HomeMy WebLinkAboutMeetings2887Packet_20260827154531516UTILITIES ADVISORY COMMISSION
Regular Meeting
Wednesday, September 02, 2026
Council Chambers & Hybrid
6:00 PM
Utilities Advisory Commission meetings will be held as “hybrid” meetings with the option to
attend by teleconference/video conference or in person. To maximize public safety while still
maintaining transparency and public access, members of the public can choose to participate
from home or attend in person. Information on how the public may observe and participate in
the meeting is located at the end of the agenda. Masks are strongly encouraged if attending in
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PUBLIC COMMENTS
General Public Comment for items not on the agenda will be accepted for up to three minutes
or an amount of time determined by the Chair. In-person comments will be heard at the
beginning of the agenda and remote comments will be heard at the end of the agenda. All
requests to speak will be taken until 5 minutes after the staff’s presentation. Written public
comments can be submitted in advance to UAC@PaloAlto.gov and will be provided to the
Council and available for inspection on the City’s website three days before the meeting. Please
clearly indicate which agenda item you are referencing in your subject line.
PowerPoints, videos, or other media to be presented during public comment are accepted only
by email to UAC@PaloAlto.gov at least 24 hours prior to the meeting. Once received, the Clerk
will have them shared at public comment for the specified item. To uphold strong cybersecurity
management practices, USB’s or other physical electronic storage devices are not accepted.
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posts, poles or similar/other type of handle objects are strictly prohibited; (2) the items do not
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of other attendees, or otherwise disturb the business of the meeting.
TIME ESTIMATES
Listed times are estimates only and are subject to change at any time, including while the
meeting is in progress. The Commission reserves the right to use more or less time on any item,
to change the order of items and/or to continue items to another meeting. Particular items may
be heard before or after the time estimated on the agenda. This may occur in order to best
manage the time at a meeting to adapt to the participation of the public, or for any other
reason intended to facilitate the meeting.
1 Regular Meeting September 02, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
CALL TO ORDER 6:00PM - 6:05PM
AGENDA CHANGES, ADDITIONS AND DELETIONS 6:05PM - 6:10PM
The Chair or Board majority may modify the agenda order to improve meeting management.
IN PERSON PUBLIC COMMENT 6:10PM - 6:15 PM
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.
APPROVAL OF MINUTES 6:15PM - 6:20PM
1.Approval of the Minutes of the Utilities Advisory Commission Meeting Held on August 5,
2026
UTILITIES DIRECTOR REPORT 6:20PM - 6:30PM
NEW BUSINESS
2.Special Presentation and Discussion on Partnering Norms for Staff and Commissioners
Effectiveness. CEQA – Not a Project (DISCUSSION: 6:30PM – 7:00PM)
3.Discussion of Baker Tilly Reserves Advisory Report and Recommendation to the City
Council of Proposed Policy Updates to the Utilities Reserve Management Policies
(ACTION: 7:00PM – 8:30PM) Late Packet Report Added
4.Update on Electric System Long Duration Resiliency; CEQA Status – Not a Project
(DISCUSSION: 8:30PM – 8:50PM)
5.City of Palo Alto Utilities Wildfire Mitigation Plan (WMP) 2026 Update: CEQA – Not a
Project (ACTION: 8:50PM – 9:00PM)
COMMISSIONER COMMENTS AND REPORTS FROM MEETINGS/EVENTS
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.
ADJOURNMENT
2 Regular Meeting September 02, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
OTHER INFORMATION
The materials below are provided for informational purposes, not for action or discussion during this meeting’s agenda. Written
public comments may be submitted in advance and will be provided to the Board and available for public inspection on the
City’s website three days before the meeting.
A.12 Month Rolling Calendar
B.Public Comments
3 Regular Meeting September 02, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
PUBLIC COMMENT INSTRUCTIONS
Members of the Public may provide public comments to teleconference meetings via email,
teleconference, or by phone.
1.Written public comments may be submitted by email to UAC@PaloAlto.gov.
2.Spoken public comments using a computer will be accepted through the teleconference
meeting. To address the Council, click on the link below to access a Zoom-based meeting.
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Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public
programs, services and meetings in a manner that is readily accessible to all. Persons with
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4 Regular Meeting September 02, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
Utilities Advisory Commission
Staff Report
Report Type: APPROVAL OF MINUTES 6:20PM - 6:25PM
Lead Department: Utilities
Meeting Date: September 2, 2026
Report #:2608-6663
TITLE
Approval of the Minutes of the Utilities Advisory Commission Meeting Held on August 5, 2026
RECOMMENDATION
Staff recommends that the Utility Advisory Commission review and approve the August 5, 2026
minutes.
Commissioner ______ moved to approve the draft minutes of the August 5, 2026 meeting as
submitted/amended.
Commissioner ____ seconded the motion.
ATTACHMENTS
Attachment A: August 5, 2026 Draft Minutes
APPROVED BY:
Alan Kurotori, Director Utilities
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UTILITIES ADVISORY COMMISSION
MINUTES OF AUGUST 5, 2026, REGULAR MEETING
CALL TO ORDER
Chair Mauter called the Utilities Advisory Commission (UAC) meeting to order at 6:00 p.m.
Present: Chair Mauter, Vice Chair Phillips, Commissioners Croft, Metz, Tucher, and Gupta
Absent: Commissioner Scharff
AGENDA REVIEW AND REVISIONS
Utilities Director Alan Kurotori said the updated 12-month calendar was left in front of the
Commission, emailed to UAC members, and made available to the public in attendance and on
the website.
IN-PERSON PUBLIC COMMENT
None.
APPROVAL OF THE MINUTES
ITEM 1: ACTION: Approval of the Minutes of the Utilities Advisory Commission Meeting Held on
June 3, 2026
Commissioner Tucher asked about the status of the work plan drafted in redline in the minutes,
which will be presented to Council as soon as August 10. Chair Mauter replied that the
Director’s Report will indicate when the work plan goes to Council.
MOTION: Vice Chair Phillips moved, seconded by Commissioner Metz, to approve the June 3,
2026 meeting minutes.
MOTION PASSED: 5-0-1, Gupta abstain
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UTILITIES DIRECTOR REPORT
Utilities Director Alan Kurotori shared positive news about the passage of AB 34, sponsored by
Senator Becker and Assemblymembers Patterson and Berman, and signed by the governor.
Staff estimated that this legislation could have a $25M impact on the Utility between 2030 and
2045.
Director Kurotori provided an update on the fiber-to-the-premises service. The fiber hut was
completed earlier this year and will enable service for up to 850 customers in the area. Staff is
currently working with about a dozen early adopters to refine the installation process, gather
feedback on their experiences, and address any startup issues. Staff will present a full update to
the UAC in October.
Gas Main Replacement Program #25 has made significant progress. Crews have installed nearly
10,000 linear feet and approximately 220 gas services in our primary residential area. A $16.5M
federal grant funded the project. This reinvestment in our infrastructure also helps reduce our
greenhouse gas emissions, as leaks from our gas mains account for roughly 3 percent of the
emissions generated by our gas utility.
The contractor for the foothill wildfire mitigation project has installed a substantial amount of
conduit and cable, with completion expected by the end of the calendar year. Due to the heat
and increased fire risk, crews are not actively working unless the work is critical or there is a
high business need. As a result, some crews are focusing their efforts outside the foothills and
high-fire-threat areas.
Director Kurotori provided an update on the Arastradero Creek rehabilitation and pipeline
relocation project. A winter storm in 2023 exposed some of our utilities. Principal Engineer
Aaron Perkins presented the proposed restoration activities to the Parks and Recreation
Commission. The plan aims to relocate pipelines away from areas that are prone to erosion
whenever possible. This project also involved gathering information and feedback from the
community and regulatory agencies.
Director Kurotori acknowledged the light agenda for today's meeting. Staff had a conversation
with the chair and vice chair about moving items forward; however, this was not possible
because some staff were out this month. Staff had about 60 potential projects, the majority
battery-only, that they had been working on with the Northern California Power Agency and
other agencies. Staff had expected to negotiate 3 or more power purchase agreements to
present to the UAC tonight. Unfortunately, negotiations between the cities and the developers
did not progress. Once staff receives further details on the next set of competitive projects for
solar and storage options, they will present that information to the UAC, though it is not yet
scheduled. Staff anticipates presenting the UAC work plan at the City Council meeting on
October 5, as indicated in the 12-month rolling calendar. The calendar incorporates items from
the Commission’s recently adopted work plan. Director Kurotori requested the Commission’s
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feedback on how staff is managing the UAC’s schedule and the number of agenda items to
ensure the UAC is not overwhelmed in any given month.
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Commissioner Croft believed the Commission could ask staff about a meeting they attended,
especially because the joint session's date was unknown and the information could be outdated
by the time it was calendared. This body had shown a keen interest in water-related issues, and
Commissioner Croft was curious about any information staff could provide to the UAC.
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NEW BUSINESS
ACTION: Calendar Year 2025 Reliability Metric Update and Annual System Reliability
Goal Setting; CEQA Status; Not a Project, CEQA Guidelines Section 15378(b)(5)
Utilities Chief Operating Officer Terry Crowley delivered a slide presentation. On March 2, 2026,
staff presented electric system reliability metrics to the Council and proposed reliability goals.
The Council agreed with staff’s recommended goals but wanted goals tied to Palo Alto’s past
performance to address electrification concerns. Tonight, staff sought the UAC’s input on the
proposed reliability goals before presenting them to the Council for adoption. COO Crowley
displayed the primary reliability metrics for 2019 through 2025: SAIDI (System Average
Interruption Duration Index), SAIFI (System Average Interruption Frequency Index), and CAIDI
(Customer Average Interruption Duration Index). Major Event Days (MED) were defined as days
when 10 percent or more of Palo Alto’s customers were affected by an outage. In 2023, the City
implemented new software that improved accuracy, so numbers before 2023 may have been
understated.
Chair Mauter asked whether MED could be exogenous to the system, such as an earthquake or
major weather event, rather than a major system outage caused by poor transformer
maintenance, and whether there was a clearer version of MED. COO Crowley responded that
there were 2 widely accepted industry definitions of an MED: The legacy version was 10
percent of customers affected in a 24-hour period. The newer, more statistically valid version is
the 2.5-beta method, which takes the standard deviation of average daily outage minutes,
multiplies it by 2.5, and then applies additional calculations to produce a range. A day that
exceeds that range is an MED. Neither version considers the outage cause. Weather events,
earthquakes, major equipment failures, or other factors could create an MED. Outages on
certain circuits in Palo Alto create an MED. Staff will continue to triage large outages regardless
of the cause. If it was the UAC’s recommendation, staff could include criteria tied to equipment
failures, weather events, or multiple outages.
COO Crowley presented regional and national reliability metrics for 2024 because 2025 data
were not available when staff prepared the report. PG&E’s DeAnza District and Palo Alto had
similar weather, climate, and population density. Benchmarking against PG&E helped assess the
value the City of Palo Alto provides compared with the most likely provider if Palo Alto chose
not to have an electric utility. Palo Alto also compared well with Alameda and Silicon Valley
Power. Palo Alto ranked in the top quartile among all utilities nationwide.
Staff’s proposed reliability goals were: Outperform PG&E’s DeAnza District on all reliability
metrics, including and excluding MED. Remain within the top quartile nationally for SAIDI and
SAIFI when MED is excluded. Set a target for average system reliability equal to or better than 4
nines (99.99 percent available), equivalent to a SAIDI of 52.6 or less. Set an operational target
to lower CAIDI to below 190 to speed restoration times following an outage. The reason for
excluding national MED was that California weather differs from other parts of the country, so
comparing MED that includes storms was not a fair comparison.
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Commissioner Gupta asked about staff’s recommended goal of lowering CAIDI below 190,
rather than a 10 percent 3-year average. COO Crowley replied that the goal was to lower CAIDI
but staff could consider using a 3-year average as an additional goal.
Commissioner Metz wanted to confirm whether the 52.6 and 190 referred to minutes, as that
clarification would be helpful throughout the presentation. COO Crowley confirmed that the
SAIDI and CAIDI numbers were minutes. SAIFI is the number of outages per year.
COO Crowley presented graphs of the proposed targets for average system availability and
reliability, as well as for historical performance against SAIDI, ASAI, and CAIDI targets. COO
Crowley believed that 4 nines, or 52.56 for SAIDI, was not out of reach relative to historical
numbers. The CAIDI target of 190 was sometimes not met, so staff needed to continue driving
those numbers downward to meet that goal. COO Crowley sought recommendations from the
Commission on the 4 goals staff proposed. Those recommendations would then be taken to
Council for final approval, after which staff would begin work on projects to meet those goals.
Vice Chair Phillips emphasized the need for metrics that clearly show whether we are doing
better or worse than in previous years, a sentiment he heard from several City Council
members. No significant changes appeared over the period shown on the slide, prompting Vice
Chair Phillips to ask whether this reflected no improvements or external factors. Given the
City's $375M investment in grid modernization to improve reliability, Vice Chair Phillips asked
how that would show up in the metrics. Vice Chair Phillips asked how these metrics would help
staff improve, how many outages were unavoidable, whether there were many storms and we
did well, or whether there were few storms and our performance was still poor. Vice Chair
Phillips believed the system should be better equipped to handle major events and suggested
that MED not be excluded. Vice Chair Phillips thought that industry-standard metrics did not
adequately serve our needs, especially as we aim to justify the expense of grid modernization.
Vice Chair Phillips wanted something creative to provide a clearer understanding, perhaps by
setting different targets or using other metrics. Vice Chair Phillips was not satisfied with the
proposed metrics.
Commissioner Tucher agreed with Vice Chair Phillips that the SAIDI, SAIFI, and CAIDI metrics
were unhelpful.
COO Crowley loved SAIDI, SAIFI, and CAIDI, and he provided the following explanation. In 2023,
the difference between including and excluding MED was substantial, 154.1 and 43.5,
respectively, indicating storms and a lot of restoration work that caused many customer outage
minutes. For normal operations, 43.5 was a good number. PG&E was in the 200s, the
nationwide quartile was in the 80s, and the numbers for Alameda and Santa Clara were higher
than Palo Alto’s. When MED is included, you assess storm response and decide how to reduce
the number. A utility weighs the value of the service against the cost. One internal discussion is
whether to rebuild the system to better manage winter storms and have staff available 24
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hours a day during storms or winter. The 2024 numbers were similar. In 2025, there were not
many winter storms, so not many MED or outage minutes were excluded; however, when
reviewing outage details, staff found that some large circuits serve more than 10 percent of the
City’s customers. An equipment failure on that circuit automatically triggers an MED, so staff
would have to consider whether we want to prepare for and manage this. Excluding MED
allows separate analysis of large outages.
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Chair Mauter thought it would be useful to have MED subsets to differentiate between weather
events and equipment failures. We want fast response times during bad weather, so including
everything is valuable. It will be easier to demonstrate the value of isolating sections of the grid,
improving robustness, and investing in tree trimming if we pull those out. Benchmarking local
agencies on recovery time is valuable because we experience the same weather events. Chair
Mauter felt it was somewhat futile to set steady averages because the numbers have been
volatile over the years, making it harder to track progress. Chair Mauter assumed the variance
was weather-related. We can promote grid modernization as something that will improve
reliability but then we get a bunch of bad storms. Chair Mauter supported the 4 nines target.
Chair Mauter appreciated setting a metric of 190 minutes, which was valuable for customers
considering investing in a backup battery, helping them decide the size of the backup battery
and how long they were comfortable going without power.
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margin. Palo Alto outperformed De Anza on all metrics including and excluding MED for SAIDI,
SAIFI, and CAIDI, except for CAIDI excluding MED. Palo Alto is in the top quartile of SAIDI and
SAIFI excluding MED. Palo Alto met the proposed 4-nines metric last year by a good margin, and
we failed it only 1 year, so Commissioner Gupta did not know if that was the best metric to
show improvement. Commissioner Gupta recommended identifying the 10 worst-performing
circuits. Commissioner Gupta suggested looking at the percentage of outages we restored
within 4 or 8 hours to evaluate our restoration efforts. We cannot promise customers they will
not experience an outage during a severe storm but promising that they will have their power
back within a couple of hours most of the time can be a helpful selling point in electrification.
Commissioner Gupta will email staff if he has any further creative ideas.
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quickly restore power to customers from another source during an outage. The industry has
tried to reduce outage frequency as much as possible but a 5- or 10-second outage is not a
reliability tool. Utilities are trying to sectionalize outages to fewer customers and then restore
service quickly. Customers want fewer and shorter outages. Customers want information about
the outage, the restoration process, and when the crew will arrive. The City uses the OMS
system to communicate with customers. COO Crowley said it would take years of hard work to
reach a higher goal of 4.5 nines, which corresponds to a SAIDI of about 26 minutes, but that
goal was not unobtainable in most years.
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Commissioner Croft mentioned that she has a heat pump water heater and, given the large
tank, thought it would take a long outage before she ran out of hot water. Car charging was a
major concern, so she suggested having a backup system to use during an outage.
Commissioner Croft recalled a previous discussion about a municipal charging station. If
customers could receive a notification on their phones and reserve a charging spot, it would
reduce concerns for those considering electrification.
Vice Chair Phillips asked what staff’s next step was on this item. COO Crowley replied that it
was up to the Commission whether staff should return or that he could coalesce the
commissioners’ comments and then return to Council to seek their input and final approval.
The Commission already expressed their opinions, so Chair Mauter recommended that staff
coalesce these comments and return to Council to seek their input and final approval.
Commissioner Tucher did not know whether the data showed we were getting better or worse,
nor did he understand what was happening behind the numbers. Answers to the questions he
raised in his public letter would give him more confidence that our outages are improving and
help us reassure customers about electrification. Commissioner Tucher posed the following
questions. Why is CAIDI so high at 245? Are a small number of big outages skewing the average,
since SAIFI is low, or does excluding MED remove the easy cases and leave only the hard ones?
What specifically is an MED (weather and equipment or other causes)? How many MED were
there? What percentage of total outages were MED? Where are the hot spots? Where were the
outages last year, and what were the causes and durations? Standard industry metrics do not
answer those questions but Commissioner Tucher thought a metrics outage report ought to.
What is an outage, and can an outage be as short as 30 seconds? Commissioner Tucher would
welcome reevaluating whether solar and battery storage pencil out, especially for commercial.
COO Crowley explained that Palo Alto’s CAIDI is typically high because outages are related to
equipment failures or other issues that require a crew to repair, such as transformer or
underground splice failures. It takes time to call out the initial troubleshooter, have them
conduct an initial investigation, identify the issue, isolate it, and restore customers. In the
meantime, we call in a crew of 3 to 5 people, and it takes time for them to arrive. We have
more outages and more customers affected in an MED but restoration time is quicker because
staff do not have travel time. Staff can calculate the outage minutes associated with MED. The
Maybell and Colorado circuits were involved in the majority of outages from October 2023 to
July 2026. Because they are large circuits, an outage affects more customers and generates
more outage minutes. Fault indicators can find and isolate the outage. As we do grid
modernization, staff is looking at adding sectionalizing devices, which is a fuse or interrupter to
break up the circuit into smaller pieces, so fewer customers are affected by a disruption.
COO Crowley said staff needed direction on these metrics or whether the UAC wanted to see
additional metrics, such as how many customers we restore within 4 hours or other goals. As
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next steps, staff will review those metrics, investigate outage details, and identify the lowest-
cost solutions or projects to reduce those numbers and meet the goals.
NO ACTION TAKEN
FUTURE TOPICS FOR UPCOMING MEETINGS
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commission, how we advocate and provide our advice, what our role is, and better ways to
work together.
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Commissioner Tucher submitted his suggestions for the work plan. The current draft contained
inconsistencies, errors, and redundancies. The UAC work plan did not include financial reviews
of each utility.
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the work plan could be spread across the June and July meetings. Commissioner Croft thought a
questionnaire should be sent in advance to help commissioners identify their top topics, as she
found it helpful this year. Chair Mauter agreed with Commissioner Croft. Director Kurotori said
work plans are fiscal and typically developed after commissioners are appointed. Chair Mauter
stated that the UAC put significant time, thought, and effort into formulating the 12-month
work plan in June, so the current UAC needed to follow through on it. Chair Mauter suggested
the Commission discuss it with City Manager Shikada next month during Commission Norms.
COMMISSIONER COMMENTS AND REPORTS FROM MEETINGS/EVENTS
VIRTUAL PUBLIC COMMENT
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1. Alex M. presented slides as the spokesperson for a group of 5 people. His company
developed an easy-to-use platform that combined structures, live fuel moisture, terrain,
and weather into a single, simple view of the wildland-urban interface, refreshed every
3 to 5 days, that firefighters can use on their iPad. Alex M. proposed a 90-day
memorandum of agreement with the City of Palo Alto to allow firefighters, utilities, City
planners, and community stakeholders to experience its operational value. Current fire
models have technological limitations because they rely on input from a 1980 satellite
launched by USGS that uses a 30-meter pixel grid. Alex M. built a platform on top of GIS.
A slide showed 1-meter-per-pixel Sentinel-2 imagery from the European Space Agency,
which can show vegetation health and growth over time; identify homes with the
highest risk based on terrain, slope, live fuel moisture, and vegetation type; and show
where flame lengths exceed 12 feet. This information helps agencies prioritize
inspections, identify high-risk areas, and note areas with utility lines and other factors
that could cause widespread urban conflagration. Gaussian Splats, a newer 3D
rendering, was implemented to run a physics-based fire model in collaboration with
some of the larger Bay Area technology companies. It can model how fire and embers
may move under dry offshore winds interacting with the foothill terrain. Alex M. offered
the possibility of applying for grant funding for the City of Palo Alto.
2. Peter Drekmeier with Yosemite Rivers Alliance raised his hand for Item 2, lowered it
when he began to speak, and then heard staff say there were no speakers. He was very
impressed with the staff presentation and believed the Commission asked good
questions and made good points, resulting in a better product going to City Council.
Yosemite Rivers Alliance had been trying to get a study session for a long time but they
were not invited to participate in the water study session. Peter Drekmeier did not have
much confidence in staff. At the Council meeting on the Urban Water Management
Plan, he commented that staff was more aligned with BAWSCA than with Palo Alto. The
City has endorsed the Bay Delta Plan but staff has been very oppositional. He has
started to reach out to some Council Members to share his concerns. He asked Director
Kurotori to reach out to him to ask what he wanted this study session to look like, how
we could work together, and how we could make it the study session Council is
expecting. BAWSCA and SFPUC did not want to engage in dialogue with Yosemite Rivers
Alliance because it embarrassed them. Peter Drekmeier was happy to work with staff
but they had to earn his trust.
ADJOURNMENT
Adjournment: The meeting was adjourned at 8:28 p.m.
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On behalf of Utilities Director Alan Kurotori, please find below the staff responses to questions
from Utilities Advisory Commission members.
1. Outage metrics –
Objective: to strengthen the message to customers that CPAU electric service is
reliable and build a more compelling case for electrification
Specifically, can we come up with a more comprehensive, nuanced reporting of our
local grid reliability? Can we report on outages and up-time so as to provide more
insight into problems and priorities?
Recommended approach:
Define outage – Is an outage any interruption in service, regardless how short?
Group outages by cause: weather, equipment failure, perhaps 1-2 other causes
Outages by Duration, perhaps grouped by short/medium/long – grouped by cause
Outages by Location: which neighborhoods, which substation or feeder – grouped
by cause and by duration/severity. Are Residential or Commercial customers
impacted?
Major Event Days (MED) – How many MEDs? What were they? Can we list them?
Which parts of our grid, or which customers did they impact? Can we provide simple
sensitivity analysis for MEDs: What if, instead of 10% impact, we look at 5% or 20%?
What if we define “impact” as 2hrs+ or 30min+ or “short vs long” interruptions?
Note: To focus only on outages is, of course, negative. Up-time is positive. What
about also reporting up-time overall, by substation or feeder, or by
Residential/Commercial?
Staff response: Below is additional information and data to answer the questions posed
in the recent email. With the outages software we are currently using, there are limitations
into how much dissecting of the data can be done. That said below provides a deeper dive
into the outage trends and some of the circuits with the highest customer outage
minutes. From the UAC’s recommendations, staff will look at ways we can break this data
down for presentation to customers in a meaningful way.
Additional Information & Data
Define outage – Is an outage any interruption in service, regardless how short?
Staff Responses to UAC Questions
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Outages or interruptions are defined as a loss of power on one or more phases.
Interruptions are broken into the categories of momentary (less than 5-minutes) and
sustained (greater than 5-minutes).
Group outages by cause: weather, equipment failure, perhaps 1-2 other causes
With the quarterly information report staff show the grouping of outages by the
primary cause (tree, animal, equipment, etc.). Below is a snip from the most recent
informational report showing the number of sustained outages within an outage type
and percent of total outages. Creating this graph helps staff understand what types
of outages occur more frequently, and which mitigation measures should be
implemented. Palo Alto’s trend shows that a focus on the urban forest and tree
trimming along with preventative equipment replacements could reduce the number
of unplanned outages. Note that Equipment Damage (19%), Equipment Worn Out
(8%), and Electrical Failure (23%) are all types of equipment failures (50% of
sustained outages).
Outages by Duration, perhaps grouped by short/medium/long – grouped by cause
The first chart (left) below shows the number of outages by their average interruption
duration (AIDI) in hours. This is basically the average time, rounded to the hour, it
took to restore the customers impacted by the outage. The second chart (right)
shows the total time from first reporting of the outage to last customer restored,
rounded to the nearest hour, for each outage. From this data roughly 67% of
customers impacted by an outages are restored within 4 hours, 57% within 3-hours.
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Outages by Location: which neighborhoods, which substation or feeder – grouped by cause
and by duration/severity. Are Residential or Commercial customers impacted?
I don’t have a visual of historical outages but can provide the table below of Circuits
that have generated the most customer outage minutes since Oct 2023. What is
seen is that historically Maybell and Colorado are large contributors to outage
minutes which tend to increase SAIDI and CAIDI. Sectionalizing devices (fuses,
reclosers, interrupters) will lower these outage minutes.
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Below is a list of the MED, based upon 10% of customers, for CY2024 and CY2025.
This list also includes the causes for each MED. Notable is the UAC
recommendation to further separate these by larger external influences rather any
outage cause that reaches the 10% threshold.
We have some limitations in the outage records we keep. For example, we do not track
outages by customer type. A separation of outage data by residential vs commercial
customers isn’t readily available. Staff does review outages by circuit and protective device
(fuse, recloser, interrupter) to identify repeat outages or outage cause trends.
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Major Event Days (MED) – How many MEDs? What were they? Can we list them?
Which parts of our grid or which customers did they impact? Can we provid Packe
simple sensitiviet Pg. 24ty analysis for MEDs: What if, instead of 10% impact, we look at
5% or 20%? What if we define “impact” as 2hrs+ or 30min+ or “short vs long”
interruptions?
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Utilities Advisory Commission
Staff Report
From: Ed Shikada, City Manager
Lead Department: City Manager’s Office
Meeting Date: September 2, 2026
Report #: 2607-6585
TITLE
Special Presentation and Discussion on Partnering Norms for Staff and Commissioners
Effectiveness. CEQA – Not a Project
RECOMMENDATION
Discuss partnering norms for staff and Commissioners effectiveness.
BACKGROUND
Citywide, the Boards, Commissions, and Committees (BCC) Handbook1 provides comprehensive
guidance for the operation of the City’s BCCs. City departments that provide staff to BCCs
periodically discuss opportunities to enhance effectiveness in providing support to the work
and BCCs, and one recently identified area for exploration is establishment of norms for
interactions between BCCs and staff. This report and Commission discussion are intended to
support ongoing alignment between Commissioners and staff to advance the work of the City.
In addition to addressing issues of importance to the Palo Alto community, the City’s Boards
and Commissions provide an important role in staff development as well as the development of
community volunteers and leaders. As such it is important that all participants receive an
environment that is welcoming and conducive to professional and personal development while
also effectively and efficiently conducting the work entrusted to each body.
On an ongoing basis, staff work with individual commissioners on concerns with staff
interactions as they arise. This report and discussion represent an effort to proactively address
issues before they become concerns, for the benefit of all. The UAC is the fourth commission to
hold this discussion over the past year.
1 City Boards, Commissions, and Committees Handbook;
https://www.paloalto.gov/files/assets/public/v/4/cityclerk/board-and-commission-handbook.pdf
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ANALYSIS
Recognizing the broad range of topic areas and procedures involved with the City’s advisory
bodies, staff is not recommending that each Commission adopt of a uniform set of norms. At
the same time, in order to provide a starting point for each discussion, staff has developed an
initial set of topic areas for discussion provided in Attachment A.
The attachment is simply provided as a starting point, with the expectation that Commissioners
may have differing views on the topic areas as well as additional topic areas to discuss. The
points provided may also serve as a reference if/when issues arise in the future.
Depending on the Commission’s interest level, next steps could vary. This could simply be a
one-time discussion, not requiring any follow-up. Otherwise, it could be included as a topic for
further discussion at a future Commission meeting such as an annual work-planning session.
Other follow-up may also be appropriate. In any case, staff appreciate the opportunity to
discuss this important issue with the Commission.
When reviewing these and normalizing activity for a commission, it is helpful to review
foundational direction on roles as well as acknowledge some inherent tensions that can arise in
fulfilling the roles of commissioners and staff.
The UAC is established by the City of Palo Alto Municipal Code Chapter 2.23. with the Purposes
and Duties outlined in PAMC 2.23.050
(a) The purpose of the utilities advisory commission shall be to advise the city council on
present and prospective long-range planning and policy and major program and project
matters relating to the electric utility, gas utility, water utility, wastewater collection
utility, fiber optics utility and recycled water matters, excluding daily operations.
UAC recommendations are typically advanced to the City Council Finance Committee (or
potentially the Policy & Services Committee), which then makes recommendations to the full
City Council for approval or direction on policy and program decisions impacting the Utility
Department.
Inherent in the design of this governmental decision-making structure are principles such as
transparency, opportunities for community engagement, and checks and balances. This can
lead to tensions such as:
- Individual topics of interest versus priorities for the Commission as a whole
- Ability to address issues of the day versus public noticing (Brown Act) requirements
- Engaging on emerging issues versus accountability for completing a workplan
- Governance versus management
- Resource allocation to progress reporting versus making progress
- Time management
These tensions are systemic and balancing competing interests requires prioritizing
collaborative governance. This item is intended to support discussion of commission norms that
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balance competing priorities and maintain the alignment necessary to advance the services
established by the City Council as priorities for the Palo Alto community.
FISCAL/RESOURCE IMPACT
ATTACHMENTS
AUTHOR/TITLE:
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Utilities Advisory Commission
Staff Report
Report Type: NEW BUSINESS
Lead Department: Utilities
Meeting Date: September 2, 2026
Report #:2608-6668
TITLE
Discussion of Baker Tilly Reserves Advisory Report and Recommendation to the City Council of
Proposed Policy Updates to the Utilities Reserve Management Policies
This will be a late packet report published on Thursday, August 27, 2026.
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Item No. 4 Page 1 of 4
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: September 2, 2026
Report #: 2604-6312
TITLE
Update on Electric System Long Duration Resiliency; CEQA Status – Not a Project
RECOMMENDATION
Recommend staff continue monitoring estimate costs for local utility scale battery storage and
provide an update to the UAC with the next Integrated Resource Plan and recommend staff
review and propose reasonable hazard mitigations with recommended capital improvement
projects.
EXECUTIVE SUMMARY
On March 2, 2026, the City Council accepted a report on the cost of local energy resources and
improved reliability and resiliency. The report found that local microgrids were not cost
effective at this time but recommended continued engagement with the Utility Advisory
Commission (UAC), Climate Action and Sustainability Committee (CASC), and the City Council
regarding micro-grids and long-term resiliency. On an ongoing basis, utility staff are reviewing
the market and publicly available information regarding the cost of local microgrids and battery
energy storage systems (BESS). Because current costs indicate that microgrids do not present
cost savings for customers, staff plans to continue to review pricing until market analysis
suggests better value. Another assessment will be included with the next update of the City’s
Integrated Resource Plan, which staff will begin updating in 2027 and planned to file in early
2028.
Simultaneously, staff are beginning a review of the Electric Department’s preparedness to
respond to large-scale events requiring a significant and sustained effort to restore electric
service. In the event of a large-scale natural disaster (earthquake, flooding, windstorm, wildfire,
heat storm, etc.), local micro-grids could help isolated pockets of electric customers remain in
power, but City staff would immediately need to begin the repair and restoration process for all
other customers. The larger effort of restoring utility service citywide requires forethought,
planning, and some capital investment. The Palo Alto Annex of the Santa Clara County Multi-
Jurisdictional Hazard Mitigation Plan (MJHMP) identifies areas of the City’s electric system that
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Item No. 4 Page 2 of 4
could be strengthened to lessen the impact of major events. Over the next several months,
staff will review utility projects identified in the MJHMP and existing Grid-Modernization (Grid-
Mod) projects consider impacts of major weather events over the expected life of the assets.
This review will help to improve long-term resiliency under adverse conditions as well as
support one of Grid-Mod’s primary goals of improving overall system reliability.
BACKGROUND
ANALYSIS
1 identified a cost for utility scale battery storage of $482/kWh, and NLR’s
2025 update2 saw a lowering of those costs to $334/kWh. The 2023 update also forecasted
battery storage pricing ranging between $255/kWh and $403/kWh in 2030, with the 2025
update estimating storage costs at $147/kWh and $339/kWh by 2035. Both the 2023 and 2025
forecasts of future battery storage costs anticipate reductions in costs, but the expected
reductions may fall within a wide range.
1 NLR Cost Projections for Utility-Scale Battery Storage 2023 Update https://docs.nlr.gov/docs/fy23osti/85332.pdf
2 NLR Cost Projections for Utility-Scale Battery Storage 2025 Update https://docs.nlr.gov/docs/fy25osti/93281.pdf
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Item No. 4 Page 3 of 4
reliable electric service rather than analysis based solely on providing the lowest cost service
regardless of reliability. Staff are working with the NLR model, adjusting the assumptions to
provide relevance for Palo Alto’s residential and commercial customers. As staff become more
familiarized with the model’s valuation of reliability, those valuations will be brought to the
UAC in the FY28-32 Electric Capital Improvement Program.
5 For the City’s Electric Department, the Annex specifically names earthquake,
heavy precipitation/atmospheric rivers, extreme heat/cold, high wind, wildfire, and sea level
rise as hazards. It also lists mitigation measures that could make the electric system more
resilient. Some of those mitigation measures have been completed, such as undergrounding
overhead electric lines in the Foothills, while others are still being studied, such as mitigation
measures addressing sea-level rise. The Annex presents a good starting point to identify
additional mitigation measures and to estimate costs in preparation of potential funding
through rate revenue and/or federal grant dollars.
5 Santa Clara County Multijurisdictional Hazard Mitigation Plan 2023 Update: City of Palo Alto Annex -
https://www.paloalto.gov/files/assets/public/v/1/oes/plans/final_vol-ii-santa-clara-mjhmp_city-of-palo-alto-
annex-1.pdf
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model. Should additional projects show a cost benefit, staff will bring the projects showing the
largest benefit to cost ratio back to the UAC for further review and discussion.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
AUTHOR/TITLE:
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Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: September 2, 2026
Report #:2608-6666
TITLE
City of Palo Alto Utilities Wildfire Mitigation Plan (WMP) 2026 Update: CEQA – Not a Project
RECOMMENDATION
Staff recommend that the Utilities Advisory Commission (UAC) review the City of Palo Alto
Utilities (CPAU) 2026 Wildfire Mitigation Plan (Plan), receive public comments, and recommend
that CPAU submit the Plan to the California Wildfire Safety Advisory Board (WSAB) in
accordance with Public Utilities Code Section 8387.1
EXECUTIVE SUMMARY
This report presents the City of Palo Alto Utilities (CPAU) 2026 Wildfire Mitigation Plan Update
for the Utilities Advisory Commission's review, receipt of comments, and recommendation for
approval to submit to the WSAB.
The Plan documents CPAU's continued efforts to reduce the risk of utility-caused wildfires
through undergrounding electric infrastructure, vegetation management, routine inspections,
weather monitoring, system hardening, emergency preparedness, customer education, and
Public Safety Power Shutoff (PSPS) planning.
The Plan specifically highlights progress on the multi-phase, multi-million-dollar Foothill Fire
Mitigation Project by undergrounding electric infrastructure and decommissioning high-voltage
overhead facilities along with other completed mitigation measures and planned future
initiatives.
BACKGROUND
Public Utilities Code Section 8387 requires publicly owned electric utilities to prepare and
maintain a Wildfire Mitigation Plan describing how electrical lines and equipment will be
1 Public Utilities Code 8387
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8387&lawCode=PUC
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constructed, maintained, and operated in a manner that minimizes the risk of utility-caused
wildfires.
3 Under the current schedule, CPAU is required to submit its
Wildfire Mitigation Plan by October 2, 2026. CPAU is currently assigned to a two-year Wildfire
Mitigation Plan reporting cycle, with a future update due in October 2028, because it continues
to own overhead electric facilities within the High Fire Threat District (HFTD) designated by the
California Public Utilities Commission (CPUC).4 Upon completion of the Foothill Fire Mitigation
Project and removal of the remaining overhead facilities within the HFTD, CPAU staff plan to
work with WSAB to determine whether the City qualifies for a four-year reporting interval
under a future reporting schedule.
ANALYSIS
The Plan includes updates on the following wildfire mitigation activities:
Planned completion of the Foothill Fire Mitigation Project in late 2026, including
undergrounding electric and fiber infrastructure and decommissioning City-owned overhead
wires and utility poles. As of August 2026, all overhead high-voltage lines have been de-
energized and customers are now being served via underground lines.
Ongoing vegetation management activities within the Foothills Area including vegetation
management around newly installed underground and pad-mounted equipment.
Inspection and preventative maintenance of electric infrastructure in the high fire threat
area to improve reliability and lower the incidence of power outages.
Weather monitoring and situational awareness using localized weather stations,
AlertCalifornia wildfire camera monitoring, regional fire weather forecasts, and Electricity
Information Sharing and Analysis Center (E-ISAC) notifications.
3 Senate Bill No. 254 - https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB254
4 Office of Energy Infrastructure Safety, Wildfire Advisory Board 2026-2029 Wildfire Mitigation Plan Schedule for
Publicly Owned Utilities and Electrical Cooperatives (Dec. 2025), https://energysafety.ca.gov/wp-
content/uploads/2025/12//2026-2029-schedule-for-pou-and-co-op-wmp-submissions.pdf
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Public Safety Power Shutoff (PSPS) education, planning, and emergency communications.
Coordination with the City's Office of Emergency Services, Fire Department, Public Works
Department, and Urban Forestry Division to support wildfire preparedness and emergency
response.
The Plan also updates Appendix A to summarize completed wildfire mitigation accomplishments, goals,
and future initiatives.
FISCAL/RESOURCE IMPACT
There is no immediate fiscal impact associated with the Plan. The Plan documents existing and planned
wildfire mitigation activities that are funded through the City's approved Capital Improvement Program
and annual operating budgets, as appropriate. Approval of the Plan does not authorize additional
funding but provides the planning framework supporting CPAU's utility wildfire mitigation program.
STAKEHOLDER ENGAGEMENT
Consistent with Public Utilities Code Section 8387, the Wildfire Mitigation Plan is presented at a publicly
noticed Utilities Advisory Commission meeting to provide an opportunity for public review and
comment prior to filing with the California Wildfire Safety Advisory Board. The 2026 Plan will be posted
on the City of Palo Alto Utilities website.7
ENVIRONMENTAL REVIEW
The Plan is not a project under the California Environmental Quality Act (CEQA) pursuant to
CEQA Guidelines Section 15378 because it is an administrative planning activity that does not
authorize or result in a physical change to the environment. Any future capital projects
identified in the Plan will undergo separate environmental review, as applicable.
ATTACHMENTS
Attachment A: CPAU Wildfire Mitigation Plan Update 2026
APPROVED BY:
Alan Kurotori, Director Utilities
Staff: Terry Crowley, Chief Operations Officer
7 City of Palo Alto Utilities Website for all versions of the WMP @
https://www.paloalto.gov/Departments/Utilities/Utilities-Services-
Safety/Safety/Utilities-Wildfire-Mitigation
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WILDFIRE MITIGATION PLAN
2026 UPDATE
September 2, 2026
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TABLE OF CONTENTS
I. UTILITY OVERVIEW AND CONTEXT ................................................................................................... 1
A. Context table ............................................................................................................................... 1
B. Statutory cross-reference table ................................................................................................... 2
C. Process for Wildfire Mitigation Plan adoption ............................................................................. 2
D. Plan location on the website ........................................................................................................ 2
II. PLAN PURPOSE AND OBJECTIVES ..................................................................................................... 3
A. Purpose ........................................................................................................................................ 3
B. Scope............................................................................................................................................ 3
C. Plan objectives ............................................................................................................................. 3
III. ROLES AND RESPONSIBILITIES ......................................................................................................... 5
A. City of Palo Alto organizational structure ................................................................................... 5
B. Coordination with other departments ......................................................................................... 6
C. Deenergization-related communication ...................................................................................... 6
IV. ELECTRIC-LINE IGNITED WILDFIRE RISK DRIVERS .............................................................................. 7
A. Primary risk drivers and specific mitigation efforts ..................................................................... 7
C. Other electric equipment-specific mitigation strategies ............................................................. 8
D. Enterprise-wide Safety Risks ........................................................................................................ 9
E. Current and prior activities ........................................................................................................ 10
V. MONITORING THE PLAN ................................................................................................................ 10
A. Measuring Plan and inspection performance ............................................................................ 10
B. Performance and outcome metrics ........................................................................................... 11
C. Applying previous Plan metrics to this Plan ............................................................................... 11
TABLE OF FIGURES
Figure 1: Map of CPAU Electric Service Area - CPUC HFTD Tier 2-Elevated Fire Risk “Foothills Area”
Figure 2: Organizational Structure of Roles & Responsibilities Supporting the Plan
Figure 3: Vegetation Buffer Diagram
Figure 4: High Level Map of the Foothill Fire Mitigation Project
APPENDICES
Appendix A: Summary of Key Wildfire Mitigation Activities
Appendix B: PSPS Policy and Process for Public Safety Power Shutoff
Appendix C: Utilities Wildfire Mitigation Utilities Response and Communications Procedure for Public
Safety Power Shutoff (PSPS)
Appendix D: Plan Revision Log of Key Changes
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City of Palo Alto Utilities Wildfire Mitigation Plan
2026 Update
Page | 1
I. UTILITY OVERVIEW AND CONTEXT
A. Context table
1 CPUC ArcGIS map https://www.arcgis.com/home/webmap/viewer.html
2 CAL FIRE’s Santa Clara Unit 2024 Strategic Fire Plan https://osfm.fire.ca.gov/what-we-do/community-wildfire-
preparedness-and-mitigation/pre-fire-planning
City of Palo Alto Utilities
High Fire
2 - 40%
1
by a PG&E PSPS.
PSPS?
to initiate its own PSPS? forecast and field conditions. Refer to the PSPS Policy
Appendix B
by information about wind regional wind conditions.2
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City of Palo Alto Utilities Wildfire Mitigation Plan
2026 Update
Page | 2
B. Statutory cross-reference table
C. Process for Wildfire Mitigation Plan adoption
Palo Alto is unique among Public Owned Utilities (POUs) because it has a Utilities Advisory
Commission (UAC), an advisory Commission to the City Council. This commission is comprised
of Council-appointed residents who meet monthly to provide advice to City Council and staff
on utilities-related matters, including the City’s Wildfire Mitigation Plan (Plan). A Brown Act
body, the UAC publishes agendas in advance of each public meeting and provides
opportunities for public comment at each meeting. Each year, Palo Alto staff presents the
Plan at a UAC meeting where staff accept any public comments and receive feedback from
Commissioners.3 Minutes and videos of past meetings are available on the City’s website.
D. Plan location on the website
Palo Alto’s Plan is the first substantive item found on the Utilities Department safety
webpage. Navigating to this page from the Department’s main page takes only two clicks and
is intuitive. Users click on “Utilities Services and Safety,” then “Wildfire Mitigation.” 4 Because
the City also has a Fire Department and an Office of Emergency Services that respond to fires
and other emergencies, this report briefly notes how this wildfire Plan differs from other City
emergency response plans.
3 PUC 8783(b)(3) requires a POU to “present its wildfire mitigation plan in an appropriately noticed public
meeting…[and] accept comments on its wildfire mitigation plan from the public….” While not the governing board
of the utility, the UAC review satisfies the legal requirement of presenting the Plan at a noticed public meeting
where comments from the public are accepted.
http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8387&lawCode=PUC
4 Utilities Department safety webpage, www.paloalto.gov/safeutility
Code section Requirement Page
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City of Palo Alto Utilities Wildfire Mitigation Plan
2026 Update
Page | 3
II. PLAN PURPOSE AND OBJECTIVES
A. Purpose
This Plan is written in compliance with Public Utilities Code section 8387 5 and describes how
the City of Palo Alto Utilities Department (CPAU) maintains and operates its electrical lines
and equipment in a manner that minimizes the risk of wildfire posed by those lines and
equipment.
B. Scope
The scope of this Plan is limited to providing information about mitigating the risk of wildfires
from electric lines and equipment. It distinguishes between mitigating risks of possible
electric line-ignited wildfires versus wildfires or wildfire suppression generally. The latter
topics are in the scope and under the purview of trained fire experts, such as the City’s Fire
Department, and not within the expertise of utility engineers and technicians. The former is
within the scope of CPAU responsibilities and is the subject of the state code section
mandating this Plan; therefore, it is the sole focus of this Plan.
Additionally, this Plan applies to the only area in the City of Palo Alto identified as a high fire
threat area per the California Public Utilities Commission (CPUC) High Fire Threat District
(HFTD) map. Currently, the high fire threat area in Palo Alto includes all areas with the City
limits west of Highway 280, referred to as the Foothills Area, see Figure 1 below. This area is
about eight square miles, is sparsely populated, and consists primarily of open space.
Lastly and per the California Wildfire Safety Advisory Board (WSAB) request of all POUs, this
updated Plan deliberately omits general information the Board already understands in favor
of specific information about the City’s territory, infrastructure, and mitigation projects. For
example, the Board already knows that CPAU, and other POUs, meet all applicable CPUC
General Order 95 (GO95) standards so it is not reiterated here.
C. Plan objectives
The Plan’s primary objective is to guide CPAU staff in minimizing the probability that the City’s
electric distribution system may be an original or contributing source for wildfire ignition. The
City strives to ensure that its infrastructure is safe and resilient by taking proactive actions to
maintain its equipment, refine the existing Public Safety Power Shutoff (PSPS) protocols as
needed, and underground the electric lines in the high fire threat area.
A secondary objective is to improve the resiliency of the City’s electric distribution system and
to measure the efficacy of the wildfire mitigation strategies.
5 Public Utilities Code section 8387
http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=8387&lawCode=PUC
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City of Palo Alto Utilities Wildfire Mitigation Plan
2026 Update
Page | 4
Figure 1: Map of CPAU Electric Service Area - CPUC HFTD Tier 2-Elevated Fire Risk “Foothills
Area”
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City of Palo Alto Utilities Wildfire Mitigation Plan
2026 Update
Page | 5
III. ROLES AND RESPONSIBILITIES
A. City of Palo Alto organizational structure
Figure 2 highlights staff and governing bodies with direct or indirect roles and
responsibilities related to the Plan.
Figure 2: Organizational Structure of Roles & Responsibilities Supporting the Plan
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City of Palo Alto Utilities Wildfire Mitigation Plan
2026 Update
Page | 6
In Palo Alto, the City Council is the governing body of all City functions including the City’s
utilities. As noted above, the UAC is a Brown Act body that provides advice on utilities-
related matters. CPAU operates and maintains all the utilities in the City, including electric,
water, gas, fiber, and wastewater. CPAU also employs communications staff to engage with
the community and a Compliance Manager who, among other duties, ensures reports such
as this Plan are completed timely and appropriately.
CPAU’s electric and fiber staff noted above all play a key role in mitigating wildfire risk from
electric lines and equipment. Specifically, CPAU engineering staff produce safe and resilient
designs, and oversee wildfire mitigation projects such as undergrounding electric and fiber
lines.6
B. Coordination with other departments
CPAU’s Electric Engineering and Operations Divisions work closely with other divisions
within the Utilities Department. Utilities collaborates with the Public Works Department
(PWD) and its Urban Forestry and Environmental Compliance Division, the Fire
Department, and the Office of Emergency Services (OES). Together, these departments and
divisions proactively prepare for wildfires, act to mitigate climate and fire-related risks,
maintain utilities infrastructure, develop plans for deenergization events, provide
vegetation management, and lead Palo Alto’s robust climate action efforts. As these
divisions, departments, and teams are under the umbrella of one City, there is a strong
history of working together closely.
C. Deenergization-related communication
CPAU’s Communications staff inform the community about deenergization events. CPAU
staff maintain and update as necessary a “Utilities Wildfire Mitigation Response and
Communications Procedure for Public Safety Power Shutoff” (PSPS), see Appendix C. This
procedure details the City's outreach to customers about Public Safety Power Shutoffs
(PSPS). CPAU proactively communicates with potentially impacted customers when first
alerted to weather conditions that may require a PSPS, provides updates while monitoring
conditions, and if a PSPS is activated, communicates with customers during and after an
event.
The City uses a variety of communication channels for public information outreach.
Customers can be reached directly through the Outage Management System (OMS) using
text notification. Information on PSPS in general and specific events as they occur is provided
on the City's website (paloalto.gov/PSPS) and recordings on City hotlines such as the Electric
Operations Dispatch phone line at the Utilities Control Center and Utilities Customer Service
Call Center.
6 To keep the public informed of CPAU’s capital improvement projects (CIPs), CPAU places CIP-related information
on its website, paloalto.gov/UtilityProjects. This information includes primary staff contact information for the
projects.
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City of Palo Alto Utilities Wildfire Mitigation Plan
2026 Update
Page | 7
IV. ELECTRIC-LINE IGNITED WILDFIRE RISK DRIVERS
WITH PREVENTION AND MITIGATION EFFORTS
A. Primary risk drivers and specific mitigation efforts
Palo Alto recognizes that the WSAB is most interested in specific risks unique to each POU
and its service territory, rather than general risks carried by all electric utilities. As such, and
because Palo Alto is in the process of undergrounding the lines in its single high fire threat
area, this Plan notes only the risk associated with electric equipment in the Foothills area.
The more general risks (outside the Foothills area) Palo Alto regularly mitigates, but does
not specifically address in this Plan, include:
• Electric distribution system operating, management, and construction practices
• Weather including high winds
• Extended drought
With regard to weather monitoring, Palo Alto installed a weather station in the Foothills area
and a second weather station at the Utility Control Center to view localized weather data.
CPAU staff also monitor regional conditions, such as red flag warnings (RFW), and
communicate with first-responder departments on any actions needed due to weather
conditions.
B. Primary risk drivers and specific mitigation efforts: Vegetation type, density, and
management practices.
Wildfire risks from electric lines and equipment include vegetation intruding into power
lines, falling onto lines, or roots damaging undergrounded equipment. Mitigation efforts
include ongoing physical inspections, ensuring the proper type of vegetation is placed at the
correct distance from equipment, and adherence to the City’s Line Clearing Program and
Tree Technical Manual for proper care of trees. Palo Alto’s dedicated Urban Forestry
Division, part of the Public Works Department and staffed by trained, experienced urban
foresters, also oversees and coordinates the work of external contractors.
Palo Alto utilizes a variety of vegetation treatment methods to reduce the risk of wildfire,
including tree or branch removal, trimming, mowing, and brush cutting. To help staff track
and manage flammable new growth, Palo Alto may utilize geographic information system
(GIS) and growth modeling. Currently, this work is performed manually with physical
inspections. In addition, for the Foothills area, Urban Forestry uses an enhanced vegetation
management buffer as shown in Figure 3.
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Figure 3: Vegetation Buffer Diagram
C. Other electric equipment-specific mitigation strategies
The overhead distribution line serving the Foothills area has been undergrounded,
eliminating the need for the previous practice of disabling automatic reclosing on protective
devices to reduce wildfire ignition risk. The underground system is protected by vacuum fault
interrupters and substation circuit breakers that automatically isolate faults. Following a
fault, service restoration is performed only after the affected equipment has been evaluated
and any necessary repairs have been completed to ensure safe restoration. Undergrounding
significantly reduces wildfire ignition risk while improving overall system reliability and
resilience.
• Utilizing specific fuses. CPAU utilizes non-expulsion fuses in the high fire threat area.
Specifically, CPAU utilizes Eaton’s Cooper PowerE series ELFE fuse, a full range,
current-limiting dropout fuse with a self-contained design that eliminates noise and
expulsive showers. If these fuses explode, any hot metal is contained within the fuse
holder, preventing contact with vegetation.
• Deenergizing, then reenergizing when prudent. CPAU considers deenergizing electric
lines as a last resort, realizing that while the lack of power could be an inconvenience
for some customers, it could cause significant health and safety concerns for others.
However, CPAU will utilize this option when necessary to minimize the risk of an
electric-line ignited wildfire in the high fire threat area. Factors CPAU considers when
determining whether to deenergize include:
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o The possible safety impacts to CPAU customers
o Any fire activity in the vicinity
o Any evacuation orders and other information from emergency personnel
o Information from local fire agencies, vegetation staff, and
CPAU electric system operators
o Local and regional weather conditions including wind, humidity,
precipitation and any red flag warnings
o The state of vegetation in the area (i.e. very dry)
• Restoring power after a wildfire or deenergization event. Lines will only be reenergized
when (1) the risk has passed, (2) the lines are inspected, and (3) any required repairs
are complete. CPAU utilizes its Public Safety Power Shutoff (PSPS) policy and
procedure, see Appendix B, when determining whether to deenergize lines because
of a wildfire risk. The written protocol also includes customer notification procedures
and reenergization information. In addition to customer notification from the Utilities
Department, PSPS communication is also coordinated with Palo Alto’s OES. The
decision to institute a PSPS also includes working with CPAU’s water utility staff to
determine if the City should pump water up to the reservoirs located in the Foothills
area in advance of shutting off power, to ensure there is sufficient water and water
pressure for any firefighting activities.
• Coordination with PG&E. As a transmission-dependent utility, CPAU seeks
collaboration with PG&E regarding their potential deenergization events that may
impact the City’s service territory.
• Studying device coordination strategies. Staff have engaged in protective device
coordination studies to ensure that any fault is isolated quickly and any impact
limited. Based on these studies, CPAU changed the fuse type and size, as noted above,
on Foothills area distribution lines and changed settings on protective devices
identified above.
D. Enterprise-Wide Safety Risks
Palo Alto’s protocol for identifying and addressing enterprise-wide safety risks is a
collaborative effort with various City departments. Together the goal is to prevent, protect
from, mitigate, respond to, and recover from a broad range of potential hazards and threats.
The City’s OES leads that coordination with the goal of developing, maintaining, and
sustaining a citywide, comprehensive, all hazard, risk-based emergency management
program that engages the whole community. This community driven hazard and risk
process leads to a range of plans, programs, projects, and other preparations to reduce risks
from the hazards of highest concern. The City maintains and updates the following
assessment and plans that provide information regarding the risks in Palo Alto and the
necessary actions to take.
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- Threat and Hazard Identification and Risk Assessment 7 - The result of the THIRA
process is an organized evaluation of vulnerability and implementation measures
based on the necessary capabilities to deal with the natural and non- natural hazards
and threats of most concern.
- Santa Clara County Multi-jurisdictional Hazard Mitigation Plan 8 - Identifies and
prioritizes potential and existing hazards across jurisdictional borders, including
hazards that may be further amplified by climate change, and provides mitigation
objectives with prioritized actions.
- Community Wildfire Protection Plan/Foothills Fire Management Plan 9 - Addresses a
broad range of integrated activities and planning documents to address and mitigate
the impacts of fire hazards in the Palo Alto Foothills Area.
E. Current and prior activities
CPAU’s earlier Plans note mitigation tasks the City has already completed, such as preparing
a Foothills Fire Mitigation Plan and acting as “territory lead” for the CPUC’s fire threat map.
Additionally, prior Plans note ongoing efforts, which continue. These include regular
vegetation management, inspection and maintenance of the electric distribution system,
and electric infrastructure designs that consider fire safety. Appendix A shows the status of
CPAU’s mitigation-related activities.
V. MONITORING THE PLAN
A. Measuring Plan and inspection performance
In preparing annual Plans, CPAU takes the opportunity to evaluate the current Plan for any
deficiencies, or if any best practices have changed. In doing so, CPAU considers what, if
anything, related to wildfires occurred in the high fire threat area. Any events related to
wildfires or City electric infrastructure in the Foothills area could inform future Plans and
help understand the effectiveness of the current Plan.
With regard to inspections, CPAU examines its electric infrastructure in the high fire threat
area more frequently than in other areas of the service territory. Staff strive to ensure that
all inspections are completed by June, before the historic start of fire season, or earlier,
7 The current 2017 Threat and Hazard Identification and Risk Assessment can be found at
https://www.cityofpaloalto.org/files/assets/public/v/1/oes/plans/unrestricted_palo_alto_thira_report_final_april-
2017.pdfhttps://www.cityofpaloalto.org/files/assets/public/v/1/oes/plans/unrestricted_palo_alto_thira_report_fi
nal_april-2017.pdf
8 The current 2023 Santa Clara County Multi-jurisdictional Hazard Mitigation Plan, along with the local Palo Alto
Annex, can be found at https://www.paloalto.gov/Departments/Emergency-Services/Plans-and-Information/Local-
Hazard-Mitigation-Plan
9 The City has updated the pre-existing Community Wildfire Protection Plan (CWPP) dated 2017 and the Foothills
Fire Management Plan (FFMP) dated 2016. The 2025 update replaces both pre-exiting plans and now serves as the
current version of the CWPP/FFMP at https://www.paloalto.gov/files/assets/public/v/1/oes/plans/city-of-palo-
alto-cwpp-ffmp-update-final-2025.pdf
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depending on drought conditions. Inspections are completed manually. Staff analyze the
results of the inspections for trends of any failures or maintenance needs, which can inform
future design changes. Staff also monitors the performance of equipment during windy and
severe weather conditions as described in the metrics below.
B. Performance and outcome metrics
CPAU audits the effectiveness of the Plan’s mitigation and prevention efforts by using two
broad metrics: performance and outcomes. Information specific to each are below:
i. Performance metrics
a. Vegetation management. This metric includes the amount of vegetation cleared
or number of trees trimmed in the high fire threat area.
b. Infrastructure maintenance in high fire threat area. This metric includes the
amount of equipment and number of lines inspected and repaired (if needed) in
the high fire threat area.
c. Project status. This metric involves monitoring the progress of any projects related
to mitigating wildfires from electric equipment or lines in the high fire threat area
and ensuring that projects progress on the proper timeline.
ii. Outcome metrics
a. Electric-line ignited wildfire. This metric includes any fire started by CPAU’s electric
equipment in the high fire threat area that traveled greater than one linear meter
from the ignition point. In at least the past 20 years, there have been zero such
fires.
b. Downed lines in the high fire threat area. For purposes of this Plan, a wires-down
event includes any instance where an electric line in the high fire threat area of
the service territory falls to the ground or onto a foreign object. CPAU will not
normalize this metric by excluding unusual events, such as severe storms. Instead,
staff will supplement this metric with a qualitative description of any such unusual
events.
C. Applying previous Plan metrics to this Plan
CPAU’s initial Plan specified two metrics for evaluating performance, each discussed below,
and noting how they have informed this revised Plan:
i. Outages to the overhead lines in the high fire threat area
In the initial 2020 Plan, staff described how CPAU would evaluate an outage in the high
fire threat area. The 2020 Plan also noted a related project in rebuilding the overhead
lines, the status of which is presented in Appendix A. CPAU’s evaluation of any
outages in the high fire threat area described in 2020 remains: Determine if CPAU’s
activities (a) could have prevented any outages, (b) were adequate to prevent an
outage, (c) could be improved, and (d) could not have prevented an outage. Both the
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evaluation and metric remain for this Plan because they properly inform CPAU efforts
in preventing outages. Since January 1, 2020, CPAU has had twelve (13) outages in the
Foothills area. None were a result of a PSPS event or weather-related.
ii. Fire ignitions
An important metric, CPAU stated in the 2020 Plan that staff would provide the
number of fires occurring in the high fire threat area that were less than ten (10) acres
in size, specifically describing any fires larger than ten (10) acres. Since January 1,
2020, CPAU has had zero wildfires in the high fire threat area over ten (10) acres with
no calls to 911 to report of a wildfire of any size.
If CPAU experiences any wildfires in this area, whether ignited by electric
infrastructure or not, CPAU will work with the Fire Department, Office of Emergency
Services, and any related local government agency to review the cause, how or if
CPAU equipment related to the cause or was impacted and collaborate on any after-
action activities.
iii. Wires down
This metric includes instances of any electric lines or conductors that fall to the
ground or come into contact with a foreign object in the high fire threat area. For each
wires-down event, CPAU will utilize an evaluation system similar to CPAU’s outage
evaluation: reviewing the cause, what actions may have prevented the event, and if
there are areas for improvement.
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Appendix A: Summary of Key Wildfire Mitigation Activities
The City’s key mitigation activity is undergrounding overhead electric lines in the Foothills area.
This multi-phase Foothill Fire Mitigation Project includes substructure construction, including the
installation of boxes and pad-mounted equipment, cable pulling and line energization, and
decommissioning of overhead city-owned poles and equipment. This project is expected to be
complete at the end of calendar year 2026.
Figure 4: High Level Map of the Foothill Fire Mitigation Project
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Summary of Key Wildfire Mitigation Activities
Grid Design, Operations
and Maintenance • Foothill Fire Mitigation Project -
undergrounding work out of 7,500 feet, including substructure and cable installation. 1,800 feet remain for
both substructure and cable installation.
• Foothill Fire Mitigation Project -
undergrounding work out of 22,000 feet, including substructure and cable installation. 10,000 feet remain
for both substructure and cable installation.
• Foothill Fire Mitigation Project -
undergrounding work, with all substructure installation finished. 4,200 feet remain for cable installation.
• Fiber Optic Extension - To strengthen communication capabilities in the high fire threat area, the installation
of underground conduit is progressing in phases, in coordination with ongoing electric substructure work,
phase by phase. The City has installed 28,000 feet out of 45,000 feet new fiber optic cables for Phases 1, 2,
3, and 4.
2025 Goals (Prior Year Objectives):
• Complete the Foothill Fire Mitigation Project - undergrounding of approximately 49,200 feet of electric
overhead distribution lines and fiber optic cable.
• Energize the remaining Foothills Fire Mitigation Project Phases 3-5
• Decommission city-owned overhead poles, along with electric and fiber lines and equipment across Phases
1-5.
2025 Accomplishments (Prior Year Overview):
• Foothill Fire Mitigation Project - Construction Phase 3 (of 5 phases): Completed 7,5
undergrounding work out of 7,500 feet, including substructure and cable installation.
• Foothill Fire Mitigation Project -
undergrounding work out of 22,000 feet, including substructure and cable installation. 10,000 feet remain
for both substructure and cable installation.
• Foothill Fire Mitigation Project - Construction Phase 5 (of 5 phases): Completed 4,200 feet of
undergrounding work, including substructure and cable installation.
• Fiber Optic Extension - To strengthen communication capabilities in the high fire threat area, the
installation of underground conduit is progressing in phases, in coordination with ongoing electric
substructure work, phase by phase. The City has installed 35,000 feet out of 45,000 feet new fiber optic
cables for Phases 1, 2, 3, and 4.
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• COMPLETE Substructure Work: 49,200’ feet Completed out of 49,200'
• COMPLETE Cable Installation: 49,200' Wire pulled out of 49,200'
• COMPLETE Energized: 49,200' out of 49,200' of cable (as of August 5, 2026)
• Fiber Installation: 35,000’ out of 45,000’
• Project completion target: December 2026
2026 Goals (Current Year Objectives):
• Complete the removal of the remaining de-energized high voltage overhead conductors and associated
equipment.
• Complete the decommissioning of city-owned overhead poles, along with electric and fiber lines
and equipment across Phases 1-5.
2026-2028 Planned Initiatives (Future Strategies):
• When electric infrastructure replacements are necessary, incorporate fiberglass materials for poles and
crossarms remaining in the high fire threat area to enhance resiliency.
• The City’s multi-year Grid Modernization initiative is focused on strengthening the electric distribution
system to support 100% electrification. This effort will improve grid resiliency and reliability through the
replacement of poles, transformers, aerial wires, select cabinets, and underground infrastructure. It also
includes upgrades to two substations, with completion targeted by 2032, aligning with both near- and long-
term energy goals.
• Evaluate opportunities to incorporate the updated 2025 CAL FIRE- Fire Hazard Severity Zone (FHSZ)
designations into infrastructure planning, emergency outreach protocols, and long-term mitigation efforts
within the Local Responsibility Area (LRA). Any potential projects or enhancements, including those
affecting newly designated Moderate risk zones, will be reviewed and prioritized based on the ability to
mitigate known risks in a cost-effective manner.
• Continue undergrounding the remaining overhead service laterals in the Foothills area to reduce the
and Inspections • Electric General Order 165 Inspections in the high fire threat area:
o Completed 100% of annual inspections
o Up to date with all intrusive pole inspections
• Vegetation Management in the high fire threat area:
o Completed 100% of vegetation inspections
332 trees trimmed
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•Continue to complete all required annual electric infrastructure inspections.
•Complete a
vegetation contact with electrical infrastructure.
•PWD staff is actively working to update the Draft Tree Landscape Technical Manual (TLTM) and also plan to
establish a tree and landscape line clearing policy, similar to the current utility line clearing policy.
2025 Accomplishments (Prior Year Overview):
•Electric General Order 165 Inspections in the high fire threat area:
o Completed 100% of annual inspections
o Up to date with all intrusive pole inspections
•Vegetation Management in the high fire threat area:
o Completed 100% of vegetation inspections
o Completed vegetation maintenance by trimming 7 trees and clearing 20 brush units.
•The City's draft Tree and Landscape Technical Manual (TLTM) was posted online for public comment from
December 2, 2024, through March 3, 2025.
2026 Goals (Current Year Objectives):
•Continue to complete all required annual electric infrastructure inspections.
•Complete annual vegetation maintenance, inspection and clearances from electrical lines to avoid
vegetation contact with electrical infrastructure.
•Develop vegetation management plan for underground and pad-mounted equipment.
2026-2028 Planned Initiatives (Future Strategies):
•The City has previously evaluated the use of drones for vegetation management and electric infrastructure
inspections. While privacy concerns, public feedback, and local regulations have posed challenges to
implementation, the City remains interested in exploring this technology for potential future use.
•PWD staff will incorporate the Public Tree Management Plan into the next update of the Urban Forest
Master Plan. Rather than developing it as a standalone document, its objectives and recommendations
will be addressed as part of the Urban Forest Master Plan update.
•Following completion of the Foothills Undergrounding Project, transition wildfire mitigation efforts from
overhead electric distribution facilities to underground utility infrastructure, including associated above
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Situational Awareness and
Forecasting
• Monitored weather conditions daily during Red Flag Warning (RFW) periods to assess wildfire risks and
maintain situational awareness. Prepared staff for potential PSPS events by briefing them on response
protocols and collaborating with the communications team for effective coordination.
• The City partnered with Stanford and Town of Woodside to install fifty (50) N5 Sensors, advanced gas
monitors for early wildfire detection. Of these, Stanford installed twenty-five (25), Palo Alto installed twelve
(12), and Woodside installed thirteen (13). While coverage in the Foothills is not complete, these sensors
have been strategically placed in the high fire threat area to enhance early warning capabilities.
2025 Goals (Prior Year Objectives):
• Continue to enhance our OMS and update our GIS data to help with locating outages and decrease response
time.
2025 Accomplishments (Prior Year Overview):
• CPAU staff updated its membership with the Electricity Information Sharing and Analysis Center (E-ISAC)
to ensure continued receipt of timely operational, physical security, cybersecurity, wildfire, and severe
weather alerts and advisories, enhancing situational awareness and supporting informed operational
decision-making.
2026 Goals (Current Year Objectives):
• Continue to enhance our OMS and update our GIS data to help with locating outages and decrease response
time.
• Leverage the new fiber infrastructure to enhance wildfire monitoring capabilities by improving
communications, data transmission, and reliability for the AlertCalifornia Wildfire Camera, CPAU's
weather station, and future wildfire monitoring technologies.
2026-2028 Planned Initiatives (Future Strategies):
• As part of the Electric Grid Modernization effort, CPAU is in the early planning stages to implement an
Advanced Distribution Management System (ADMS). The ADMS will integrate various functionalities such
as the OMS, Distributed Energy Resource Management (DERM), and real-time monitoring to enhance grid
reliability, efficiency, and resilience. The new system will help manage issues like severe weather, the
• As part of the City's ongoing commitment to wildfire preparedness, the City engaged independent auditor
BakerTilly to conduct the Emergency Preparedness Wildfire Audit in 2024. The audit evaluated current
efforts and provided recommendations to strengthen evacuation planning and wildfire mitigation to
enhance local wildfire resilience.
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• A tabletop exercise for wildfire mitigation: Conduct a comprehensive tabletop exercise to assess and
improve the City’s response plans for wildfire events. This exercise will simulate wildfire scenarios, engage
key stakeholders, and identify potential gaps in communication, coordination, and resource management
to strengthen preparedness and response strategies.
• City staff is in the process of updating two existing plans, the OES Emergency Operations Plan (EOP) and the
Foothills Fire Management Plan (FFMP), part of Annex 3 of the Santa Clara County Community Wildfire
Protection Plan, to improve coordination of emergency response and wildfire prevention efforts.
2025 Accomplishments (Prior Year Overview):
• The Water Utility led a wildfire mitigation tabletop exercise on June 25, 2025. The exercise included
participation from the Water, Gas, Wastewater, and Electric Operations and Engineering teams, the Utility
Control Center, the City's Office of Emergency Services (OES), and the Fire Department. The exercise
simulated wildfire response scenarios to strengthen coordination, communication, and preparedness
across participating departments.
• CPAU staff participated in PG&E's wildfire tabletop exercise on 4/30/2026 to strengthen emergency
preparedness and interagency coordination. The exercise enhanced CPAU's understanding of wildfire
response protocols, communication processes, and utility coordination during a wildfire event.
• The City updated its emergency planning documents to strengthen emergency preparedness, wildfire
prevention, and coordinated response efforts. The Emergency Operations Plan (EOP) was updated in
March 2025 and outlines how the City and its partners coordinate preparedness for, response to, and
recovery from major emergencies and disasters. The City also updated the Community Wildfire Protection
Plan (CWPP) (2017) and Foothills Fire Management Plan (FFMP) (2016). The new April 2025 CWPP/FFMP
replaces both plans and now serves as the City's current CWPP/FFMP and Annex 3 of the Santa Clara
County Community Wildfire Protection Plan. These updates improve emergency management and
wildfire preparedness. Consistent with the Healthy Forest Restoration Act of 2003.
2026 Goals (Current Year Objectives):
• Continue coordinating wildfire preparedness messaging and community outreach efforts with City
departments and stakeholders to provide consistent public communication regarding wildfire
preparedness, mitigation activities, and emergency response.
2026-2028 Planned Initiatives (Future Strategy):
• Continued participation in tabletop exercise for wildfire mitigation. This exercise aims to improve internal
awareness, validate updated plans mentioned above, build collaboration with our public safety staff, and
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2.Notification and response
Community Outreach and
Engagement •Updated the "Utilities Wildfire Mitigation Response and Communications Procedure for Public Safety
Power Shutoff (PSPS)," enhancing coordination with city departments and improving communication with
the community, impacted customers, and media outlets. Enhanced customer communication functions
through modifications to the OMS for recorded messages, outbound SMS text notifications, and phone
calls.
2025 Goals (Prior Year Objectives):
•Continue to refine best practices to disseminate information across the City’s website and other
communication channels so customers can easily find information and updates on PSPS, specifically
during and post event(s).
2025 Accomplishments (Prior Year Overview)
• Delivered print and digital correspondence to customers in the Foothills area with information on PSPS
protocols, reminder to update contact information for notifications via OMS, and encouragement to sign
up for emergency notification platforms such as AlertSCC.
2026 Goals (Current Year Objectives):
•Continue coordinating wildfire preparedness messaging and community outreach efforts with City
departments and stakeholders to provide consistent public communication regarding wildfire
preparedness, mitigation activities, and emergency response.
2026-2028 Planned Initiatives (Future Strategy):
•Continue to educate customers about PSPS, including increased risks of wildfire due to climate change.
Inform customers about CPAU’s efforts to mitigate risks such as through utilities undergrounding, system
monitoring, and other improvements. Ensure all customers in high fire threat areas are well-informed
about how to take steps to prevent wildfire (in coordination with the Fire Department), how to prepare
for emergencies and what to do during PSPS, and what to expect from CPAU in terms of communication
and response.
•Review the PSPS Policy and Process and the Utilities Wildfire Mitigation Response and Communications
Procedure and update them as appropriate to reflect the completion of the Foothills Undergrounding
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Appendix B: PSPS Policy and Process for Public Safety Power Shutoff
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Appendix C: Utilities Wildfire Mitigation Utilities Response and Communications
Procedure for Public Safety Power Shutoff (PSPS)
Policy
The City has established a Public Safety Power Shutoff (PSPS) Policy which defines the conditions for a
Public Safety Power Shutoff (PSPS) and establishes general procedures.
Public Safety Power Shutoff (PSPS)
High winds can cause trees and debris to contact energized electric power lines, damage equipment,
and potentially lead to wildfire ignition. Utilities may temporarily turn off power to specific areas to
reduce the risk of fires caused by electric infrastructure. This temporary outage is called a Public Safety
Power Shutoff (PSPS). The City of Palo Alto Utilities (CPAU) prepares for a PSPS when severe weather
may create the risk for wildfire.
Criteria for PSPS
CPAU aligns PSPS criteria with Pacific Gas and Electric (PG&E), the primary electricity provider for the
region where Palo Alto is located. Conditions for a PSPS are:
• Red Flag Warning issued by the National Weather Service;
• Low humidity levels less than 30%;
• Forecasted high winds above 19 miles per hour and gusts above 25-40 miles per hour.
High Fire Threat Areas
The California Public Utilities Commission (CPUC) has sorted regions according to their wildfire risk.
Homes and businesses in Tiers 2 and 3 wildfire risk areas are more likely to experience a PSPS.
• Tier 2: An area where there is an elevated risk of wildfire.
• Tier 3: An area where there is an extreme risk of wildfire.
View the CPUC map and information on fire-threat areas 10.
The electric lines most likely to be considered for PSPS are lines in Palo Alto west of Highway 280 which
are in a Tier 2 (elevated risk for wildfire) area on the CPUC Fire Threat Map. Palo Alto could also be
impacted by PSPS activities initiated by PG&E on the transmission system.
Purpose and Scope of the Utilities Wildfire Response and Communications Procedure
This document provides details on responsibilities and instructions for the implementation of a PSPS.
10 CPUC map and information on fire-threat areas https://www.cpuc.ca.gov/industries-and-topics/wildfires/fire-
threat-maps-and-fire-safety-rulemaking
Title:
Utilities Wildfire Mitigation
Response and Communications Procedure for Public Safety
Power Shutoff (PSPS)
Document Date:
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The purpose of this procedure is to establish a process, assign responsibilities, and define a
communication plan for the discontinuation of electrical service to high fire threat areas in Palo Alto to
prevent potential wildfires ignited by electrical power lines and equipment.
Pertinent documents including contact information for staff in critical responder roles and backup
support, messaging templates, customer list, and more, are maintained by the CPAU.
Procedure
A.Monitoring for a PSPS
Utilities System Operators are responsible for monitoring the weather forecast for Red Flag Warnings
issued by the National Weather Service (NWS) for the Santa Cruz Mountains. NWS will often forecast
Red Flag Warnings up to five day forecast. The operator will note the date of the Red Flag Warning in
the daily log and will inform their Supervisor (or designee) of the conditions.
The Supervisor of the Utilities System Operators (or designee) will become the Incident Commander for
PSPS. The Incident Commander is responsible for managing the dissemination of information and
executing the PSPS procedure upon approval from the Utilities Director.
In coordination with the Utilities Director, the Incident Commander will specify the anticipated
timeframe for a potential PSPS and notify City staff listed in the Notification Section of PSPS conditions.
B.Declaring a PSPS
The Utilities Director (or designee) is responsible for declaring a PSPS event and directing the Incident
Commander to initiate a PSPS event. The Incident Commander will notify City staff listed in the
Notification Section of this PSPS protocol that a PSPS event has been initiated and provide the following
information:
•State that a PSPS event has been declared.
•The approximate timeframe of the event.
•The affected areas.
CPAU has aligned the PSPS criteria with PG&E. The latest 2024 PSPS guide is as follows:
•Red Flag Warning issued by the National Weather Service;
•Low humidity levels, generally 30% and below;
•Forecasted high winds above 19 miles per hour and gusts above 25-40 miles per hour.
C.Preparation for a PSPS
The Incident Commander (or designee) will be responsible for the following:
•Instruct the Electric Operations Manager to prepare personnel for the power shutoff and
restoration process.
•Instruct the Water-Gas-Wastewater (WGW) Manager to prepare personnel and Water and
Wastewater facilities in the high-fire threat area for an electrical shutdown.
•Inform City staff enrolled in the outage communications chain (“top 20 list”) via text message
thread.
•Instruct the Utilities Communications Manager and the Utilities Customer Service Manager to
initiate notifications to affected customers, the Customer Service Call Center, Utility Program
Services, as well as other City staff in public-facing customer roles.
•Provide updates about PSPS conditions at mutually agreeable regular intervals to the Utilities
Communications Manager and the Utilities Customer Service Manager so staff in public-facing
customer roles will be able to edit scripted messages and address customer inquiries across
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communication platforms (website, email, text, call center recordings, social media).
The Utilities Customer Service Manager (or designee) is responsible for the following:
• Maintain and provide contact information for customers in the high-fire threat area. This list
will be used to contact customers before, during, and after PSPS events. This list will be
updated as follows:
o In May or leading into fire weather season, and/or;
o When the Utilities Customer Service Manager indicates changes to the customer list
maintained on the PSPS/Outage internal SharePoint site.
• Prepare Customer Service Representatives for calls and customer inquiries related to PSPS.
• Activate recorded messages for the Customer Service Call Center Automatic Call Distribution
(ACD) for customers to hear information about a PSPS when calling (650) 329-2161.
• Relay updates from Electrical Operations on PSPS conditions to the Customer Service call
center staff and direct appropriate updates to Customer Service communication platforms
to address customer inquiries.
The Utilities Communications Manager (or designee) is responsible for the following:
• Prepare and get approval from the Utilities Director (or designee) for scripts to be used for
customer notifications.
• Maintain template messaging that will be used in notifications to customers about PSPS.
• Inform the Utility Program Services Manager about PSPS to inform key account and business
customers in affected areas.
• Ensure that the appropriate staff, including Utilities Customer Service Representatives, Utilities
Key Account Representatives, and Utilities System Operators have access to these protocols for
PSPS communication and customer notifications.
• Initiate customer notifications before, during, and after a PSPS.
• Update status of PSPS conditions via website, social media, and other communication platforms.
D. Monitoring Weather Condition Forecasts
The Utilities Incident Commander is responsible for monitoring the weather forecasts and informing the
Utilities Director of conditions, including establishing a recommended start time and duration for a PSPS
event. Once the Utilities Director has declared a PSPS and established a timeframe in coordination with
the Incident Commander, the Incident Commander will notify all City staff listed in the Notification
Section of this PSPS protocol.
The Incident Commander will contact the Utilities Communications Manager and Utilities Customer
Service Manager to initiate the approved Second Tier Message. That message will be sent to customers
who will be impacted by the PSPS and provide an estimate of the time of the PSPS. (See example in the
Messaging Section).
E. Power Shutoff
The Utilities System Operators will monitor wind conditions and the status of the Red Flag Warning after
the PSPS event has been declared and provide updates to the Utilities Director and Incident
Commander. Operators will record wind conditions in the Dispatch Log every 30 minutes.
The Utilities Director (or designee) is responsible for declaring a PSPS. Upon approval from the Utilities
Director, the Utilities System Operators will initiate a power shutoff if the following conditions are met:
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• Red Flag Warning issued by the National Weather Service;
• Low humidity levels less than 30%;
• Forecasted high winds above 19 miles per hour and gusts above 25-40 miles per hour.
The Utilities System Operators will inform the Incident Commander that the power shutoff is being
initiated. The Incident Commander will notify City staff in the Notification Section of this PSPS protocol
that the power is being shutoff.
The Utilities System Operators are responsible for the following:
• Notify the Incident Commander when conditions meet PSPS criteria.
• Initiate PSPS following direction from the Incident Commander and inform the Incident
Commander when power is shutoff.
• Document the time the PSPS occurs and confirm the area of impact and number of customers
affected.
• Open the switch that terminates power to the affected areas.
• Update the Outage Management System (OMS) outage map, customer SMS text notification,
voicemail recording for the Utilities Control Center, and email and/or phone call notifications – if
the latter is determined by the Incident Commander to be required - with PSPS information.
F. Ending PSPS Event
The Utilities System Operators will continue to monitor weather conditions and will inform the Incident
Commander when the wind speeds have decreased, or the Red Flag Warning has been called off. The
Incident Commander will inform the Utilities Director of the conditions. The Utilities Director will make
the determination that the PSPS event has ended and inform the Incident Commander. The Incident
Commander will inform City staff in the Notification Section that the PSPS declaration is over and when
restoration is complete.
G. Restoration of Power
The Incident Commander will direct the Utilities System Operators to begin the process of restoration.
The Utilities System Operators will call out line personnel for line patrol inspections. All line patrol
inspections will be conducted during daylight hours to ensure the lines are in working order. Any
damage will be assessed, and any necessary repairs must be complete before power can be restored to
those sections or anything downstream. Overhead lines will be restored after line patrol inspections are
complete.
Power restoration will occur in phases starting at the open switch near Junipero Serra Boulevard. Line
configuration at the time of reclosing will determine the sequence of restoration. Utilities System
Operators will coordinate the sequence of power restoration under guidance of the Incident
Commander.
The Incident Commander will inform the Utilities Communications Manager and Customer Service
Manager that power has been restored.
The Utilities Communications Manager and Customer Service Manager (or designees) will notify
affected customers that their power has been restored.
H. Coordination with Departments Outside of Utilities
The Utilities Director (or designee) will be responsible for communicating activities outside of the
Utilities Department and is the main channel of communication for the Incident Commander.
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The Office of Emergency Services will be responsible for the following:
• Assist the inter-departmental coordination efforts resulting from a PSPS incident.
• Assist with external communications as needed.
• Assist with the coordination of external entities and agencies required by the incident.
City Staff Notification List
Those on the CPA Top 20 Internal Emergency Alerts Text Group include:
City Manager
Assistant City Manager
Utilities Director
Utilities Chief Operating Officer
Utilities Communications Manager
Utilities Customer Service Manager
Assistant Director of Electric & Fiber Utilities
Utilities Electric Operations Manager
Utilities Electric Operations Supervisors
Chief Communications Officer
Office of Emergency Services Director
Office of Emergency Services Coordinator
Fire Chief
Police Captain
Information Technology Director
Utilities Strategic Business Manager
Utilities Communication Projects Coordinator
Also inform:
Public Works Director
Assistant Director of Customer Services
Assistant Director of Water-Gas-Wastewater Utilities
Manager of Water-Gas-Wastewater Operations
Urban Forester
I. Utilities Communication Plan
The Utilities Communications Manager (or designee) will send out First Tier messages warning
customers that a PSPS is possible, Second Tier messages informing customers that power will be shut off
for PSPS, and eventually messaging about power restoration following the end to a PSPS event:
• First Tier Message - CPAU is monitoring conditions for a potential PSPS.
• Second Tier Message – CPAU expects a PSPS.
• Third Tier Message – PSPS initiated.
Customer Notification Steps:
1) The Utilities Communications Manager will coordinate with the Utilities Director (or designee)
on status of potential PSPS and customer notifications.
2) The Utilities Communications Manager will coordinate with staff in Electric Operations to
update and activate OMS voicemail recording on the Utilities Control Center phone line and
OMS SMS text messaging for customers in the affected areas.
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3) The Utilities Communications Manager will coordinate with the Customer Service Manager to
call customers without mobile phones in the affected areas and update outgoing messages in
the Utilities Customer Service Call Center to alert customers about a PSPS event.
The following communication platforms will have coordinated messages:
• OMS - Outage Management System voicemail recording and SMS text
• Website
• Emails to affected customers
• ACD – Automatic Call Distribution recording on Utilities Customer Service Call Center line at
(650) 329-2161
• Social media – X (formerly Twitter) and Facebook – if deemed appropriate by the Utilities
Director and Utilities Communications Manager.
Template Messaging
First Tier (Monitoring for a potential PSPS)
1) OMS Text (SMS)
Red Flag Warning in effect from Date and Time through Date and Time. CPAU is monitoring conditions in
the Foothills for possible power shutoffs. More info at paloalto.gov/utilities
2) Outlook Email
a. (Use either Utilities Customer Service or Utilities Communications email address)
Subject Line: Potential Public Safety Power Shutoff (PSPS) for the Palo Alto Foothills
The National Weather Service issued a Red Flag Warning for parts of the Bay Area due to dry and windy
conditions from Date and Time through Date and Time. The City of Palo Alto Utilities is monitoring
conditions to determine if a Public Safety Power Shutoff (PSPS) will be required to reduce the potential
for wildfire in the Foothills area of Palo Alto. We do not expect that the remainder of the City’s
businesses and residences will be impacted by a power shutoff. Do not call 9-1-1 if your power is out
unless there is a threat to life safety. View the power outage map at www.paloalto.gov/outagemap
3) Website
Potential Public Safety Power Shutoff (PSPS)
Red Flag Warning: Date
The National Weather Service (NWS) issued a Red Flag Warning for parts of the Bay Area due to dry and
windy conditions that pose a risk of wildfires spreading quickly. The Red Flag Warning is in effect Date(s)
and time.
Status: Monitoring Conditions
Due to current weather conditions, the City is monitoring winds to determine if a Public Safety Power
Shutoff (PSPS) will be required to reduce wildfire potential. Electric lines most likely to be considered for
a PSPS event are those in the Palo Alto Foothills west of Highway 280. We do not expect that the
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remainder of the City’s businesses and residences will be impacted by a power shutoff.
Do not call 9-1-1 if your power is out unless there is a threat to life safety. View the power outage map
at www.paloalto.gov/outagemap
This page will be updated as conditions evolve and new information becomes available.
Learn more about preparing for power outages at www.paloalto.gov/PSPS
Information for Palo Alto PG&E Customers
There are a few Palo Alto residents in the Palo Alto Foothill served by PG&E who may be impacted by a
shutoff from PG&E. If you are a Palo Alto resident served by PG&E, visit their website for information on
their Public Safety Power Shutoff plans.
Second Tier (CPAU expects a PSPS)
1) OMS SMS Text
Red Flag Warning in effect from Date and Time through Date and Time. CPAU is monitoring conditions in
the Foothills for possible power shutoffs. View power outage map at www.paloalto.gov/outagemap
2) Outlook Email
a. (Use either Utilities Customer Service or Utilities Communications email address)
Subject Line: Public Safety Power Shutoff (PSPS) May Occur
The National Weather Service (NWS) issued a Red Flag Warning for parts of the Bay Area due to dry and
windy conditions that pose a risk of wildfires spreading quickly. The Red Flag Warning is in effect from
Date and Time through Date and Time.
Due to current weather conditions, the City of Palo Alto Utilities is monitoring conditions to determine if
a Public Safety Power Shutoff (PSPS) will be required to reduce the potential for wildfire in the Foothills.
Our records show that you are in an area that may require a power shut off for safety precautions. We
will do our best to inform you as conditions evolve and new information becomes available.
View Palo Alto PSPS updates at www.paloalto.gov/utilities (insert link to specific news item if available).
View the power outage map at www.paloalto.gov/outagemap
Read more about PSPS at www.paloalto.gov/psps
Additional Resources
Ensure we have your current mobile number to be notified of outages and updates through the City’s
Outage Management System. Log in to MyCPAU at www.paloalto.gov/mycpau or contact Utilities
Customer Service at (650) 329-2161 to update your contact information.
Do not call 9-1-1 unless you are experiencing a life-threatening emergency. For non-emergency public
safety issues, call (650) 329-2413.
Information for PG&E Customers
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In response to the current forecast, PG&E is also monitoring conditions for their electric utility
customers. There are a few Palo Alto residents in the Palo Alto area west of highway 280 served by
PG&E who may be impacted by a shutoff from PG&E. These customers should contact PG&E for
information on their Public Safety Power Shutoff plans. Visit https://pgealerts.alerts.pge.com/psps-
updates/
Outage Preparations
You may want to consider the following steps to be prepared for a power outage:
• Utilize an emergency supply kit with enough water, food, medicine, batteries and flashlights to
last several days.
• Consult with your medical professional regarding medical treatment, backup generators, or
other power supplies for medical or other needs.
• Have your vehicle gas tank filled or electric battery charged and cash on hand (as electronic
transaction devices and ATM machines may be without power).
3) ACD Recording on Customer Service Call Center Phone Line
The National Weather Service issued a Red Flag Warning for parts of the Bay Area due to dry and windy
conditions from Date and Time through Date and Time. The City of Palo Alto Utilities is monitoring wind
conditions to determine if a Public Safety Power Shutoff (PSPS) will be required to reduce the potential
for wildfire in the Foothills area of Palo Alto. We do not expect that the remainder of the City’s
businesses and residences will be impacted by a power shutoff. Please do not call 9-1-1 if your power is
out unless there is also a threat to life safety. View the power outage map at
www.paloalto.gov/outagemap
4) Website
Potential Public Safety Power Shutoff (PSPS)
Red Flag Warning: Date
The National Weather Service (NWS) issued a Red Flag Warning for parts of the Bay Area due to dry and
windy conditions that pose a risk of wildfires spreading quickly. The Red Flag Warning is in effect Date(s)
and time.
Status: Monitoring Conditions
Due to current weather conditions, the City is monitoring winds to determine if a Public Safety Power
Shutoff (PSPS) will be required to reduce wildfire potential. Electric lines most likely to be considered for
a PSPS event are those in the Palo Alto Foothills west of Highway 280. We do not expect that the
remainder of the City’s businesses and residences will be impacted by a power shutoff.
Do not call 9-1-1 if your power is out unless there is a threat to life safety. View the power outage map
at www.paloalto.gov/outagemap
This page will be updated as conditions evolve and new information becomes available.
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Learn more about preparing for power outages at www.paloalto.gov/PSPS
Information for Palo Alto PG&E Customers
There are a few Palo Alto residents in the Palo Alto Foothill served by PG&E who may be impacted by a
shutoff from PG&E. If you are a Palo Alto resident served by PG&E, visit their website for information on
their Public Safety Power Shutoff plans.
Messaging – Third Tier (PSPS initiated)
1) OMS Text (SMS)
Public Safety Power Shutoff necessary. View power outage map at www.paloalto.gov/outagemap
2) OMS Voice Recording for incoming calls to UCC
Public Safety Power Shutoff for customers in the Foothills. Due to anticipated fire weather conditions,
the City of Palo Alto Utilities shut off power to reduce the potential for a wildfire. We do not expect that
the remainder of the City’s businesses and residences will be impacted by a power shutoff. View the
power outage map at www.paloalto.gov/outagemap
3) ACD Recording on Customer Service Call Center Phone Line
Due to Red Flag Warning conditions from the National Weather Service, the City of Palo Alto Utilities
shut off electricity to customers in the Foothills to prevent the risk for a potential wildfire. We do not
expect that the remainder of the City’s businesses and residences will be impacted by a power shutoff.
Do not call 9-1-1 if your power is out unless there is a threat to life safety. View the power outage map
at www.paloalto.gov/outagemap
4) Outlook Email
a. (Use either Utilities Customer Service or Utilities Communications email address)
Subject Line: Public Safety Power Shutoff (PSPS) for Palo Alto Utilities Customers in the Foothills
Due to anticipated fire weather conditions, the City of Palo Alto Utilities shut off power in the Foothills
to reduce the potential for wildfire. Our records show that you are in this area and may be impacted by
a power shutoff for safety precautions. We do not expect that the remainder of the City’s businesses
and residences will be impacted by a power shutoff.
The City will continue to monitor conditions and do our best to keep you informed as conditions evolve
and new information becomes available.
View Palo Alto PSPS updates at www.paloalto.gov/utilities (insert link to specific news item if available).
View the power outage map at www.paloalto.gov/outagemap
Read more about PSPS at www.paloalto.gov/psps
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The State’s Office of Health & Human Services has set up a non-emergency hotline at 1 (833) 284-3473
to help those who are medically vulnerable.
Dial 9-1-1 in the event of a life-threatening emergency. For non-emergency public safety issues, call
(650) 329-2413. For Public Safety Power Shutoff updates, call Utilities Customer Service at (650) 329-
2161.
The City of Palo Alto also uses AlertSCC to communicate during emergency events such as natural
disasters, crime bulletins, power outages, and more. You can sign up to receive Alert SCC notifications at
https://emergencymanagement.sccgov.org/AlertSCC and follow our Emergency Preparedness page at
www.paloalto.gov/preparedness
5) Website
Due to a Red Flag Warning from the National Weather Service, electricity has been shut off for
customers in high fire threat areas in the Foothills to avoid potential risk of wildfire. We do not expect
that the remainder of the City’s businesses and residences will be impacted by a power shutoff.
View Palo Alto PSPS updates at www.paloalto.gov/utilities (insert link to specific news item if available).
View the power outage map at www.paloalto.gov/outagemap
Read more about PSPS at www.paloalto.gov/psps
At this time, we do not know when power will be restored. Restoration will begin as soon as possible
after conditions clear. Prior to energizing power again, Utilities must patrol the lines during daylight
hours for safety precautions. This may take multiple hours or days depending upon the conditions.
The State’s Office of Health & Human Services has set up a non-emergency hotline at 1 (833) 284-3473
to help those who are medically vulnerable.
Dial 9-1-1 in the event of a life-threatening emergency. For non-emergency public safety issues, call
(650) 329-2413. For Public Safety Power Shutoff updates, call Utilities Customer Service at (650) 329-
2161.
6) Social media (Upload image if possible and tag @cityofpaloalto and @paloaltopolice in social
media posts)
Power has been shut off for customers in the Foothills to prevent risk of wildfire. CPAU must patrol lines
during daylight hours for safety before reenergizing. This could take hours to days, depending upon the
conditions. View the power outage map at www.paloalto.gov/outagemap
or call 650-496-6914 for other electrical emergencies.
Messaging - Restoration
1) ACD Message, Email, and Website
The City of Palo Alto Utilities has restored power to customers in the Foothills following a Public Safety
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Power Shutoff to prevent the risk of wildfire. If your power was shut off during this period and you still
do not have power, please contact us at (650) 496-6914 to report a continuing outage.
2) Social Media (only if deemed necessary by the Utilities Director and Utilities Communications
Manager)
POWER OUTAGE UPDATE: CPAU restored power to the Foothills as the Red Flag Warning has been
lifted. Call 650-496-6914 to report a continuing outage and/or power issue. Thank you for your patience
as we work to ensure the safety of all in our community. www.paloalto.gov/utilities
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Appendix D: Plan Revision Log of Key Changes
Plan Revision Log of Key Changes
Date Plan Section/Location Description
9/2/26 Section IV Monitoring the Plan
C. Applying previous Plan metrics to this
Plan, ii Fire ignitions
Section D. Community Wildfire Protection
Plan/Foothills Fire Management Plan
Appendix A – Wildfire Mitigation Activities
•Updated Section D with new document title and updated footnote and link.
•Updated Appendix A – Wildfire Mitigation Activities to correct trees trimmed in
2024 within the Tier 2 zone and provided accomplishments for 2025, goals for
2026, and 2026-2027 future initiatives.
•Updated ii Fire ignitions verbiage to be more generic, still use the previous
metrics.
•General editorial improvements for clarity and consistency.
6/4/25 Section III Roles and Responsibilities -
Sections
A.City of Palo Alto Utilities Department
C.Deenergization-related communication
(including revised Appendix C)
Section IV Monitoring the Plan
C. Applying previous Plan metrics to this
Plan
Appendix A – Wildfire Mitigation Activities
Added Appendix D – Plan Revision Log of
Annual Update, Plan will be dated June 4, 2025 upon UAC adoption.
•Updated organizational chart to reflect current structure.
•Updated outage metric since 2020 from ten (10) to twelve (12).
•Revised Appendix A using a hybrid format based on the recommended WSAB
template to summarize mitigation activities such as project progress.
•Added Appendix D: Plan Revision Log of Key Changes to formally track Plan
changes, included high level of past updates/changes.
•Updated sections related to deenergization to align with the latest PSPS
communication protocols.
•General editorial improvements for clarity and consistency and including listing
out Appendices and Table of Figures.
(HFTD) Map
Appendix A – Wildfire Mitigation Activities
•Updated Appendix A, minor changes were made to reflect current status of
wildfire mitigation activities and project status.
•Initiated a review and update of the Utilities Wildfire Mitigation Response and
Communications Procedure for Public Safety Power Shutoff (PSPS) to enhance
community readiness. This included incorporating Outage Management System
(OMS) features to support outbound communications during potential PSPS
11 Staff Report ID 2404-2905 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=15094
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•
•
•Comprehensive revision of the Plan was completed to determine its efficacy,
legal compliance, and provide suggestions for improvement. The
comprehensive review was completed by an Independent Evaluator (IE) Dudek.
•
Date Plan Section/Location Description
Context Table
Cross Reference Table
Appendix G - Utilities Wildfire Mitigation
Response and Communications Procedure
for Public Safety Power Shutoff (PSPS)
Appendix E- Status of Proposed Activities
•Submitted redlined Plan document as part of the WSAB’s request and;
o Updated Plan placement on the Utilities website for easier navigation.
o Included the WSAB’s Context Table.
o Included Dates of past years’ public presentations.
o Added more context to community outreach efforts during a fire
o Added Appendix G Utilities Wildfire Mitigation Response and
Communications Procedure for Public Safety Power Shutoff (PSPS).
o Updates made to the status of reported projects, including: the
installation of a weather station, progress on undergrounding lines,
assessments for emergency back-up generators, etc. (Appendix E).
o
to Reduce Risk of Wildfire or Improve •The primary revision focused on updating the status of proposed wildfire
15
12 Staff Report ID 2301-0900 https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=11331
13 Staff Report ID 14175 https://www.cityofpaloalto.org/files/assets/public/v/2/agendas-minutes-reports/agendas-minutes/utilities-advisory-commission/archived-
agenda-and-minutes/agendas-and-minutes-2022/06-08-2022/06-08-2022-id-14175-item-3-wildfire.pdf
14 Staff Report ID 12190 https://www.cityofpaloalto.org/files/assets/public/v/2/utilities/id-12190-item-2.pdf
15 Staff Report ID 10670 https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager-reports-cmrs/year-archive/2020/id-
10670-mini-packet-01212020.pdf?t=53268.17%20
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Date: September 2, 2026
12-MONTH ROLLING CALENDAR
FORECAST
*Numbers at the end of titles correspond with Workplan line
City Council
CCM – City Council Meeting
2026
September 2, 2026
•Commission Norms
•Commissioners Memo
•Utilities Reserve Management Policies (#4)
•Electric Long Duration Resiliency (#2)
•
•
•CAD Master Amendment #2
•A3 Contract for Sewer Lateral Replacement Project
•City of Palo Alto Utilities Electric Utility Physical Security Plan
Update
•
2026
October 7, 2026
•Bond Financing for Grid Modernization Project
•Rates, Reservation Fees, Contracts, Policies, and
Development Requirements for Data Centers
(#7 & #15)
•Time of Use Update (#8)
•Palo Alto Low Carbon Fuel Standards Program
Update (#10)
•Informational Report - Dahl and Park Storage
•
•Approval of UAC Workplan - Oct. 5th
•Veolia Contract for Efficiency and Electrification Program
•Accent Gold Contract for Customer Program Management
•Woodard and Curran Contract for Hydraulic Modeling Support
•Muni Code Change to Allow Power Purchasing Agreements
Unsolicited Negotiations
•Recommend Approval of Bond Financing for Grid
Modernization Project (FCM)
2026
November 4, 2026
•FY 2028 Preliminary Rates (#3)
•Fiber Expansion and Fiber to the Premises
(FTTP) Update (#6)
•Water COSA Guidelines
•Utilities Legislative & Regulatory Updates (#11)
•Discussion on Utilities Quarterly Report FY26 –
•
•Purchase Fiber Cables for Fiber Backbone Rebuild
•Transmission Agency of Northern California Contract
Modifications
•Fiber Expansion and FTTP Update (FCM)
November 9, 2026 or November 16, 2026
•Joint Session with City Council and BAWSCA on Water Demand Forecast (#13)
December
2026
December 2, 2026
•S/CAP Funding and Revised Carbon Neutral and
C&I Use (#10)
•Study Results from CASC and UAC Joint Meeting
(#10)
•Informational Report - Annual Review of the
City’s Renewable Procurement Plan, Renewable
Portfolio Standard Compliance, and Carbon
Neutral Electric Supplies for 2025 (#9)
•
•Approval of the City of Palo Alto’s Updated 2027 Water, Gas,
and Wastewater Utility Standards
•Approval of Bond Financing for Grid Modernization Project
•Utilities Reserve Management Policies (FCM)
•Informational Report on FY 2026 Cap and Trade Program
•Informational Report on the Annual Review of the City’s
Renewable Procurement Plan, Renewable Portfolio Standard
2027
January 6, 2027
•5 Year Capital Improvement Project (Includes
Treatment Plant) (#5)
•Utility Legislative Guidelines (#11)
•Gas Transition Study (#1)
•Fiber Expansion and FTTP Update (#6)
•Informational Report – Utilities Quarterly
•
2027
February 3, 2027
•Electric Utility Business Strategy (#15)
•Interim update on Electric Supply Costs
(3/02/26 Council Action minutes) (#9)
•Business and Key Account Customer
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March
2027
March 3, 2027
• FY2028 Water Rates and 5 Year Forecasts (#3)
• FY2028 Wastewater Rates and 5 Year Forecasts
(#3)
• Informational Report – Utilities Quarterly
•
• FY2028 Wastewater Rates and 5 Year Forecasts (FCM)
April 7, 2027
• FY2028 Electric Rates and 5 Year Forecasts (#3)
• FY2028 Gas Rates and 5 Year Forecasts (#3)
• FY2028 Fiber Rates and 5 Year Forecasts and
•
• FY2028 Gas Rates and 5 Year Forecasts (FCM)
• Interim update on Electric Supply Costs (3/02/26 Council Action
minutes)
•
May 5, 2027
• FY2028 Utilities Operating and CIP Budget
• Election of the UAC Chair and Vice Chair
FY2028 Fiber Rates and 5 Year Forecasts and Next Steps (FCM)
June 2027 June 2, 2027
• UAC Workplan
•
• FY 2028 Utilities Operating and CIP Budget
•
July 7, 2027
• Informational Report – Utilities Quarterly
COUNCIL SUMMER BREAK
August 4, 2027
Council Recap on Utilities Items – August 2026
Approved By Council:
• Adoption of a Resolution Approving a Base Contract for
Sale and Purchase of Natural Gas with JPMorgan Chase
Bank for a Portion of the City’s Natural Gas Requirements
• Approval of Contract with "High Point Power Systems“ for
the repair and refurbishment, and extension of the
critical life of a load tap changer (Adobe Creek
• Adoption of a Resolution to Transact for Electric Supplies to
Meet the City’s Electrical Needs under Electric Master
Agreements
• Approval of Contract No. C27196740 with “Blackhawk Painting
Inc.” for Electric Substations Equipment and Mechanical
Structures Painting Services
Work Plan Items to Be Scheduled Items to Be Scheduled
• Review Load Projections & Grid Upgrades (#14)
• Informational Report - Customer Communications (#12)
• Upcoming Power Purchasing Agreements
One Year look back at DER, Cost Effectiveness (#10)
• LAFCO, Water and Wastewater Review
Link to UAC Workplan Pending Council Approval: https://www.paloalto.gov/files/assets/public/v/1/utilities/utilities-advisory-
commission/uac-approved-fy-2027-utility-advisory-commission-priorities.pdf
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Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: September 2, 2026
Report #: 2606-6492
TITLE
Discussion of Baker Tilly Reserves Advisory Report and Recommendation to the City Council of
Proposed Policy Updates to the Utilities Reserve Management Practices
RECOMMENDATION
Staff recommends that the Utilities Advisory Commission (UAC) recommend the City Council
(via the Finance Committee) adopt the following:
1. Revisions to the Utilities Reserve Management Practices based on staff’s proposed
policies for the reserve targets:
a. Replace the Capital Improvement Program (CIP) Reserve minimum and
maximum guidelines with a reserve target based on the Average Annual CIP
Budget.
b. Add a Rate Stabilization Reserve (RSR) target based on 10% of operating
expenses and define rules for when reserve balance is above or below target;
and
2. Proposed 5-year timeline for achieving revised RSR policy targets; and
3. Proposed timelines for achieving revised CIP Reserve policy targets: 5 years for the Gas
and Water Utilities and 10 years for the Electric Utility; and
4. Proposed FY 2027 workflow for revising and approving the Utilities Reserve
Management Practices.
EXECUTIVE SUMMARY
Staff recommends establishing a RSR target (based on 10% of operating expenses) and a CIP
Reserve target (based on Average Annual CIP Budget). The overall combined impact of staff’s
recommendation adds an estimated 0.3% to 0.5% per year for the Electric, Gas, and Water
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Utility’s rate trajectory forecast, as shown in Table 7.1 Staff’s recommendations balance
affordability with a measured transition to the financial practices described in this report.
2. In March 2026, Baker Tilly Advisory Group, LP (Baker Tilly), in its capacity
serving as the Office of the City Auditor, completed an assessment of the City's utility reserve
policies. This assessment resulted in the Advisory Report, which evaluated the City’s existing
reserve policies and compared them with industry best practices and peer agencies.
BACKGROUND
3, and Policy and Services Committee (P&S) accepted the results on April 14,
20264. Discussion at the P&S meeting centered on developing a plan to steadily and sustainably
increase reserves.
1 Staff’s recommendation assumes a 5-year timeline for achieving revised RSR targets for all utilities; 5-year CIP
Reserve timeline for Gas and Water Utilities; and 10-year CIP Reserve timeline for the Electric Utility.
2 City of Palo Alto Utility Reserves Advisory Report, March 27, 2026:
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=ab3102f7-8c84-4348-a68d-
2e6bee10328c
3 City Council Staff Report #2650-6353, June 8, 2026:
https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=2e6cf5
71-d9f1-4ba5-b71d-a3f042acbefb; and Management Response, April 2, 2026:
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=b4ab74b3-645b-44bb-a72c-
a5ca87b97e0c.
4 Policy and Services Committee Staff Report #2509-5177, April 14, 2026:
https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=64580
a69-262d-4e61-b2a9-3b18cf4eccb6
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The Advisory Report made five key recommendations that relate to the Electric, Gas, Water and
Wastewater Collection Utilities. One additional recommendation addressed outdated policies
and structures of the Wastewater Treatment, Refuse, and Stormwater reserve policies; that
recommendation is being separately addressed by the Public Works Department.
Do not eliminate any of the current reserve funds in place: This recommendation notes
that Palo Alto’s Operations, Rate Stabilization, and Capital Improvement Program (CIP)
Reserves are in line with benchmark communities and that Palo Alto’s separate reserve
funds are in place for specifically defined and valid purposes and should remain in place
until those purposes are accomplished or are no longer applicable. No action needed
Clarify CIP reserve fund language: This recommendation notes that the Electric Special
Project (ESP) Reserve is distinct from the CIP Reserve within the Electric Utility and
recommends clarity on the intended use of funds. An update on the Council-adopted
policy on the use of the ESP Reserve is appropriate. Staff plans to bring forward
proposed revised policy within a year.
Formalize reserve tracking: This recommendation proposes reporting requirements to
the City Council. As noted in the management response, staff provides information
about the reserve balances to the City Council in the Operating Budget, Annual
Comprehensive Financial Report and Utility Financial Forecasts each year, and staff
plans to continue this practice. Staff recommends exception-based reporting added to
the existing quarterly financial report to Council. Staff is in the process of implementing
this recommendation by the end of 2026. Staff plans to include this reporting in the
Utilities quarterly report that will be provided to the City Council as an informational
report going forward.
Consider adjustment to CIP reserve guideline levels: The Advisory Report recommends
maintaining the CIP reserve at 20% of 60 months of budgeted (cash-funded) CIP
expenses or alternatively one-year of depreciation expense.
Adjust RSR policy to align with bond covenants and benchmark communities: The
Advisory Report recommends establishing RSR target levels based on bond covenants,
as applicable, or a percentage of total operating revenues or operating expenses.
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the utility’s costs, risks, and operating contingencies, which may differ for each of the Electric,
Gas, Water and Wastewater Collection Utilities.
Electric Reserves FY 2027 Projected Balance
(Target, $38.2M to $76.4 M)9
Electric Special Projects (managed in accordance with
Council guidelines set forth in Resolution 1007610)
$31.2M
Underground Loan (adjusted each year by the principal
payments made against outstanding underground loans)
$0.7M
Hydro Stabilization (used to manage the supply cost impacts
associated with variations in generation from hydroelectric
resources with a target level of $19M in accordance with the
Council Resolution 974411)
$18.8M
Electrification Reserve (tracks City’s building appliance and
vehicle electrification projects and programs)
$2.0M
Public Benefit, Low Carbon Fuel Standard, Cap & Invest
(tracks net of revenues and expenses for each of these
special revenue sources)
$18.8M
Gas Reserves FY 2027 Projected Balance
(Target, $10.1M to $20.2M)12
($4.5 million to be reserved for future short-term gas
price spikes13)
Cap & Invest
9 The FY27 financial forecast projected the Electric Operations reserve year-end balance at $54M. The FY27
adopted budget assumed higher bond revenue proceed by about $19M
10 Resolution #10076, October 3, 2022, Resolution of the Council of the City of Palo Alto Establishing an
Electrification Reserve and Amending the Electric Utility Reserves Management Practices:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61565&dbid=0&repo=PaloAlto
11 Resolution #9744, March 19, 2018, Resolution of the Council of the City of Palo Alto Adopting Electric Rate
Schedule E-HRA (Electric Hydro Rate Adjuster) and Amending the Electric Utility Reserve Management Practices:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=54142&dbid=0&repo=PaloAlto
12 The FY27 financial forecast projected the Gas Operations reserve year-end balance at $7.3M. The FY27 adopted
budget overstated revenue by about $16M due to over-reported grant funding and Cap-and-Invest revenues
13 Resolution #10187, August 19, 2024 Resolution of the Council of the City of Palo Alto Amending the Gas Utility
Long-term Plan Objectives, Strategies and Implementation Plan, Amending the Gas Utility Reserves Management
Practices, Amending the FY 2025 Gas Fund Budget Appropriation, and Amending Rate Schedules G-1 (Residential
Gas Service), G-2 (Residential Master-Metered and Commercial Gas Service), G-3 (Large Commercial Gas Service),
and G-10 (Compressed Natural Gas Service): https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=62063
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Water Reserves FY 2027 Projected Balance
Operations (Target, $9.2M to $18.5M)$11.86M
Rate Stabilization $4.00M
CIP Reserves $9.00M
In addition to the reserves listed above, each utility also has a reserve for commitments and
reserve for reappropriations. The reserve for commitments holds an amount equal to the
remaining spending authority for all active contracts while the reserve for reappropriations
holds the amount of all remaining budgets that will be reappropriated to the following fiscal
year.
ANALYSIS
In its management response to the Advisory Report, staff proposed to develop a workflow
over the coming year to review and revise reserve policies for City Council consideration
with the assistance of the Utility Advisory Commission and the Finance Committee. While
the Advisory Report contains several recommendations, the most significant policy
considerations relate to the CIP Reserves and RSR Reserves due to their potential impacts
on utility financial planning and customer rates. Accordingly, this section focuses on policy
considerations for these two reserve categories as part of the FY 2027 Workflow.
Workflow to Review and Revise Reserve Policies for City Council Consideration
Table 1 lists the timeline for the workflow to review and revise reserve policies for City
Council consideration. For reference, the current reserve management practices are
available at the following links and were most recently approved by the City Council on June
15, 2026.
Electric Utility Reserves Management Practices19
Gas Utility Reserves Management Practices20
Water Utility Reserves Management Practices21
Wastewater Collection Utility Reserves Management Practices22
19 Electric Utility Reserves Management Practices: https://www.paloalto.gov/files/assets/public/v/1/agendas-
minutes-reports/agendas-minutes/city-council-agendas-minutes/2026/june/rates/attachment-d-exhibit-3-fy27-
electric-reserves-management-practices-redline.pdf
20 Gas Utility Reserves Management Practices: https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-
reports/agendas-minutes/city-council-agendas-minutes/2026/june/rates/attachment-e-exhibit-3-fy27-gas-
reserve-management-practices-redline.pdf
21 Water Utility Reserves Management Practices: https://www.paloalto.gov/files/assets/public/v/1/agendas-
minutes-reports/agendas-minutes/city-council-agendas-minutes/2026/june/rates/attachment-a-exhibit-3-fy27-
water-reserve-management-practices.pdf
22 Wastewater Collection Utility Reserves Management Practices:
https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/agendas-minutes/city-council-
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27
The staff recommendations and proposed workflow breaks up the review into two phases.
Phase 1 Workflow: Review and Revise CIP and RSR Policies
The first phase will occur this year in preparation for the FY 2028 rate setting process, focusing
on the Electric, Gas and Water Utilities. Wastewater reserve changes will be addressed
separately, since the Regional Water Quality Control Plant is in the process of conducting a
separate analysis with an outside consultant and the RWQCP’s partners, including the City of
Palo Alto. The RWQCP is developing recommendations to go to Finance Committee in October
2026. Once those recommendations are available, as part of the workflow, staff would also
present information and make recommendations for the Wastewater Collection Utility
reserves.28
Table 1: Phase 1 Workflow - Review and Revise CIP and RSR Reserve Policies
Meeting Date Governing Body Topic
Sept 2, 2026 UAC Reserve policy recommendations for Electric, Gas, and
Water (Action)
Nov 2026 UAC Reserve policy recommendations for Wastewater
Collection (Action)
Nov/Dec 2026 Finance
Committee
Reserve policy recommendations for Electric, Gas, Water
and Wastewater Collection (Action)
January 2027 Council Adoption of Reserve Management Practices for Electric,
Gas, Water and Wastewater Collection Utilities (Consent)
March/April
2027
UAC FY 2028 rates and five-year forecast for Electric, Gas,
Water and Wastewater Collection (in alignment with
January 2027 Council action) (Action)
April/May
2027
Finance
Committee
FY 2028 rates and five-year forecast for Electric, Gas,
Water and Wastewater Collection (in alignment with
January 2027 Council action) (Action)
June 2027 Council FY 2028 rates and five-year forecast for Electric, Gas,
Water and Wastewater Collection (in alignment with
January 2027 Council action) (Action)
agendas-minutes/2026/june/rates/attachment-b-exhibit-3-fy27-wastewater-collection-reserve-management-
practices.pdf
28 Because the Wastewater Collection utility is responsible for its share of treatment costs to treat Palo Alto’s
wastewater, the Wastewater Collection utility needs to contribute to reserves at the RWQCP. Additionally, the
Wastewater Collection utility needs its own reserves in alignment with the Advisory Report recommendations.
Showing the impact of the Advisory Report recommendations on the Wastewater Collection utility together with
the recommendations from the RWQCP, once those are available, will provide a more complete picture of the
impacts and risks. Table 1 shows that more information for the Wastewater Collection utility will be provided to
the UAC.
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The second phase is planned to occur in FY 2028 potentially for the FY 2029 rate setting
process to focus on reserve specific proposals, such as the Hydro Rate Stabilization Reserve,
and Gas Price Mitigation Adder. Revisions to the Reserve Management Practices may be
needed after each phase.
Phase 2 Workflow: Refinement of Reserve-Specific Detailed Policies
UAC Fall 2027: Policy recommendations and results of rate consultant review of
Hydro Rate Stabilization Reserve, Gas Price Mitigation Adder, and ESP Reserve
Guidelines and sunset date. (Action)
Finance Committee Fall/Winter 2027: Policy recommendations and results of rate
consultant review of Hydro Rate Stabilization Reserve, Gas Price Mitigation Adder,
and ESP Reserve Guidelines and sunset date. (Action)
City Council Winter 2027/Spring 2028: Adoption of policy recommendations and
results of review of Hydro Rate Stabilization Reserve, Gas Price Mitigation Adder,
and ESP Reserve Guidelines and sunset date. (Action)
Advisory Report Recommendations
30 and guidance from the Government
Finance Officers Association (GFOA). Importantly, GFOA guidance allows for a capital reserve
level that best serves the capital needs and financial capabilities of a given organization.31
Current CIP-related CPAU Reserve Policies
30 City Council Staff Report #2605-6353, June 8, 2026:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=887085 (pg. 39-42)
31 Strategies for Establishing Capital Asset Renewal and Replacement Reserve Policies, Board approval date, Friday,
March 8, 2019: https://www.gfoa.org/materials/strategies-for-establishing-capital-asset-renewal-and
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- Regulatory requirements
- Supply chain delays that can shift or accelerate capital investment project schedules
- Emergency infrastructure failures requiring immediate response
- Climate-related events including drought, wildfire, flooding and extreme weather that
may require unplanned capital expenditure
Currently, the Electric, Gas, Water and Wastewater Collection Utilities have a CIP Reserve
maximum guideline of average annual CIP budget for 48 months of budgeted CIP expenses, and
a minimum guideline of 20% of the maximum CIP reserve guideline level. The CIP Reserve
policies do not include a target guideline level. In recent years the CIP Reserves for the Electric
and Gas Utilities have been maintained below the current minimum guideline levels to
moderate rate increases. The Fiscal Year Ending (FYE) 2027 projected CIP Reserve balances are
shown in the table below.
Table 2: FY 2027 CIP Reserve Projected Balances, Minimum and Maximum Guidelines ($
Millions)
Electric Gas Water
CIP Reserve Balance $ 5.88 $ 0 $ 9.00
CIP Reserve Minimum $ 5.66 $ 2.82 $ 3.43
CIP Reserve Maximum $ 28.31 $ 14.09 $ 17.13
While calculated from different base periods, the City's current CIP Reserve maximum guideline
and the Advisory Report recommendation of 20% over 60 months are both equivalent to
maintaining average annual CIP budget in reserve. For simplicity, this report refers to both
approaches as Average Annual CIP Budget. Table 3 compares the current reserve policy
guidelines with the Advisory Report recommendations.
Table 3: Policy Targets by Utility Based on FY 2032 Projections (5 years) ($ Millions)
Electric Gas Water
Average Annual CIP Budget
(Current Maximum Guideline &
Advisory Report Recommendation)
$ 35.32 $ 15.51 $ 15.93
Annual Depreciation Expense
(Advisory Report Alternative
Recommendation)
$ 13.60 $ 5.60 $5.16
20% of Average Annual CIP Budget
(Current Minimum Guideline)
$ 7.06 $ 3.10 $3.19
Estimated Rate Impacts
Staff estimates that adopting the Average Annual CIP Budget recommendation as the CIP target
reserve level would require rate increases for the Electric and Gas Utilities. This policy
recommendation would not require rate increases for the Water Utility as it is already
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forecasted to achieve this target level by 2031. Table 4 shows estimated rate impacts to the
Electric and Gas Utilities under two phase-in scenarios, over a five (5) or ten (10) year period. In
each scenario, a fixed percentage rate increase is applied annually throughout the period so
that the incremental revenue collected each year, compounded over the period, equals the
necessary funds needed by the end of each phase-in period.
Table 4: Estimated Annual Rate Impacts of Advisory Report CIP Reserve Target
Recommendation of Average Annual CIP Budget
Electric Gas
5-year Implementation
10-year Implementation
34 After the fifth year,
and assuming all else is equal, these incremental adjustments would be removed from the rate.
However, in practice, rather than resulting in a decrease in rates, customers would likely see a
reduced magnitude of future rate increases that would otherwise be needed. The incremental
adjustment can also be reevaluated annually based on financial performance, market
conditions, and the extent to which reserve funds are needed to respond to market events or
other financial needs. This approach allows for flexibility to adjust the rate increments over
time while continuing to make gradual progress toward the target reserve levels.
Policy Considerations, Recommendations and Next Steps
34 This example is for illustration only and does not take into account the compounding effects of rate increases
but it is provided to clarify that this is not a sustained 0.3% increase and rather is an additional 0.3% added each
year.
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to manage capital risks. The calculation of the Average Annual CIP Budget only includes cash-
funded CIP and it does not include CIP projects funded by grants or customer connection fees.
Advisory Report Recommendations
36. The Advisory Report observed that Palo
Alto’s Electric, Water, and Gas Utilities lack guideline levels, whereas peer utilities tend to have
defined targets. The Advisory Report includes peer examples for reference and recommends
that CPAU management set its targets based on the amount desired to be held in the fund to
help stabilize future rate increases.
36 City Council Staff Report #2605-6353, June 8, 2026:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=887085 (pg. 32-35). The Advisory Report also
recommends aligning RSR guidelines with the bond covenants of the City’s 2009 Series A Water Revenue Bonds
(2009 Revenue Bonds) and 2011 Utility Refunding Bonds (2011 Revenue Bonds). As staff outlined in the
management response, staff plans to refund the 2009 Revenue Bonds under a new bond indenture in FY 2027,
which would eliminate the current bond covenant reserve requirements. The 2011 Revenue Bonds fully matured in
FY 2026. As a result, this eliminates the need to modify the minimum guideline levels solely for bond covenant
considerations.
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The Advisory Report also recommends revising the RSR policy to state that “if a Utility Financial
Plan proposes a rate increase, the funds in the RSR Fund in excess of the target amounts must
be drawn down to offset the proposed rate increase.”38
Current CPAU Reserve Policies
The Reserves Management Practices outline the purpose for each utility’s RSR. These reserves
are intended to manage the trajectory of future year rate increase and to mitigate temporary
fluctuations in revenues or expenses from events such as:
- Volatility in electricity rates resulting from fluctuations in power costs
- The impact of short-term gas market price spikes
- The impacts of drought or changing demand
- Economic downturns that reduce customer demand or increase bad debt expense
The existing RSR policy does not include a target level or guideline range. The projected RSR
balances for the Electric, Gas, and Water Utilities are shown in the table below.
Table 5: Projected RSR Balances ($ Millions)
Electric Gas Water
FY 2027 Projected Balance $ 0 $ 039 $ 4.00
FY 2032 Projected Target Based on
10% of Operating Expenses $ 11.01 $ 4.09 $ 3.13
For each of the RSRs, the Reserves Management Practices currently state that the utilities must
plan to withdraw all the funds from the reserve by the end of the next financial planning period
(unless Council approves an exception to this requirement). The Hydro Rate Stabilization
Reserve funds are separate from the RSR in the Electric Utility.
Estimated Rate Impacts
Staff analyzed the rate impacts of a 10% of operating expenses (excluding supply expenses) RSR
target scenario and estimates that this RSR target level would require additional rate increases
for each utility. Table 6 shows estimated rate impacts to the Electric, Gas and Water Utilities
under two phase-in scenarios, over a five- or ten-year period. In each scenario, a fixed
percentage rate increase is applied annually throughout the period, so that the incremental
revenue collected each year, compounded over the period, equals the necessary funds needed
by the end of each phase-in period. This analysis assumes that the funds in the Hydro Rate
38 City Council Staff Report #2605-6353, Attachment A, p. 6:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=887085.
39 The projected balance excludes funds being collected through the Gas Price Spike Mitigation Adder in the Gas
Rate Stabilization Reserve for price spike mitigation purposes.
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Stabilization Reserve as well as the Gas Price Spike Mitigation Adder accumulated funds are
excluded and addressed separately in Phase 2.
Table 6: Estimated Annual Rate Impacts of 10% of Operating Expense RSR Target
Electric Gas Water
5-year Implementation
10-year Implementation
42
Policy Recommendations, Considerations and Next Steps
Establish a target level of 10% of operating expenses (excluding supply expenses).
Remove the current provision from the Reserves Management Practices that states that
the utilities must plan to withdraw all the funds from the RSR by the end of the planning
period.
Require that if a Utility Financial Plan proposes a rate increase, the funds in the Rate
Stabilization Reserve in excess of the target amounts must be drawn down to offset the
proposed rate increase.
42 This example is for illustration only and does not take into account the compounding effects of rate increases
but it is provided to clarify that this is not a sustained 0.3% increase and rather is an additional 0.3% added each
year.
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Credit Rating Considerations
44 and
plans to issue refunding bonds (Series 2026A Water Revenue Refunding Bonds45) to refinance
the Water Fund’s 2009 Revenue Bonds in fall of FY 2027.
46 outlining its rationale for the rating. The press release stated that the stable outlook
reflects their view that the utility will “sustain historically robust liquidity” and adjust rates to
sufficiently fund capital needs without materially drawing on reserves. The press release also
stated that they “could lower the rating over the next two years if the utility’s debt service
coverage or liquidity materially decline to levels observed in the past few years, either due to
insufficient rate adjustments or unexpected capital needs that require additional debt or
significant cash draws.”
44 Resolution #10209 A Resolution of the City of Palo Alto Declaring Intention to Reimburse Expenditures Relating
to Modernization of the Electric Utility System Infrastructure from the Proceeds of Tax-Exempt Debt:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=62094&dbid=0&repo=PaloAlto&cr=1
45 Finance Committee Staff Report #2603-6099:
https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=9d997ec2-d7ef-4322-bd41-
8904e984d6a2
46 S&P Global Ratings Press Release, August 17, 2026: https://www.spglobal.com/ratings/en/regulatory/article/-
/view/type/HTML/id/3612769
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more cumulative revenue and reducing the annual rate impact needed to reach the reserve
target.
FISCAL/RESOURCE IMPACT
Table 7: Estimated Annual Rate Impacts for Proposed Reserve Targets (FY 2028 – FY2031)*
Electric†
Gas
Water
Electric
Gas
Water
Electric
Gas
Water
Table 8: Rate Forecasts as Adopted by the City Council in the Financial Forecasts in June 2026
Electric
Gas
Water
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Because these adjustments are rounded to the nearest whole percentage, this change only
impacts the overall rate trajectory for the Gas Utility, as shown in Table 9.
Table 9: Rate Forecasts Including Staff Recommendations for CIP and RSR Reserves
Electric
Gas
Water
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
AUTHOR/TITLE:
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