Item No. 5
Town of Atherton
CITY COUNCIL STAFF REPORT – PUBLIC HEARING
TO: HONORABLE MAYOR AND CITY COUNCIL
GEORGE RODERICKS, CITY MANAGER
FROM: TOM FORD, SENIOR PLANNER
DATE: JUNE 17, 2026
SUBJECT: CONSIDERATION OF A RESOLUTION ADOPTING AMENDMENTS TO
THE ATHERTON GENERAL PLAN TO IMPLEMENT UPDATES TO THE
COMMUNITY SAFETY ELEMENT, OPEN SPACE AND
CONSERVATION ELEMENT, AND CIRCULATION ELEMENT
CEQA: PROJECT IS EXEMPT UNDER THE COMMON-SENSE EXEMPTION SET FORTH IN CEQA GUIDELINES SECTION 15061(B)(3)
RECOMMENDATION:
Staff recommends that the City Council take public comment and adopt a resolution to amend the Atherton General Plan to implement updates to the Community Safety Element, Open Space and Conservation Element, and Circulation Element; and direct staff to file a Notice of Exemption with the San Mateo County Clerk and to forward the adopted Community Safety Element to the California Office of Emergency Services and other required State agencies.
BACKGROUND
What is the Community Safety Element?
The Community Safety Element of Atherton’s General Plan is a State-mandated component of every city's and county's General Plan, required under California Government Code Section 65302(g). It identifies potential natural and human-caused hazards that could affect residents, businesses, and services in the community. The purpose of the Community Safety Element is to establish a framework that identifies and anticipates these hazards and prepares the community to minimize risks and harm resulting from these hazards.
The Community Safety Element identifies the natural and human-caused hazards that affect Atherton, describes present and expected future conditions, and sets goals and policies to minimize Amendments to General Plan Elements
June 17, 2026
hazards to safety. This includes efforts to protect the health and safety of community members, minimize physical harm to the buildings and infrastructure, and reduce damage to local economic systems, community services, and ecosystems. The last time the Town updated its Safety Element was in 2020 as part of a comprehensive effort to update the entire General Plan.
State Law Requirements for Safety Elements
California Government Code Section 65302(g) contains the requirements for Safety Elements, including that it must be updated upon each revision of the housing element or local hazard mitigation plan, but not less than once every eight years. A series of recent legislative changes has significantly expanded the content requirements for Safety Elements. Key legislation includes:
• Senate Bill (SB) 379 (2017), codified in Section 65302(g)(4), requires local governments to conduct vulnerability assessments as part of their long-range planning efforts and to prepare resilience and adaptation policies that will protect against harm caused by climate change.
Therefore, an assessment is prepared with each Safety Element update. The updated vulnerability assessment prepared for this update to the Community Safety Element is included as Appendix B.
• SB 1035 (2018) established Section 65302(g)(6) of the California Government Code, requiring jurisdictions to review and update the Safety Element upon updates to the Housing Element and Local Hazard Mitigation Plan (LHMP), or at least every eight years. An update to the Housing Element was certified by the State in May 2025. This Community Safety Element update will incorporate the multijurisdictional LHMP approved in 2021. The effort to update the 2026 LHMP is underway and receiving public comment through June 15, 2026. • SB 99 (2019) established Section 65302(g)(5) of the California Government Code and requires jurisdictions to review and update the Safety Element to include information identifying residential developments in hazard areas that do not have at least two emergency evacuation routes. This update to the Community Safety Element institutes expanded discussion and mapping that identifies hazards and evacuation routes. • Assembly Bill (AB) 747 (2019) established Section 65302.15 of the California Government Code. It required jurisdictions to identify evacuation routes and their capacity, safety, and viability. AB 1409 (2021) amended this section to include identifying evacuation locations.
This requirement is being addressed by the county-wide All-Hazards Evacuation Plan, which is currently in progress and which Atherton is participating in. • AB 2684 (2024) added Section 65302.01 to the California Government Code, requiring jurisdictions to identify areas most vulnerable to extreme heat, assess health and infrastructure risks, and include goals, policies, and implementation measures to address those risks. This requirement takes effect January 1, 2028.
In addition to the Safety Element laws identified above, other state laws have requirements that tier from Safety Elements. Included in this update is are updates to comply with SB 1425, which requires every California jurisdiction to review and update its Open Space Element to address specified issues, including climate resilience and other cobenefits of open space, correlated with the Safety Element.
Purpose of the Community Safety Element and General Plan Update Atherton's Community Safety Element was last updated in 2020. The update described in this staff report is undertaken to bring the Town’s General Plan into full compliance with the State laws described above, to incorporate the results of a new climate vulnerability assessment, and to reflect Amendments to General Plan Elements
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updated hazard information and community priorities. The update includes revised and new goals, policies, and implementation actions organized around the hazard topics addressed in the element.
Updates to the Community Safety Element necessitated text edits to the Open Space and Conservation Element, as well as the Circulation Element, to ensure conformity across the General Plan. Additionally, the recent passage of SB 1425 (2022) requires that Open Space Elements be updated to address equal access for all residents, climate resilience, and other cobenefits of open space, correlated with the safety element.
Community Outreach
Throughout the multi-year effort to prepare the Community Safety Element and General Plan Update the Town has conducted public outreach at various milestones. Staff first introduced the project to the Planning Commission and City Council as an informational item at their meetings on January 24, 2024 and February 26, 2024, respectively. Additionally, staff held public workshops on May 13, 2024 and November 11, 2025, and coordinated with Get Ready Atherton (formerly A.D.A.P.T.) to integrate comments at various draft stages. Planning staff also collected feedback from the Town’s Public Works, Building and Police Departments, as well as Menlo Fire.
Prior to this adoption effort, a preliminary draft was hosted on the Town’s General Plan website to solicit comments for 30 days.
Town staff initiated a webpage on the Planning Department’s General Plan page that provided an overview of the process to update the Community Safety Element. Draft versions of the three General Plan Elements proposed for amendments were available via links and the comment period was identified as closing on December 31, 2025.
ENVIRONMENTAL REVIEW
The Community Safety Element update qualifies for a CEQA exemption under the common-sense exemption set forth in CEQA Guidelines Section 15061(b)(3). This exemption applies where it can be seen with certainty that there is no possibility the activity may have a significant effect on the environment. The CEQA Exemption Memorandum and Notice of Exemption form are provided as Attachment 1. Key findings include:
• The Community Safety Element update is a program-level policy document establishing a framework for addressing hazards and does not commit the jurisdiction to any specific development action.
• The update does not include land use or zoning changes, does not increase development potential, and does not grant entitlements for development projects. • No provisions of the update would result in direct or indirect population growth or place additional demands on natural resources, public services, or infrastructure. • Future implementation actions that could affect the environment, such as code amendments, capital projects, or other physical improvements, would be subject to separate CEQA review at the time they are prepared, as applicable.
Following adoption of the Community Safety Element, staff will file the Notice of Exemption with the San Mateo County Clerk and post it with the State Clearinghouse, as required.
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REVIEW BY OTHER AGENCIES
As part of the Safety Element update process, the draft Safety Element was circulated to the following State agencies for review, as required by California Government Code Section 65302.5:
• California Geological Survey (CGS): All Safety Elements must be submitted to CGS for review prior to adoption. CGS reviews the Safety Element for adequacy of coverage of seismic, geologic, and related hazards.
• Governor's Office of Emergency Services (Cal OES): Safety Elements must be submitted to Cal OES for review. Cal OES reviews the Safety Element for consistency with the jurisdiction's LHMP. Confirmation from Cal OES that the Safety Element appropriately integrates the LHMP ensures the jurisdiction remains eligible for California Disaster Assistance Act (CDAA) funding.
PROJECT DESCRIPTION
The following section summarizes the revisions to the General Plan that are included in this project based on edits to the individual elements. A clean version of the new text for the Community Safety Element, the Conservation and Open Space Element and the Circulation Element are provided at Attachment 2. Appendices to the Community Safety Element are provided at Attachment 3. Trackedchanges of the revised Elements are provided at Attachment 4. Large format versions of the maps shown in the Elements are provided as Attachment 5.
Summary of Changes to the Community Safety Element
The updated Community Safety Element has been organized to address all hazard topics required by current State law and to reflect local conditions and community priorities identified through the planning and community engagement process. Key changes include:
• New coverage of climate change vulnerability, including the results of the Peninsula Resilience Planning (PREP) project vulnerability assessment, which analyzed current and projected future risks to people, buildings, infrastructure, and key services from a range of climate hazards. All information about existing hazard conditions was reviewed and updated as needed.
• The PREP project work resulted in an updated Climate Change Vulnerability Assessment that is summarized in Appendix B of the Community Safety Element. The Vulnerability Assessment Summary provides community members and decision makers with greater understanding of climate change hazards, such as extreme heat, flooding, and wildfire. The Vulnerability Assessment Summary provides guidance on which parts of the community should be prioritized for adaptation and resilience.
• Updated wildfire policies, including information on new Fire Hazard Severity Zones mapping.
• New content on emergency evacuation, including an analysis of residential areas that may lack two or more emergency evacuation routes, consistent with SB 99 requirements. • New policies addressing extreme heat, severe weather, and drought. • Updated hazard maps for all major hazard categories.
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• Updated references to Get Ready Atherton (formerly known as A.D.A.P.T., the Atherton Disaster and Preparedness Team), an all-volunteer group of Atherton residents that collaborate with Town officials, Atherton Police, and the Menlo Park Fire District. • A background report (attached as Appendix A to the Community Safety Element), documenting the current state of all hazards discussed in the element.
These amendments will bring the General Plan into alignment with the Multijurisdictional LHMP adopted in 2021, available on the San Mateo County website at:
https://www.smcgov.org/ceo/2021-multijurisdictional-lhmp.
Summary of Changes to the Open Space and Conservation Element The updated Open Space and Conservation Element has been amended to conform to amendments made to the Community Safety Element and other amendments, including:
• Discussion of the recently constructed Town Center Park. • Discussion of the implementation of the Town’s flood control project. • A new Goal (OSC-6) and Policy (OSC-6.1) to promote climate resilience and other cobenefits of open space and encourage a range of opportunities related to the preservation and enhancement of open space networks. This amendment serves to address the requirements of SB 1425, as discussed further below.
Summary of Changes to the Circulation Element
The updated Circulation Element has been amended to conform to amendments made to the Community Safety Element and other amendments, including:
• Discussion of the recent closure of Atherton Train Station. • Discussion of the recent improvement to Watkins Avenue rail crossing.
General Plan Compliance with SB 1425
As noted above, SB 1425 requires local jurisdictions to address equal access for all residents, climate resilience, and other co-benefits of open space, correlated with the safety element.
Jurisdictions are required to demonstrate compliance with SB 1425 by January 1, 2026. The Town is delayed in this effort for the purpose of aligning it with the broader Safety Element efforts. State law limits the number of times a jurisdiction may update their General Plan within a year.
SB 1425 requires that the General Plan shall contain self-mandated local programs that promote:
• Access to open space for all residents in a manner that considers social, economic, and racial equity, correlated with the environmental justice element or environmental justice policies in the general plan, as applicable.
• Climate resilience and other co-benefits of open space, correlated with the safety element.
Compliance with SB 1425 is mostly accomplished by a series of existing General Plan Policies.
These include:
• Action OSC-1.1: Minimum lot sizes, setback restrictions, height limitations, tree protection and preservation, and sign regulations shall be employed to accomplish open space and conservation objectives.
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• Action OSC-1.2: The Town shall evaluate the potential for cooperative recreational use of existing school sites.
• Action OSC-3.1: The Town will continue to seek and coordinate partnering opportunities for shared green infrastructure projects with other public and private entities and property owners, as feasible.
• Action OSC-3.2: The Town will encourage property owners to incorporate water conservation techniques into their landscaping to reduce water usage and use green infrastructure techniques to capture and/or treat rainfall and stormwater runoff at its source, as feasible.
The addition of a new Goal and new Policy proposed for the Open Space and Conservation Element will directly address the remaining requirements of SB 1425. These are:
• Goal OSC-6: Promote climate resilience and other co-benefits of open space, correlated with the Community Safety Element and the Town’s Climate Action Plan. • Policy OSC-6.1: Encourage opportunities to preserve, enhance, and expand an integrated network of open space to support beneficial uses, such as habitat, recreation, natural resources, historic and tribal resources, water management, and aesthetics.
ANALYSIS
Atherton General Plan Amendments
State law requires the Town to maintain a General Plan with specific elements to provide a vision for the Town’s future and inform local decisions about land use and development. The Atherton Municipal Code (AMC) Chapter 17.23 addresses General Plan Amendments. AMC Section
17.23.040 notes that a general plan amendment may be initiated by the Town to clarify text, address changes mandated by State law, maintain internal general plan consistency, or for any other reason beneficial to the town. As previously indicated, this effort is to align with state mandates.
Planning Commission Recommendation
At the Planning Commission meeting on May 27, 2026, the Commission took the following action:
Approved Resolution No. 2026-02 recommending that the City Council adopt a resolution to amend the Atherton General Plan to implement updates to the Community Safety Element, Open Space and Conservation Element, and Circulation Element; and direct staff to file a Notice of Exemption with the San Mateo County Clerk and to forward the adopted Community Safety Element to the California Office of Emergency Services and other required State agencies. (5 Ayes: M-Levison, S-Leugers). (Attachment 6)
STAFF RECOMMENDATION
Staff recommends that City Council adopt a resolution to amend the Atherton General Plan to implement updates to the Community Safety Element, Open Space and Conservation Element, and Circulation Element; and direct staff to file a Notice of Exemption with the San Mateo County Clerk and to forward the adopted Community Safety Element to the California Office of Emergency Services and other required State agencies.
Amendments to General Plan Elements
June 17, 2026
FISCAL IMPACT
The updates to the three General Plan Elements and CEQA documentation were completed under a Memorandum of Understanding (MOU) between the Town and the County of San Mateo. Under the MOU, the County coordinated the project and consultant team for the “Multijursdictional Safety Element Project” for nine San Mateo County jurisdictions, including Atherton. The Town entered into the MOU on June 15, 2023, and paid $105,169 for the Atherton portion of the Multijursdictional Safety Element Project.
PUBLIC NOTICE
Public notification was achieved by posting the City Council agenda, with this agenda item being listed, at least 72 hours prior to the meeting in print and electronically. Legal advertisement of this hearing was published in The Almanac newspaper, 12 days prior to the hearing date. Information about the project is also disseminated via the Town’s electronic News Flash and Atherton Online.
There are approximately 1,200 subscribers to the Town’s electronic News Flash publications.
Subscribers include residents as well as stakeholders – to include, but not limited to, media outlets, school districts, Menlo Park Fire District, service providers (water, power and sewer), and regional elected officials.
ATTACHMENTS
1. Notice of Exemption (NOE)
2. General Plan Elements_Clean
3. Appendices to the Community Safety Element
4. General Plan Elements_Track Changes
5. Large Format Maps
6. Planning Commission Resolution
7. Adoption Resolution