Loading...
HomeMy WebLinkAbout2026-10-07 Utilities Advisory Commission Agenda PacketUTILITIES ADVISORY COMMISSION Regular Meeting Wednesday, October 07, 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 person. The meeting will be broadcast on Cable TV Channel 76, live on YouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen Media Center https://midpenmedia.org. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/96691297246) Meeting ID: 966 9129 7246 Phone: 1(669)900-6833   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. Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks, posts, poles or similar/other type of handle objects are strictly prohibited; (2) the items do not create a facility, fire, or safety hazard; and (3) persons with such items remain seated when displaying them and must not raise the items above shoulder level, obstruct the view or passage of other attendees, or otherwise disturb the business of the meeting. 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 October 07, 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 September 2, 2026 UTILITIES DIRECTOR REPORT 6:20PM - 6:30PM   NEW BUSINESS   2.Approval of Water and Wastewater Collection Rate Design Guidelines and Principles (ACTION: 6:30PM – 7:30PM) 3.Electric Grid Modernization Bond Financing; Recommendation to the City Council to Adopt a Resolution Authorizing the Issuance and Sale of Tax-Exempt Electric Revenue Bonds Principal Amount Not-to-Exceed $100,000,000 (ACTION: 7:30PM – 7:45PM) 4.Recommending Approval of Updated Palo Alto Low Carbon Fuel Standards Program Guidelines, including a Definition for Low-Income and a Methodology to Allocate Customer Program Cost Across Low-Income and Non-Low-Income (ACTION: 7:45PM – 8:30PM) Late Packet Report Added FUTURE TOPICS FOR UPCOMING MEETINGS (8:30PM - 8:45PM)   12 Month Rolling Calendar 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.  2 Regular Meeting October 07, 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 ADJOURNMENT 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.Public Comments B.Informational Report on Framework for Data Center Capacity Reservation and Cost Recovery C.Informational Update on Voluntary Residential Time-of-Use Electric Rate Enrollment and Customer Outreach 3 Regular Meeting October 07, 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. Please read the following instructions carefully. ◦You may download the Zoom client or connect to the meeting in- browser. If using your browser, make sure you are using a current, up-to-date browser: Chrome 30 , Firefox 27 , Microsoft Edge 12 , Safari 7 . Certain functionality may be disabled in older browsers including Internet Explorer. ◦You may be asked to enter an email address and name. We request that you identify yourself by name as this will be visible online and will be used to notify you that it is your turn to speak. ◦When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will activate and unmute speakers in turn. Speakers will be notified shortly before they are called to speak. ◦When called, please limit your remarks to the time limit allotted. A timer will be shown on the computer to help keep track of your comments. 3.Spoken public comments using a smart phone will be accepted through the teleconference meeting. To address the Council, download the Zoom application onto your phone from the Apple App Store or Google Play Store and enter the Meeting ID below. Please follow the instructions B-E above. 4.Spoken public comments using a phone use the telephone number listed below. When you wish to speak on an agenda item hit *9 on your phone so we know that you wish to speak. You will be asked to provide your first and last name before addressing the Council. You will be advised how long you have to speak. When called please limit your remarks to the agenda item and time limit allotted. CLICK HERE TO JOIN Meeting ID: 966 9129 7246 Phone:1-669-900-6833 Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public programs, services and meetings in a manner that is readily accessible to all. Persons with disabilities who require materials in an appropriate alternative format or who require auxiliary aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at (650) 329-2550 (voice) or by emailing ada@PaloAlto.gov. Requests for assistance or accommodations must be submitted at least 24 hours in advance of the meeting, program, or service.  4 Regular Meeting October 07, 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 6:15PM - 6:20PM Lead Department: Utilities Meeting Date: October 7, 2026 Report #:2609-6804 TITLE Approval of the Minutes of the Utilities Advisory Commission Meeting Held on September 2, 2026 RECOMMENDATION Staff recommends that the Utility Advisory Commission review and approve the September 2, 2026 minutes. Commissioner ______ moved to approve the draft minutes of the September 2, 2026 meeting as submitted/amended. Commissioner ____ seconded the motion. ATTACHMENTS Attachment A: September 2, 2026 Draft Minutes APPROVED BY: Alan Kurotori, Director Utilities Item #1     Packet Pg. 5     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 1 of 17 UTILITIES ADVISORY COMMISSION MINUTES OF SEPTEMBER 2, 2026, REGULAR MEETING CALL TO ORDER Chair Mauter called the meeting of the Utilities Advisory Commission (UAC) to order at 6:00 p.m. Present: Chair Mauter, Vice Chair Phillips, Commissioners Croft, Gupta, Metz, Scharff, and Tucher Absent: None AGENDA REVIEW AND REVISIONS None. IN-PERSON PUBLIC COMMENT None. APPROVAL OF THE MINUTES ITEM 1: ACTION: Approval of the Minutes of the Utilities Advisory Commission Meeting Held on August 5, 2026 Commissioner Croft requested an edit to the August 5, 2026, minutes to reflect the wording included in the motion. MOTION: Vice Chair Phillips moved, seconded by Commissioner Scharff, to approve the minutes of the August 5, 2026, meeting including the following amendment: 1. On Packet Page 14, replace, “Commissioner Croft liked the 4 nines” with “Commissioner Croft recommended setting a goal slightly better than 4 nine since we already meet that metric.” Item #1     Packet Pg. 6     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 2 of 17 MOTION PASSED: 7-0 UTILITIES DIRECTOR REPORT Utilities Director Alan Kurotori stated that future Utilities Director Reports would be provided in presentation format before meetings and designed to provide sufficient context as stand-alone documents, as requested by the UAC. Mr. Kurotori thanked Commissioners Gupta, Metz, and Tucher for suggestions regarding the report content. S&P Global assigned a AAA rating to the refunding of the 2009 Water Revenue Bonds. The refunding will save approximately $309,000 through 2035, eliminate reserve requirements involving the Water, Gas, and Electric Funds, and reduce exposure to federal interest subsidy sequestration. The Finance Committee reviewed the refunding on August 18 and Council consideration is scheduled for September. Mr. Kurotori noted the favorable rating as the City prepares for upcoming Electric Fund bonds related to grid modernization. Mr. Kurotori reported that Public Works, Utilities, and IT staff participated in an EPA call regarding cybersecurity threats following reported attacks in Minnesota and subsequently found no indications of risks or penetrations into City systems. The U.S. Department of Transportation awarded the City a $16.5M grant and Palo Alto was 1 of only 2 recipient cities to receive a low-risk rating in a subsequent assessment of grant recipients. Mr. Kurotori noted that the rating could benefit the City when pursuing future grants. The statewide commercial customer survey conducted with CMUA was completed in August, with Palo Alto-specific outreach beginning September 15, results expected in November and presentation to the UAC anticipated in January. A residential customer survey will follow. Mr. Kurotori reported that the high-voltage underground electric lines in the Foothills have been energized, with only the low- voltage service lines remaining. Referencing slides, Mr. Kurotori discussed Palo Alto's participation in a CEC workshop regarding large-load projections and stated that the CEC is considering thresholds and policies similar to Palo Alto's process of grouping projected loads by confidence level. Induction cooktop rebates have been offered since March as an energy- efficiency measure funded through a dedicated fee rather than ratepayer revenues, with income-qualified customers eligible for twice the standard rebate. Palo Alto libraries have expanded an induction cooktop loaner program in response to high demand. Mr. Kurotori concluded by referencing a slide tracking outstanding UAC follow-up items and their anticipated scheduling and stated that staff will continue to update the list. Commissioner Gupta inquired about the timing of the tentative November 16 joint Council/UAC study session. Mr. Kurotori stated that the study session would be part of the City Council meeting and held in the evening. Commissioner Tucher thanked Mr. Kurotori for incorporating prior Commission suggestions into the expanded report, including updates from Council, committee, and regional agency meetings and follow-up from prior UAC meetings. Commissioner Tucher suggested that the Item #1     Packet Pg. 7     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 3 of 17 Commission could identify selected projects for periodic updates in future Director's Reports to help determine whether related items should be scheduled sooner for UAC consideration. NEW BUSINESS ITEM 2: DISCUSSION: Special Presentation and Discussion on Partnering Norms for Staff and Commissioners Effectiveness. CEQA – Not a Project City Manager Ed Shikada clarified that the discussion was not prompted by wrongdoing and was the 4th such discussion held with a City commission. The purpose was to support the working relationship between commissioners and staff and establish common expectations. Mr. Shikada noted that the BCC Handbook provides general guidance and suggested revisiting the discussion periodically. Referencing a slide, Mr. Shikada described tensions inherent in commission work, including individual interests versus Commission priorities, emerging issues versus public noticing and work plan requirements, governance versus management, progress reporting versus making progress, and time management. Mr. Shikada reviewed staff- generated norms addressing Commission scope and role, professional conduct and communication, time management, transparency and legal compliance, feedback on staff work, and public trust. Regarding feedback on staff work, Mr. Shikada requested that public discussion focus on the work rather than individual staff members and that concerns regarding staff performance be directed to the Utilities Director. Item 2 Public Comment: None. Vice Chair Phillips asked whether the staff-generated norms were intended as expectations for Commissioner conduct or as suggestions for discussion. Mr. Shikada clarified that the norms were intended as general guidance rather than requirements and could serve as a point of reference if issues arise. Vice Chair Phillips expressed concern that the norm regarding feedback on staff work could be interpreted as limiting Commissioners' ability to publicly critique or question the substance of staff presentations. Mr. Shikada clarified that criticism of the work is appropriate and summarized the intent as criticizing the work rather than the worker. Commissioner Croft asked whether the UAC could receive earlier Council feedback on its proposed work plan, noting that the UAC had devoted considerable time to developing the work plan in the prior year. Mr. Shikada stated that Council consideration of commission work plans had been inconsistent in part because of the Council's heavy docket and reported that the UAC work plan is scheduled for Council consideration in October, providing an opportunity for substantive feedback. Commissioner Croft supported receiving Council feedback, noting that the UAC has limited direct interaction with the Council. Chair Mauter asked whether she could directly ask Councilmembers about their priorities when presenting the UAC work plan. Mr. Shikada stated that there was no restriction on doing so. Councilmember Lauing noted that Council does not automatically approve commission work Item #1     Packet Pg. 8     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 4 of 17 plans and supported asking questions during Council consideration. Commissioner Scharff clarified that Council had substantively discussed the prior UAC work plan, including questions and concerns raised by Councilmembers. Commissioner Scharff expressed concern that Commissioners had at times been rude toward staff and supported identifying incomplete or inadequate work while providing feedback respectfully, particularly to junior staff. Mr. Shikada noted that prospective employees may watch Commission meetings when considering employment with the City. Utilities Director Alan Kurotori reported that candidates for a current Assistant Utilities Director position had watched UAC meetings to understand the Commission's interests and interactions with staff. Commissioner Scharff emphasized that respectful and functional Commission interactions can affect whether prospective employees view the City as a desirable place to work. Chair Mauter echoed Commissioner Scharff's comments and stated that the Chair has a role in maintaining respectful communication with staff. Chair Mauter encouraged Commissioners to speak up if interactions, including her own, cross that boundary. Chair Mauter emphasized that although the Commission does not manage staff time, Commissioner requests and interests can consume time needed to operate the Utilities Department. Chair Mauter supported prioritizing topics included in the Council-approved work plan and being receptive when staff indicates that time or resources are unavailable. Chair Mauter emphasized that the UAC serves in an advisory rather than managerial role and that responsibility for managing Utilities staff rests with Mr. Kurotori. Commissioner Gupta emphasized the importance of respectful communication, particularly when disagreements arise, and noted that disrespectful interactions on the UAC have been rare. Commissioner Gupta asked whether Council had participated in developing the proposed norms. Mr. Shikada stated that the norms were developed by staff without direct Council involvement, although BCC Chairs had discussed the topic with the Mayor and Vice Mayor. Commissioner Gupta encouraged periodic review of the BCC Handbook and suggested providing examples to help clarify the distinction between the UAC's advisory role and matters considered part of daily Utilities operations. Commissioner Scharff added that Council developed the BCC Handbook and characterized the guidance in the handbook as a Council directive. Commissioner Tucher questioned the purpose of discussing norms that Commissioners generally agreed were appropriate and requested specific observations from Mr. Shikada based on his review of prior UAC meetings. Mr. Shikada stated that he had observed instances in which frustration became apparent and could reflect poorly on the UAC as a whole. Mr. Shikada identified that concern as one reason for bringing the norms forward. Chair Mauter noted that UAC meetings frequently run long and emphasized more closely adhering to the agenda as a way to respect Commissioners' and staff's time. Item #1     Packet Pg. 9     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 5 of 17 Commissioner Tucher acknowledged the amount of time staff spends preparing and presenting materials to the UAC and Council but suggested that clearer staff reports and presentations could significantly reduce meeting length. Commissioner Tucher questioned whether lengthy meetings resulted from discussion outside the agenda, noting that the Commission may instead spend considerable time discussing agendized items. Mr. Shikada noted that Council uses timed comments to manage meeting length and suggested that Commissioners may underestimate the amount of time they spend speaking. Commissioner Scharff suggested limiting Commissioners to an initial opportunity to speak and 1 follow-up, noting that repeated rounds of comments contribute to lengthy meetings. Chair Mauter agreed and suggested that Commissioners prioritize their most important points during meetings and reserve less critical comments for appropriate follow-up outside the meeting. Commissioner Tucher discussed his use of public memoranda to provide questions in advance and suggested evaluating whether that approach is effective and constructive. Chair Mauter proposed experimenting with a 2-round approach, with Commissioners generally speaking once and using a second opportunity for necessary follow-up, while limiting each exchange to approximately 2 minutes. Commissioner Croft supported trying the approach and observed that UAC discussions have become more detailed and antagonistic during her 3 years on the Commission, expressing concern that the nature of the discussions could make staff hesitant to present to the UAC. Vice Chair Phillips suggested limiting meeting questions to matters relevant to the decision before the Commission and reserving ancillary questions for subsequent email. Commissioner Gupta was willing to try a more structured approach while preserving substantive discussion and staying on topic. NO ACTION ITEM 3: ACTION: Discussion of Baker Tilly Reserves Advisory Report and Recommendation to the City Council of Proposed Policy Updates to the Utilities Reserve Management Policies Utilities Director Alan Kurotori introduced the item and noted that 2 Baker Tilly representatives were available remotely to participate in the discussion. Assistant Utilities Director Lisa Bilir reported that Council accepted the Baker Tilly reserve advisory report in June and staff subsequently developed recommendations and a workflow for revising the Utilities Reserve Management Practices. The advisory report recommended retaining the existing reserve funds, clarifying Capital Improvement Program (CIP) Reserve language, formalizing reserve tracking, considering adjustments to CIP Reserve guideline levels, and aligning the Rate Stabilization Reserve (RSR) policy with bond covenants and benchmark Item #1     Packet Pg. 10     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 6 of 17 communities. Ms. Bilir stated that no action was needed on the recommendation to retain existing reserves, revisions involving the Electric Special Projects Reserve would be addressed in Phase 2, and that staff recommended exception-based reserve reporting. The current discussion focused on the CIP and RSR recommendations because they have the most significant rate impacts. Staff proposed addressing Electric, Gas, and Water reserve policies during Phase 1, with Council adoption targeted for January 2027 before FY 2028 rates are considered. Wastewater Collection recommendations are planned for separate UAC consideration in November pending analysis of the treatment component. More detailed supply-related reserve policies, including the Hydro Rate Stabilization Reserve and Gas Price Mitigation Adder, would be addressed with assistance from a rate consultant in Phase 2. Ms. Bilir reported that Baker Tilly recommended setting the CIP Reserve target at 1 year of budgeted CIP expenses, with annual depreciation expense as an alternative. The existing policy uses 1 year of budgeted CIP expenses as the maximum and establishes a separate minimum. Staff recommended simplifying the policy by replacing the minimum and maximum guidelines with a single target based on the average annual CIP budget. Ms. Bilir noted that annual depreciation is approximately 30 to 40 percent of the annual CIP budget and therefore substantially lower than annual CIP needs. Staff recommended achieving the proposed CIP target over 5 years for Gas and Water, which currently have limited reserves, and 10 years for Electric, which has additional reserves. The UAC could alternatively recommend different targets by utility. Regarding the RSR, Ms. Bilir reported that peer utility targets range from 10 to 65 percent of operating revenues or expenses. Palo Alto's existing policy has no RSR target and requires any balance to be returned to ratepayers by the end of the 5-year planning period. Staff recommended establishing a target of 10 percent of operating expenses, the low end of the peer range, and achieving the target over 5 years. Staff further recommended eliminating the requirement to draw down the entire RSR during the planning period so funds remain available to stabilize rates following unexpected events. If a rate increase is proposed, however, any RSR balance exceeding the target would be required to offset the proposed increase during the 5- year period. Ms. Bilir clarified that the current recommendation addresses the distribution component of rates and that supply-related components would be addressed in Phase 2. The Gas Utility would experience the greatest rate impact from the proposed reserve changes. Ms. Bilir summarized staff's recommendation that the UAC recommend Council revise the Utilities Reserve Management Practices to establish a CIP Reserve target based on the average annual CIP budget and an RSR target of 10 percent of operating expenses with rules governing balances above or below the target; establish a 5-year period for achieving the RSR target; establish CIP target implementation periods of 5 years for Gas and Water and 10 years for Electric; and approve the proposed FY 2027 workflow for revising the Utilities Reserve Management Practices. Item 3 Public Comment: None. Item #1     Packet Pg. 11     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 7 of 17 Commissioner Tucher asked whether bond- and grant-funded CIP projects were excluded from the Electric CIP Reserve calculation. Ms. Bilir confirmed that the calculation includes only the cash-funded portion of CIP projects, including grid modernization projects. Vice Chair Phillips asked how the proposed RSR for distribution operations would relate to existing supply-related reserves and whether an additional reserve would be needed for other supply costs. Ms. Bilir explained that the Gas Price Spike Mitigation Adder and Hydro Rate Stabilization Reserve were established by Council for specific purposes and require further analysis with a rate consultant. Staff recommended proceeding with the distribution-related RSR now to meet the timeline for FY 2028 rates and addressing supply-related reserves in Phase 2. The reserves ultimately could be combined into a single reserve, which would require a subsequent policy modification. Phase 2 work would begin during the current fiscal year but would not be ready for consideration within the current implementation timeline. Chair Mauter asked how interest earned on reserves is allocated and whether the proposed changes would affect transfers among reserves. Ms. Bilir stated that interest is calculated quarterly and allocated to the appropriate enterprise fund reserve. Ms. Bilir explained that staff will revise the Reserve Management Practices before Council consideration in January to specify allowable transfers among reserves and the respective approval authority of Council and staff. Staff is not currently proposing changes to existing transfer practices, although the policies could be revised based on UAC and Finance Committee feedback. Commissioner Croft asked approximately what percentage of rates is attributable to operating expenses excluding supply costs. Ms. Bilir estimated approximately 50 percent but stated that staff would need to develop a more precise estimate. Staff separated operating and supply costs to avoid establishing an overly broad RSR target before conducting a more detailed analysis of supply-related reserves. Commissioner Scharff asked about existing RSR balances and Council policies. Ms. Bilir stated that most Utilities have no RSR balance and that existing RSRs do not have a general target. The Water Utility has approximately $4M remaining from funds accumulated before the drought, which have been used during and after the drought to manage the rate trajectory. Ms. Bilir identified the Hydro Rate Stabilization Reserve and the Gas Price Mitigation Adder Reserve as reserves with specific Council-approved funding levels or purposes. Commissioner Scharff asked whether the proposed policy was intended to create larger RSRs. Baker Tilly Representative Ross Hagen stated that Baker Tilly's review of industry practices and comparable local utilities found that maintaining an RSR with a defined target or guideline is a best practice, with peer targets ranging from 10 to 65 percent of operating revenues or expenses. Mr. Hagen identified 2 concerns with Palo Alto's existing policy: the absence of defined RSR targets and the requirement to draw down existing balances during the financial planning period. Mr. Hagen explained that requiring the balances to be drawn down runs Item #1     Packet Pg. 12     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 8 of 17 counter to the purpose of an RSR, which is to absorb unexpected financial volatility and mitigate resulting rate increases. Baker Tilly therefore recommended establishing appropriate RSR targets and revising the policy language governing excess reserve balances. Commissioner Gupta asked why the projected rate impacts were lower than those presented in staff's initial management response to the Baker Tilly report. Ms. Bilir explained that the initial analysis modeled an immediate increase maintained over several years, while the current proposal would build reserves through smaller cumulative increases over 5 or 10 years. The total amount recovered would be the same but achieved more gradually. Ms. Bilir noted that the implementation estimates reflect rounding and cumulative effects and that staff could provide additional calculations regarding the compounded rate impact. Commissioner Gupta asked whether the total rate impact remained within the range estimated in the initial management response. Assistant City Manager Kiely Nosé stated that staff could not make an equivalent comparison because the current analysis addresses only 2 reserves. The phased process would allow staff and the UAC to evaluate the reserve policies collectively during the second year and make adjustments if necessary. Commissioner Metz supported several proposed changes to the Reserve Management Practices but questioned the rationale for increasing reserve levels based primarily on comparisons with other utilities. Commissioner Metz asked what risks the City would face without the proposed reserves and initially indicated that he could not support the recommendation without a clearer explanation of the benefits and trade-offs. Ms. Nosé stated that reserve levels are ultimately a policy decision reflecting the City's risk tolerance and that maintaining the existing reserve levels remained an option. Ms. Nosé cautioned that S&P's rating identified factors that could result in a downgrade and noted that a lower credit rating would increase borrowing costs, particularly as the Electric Utility prepares to issue significant debt. Mr. Kurotori added that Palo Alto's AAA rating reflects several strengths but that its days of cash on hand were below the median considered by the rating agency. Mr. Kurotori explained that an RSR provides greater ability to manage financial changes while stabilizing rates for residents and businesses and noted differences in the reserve structures of benchmark utilities. Commissioner Metz found the additional explanation more compelling but continued to seek clarity regarding the trade-off involved. Ms. Nosé stated that the UAC's recommendation would help establish the City's risk tolerance by balancing affordability against the amount collected and retained to mitigate future financial volatility. Commissioner Scharff distinguished between maintaining adequate reserves and using reserves to stabilize rates. Maintaining only the cash reserves and liquidity necessary to protect the City's bond rating and address emergencies would be preferable to using reserves to suppress price signals or subsidize future ratepayers with funds collected from prior ratepayers. Commissioner Scharff suggested slowing noncritical CIP projects during periods of unusually high rate increases, noting that the existing Hydro Rate Stabilization Reserve mitigates some Item #1     Packet Pg. 13     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 9 of 17 electric supply risk. Commissioner Scharff noted he could not support the motion as currently presented. Ms. Nosé stated that no formula identifies the reserve level necessary to maintain a AAA rating because ratings reflect multiple factors. Staff therefore sought a moderate approach that considered affordability, including an RSR target at the low end of the peer range and excluding supply-related reserves from the current analysis. Mr. Kurotori noted the need to replenish the Gas Utility's insufficient CIP reserves and stated that grant funding requires the City to maintain existing project commitments, limiting the ability to defer projects without jeopardizing eligibility for additional grants. Ms. Bilir stated that the City's cash levels are below those identified in the Baker Tilly report as extremely strong and associated with AAA ratings. Establishing reserve levels based solely on protecting the rating would require substantially higher rate increases, while staff's recommendation was intended to balance affordability with peer practices and industry guidance. Mr. Hagen explained that liquidity and reserves account for 25 percent of S&P's rating scorecard for electric and gas utilities. The final rating considers additional factors, including confidence in the City's governance and management and their ability to make necessary rate and reserve decisions to meet debt service obligations. Mr. Hagen noted that S&P may therefore assign a rating above that indicated by the scorecard based on its broader evaluation. Commissioner Croft asked what risks associated with operating expenses, excluding supply costs, would require an RSR. Mr. Hagen distinguished an O&M reserve, which supports short- term liquidity and continued operations during unexpected events, from an RSR, which provides medium- to long-term protection of the rate plan. Commissioner Croft questioned whether the O&M reserve could serve the rate-stabilization function rather than creating a separate reserve, asked whether the existing O&M reserve levels would be sufficient for that purpose, and questioned differences in the reserve balances shown in the report. Ms. Bilir explained that the figures reflect FY 2027 projected ending balances from the budget and that differences from the financial forecast are explained in the footnotes, which incorporate additional information available during the forecasting process. Ms. Bilir confirmed that O&M reserve funds could be used for rate stabilization but noted that maintaining separate reserves is more consistent with the peer practices and industry guidance identified by Baker Tilly. Ms. Nosé agreed that the City could establish a policy allowing the O&M reserve to serve O&M and rate-stabilization purposes but stated that staff had not determined whether the existing targets would be sufficient. Mr. Hagen explained that separate O&M and rate stabilization reserves provide clearly defined purposes for the funds and greater assurance that each reserve will be used as intended. Commissioner Metz asked how replacing the existing minimum and maximum reserve guidelines with a single target would help protect the City's bond rating and debt coverage. Ms. Nosé stated that using a target rather than a range would not affect debt coverage and was a Item #1     Packet Pg. 14     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 10 of 17 policy choice intended to provide greater simplicity and clarity based on Baker Tilly's assessment. Commissioner Metz asked how staff would respond if planned rate increases failed to achieve the reserve targets. Ms. Bilir stated that staff would reevaluate reserve levels annually through the rate forecast, report the results, and revise the approach as appropriate. Ms. Nosé added that the UAC could choose not to recommend making up lost ground toward the target when other financial challenges arose, similar to decisions Council regularly makes regarding proactive pension funding. Mr. Kurotori confirmed that the annual process would provide an operational feedback loop. Commissioner Gupta emphasized evaluating reserve policies based on their cumulative rate impacts rather than individual annual increases and requested that future presentations include the cumulative impact over a 5-year period. Commissioner Gupta expressed concern about growing customer sensitivity to utility costs and the potential effect of recurring 6 to 7 percent annual rate increases on affordability. Ms. Bilir clarified that the rate impacts presented by staff reflect the combined effect of the proposed CIP and RSR changes, which would increase projected rates by less than 1 percentage point for the Electric and Water Utilities and approximately 0.5 percentage point annually for the Gas Utility. Ms. Bilir stated that staff sought to balance affordability with appropriate reserve levels and that any additional reserve changes considered in Phase 2 would be incorporated into the overall rate impact before further decisions were made. Commissioner Tucher questioned why staff proposed the same CIP Reserve methodology for all 3 Utilities rather than considering different approaches based on each Utility's circumstances, noting the substantial difference between the average annual CIP budget and depreciation methodologies. Ms. Nosé explained that historical CIP costs are not a reliable indicator of future costs because capital costs for materials, labor, and supply-chain challenges have increased substantially. Commissioner Tucher requested greater clarity regarding policies governing transfers among Utilities and between CIP and operating reserves and questioned whether the combined reserve levels could exceed what is necessary. Commissioner Tucher suggested that future presentations identify the specific risks the reserves are intended to address and explain how those risks differ among the Gas, Electric, and Water Utilities. Chair Mauter stated that the discussion had persuaded her that separate reserves could appropriately address different risks. Chair Mauter supported staff's relatively conservative 10 percent RSR target and emphasized balancing adequate reserves and favorable bond ratings against rate impacts. Chair Mauter requested stronger justification for applying different approaches among the Utilities and information regarding the financial implications of a lower bond rating, particularly as the City moves forward with wastewater investments. Vice Chair Phillips questioned whether the individual risks could be sufficiently identified and quantified and suggested focusing instead on the total reserve level and policies necessary to Item #1     Packet Pg. 15     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 11 of 17 provide high confidence in maintaining the City's AAA rating under a range of circumstances. Vice Chair Phillips understood the rationale for maintaining reserves for different purposes but favored consolidating them into fewer reserves. Concern about acting before the forthcoming Wastewater Collection reserve analysis led Vice Chair Phillips to indicate that he was leaning against the current proposal. Commissioner Croft expressed concern about the low Gas CIP Reserve balance and proposed using annual depreciation expense as the target for replenishing the reserve. Commissioner Croft suggested the same methodology for the Electric CIP Reserve but questioned whether that amount would be sufficient given upcoming large projects. Commissioner Croft placed greater priority on funding the CIP Reserves than establishing an RSR and proposed deferring a separate RSR until the hydro analysis and IRP provide a more complete understanding of exposure to market price volatility and potential rate impacts. In the interim, Commissioner Croft suggested using the O&M Reserve for rate stabilization and having staff determine the reserve level needed to support future financing requirements. Commissioner Scharff distinguished the need for sufficient reserves to support the City's bond rating from the purpose of an RSR and opposed establishing an RSR under the current proposal. Commissioner Scharff supported increasing the O&M Reserve if additional reserves were needed for financing purposes and could consider an RSR in the future if its use were limited to temporary, extraordinary events rather than offsetting ongoing cost increases. Commissioner Scharff supported the proposed CIP Reserve changes and was open to using annual depreciation expense as the target for the Electric and Gas Utilities if staff determined that approach was sufficient. Commissioner Scharff supported the proposed FY 2027 workflow and suggested developing a recommendation that could gain broader Commission support. Vice Chair Phillips asked what would occur if the UAC did not provide a recommendation or alternative proposal. Ms. Nosé stated that staff would forward the item to the Finance Committee with a summary of the UAC discussion and note that the UAC had not provided an alternative. Chair Mauter proposed moving the staff-recommended motion and then considering amendments based on the Commission's discussion. The Commission and staff discussed potential modifications to the staff recommendation and worked together to develop the motion language. The Commission informally polled its members regarding use of the annual depreciation expense methodology for the CIP Reserve and further discussed incorporating that approach into the motion. MOTION: Chair Mauter moved, seconded by Commissioner Scharff, to 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: Item #1     Packet Pg. 16     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 12 of 17 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 5. Recommend that staff return with the pros and cons of the Rate Stabilization Reserve FRIENDLY AMENDMENTS INCORPORATED INTO THE MOTION WITH THE CONSENT OF THE MAKER AND SECONDER MOTION PASSED: 5-2, Gupta, Tucher no [The Commission took a 9-minute break] ITEM 4: DISCUSSION: Update on Electric System Long Duration Resiliency; CEQA Status – Not a Project Utilities Chief Operating Officer Terry Crowley reported that Council considered local energy resources and long-duration resiliency in March 2026 and determined that local utility-scale microgrids were not sufficiently cost-effective to pursue additional studies or site development. Council directed staff to continue engaging the UAC, Climate Action and Sustainability Committee (CASC), and Council during 2026. Mr. Crowley reported that utility-scale microgrid costs remain high relative to their benefits. Citing estimates from the National Laboratory of the Rockies, Mr. Crowley stated that a 4 MW, 4-hour battery costing approximately $5.4M could serve approximately 300 single-family homes for 24 hours, representing approximately 1 percent of Palo Alto's residential customers. The estimate excludes the solar generation needed to recharge the battery, which would require approximately 20 acres and cost an additional $12M to $15M. Battery costs are projected to decline significantly by 2035 and staff will continue monitoring costs and address local renewable energy and battery storage projects in the IRP scheduled for 2027. Mr. Crowley stated that resiliency planning must account for system damage that could prevent customers from accessing stored energy during an outage. Staff is considering rapid repairs, redundant facilities, and resilient infrastructure as part of grid modernization CIP planning and will identify relevant hazards and potential mitigation measures. Staff recommended continuing to monitor local utility-scale battery storage costs, Item #1     Packet Pg. 17     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 13 of 17 providing an update with the next IRP, and proposing reasonable hazard mitigation measures through recommended CIP projects. Item 4 Public Comment: None. Commissioner Metz asked what hazard mitigation measures staff anticipated proposing. Mr. Crowley identified potential measures addressing flooding and sea-level rise at the Colorado Substation, liquefaction and earthquake risks associated with new foundations, and capacity needs related to grid modernization. Staff would evaluate these and other hazards, including cybersecurity and pandemics, assess the costs and propose reasonable mitigation measures through the CIP budget. Chair Mauter inquired whether staff was requesting a motion supporting the recommendations. Mr. Crowley stated that staff was seeking clarification or advice regarding how to proceed. Commissioner Gupta sought clarification regarding whether the estimate of 300 homes assumed normal or reduced electricity use. Mr. Crowley stated that the estimate assumes normal customer usage and that reduced consumption could extend the duration or number of customers served. Mr. Crowley reiterated that battery storage would provide limited benefit if an event damaged the grid and prevented power from reaching customers. Commissioner Tucher requested clarification regarding Council's purpose in directing staff to engage the UAC on battery storage. Mr. Crowley recalled that Council was interested in exploring microgrids of varying sizes and the potential use of battery technology to provide long-duration resiliency. Mr. Crowley understood resiliency to be the sole focus of Council's direction. Commissioner Metz stated that the key question was what CPAU should be doing to prepare for long-term resilience. He supported continuing efforts to improve grid resilience, including grid modernization and improvements to the system's ability to remain connected to the transmission grid. He stated that CPAU should work towards long-term resilience in worst-case emergencies. Commissioner Metz stated that CPAU should first recognize the need to invest in electrical resilience and noted that the Water Utility already has emergency preparedness measures, such as wells and diesel generators. Commissioner Metz suggested working with the Office of Emergency Services (OES) to define the emergencies the Electric Utility should be prepared to address. He stated that OES has strong opinions regarding anticipated emergencies and their effects on the community, while CPAU has special domain knowledge regarding how emergencies such as fires, earthquakes, and floods could affect the electric utility. If CPAU could work together with OES, it would be very valuable for the community. Item #1     Packet Pg. 18     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 14 of 17 Commissioner Metz also recommended explicitly considering risk and developing scenarios for potential CPAU responses to a major emergency, including different levels of action. He suggested evaluating the benefits, risks, and costs of the alternatives and presenting them to the City Council and the community. Finally, he stated that CPAU should develop stronger internal competencies in emergency preparedness, reliability, and resilience, which he identified as important long-term strategic areas for the Utility. Commissioner Scharff expressed concern that the presentation did not clearly convey the scale and cost of battery storage or the specific resiliency problem it was intended to address. Commissioner Scharff questioned whether protection against a 24-hour outage would justify a multimillion-dollar investment and requested that staff provide Council with clearer cost information and identify the types and magnitude of outages the proposed resiliency measures would address. Vice Chair Phillips supported continued monitoring of battery costs and emerging technologies but questioned whether microgrids would play a significant role in a broader resiliency plan. Vice Chair Phillips supported staff's recommendation and encouraged continued coordination with the OES. Commissioner Croft supported clearly defining the resiliency goal, including whether battery storage would provide backup power broadly to residents or serve critical emergency needs. Commissioner Croft suggested that future analysis consider solar generation with battery storage for long-duration resiliency and evaluate whether batteries could provide economic benefits through energy arbitrage while providing backup power as an ancillary benefit. Commissioner Croft supported deferring investment while incorporating these issues into disaster mitigation planning and returning to the UAC with a clearer definition of the resiliency objectives. Commissioner Gupta agreed that battery storage was not currently cost-effective and emphasized near-term mitigation measures. Commissioner Gupta noted that residents may be unprepared for extended power outages and suggested increasing communication regarding emergency preparedness, particularly for residents dependent on medical devices or refrigerated medications, while staff continues monitoring battery costs. Commissioner Tucher supported staff's recommendation but suggested that Council consider a broader analysis of where large-scale battery storage could provide value in Palo Alto rather than focusing solely on resiliency. Commissioner Tucher referenced prior analysis of solar and storage applications and recommended evaluating where battery projects would be most beneficial and their value proposition. Commissioner Tucher requested that future staff reports provide additional context regarding Council's specific direction, including a link to the relevant Council discussion. Item #1     Packet Pg. 19     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 15 of 17 An informal poll indicated interest in moving a motion. Commissioner Metz proposed amending the motion to focus future efforts on what CPAU should be doing to achieve long-term resiliency. Commissioner Tucher proposed directing staff to return to the UAC with an analysis of potential large-scale battery applications, including substation and distributed installations with or without solar. Chair Mauter expressed concern that the proposal would direct specific staff work rather than provide policy guidance and supported framing the motion more broadly around long-term resiliency. The Commission further discussed and refined the motion language. MOTION: Vice Chair Phillips moved, seconded by Commissioner Scharff, to recommend the following 1. Staff continue monitoring and provide updated estimates for local utility scale battery storage and update the UAC with the next Integrated Resource Plan 2. Recommend staff review and propose reasonable hazard mitigations with recommended capital improvement projects 3. Recommend that the focus of future efforts should be what CPAU should do for long term resilience FRIENDLY AMENDMENT INCORPORATED INTO THE MOTION WITH THE CONSENT OF THE MAKER AND SECONDER MOTION PASSED: 7-0 ITEM 5: ACTION: City of Palo Alto Utilities Wildfire Mitigation Plan (WMP) 2026 Update: CEQA – Not a Project Utilities Chief Operating Officer Terry Crowley reported that the City is required by the Public Utilities Code to prepare a Utility Wildfire Mitigation Plan (WMP) focused on reducing the risk of utility-caused wildfires, present the plan at a public meeting, and receive public comments. The 2026 WMP is due to the California Wildfire Safety Advisory Board (WSAB) by October 2, 2026, with the next update due in October 2028. Palo Alto's highest-risk area identified by the California Public Utilities Commission (CPUC) is primarily in the Foothills, where high winds and low fuel moisture increase wildfire risk. Mr. Crowley identified undergrounding overhead electric lines as the City's primary wildfire mitigation measure, supplemented by vegetation management, equipment inspections and monitoring, public safety power shutoff policies, and customer education and notification. The City has completed 9 miles of undergrounding in the wildfire area, including the high-voltage lines, with remaining low-voltage connections to homes targeted for completion by the end of 2026. Future work includes establishing inspection and vegetation management practices for underground facilities, updating public safety power shutoff policies for the underground system, and evaluating additional mitigation Item #1     Packet Pg. 20     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 16 of 17 work adjacent to the wildfire area. Staff requested that the UAC review the WMP, receive public comments, and recommend submission of the plan to the California WSAB. Item 5 Public Comment: None. Commissioner Scharff inquired about using drones for vegetation management and utility inspections. Mr. Crowley stated that inspections are currently conducted visually from the road and that City use of drones for surveillance would require a policy or Council authorization. Utilities Director Alan Kurotori noted that undergrounding reduces the potential benefit of drones in the wildfire area but that drones can be used for substation and other inspection work. Mr. Kurotori reported that staff is evaluating use of drone surveillance. Vice Chair Phillips sought clarification regarding vegetation management for underground facilities. Mr. Crowley explained that vegetation must be maintained at least 3 feet from pad- mounted equipment and inspected for encroachment or debris following events such as heavy windstorms. Commissioner Croft requested that the WMP performance metrics on Packet Page 50 quantify the percentage of vegetation cleared and equipment inspected annually. Commissioner Croft questioned whether staff was comfortable submitting the existing public safety power shutoff (PSPS) plan given that it was developed for the overhead system. Mr. Crowley described the plan as a living document and stated that staff would continue revising the PSPS standard to reflect the underground system rather than relying on provisions that no longer fit current conditions. Mr. Kurotori reiterated that the remaining low-voltage lines would be undergrounded within a few months. Commissioner Croft commended staff on the milestone of de-energizing the overhead lines before the rainy season. MOTION: Vice Chair Phillips moved, seconded by Chair Mauter, to recommend the City of Palo Alto Utilities submit the 2026 Wildfire Mitigation Plan to the California Wildfire Safety Advisory Board (WSAB) in accordance with Public Utilities Code Section 8387. MOTION PASSED: 7-0 COMMISSIONER COMMENTS AND REPORTS FROM MEETINGS/EVENTS None. VIRTUAL PUBLIC COMMENT None. ADJOURNMENT Item #1     Packet Pg. 21     Utilities Advisory Commission Summary Minutes – September 2, 2026 Page 17 of 17 Chair Mauter noted that the 12-month rolling calendar was included in the packet and would be discussed the following month. The meeting adjourned at 9:49 p.m. Item #1     Packet Pg. 22     Item No. 2 Page 1 of 4 Utilities Advisory Commission Staff Report From: Alan Kurotori, Director Utilities Lead Department: Utilities Meeting Date: October 7, 2026 Report #: 2608-6657 TITLE Approval of Water and Wastewater Collection Rate Design Guidelines and Principles RECOMMENDATION Staff recommends that the Utilities Advisory Commission (UAC) recommend that the Council approve the Design Principles for Water and Wastewater Collection Rates in Alignment with Proposition 218 Cost of Service Analysis. EXECUTIVE SUMMARY Article XIII D of California Constitution (often referred to as Proposition 218, added in 1996) requires that the amount of a fee or charge imposed upon any parcel or person as an incident of property ownership shall not exceed the proportional cost of the service attributable to the parcel. Public agencies rely on ratemaking consultants to determine the costs of providing services and to design rates that accurately recover those costs; this is referred to as a “cost of service analysis”, or COSA. This report proposes design principles to guide staff and the City’s ratemaking consultants on Water and Wastewater Utility COSAs in alignment with California’s Constitutional requirements. BACKGROUND Periodically, the City of Palo Alto Utilities Department staff reviews and updates its COSAs in combination with other information to evaluate the adequacy and fairness of its rate structures. The Utilities Department plans to complete an updated Water COSA in Fiscal Year (FY) 2028. The COSA will assist staff in determining if new or modified rate structures should be considered in light of updated utility financial information and customer usage data while also ensuring compliance with Proposition 218 and other regulatory requirements. Given the upcoming Water COSA, this staff report focuses on Water Utility-specific considerations though the recommended rate design principles apply to both the Water and Wastewater Collection Item #2     Packet Pg. 23     Item No. 2 Page 2 of 4 Utilities. The recommendations are also consistent with the Council-approved rate design principles for the Electric and Gas Utilities1. 2, 20153 and 20194 to ensure continued compliance with Proposition 218. The most recent review in 2019 determined that the methodology and rate structure described in the 2012 COSA study remained fundamentally sound. In addition, it updated data and refined the analysis which resulted in several COSA adjustments. The constitutional requirements for existing, new or increased fees under Article XIII.D(b) include the following five factors: ANALYSIS 1 City Council Staff Report 2507-4958, September 15, 2025: https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=043abd5a-f59f-4702-ad04-845541a8133f 2 City Council Staff Report 2676, April 18, 2012: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=78511&dbid=0&repo=PaloAlto 3 City Council Staff Report 5951, August 17, 2015: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=86549&dbid=0&repo=PaloAlto&searchid=c0ca7cc0 -d00f-44e3-8af6-606737da65b9 4 City Council Staff Report 10295, June 17, 2019: Item #2     Packet Pg. 24     Item No. 2 Page 3 of 4 Each utility is operated as a separate enterprise; ratepayer funds are not comingled among enterprises. Rates cannot be structured solely to drive policy goals such as conservation; instead rates must be based on the utility’s cost of providing service. Item #2     Packet Pg. 25     Item No. 2 Page 4 of 4 FISCAL/RESOURCE IMPACT The work associated with this project will be absorbed using existing staff and contract budgets. STAKEHOLDER ENGAGEMENT After receiving the UAC’s recommendation, staff will present the Design Principles for Water Rates to the Finance Committee, followed by review and consideration by the City Council. If accepted by Council, staff will apply these Design Principles to the Water COSA which will be used to develop water rates, effective January 1, 2028. Additionally, if accepted by Council, staff will apply these Design Principles to the next Wastewater Collection Utility COSA. The most recent Wastewater Collection COSA was completed in 20219 and staff plans to complete an update in the next three to four years. ENVIRONMENTAL REVIEW Recommendation of rate Design Principles for Water and Wastewater Utilities does not meet the definition of a project, under Public Resources Code Section 21065 and CEQA Guidelines Section 15378(b)(5), because it is an administrative governmental activity which will not cause a direct or indirect physical change in the environment, thus no environmental review is required. AUTHOR/TITLE: Alan Kurotori, Director Utilities Staff: Adriana Artola, Senior Resource Planner 9 City Council Staff Report 12378, August 9, 2021: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=81558&dbid=0&repo=PaloAlto Item #2     Packet Pg. 26     Item No. 3 Page 1 of 5 1 0 4 9 0 Utilities Advisory Commission Staff Report From: Alan Kurotori, Director Utilities Lead Department: Utilities Meeting Date: October 7, 2026 Report #: 2609-6818 TITLE Electric Grid Modernization Bond Financing; Recommendation to the City Council to Adopt a Resolution Authorizing the Issuance and Sale of Tax-Exempt Electric Revenue Bonds Principal Amount Not-to-Exceed $100,000,000 RECOMMENDATION Staff recommend that the Utilities Advisory Commission (UAC) recommend that the City Council adopt a resolution authorizing the issuance and sale of tax-exempt Electric Revenue Bonds in a principal amount not to exceed $100,000,000 under the first tranche and authorize official actions and related documents thereto. EXECUTIVE SUMMARY The Electric Utility’s Electric Grid Modernization Project (Grid Mod) is a multi-year investment to improve reliability, support electrification, and replace aging infrastructure. Previous staff reports presented to the Utilities Advisory Commission (UAC) and City Council have outlined both the capital needs and long-term financial considerations of the Electric Utility. Staff recommends that the UAC recommend that the City Council authorize financing the Electric Grid Mod project through issuance of Electric Revenue Bonds. PROJECT DESCRIPTION The Electric Grid Modernization Project includes high-priority system upgrades identified in earlier UAC and Council briefings. Major components include: Replacement of aging transformers, switches, and distribution lines Feeder capacity expansion to support electrification and reduce overload risk Deployment of advanced automation and outage-management tools Infrastructure readiness for distributed energy resources Conversion of 4kV to 12kV systems to increase capacity and reliability Item #3     Packet Pg. 27     Item No. 3 Page 2 of 5 1 0 4 9 0 The project timeline is informed by technical assessments presented in the City’s Sustainability and Climate Action Plan1 and successive CIP updates BACKGROUND 2 including an electric capital improvement budget of roughly $206 million over five years (FY 2027 – FY 2031) for Electric Grid Modernization (Grid-Mod) Projects. City Council, June 15, 2026 – FY 2027 Electric Rates and CIP Budget City Council, May 4, 2026 – Electric Grid Modernization FY 2026 Update Climate Action & Sustainability Ad Hoc Committee, March 6, 2026 – Grid Modernization Update Utilities Advisory Commission, January 7, 2026 – FY 2026 Mid-Year Electric Grid Modernization Update City Council, December 16, 2024 – Adoption of a Resolution of Intention to Reimburse Expenditures for the Grid Modernization and Related Projects of the Electric Utility System Infrastructure from the Proceeds of Tax-Exempt Utility Revenue Bonds Finance Committee, October 20th – Electric Grid Mod Bond Authorization Approval Week of December 14th – Receive ratings from rating agencies City Council, December 7th – Electric Grid Mod Bond Authorization Approval Week of January 11th – Pricing Week of January 25th - Closing 3, the City Council adopted a resolution of intent to reimburse expenditures for Grid-Mod and related projects of the Electric Utility system infrastructure from the proceeds of tax-exempt utility revenue bonds. The resolution allows the City’s Utility enterprise fund to use bond proceeds to reimburse itself for certain pre-construction and construction costs within the scope of the Grid-Mod project that are incurred before the bonds are issued. The reimbursement of these expenditures would restore the Electric Fund’s 1 City of Palo Alto 2022 Sustainability and Climate Action Plan 2 FY 2027 Adopted Capital Budget (pp. 439 – 519) 3 City Council, December 16, 2024: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83165&dbid=0&repo=PaloAlto&searchid=ed2c3129 -ccb2-4781-8182-c461eb1a6b5d Item #3     Packet Pg. 28     Item No. 3 Page 3 of 5 1 0 4 9 0 reserve(s) and as of June 30, 2026, Grid-Mod project costs eligible for reimbursement by future bond proceeds total $27.1 million. These project costs are attributed to the following activities in Table 1. Table 1: Grid Mod Expenditures from Dec 19, 2024 – Jun 30, 2026 Description Amount Colorado Substation Master Plan $ 102,000 Distribution System Upgrade $ 272,000 Engineering Design $ 1,103,000 Line Clearing $ 314,000 Line Conversion $ 4,468,000 Overhead Construction $ 3,467,000 Pole Replacement $ 1,231,000 Transformer $ 7,103,000 Underground Construction $ 463,000 Warehouse Purchase $ 8,614,000 Grand Total $ 27,137,000 ANALYSIS Debt Structure, Policy, and Administration Item #3     Packet Pg. 29     Item No. 3 Page 4 of 5 1 0 4 9 0 execute a Bond Purchase Agreement. Interest rates on the 2027 Bonds will be determined on the pricing date and will reflect prevailing market conditions at that time. Table 2: Estimated Funding Results (rates as of September 23, 2026) Principal Amount of Bonds $98,050,000 True Interest Cost (TIC)4.80% All-In TIC 4.83% First Maturity 06-01-2028 Final Maturity 06-01-2057 7. Rating Agency Presentation Financing Mechanics FISCAL/RESOURCE IMPACT 7 California Debt and Investment Advisory Commission, California Debt Financing Guide: https://debtguide- api.treasurer.ca.gov/guide-pages/chapter-5-sale-of-municipal-debt/5-3-negotiated-public-offerings/5-3-1- advantages-of-a-negotiated-public-offering Item #3     Packet Pg. 30     Item No. 3 Page 5 of 5 1 0 4 9 0 sale date. The expenses associated with issuing the 2027 Bonds are estimated to be $0.6 million and will be paid with proceeds of the 2027 Bonds. STAKEHOLDER ENGAGEMENT 9, the Climate Action & Sustainability Committee (CASC) on March 6, 202610, and as an Informational Report to City Council on May 4, 2026Error! Bookmark not defined.. The Administrative Services, Utilities Department, City Attorney’s Office, and City Manager Office worked collaboratively to develop this debt financing strategy and on the required documents for this bond refinancing. ENVIRONMENTAL REVIEW ATTACHMENTS AUTHOR/TITLE: 9 Palo Alto Utility Advisory Commission, January 7, 2026: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85181&dbid=0&repo=PaloAlto 10 Climate Action & Sustainability Committee, March 6, 2026: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=86701&dbid=0&repo=PaloAlto Item #3     Packet Pg. 31     Resolution No. _____ Resolution of the Council of the City of Palo Alto Authorizing the Issuance and Sale of Electric Revenue Bonds to Finance the Electric Grid Modernization for Electrification Project, Approving an Electric Revenue Bond Indenture, a First Supplemental Electric Revenue Bond Indenture, a Bond Purchase Agreement and an Official Statement, and Authorizing Official Actions and Documents RECITALS WHEREAS, the City of Palo Alto (the “City”) is a chartered city and municipal corporation organized and existing under the constitution and laws of the State of California; the City is duly empowered as a chartered city to exercise the powers reserved to it under such constitution with respect to municipal affairs; and WHEREAS, as an exercise of such powers, the City has adopted the provisions of Chapter 12.28 (commencing with Section 12.28.010) of the Palo Alto Municipal Code (the "Bond Law") which authorize the City, when the public interest and necessity require, by resolution, to issue its revenue bonds for the purpose of financing or refinancing the acquisition, construction, extension or improvement of any utility enterprise system or facility of the City; and WHEREAS, the City furnishes electric utility service to its inhabitants, and owns and operates an electric system which includes facilities for the transmission and distribution of electric energy (the “Electric System”); and WHEREAS, the City has developed an Electric Grid Modernization for Electrification Project to increase distribution capacity, enhance grid resiliency and reliability of the electric distribution system, and to continue to accelerate the City’s clean energy and decarbonization goals; and WHEREAS, the City Council, after due investigation and deliberation, has determined that the public interest and necessity require the City at this time to authorize the issuance of its revenue bonds in the maximum principal amount of $_____ (the “Bonds”) under the Bond Law to finance the Electric Grid Modernization Project and pay certain costs of issuing the Bonds; and WHEREAS, the Bonds will be secured by a pledge of and lien on net revenues of the Electric System; and WHEREAS, staff has worked with the City’s financing team to prepare the necessary agreements and other documents, including a form of preliminary Official Statement to be distributed in connection with the marketing of the Bonds, and the City Council has reviewed the preliminary Official Statement to assure proper disclosure of all material facts relating to the Bonds that are in the personal knowledge of the members of the City Council and the City staff; and WHEREAS, the City proposes to sell the Bonds to J.P. Morgan (the “Underwriter”) pursuant to a Bond Purchase Agreement (the “Bond Purchase Agreement”) between the City and the Underwriter; and Item #3     Packet Pg. 32     -2- WHEREAS, in accordance with Government Code Section 5852.1, the City Council has obtained and wishes to disclose the information set forth in Exhibit A. NOW, THEREFORE, the Council of the City of Palo Alto does hereby RESOLVE, as follows: 1. Recitals. The Council hereby finds that the foregoing recitals are true and correct. 2. Authorization of the Bonds. The Council hereby authorizes the issuance of the Bonds under the Bond Law and the Indenture of Trust that is approved below, in a maximum principal amount of $_________. The Bonds shall be designated the “City of Palo Alto Electric Revenue Bonds, Series 2027,” or such other designation given them by an Authorized Official (as defined below). The Bonds shall be dated their date of issuance and mature no later than [to come]. The Bonds shall accrue interest at a fixed interest rate, and the principal of and interest on the Bonds shall be payable on the dates specified in the Indenture (defined below). The terms of redemption of the Bonds shall be set forth in the Indenture. 3. Sale of the Bonds. The Council hereby approves the sale of the Bonds by the City to the Underwriter pursuant to the terms and provisions of the Bond Purchase Agreement, provided that the aggregate principal amount of the Bonds may not exceed $_______, the true interest cost may not exceed ______% and the underwriter's discount (exclusive of any original issue discount) may not exceed ________%. 4. Bond Purchase Agreement. The City Council hereby approves the Bond Purchase Agreement, in substantially the form on file with the City Clerk, together with any changes therein or additions thereto deemed advisable by the City Manager, the Administrative Services Director or a designee appointed in writing by any such officer (the “Authorized Officials”; each, an “Authorized Official”), each acting alone. The Mayor or City Manager, acting alone, is hereby authorized and directed for and on behalf of the City to execute the final form of the Bond Purchase Agreement. Execution of the Bond Purchase Agreement by the Mayor or City Manager shall be conclusive evidence of the approval of the final form of the Bond Purchase Agreement. 5. Indenture of Trust. The Bonds shall be issued pursuant to an Electric Revenue Bond Indenture (the “Master Indenture”), as supplemented by a First Supplemental Electric Revenue Bond Indenture (“First Supplemental Indenture; together with the Master Indenture, the “Indenture”), each by and between the City and U.S. Bank Trust Company, National Association, as trustee (the "Trustee"). As provided in the Indenture, the Bonds shall be secured by the Electric Net Revenues (as that term is defined in the Indenture) of the Electric System. The Indenture, in substantially the form on file with the City Clerk, is hereby approved, together with any changes therein or additions thereto deemed advisable by an Authorized Official, acting alone. The final form of the Indenture shall be executed in the name and on behalf of the City by the Mayor or City Manager, and such execution shall be conclusive evidence of the approval of the final form of the Indenture. The City Clerk is hereby authorized and directed to attest to the Mayor or City Manager’s signature. Item #3     Packet Pg. 33     -3- 6. Preliminary Official Statement; Official Statement. Staff has caused to be prepared a preliminary Official Statement relating to the Bonds, a copy of which is on file with the City Clerk, for distribution to potential purchasers of the Bonds. The City Council hereby approves and deems nearly final within the meaning of Rule 15c2-12 of the Securities Exchange Act of 1934 (the “Rule”) the preliminary Official Statement describing the Bonds, in the form on file with the City Clerk, together with such modifications thereof as may be approved by an Authorized Official after consultation with Stradling Yocca Carlson & Rauth LLP (“Disclosure Counsel”), the Municipal Advisor, the Bond Counsel and the City Attorney. An Authorized Official is hereby authorized to execute an appropriate certificate stating the Council's determination that the preliminary Official Statement has been deemed nearly final within the meaning of the Rule. The Underwriter is hereby authorized and directed to distribute the preliminary Official Statement to prospective bidders for the Bonds. The Authorized Officials, each acting alone, are hereby authorized and directed, upon consultation with the Municipal Advisor, Disclosure Counsel, Bond Counsel and the City Attorney, to approve such changes to the preliminary Official Statement as shall be necessary to cause such preliminary Official Statement to be brought into the form of a final Official Statement, and an Authorized Official, acting alone, is hereby authorized and directed to execute and deliver the final Official Statement to the Underwriter, at the time of delivery of the Bonds. 7. Continuing Disclosure Certificate. The City Council hereby approves the Continuing Disclosure Certificate, pursuant to which the City will agree to provide certain information on a continuing basis, in substantially the form on file with the City Clerk, together with any changes therein or additions thereto deemed advisable by an Authorized Official, acting alone. The Mayor or City Manager, acting alone, is hereby authorized and directed for and on behalf of the City to execute the final form of the Continuing Disclosure Certificate. Execution of the Continuing Disclosure Certificate by the Mayor or City Manager shall be conclusive evidence of the approval of the final form of the Continuing Disclosure Certificate. 8. Preparation of Bonds. The Director of Administrative Services (or their designee) is directed to cause the Bonds to be prepared in the form set forth in, and in accordance with the provisions of, the Indenture of Trust and to cause their execution by the proper officers of the City and authentication by the Trustee, and to cause the Bonds to be delivered when so executed and authenticated to or on behalf of the purchaser or purchasers thereof, upon the receipt of the purchase price therefor. 9. Additional Authority. The Mayor, Vice Mayor, City Manager, City Clerk, Director of Administrative Services, Director of Utilities, Director of Public Works, City Attorney and any and all other officers of the City, each acting alone, are authorized and directed in the name and on behalf of the City to execute and deliver any and all certificates, requisitions, agreements, notices, consents, warrants and other documents, which they or any of them might deem necessary or appropriate in order to consummate the lawful issuance, sale and delivery of the Bonds to the original purchaser thereof. Item #3     Packet Pg. 34     -4- 10. Exemption from CEQA. The City Council finds that this resolution and the issuance of the Bonds are not projects under Section 21065 of the California Environmental Quality Act. [confirm] 11. Effective Date. This resolution shall be effective upon the date of its adoption. * * * * * * INTRODUCED: PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: _________________________________ City Clerk APPROVED AS TO FORM: By: Chief Assistant City Attorney By: Christopher K. Lynch, Bond Counsel APPROVED: _________________________________ Mayor APPROVED AS TO CONTENT: City Manager Director of Utilities Director of Administrative Services Item #3     Packet Pg. 35     EXHIBIT A GOVERNMENT CODE SECTION 5852.1 DISCLOSURE The following information consists of estimates that have been provided by the Municipal Advisor, which has been represented by such party to have been provided in good faith: (A) True Interest Cost with respect to the Bonds: ______%. (B) Finance Charge with respect to the Bonds (Sum of all fees paid to third parties): $_______. (C) Net Proceeds to be Received from the sale of the Bonds (net of finance charges, reserves and capitalized interest, if any): $________. (D) Total Payment Amount Through Maturity: $________. The foregoing estimates constitute good faith estimates based on a refinancing of the 2009 Bonds. The principal amount of the Bonds, the true interest cost of the Bonds, the finance charges thereof, the amount of proceeds received therefrom and total payment amount with respect thereto may differ from such good faith estimates due to (a) the actual date of the sale of the Bonds being different than the date assumed for purposes of such estimates, (b) the actual principal amount of Bonds sold being different from the estimated amount used for purposes of such estimates, (c) the actual amortization of the Bonds being different than the amortization assumed for purposes of such estimates, (d) the actual market interest rates at the time of sale of the Bonds being different than those estimated for purposes of such estimates, (e) other market conditions, (f) alterations in the City’s financing plan, or a combination of such factors and (g) the treatment of the interest with respect to the Bonds under federal tax law. The actual date of sale of the Bonds and the actual principal amount of Bonds sold will be determined by the City based on the timing of the need for proceeds of the Bonds and other factors. The actual interest rates borne by the Bonds will depend on market interest rates at the time of sale thereof. The actual amortization of the Bonds will also depend, in part, on market interest rates at the time of sale thereof. Market interest rates are affected by economic and other factors beyond the control of the City. Item #3     Packet Pg. 36     Utilities Advisory Commission Staff Report Report Type: NEW BUSINESS Lead Department: Utilities Meeting Date: October 7, 2026 Report #:2609-6805 TITLE Recommending Approval of Updated Palo Alto Low Carbon Fuel Standards Program Guidelines, including a Definition for Low-Income and a Methodology to Allocate Customer Program Cost Across Low-Income and Non-Low-Income This item will be a late packet publication on 10/1/26. Item #4 Packet Pg. 37 12-MONTH ROLLING CALENDAR FORECAST *Numbers at the end of titles correspond with Workplan line City Council CCM – City Council Meeting FCM – Finance Committee Meeting 2026 October 7, 2026 •Water Cost of Service Analysis Guidelines (#3) •Bond Financing for Grid Modernization Project (#14) •Palo Alto Low Carbon Fuel Standards Program Update (#10) •Informational Report - Time of Use Update (#8) •Informational Report - Preliminary Electric Utility Contract Policies for Data Centers or • •Recommend Approval of Bond Financing for Grid Modernization Project (FCM) •Update on Electric System Long Duration Resiliency (CASC) 2026 November 4, 2026 •FY 2028 Preliminary Rates (#3) •Reserve Policy Recommendations for Wastewater Collection and Rate Stabilization for All Utilities (#4) •Utilities Legislative & Regulatory Updates (#11) •Informational Report - Customer Communication Programs, Activities and Methods (#12) •Informational Report - Dahl and Park Storage Reservoir Condition Assessment (#2) •Electric Long Duration Resiliency •Transmission Agency of Northern California Contract Modifications •Veolia Contract for Efficiency and Electrification Program •Accent Gold Contract for Customer Program Management •Purchase and Installation of Security Cameras at Bayshore Warehouse and Substations •Woodard and Curran Contract for Hydraulic Modeling Support •Utilities Reserve Management Policies (FCM) •Water Cost of Service Guidelines and Principles (FCM) •Legislative Guidelines, Utilities Legislative Guidelines, Legislative/Regulatory Updates (PS) •Muni Code Change to Allow Power Purchasing Agreements November 16, 2026 • 2026 December 2, 2026 •Review of Electric Supply Portfolio Carbon Neutral Plan and Use of Revenues Derived from the REC Exchange Program (#10) •Study Results from CASC and UAC June 12, 2026 Joint Meeting "Evaluating Strategies for Community Wide Electrification" (#10) •Discussion on Utilities Quarterly Report FY26 – Q4 •Fiber Expansion and Fiber to the Premises (FTTP) Update (#6) •Informational Report - Annual Review of the City’s Renewable Procurement Plan, Renewable Portfolio Standard Compliance, and Carbon • •Approval of Water Cost of Service Guidelines and Principles •Approval of Bond Financing for Grid Modernization Project •Informational Report on FY 2026 Cap and Trade Program •Informational Report - Annual Review of the City’s Renewable Procurement Plan, Renewable Portfolio Standard Compliance, and Carbon Neutral Electric Supplies for 2025 •Informational Report – Utilities Quarterly Report FY26-Q4 2027 January 6, 2027 •5 Year Capital Improvement Project (Includes Treatment Plant and Grid Modernization) (#5) •Utility Legislative Guidelines (#11) •Gas Transition Study (#1) •Informational Report – Utilities Quarterly • •Informational Report – Utilities Quarterly Report FY27-Q1 Future Topics for Upcoming Meetings Packet Pg. 38 February 2027 February 3, 2027 •Electric Utility Business Strategy (#15) •Interim update on Electric Supply Costs (3/02/26 Council Action minutes) (#9) •Customer Satisfaction Results, Outreach Method, and New Initiatives from Key Accounts and Businesses (#12) •Fiber Expansion and FTTP Update (#6) March 2027 March 3, 2027 (Estimated 1.5hrs) •FY2028 Water Rates, 5 Year Forecast, and Cost of Service Analysis (#3) •FY2028 Wastewater Rates and 5 Year Forecasts • Analysis (FCM) •FY2028 Wastewater Rates and 5 Year Forecasts (FCM) •Fiber Expansion and FTTP Update (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 Next Steps (#6) •Informational Report – Utilities Quarterly • •FY2028 Gas Rates and 5 Year Forecasts (FCM) •FY2028 Fiber Rates and 5 Year Forecasts and Next Steps (FCM) •Informational Report – Utilities Quarterly Report FY27-Q2 May 5, 2027 •FY2028 Utilities Operating and CIP Budget (#3) •Election of the UAC Chair and Vice Chair FY2028 Utilities Operating and CIP Budget (FCM) June 2027 June 2, 2027 •UAC Workplan • •FY 2028 Utilities Operating and CIP Budget July 2027 July 7, 2027 (potential break) •Informational Report – Utilities Quarterly COUNCIL SUMMER BREAK August 4, 2027 • September 1, 2027 Council Recap on Utilities Items – September 2026 Approved By Council: •Adopt a Resolution approving the City of Palo Alto Utilities Electric Utility Physical Security Plan Update •Refinancing of the 2009A Water Revenue Bonds, Series A; Adoption of a Resolution Authorizing the Issuance and Sale of Tax-Exempt Water Revenue Refunding Bonds in a Principal Amount Not-to-Exceed $20,000,000, Approval of the Official Notice of Sale, Indenture of Trust, Official Statement, Irrevocable Refunding Instructions, and •Approval of Contract Number C27197641 with A3 Pipeline in the Amount Not-to-Exceed $2,466,255 for the Sewer Lateral Replacement Project (WC-99013) at various locations across the City; Authorization for the City Manager or Designee to Negotiate and Execute Related Change Orders Not-to-Exceed $246,626 for a Total Not-to-Exceed Amount of $2,712,881 for a Three-Year Term. Work Plan Items to Be Scheduled Items to Be Scheduled • •Upcoming Power Purchasing Agreements (#9) 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 Future Topics for Upcoming Meetings Packet Pg. 39 Item B. Page 1 of 4 Utilities Advisory Commission Staff Report From: Alan Kurotori, Director Utilities Lead Department: Utilities Meeting Date: October 7, 2026 Report #: 2606-6502 TITLE Informational Report on Framework for Data Center Capacity Reservation and Cost Recovery RECOMMENDATION This is an informational report and no action is needed by the Utilities Advisory Commission. EXECUTIVE SUMMARY Electric Utility staff are seeing an increase in the number of applicants requesting to connect to Palo Alto’s electric system to serve large computational loads. These applicants are not the typical large data centers seen in other jurisdictions; they are seeking service for smaller loads focused on product research and development. The increased number of projects will impact available electric system capacity, sub-transmission and substation capacity. Staff are developing a framework for managing requests for electric system capacity for specific projects, including a capacity reservation agreement and associated capacity reservation fee. The framework under development would provide a voluntary process for committed developers of new or expanded loads greater than 2.5 megawatts (MW) to secure capacity for projects in the early concept phase, as well as provide a formalized process for staff to track and equitably manage available system capacity. At base, the capacity reservation agreement would provide a limited-term guarantee of electric capacity availability in exchange for payment of a non-refundable capacity-reservation fee. BACKGROUND The City of Palo Alto has seen growing requests to serve research and development loads, such as small (boutique) data centers. While these loads are relatively small from a utility industry perspective, within Palo Alto they are often competing for existing electric system capacity, creating a need to formalize the allocation and reservation of electric system capacity to interested developers and property owners. Palo Alto’s Planning & Development Department implements the City’s adopted policies for development within the City. Planning Department staff would explore developing objective Item #B     Packet Pg. 40     Item B. Page 2 of 4 measurable standards for data centers or similar research and development facilities if directed by City Council. While Planning design guidelines and permitting requirements are outside of the purview of the Utilities Advisory Commission, it’s informative to understand limits being considered. If directed Planning Staff would consider the following restrictions for commercial and industrial facilities that may house full or partial data centers; these would need to be further vetted through the Planning and Transportation Commission and City Council. Palo Alto Building Height & Equipment screening requirement1 (existing) Backup generation (Tier II or Tier III as required by Bay Area Air District (existing) Palo Alto Noise Ordinances2 (existing) Closed loop water system or recycled water (in development) Aesthetics (in development) Parking (in development) Equitable contributions to the community (in development) ANALYSIS 1 City of Palo Alto Municipal Code Zoning General Standards and Exceptions https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-80178 2 City of Palo Alto Municipal Code Title 9 - Public Peace, Morals, and Safety https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-66052 Item #B     Packet Pg. 41     Item B. Page 3 of 4 2) “Will Serve” letter: Electric Utility staff issues this after determining that the proposed project is in City of Palo Alto Utilities (CPAU) service territory, making clear that additional system studies may be needed to determine what facilities are needed to provide the requested capacity, and the associated costs; 5. Item Description Value 5 Under Palo Alto’s Utility Rule and Regulation 20, customers can request additional facilities beyond what the City deems necessary to serve their load. When requested the ongoing costs of these facilities are recovered through a special facilities agreement. Special Facilities agreements can accommodate customers who wish to reserve additional system capacity beyond their current monthly demands (planned growth or ramping of usage over time). Item #B     Packet Pg. 42     Item B. Page 4 of 4 In administration of the agreement and fee, the capacity fee remain non-refundable and as developers execute cost recovery agreements, capacity fees paid may be used to offset electric infrastructure costs that would otherwise be paid to the City for design and installation of electric infrastructure necessary to offer the new or expanded service. The fee would require a financial commitment from an applicant seeking to reserve capacity and would remain non- refundable. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT 7). The UAC’s overall message was to mitigate risks while exploring data center opportunities and asked about next steps, including whether staff would pursue outreach, develop a plan, or bring recommendations to the City Council. Director Kurotori responded that staff will continue evaluating expectations and community concerns, including noise and aesthetics, and may coordinate with other departments on potential permitting approaches to provide clarity for prospective projects. ENVIRONMENTAL REVIEW ATTACHMENTS AUTHOR/TITLE: 7Utilities Advisory Commission Meeting February 4, 2026: Background and Discussion on Data Centers in Palo Alto https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=c5a04a11-8a1a-4ce8-a339- 34e23c788430 Item #B     Packet Pg. 43     Item C. Page 1 of 15 Utilities Advisory Commission Staff Report From: Alan Kurotori, Director Utilities Lead Department: Utilities Meeting Date: October 7, 2026 Report #: 2609-6819 TITLE Informational Update on Voluntary Residential Time-of-Use Electric Rate Enrollment and Customer Outreach RECOMMENDATION This is an informational report for the Utilities Advisory Commission (UAC) on implementation of the voluntary residential Time-of-Use (TOU) electric rate schedule (E-1 TOU), including customer enrollment, billing system and customer portal testing, electricity usage patterns, customer experience and the Utilities Department's expanded marketing and outreach strategy, which began in September 2026. No action is required. EXECUTIVE SUMMARY This report provides an interim update on the implementation and customer enrollment in the Residential E-1-TOU rate in response to the Utilities Advisory Commission’s (UAC) interest in including an update on the E-1-TOU rate implementation in the UAC’s workplan.1 The report presents preliminary analysis of customer behavior and load shifting changes, bill impacts and experiences, and planned marketing and outreach for continuing customer enrollment in the TOU rate. An initial set of seven customers have approximately six months of billing data available since enrolling in the E-1-TOU rate. Given the limited number of participants and duration of the data available, the results are preliminary and provided for informational purposes only. As of the early September, the number of residential customers enrolled in the E-1-TOU rate has grown to 96 without any widescale publicity. Staff began broadly marketing the TOU rate to the community in September and anticipate there may be a potential 300- 400 enrollees by the end of the 2026 calendar year. Preliminary observations for the initial seven participants indicate that peak period consumption is lower post 1 The UAC’s FY 2027 Draft Workplan line #8 includes the objective to review and evaluate preliminary results of the E-1-T time of use rate pilot, changes in energy usage patterns and financial impacts to customers and utility to inform further implementation to the full Palo Alto community. Item #C     Packet Pg. 44     Item C. Page 2 of 15 enrollment in the E-1-TOU rate compared with the same customer’s usage for the same months one year prior. Additionally, preliminary results indicate that customers with low overall electricity usage and little opportunity to shift load to different times of day do not experience bill savings under the E-1-TOU rate. However, preliminary results for the first seven customers indicate that customers with higher overall electricity use and who are able to shift load, such as EV charging, into off-peak hours are most likely to experience bill savings with the E-1-TOU rate. These results are preliminary and need to be analyzed with a larger sample size over a longer time period to attribute the changes to the E-1-TOU rate. Survey results reinforce the value of providing customers with clear information about who may benefit financially from TOU rates and how customers can manage their electricity consumption. BACKGROUND 3 The TOU rate provides City of Palo Alto Utilities residential customers with separately metered, Advanced Metering Infrastructure (AMI), with an alternative to the city's existing electric rate. The TOU rate aligns with the requirements of Article XIII C of the California Constitution, often referred to as Proposition 26, and provides customers with the opportunity to take advantage of lower-cost and lower carbon intensity time periods for electric vehicle charging or other electric uses. 4, most carbon intensive grid electric supply, as well as distribution system and residential class peak demand. Conversely, super off-peak TOU rates for electricity are from 9 a.m. - 3 p.m. every day. These are the solar production hours when electricity has the lowest marginal cost, and the lowest carbon intensity. The off-peak rates are charged from 3 p.m.- 4 p.m. and 9 p.m. – 9 a.m. as these rates are between the peak and super off-peak rates. 3 Staff Report 2505-4750; https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=031339b2- 900e-422e-96c0-b5a0be11056b 4 The electricity price changes every hour in the market place, this is the marginal energy cost. Item #C     Packet Pg. 45     Item C. Page 3 of 15 Staff presented the TOU implementation and communications plan to the UAC on October 1, 2025.7 Since then, staff finalized the outreach and marketing materials for the E-1-TOU rate, taking into account the feedback from UAC Commissioners. In February 2026, the city began enrolling a small number of customers to beta test the implementation of the new rate in the utilities billing system, identify and resolve implementation issues, evaluate customer experience, and gather feedback from early adopters before conducting broader outreach. Since then, the Utilities Department has continued a phased approach to launching the voluntary TOU rate. Beta test the E-1 TOU rate in the utilities billing system; Confirm that customers are correctly enrolled and billed; Evaluate customer-facing information and the MyCPAU customer portal; Identify and resolve implementation issues before expanding enrollment; Gather feedback from early-adopter customers; Analyze customer electric usage patterns and potential bill impacts; and Use lessons learned to improve customer education and outreach materials. 8 Enrollment has grown steadily from seven customers in February 2026 to 96 customers as of the beginning of September 2026. The initial enrollment period has provided staff with valuable operational experience. 7 Staff Report 2508-5128; UAC report dated October 1, 2025 (page 73 of 125) https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=11770&dbid=0&repo=PaloAlto&searchid=7d626dac -8a01-4981-9e35-6c66b9187096 8 Staff Report 2605-6329; UAC report dated June 3, 2026 (page 16 of 64) https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=896997&dbid=0&repo=PaloAlto&searchid=7d626d ac-8a01-4981-9e35-6c66b9187096 Item #C     Packet Pg. 46     Item C. Page 4 of 15 Figure 1: Illustration of TOU Rate 11 ANALYSIS 12 The report presents preliminary analysis of customer behavior and load shifting changes, bill impacts and experiences, and planned marketing and outreach for 11 Customers who enroll in the TOU rate must remain enrolled for a minimum period of six months. If a customer decides to switch back to the standard residential electric rate, they cannot return to the TOU rate for another 12 months. These restrictions are designed to lower administrative burden and prevent customers from frequently switching to a rate that benefits them financially (e.g. if certain seasonal usage is beneficial under one rate and the next seasonal usage beneficial under the second rate). 12 The UAC’s FY 2027 Draft Workplan line #8 includes the objective to review and evaluate preliminary results of the E-1-T time of use rate pilot, changes in energy usage patterns and financial impacts to customers and utility to inform further implementation to the full Palo Alto community. Item #C     Packet Pg. 47     Item C. Page 5 of 15 continuing customer enrollment in the TOU rate. An initial set of seven customers have approximately six months of billing data available since enrolling in the E-1-TOU rate. Given the limited number of participants and duration of the data available, the results are preliminary and provided for informational purposes only. BACKGROUND 15 The TOU rate provides City of Palo Alto Utilities residential customers with separately metered, Advanced Metering Infrastructure (AMI), with an alternative to the city's existing electric rate. The TOU rate aligns with the requirements of Article XIII C of the California Constitution, often referred to as Proposition 26, and provides customers with the opportunity to take advantage of lower-cost and lower carbon intensity time periods for electric vehicle charging or other electric uses. 16, most carbon intensive grid electric 15 Staff Report 2505-4750; https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=031339b2- 900e-422e-96c0-b5a0be11056b 16 The electricity price changes every hour in the market place, this is the marginal energy cost. Item #C     Packet Pg. 48     Item C. Page 6 of 15 supply, as well as distribution system and residential class peak demand. Conversely, super off-peak TOU rates for electricity are from 9 a.m. - 3 p.m. every day. These are the solar production hours when electricity has the lowest marginal cost, and the lowest carbon intensity. The off-peak rates are charged from 3 p.m.- 4 p.m. and 9 p.m. – 9 a.m. as these rates are between the peak and super off-peak rates. 19 Since then, staff finalized the outreach and marketing materials for the E-1-TOU rate, taking into account the feedback from UAC Commissioners. In February 2026, the city began enrolling a small number of customers to beta test the implementation of the new rate in the utilities billing system, identify and resolve implementation issues, evaluate customer experience, and gather feedback from early adopters before conducting broader outreach. Since then, the Utilities Department has continued a phased approach to launching the voluntary TOU rate. Beta test the E-1 TOU rate in the utilities billing system; Confirm that customers are correctly enrolled and billed; Evaluate customer-facing information and the MyCPAU customer portal; Identify and resolve implementation issues before expanding enrollment; Gather feedback from early-adopter customers; Analyze customer electric usage patterns and potential bill impacts; and Use lessons learned to improve customer education and outreach materials. 20 Enrollment has grown steadily from seven customers in February 2026 to 96 customers as of the beginning of September 2026. The initial enrollment period has provided staff with valuable operational experience. 19 Staff Report 2508-5128; UAC report dated October 1, 2025 (page 73 of 125) https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=11770&dbid=0&repo=PaloAlto&searchid=7d626dac -8a01-4981-9e35-6c66b9187096 20 Staff Report 2605-6329; UAC report dated June 3, 2026 (page 16 of 64) https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=896997&dbid=0&repo=PaloAlto&searchid=7d626d ac-8a01-4981-9e35-6c66b9187096 Item #C     Packet Pg. 49     Item C. Page 7 of 15 Figure 1: Illustration of TOU Rate In September 2026, the city transitioned from the initial low-profile TOU enrollment and testing phase to a broader customer marketing and outreach campaign. The campaign aims to employ a comprehensive communication approach to increase customer awareness, explain how the rate schedule works, help customers determine whether the rate may be appropriate for their household, and encourage customers to shift electricity use away from peak period to super off-peak and off-peak hours. Because E-1 TOU is voluntary, some customers may enroll in TOU, determine that the rate does not provide sufficient financial benefit for their household, and return to the standard rate after meeting the minimum participation requirement.23 DISCUSSION In February 2026 staff enrolled seven customers, verified the customers were accurately billed in March, then subsequently enrolled three customers in April, and four in May. After adjusting for a few billing system integration challenges that affected customer electric consumption data in the MyCPAU portal display, staff increased enrollment to about 20 customers per month from June through August. The pace of enrollment is likely to accelerate, as staff began a 23 Customers who enroll in the TOU rate must remain enrolled for a minimum period of six months. If a customer decides to switch back to the standard residential electric rate, they cannot return to the TOU rate for another 12 months. These restrictions are designed to lower administrative burden and prevent customers from frequently switching to a rate that benefits them financially (e.g. if certain seasonal usage is beneficial under one rate and the next seasonal usage beneficial under the second rate). Item #C     Packet Pg. 50     Item C. Page 8 of 15 dedicated marketing campaign in September. Figure 2 illustrates the cumulative number of customers on the TOU rate as of end of August. Figure 2: Cumulative Number of Customers Enrolled in E-1 TOU Rate by Month in 2026 Item #C     Packet Pg. 51     Item C. Page 9 of 15 Figure 3: Customer Electricity Usage Patterns (March 2026 to August 2026) Item #C     Packet Pg. 52     Item C. Page 10 of 15 Figure 4: Comparison of Consumption Patterns (March to August 2026 vs. 2025) *Note: AMI-based consumption data for Customer #1 is available only from July 2025, as reflected in Figure 2. The total consumption shown in the figure excludes Customer #1. Early Customer Bill Analysis Staff analyzed customer bills to gauge the impact on customer bills of switching from the City’s standard electric rates to the TOU rate. The preliminary findings indicate: 1. Customers with lower overall electricity use generally do not experience financial savings under the TOU rate. 2. Customers with higher overall electricity use and with a very large percentage of electricity usage outside of peak hours, tend to experience modest savings of approximately 1% to 5%, or $1 to $8 per month. 3. Customer circumstances and electric use patterns vary significantly, reinforcing the importance of helping customers understand their individual usage before deciding to enroll in TOU. Table 1 shows the bill analysis for the first seven customer enrollees in the E-1-TOU Rate. Item #C     Packet Pg. 53     Item C. Page 11 of 15 Table 1. Utility Bill Analysis of the First Seven Customers Enrolled in the TOU Rate Customer 6, with a high monthly energy load and low consumption during peak hours, saved the most money by switching to TOU. Customer 5 also has a similar profile. Customer 1 and 2 had low consumption, which fall in the lower cost tier of the standard rate, hence their bill under the TOU rate is higher25. A simulated bill comparison for the July 2025 to June 2026 period for 68* customers who were enrolled as of August showed, for 25 customers the TOU bill would have been lower by $7.60/month on average, and for 43 customers the TOU bill would have been higher by $4.20/month on average. The corresponding average monthly electricity use was 1,110 kWh and 640 kWh respectively, further illustrating that high usage customers tend to gain more by switching and low usage customers do not save money by switching. Note that this analysis assumes no behavior change after switching to the TOU rate for most of the data points. 25 TOU rate is designed to collect the average rate for the residential class; this is higher than the Tier 1 rate and lower than the Tier 2 rate. Customer Average Monthly Consumption (kWh) Average Monthly Bill E1-TOU ($) Average Monthly Bill E1-Tiered ($) Average Monthly Bill Decrease/ (increase) under TOU ($) Percentage Change Customer#1 340.57 79.31 75.20 (4.10) -5% Customer#2 410.77 93.78 90.25 (3.53) -4% Customer#3 735.48 160.41 163.20 2.79 2% Customer#4 545.19 119.70 120.44 0.73 1% Customer#5 560.38 117.59 123.05 5.45 5% Customer#6 723.43 152.28 160.44 8.15 5% Customer#7 510.52 111.63 111.59 (0.05) 0% Item #C     Packet Pg. 54     Item C. Page 12 of 15 Figure 5: Variation of Bill Differential with Electricity Consumption for 68* Customers Enrolled (simulated comparative bills for the period July 2025 to June 2026, presented on an average/month basis) *Of the 74 customers enrolled only 68 customers had AMI data going back to July 2025 Customer Feedback and Survey Results Staff conducted a survey of the seven initial participants in March/April 2026. Four customers responded, and feedback was generally positive. Participants indicated that communication about the TOU rate was helpful, and respondents demonstrated awareness of technologies that can help automatically manage electricity use. Responses regarding bill impacts were mixed. Two customers reported no meaningful impact on their bills, while one customer reported that their bill had decreased. Survey respondents also highlighted that the TOU rate may not be equally advantageous for all households. One participant was hesitant to recommend the rate because they believed the schedule might not work as well for families whose daily routines do not allow them to switch energy usage to lower-cost periods. Staff distributed a second survey to participating customers in mid-August 2026 and received eight responses. The feedback generally reinforces the value of providing customers with clear information about who may save money from TOU rates and how customers can manage their electricity consumption. Selected comments have helped staff understand how to refine messaging through the broader outreach campaign, including: Item #C     Packet Pg. 55     Item C. Page 13 of 15 Providing clearer information about what the TOU rate is, and when it was implemented. One customer had moved to Palo Alto from a different city and thought TOU was the standard electric rate. Clearly explaining when customers can change back to the standard residential electric rate. Highlighting the benefits of TOU for customers with electric vehicles who have greater flexibility to shift charging to lower-cost periods. Staff will continue to monitor customer enrollment, retention, behavior changes, bill impacts, and feedback to identify opportunities for additional education and refinements. A complete summary of the April and August survey results is provided in Attachment B. Customer Marketing and Outreach During the initial implementation period, the Utilities Department intentionally used lower- profile communications channels, such as word of mouth, to introduce the TOU rate while the billing system was being tested and staff gained experience with customer questions. This approach allowed staff to refine messaging before promoting the rate to a larger audience. Utilities staff also used community engagement opportunities at outreach events to share information on the TOU rate and gather informal feedback. With the initial billing system beta testing substantially complete and 74 customers enrolled as of the end of August, staff began a more comprehensive marketing and outreach effort in September 2026. The purpose of the expanded campaign is not simply to increase enrollment, but to increase informed enrollment. Communications will focus on helping customers understand whether the TOU rate may be a good fit for their household and what actions they can take to maximize potential savings. Educational materials will explain TOU pricing and peak periods, and practical examples of ways customers can shift electricity use to lower-cost periods. Messaging will emphasize that the TOU rate is voluntary and that customer results will vary. Messaging will inform customers that they can use Advanced Metering Infrastructure (AMI) data on the MyCPAU portal to better understand when they are using energy and modify their consumption behaviors to shift electricity usage to super off-peak and off-peak hours. Messaging will also highlight the benefits for customers who may have greater flexibility to shift electricity use, including households with electric vehicles, battery storage, smart appliances, electric water heating, or other controllable loads. Customer communication methods are expected to include: Utility bill inserts and bill messaging; Direct customer communications; Customer feedback surveys; Item #C     Packet Pg. 56     Item C. Page 14 of 15 City and Utilities residential newsletters; Website (www.paloalto.gov/timeofuse) with frequently asked questions; MyCPAU information; Social media and Nextdoor; Flyers and brochures; Videos; Advertisements in local media publications; Community events and outreach opportunities; Updates for the UAC and City Council. In addition to regular circulation of marketing materials, staff will attempt to engage local media publications for coverage and advertisements, which have a broad print and digital audience reach of tens of thousands of readers. Table 2 provides an overview of planned outreach activities, the approximate number of Palo Alto residents reached through each venue, and the frequency of those communications. Samples of outreach materials are provided in Attachment C. Table 2: Customer Communication and Outreach Methods Anticipated Outcomes The broader outreach campaign is expected to substantially increase awareness and participation in the TOU rate. Based on the planned marketing effort and current enrollment trajectory, staff project that 300 to 400 residential customers could be enrolled by the end of 2026. The expanded enrollment will provide several benefits beyond increasing participation, including providing more representative data for evaluating bill impacts across different levels and patterns of electricity consumption. As additional customers participate for longer periods, staff will be able to better assess whether TOU pricing results in measurable changes in when customers use electricity. Impact on utility sales revenue and utility costs to purchase electricity will also be assessed. Customer questions and survey responses will continue to inform refinements to outreach materials and messaging, helping to provide clearer information about the rate, potential benefits, limitations, and enrollment requirements. Expanded enrollment should also provide Communication Method Estimated Reach % of Residential Accounts Frequency Residential Utility Bill Inserts 26,428 100% Monthly Utilities and Community Announcements on Bill 26, 428 100% Monthly Utilities Subscriber Email Newsletter 11,000 42% 1-2x/month MyCPAU Portal Messaging (residential users) 22,647 86% Ongoing Website (paloalto.gov/timeofuse) 2,677 10% Ongoing Social Media and Nextdoor (followers) 7,038 27% 1-2x/month Community Outreach Events and Workshops 4,000 15% 30-50/year Item #C     Packet Pg. 57     Item C. Page 15 of 15 Utilities with an improved understanding of which customers save money on the TOU rate. Over time, staff will be able to better identify customer characteristics and usage patterns associated with financial savings and successful participation. Results from the broader enrollment period will guide decisions on additional targeted outreach and customer tools or program modifications that could improve the effectiveness of the voluntary TOU rate. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS AUTHOR/TITLE: Item #C     Packet Pg. 58     1 2 6 1 7 Attachment A: Screenshots of MyCPAU Customer Portal Displays OPENING SCREEN DAILY CONSUMPTION PATTERN Item #C     Packet Pg. 59     1 2 6 1 7 HOURLY CONSUMPTION PATTERN Item #C     Packet Pg. 60     1 2 6 1 5 Attachment B: Customer Survey Results Shown below is a compilation of 4 survey responses received March-May and 8 survey responses received in August through early Sept 2026. Open-ended comments from survey respondents: o I didn't know what I didn't know about TOU. I thought it was the standard (having moved from Sunnyvale). When was TOU implemented/revised? o Can I change TOU back to normal in October? o It would be nice to have a real-time demand-response option, or a real-time rate. I realize these would not be attractive to most customers, though. o Mainly I’d recommend to folks with EVs. o One participant was hesitant to recommend the rate because they believed the schedule might not work as well for families whose daily routines do not allow them to switch energy usage to lower-cost periods. Item #C     Packet Pg. 61     Attachment C: Customer Communication and Outreach Materials September 2026 Utilities Bill Insert Item #C     Packet Pg. 62     Tri-Fold Brochure – Outside Cover Tri-Fold Brochure – Interior Pages Item #C     Packet Pg. 63     TOU Removable Cling Sticker and Magnet Sample Image of TOU Cling or Magnet on an Appliance Item #C     Packet Pg. 64     Rotating Banner Image on Utilities Home Webpage (www.paloalto.gov/utilities) Item #C     Packet Pg. 65     Time-of-Use Webpage Screenshot (www.paloalto.gov/timeofuse) Item #C     Packet Pg. 66     Sample Social Media Graphics Item #C     Packet Pg. 67     Item No. 4 Page 1 of 7 1 0 0 6 8 Utilities Advisory Commission Staff Report From: Alan Kurotori, Director Utilities Lead Department: Utilities Meeting Date: October 7, 2026 Report #: 2605-6404 TITLE Recommending Approval of a Definition of “Low-Income Individual” for Palo Alto’s Low Carbon Fuel Standards Program RECOMMENDATION Staff recommends that the Utilities Advisory Commission (UAC) recommend that the City Council adopt a definition of “low-income individual” for Palo Alto’s Low Carbon Fuel Standards (LCFS) program that includes individuals eligible for Palo Alto’s Rate Assistance Program (RAP). EXECUTIVE SUMMARY The LCFS Program, administered by the California Air Resources Board (CARB) is designed to reduce the carbon intensity of transportation fuel and is a funding source for the City of Palo Alto Utilities (CPAU) transportation electrification customer programs. The LCFS regulations, effective July 1, 2025, require that at least 50%1 of LCFS credit proceeds from residential Electric Vehicle (EV) charging be spent on equity-focused transportation electrification projects benefiting disadvantaged communities, low-income communities, rural areas, or low-income individuals. The regulation also provides an updated list of approved transportation electrification efforts that could qualify as equity project spending.2 The LCFS regulation describes several bases on which an individual may qualify as “low- income,” including those that meet “the definition of low-income established by a POU’s [publicly owned utility’s] governing body.”3 CPAU operates a Rate Assistance Program (RAP) for qualifying customers based on financial or medical need. This report recommends that the 1 17 CCR 95483(c)(1)(A)(5)(a), page 45 Unofficial electronic version of the Low Carbon Fuel Standard Regulation effective July 1, 2025 (https://ww2.arb.ca.gov/sites/default/files/2025-08/2025_lcfs_fro_oal-approved_unofficial_08112025.pdf ) specifies the 50% spending requirement. The equity project spending requirement was 30% in 2022, 40% in 2023, and 50% from 2024 onwards. 2 Additionally, as a result of the changes in the regulation, the number of electricity credits CPAU earns has decreased, and compressed natural gas (CNG) dispensed at the Municipal Service Center generates deficits, rather than credits, as of 2025. 3 17 CCR 95483(c)(1)(A)(5)(a). Item #4     Packet Pg. 68     Item No. 4 Page 2 of 7 1 0 0 6 8 Council adopt a definition of “low-income individual” for the purposes of Palo Alto’s LCFS program that includes customers who are eligible for RAP based on financial need. BACKGROUND 7 in funding and has expended $8.1 million on projects and programs supporting the transition to electric transportation in Palo Alto8. Palo Alto transportation electrification programs provide technical assistance to multi-family and non-profit organizations to install EV charging infrastructure and provide cash rebates to partially defray the cost of installing EV chargers. As of December 2025, approximately $6.8 million in reserves and annual revenues of ~$1.3 million are available for future transportation electrification customer programs. 7 The $14.9 million is the proceeds from the sale of 135,000 LCFS credits received since 2016. Of these proceeds $14.3 million was related to sale of LCFS ’base credits’ earned by City of Palo Alto Utilities (CPAU) for electricity provided for residential charging. Electricity and Natural gas dispensed by PWD-operated EV chargers and CNG stations received ~$465k and ~$150k of the proceeds respectively. Due to changes to the LCFS regulation, the CNG station no longer receives credits, but instead, needs to buy credits to meet the LCFS regulatory requirements. 8 EV customer programs have providing EV charger rebates ($3M), CALeVIP rebates ($0.53M), California Clean Fuel Rebate ($1.66M), technical assistance program for multi-family and non-profits to install EV chargers ($0.64M), DCFC electricity rate discount ($0.23M), funding for the installation and maintenance of EV chargers in City garages ($0.35M), educational programs and events promoting EVs and available customer programs ($0.57M), program management services/staffing ($1.1M), other ($0.1M). Item #4     Packet Pg. 69     Item No. 4 Page 3 of 7 1 0 0 6 8 Table 1: FY 2027 Budget for Transportation Electrification Spending Category FY2027 Budget Reappropriations LCFS Electric C&I Total FY2027 Outreach and Education $172,548 -$172,548 -$172,548 Multi-Family/ Nonprofit EV 1.0 (projects in progress) Multi-family Affordable Chargers - $872,960 $872,690 -$872,960 Multi-family & Nonprofit Full / Partial Market Rate Chargers - $1,491,087 $1,491,087 -$1,491,087 Multi-Family EV 2.0 (new projects) Multi-family Affordable Charging and Programs $1,427,480 -$1,427,480 -$1,427,480 Multi-family Full / Partial Market Rate Charging $2,183,000 $525,000 $1,114,410 $1,593,590 $2,708,000 Public Agency EV Charger Program $566,400 $181,248 $385,152 $566,400 FUNDING TOTALS:$5,259,463 $1,978,742 $7,238,475 Palo Alto is categorized as an Electric Distribution Utility (EDU) in the LCFS regulation. The LCFS regulation requires that 50% of holdback credit annual spending11 be directed towards projects serving low-income individuals and low-income communities (also known as “equity projects” in the LCFS regulation). Per the LCFS Regulation, approved uses of equity project spending include transportation electrification efforts for the primary benefit of or primarily serving disadvantaged communities, rural areas, tribal lands, low-income communities, or low-income individuals. The regulation lists the following pre-approved categories of equity projects: Electrification of drayage trucks and other medium-, heavy-duty, or off-road vehicles, including school and transit buses; Publicly accessible and multifamily EV charging infrastructure; o Public EV charging infrastructure must be in a disadvantaged community, low- income community, rural area, or tribal land, while multifamily EV charging infrastructure may also qualify by specifically benefitting low-income individuals. Investment in e-mobility options such as EV sharing and ride-hailing; 11 Base credits are allocated to EDUs based on the number of EVs registered in its service territory, in recognition of the electricity supplied to charge the EVs. There is an obligation for EDUs to contribute certain amount of these sales proceeds to fund the statewide Clean Fuels Rewards (CFR) program. Remaining base credits are called the holdback credits. Starting in CY2026 CPAU does not have any obligation to fund the CFR program, hence the number of base credits and holdback credits are the same. Item #4     Packet Pg. 70     Item No. 4 Page 4 of 7 1 0 0 6 8 o Rebates and incentives must directly benefit low-income individual drivers or riders, or the majority of ride endpoints must occur in disadvantaged communities, low-income communities, rural areas, or tribal lands. Rebates and incentives beyond existing local, federal and State rebates and incentives for purchasing/leasing new and used EVs, for residential EV charging infrastructure, and offsetting costs for residential and nonresidential EV charging; o The rebates and incentives must be offered to low-income individuals. Promoting use and additional incentives for use of public transit and other clean mobility solutions via charging equipment or infrastructure that directly supports the following categories: o EV sharing and ride hailing programs These incentives must directly benefit low-income individuals, or the majority of ride endpoints must occur in disadvantaged communities, low-income communities, rural areas, or tribal lands. o Electrification of public transit and school buses, including battery swap programs These transit vehicles and school buses must serve disadvantaged communities, low-income communities, rural areas, or tribal lands. o Use or ownership of neighborhood EVs, eBikes, eScooters, eMotorcycles, and other micromobility solutions These electric vehicles must be owned by low-income individuals, or provided for disadvantaged communities, low-income communities, rural areas, and/or tribal lands. Workforce development programs in support of transportation electrification; Grid-side infrastructure that supports medium and heavy-duty charging. o The infrastructure must directly support a disadvantaged community, low- income community, rural area, or tribal lands. Transportation electrification projects that are identified in, or consistent with, a Community Emission Reduction Plan created in response to AB 617: Community Air Protection Program (2017). Projects not listed above may still be treated as equity projects with prior approval from CARB. In addition to the equity projects listed above, other non-equity approved uses of holdback credit annual spending per the LCFS Regulation are: Investments in grid-side distribution infrastructure necessary for EV charging. Support for vehicle-grid integration with projects such as: o Encouraging the optimization of EV charging through education in peak demand, rate pricing, grid emergencies, potential power shutoffs, infrastructure deferral, renewable integration, and/or other signals and grid needs to provide grid and customer benefits. Item #4     Packet Pg. 71     Item No. 4 Page 5 of 7 1 0 0 6 8 o Providing program incentives to encourage driver participation in monitored/managed charging, demand response, or vehicle-to-load / vehicle-to-grid applications. o Supporting the deployment and installation of bidirectional charging equipment. o Other innovative approaches to promoting and managing EV charging and discharging that provides benefits to customers and the grid. Hardware and software that decrease the cost of or avoid updates to infrastructure, including load management software or outlet splitting. Projects listed above as approved uses of equity project spending that do not primarily serve DACs or low-income communities or individuals. CPAU Future Plans for LCFS Spending, with a Focus on Low-Income Programs Staff plans to develop new transportation electrification programs that primarily benefit low- income customers including publicly-accessible curbside EV chargers, EV chargers in publicly- accessible parking lots within walking distance of affordable housing that can accommodate electric vehicle (EV) charging infrastructure, and EV and other e-mobility offerings for low- income individuals such as vehicle leasing or purchasing incentives, EV charging rate discounts, EV charging infrastructure incentives, and electric carsharing or ride hailing services. Staff plans to seek approval from CARB in support of its transportation electrification programs and projects where necessary. In September 2016, Council approved the City’s first Program for the use of Revenues from the sale of LCFS Credits (LCFS Program Guideline)13 and in December 2019, Council approved (Staff Report 1084614, Resolution 987115) an update to the Program. With CARB’s updates in the LCFS regulations since 2019, staff plans to incorporate feedback from CARB and bring an update to the LCFS Program Guidelines to the City Council. If an EDU fails to spend the required percentage on equity projects in a calendar year, the shortfall of spending is added to its total equity spending requirement for the following year. For example, during CY2025, Palo Alto’s equity spending requirement was $838,779 (50% of the total spending of $1,677,558), but the actual equity spending was $459,546. Since the equity spending was less than the equity spending requirement, the remaining $379,232 will be carried forward to be spent in CY2026+ for low-income programs. A project’s eligibility as an equity project can depend in part on whether it specifically benefits low-income individuals. This report recommends that individuals eligible for Palo Alto’s RAP 13 Staff Report 7128 https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=79787&dbid=0&repo=PaloAlto&searchid=a38366f6-5872-4e32- acf7-3833f61cb71c 14 Staff Report 10846 https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=896778&dbid=0&repo=PaloAlto&searchid=ce0a135e-2f36-4b0c- abe5-fe0ab62722d3 15 Resolution 9871 https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=54120&dbid=0&repo=PaloAlto Item #4     Packet Pg. 72     Item No. 4 Page 6 of 7 1 0 0 6 8 program be considered “low-income individuals” for the purposes of Palo Alto’s LCFS program, in order to maintain consistency across eligibility criteria for CPAU’s income-based programs. ANALYSIS or the definition of low-income established by a POU’s governing body . . .”19 (emphasis added). 20 Using eligibility for RAP as the definition of “low-income individual” for the purposes of Palo Alto’s LCFS program will provide consistency across utility programs, even in the event that the financial eligibility criteria for RAP changes in the future. Additionally, this definition will allow for ease of implementation as well as ensure the LCFS funds benefit the low-income individuals that staff and Council have identified through development of the RAP program. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT 19 17 CCR 95483(c)(1)(A)(5)(a). 20 Staff Report 2501-4065: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=887042&dbid=0&repo=PaloAlto&searchid=de51859c-8532- 420b-8018-dfcfcfef9a93; additionally, Palo Alto operates a Residential Energy Assistance Program (REAP) that provides free energy efficiency and electrification solutions. To qualify for REAP, residents must be enrolled in the RAP program. Owner- occupied residents must meet additional qualifying criteria to qualify for REAP. Item #4     Packet Pg. 73     Item No. 4 Page 7 of 7 1 0 0 6 8 On June 1, 2026, the City Council approved changes to the Residential Rate Assistance Program (RAP) to set the qualifying income level to 80% of the Santa Clara County Area Median Income (AMI).23 On November 17, 2025, Council approved the Program Design Guidelines for Successor to Multi-family Electric Vehicle Charger Program24 (EV 2.0 Design Guidelines) to guide development of a revised multi-family electric vehicle (EV) charger program. These guidelines, informed by conversation with electrical contractors and EV service providers that had completed EV infrastructure projects in Palo Alto, were unanimously recommended to Council by the City’s Climate Action and Sustainability Committee (CASC) on September 19, 2025. These design guidelines focus on the financial and technical design of future EV charging infrastructure program offerings. They also highlight complementary customer-facing programming that would support EV infrastructure investments. On August 18, 2025 the City Council accepted the E-Mobility Strategic Roadmap.25 The E-Mobility Strategic Roadmap coordinates and prioritizes the City’s efforts in expanding electric mobility options to meet climate and transportation goals. ENVIRONMENTAL REVIEW AUTHOR/TITLE: 23 Staff Report 2501-4065: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=887042&dbid=0&repo=PaloAlto&searchid=de51859c-8532- 420b-8018-dfcfcfef9a93 24 Staff Report 2508-5087: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83873&dbid=0&repo=PaloAlto&searchid=3bff221c-e00d-44a0- 8593-9d6e3a5ddfe7 25 City Council, August 18, 2025, Staff and the Climate Action and Sustainability Committee Recommendation to Accept the E- Mobility Strategic Roadmap, Attachment B, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83554&dbid=0&repo=PaloAlto&searchid=fe370365-e701-4f14- b9fd-13d37b1a8254 Item #4     Packet Pg. 74