evaluate zoning and policy tools that expand housing diversity while supporting
the City’s adopted Housing Element goals related to housing choice, aging in place, affordability,
and efficient land use.
This report prepared as an initial analysis includes research done, outcomes, and the preliminary
approaches related specifically to Implementing Objective B of Program 6.5. The program intends
to:
Allow innovative housing structures, such as micro unit housing and new shared and
intergenerational housing models, to help meet the housing needs of aging adults,
students, and lower-income individuals citywide.
Identify appropriate locations in the City to build alternative housing models,
Make recommendations to City Council and follow up with an ordinance to change local
zoning regulations as directed.
Research completed as part of the 2023-2031 Housing Element indicates the need for alternative
housing due to multiple interrelated demographic conditions, including:
Inaccessible housing. Housing is increasingly unaffordable in Palo Alto. In 2018, 17
percent of all households were cost burdened, or spent more than 30 percent of monthly
income on housing 1. Over 14 percent of households were severely cost burdened or
spent more than 50 percent of their income on housing 2.
Overcrowding. Average household size has increased steadily in Palo Alto, from 2.3
persons per household (pph) in 2000, to 2.5 pph in 2013, and to 2.6 pph in 20203.
Overcrowding disproportionately impacts low-income households. It is exacerbated by
the current lack of larger (three or more bedrooms) affordable rental units. Approximately
3.5 percent of renters experience moderate overcrowding, compared to 0.9 percent of
owners4.
1United States Department of Housing and Urban Development, Comprehensive Housing Affordability Strate
gy (CHAS), based on the 2014-2018 American Community Survey (ACS).
2 Ibid.
3 US Census 2000 and 2010, Department of Finance 2013, and 2016-2020 ACS five-
year estimates (Table S1101).
4U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (
CHAS) ACS tabulation, 2013-2017 release.
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Elderly population. The percentage of elderly persons in Palo Alto has increased
significantly. Residents 65 years and older made up about 13 percent of the population in
1980. In 2020, the elderly made up about 19 percent of the population 5.
Large households. In 2020, Palo Alto was estimated to have about 1,848 households with
five or more members 6, representing approximately seven percent of total households
(owner and renter occupied combined). There is a severe mismatch between the number
of these families and the number of dwelling units sized to accommodate them.
In 2021, traditional single-family homes accounted for over 60 percent of all existing housing
units built in Palo Alto, highlighting the importance of a diversifying the City’s housing stock.
PlaceWorks assessed the three alternative housing models identified in Program 6.5(B), including
micro housing, shared housing, and intergenerational housing, as well as senior housing based
on staff recommendation. PlaceWorks reviewed existing laws, building codes, and industry
standards used to define each model and guide local polices. PlaceWorks also reviewed the City’s
current regulations as well as relevant zoning approaches in other jurisdictions. Finally,
PlaceWorks identified nonregulatory and regulatory challenges to constructing alternative
housing.
This analysis is supported by interviews with nine stakeholders experienced and/or invested in
alternative housing, both locally and in general. The results of this outreach process are
summarized in Appendix A of this document.
SUMMARY PRELIMINARY APPROACHES
This Report identifies potential, preliminary approaches to amending the Palo Alto Municipal
Code (PAMC) to facilitate alternative housing. The housing models identified in Program 6.5(B)
are diverse and distinctly different from senior housing. Hence, senior housing is discussed as a
distinct typology requiring a unique implementation approach in this report. Research and
stakeholder interviews completed as part of this project suggest all are supported by the
following policy frameworks and geographies:
Flexible development standards. The small unit sizes, design challenges and required
densities of micro housing and urban co-living projects generally require generous floor-
area-ratio (FAR) standards, high lot coverage allowances and reduced open space
requirements.
Low parking minimums. Most existing and approved alternative housing projects in the
Bay Area provide no off-street vehicle parking. Many are located in districts without
parking minimums or with parking maximums. Architects and developers consulted
stated that off-street parking requirements are significant barriers to most alternative
housing.
5 US Census 1980, 1990, 2000, 2010, 2010-2012 ACS three-year estimates, and 2016-2020 ACS five-
year estimates (Table DP05).
6 2016 -2020 ACS five-year estimates (Table B25009).
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Transit adjacency. The small units, shared spaces, and typical tenants that define
alternative housing are generally associated with car-free living. Relevant projects thrive
on transit corridors and near transit stations or hubs.
Highly resourced locations. Alternative housing typically includes limited common, private
or recreational open space, and either small or shared living spaces. As noted, projects
are often occupied by zero-vehicle households. As such, these projects are best suited to
sites within walking distance of public parks, grocery and retail, diverse services, medical
facilities and other community resources.
The following preliminary zoning approaches, developed for initial review, consider both the
diversity of different alternative housing models as well as the trends identified above.
A. Adopt comprehensive zoning amendments. This approach involves amending the PAMC to
include cohesive, comprehensive zoning standards for each alternative housing model
prioritized by City leaders. This includes:
• Adopting new definitions and purpose statements for each housing type.
• Adding new types as allowable uses in selected zoning districts.
• Adopting new density, floor area ratio (FAR) and development regulations for each
housing type.
• Amending Contextual Design Criteria and Objective Design Standards (ODS) to further
streamline alternative housing.
B. Amend key development standards in supportive locations. This approach involves increasing
FAR, reducing open space minimums, increasing lot coverage, and reducing off-street parking
requirements in areas that are currently, or are planned to be, suited to alternative housing.
These could include one or more of the following:
• California Avenue Pedestrian and Transit-Oriented Development (PTOD) Combing District.
Multiple stakeholders identified the PTOD as appropriate for alternative housing and the
target of PAMC amendments.
• South of Forest Area Coordinated Area Plan (SOFA 1 CAP). The 2000 SOFA 1 CAP included
City approval of 160 new dwelling units and 30,000 square feet of retail and office space
in a 9-block area. This land use vision, which includes a public park and childcare facility, is
consistent with alternative housing.
• San Antonio Road Area. The ongoing San Antonio Road Area Plan is an opportunity to
zone for alternative housing as part of a larger community vision consistent with such
housing. There is a strong demand for mid-rise multifamily projects in the area, and city’s
proposed vision for the area includes adding new public and private resources to support
new housing.
• ROLM Housing Element Focus Area. This HE focus area includes multiple housing
opportunity sites. Although not currently fully resourced, this focus area will benefit from
the community vision, policies and future implementation of the adjacent San Antonio
Road Area Plan.
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C. Coordinate Amendments with State legislation. This approach includes amending open space
and lot coverage standards within 0.5-mile of the city’s Caltrain stations. This approach would
build on Assembly Bill (AB) 2097, which prohibits public agencies from imposing minimum
parking requirements on any project located within 0.5-mile of a major transit stop, and
Senate Bill (SB) 79, which will require distance-dependent upzoning surrounding transit stops
in urban transit counties such as Santa Clara County.
Elements of one or more of the above approaches could be combined in a final zoning approach.
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Defining Alternative Housing
There is agreement among stakeholders consulted on this project, as well as relevant research
and policy, that there are no standard definitions of the alternative housing products identified in
HE Program 6.5(B). The following initial descriptions are based on various building codes, State
laws, federal policies, and stakeholder input.
These definitions are used to inform the preliminary, potential approaches outlined in Section 6
of this report.
MICRO UNIT HOUSING
“Micro unit housing” or “micro housing” refers to housing products with multiple dwelling units
that typically do not exceed 350 square feet. Related terms include “efficiency housing,”
“efficiency apartments,” “micro apartments,” and “tiny homes.” Existing laws and regulations
primarily regulate individual “micro units” rather than development models that contain them.
There is no standard size threshold beyond which a traditional “dwelling unit” or studio becomes
a “micro unit.” However, the following codes regulate minimum dwelling unit size in California:
• International Building Code (IBC) Section 1208.4, Efficiency Dwelling Units. This section
establishes that “Efficiency Dwelling Units” shall have a living room of not less than 190
square feet (sf), and that such units shall:
o Be provided with a separate closet.
o Be provided with a kitchen sink, cooking appliance and refrigerator, each having a
clear working space of not less than 30 inches (762 mm) in front.
o Be provided with a separate bathroom containing a water closet, lavatory, and
bathtub or shower.
• California Health and Safety Code (HSC) Section 17958.1. This section establishes that
local governments may “permit efficiency units for occupancy by no more than two
persons which have a minimum floor area of 150 square feet, and which may also have
partial kitchen or bathroom facilities, as specified by the ordinance.” Per this code, a
jurisdiction shall not:
o Limit the number of efficiency units in an area zoned for residential use and
located within one-half mile of public transit or where there is a car-share vehicle
within one block of the efficiency unit.
o Limit the number of efficiency units in an area zoned for residential use and within
one mile of a University of California or California State University campus.
o For purposes of this subdivision, any requirements related to density, setbacks, lot
coverage, or height restrictions established by local ordinance are not considered
a limit on the number of efficiency units.
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• California Residential Code (CRC) Section R304.5, Efficiency Dwelling Units. This section
states that Efficiency Dwelling Units shall have a living room of not less than 220 square
feet of floor area. An additional 100 square feet of floor area shall be provided for each
occupant of such in excess of two.
Two architects consulted as part of this analysis stressed that achieving livable micro units that
attract a wide market is difficult within the minimal space parameters of the IBC. This is
consistent with an Urban Land Institute (ULI) survey of developers of micro housing, which found
“…that a micro unit with less than 200 square feet was too small, that a unit with 375 square feet
was too large, and that something in the 275- to 300-square foot range was optimal 7…” This is
about the size of a typical hotel room.
Based on stakeholder input and national research, this analysis assumes that a recommended
local definition for “micro unit” is a dwelling unit of 250 -350 square feet, inclusive of a required,
separate bathroom and functioning kitchenette, with interior space dimensions that comply with
IBC standards.
Accessory Dwelling Units (ADU) are sometimes categorized as micro housing. However, because
ADUs are regulated in Chapter 18.09 of the Palo Alto Municipal Code (PAMC) and are not
included in Housing Element Program 6.5(B), they are not included in this analysis and are not
recommended to be included in the definition of “micro unit” housing.
Multifamily
Multifamily micro housing, or micro apartments, refers to residential or mixed-use projects with
five or more individual micro units. Not all units in these projects must be micro units. Input from
design stakeholders and review of recent projects indicate that multifamily micro housing
projects are typically two to six-story structures designed to maximize density on small sites in
walkable, transit-oriented neighborhoods.
Stakeholders and research suggest that the location of micro housing is a key component of this
housing model. As unit space decreases, so does the need to build such units in highly resourced
locations. In a summary of walkability and location, one legal researcher of micro housing wrote:
“The shrinking of space within private homes may be offset by external amenities 8.” Potential
sites for micro housing in Palo Alto are discussed further in Section 6 of this report.
Multifamily micro housing is attractive to college students, early-career professionals, teachers,
healthcare and service workers, and single-person households earning low to moderate income
levels who seek affordable, well-located housing with access to jobs, transit, and amenities. As
described by one architect, these may be “young professionals who put a premium on vibrant
and convenient locations.” Active retirees are also attracted to the convenience and walkability.
7 Urban Land Institute, 2015, The Macro View and Micro Units, Page 25.
8Infranca, John, Stanford Law & Policy Review, Vol.25, Housing Changing Households: Regulatory Challenges
For Microunits And Accessory Dwelling Units, page 86.
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Car-free residents and those who rely on public transit or active transportation find these units
particularly appealing, as they are typically located in downtown or transit-oriented communities.
Rise Berkeley. This project is located at 2025 Kala Bagai Way in downtown Berkeley. It
includes 48 single- or double-occupancy micro studios ranging from 350 to 427 square feet. The
project is situated on a 3,700 square-foot lot, resulting in a density of 570 units per acre.
Common open space is provided in the form of a landscaped rooftop garden. The project does
not include vehicle parking. October 2025 listings include a 427 square-foot studio for
$1,236/month and a 359 square-foot studio for $999/month.
Detached micro housing refers to a range of housing products commonly referred to as “tiny
homes.” The 2021 International Residential Code, Appendix AQ, defines “tiny house” or “tiny
home” as “a dwelling that is 400 square feet (34 m2) or less in floor area excluding lofts.”
According to the California Department of Housing and Community Development, tiny homes
may be permanent or mobile 9.
Multifamily micro housing is typically considered a higher and better use of urban land than free-
standing detached micro housing. Moreover, City staff and local housing advocates stressed there
is less prioritization and potential for detached micro housing in Palo Alto than for micro
apartments. Thus, this analysis focuses on multifamily micro housing.
Single Room Occupancy Housing Units
Single Room Occupancy (SRO) housing represents another form of alternative housing that has
historically provided smaller and more affordable housing options for one-person households.
Unlike micro housing, SRO developments generally consist of private sleeping rooms with shared
kitchens, bathrooms, or other common facilities, whereas micro housing consists of self-
contained dwelling units with private kitchens and bathrooms. While the Palo Alto Municipal
Code does not define SROs as a distinct residential use, the City currently permits SRO-type
housing through its existing residential regulations, including provisions governing efficiency
dwelling units, lodging units, and other residential uses, depending on the design and operational
characteristics of the project.
The City previously amended its Zoning Ordinance to allow SRO housing consistent with Housing
Element requirements; however, SRO housing is not regulated through a standalone zoning
classification. Depending on the project design, permanent SRO developments may satisfy
the HCD‘s definition of a housing unit and therefore count toward the City's RHNA. Although SRO
housing was discussed as an alternative housing model at the PTC Study Session, the Commission
recommended that implementation efforts under Housing Element Program 6.5(B) focus on
micro housing and senior housing.
9California Department of Housing and Community Development, May 9, 2016, INFORMATION BULLETIN 201
6-01 (MH, FBH, SHL, MP/SOP, RT, OL)- Revised
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SHARED HOUSING
“Shared housing” is an umbrella term for residential projects in which multiple private dwelling
units share one or more communal spaces.
A recent trio of assembly bills (AB 682, AB 1551, and AB 2334) added shared housing projects to
the types of projects eligible for density bonuses if they provide affordable units or senior
housing.
Per AB 682, the following definitions are included in Government Code Section 65915 (7) (A) (i):
• “Shared housing building.” “A residential or mixed-use structure, with five or more shared
housing units and one or more common kitchens and dining areas designed for
permanent residence of more than 30 days by its tenants. The kitchens and dining areas
within the shared housing building shall be able to adequately accommodate all
residents.”
• “Shared housing unit:” “…one or more habitable rooms, not within another dwelling unit,
that includes a bathroom, sink, refrigerator, and microwave, is used for permanent
residence, that meets the “minimum room area” specified in Section R304 of the
California Residential Code and complies with the definition of “guestroom” in Section
R202 of the California Residential Code.”
• “Student housing development:” “… a development that contains bedrooms containing
two or more bedspaces that have a shared or private bathroom, access to a shared or
private living room and laundry facilities, and access to a shared or private kitchen.”
Palo Alto has adopted these definitions and incorporated these products into PAMC Section
18.15.030, Density Bonuses.
California code allows cities to expand or restrict local definitions beyond “the attributes of a
shared housing building beyond the state definition.” Expanding the definition of shared housing
allows cities to capture other federally identified housing models that are consistent with the
goals of Program 6.5(B).
The U.S. Department of Housing and Urban Development (HUD) defines shared housing broadly,
as “a living arrangement in which two or more unrelated people share a house or apartment 10,”
HUD stresses that “[shared housing] is an affordable living arrangement…in urban areas with high
housing costs 11.” The City of Palo Alto is consistent with this characterization.
HUD identifies “co-housing” and “co-living” as formal variants of shared housing.
10U.S. Department of Housing and Urban Development, Office of Policy Development and Research, June 202
1, Insights Into Housing and Community Development Policy, Assessments of Shared Housing in the United S
tates.
11 Ibid.
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Co-housing
Co-housing refers to a development with private, self-contained units clustered around shared
space to form intentional communities. According to the Cohousing Association of the United
States, co-housing is not a financial or legal model. It is a descriptive term for “an intentional,
collaborative neighborhood that combines private homes with shared indoor and outdoor spaces
designed to support…community life 12.” Co-housing projects may include for-sale or for-rent
units and may be organized formally as a co-op or a homeowner’s association. Units are typically
fully amenitized, with shared spaces dedicated to recreation and communal activity.
According to a prominent developer and designer of cohousing projects consulted as part of this
project, these developments are valuable “go-betweens” that attract potential residents
interested in living in small communities rather than single-family homes or large multifamily
projects. Co-housing attracts families, older adults, retirees, and intergenerational households
who seek long-term stability, collaboration, and a strong sense of community. These residents
value shared responsibility, social interaction, and the ability to participate in decision-making
within an intentional neighborhood.
At 2200 Lisa Lane in Pleasant Hill, CA. This is a suburban co-housing
community on a 2.2-acre site. Developed in 2001, the community includes 32 townhouse-style
homes that are individually owned condominiums managed under a homeowner's association.
The community emphasizes environmental sustainability and social connection, featuring energy-
efficient green building design and shared facilities such as a common house with a full kitchen,
dining and gathering spaces, a workshop, organic garden, kiln, pool, and hot tub. Residents
regularly share community meals two to five times per week, supporting a cooperative lifestyle
among households of all ages.
Living
Co-living is an urban housing model in which individuals rent private, often furnished rooms in
multifamily buildings that contain shared common spaces. HUD stresses that co-living
“Frequently target[s] adult professionals in high-demand housing markets 13.” Common shared
facilities include kitchens, dining areas, living areas, and/or recreational areas.
Similar to micro housing, co-living appeals to college students, early-career professionals,
teachers, essential workers, and single-person households who prioritize affordability, flexibility,
and convenience. Co-living residents often prefer furnished, well-located housing in transit-
accessible areas that enable independent yet socially connected living. Together, these housing
models offer diverse, community-oriented, and attainable housing options that meet the needs
of residents seeking connection, affordability, and efficiency in high-cost urban areas.
12 The Cohousing Association of the United States, Cohousing.org, accessed April 23, 2025.
13U.S. Department of Housing and Urban Development, Office of Policy Development and Research, June 202
1, Insights Into Housing and Community Development Policy, Assessments of Shared Housing in the United S
tates.
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Broadway This 595,440 square-foot apartment building is located above the 19th Street
BART station in downtown Oakland. It contains 451 market rate units. A portion of the units are
co-living suites, each with four private bedrooms, two shared bathrooms, and fully equipped
common living and kitchen spaces. Leases are per bedroom. Some bedrooms are furnished with
expandable furniture. As of October 2025, bedroom leases in shared suites started at
approximately $1,700/month.
Living This project is on San Pablo Avenue in Berkeley’s transit rich West Berkeley
Commercial (C-W) District. The four-story, mixed-use building contains 42 private rooms, each
with a private bathroom. A community kitchen and balcony are provided on each floor. The
rooms operate under Berkeley’s Group Living Accommodations (GLA), defined as “A building or
portion of a building designed for or accommodating Residential Use by persons not living
together as a Household. According to the architect, the project was “designed as a prototype for
a new housing type for UC Berkeley grad students and as a model for the greater Bay Area in
addressing the housing crisis.” The project includes no vehicle parking.
INTERGENERATIONAL HOUSING
The United States Census defines “multigenerational household” as a household that consists of
at least two adult generations. “Multigenerational” and “intergenerational” are considered
interchangeable terms. There are two common approaches to intergenerational housing: (1)
programmed intergenerational housing and (2) multigenerational households.
Intergenerational
Programmed intergenerational housing refers to projects designed to support specific
populations of older and younger adults from different families. These developments typically
include eligibility requirements intended to facilitate successful cohabitation and:
• Provide for safety, health, and the necessities of life.
• Promote programs that increase cooperation and interaction between people of different
generations.
• Enable all ages to support each other in relationships that benefit both individuals 14.
As is the case with shared housing, California code establishes specific parameters for this
housing model that can be expanded in a local definition.
• California Civil Code Section 51.3.5 defines “intergenerational housing” as developments
that consist of units for senior citizens (55 or older), caregivers, or transition-age youths
(Individuals aged 18 to 24 who are either current or former foster or homeless youth).
14Harvard University, Joint Center for Housing Studies, 2024, Healthier Lives Across Generations, A Blueprint f
or Intergenerational Living
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Residents of these projects typically share features such as common rooms, dining areas,
recreational spaces, and gardens. These projects are typically publicly subsidized and built by
nonprofits or affordable housing developers.
Intergenerational housing appeals to residents across generations who seek connection, mutual
support, and stability within an inclusive community environment. Seniors benefit from
companionship, safety, and reduced isolation, while younger residents gain financial relief
through affordable living opportunities, and young families benefit from everyday assistance such
as childcare or household support through intergenerational interaction. Caregivers may also live
on-site to provide additional assistance and strengthen community relationships. These
communities integrate shared amenities and social programming to foster mutual support and
enhance the well-being of residents of all ages.
Approved
Avenue The City of Emeryville recently approved the first intergenerational
affordable housing development in California at 4300 San Pablo Avenue, located on a City-owned
site and treated as an emergency shelter under the City’s zoning regulations. The property is
owned by the City and formerly served as the City’s Recreation Center, consisting of portable
office structures. Since 2019, the site has been temporarily used for emergency shelter and
related operations. The development will deliver 68 units of 100 percent affordable
intergenerational apartment homes serving seniors, caregivers, and transition-age youth.
Because the project is classified as an “emergency shelter” use, the project is not subject to
residential density limits or open space requirements, nor does it trigger any development
bonuses or require off-street parking.
Multigenerational
Multigenerational households refer to dwelling units sized and designed to accommodate all
members of households with two or more adult generations. Based on HE data and
programming, this refers to affordable rental units with three or more bedrooms in Palo Alto. The
need is supported by HCD: “Due to the limited supply of adequately sized units to accommodate
larger households, large families often face significant difficulty in locating adequately sized,
affordable housing 15.”
Palo Alto HE Program 6.2, Family Housing and Large Units, calls for the City to “Research and
implement incentives to encourage larger units, such as FAR exemptions for three or more-
bedroom units, and creation of family-friendly design standards.” Therefore, this project does not
assess approaches to multigenerational households.
SENIOR HOUSING
15California Department of Housing and Community Development, Building Blocks webpage, https://www.hc
d.ca.gov/planning-and-community-development/housing-elements/building-blocks/large-families- and-
female-headed-households, accessed April 29, 2025.
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Senior housing is intended to serve adults aged 55 years and older and includes independent
living communities designed to enable older adults to age in place within the community. The
City of Palo Alto prioritizes senior housing in citywide and neighborhood-level policy documents
but has not adopted supportive zoning regulations. The primary zoning tool to promote senior
housing is the overlay zone.
An overlay zone is a supplemental zoning layer placed over a parcel's existing base zoning. Rather
than replacing the underlying district, the overlay adds to or modifies its requirements to
advance a specific objective. The parcel retains its base zoning. Overlays are a common and
flexible land use tool for encouraging types of development in select locations. Housing overlay
zones place a layer of special standards, and often incentives for meeting those standards, over
base zoning to encourage uses such as senior housing.
They generally work through the following elements:16,17,18
• Base districts. Most overlays attach to residential or non-residential base zones while the
parcel keeps its underlying zoning. Potential is often greatest in commercial or underused
zones, where a city can promote infill or find additional housing sites. Overlays can also
be developed to target only some properties within a zone.
• Eligibility requirements. Overlays facilitate a target development type by establishing
qualifying criteria for that development. For example, affordability-based overlays include
a minimum share or level of affordable units, sometimes tiered. For senior housing
overlays, the primary criteria is occupancy restricted to senior citizens, and potentially
other physical or programmatic requirements.
• Special standards or incentives. Overlays typically promote desired development with
special development standards for projects that meet requirements. Typical standards
include increased height, reduced parking requirements, reduced setback or open space,
unit-size flexibility, and in some cases fee waivers.
• Streamlining. Overlays can reduce or exempt qualifying projects from discretionary
review, and where land is not already zoned residential, can avoid a general plan
amendment, cutting time and cost.
Senior housing overlays allow jurisdictions to identify priority locations for senior housing and
encourage project development. Overlays can tailor development standards to the needs of
senior residents and/or physical development requirements; or match the standards of the
existing base district where that is more appropriate.
16 Terner Center for Housing Innovation, April 2019, Affordable Housing Overlay Zones: Oakley.
17 Association of Bay Area Governments, September 25, 2025, Affordable Housing Overlay Zones.
18 San Joaquin Valley Council of Governments, Housing Overlay Zones (HOZs), https://sjvcogs.org/regulatory-
mechanisms/housing-overlay-zones-hozs/.
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Versailles: This 55+ for-sale condominium community is located at 10 Crystal Springs Rd, at the
corner of El Camino Real and Crystal Springs Road in San Mateo, within the E2 (Executive
offices)/R5 (Multiple Family Dwellings, High Density) zoning districts eligible for the SC Overlay.
The project, built in 2008, includes 61 condominium units across a range of one- and two-
bedroom floor plans.
Sequoia Haven This affordable rental community in Menlo Park's Belle Haven
neighborhood was developed by MidPen Housing Corp. and completed in 2017. The
development provides 90 apartments, 86 one-bedroom and 4 two-bedroom units, all restricted
to seniors 62 and older earning up to 50 percent of area median income. Built on the site of the
1960s-era Gateway Apartments, the project replaced 48 aging units and achieved a net increase
of 42 affordable units, made possible by a 2013 City rezone to allow higher density.
Square This affordable senior rental housing was developed by MidPen
Housing Corp. comprises 66 affordable rental apartments restricted to residents 62 and older
earning up to 50 percent of area median income. The project achieved a density of
approximately 127 units per acre, up from a baseline of 35 units per acre, made possible by the
Senior Housing Overlay's reduced unit size standards and shared parking and infrastructure with
the broader Foster Square development.
Based on negotiations between the City and MidPen Housing Corp., the project utilized a parking
ratio of 0.59 spaces per unit through shared parking, resulting in cost savings of approximately
$1.6 million, including $1.27 million in shared infrastructure and $202,000 in parking reductions.
DEFINITION AND RHNA
Whether alternative housing units count toward a jurisdiction’s regional housing needs allocation
(RHNA) is an ongoing topic of concern. The California Department of Housing and Community
Development (HCD) uses the U.S. Census Bureau’s definition of “housing unit” in its regional
housing needs determination (RHND) and RHNA processes. Per this definition, a unit is “A house,
an apartment, a mobile home, a group of rooms, or a single room that is occupied (or if vacant, is
intended for occupancy) as separate living quarters.” Alternative housing products such as
individual microunits or separate condos in shared living projects are consistent with this
definition and would count toward Palo Alto’s RHNA requirement.
Other shared housing, such as co-living group units or programmed intergenerational housing,
may be more consistent with the Census Bureau’s definition of “group quarters,” which are
“places where people live or stay in a group living arrangement that is owned or managed by an
organization providing housing and/or services for the residents.” This concern was raised at a
2022 hearing of the Assembly Committee on Local Government, regarding Assembly 682.
Committee members stressed that the cohousing units envisioned in the bill may not be eligible
to count toward a local government’s RHNA target.
Intergenerational housing may also count toward the City's Regional Housing Needs Allocation
(RHNA) provided the development contains individual dwelling units that satisfy HCD's definition
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of a housing unit. Similar to shared housing developments, RHNA eligibility depends on whether
residents occupy separate living quarters intended for independent residential occupancy. The
age composition of residents does not affect whether units count toward RHNA; rather, eligibility
is based on the physical characteristics and occupancy of the dwelling units.
HCD is currently reconsidering the role of group quarters in the RHNA process. In California’s
Housing Future 2040, The Next Regional Housing Needs Allocation (RHNA) (April 2024) HCD
evaluates the role of group quarters in the RHNA process, and the potential for crediting a wider
range of housing types. According to the report, “some group quarters represent an essential
form of housing that the state has an interest in incentivizing. Creating a more nuanced process
for determining which group quarters are counted in the RHND can help ensure that the state is
fully accounting for the housing need and leveraging the RHNA process to incentivize key housing
types.” Although no action has been taken, the report outlines a series of recommended
statutory changes to adjust how group quarters are treated in the RHNA process.
STATE LAWS INFLUENCING ALTERNATIVE HOUSING
Since adoption of the 2023–2031 Housing Element, the State has enacted several housing laws
that support many of the objectives identified in Housing Element Program 6.5(B).
• AB 130 expanded statutory streamlining and environmental review exemptions for
qualifying infill housing developments.
• State Density Bonus Law continues to incentivize affordable and qualifying senior housing
through additional development capacity and regulatory concessions.
• AB 2097 eliminated minimum parking requirements for qualifying projects located near
major transit stops, improving the feasibility of compact housing products.
• SB 79 further requires local jurisdictions to permit increased residential development
intensity within designated transit-oriented development areas.
Although these laws do not specifically establish standards for alternative housing, they
collectively reduce regulatory barriers and create a policy framework that supports smaller
housing types, transit-oriented development, and housing diversity. The implementation
approaches evaluated in this report build upon these recent State law changes
by identifying local zoning amendments that could further facilitate alternative housing
while remaining consistent with the City's adopted Housing Element and Comprehensive Plan.
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Existing City of Palo Alto Regulations
There is precedent for supporting alternative housing in existing City of Palo Alto land use and
housing policies and regulations.
LAND AND COMMUNITY DESIGN ELEMENT
The Land Use and Community Design Element of the 2030 Comprehensive Plan prioritizes a mix
of housing types. Although no policies refer directly to “alternative housing,” many are consistent
with HE Program 6.5(B). These include:
• Policy L 2.3: As a key component of a diverse, inclusive community, allow and encourage a
mix of housing types and sizes, integrated into neighborhoods and designed for greater
affordability, particularly smaller housing types, such as studios, co-housing, cottages,
clustered housing, accessory dwelling units, and senior housing.
• Program L2.4.5: Update the municipal code to include zoning changes that allow a mix of
retail and residential uses, but no office uses. The intent of these changes would be to
encourage a mix of land uses that contributes to the vitality and walkability of commercial
centers and transit corridors.
• Program L2.4.7: Explore mechanisms for increasing multifamily housing density near
multimodal transit centers.
• Program L2.4.8: Identify development opportunities for below-market rate and more
affordable market-rate housing on publicly owned properties in a way that is integrated
with and enhances existing neighborhoods.
• Policy L-2.5: Support the creation of affordable housing units for middle- to lower-income
level earners, such as City and school district employees, as feasible.
HOUSING ELEMENT
Chapter 5, Goals & Policies of the 2023-2031 Housing Element includes policies that support the
development of alternative housing and the approaches to facilitating alternative housing
identified in this report. These include:
• Policy 2.1: Increase opportunities for affordable housing development through use of
flexible development standards.
• Policy 2.2: Enhance incentives that expand development standard concessions and other
inducements offered as tools to facilitate the development of more affordable housing,
with a mix of affordability levels within mixed-income housing.
• Policy 2.3: Achieve a diversity of rental and homeownership opportunities, including
apartments, townhomes, condominiums, single-family houses, and accessory dwelling
units, micro-units and alternative housing options to accommodate the housing needs of
all socioeconomic segments of the community.
• Policy 3.3: Prioritize funding for the acquisition of housing sites near public transit and
services, the acquisition and rehabilitation or replacement in existing housing, and the
provision for housing-related services for affordable housing.
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NORTH VENTURA COORDINATED AREA PLAN
The development of micro, shared, and/or intergenerational housing in the 2024 North Ventura
Coordinated Area Plan (NVCAP) would partially support the NVCAP’s overarching Housing and
Land Use goal: “Add to the City’s supply of multi-family housing, including market rate,
affordable, “missing middle” and senior housing in a walkable, mixed use, transit-accessible
neighborhood, with retail and commercial services, open space, and possibly arts and
entertainment uses.”
In addition, the relatively high-density land use districts in the NVCAP, shown in Table 1, would
work to accommodate alternative housing.
NVCAP DEVELOPMENT STANDARDS
Density (du/acre)(ft)FAR
Density NV
Density NV
Density NV
Density Residential NV R4
Density Residential NV R3
AFFORDABLE HOUSING FUND
Palo Alto’s Affordable Housing Fund (AHF) was established “to provide financial assistance for the
development, acquisition and rehabilitation of housing affordable to extremely low, very low-,
low-, and moderate-income households that live or work in the City.” The AHF Guidelines,
amended via resolution by the City Council in 2025, are not land use regulations. However, the
document includes language that highlights Palo Alto’s commitment to accessible alternative
housing.
Section C, Eligible Housing Types, Projects, and Activities, identifies “Shared housing, co-housing,
mobile home parks and other special or innovative housing products” as one of the groups of
housing approaches that “Affordable Housing Fund revenues will primarily be used to assist 19.”
All three alternative housing products defined in this report are consistent with this group of
approaches.
Amending local land use regulations to further support these approaches would remove
significant barriers to the fulfillment of AHF objectives.
MUNICIPAL
This section identifies only direct references to alternative housing products in the PAMC. There
are many existing PAMC regulations that are relevant to alternative housing, both as
opportunities for implementation and challenges to production. These will be explored in Section
6 of this document.
19 City of Palo Alto, March 24, 2025, City of Palo Alto Affordable Housing Fund Guidelines.
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Micro housing is not defined in PAMC Section 18.04, Definitions. There are two references to
“efficiency unit” in PAMC Section 18.04. One is under definition (4)(A), as a type of unit allowed
by the State of California as an ADU. The second is under definition (135) “Studio dwelling unit,
efficiency dwelling unit” means a dwelling unit consisting of a single habitable room for living and
sleeping purposes, plus ancillary kitchen and bath facilities.
There is one direct reference to micro housing in the PAMC. Table 1 of PAMC Section 18.52.040,
Off-Street Parking, Loading and Bicycle Facility Requirements, states that one parking space per
micro unit is required, the same requirement for studio units and 1-bedroom units. A table
notation states: “A ‘micro unit’ as used herein means a residential unit of 450 square feet or less.”
Parking standards for “micro units” are documented in the City’s past planning record. A 2018
Staff Report to the Planning & Transportation Commission recommends conducting a public
hearing for a series of draft zoning amendments. One of the amendments is the addition of off-
street parking standards for micro units, set at one space per unit. Unlike the current PAMC, the
2018 draft table notation does not quantify the size of micro units. It states that the parking
standard would be reduced to 0.5 spaces per micro unit on parcels “within one-half mile radius
of a major fixed rail transit station.” This reduction is not included in the current PAMC.
“Shared housing” is not defined in PAMC Section 18.04. However, Section 18.04 includes the
following uses characterized by group living and/or shared facilities:
• (35) “Convalescent facility” means a use other than a residential care home providing
inpatient services for persons requiring regular medical attention but not providing
surgical or emergency medical services.
• (124) “Residential care home” means use of a dwelling unit or portion thereof licensed by
the state of California or county of Santa Clara, for care of up to six persons, including
overnight occupancy or care for extended time periods, and including all uses defined in
Sections 5115 and 5116 of the California Welfare and Institutions Code, or successor
legislation.
• (135.5) “Supportive housing” means housing with no limit on length of stay, that is
occupied by target populations, as defined by Section 53260(d) of the California Health
and Safety Code, and that is linked to on- or off-site services that assist the supportive
housing residents in retaining the housing, improving his or her health status, and
maximizing his or her ability to live and, when possible, work in the community.
Supportive housing shall be considered a residential use of property and shall be subject
only to those restrictions that apply to other dwellings of the same type in the same zone.
Supportive housing programs may use residential care homes wholly or as a part of their
overall facilities.
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As previously noted, the PAMC also includes definitions consistent with recent State density
bonus laws (see Section 2 of this report). These include the following (full definitions not
repeated here):
• "Shared housing building"
• "Shared housing unit”
• “Student housing development"
Per the PAMC, “For purposes of calculating a density bonus granted pursuant to this section for a
shared housing building, "unit" means one shared housing unit and its pro-rated share of
associated common area facilities.”
Intergenerational
Intergenerational housing is not defined or regulated in PAMC Title 18.
However, PAMC Section 9.74.010, Discrimination Against Families with Minor Children In
Housing, states “The overall effect of such discrimination is to encourage the flight of families
from the city, resulting in the decline of stable, intergenerational neighborhoods, the closure of
schools, and the reduction of social and recreational services for children and their families.”
This language indicates that accommodating intergenerational families is an ongoing priority in
Palo Alto, and that implementation of HE Program 6.5(B) is consistent with at least one of the
City’s social and quality of life objectives.
PROJECT APPLICATIONS
The City has received a limited number of applications for micro housing and other alternative
project types over the past decade. Although none have been built as originally submitted, the
entitlement processes indicate both developers’ interest and City’s receptiveness to such
projects. Two examples include:
• 2755 El Camino Real 20. In September 2016, staff recommended that the City Council
conduct a preliminary review of a project to develop a 2.6-acre property with high-
density, multifamily housing. The project included 60 small units and 45 parking spaces,
26 of which would be provided via a “puzzle parking” lift system. The project did not
conform to any nearby zoning and was labeled a potential “pilot for micro housing.” One
councilmember suggested that the City needed a zoning classification that allows for
micro units and highlighted the idea of a “residential, low car impact project.” Staff
presented three options that “could achieve the applicant’s basic objectives,” including
creating a “Pilot Project” in the Public Facilities (PF) Zone District, creating a “micro
housing combining district overlay,” and modifying Pedestrian and Transit Oriented
Development Combining District regulations for the project.
20 City of Palo Alto, City Council Staff Report, ID# 7152, September 12, 2016.
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• Community feedback ranged from support for micro housing to concern over market
viability and traffic impacts. The project was approved with an additional 20 parking
spaces (65 total) parking in 2018, and via the addition of a Workforce Housing (WH)
Combining District to the existing PF Zoning District. The final building, with 57 dwelling
units, completed construction and received occupancy in May 2024.
• 955 Alma Street21. In May 2021, an applicant made a request for a Council Prescreening
to consider a proposal to rezone a site in the SOFA 2 area from RT-35 to Planned
Community/PHZ and redevelop the site with a four-story, mixed-use development with 36
“innovation micro studio residences” averaging 342 square feet (sf). The applicant
requested a 30 percent parking reduction and lift parking. Some residents praised the
project and its location near the Caltrain Station, stating the units were suitable for young
people and those without cars. Others questioned whether it would truly provide more
affordable options, while some highlighted that it was out of context with the
neighborhood and did not fit on the small site. The project was never submitted for
formal review.
Senior housing is not separately defined or comprehensively regulated in Palo Alto. However, the
City has mentions senior projects as “an independent living facility, not a convalescent or a
residential care facility.” Additionally, PAMC 18.52 provides parking standards for senior housing
projects (0.75 spaces/ unit) and 18.15 details eligibility of senior housing projects for density
bonus and waivers (20 percent bonus for 100 percent senior citizen housing development).
The City, however, does not have an established Senior Housing overlay and currently uses one or
more other overlay zones to regulate target uses and locations. These include:
• PAMC 18.12 Single Story Overlay (S) Combining District
• PAMC 18.34 Pedestrian and Transit Oriented Development (PTOD) Combining District
• PAMC 18.60 Alternative Standards Overlay Districts
Cities such as Menlo Park, San Mateo, Lafayette, and Foster City have established a dedicated
senior housing overlay, that is discussed in this report.
21 City of Palo Alto, City Council Staff Report, ID# 12020, May 18, 2021.
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Other Jurisdictions Approaches and Projects
The following section is a brief overview of other zoning-based approaches to alternative housing
and examples of local projects. Due to the small number of alternative housing projects recently
approved or built and the variety of regulatory approaches, it is difficult to draw a direct
association between regulation and construction. Most alternative housing projects are located
in urban markets such as Berkeley and San Francisco. Smaller cities have adopted regulation to
promote alternative housing more recently. While there are fewer approved or built projects in
those communities, this may reflect timing or market challenges rather than the effectiveness of
that regulation.
CITY BERKELEY
The City of Berkeley has the Bay Area’s largest per-capita stock of micro units, and the recent
approval of a unique shared housing project (summarized below) is further indication of the
City’s prioritization of alternative housing. While Berkeley is more urban than Palo Alto and with a
higher student demand for alternative housing, four characteristics of the city’s zoning code help
facilitate these projects:
• Purpose-driven development standards.
• “Per resident” open space standards.
• Lack of Parking Minimums.
• Minimum unit size.
Driven Development
Title 23, Zoning, of the Berkeley Municipal Code includes qualitative and quantitative regulations
to support alternative housing. The zoning districts are guided by purpose statements consistent
with alternative housing, such as reduced open spaces, transit orientation, convenience and
affordability. Development standards such no maximum FAR and 100% allowable lot coverage
were adopted to support these outcomes.
Resident”
Berkeley has separate Minimum Useable Open Space requirements per Dwelling Unit and per
“Group Living Resident.” This was amended from the original 200 square feet of usable open
space per dwelling unit and 90 square feet per group living accommodation resident to 40 square
feet per dwelling unit and 40 square feet per group living resident with the adoption of the 2023
Southside zoning amendment. According to Title 23, Group Living Residents are residents of
“Group Living Accommodations,” which is defined as “A building…designed for or accommodating
a residential use by persons not living together as a household. Group living accommodations
typically provide shared living quarters without separate kitchen or bathroom facilities for each
room or unit.” The reduced resident-based open space requirement facilitates the design and
approval various shared and co-living housing projects.
Lack Parking
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Residential off-street parking minimums are limited to the City’s Hillside Overlay area. In all other
locations, off-street parking is not required for any residential use, including ADUs, dwelling units,
Group Living Accommodations, and various congregate housing types.
The minimum housing unit size allowed in Berkeley is 190 square feet plus a kitchen, as regulated
in the Berkeley Housing Code (Section 19.10). This is smaller than the “ideal” micro unit
identified by stakeholders and existing literature and is consistent with existing building codes.
Other dimensions include:
• Section 19.01, Unit Floor Area. “… Dwelling units…shall have at least one room which shall
have not less than 120 square feet of floor area. Other habitable rooms, except kitchens,
shall have an area of not less than 70 square feet.”
Berkeley’s code also states that “Nothing in this section shall prohibit the use of an efficiency
living unit within an apartment house meeting the following requirements:
a. The unit shall have a living room of not less than 220 square feet of superficial floor area.
An additional 100 square feet of superficial floor area shall be provided for each occupant
of such unit in excess of two.
b. The unit shall be provided with a separate closet.
c. The unit shall be provided with a kitchen sink, cooking appliance and refrigeration
facilities, each having a clear working space of not less than 30 inches in front. Light and
ventilation conforming to this code shall be provided.
d. The unit shall be provided with a separate bathroom containing a water closet, lavatory,
and bathtub or shower.
Berkeley
• Studio 2000. This project consists of 82 studio micro units in City’s Downtown Mixed-Use
District. Twenty percent of the units are below market rate, resulting in a State Density
Bonus allowance. The building is designed with a “sawtooth” facade that allows for
increased light and views. The property is within five minutes walking distance of the
Downtown Berkeley BART Station. The project does not include vehicle parking.
• Cityspace 2539. This is a six-story co-living and micro unit project at 2539 Telegraph
Avenue in the City’s C-T Telegraph District. It includes 354-square foot studios as well as
two-, three- and four-bedroom shared suites. Each suite is centered around a shared
kitchen and living area and is fully furnished. The exterior design is characterized by
oversized windows to capture light and views. The project is adjacent multiple Alameda
County (AC) Transit bus routes and stops. It does not include vehicle parking.
• Berkeley Moshav. This co-housing project broke ground in March 2025. It is in the City’s C-
W (West Berkeley Commercial) District, on a block characterized by two-story multifamily
buildings, automotive and retail uses. The project includes 36 privately-owned, market-
rate condominiums ranging in size from one bedroom to three-plus bedrooms. It
emphasizes multi-generational living and includes two communal kitchens.
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CITY SAN
The City of San Jose adopted co-living standards into Title 20, Zoning, of the City’s Municipal
Code in 2023.
Per Section 20.200.197, a “Co-Living Community” (CLC) is a “residential facility where individual
secure bedrooms rented to one or two persons, are provided for an established period of time
with a lease agreement, in exchange for an agreed payment of a fixed amount of money. To be
considered a Co-Living Community, shared full kitchen facilities must serve six (6) or more
bedrooms, and must include interior common space excluding janitorial storage, laundry facilities
and common hallways.”
Co-living Communities are allowed as special (S) uses in the City’s Downtown Zoning Districts,
and as conditional (C) or special uses in the City’s various Urban Village and Mixed-Use Zoning
Districts. They require permits subject to various criteria approval, such as:
• Bedroom size: CLC bedrooms must be at least 100 square feet in floor area if occupied by
one person, and 150 square feet in floor area if occupied by two persons, excluding closet
and bathroom.
• Common space: CLCs must provide a minimum of 20 square feet of interior common
space per bedroom.
• Management Plan. CLCs must be accompanied by an approved operation and
management plan.
• Design Standards. CLCs must conform to design standards for relevant zoning district.
• TDM Plan. CLC applicants must submit a Transportation Demand Management (TDM)
plan.
Off-street parking requirements for CLCs is on a per-bedroom basis. They are determined by the
results of the required TDM.
• Mesa Terrace (Formerly Gallup and Mesa). This programmed intergenerational housing
development is at 1171 Mesa Drive, in the City’s UR (Urban Residential) District. It
comprises 46 affordable and supportive units built by Eden Housing, Inc. on a 0.38-acre
site. The 5-story wood-frame building over a concrete podium includes 16 studios, 19
one-bedroom units, 5 two-bedroom units, 5 three-bedroom units, and 1 manager’s unit.
Of the total units, 23 are reserved for transition-age youth, young adults who have aged
out of the foster care system and need stable housing, while the remaining units are
rented to families, creating an intentionally mixed and supportive community. There is a
1,000 SF community room on the ground floor.
CITY MOUNTAIN VIEW
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The City of Mountain View has adopted regulations to support micro housing in specific planning
areas. These include establishing desired ratios of micro units in specific districts and eliminating
parking minimums in target geographies. For example:
• North Bayshore Precise Plan. The City’s North Bayshore Precise Plan (amended 2021) is
shaped by a series of urban-oriented land use goals, including housing affordability,
concentrated growth, walkable blocks, and the promotion of active transportation. The
Plan establishes a housing unit mix goal of 40 percent micro units in the Plan’s North
Bayshore District. Micro-units are defined as dwelling units “up to 450 square feet and
without a separate bedroom.” The Plan also establishes an off-street parking maximum
for micro units of 0.25 spaces/unit.
• Plan-wide elimination of parking minimums. The City eliminated parking minimums for
residential uses in the plan areas of the Downtown Precise Plan, El Camino Real Precise
Plan, San Antonio Precise Plan, and East Whisman Precise Plan. These are considered
“transit-oriented Precise Plan areas with the greatest development opportunities.”20
The City of Mountain View has not established specific regulations for shared or
intergenerational housing in its municipal code. However, the city approved the Mountain View
Cohousing Community, a downtown development consisting of individually owned condominium
homes.
• Mountain View Cohousing Community. Like Berkeley Moshav, this is an example of
market-rate co-housing community, located at 1445 Calderon Ave. The community
includes 19 individually owned, single-level condominium-style homes ranging in size
from 1,400 to 2,000 square feet, situated on land held collectively by the community
membership. The 1.1-acre site is within the downtown area of Mountain View The
development includes three buildings: a main three-story structure with 15
condominiums, a 6,000-square-foot common house, and a roof deck; a second three-
story building with additional units, a townhouse, and a workshop; and a restored historic
farmhouse that serves as a meeting place and guest house. Two parking spaces per
owner are provided underground. The community operates through consensus-based
governance, with all households participating in major decisions and contributing weekly
to the upkeep of shared spaces.
CITY SAN FRANCISCO
San Francisco is highly urban with a diverse population. The City regulates both shared and
intergenerational housing in its municipal code by allowing key uses within defined geographies.
Group Housing is defined as “a Residential Use that provides lodging or both meals and lodging,
without an individual or limited cooking facilities or kitchens, by prearrangement for 30 days or
more at a time and intended as Long-Term Housing.” Examples of Group Housing include a
Residential Hotel, boardinghouse, guesthouse, rooming house, lodging house, residence club,
commune, fraternity or sorority house, monastery, nunnery, convent, or ashram.
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The City requires that the residential square footage of Group Housing include both common and
private space. Specifically:
• For every gross square foot of private space, 0.5 gross square feet of common space shall
be provided.
• At least 15 percent of the common space must be devoted to communal kitchens.
• A minimum of one kitchen is required for every 15 Group Housing units.
Micro housing and shared housing is further accommodated by Special Use Districts (SUDs) that
offer increased density allowances and flexible development standards. The modifications of
standard zoning regulations apply to all geographic areas identified by the SUDs.
One SUD facilitates increased density allowances and flexible development standards for family
and senior housing. The City defines Senior Housing as “a Residential Use defined as dwellings
that are specifically designed for and occupied by senior citizens.” The modifications of standard
zoning regulations apply to all geographic areas identified by the SUD.
The following alternative housing projects reflect San Francisco’s prioritization of alternative
housing:
• SmartSpace Micro Apartments. Located in the SOMA district. The SmartSpace project
provides 23 micro-apartment units, each approximately 295 square feet in size, within a
total building area of 11,740 square feet. The units feature a full kitchen, queen-sized
bed, dining table, full bathroom, and ample built-in storage.
• The Village. Located in downtown San Francisco between the Union Square and Civic
Center areas. A multigenerational co-living community of 18 residents, adults, children,
parents, and non-parents, living together. The home includes 18 bedrooms, 3 kitchens,
and 9 bathrooms across three connected flats, with shared spaces such as a playroom,
tearoom, and multi-purpose area.
CITY SEGUNDO
Although outside the Bay Area, the City of El Segundo is an example of a small California
jurisdiction (population 17, 272) that regulates micro-units and micro-housing comprehensively
in a dedicated chapter of the zoning code.
The purpose of Chapter 15-13C, Micro-Units, is “to encourage the production of a more diverse
housing stock and more affordable housing options. In enacting this chapter, it is also the intent
of the City to implement the goals, objectives, and policies of the Housing Element of the City's
General Plan.”
The City defines “Micro-Unit Developments” as “housing developments containing 5 or more
units 250 to 450 square feet.” The code also states that:
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• 50 percent of the micro-units in a project must be at least 350 square feet in floor area.
• A maximum of 25 percent of residential units in a development may be micro-units,
unless otherwise agreed to via development agreement.
• Micro-unit developments shall comply with a series of operational standards, such as
minimum length of resident stay, per-unit occupancy limits, and submission of a
development management plan.
Per Section 15-13C-2, micro-unit developments are permitted in the following zones and
districts:
• Multifamily Residential (R-3) Zone.
• Housing Overlay (HO) District.
• Mixed-Use Overlay (MU-O) District.
• Downtown Specific Plan (DSP).
Parking standards require one space for studios and one-bedroom units, and 1.5 spaces for two-
bedroom units. As is the case with other local approaches to alternative housing, deviations from
parking standards require the submission of a TDM program and provision of mobility amenities,
such as shuttles to transit stations, on-site childcare, and on-site bike-share stations.
Section 15-13C-10, Design Standards, established a basic set of standards specific to micro-unit
developments. They include required nine-foot ceiling heights, direct access to natural light, and
total window space that is at least 15 percent of the unit’s total gross floor area.
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Challenges to Alternative Housing
The following discussion is based primarily on input from stakeholders consulted on this project
and analysis of other jurisdictions’ approaches. There is general agreement that developing
alternative housing faces multiple nonregulatory and local regulatory barriers. There are also
potential approaches to overcoming each of these challenges, as outlined in the following section
of this report.
NONREGULATORY CHALLENGES
The following potential challenges were identified by one or more stakeholders. They are also
consistent with existing research and initial analysis for this project. Each will influence the
potential for alternative housing in Palo Alto.
Financial Feasibility. Developers of co-housing, designers of micro housing and the
housing finance expert consulted for this project highlighted current financial challenges
that may influence the construction of alternative housing as much as local regulation.
These include lack of market demand, high interest rates, liability and insurance costs and
construction costs. Stakeholders stressed the difficulty of acquiring lending for all but the
largest multifamily projects, as well as liability concerns may result in extremely high
insurance costs. The co-housing developer stated that developing co-ops and co-living
projects as BMR developments is typically financially infeasible. According to one
designer, “In today’s financial environment, only large projects can access the resources
that allow you to dip into the lower income spectrum.”
Affordability. There are concerns that housing costs do not decrease in proportion to unit
size. Rents for smaller units are not sufficiently less than rents for slightly larger units,
particularly when rents are based on BMR income limits instead of market/size of unit.
However, most studies in markets such as San Francisco and Seattle indicate that micro
housing is significantly more accessible than traditional housing. According to a May, 2025
study, the average rent of a micro unit in San Francisco was $1,888.00 and the average
rent of a conventional unit was $3,516.00. In Seattle, the average rent of a micro unit was
$1,289.00 versus a conventional rent of $2,388.00.
Community Concerns. As noted in Section 3, past applications for micro housing have
been met with mixed opinions from community members. Due to their innovative nature,
alternative housing products are less familiar to members of all communities than
traditional housing types. Stakeholder input and public feedback to past applications
indicates this may be a challenge in Palo Alto. As stated in the HE, most housing in Palo
Alto consists of single-family homes. Multiple stakeholders stressed that residents have a
history of strong, consistent opinions regarding housing development. This has resulted in
predictability in many cases, but according to one stakeholder, may result in the
community viewing micro housing or shared housing products as “a ‘step down,’ rather
than a needed lateral approach.”
REGULATORY CHALLENGES
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Palo Alto land use and housing policies reviewed in Section 3 of this report indicate broad
support for local alternative housing. The following section outlines City of Palo Alto zoning,
development and design standards that may impede the construction of alternative housing.
Lack of Formal Definitions
As previously stated in this Report, PAMC Section 18.04 does not include formal definitions of the
three alternative housing approaches included in HE Program 6.5(B). As a result, associated
standards and regulations cannot be accurately assessed and adopted, and it is difficult to
identify districts in which the uses may be allowed. Moreover, without definitions, what
constitutes each product is open to discretion by applicants, City staff and community members
alike. This prevents streamlining and accuracy in the entitlement process.
Lack Integration Zoning
Associated with lack of definitions, neither micro housing, shared housing or intergenerational
housing is identified in land use tables of any zoning districts. Therefore, each application for
these uses requires an interpretation of appropriateness by the Director, per PAMC Section
18.08.080.
Moreover, the absence of alternative housing in land use tables means that none of the models
are referenced in the “Purposes” statements of any zoning district. The result is an overall lack of
City prioritization of alternative housing. As identified in Section 3, numerous Palo Alto policies
encourage supporting the construction of alternative housing in various multifamily and
commercial/mixed use districts. This language could be used to develop relevant, consistent
PAMC purpose statements.
Potentially Restrictive FAR
Stakeholder input collected for this analysis, review of other jurisdictions’ regulations and past
project applications suggest that FAR is a greater barrier to alternative housing, specifically micro
housing, than units/acre standards. PlaceWorks understands that the City of Palo Alto has
recently adopted, or is currently studying, FAR increases through the Housing Incentive and
Affordable Housing Incentive programs, and in various study and focus areas. Most of these areas
are consistent with the type of walkable, transit-oriented urban nodes that are amenable to
alternative housing. In addition, the PAMC includes multiple paths toward FAR increases. These
include locating sites on El Camino Real in CN and CS zones, FAR increases for housing
developments of 3-10 units (PAMC 18.18.065), project locations in specific assessment districts,
and projects that include seismic or historic upgrades.
PROPOSED HOUSING OPPORTUNITY DEVELOPMENT STANDARDS
Existing Residential
FAR Residential FAR
Density Multiple-Family Residence (RM-40) 1.5 4.0
-C Downtown Commercial Community Subdistrict 2.0 4.0
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CD-N Downtown Commercial Neighborhood Subdistrict 1.5 3.0
NV-R4 High Density Multiple Family Residential 3.0 5.0
NV-MXH High Density Mixed-Use 3.0 5.0
Potentially Restrictive Parking Requirements
Nearly all stakeholders interviewed as part of this project stressed that alternative housing, with
typically smaller units or shared spaces, justifies and requires reduced parking requirements.
Designers and local housing advocates identified Palo Alto’s current off-street parking
requirements as a potential barrier to these products. To facilitate this, there is also general
agreement that these products should be built in walkable, transit rich areas.
PAMC Section 18.52.040 Minimum Off-Street Parking Requirements for Multifamily Uses shows
that shared units and intergeneration housing are not regulated. The requirements for micro
units are greater than ADUs and the same as studio and 1-bedroom apartments. Additionally, the
current maximum size of a micro unit in Palo Alto (450 sq. ft.) is equivalent to many studios,
making it difficult to justify a reduced parking requirement. As previously noted, this is the only
reference to “micro units” in the PAMC.
CURRENT STREET PARKING MINIMUMS
Parking Requirement
No. spaces)
Bike Parking
Requirement No.
spaces)
Accessory Dwelling Unit None None
Accessory Dwelling Units None None
-Family Residential (R-2 & RMD Districts) 1.5 1 per unit
Multiple-Family Residential
Unit (450 sq. ft. or less) 1 1 per unit
Unit 1 1 per unit
-Bedroom Unit 1 1 per unit
-Bedroom or Larger Unit 2 1 per unit
Source: PAMC 18.52.040, Table 1
As will be assessed in Section 6, recent State legislation was passed to reduce parking
requirement and manage parking policy around major transit stops in California.
Lack Objective
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Like most Bay Area jurisdictions with objective design standards (ODS), Palo Alto’s ODS apply to
development types included in state streamlining laws and those indicative of regional housing
trends. These include:
• Traditional multifamily and mixed-use development forms, including townhouses (PAMC
Chapter 18.24).
• Townhome style multifamily projects, or “Village Residential” (PAMC Section 18.13.060).
As has been stressed, the alternative housing products assessed in this report are diverse in form
and utility. Palo Alto’s current ODS do not account for these differences, which include, but are
not limited to:
• The impacts of micro unit size on external façade patterns and massing breaks.
• The diversity of scale and massing that may be associated with shared and micro housing.
• Varied design and placement of private open spaces.
• Changes to entryway standards resulting from primary common areas rather than
individual units.
• Design of common open spaces and shared facilities.
• New standards for lighting and ventilation.
Potentially Restrictive Requirements
Multiple architects and planners interviewed for this project identified the City’s open space
requirements as a barrier to past multifamily housing applications, and a potential barrier to
alternative housing projects. They cited two potentially challenging components of the
standards:
• The minimum usable open space minimum, set at 150 sq./ft. per unit in most high-
density and commercial mixed-use districts.
• The existence of multiple, interrelated open space standards, including:
• Minimum usable open space.
• Minimum common open space.
• Minimum private open space.
• Minimum landscape/open space coverage.
As suggested, this group of standards can be restrictive and is often perceived as overly complex.
This may be particularly true for innovative housing types defined by shared common and open
areas, small units that maximize living areas, and designs that assume residents will utilize
surrounding open spaces and resources.
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Preliminary Zoning Approaches and Incentives
The following sections include a series of preliminary approaches to facilitating alternative
housing via PAMC amendments.
APPROACH COMPREHENSIVE ZONING AMENDMENTS
As is the case in most Bay Area cities, Palo Alto’s regulations for alternative housing types are
currently limited and not fully cohesive. Amending the PAMC to include an integrated and
intentional approach to regulation could support these housing models. As part of this approach,
the City would:
a. Define New Housing Uses
b. Integrate Uses into Appropriate Districts
c. Amend Development Standards
d. Tailor Design Criteria and Objective Design Standards
Define New
This strategy includes formally defining each model, identifying one or more as an allowed land
use in selected districts, adding purpose statements to those districts that document the City’s
support for such approaches and adopting development standards specific to the new uses. The
following may be used to shape future definitions:
• Micro housing. Micro units should be defined as dwelling units of not more than 350
square feet, including a living room of not less than 220 square feet of floor area.
Required amenities such as a kitchen sink, cooking appliances and refrigerator, as well a
functional separate bathroom with lavatory, bathtub or shower should be identified.
• Shared housing. The definition of shared housing should be consistent with, but expand
on, recent State Density Bonus law updates. It should include the required ratio of
bedrooms to shared kitchens, as well as tenant and operational requirements.
• Intergenerational housing. Palo Alto should define intergenerational housing as
developments with 10 or more units that are programmed with various multigenerational
eligibility requirements and an approved operations plan.
The following are examples of districts considered appropriate for alternative housing, based on
location and existing purpose statements:
• RM-40 High Density Multiple-Family Residence: This district is “…intended to create,
preserve and enhance locations for apartment living at the highest density deemed
appropriate for Palo Alto. The most suitable locations for this district are in the downtown
area, in select sites in the California Avenue area and along major transportation corridors
which are close to mass transportation…”
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• CD-C Downtown Commercial: The purpose of the district includes “…accommodating a
wide range of commercial uses serving city-wide and regional business and service needs,
as well as providing for residential uses and neighborhood service needs…”
• CS Commercial Service: As noted by City staff, many major housing projects in Palo Alto
are occurring on CS Commercial Service zoned parcels. The purpose of the district
includes “...create and maintain areas accommodating citywide and regional services that
may be inappropriate in neighborhood or pedestrian-oriented shopping areas, and which
generally require automotive access for customer convenience, servicing of vehicles or
equipment, loading or unloading, or parking of commercial service vehicles.”
• NVCAP Districts: The NVCAP establishes an innovative vision for transit, mobility, and
shared space that is consistent with alternative housing. In addition to transit accessibility,
the Plan outlines a vision for public pedestrian access, stating: “Central to the vision for a
re-imagined North Ventura neighborhood is a shared street, or “woonerf,” along Portage
Avenue…that can provide a placemaking space for community gatherings, events, retail,
and other flexible uses.” The following NVCAP districts would support alternative housing:
o NV-R4 High Density Multiple-Family Residential District: This district is intended to
“create, preserve and enhance locations for apartment living at the greater
density deemed appropriate for NVCAP. The most suitable locations for this
district are along major transportation corridors which are close to mass
transportation facilities and major employment and service centers.”
o NV-MXH High Density Mixed-Use District: This is intended to “…ensure
neighborhood- oriented retail and services are provided within walking distance of
high density residential…”
Development
Another component of a comprehensive zoning approach involves amending and/or creating
new development standards to accommodate alternative housing. This could include base FAR,
parking requirements, minimum useable open space and maximum site coverage for the select
districts.
Objective
The final potential component of a comprehensive zoning approach includes tailoring Palo Alto’s
design direction to the unique physical and design characteristics of alternative housing.
Currently, PAMC Chapter 18.24 includes Contextual Design Criteria and ODS. This combination
offers applicants the flexibility to undergo traditional discretionary review or streamlined
ministerial review. Moreover, many projects to which ODS apply, including those consistent with
State Density Bonus, can use waivers to adapt ODS to their desired project. Regardless, the
availability of subjective and objective design standards is an important facet of regulating
multifamily and residential mixed-use projects. Tailoring this regulation to alterative housing
would result in a similar comprehensive approach.
As highlighted by stakeholders and indicated by approaches in other jurisdictions, the following
design characteristics of alternative housing project may differ from traditional multifamily
projects:
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• Site layout. Shared housing often contains a central open space resulting in a campus-
style, internally facing layout composed of multiple small buildings. Many ODS do not
account for this campus-style development, with standards for building orientation,
façade breaks, street facing elevations and other standards that respond to traditional,
single building projects.
• Façade articulation. Micro-units may significantly impact the design of external building
elevations. Their size results in more compressed unit breaks, while the reduction in
private open spaces alters façade patterns. Current Palo Alto ODS for façade articulation,
vertical and horizontal recesses and projections, and datum requirements may not
translate to alternative housing forms.
• Open space planning. Current ODS contain standards for private and common open
space. The standards do not account for shared facilities, and existing minimum size
requirements may be too large for micro-unit spaces.
• Lighting and ventilation. Designers stressed that a key challenge for micro housing is
ensuring that all units receive adequate light and ventilation. Standards for these
developments should include updated minimum window area and shade structure design
requirements.
These represent a sample of design components that, if regulated via ODS tailored to one or
more alternative housing approaches in lieu of the existing parallel standard, would support
these housing types. As part of this approach, the City could:
• Amend various Contextual Design Criteria sections to include design statements in
support of alternative housing.
• Adopt a new set of design standards applicable only to alternative housing. These
standards would regulate relevant issues such as access to light and adequate ventilation,
private and common open space design, window location and total area, and internal
hallway and stair design.
• Amend existing standards to include optional standards for alternative housing types.
These could include standards for building entries into primary common areas for shared
housing, reduced ceiling height requirements, reduced minimum façade breaks for micro
apartments, and revised façade design standards that allow for the compressed external
patterns created by micro units and their private open spaces.
APPROACH AMEND KEY STANDARDS IN STRATEGIC LOCATIONS
Rather than adopt comprehensive, district-wide Title 18 amendments to support alternative
housing, the city could limit amendments to key development standards in specific locations
consistent with the urban contexts shown to support alternative housing.
Stakeholders, research, and past project applications in Palo Alto suggest that alternative housing
is sensitive to restrictive FAR, open space and off-street parking standards, and that it thrives in
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transit-oriented, highly resourced areas. One approach for Palo Alto could be to amend these
standards in one or more of the following supportive geographies (see Figure 1):
• California Avenue Pedestrian and Transit-Oriented Development (PTOD) Combining
District. Multiple local housing advocates interviewed as part of this project identified the
PTOD as appropriate for alternative housing and the target of associated PAMC
amendments. Per PAMC 18.34.010, the PTOD is intended “to allow higher density
residential dwellings on commercial, industrial and multi-family parcels within a walkable
distance of the California Avenue Caltrain station…” and foster densities that “support the
use of public transportation…Encourage a variety of housing types… Implement the city's
Housing Element and Comprehensive Plan.”
It should be noted that most of the PTOD Combining District boundary is within 0.5-miles
of the California Avenue Caltrain Station. As such, the area is subject to the upzoning
requirements of SB 79 and parking requirements of AB 2097 and could be included in
Approach 3, below.
• South of Forest Area Coordinated Area Plan (SOFA 1 CAP). The 2000 1 CAP included City
approval of 160 new dwelling units and 30,000 square feet of retail and office space in a
9-block area. This land use vision, which “provides increased housing opportunities
convenient to shops services, and transit,” and resulted in a public park, is consistent with
alternative housing. Additionally, SOFA 1 policies such as Policy L-12 support non-
automobile-oriented development, stating “…new commercial, residential. and mixed-use
development shall, to the greatest extent possible, incorporate measures into their
design and operation to mitigate potential nuisance conflicts with existing automobile
and other service uses in the MU and AMF land use designation.”
It should be noted that most of the SOFA 1 boundary is within 0.5 miles of the Palo Alto
Caltrain Station. As such, the area is subject to the upzoning requirements of SB 79 and
parking requirements of AB 2097 and could be included in Approach 3, below.
• San Antonio Road Area. The 2023-2031 Housing Element establishes a pair of housing
Focus Areas associated with GM (General Manufacturing) and ROLM (Research, Office
and Limited Manufacturing) districts. Development standards for these housing focus
areas, including FARs of up to 2.5, are established in PAMC Section 18.14.20. The Housing
Element also calls for extending the local Housing Incentive Program (HIP) to these focus
areas, which would further facilitate alternative housing.
Program 6.6 of the Housing Element calls for developing the GM (General Manufacturing)
Focus Area into a local area plan. Currently, this area of Palo Alto does not contain the
diversity of transit and community resources that typically support alternative housing.
However, as stated in Housing Element Program 6.6.C, the area plan would include
integrating housing with multi-modal transportation and facilitating accessible
retail/service amenities, parks and open spaces, and various placemaking improvements.
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The now ongoing San Antonio Road Area Plan is an opportunity to zone for alternative
housing as part of a larger community vision. As stated in current Plan documents, there
is strong demand for mid-rise multifamily projects in the area, and it is understood that
the area requires a vision for new public and private resources to support new housing.
• ROLM Housing Element Focus Area. The ROLM Focus Area, which is located adjacent to
the current San Antonio Road Area Plan is a separate target for alternative housing
upzoning. It includes a series of housing opportunity sites and would benefit from the
community vision, policies and future implementation of the San Antonio Road Area Plan.
FAR increases and potential other amendments could be tailored to these areas and adopted
separately. This approach could also be implemented in the form of an overlay zone, as has been
suggested by previous City Council members in response to relevant projects (see Chapter 3 of
this Report).
APPROACH COORDINATE WITH LEGISLATION
Two recent state laws mandate a series of local zoning changes that will ease the development of
alternative housing in areas shown to support such housing. In this zoning approach, Palo Alto
would limit zoning amendments to station areas to build on these state mandates.
Assembly Bill 2097 (2022) prohibits a public agency from imposing or enforcing any minimum
automobile parking requirement on a residential, commercial or other development project
located within one-half mile of a major transit stop. Per Section 65863.2 of the CA Government
Code “the Legislature finds and declares that the imposition of mandatory parking minimums can
increase the cost of housing, limit the number of available units, lead to an oversupply of parking
spaces, and increased greenhouse gas emissions.”
When effective July 1, 2026, Senate Bill 79 (2025) will override local zoning limitations to allow
greater heights and densities for residential development near transit stops in urban transit
counties, including Santa Clara County. The Bill includes a tiered approach to height, density and
FAR upzoning requirements based on the type of transit stop and distance from the stop. All
three Caltrain stations in Palo Alto are considered Tier 1 stations. As shown in Table, required
maximum heights range from 65 – 95 feet, densities from 30 – 160 du/acre, and FAR from 3.0 to
4.5.
Development (Tier 1)
Development
feet)
Residential Density
Residential
Ratio (FAR)
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As indicated by research and stakeholders interviewed, micro and shared housing products will
likely benefit from parking and intensity changes resulting from these bills. This approach
includes amending the City’s open space and site coverage standards for sites within 0.5-mile of
the City’s Caltrain Stations to maximize alternative housing-friendly regulation near transit.
Existing PAMC open space standards: Minimum Landscape/Open Space Coverage and Minimum
Usable Open Space can be amended to a “Per shared housing resident” standard applicable to
alternative housing projects.
Maximum Site Coverage Amendments
The densities and designs of alternative housing projects are challenged by site coverage
restrictions. Maximum Site Coverage areas within 0.5-mile of Palo Alto’s three Caltrain stations
can be increased to 100%. This is consistent with North Ventura Medium and High-Density
Mixed-Use Districts (PAMC Chapter 18.29).
POTENTIAL INCENTIVES FOR MICRO , SHARED, AND INTERGENERATION HOUSING
As noted in previous sections of the report, alternative housing projects face significant feasibility
challenges. Palo Alto could reduce these challenges by adopting a series of amendments across
various policies and regulations. These include, but are not limited to:
Inclusionary Housing Requirements
The developer of shared housing projects interviewed as part of this project stated that the
affordability requirements of all inclusionary housing ordinances are extremely difficult to fulfill
via the addition of affordable units. In-lieu fees are typically the selected path to compliance. Palo
Alto’s inclusionary requirements range from 15 to 25 percent, as established in PAMC Chapter
16.65, Citywide affordable housing requirements.
The City could consider performing a focused feasibility analysis to assess the potential for
reduced affordability requirements specifically for shared, intergenerational, and micro housing;
and/or adopting new incentives to ease compliance with affordability housing requirements.
Transportation Demand Management Measures
Past research, current analyses, and outreach conducted for this project suggest that alternative
housing has a different relationship with the surrounding mobility landscape than traditional
single and multifamily housing. As a result, these products could be supported by a combination
of reduced parking requirements and new “pre-approved” transportation demand management
measures that supplant all PAMC Section 18.29.110 Transportation Demand Management Plan
(TDM) submission and review requirements. Demand measures could include:
• Subsidized transit pass programs
• Transit access support programs for seniors
• Shared bike facilities
• Delivery service facilities
• “School pool” programs
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• Car share stations
The City could adopt these measures as a full list to be included in projects, or as a list from
which different alternative projects must select a minimum number.
APPROACHES FOR SENIOR HOUSING
A senior housing overlay could be established as either a fixed or a floating overlay, each
discussed below.
Fixed Overlay Zones
A fixed overlay is mapped to specific “base” zoning districts and therefore has typical district
boundaries. In the case of senior housing, this approach would offer predictability and clarity,
pairing senior housing with the geographies and purposes of existing zone(s). The desired
locations of senior housing are explicit in the overlay boundaries. Land within a fixed overlay
retains its existing underlying zoning and may be developed either under the base district
regulations or subject to modified or additional senior housing standards. Because the eligible
districts and applicable standards are established ahead of time, projects are subject to a typical
and predictable review process.
Multiple local cities including San Mateo have adopted fixed senior housing overlay zones to
encourage senior housing development.
Palo Alto’s comprehensive planning and housing documents indicate a
desire for senior housing in diverse neighborhoods. Candidate base districts and associate
geographies should reflect this diversity, and could include:
• Multifamily residential districts (RM-20, RM-30, and RM-40).
• Commercial districts (CN and CC), are located near services and transit, including Caltrain
stations, VTA and SamTrans bus routes, Dumbarton Express service, and transit-served
corridors such as Alma Street, El Camino Real, and California Avenue.
• SOFA and NVCAP districts.
• Districts in or associated with the ROLM Focus Area.
• Districts in or associated with the San Antonio Road Area Plan.
Eligibility Requirements The overlay would establish the criteria to define a “senior housing
project” eligible for special standards. At a minimum, these would include:
• Occupancy is limited to senior citizens and qualified permanent residents, in accordance
with state legal definitions.
• Eligibility or restriction of congregate housing development.
Requirements could be expanded to include:
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• Specific design and physical criteria, and/or required facilities, needed to accommodate
the elderly and comply with state and federal regulation.
• Location criteria to ensure projects are proximate to public transportations and/or other
daily use resources.
• Requirements restricting use of the property to senior housing development in the
future, via recordation of covenant.
Special Development Standards: The overlay would establish special development standards,
beyond base standards, modified to make senior housing feasible.
Incentives: Palo Alto could consider developer incentives to promote senior housing projects
consistent with overlaying requirements and standards. Potential examples include:
• Fast track processing of plan review and approval.
• Waiver of City fees.
• Relaxation of City standards, including density and/or FAR increases.
• Combinations of the above.
Floating Overlay Zones
Other jurisdictions have adopted “floating” overlay zones to facilitate specific development types.
A floating overlay has no predetermined location. Rather than being mapped to base districts in
advance, it is assigned to an individual lot or group of lots following project approval, including
findings of site appropriateness and General Plan consistency. Applied this way, the overlay can
supersede existing zoning regulation with development standards tailored to the unique
characteristics of a particular site. Because a floating overlay is applied on a project-by-project
basis, the on-site and off-site conditions of every project are reviewed. This facilitates additional
control and discussion. This approach, without boundaries, also expands the geographic potential
of a given project type. A floating senior housing overlay typically assumes that senior housing
may work in all areas of a city, depending on the specifics of a site and its surroundings.
Menlo Park and Foster City have established floating overlay districts to facilitate senior housing
development.
If Palo Alto were to develop a floating senior housing overlay, the ordinance would also need to
address:
Development Standards Without reference to base layers, neither base development standards
nor special development standards are directly applicable. The City would need to adopt a
development standards structure, potentially through:
• Association with the Planned Community (PC) district.
• Adoption of overlay-specific development standards.
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Location criteria: Without base layer boundaries, a floating overlay would not regulate allowed
location. It would be applied to a site in any base district the City determines is suitable for senior
housing, with each parcel retaining its underlying zoning. As such, the City would likely establish
locational criteria against which proposed projects are reviewed. Potential criteria include:
• Compatibility of surrounding land uses.
• Noise, air quality, and/or other environmental impacts.
• Adequacy of infrastructure.
• Proximity to medical services, open space, and other daily resources.
• Proximity to public transit.
Project review and approval: Due to the project-based review structure, a successful floating
ordinance would regulate the project review and approval process, including:
• Sequence of review and approval by the PTC, ARB, and/or PSC and City Council.
• The type of site approval, conditional or otherwise.
• Potential developer agreement requirements, to ensure implementation of all project
commitments that qualified the project for approval and/or incentives.
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Manager/City Clerk
Meeting Date: August 11, 2026
Report #:2512-5634
TITLE
Discuss and Recommend Approval of Scope of Work for State and Federal Legislative Advocacy and
Grant Consulting and Compliance Services
RECOMMENDATION
Staff recommends that the Policy and Services Committee review and provide general feedback on this
draft scope of work for legislative advocacy and grant support services and recommend the City Council
approve the scope of work.
BACKGROUND
In 2022, staff conducted a request for proposals (RFP) process for Federal and State legislative advocacy
services as well as for grant services. The City offered the RFP where interested parties could bid on
providing services related to State/Federal advocacy, and/or grants, or any combination of the three
possible scopes. At the time of contract award to the vendor, the City Council asked to review the scope
of work before it was bid out for the next contract. The City seeks to conduct an RFP for this service every
5 years as good governance practice and ensure the scope still meets the City’s needs.
The current contract for State advocacy and grant services will expire in December 2026. Due to budget
limitations, the City has suspended Federal advocacy services in this current fiscal year. Staff will bring a
contract amendment to City Council to remove federal advocacy services from the contract and to
approve an additional contract 1-year extension at the same time for the State advocacy and grant
services. This will extend the current contract expiration date from December 2026 to December 2027
and it is the last of the contract extensions that the City Council anticipated through the 2023 contract
approval. The most recent contract extension amendment was done in June 2026.
ANALYSIS
The current scope of work for each service is shown below. Staff does not have any recommended changes
to the scopes at this time. After the Policy and Services Committee reviews this scope, staff will take the
Policy and Services Committee recommendation to the full City Council. Staff plans to incorporate
feedback from these meetings to post a final RFP in late Fall 2026, with the new contract beginning at the
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end of calendar year 2027 upon conclusion of the current contract. This provides time for the RFP as well
as legal review of any updates to the contract scope and contract negotiation.
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on committees relevant to the City’s agenda. Furthermore, whenever possible, CONSULTANT
will also schedule site visits by legislators to the City.
7. Track Legislation: CONSULTANT will identify, analyze, and monitor all bill introductions and
amendments relevant to the City’s legislative platform and assess their potential impact on
the City.
8. CONSULTANT will ensure that the City receives relevant information in a timely manner on
such legislation.
9. Craft Testimony and Position Letters: CONSULTANT will prepare and submit written and
verbal testimony regarding legislation relevant to the City.
10. CONSULTANT will also draft and deliver position letters to legislators and key officials on
specific bill language.
11. Draft Bill Language: CONSULTANT will draft language and amendments for relevant
legislation, as required to protect and promote the City’s agenda.
12. State Budget Funding Opportunities: In an effort to maximize state funding, CONSULTANT will
work with the City to identify projects and other funding priorities that may be suitable for
funding through the State Budget.
13. CONSULTANT will coordinate with the City to develop supporting materials for the budget
request.
14. CONSULTANT will also work with members of the City’s state legislative delegation, along with
the Assembly and Senate Budget Committees, to gain support for the inclusion of the City’s
project in the final State Budget approved by the Legislature.
15. Strategic Communications Guidance: As directed, CONSULTANT advocates will recommend
strategic media strategies to improve the image of the City in the state and effectively
communicate the City’s policy priorities and positions to a broad audience as needed.
Examples include advice on Op-Ed materials, strategizing with media outlets for visits with
the City’s legislative delegations, and delivering state and local responses to legislative issues.
16. Provide Progress Reports: CONSULTANT will confer regularly with the City on our activities.
17. CONSULTANT will provide timely electronic reports on the status of all legislative activity, such
as bill language, amendments, and committee analyses.
18. In addition to written reports, CONSULTANT will be available to the City for conference calls,
in-person briefings, and meetings.
19. Prepare and File Lobbying Disclosure Reports: CONSULTANT will prepare and file, on behalf
of the City, all applicable state lobbying disclosure reports.
Task 2: Scope for Grant Support Services and Deliverables
Task 2A: Funding Needs Assessment and Citywide Prioritization
1. Conduct Detailed Orientation: CONSULTANT will utilize a comprehensive onboarding process
that includes extensive meetings with various relevant members of City leadership and key
City departments to develop a strategic plan that is tailored to satisfy the needs of the City,
as well as designed for maximum success in the current political climate and funding
environment.
2. Craft Strategic Funding Plan: Utilizing the information gathered during the onboarding
process, CONSULTANT will coordinate with CITY to develop a proactive and comprehensive
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strategic funding plan that serves the needs of the City’s priorities. The plan will identify City
projects, outline and prioritize multiple funding options for each project, and develop a
specific plan of work tailored for each project. The plan will also identify key criteria or
restrictions that will help the City assess the cost/benefit ratio for each grant opportunity.
3. Identify, Research, and Monitor Grant Funding Opportunities: CONSULTANT will utilize list-
serve subscription programs, funding workshops, agency canvassing, and other networking
tactics to ensure every potential opportunity is identified and reviewed for relevance with the
City’s projects.
4. CONSULTANT will Share these opportunities with CITY for further assessment and
determination if a grant application is warranted. CITY will also receive a grant matrix of
funding programs that is updated regularly as new opportunities arise and to assist with
workload management and prioritization.
Deliverables for Task 2A:
1. Meet with City staff to ascertain needs and goals
2. Conduct background research as requested by City
3. Provide advice on best grants for City to pursue, based on Strategic Funding Plan and grant
requirements and guidelines
4. Regular communication via email, phone, or video conference regarding upcoming grant
opportunities.
5. Prepare Strategic Funding Plan and Grant Matrix of Funding Programs that includes elements
outlined above
Task 2B: Grant Writing Services
1. Community Outreach: CONSULTANT will assist CITY with community outreach required for
grant applications by ensuring the City is aware of specific requirements, help develop
materials that capture all elements required by the grant, and compile the data following the
outreach to include in the application.
2. Grant Application Development and Submittal: CONSULTANT will develop, draft, submit, and
follow up on each City grant application through the following process:
a.Establishment of Clear Accountabilities: To avoid confusion and inefficiencies and to
ensure that CITY is burdened as little as possible as CONSULTANT pursues a grant
opportunity, CONSULTANT will coordinate with CITY to ensure the assignment of
responsibilities and tasks are made clear.
b. Provide Overview of Full Application Requirements: To ensure that the program is a
strong fit for the City’s project, CONSULTANT will provide CITY with a detailed
overview of the requirements for each grant program and corresponding application.
This will include:
i. Application timeline
ii. Eligible project types
iii. Funding availability and award maximum and minimums
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iv. List of application components, including proposal questions and any
required
v. Attachments
c. Assemble Project Background and Details: CONSULTANT will conduct a detailed
informational interview with City staff most involved with each project to gain a full
understanding of the project background and scope details necessary for developing
the grant proposal and addressing all application questions.
d. Coordinate Technical Project Details: For technical application components such as
site plans, detailed cost estimates, project timelines, engineering plans, and cost
benefit analyses, CONSULTANT will coordinate with City staff to compile all necessary
attachments and ensure consistency across all elements of the application.
e. Draft Written Proposal: CONSULTANT will fully draft all narrative components of the
application and, when applicable, will indicate where additional input or project detail
from the City could be provided during the proposal review process.
f. Incorporate Feedback to Finalize Proposal: Well ahead the of the application
deadline, CONSULTANT will provide CITY with a full draft for review and feedback.
CONSULTANT will incorporate any additional details or revisions provided during this
process to finalize the grant application and will obtain CITY’S approval for the final
version of the application prior to submission.
g. Submit Completed Application: CONSULTANT will ensure that applications are
submitted prior to the deadline, whether the submission is electronic or through hard
copies, in accordance with submission instructions for each individual program. For
hard copy submissions, CITY will print and package applications according to
submission instructions and will ship applications through a reliable carrier service
such as FedEx in order to provide the City with tracking and delivery confirmation for
the application.
h. CONSULTANT will also obtain a receipt for proof of submission and provide a final
copy of all submitted application documents to CITY.
3. Funding Advocacy: Throughout grant application process CONSULTANT will leverage
relationships with relevant officials and program officers in various state and federal funding
agencies to ensure that grant applications are aligned with the goals of the specific grant
program and that the applications are well-crafted and well positioned for funding.
Deliverables for Task 2B:
1. Develop/draft, finalize, and submit all sections of grant applications, with direction of CITY.
2. Monthly reports that advise CITY of status of grants in progress, grants submitted, and grants
awarded.
3. Ensure timelines for grant submittal are met.
Task 2C: Grant Compliance Support
1. Post-Grant Submittal Advocacy: CONSULTANT will frequently contact legislators and agency
officials to follow up on the status of a grant application and promote its need and urgency.
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This will include drafting letters of support after grant submissions and distributing them to
legislators for their consideration. In addition, CONSULTANT will work with legislators to reach
out to individual granting agencies to provide background on City’s projects and convey their
support for those projects.
2. Post-Award Grant Administration and Compliance: CONSULTANT will also assist with post-
award administration and compliance for all grant applications submitted by CONSULTANT
on behalf of CITY. This assistance will include interacting with granting agencies on behalf of
the City, providing support for the drafting and submission of required reports, evaluations,
and other tasks related to successful monitoring of and compliance with the program
requirements.
a. CONSULTANT will provide post-award grant administration and compliance technical
expertise and/or support, as agreed upon between the CONSULTANT and CITY for
grants not submitted by CONSULTANT.
b. Scope and fees for these ADDITIONAL SERVICES will be agreed upon by CONSULTANT
and CITY and a TASK ORDER issued.
3. Comprehensive Follow-Up on Unsuccessful Applications: Despite all best efforts, some grant
applications are not selected for funding. In those instances where grant applications are
unsuccessful, CONSULTANT will work with the relevant state and federal funding agencies to
set up in-person or telephone debriefing sessions to discuss the grant applications and how
to best revise the grant applications for the next funding round to ensure success.
4. Provide Monthly Progress Reports: CONSULTANT will confer regularly with CITY on grant
opportunities, progress reports, and other activities. CONSULTANT will provide timely
electronic monthly reports on the status of all funding activity, such current funding
opportunities, current applications, submitted applications, and post-grant submittal
advocacy, and a summary of activities taken during the previous month and the status. In
addition to written reports, CONSULTANT will be available to the City for conference calls, in
person briefings, and meetings.
Deliverables for Task 2C:
1. Monthly reports that detail grant compliance activities, current and upcoming, and state
and/or federal legislative advocacy work/support.
Task 3: Scope for Federal Legislative Advocacy Services and Deliverables
CONSULTANT will utilize the following strategic and comprehensive approach to provide federal
legislative advocacy services to the City.
1. Conduct Detailed Orientation: CONSULTANT will utilize a comprehensive onboarding process
that includes extensive meetings with various relevant members of City leadership and key
City departments to help develop a strategic plan that is carefully tailored to satisfy the needs
of the City, as well as designed for maximum success in the current political climate and
funding environment.
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2. Develop Legislative Strategy: Utilizing the information gathered during the onboarding
process, CONSULTANT will coordinate with the City to develop an official legislative platform
and strategy that represents the City’s priorities in Washington, DC. This blueprint will be
shared with key stakeholders in Congress and the Presidential Administration.
3. Implement the Legislative Strategy: CONSULTANT will advocate for the City’s legislative
agenda utilizing the following activities (not limited to):
4. Leverage Relationships for Strategic Advocacy Plan: CONSULTANT will engage various
techniques to leverage our network of key relationships on behalf of the City:
a. Schedule meetings for the City to discuss relevant legislation
b. Prepare all briefing materials and talking points for the City
c. Brief legislative offices and stakeholders on the City’s legislative agenda
d. Follow-up on meetings to ensure commitments and deliverables are being met or
coordinated
5. Advocacy Trips: CONSULTANT will work with the City to coordinate advocacy trips to
Washington, DC to meet with the City’s legislative delegation, as well as legislators that serve
on committees relevant to the City’s agenda. Furthermore, whenever possible, CONSULTANT
will also schedule site visits by legislators to the City.
6. Track Legislation: CONSULTANT will identify, analyze, and monitor all bill introductions and
amendments relevant to the City’s legislative platform and assess their potential impact on
the City.
7. CONSULTANT will also track other initiatives occurring in Washington, DC that could impact
the City (e.g., new programs with local impacts; relevant funding opportunities; etc.)
8. Craft Testimony and Position Letters: CONSULTANT will prepare and submit written and
verbal testimony regarding legislation or initiatives relevant to the City.
9. CONSULTANT will also draft and deliver position letters to relevant agencies and legislators.
10. Draft Bill Language: In partnership with legislators, CONSULTANT will draft language and
amendments for relevant legislation, as relevant and feasible to promote the City’s agenda.
11. Federal Earmark / Community Project Funding Opportunities: In an effort to maximize federal
funding, CONSULTANT will work with the City to identify projects and other funding priorities
that may be suitable for funding through the Federal Earmark process.
12. CONSULTANT will coordinate with the City to develop supporting materials for the earmark
request.
13. CONSULTANT will also work with members of the City’s federal legislative delegation to gain
support for the inclusion of the City’s project.
14. Build and Strengthen Relevant Relationships: CONSULTANT has cultivated a network of
valuable relationships that will be leveraged to promote the City’s legislative agenda. These
relationships will include:
a. City Legislative Delegation (US Senators and Representative representing Palo Alto
area)
i. Administration
ii. White House Office of Intergovernmental Affairs
iii. Department of Agriculture
iv. Department of Commerce
v. Department of Education
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vi. Department of Homeland Security
vii. Department of Housing and Urban Development
viii. Department of the Interior
ix. Department of Justice
x. Department of Labor
xi. Department of Transportation
xii. Army Corps of Engineers
xiii. Bureau of Reclamation
xiv. Economic Development Administration
xv. Environmental Protection Agency
xvi. Fish and Wildlife Service
xvii. National Marine Fisheries Service
xviii. National Park Service
b. Federal Agencies
i. Army Corps of Engineers
ii. Bureau of Justice Assistance
iii. Community Oriented Policing Services (COPS)
iv. Employment and Training Administration
v. Environmental Protection Agency
vi. Department of Energy
vii. Federal Emergency Management Agency
viii. Department of Transportation
ix. Federal Highway Administration
x. Federal Railroad Administration
xi. National Endowment for the Arts
xii. National Park Service
xiii. US Economic Development Administration
xiv. US Fish and Wildlife Service
xv. US Forest Service
c. House Appropriations Committee
d. Energy and Commerce Committee
e. House Ways and Means Committee
f. Transportation and Infrastructure Committee
g. Municipal Organizations
h. US Conference of Mayors
i. National League of Cities
j. Mayors and CEOs for U.S. Housing Investment
k. Mayors and CEOs for U.S. Housing Investments
15. Provide Progress Reports: CONSULTANT will confer regularly with the City on our activities.
16. CONSULTANT will provide timely electronic reports on the status of all legislative activity, such
as bill language, amendments, and committee analyses. In addition to written reports,
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CONSULTANT will be available to the City for conference calls, in-person briefings, and
meetings.
17. Prepare and File Lobbying Disclosure Reports: CONSULTANT will prepare and file, on behalf
of the City, all applicable federal lobbying disclosure reports.
FISCAL/RESOURCE IMPACT
Reviewing the scope of work has no fiscal impact. The State Advocacy and Grant Support services are
estimated to be $10,800 monthly ($129,600 annually). The funds for these services are already included
in the appropriate department budgets for FY 2027. The budget for Federal advocacy services was
eliminated in the FY 2027 budget process.
STAKEHOLDER ENGAGEMENT
Staff will continue to engage with relevant staff on their State and Grant advocacy needs. The consultant
chosen through this process will advance the City’s advocacy efforts as previously done.
ENVIRONMENTAL REVIEW
Not a project.
APPROVED BY:
Ed Shikada, City Manager
Mahealani Ah Yun, City Clerk
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Item No. 1 Page 1 of 1
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8
Policy & Services Committee
Supplemental Report
From: Kate Murdock, City Auditor
Meeting Date: August 11, 2026
Item Number: 1
Report #:2608-6605
TITLE
Office of the City Auditor Presentation of the Junior Museum & Zoo Audit. CEQA Status – Not a
project.
ANALYSIS
This Supplemental Report and the attached amended JMZ Audit Report are issued to update
financial information presented in one section of the report. The Office of the City Auditor
(OCA) received revised financial information from Junior Museum & Zoo Management for
Educational Programming activities covering FY 2023 through FY 2025. OCA reviewed the
revised information and updated the applicable figures and related narrative in the report
accordingly.
The revised financial information is reflected in Figures 3 and 4 and the accompanying report
text on pages 11 and 12 of the attached amended audit report. These revisions do not
materially affect the report's findings, conclusions, or recommendations.
ATTACHMENTS
Supplemental Attachment A: Junior Museum & Zoo Audit Report (Revised)
APPROVED BY:
Kate Murdock, City Auditor
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1
August 6, 2026
City of Palo Alto
Office of the City Auditor
Junior Museum and Zoo Audit
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A - Junior Museum & Zoo
Audit Report (Revised)
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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
AUDIT RESULTS.............................................................................................................. 6
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Audit Report (Revised)
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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 audit of the Junior Museum and Zoo (JMZ)
based on approved Task Order 4.31 as part of the City’s FY25 Audit Plan. The objective of this audit
was to determine if the City’s Junior Museum and Zoo is operating effectively and efficiently to fulfill
the program’s mission.
Report Highlights
(Page 6) community demand, including near-weekly sellouts, high program participation, and
improved ticketing efficiency through the ACME system. However, JMZ does not yet
have a recurring, consolidated performance measurement framework to assess
overall program impact, demand, utilization, customer experience, staffing capacity,
revenue, and administrative workload. As a result, the City has useful data in certain
areas but limited visibility into whether JMZ is meeting community demand, using
resources efficiently, and supporting budget and staffing decisions with complete
performance information.
• The ACME ticketing system improved operations and reportedly reduced daily
entrance duties by about 30%.
• JMZ has useful data in some areas, but does not consistently consolidate key
metrics across attendance, utilization, guest experience, event demand,
revenue, staffing, and workload.
• Some demand indicators are not fully tracked, including birthday party
requests, member no-shows, and guest feedback.
• Staffing and administrative capacity challenges limit JMZ’s ability to track,
analyze, and use data for broader management decisions.
The City and JMZ should establish a recurring framework to measure the JMZ's
demand, results, and operating performance and to inform budget and staffing
decisions. This framework can be built largely by consolidating existing data, since
systems like ACME already capture attendance, ticket sales, and time-slot activity. At
a minimum it should cover visitor demand and access, guest experience, revenue by
source against costs where feasible, program and event demand, and staffing and
administrative workload, with JMZ and Community Services Department (CSD)
leadership reviewing it at least quarterly. As it implements the framework, the City can
also weigh whether dedicated business operations support is warranted, given the
Executive Director's stated future need for a business or analyst role and the already-
stretched administrative capacity.
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EXECUTIVE SUMMARY
Finding 2:
(Page 9)
JMZ’s education program is an area that continues to grow, serves many students
and adults, and receives strong customer satisfaction ratings. However, staffing,
supplies, financial reporting, funder tracking, and program evaluation practices have
not kept pace with this growth. Without stronger resource planning, financial
reconciliation, and performance measurement, management has limited ability to
determine whether the program is financially sustainable, adequately resourced, and
achieving broader outcomes beyond participant satisfaction.
• The education program expanded in FY2025, generating more than $980,000
in revenue, delivering more than 2,700 programs or lessons, and serving more
than 24,000 children and students.
• Staffing and supplies have not kept pace with growth due to part-time turnover,
slow hiring, vacancies, limited administrative capacity, and a supplies budget
that has increased only modestly while participation has more than doubled.
• Financial reporting does not clearly connect program activity to revenue,
expenses, and fiscal year timing, limiting management’s ability to assess cost
recovery and sustainability.
• Survey results show strong satisfaction, but low response rates and limited
outcome-based evaluation make it difficult to determine whether feedback is
representative or whether the program is achieving broader educational goals.
Key Recommendation:
JMZ should develop an integrated education program dashboard linking program
activity, staffing, supplies, revenues, expenses, subsidies, funding sources, and
evaluation results. The dashboard should include workload-based staffing and supply
assumptions, budget-to-actual reporting by program type, reconciliation between
service/revenue reports and financial records. In addition, it should track Friends of
the Museum-funded programs from planning through payment. Finally, survey
response rates and comment trends, and outcome measures tied to curriculum goals
should be consistently tracked and monitored. This would better enable the JMZ to
keep expanding successful programs while better demonstrating whether they are
financially sustainable, adequately staffed, and achieving intended results.
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Finding 3:
(Page 14) regulatory compliance systems, including earning Association of Zoos and Aquariums
(AZA) accreditation, finalizing a veterinary services agreement, and maintaining daily
animal-care reporting. However, OCA identified opportunities to improve consistent
execution and documentation of key safety and compliance controls, including
emergency drills, animal transport, and recordkeeping. Strengthening documentation
and oversight in these areas would help JMZ demonstrate ongoing compliance with
AZA standards and better ensure that safety and animal welfare controls are
operating as intended.
• Emergency drills were not always completed or documented as required,
though JMZ has since developed a checklist to capture drill results, lessons
learned, and corrective actions.
• Animal transport practices should be formalized, including documented vehicle
use expectations, safety training, and procedures for transporting animals,
staff, and education materials.
• Recordkeeping is spread across daily reports and multiple files, making it
difficult to verify that required actions were completed and retained
consistently.
• The City should evaluate whether the semi-open elevator / lift shaft presents a
safety risk and determine whether additional safeguards, such as a full-height
door, gate, or barrier, are needed.
Key Recommendation:
The City and JMZ should establish a centralized safety and compliance tracking
process to document and monitor required animal care, safety, and regulatory
compliance activities, including responsible staff, completion frequency, required
evidence, reviewer sign-off, and corrective actions. The process should include
emergency drill tracking and evaluation, consistent use of the Emergency Drill/Incident
Review Checklist, documentation of lessons learned and follow-up actions, and a
written animal transport policy addressing vehicle use, staff training, animal
containment, trip documentation, and emergency procedures. JMZ and CSD
management should review the tracker at least quarterly to confirm that required
activities are completed, documentation is retained, and corrective actions are
addressed, helping JMZ demonstrate compliance with AZA documentation
expectations and assess whether key controls are operating as intended.
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Introduction
1 Friends of the Palo Alto Junior Museum & Zoo – Friends of the Palo Alto Junior Museum & Zoo
Objective effectively and efficiently to fulfill the program's mission.
Background
the City. The facility was entirely rebuilt and reopened in November 2021,
following a major renovation supported in large part by the Friends of the JMZ 1,
which raised approximately $25 million for the project.
The JMZ operates under the City’s CSD, and the collection includes over 65
species and approximately 85 individual animals, including a live bald eagle held
under a U.S. Fish and Wildlife Service permit.
The JMZ’s education program is one of its largest program areas. It employs
approximately 20 educators and instructors who provide over 2,700 inquiry-
based science lessons across 168 schools and community centers, serving more
than 24,000 students annually. During the summer, staff operate week-long
camp sessions across nine content areas, with a majority selling out in the first
round of applications.
The JMZ is primarily funded through the City’s General Fund, supplemented by
ticket revenue, education program fees, and fundraising by the Friends of the
JMZ, a support organization that has existed for over 50 years and focuses on
accessibility, inclusion, and fundraising for facility improvements and special
programs.
During the audit period, the JMZ successfully obtained accreditation from the
AZA through September 2030. AZA accreditation represents the highest
standard for zoological institutions and enables the JMZ to participate in species
exchange programs, streamline permitting processes, and demonstrate
adherence to leading professional practices.
Scope covering FY 2024 through 2025. The audit included assessing the following
areas: educational activities, financial and program data, staffing and
administrative processes, guest services and cash handling, animal care and
wellbeing, veterinary coverage, emergency preparedness, safety and security,
selected wildlife permits, and governance/oversight considerations.
Methodology
• Interviewed the appropriate individuals to gain an understanding of the
organizational structure, processes, and controls related to JMZ
operations.
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INTRODUCTION
2 Government auditing standards require an external peer review at least once every three (3) years. The last peer review of the Palo Alto
Office of the City Auditor was conducted in 2017. The Palo Alto City Council approved a contract with Baker Tilly U.S, LLP for internal audit
services for October 2020 through June 2022 with an extension through June 2025. City Council appointed Kate Murdock, Senior 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 2026. It should be noted that Baker Tilly’s most recent firmwide
peer review was completed in November 2024 with a rating of “Pass”. The scope of that peer review includes projects completed under
government auditing standards.
regulatory requirements to identify the criteria to be used for evaluation of
control design and effectiveness.
• Conducted an on-site visit to evaluate animal care and veterinary
records, financial management controls, and safety and security
practices, including animal health and wellbeing records, necropsy
reports, daily animal care reports, veterinary documentation, cash
handling procedures, P-card usage, budgeting practices, ticket revenue
management, emergency drill records, education, facility access controls,
and incident reporting systems.
• Completed audit report of findings, conclusions, and recommendations
based on the supporting evidence gathered.
Compliance
Statement accepted government auditing standards, except for the requirement of an
external peer review 2. Those standards require that we plan and perform the
audit to obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings, 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.
Organizational
Strengths across all program areas. The education program is a standout asset, serving
tens of thousands of students with high-quality, inquiry-based science instruction.
The JMZ’s successful attainment of AZA accreditation demonstrates its
commitment to operational excellence, industry best practices, and continuous
improvement. The modern facility, rebuilt in 2021, is a valued asset to the Palo
Alto community. We appreciated the participation of JMZ staff in interviews and
their responsiveness to follow-up requests throughout the audit.
The OCA greatly appreciates the support of the CSD in conducting this audit activity.
Thank you!
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Audit Results
JMZ delivers high-
demand mission-
driven programs,
and the City has
an opportunity to
further develop a
formal
performance
measurement
framework to
assess impact,
demand, and
operating results.
live-animal zoo, public attraction, event venue, and community-serving facility. The
JMZ is valued by the community and offers a distinctive experience within the City.
Available operational information indicates strong demand for JMZ services.
Based on OCA’s review of ticket sales, education program participation counts, and
other program data, JMZ has indicators of strong demand across both general
admission and education programming. Guest Services staff reported that JMZ
implemented paid ticketing in 2021, using the ACME ticketing system, and sells out
nearly every weekend. Staff also reported that ACME has saved approximately 30%
of staff time in daily museum entrance duties. The graph below shows the number of
admissions in FY24 and FY25 with total admissions of 128,006 and 120,822
respectively.
Figure 1: JMZ General Admission by Month, FY2024 vs. FY2025
Source: OCA analysis of JMZ general admission data, FY2024–FY2025. FY2025
includes a mid-year transition to the ACME ticketing system in FY2025.
While JMZ has increased use of operational data for decision-making, there are
additional opportunities to improve performance reporting.
JMZ has begun using operational data and business analysis in selected areas. For
example, Guest Services staff can use the ticketing system to track tickets sold by
day or date range, and CSD leadership reported that the City performed an analysis
of staffing models and ticket pricing, which led to an increase in ticket prices.
However, JMZ does not yet have a formal, recurring performance measurement
-
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
At
t
e
n
d
a
n
c
e
Month (fiscal year: July-June
FY 2024 FY 2025
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AUDIT RESULTS
facilities, and administrative workload.
As a result, the City has useful operational data in specific areas but no recurring,
consolidated view of how the JMZ's programs are performing overall. Through the
ACME system, Guest Services tracks ticket sales by day and date range, but other
demand and utilization signals are not captured.
Staff reported that members book admission up to eight weeks ahead and often do
not attend. Roughly 75% to 80% of booked guests attend, which reduces availability
for non-members, however this pattern is not formally measured. According to the
Assistant Director for CSD, the JMZ also lacks a structured process for collecting
customer feedback, though staff are working to implement one.
Another area where more information would be helpful is in special programming
such as parties and events. According to Guest Services staff, birthday programming
is capped at 16 bookings per month and demand exceeds that capacity. However, at
the time of the audit management reported that they were not consistently tracking
the number of requests for birthday parties so demand for this service remains
unknown. According to birthday party reports from FY24 to 25 there was reduction in
the number of parties from 29 in FY24 to 18 in FY25. This represented a 36.2%
decrease in party-guest attendance and a 63.5% decrease in revenue from $25,148
to $9,170. Guest Services staff indicated this was due to staffing and software issues,
which have since been resolved.
Finally, staff noted that marketing efforts are not tracked and monitored and social
media and website information is not consistently or regularly updated. Increasing
such efforts could help the JMZ continue to expand its services and reach.
According to Guest Services staff, a single position handles contracts, scheduling,
guest services, and program coordination and described the workload as
overwhelming, and staffing has consistently been a challenge. The Executive
Director stated that hiring takes eight months to a year and that the City’s Human
Resources Department often cannot accommodate hiring requests timely. The
Executive Director also identified a future need for a management analyst or director
of business to manage budgets, HR, and contracts and to "acquire, review and
present data to inform strategies JMZ-wide" indicating no dedicated data-analysis
function exists today.
Without a recurring framework consolidating indicators such as attendance, ticket
utilization, customer experience, event demand, revenue, staffing capacity, and
administrative workload, the City has limited ability to tell whether the JMZ is meeting
community demand, using resources efficiently, and achieving intended outcomes, or
supporting informed budget and staffing decisions.
Recommendation to track the JMZ's mission impact, demand, and operating results and to support
budget and staffing decisions. Much of the underlying data already exists in current
systems, the ACME ticketing system, for example, captures attendance, ticket sales,
and time-slot activity, so the framework can be built largely by consolidating and
regularly reviewing existing data rather than acquiring new systems. At a minimum
the framework should include:
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•Visitor demand and access measures
Track attendance, ticket sales, sold-out periods, no-show rates, member
reservation activity, non-member ticket availability, walk-ins, time-slot
utilization, and peak versus underutilized periods.
• Guest experience measures
Implement a guest services survey or other structured feedback process to
measure visitor satisfaction, ease of ticketing, accessibility, customer service,
complaints, response times, and recurring service themes.
• Revenue and cost measures
Report revenue by major source, including admissions, memberships, facility
rentals, birthday parties, events, donations, and other earned revenue. Where
feasible, compare revenue to direct costs and staffing requirements.
• Program and event demand measures
Track demand for birthday parties, rentals, special events, animal encounters,
accessibility programs, and other public-facing services, including waitlists,
declined requests, cancellations, and unmet demand.
• Staffing and administrative workload measures
Track vacancies, time to fill positions, part-time staffing reliance, overtime or
coverage gaps, administrative workload, contract volume, customer response
times, and major bottlenecks.
• Quarterly management review
JMZ leadership and CSD management should review the performance
framework at least quarterly and document key trends, decisions, follow-up
items, responsible parties, and target completion dates.
The City should also evaluate whether JMZ needs dedicated business operations
support, such as a management analyst or business manager, to help maintain the
framework, analyze results, support budget development, coordinate contracts and
administrative requirements, and provide JMZ-wide data for decision-making.
Management
Response
Responsible Department(s):Community Services
Concurrence: Agree
Target Date: Q4, FY 2027
Action Plan:
made significant progress in expanding the use of operational data through
implementation of the ACME ticketing system, program participation tracking, and
revenue reporting. Management agrees that consolidating these existing data
sources into a recurring performance dashboard will strengthen strategic decision-
making and support future budget, staffing, and operational planning.
During FY2027, JMZ will formalize a recurring performance measurement framework
by consolidating existing operational data into a management dashboard. The ACME
ticketing system already captures many key performance indicators, including
attendance, ticket sales, sold-out periods, member reservation activity, no-show
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visitation periods. JMZ will incorporate these existing metrics into a recurring
dashboard while continuing to expand performance measures as additional data
becomes available.
JMZ is also implementing new visitor and birthday party survey tools to better
measure guest experience and customer satisfaction. Existing waitlists will continue
to be used to assess demand for programs where applicable, and additional tracking
methods will be developed for programs and services where unmet demand is not
currently captured. Together, these enhancements will provide a more
comprehensive understanding of visitor demand, customer experience, operational
performance, and resource needs.
Management also recognizes the value of potential enhanced business and
analytical support. Any future staffing additions will be evaluated and proposed during
the City's annual budget development process and based on organizational priorities
and available resources.
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Finding 2:
Educational
program offerings
continue to
increase but
staffing challenges
and budget
constraints limit
the program’s
ability to meet
demand.
The JMZ education program is expanding and receives strong customer satisfaction
ratings, but the available evidence indicates that its staffing, supply budget, financial
reporting, funder tracking, and program evaluation practices have not kept pace with
that growth. As a result, management has limited ability to determine whether the
program is financially sustainable, sufficiently resourced, and achieving program-wide
outcomes beyond participant satisfaction.
The JMZ education program is a core mission-delivery function and one of the
organization’s major public-facing services. The program continues to expand,
generating more than $980,000 in FY2025 revenue while delivering more than 2,700
programs or lessons across schools and community centers. In FY2025, the program
served more than 24,000 children and students and more than 2,100 adults.
This growth reflects a broader year-over-year increase in education activity almost
every year for the past decade. From FY2024 to FY2025, reported
programs/sessions increased from 2,510 to 2,710, children/students served
increased from 23,197 to 24,525, and revenue increased from $918,356 to $980,553.
Adult participation also increased, rising from 656 adults served in FY2024 to 2,157
in FY2025. Overall, these changes represent increases of approximately 8.0% in
programs/sessions, 5.7% in children/students served, and 6.8% in revenue.
Figure 2: Children and Students Served by JMZ Programs
Source: OCA analysis of Service Reports FY16, FY17, 18, 23, 24, 25
*OCA was not provided with FY19, 20, 21, and 22
However, according to the Director of Education and our analysis, the program’s
staffing and supplies have not kept pace with this growth. The program has 18
science teachers, three are full-time and the remainder are part-time. The program
experiences high turnover in part-time positions and a slow hiring process resulting
in vacancies that remain unfilled for extended periods. Once hired, the Education
Director estimated that new staff take approximately six months to become fully
efficient. In addition, OCA noted that the supplies budget has increased by
approximately $2,000 over 16 years while the number of students served has more
17,911 17,760
12,853
20,927
23,197 24,525
-
5,000
10,000
15,000
20,000
25,000
30,000
FY 2016 FY2017 FY 2018 FY 2023 FY 2024 FY 2025
#
o
f
S
t
u
d
e
n
t
s
Fiscal Year*
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demand, but the current budget does not provide the additional staffing needed to
support that growth.
Figure 3: JMZ Education Program Earned Revenue by Year, 2020–2025
Source: OCA analysis of JMZ financial performance data (earned revenue by
program, 2020–2025).
Based on the available information provided to the OCA there does not appear to be
a way to clearly connect program activity to budget and actual results. OCA could not
entirely reconcile information from reports generated by the Education Program and
the City’s SAP (Systems, Applications, and Products in Data Processing) System.
According to the Education Director, staff do not have the capacity to reconcile these
figures, in part because payment receipts sometimes miss a fiscal year's cutoff and
are recorded in the following year. The FY2025 Budget Performance file reflects this,
noting that FY2025 revenue includes some FY2024 payments that were not received
or processed until FY2025, which further complicates year-over-year comparison.
Available financial data also shows that education-related activity requires ongoing
subsidy or budget-variance management. Available budget information shows annual
losses of $494,456 in 2020, $750,607 in 2021, $661,057 in 2022, $509,477 in 2023,
and $575,085 in 2024 and $392,787 in 2025. The FY2025 SAP report shows
$1,004,829 in total actual revenues from Camp and Bayland Educational
Programming and $1,397,616 in total actual expenses.
$621,346
$312,694
$554,341
$687,645
$794,605
$1,004,829
$0
$200,000
$400,000
$600,000
$800,000
$1,000,000
$1,200,000
2020 2021 2022 2023 2024 2025
Re
v
e
n
u
e
Year
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3 What is a Good Survey Response Rate? | SurveyMonkey
Figure 4: Education Programs — Actual Revenues vs. Actual Expenses
(Outreach, Camp, and Baylands Combined)
Source: OCA analysis of JMZ education program financial data, 2020–2024. Labels
show the annual operating deficit.
The program also relies on Friends-funded support to provide programming for
underserved youth, but the delivery plan has little margin for error. According to
management, Friends of the JMZ provides $163,000 annually for school programs,
after-school programs, and camp scholarships. The Friends-funded Program Delivery
Plan shows a Total Plan of 578 programs, with $160,176 in planned expense against
$163,250 in total funding available, leaving $3,074, or about 1.9%, between planned
expenses and available funding. Management should assess whether this margin is
adequate.
OCA’s analysis of program survey information found strong customer satisfaction
ratings, but response rates could be improved to ensure greater feedback is obtained
for making program adjustments. According to the Director of Education, the
program uses electronic evaluations completed by participants and teachers to
assess and improve program quality. Survey exports for Fall 2024, Winter 2025, and
Spring 2025 family programs show many satisfaction and likelihood-to-recommend
ratings of 5, with positive comments about instructors and program content. Based on
the provided family program survey export, there were 37 satisfaction responses,
with an average satisfaction score of 4.84 out of 5. Based on the 2025 summer camp
survey export, there were 119 satisfaction responses, with an average satisfaction
score of about 4.92 out of 5. However, the survey exports do not show how many
participants were asked to respond, response rates, or whether the responses are
representative of all school, camp, and family program participants. FY2025 service
totals show 24,525 children/students served, resulting in a survey response rate of
less than 1%. While survey response rates can vary significantly 3, increasing the
response rate could help the JMZ better understand which program elements are
working well and which need improvement.
-$494,456 -$750,607
-$661,057 -$509,447
-$575,085 -$392,787
$0
$200,000
$400,000
$600,000
$800,000
$1,000,000
$1,200,000
$1,400,000
$1,600,000
2020 2021 2022 2023 2024 2025
Year
Total Actual Revenues Total Actual Expenses
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identified some specific service-improvement opportunities. Family program
respondents requested more hands-on science, noted that some children were too
young to fully participate, and asked for programming after noon so transitional
kindergarten children could attend. Camp survey respondents requested expanded
offerings for older children or tweens, additional weeks of Zoo Camp, and more
communication tools such as photos or take-home materials to help families
understand what children did during their camp experience.
While educational programming has continued to expand, the absence of an
integrated management framework linking service growth with staffing capacity,
hiring timelines, supplies, program costs, funding commitments, revenue recognition,
and performance outcomes limits the program’s ability to manage growth effectively.
Staff interviews highlighted growth expectations without corresponding staffing
budget increases, slow hiring, high part-time turnover, supply budget constraints, and
insufficient administrative support.
Without stronger resource planning, financial reconciliation, and performance
measurement, JMZ management cannot determine whether or not education
program growth is sustainable, program costs and revenues are being reported in the
correct categories and fiscal years, subsidies align with management’s intent,
Friends-funded programs are delivered as planned, or high satisfaction ratings reflect
program-wide effectiveness. Although the program continues to provide valued
services, management lacks the information needed to assess cost recovery, staffing
adequacy, customer demand, access goals, and educational outcomes.
Recommendation
ties program activity to staffing, supplies, full program costs, revenues, subsidies,
funder commitments, and evaluation results, so management can determine whether
program growth is financially sustainable, sufficiently resourced, and achieving
outcomes beyond participant satisfaction. Much of the underlying data already exists,
in the service and revenue reports, the Budget Performance files, the Friends-funded
Program Delivery Plan, and the program's electronic evaluations, so the framework
can be built largely by consolidating and reconciling existing data rather than
acquiring new systems. At a minimum the framework should include:
• Staffing and supply measures
Establish workload-based staffing and supply assumptions tied to the number
of programs and students served, and track hiring timelines, vacancies, part-
time turnover, and time for new staff to reach full efficiency. Flag where
service volume outpaces current staffing and supply capacity, including the
recurring supplies-budget overage.
• Budget-to-actual and cost measures
Report revenue and expense by program type, such as Outreach, Camp, and
Baylands, compare actual results to budget, and identify the operating
subsidy or deficit for each program area.
• Financial reconciliation measures
Reconcile the service and revenue reports to the financial records, tie
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consistently from year to year.
• Funder and Friends-funded program tracking
Track Friends-funded programs from planned to schedule, delivered,
invoiced, and paid, and monitor the delivery plan's remaining margin and any
unresolved implementation items.
• Program evaluation and outcome measures
Capture survey response rates and the share of participants represented,
trend-analyze survey comments to identify recurring service-improvement
themes and add outcome measures tied to curriculum goals, so program
quality is assessed beyond satisfaction ratings.
• Quarterly management review
JMZ leadership and CSD management should review the framework at least
quarterly and document key trends, decisions, follow-up items, responsible
parties, and target completion dates.
Using the information the framework produces, JMZ and CSD management should
evaluate whether current staffing levels, supply budgets, and subsidy levels are
adequate to sustain program growth, and whether adjustments to program scope,
fees, or resources are warranted to align the program's growth with its budget and
mission.
Management
Response
Concurrence: Agree
Target Date: Q4, FY 2027
Action Plan:
Management concurs with the recommendation. The Junior Museum & Zoo's
Education Program has experienced significant growth in recent years, expanding
both the number of participants served, Educators employed, and earned revenue
while maintaining high levels of customer satisfaction. Management agrees that as
the program continues to grow, strengthening performance reporting and resource
planning will better support long-term operational and financial decision-making.
JMZ is already implementing many of the recommended practices by expanding the
use of service reports, financial data, participant evaluations, and Friends-funded
program tracking to better monitor program performance. During FY2027, these
existing data sources will be consolidated into a more integrated education program
management framework that provides improved visibility into staffing capacity, supply
needs, program activity, revenues, expenditures, funding sources, and overall
program performance.
Management will continue to work collaboratively with our department budget analyst
and the Friends of the Junior Museum & Zoo to improve financial reporting and
reconciliation while recognizing the timing differences that can occur between
program delivery and revenue recognition across fiscal years. JMZ will also continue
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Resource needs identified as part of this evaluation will be proposed as part of the
annual budget development process.
Participant feedback will continue to be an important component of program
evaluation. JMZ will implement strategies to increase survey participation and further
enhance outcome-based performance measures to support continuous improvement
and demonstrate the educational impact of its programs.
Finding 3:
JMZ has
strengthened
animal care and
regulatory
compliance
systems earning
accreditation this
past year; but
some safety,
animal welfare and
documentation
controls could be
improved
safety, and regulatory compliance systems as evidenced by the AZA Accreditation,
OCA identified several areas where controls should be more consistently executed
and documented.
During the audit period, the JMZ earned AZA accreditation and continued to
strengthen its animal care and safety practices, including finalizing a signed
veterinary services agreement and maintaining daily animal-care reporting. OCA
identified a few opportunities for management to more consistently document
processes and support required reporting.
Emergency Drills
According to the Zoo Director, the JMZ conducts emergency drills twice a year, more
often than the once-a-year minimum in AZA Standard 11.2.5, but OCA found that
some scheduled drills were not completed. OCA also found drills noted but without
the evaluation record the standard requires. AZA Standard 11.2.5 requires that the
four basic emergency drills be recorded and their results evaluated. The JMZ has
since developed an Emergency Drill/Incident Review Checklist that captures key drill
elements. Completing drills as scheduled and retaining the checklist, lessons
learned, and corrective actions will meet this requirement.
Animal Transport and Vehicle Safety
OCA found documentation gaps related to animal transport too. According to the JMZ
Director, animals taken to off-site educational programs are moved in built, mobile
habitats and transported in employees' personal vehicles, as the JMZ shares a single
City vehicle with other facilities. It appears that education staff do not receive safety
training for City vehicle use, and OCA did not identify a documented policy governing
animal transport. Because the education program operates at scale, more than
24,000 students across 150 schools and community centers in FY25, a documented
transport policy and related training would help ensure the safe and consistent
transport of animals, staff, and materials.
Overall Recordkeeping
AZA standards emphasize the importance of documentation, providing that an
institution that takes the proper steps but does not document them will not be
considered in compliance. For the JMZ, recordkeeping is spread across daily reports
and multiple separate files, and several assessment and documentation practices are
new or recently implemented, so evidence of completed actions may be hard to track
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AUDIT RESULTS
standards or to evaluate whether its controls are operating as intended, even where
the underlying practices are sound.
Finally, during the onsite visit, OCA observed a semi-open elevator/lift shaft in the
zoo area. While OCA did not identify any standards or best practices related to these
types of lifts other than regular maintenance, the opening at the top of the lift when it
is on the ground floor could present a safety risk. According to the JMZ Director, the
JMZ has not experienced any incidents and has a maintenance agreement for the lift.
In addition, the Zoo Director stated that staff check the lift each morning to confirm it
is locked. Given the location, the City may wish to evaluate whether additional
safeguards, such as enclosing the lift area or installing a full-height door, gate, or
barrier, are warranted.
Recommendation
The City and JMZ should establish a centralized safety and compliance tracking
process to support consistent execution, documentation, and follow-up of animal
care, safety, and regulatory compliance controls. The process should identify each
required activity, responsible staff member, frequency, required documentation,
completion date, reviewer sign-off, and any corrective action:
• Emergency Drill Tracking
The process should include annual emergency drill tracking and
evaluation, use of the Emergency Drill/Incident Review Checklist,
documentation of lessons learned and corrective actions, and follow-up for
drills that are postponed or not completed.
• Animal Transport Policy
JMZ should also develop a written animal transport policy for off-site
education programs and other animal movements, including requirements
for approved vehicles, personal vehicle use, insurance expectations,
animal containment, temperature or life-support needs, staff training, trip
documentation, and emergency procedures.
• Quarterly Review of Tracker
JMZ and CSD management should review the tracker at least quarterly to
confirm that required activities are completed, documentation is retained,
and corrective actions are addressed.
This would help JMZ demonstrate compliance with AZA documentation expectations
and provide management with a more complete view of whether key controls are
operating as intended.
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AUDIT RESULTS
Management
Response
Responsible Department(s): Community Services
Concurrence: Agree
Target Date: Q2, FY 2027
Action Plan:
Management concurs with the recommendation. The Junior Museum & Zoo has
made significant investments in strengthening its animal care, safety, and regulatory
compliance programs, culminating in the successful achievement of Association of
Zoos and Aquariums (AZA) accreditation in 2025. Management agrees that
continued standardization of documentation and compliance tracking will further
strengthen existing practices and support ongoing compliance.
Since completion of the audit fieldwork, JMZ has implemented an Emergency
Drill/Incident Review Checklist and completed all required emergency drills. The
checklist provides standardized documentation of drill activities, lessons learned, and
any follow-up actions to support ongoing compliance with AZA standards.
Documentation of these completed drills and review checklists has been provided to
the Office of the City Auditor.
JMZ currently maintains written procedures for the transport of animals for off-site
educational programs. Management will review and enhance the existing policy to
incorporate the additional elements identified in the audit to further strengthen
consistency and documentation.
JMZ will also implement a centralized compliance tracking process and conduct
quarterly management reviews to ensure required animal care, safety, and regulatory
compliance activities are completed, documented, and retained, and that any
corrective actions are identified and addressed in a timely manner.
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Item 1
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A - Junior Museum & Zoo
Audit Report (Revised)
Item 1: Staff Report Pg. 21 Packet Pg. 117 of 117