Agenda packet, second session — Brentwood City Council, December 10, 2024 (part 4 of 7)

BRENTWOOD BRIDLEGATE PROJECT • VMT ASSESSMENT• OCTOBER 2024 6 TABLE 2: APPLICABLE MITIGATION STRATEGIES
Source: CAPCOA. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, December 2021.

TABLE 3: MITIGATION SUMMARY
FORMULA A = (B-C)/C x D
A – PERCENT VMT REDUCTION 9.97%

B - INTERSECTION DENSITY WITH

MITIGATION
Area = 135 acres (0.21 square miles)
Intersections with mitigation = 13
Intersection density with mitigation = 61.6 per square mile C - AVERAGE INTERSECTION DENSITY 36
D – ELASTICITY OF VMT TO DENSITY -0.14
VMT PER CAPITA AFTER MITIGATION 27.9 x (1-.0997) = 25.08 Sources: CAPCOA (2021) and DKS Associates.

STRATEGY MAXIMUM MITIGATION

EFFECTIVENESS
T-1 INCREASE RESIDENTIAL DENSITY 30.0%
T-4 INTEGRATE AFFORDABLE HOUSING 28.6%
T-9 IMPLEMENT SUBSIDIZED TRANSIT PROGRAM 5.5%
T-15 LIMIT RESIDENTIAL PARKING SUPPLY 13.7%
T-16 UNBUNDLE RESIDENTIAL PARKING COSTS 15.7%
T-17 IMPROVE STREET CONNECTIVITY 30.0%
T-19-A. CONSTRUCT OR IMPROVE BIKE FACILITY 0.8%
T-21-A IMPLEMENT CARSHARE PROGRAM 0.15%
T-22-A-C. IMPLEMENT BIKESHARE OR SCOOTER SHARE
PROGRAM 0.02-0.07%
T-23 IMPLEMENT COMMUNITY BASED TRAVEL PLANNING 2.3%

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BRENTWOOD BRIDLEGATE PROJECT • VMT ASSESSMENT• OCTOBER 2024

APPENDIX

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PUBLIC WORKS DEPARTMENT GENERAL FACILITIES CIVIL ENGINEER SOILS ENGINEER NOTEBENCHMARK BASIS OF BEARINGS OWNER/DEVELOPER VICINITY MAP BRIDLE GATE - ALTERNATE LOTTING PLAN - 09-19-2024 SHEET INDEX

HC SE NT TU AO K

EVI RD DOO WES OR
R S A .

K
E D

SAND CRE K ROAD
(FUTURE EXTENSION)
L S C

RD VI E

TAG L V

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PUBLIC WORKS DEPARTMENT

CHESTNUT OAK DR VI E

HC SE NT TU AO K RD VI E

HEATHERWOOD DRIVE HEATHERWOOD DRIVE COTTONWOOD AVENUE COTTONWOOD AVENUE WOODGLEN DRIVE SAN JOSE AVENUE

SAN JOSE AVENUE

EVI RD DOO WES OR NOT TO SCALE NOT TO SCALE NOT TO SCALE ABBREVIATIONS T I
I R
L R O
R K AD
L S U
OJ SE
I R

R AG E BRIDLE GATE DRIVE
SAN

AL KAO EN

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Additional Intersection Circled in Red

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FINAL Vehicle Miles Traveled (VMT) Analysis Peer Review November 8, 2023 Bridlegate Residential Development Page 2 of 2
§ It should be noted that the new affordable housing component of the Project would likely further reduce the project’s VMT.

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10 Attachment C
Updated VMT Assessment Peer
Review

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FINAL Vehicle Miles Traveled (VMT) Analysis Peer Review November 8, 2023 Bridlegate Residential Development Page 1 of 2
Memorandum
To: Megane Brown-Allard
Rod Stinson
From: Chris Gregerson, P.E., T.E., PTOE, PTP
Ben Huie, P.E.

Re: FINAL Vehicle Miles Traveled (VMT) Assessment Peer Review Bridlegate, City of Brentwood
Date: November 8, 2024
This memorandum documents a peer review completed by Kimley-Horn of a VMT assessment for the proposed Bridlegate Residential development in Brentwood, CA dated October 11, 2024, completed by DKS Associates1. This latest version of the VMT assessment was prepared in response to an update in the Project site plan resulting in a 269-lot alternative configuration. A previous VMT analysis with a different site plan was reviewed by Kimley-Horn on November 15, 2022 and the original VMT assessment prepared by DKS Associates and dated February 18, 2022. This memorandum summarizes the comments prepared by Kimley-Horn that address any changes to analysis or results not previously reviewed or approved as a part of legacy Project VMT analyses.

Peer Review Comments
A. Introduction
§ No comment, Kimley-Horn finds this section accurate, clear, and concise.

B. Background on Senate Bill 743 and VMT Metrics
§ No comment, Kimley-Horn finds this section accurate, clear, and concise.

C. Methodology and Analysis Standards
§ Syntax: Remove “utilizes” or “follows” from last sentence of first paragraph § Kimley-Horn agrees that an acceptable version of the CCTA TDM was selected for analysis purposes. Kimley-Horn also agrees that other methods of determining the project’s VMT, such as using online tools for estimating VMT, are not consistent with the required VMT methodology and provide inaccurate estimates of the project’s VMT.
§ Kimley-Horn agrees with the selection and identification of the threshold of significance to be 15% below the City of Brentwood average VMT per capita, i.e. 25.2.

D. Project Screening
§ No comment, Kimley-Horn finds this section accurate, clear, and concise.

E. Project VMT Analysis
§ For clarity, please move the footnote “a” in Table 1 to append the 25.2 value (instead of the City average of 29.6)
§ Kimley-Horn identified no changes to the previously reviewed and approved reduction strategies identified in the analysis. No comment.
1 VMT Assessment for Bridle Gate Residential Project - Updated, DKS Associates, October 11, 2024.

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11 Attachment D
Updated Noise Assessment

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October 11, 2024
Doug Chen, RCE, LS
ADSCO/Legacy Builders Inc
4021 Port Chicago Hwy
Concord CA 94520
[email protected]
Subject: Bridle Gate Residential Project – Response to Noise Comments from the August 27. 2024 City Council Hearing – City of Brentwood, California
Dear Mr. Chen:

At your request, Saxelby Acoustics has prepared this letter to reaffirm to the City Council that the noise study1 prepared for this project meets all requirements of the City of Brentwood. Additionally, our study was peer reviewed by the City’s CEQA noise consultant (Bollard Acoustical Consultants) and also found to meet all requirements.

Saxelby Acoustics conducted noise monitoring at three locations on the project site to ensure that noise levels at the proposed future residential uses would be accurately predicted. The noise model was also adjusted upwards by 2 dBA to account for future growth in traffic volumes on the adjacent roadways, including SR-4. Noise levels were mapped on the future uses using the SoundPLAN noise model, the leading sound prediction model used worldwide to map exterior noise. A sound wall was designed to ensure that exterior noise levels would remain at or below 63 dBA Ldn, 2 dBA lower than the City’s 65 dBA exterior noise standard. For the Alternate Map (9/19/2024), the exterior noise levels would remain at or below 63 dBA for the lots adjacent to the potential second access to Sand Creek Road should that be considered, between lots 149 and 153, provided the sound wall is maintained 8 feet above pad elevation for the wrapped sections. Additionally, windows with a sound transmission class (STC) rating of 34 were recommended to ensure that interior noise levels meet the City’s 45 dBA Ldn interior noise standard.

Our study also assessed potential off-site noise and vibration levels due to increased traffic, construction, and operation of the project and found that the project would meet the City’s standards, as well as the requirements of CEQA, with standard mitigation measures.

Thank you for your thoughtful consideration, I hope this information is helpful, please don’t hesitate to contact us with any additional comments.

Sincerely,
Saxelby Acoustics LLC
Luke Saxelby, INCE Bd. Cert.

Principal Consultant
Board Certified, Institute of Noise Control Engineering 1 Environmental Noise Assessment, Bridle Gate Residential. Saxelby Acoustics LLC. January 26, 2023.

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Bridle Gate Residential
City of Brentwood, California
Figure 4
Future (2043) Transportation Noise
Contours (dBA Ldn) – with Sound Walls
Sand Creek Road
Sand Creek Road
1st Floor: 59 dBA
2nd Floor: 68 dBA
1st Floor: 59 dBA
2nd Floor: 68 dBA
1st Floor: 59 dBA
2nd Floor: 69 dBA
1st Floor: 60 dBA
2nd Floor: 71 dBA
1st Floor: 57 dBA
2nd Floor: 62 dBA
1st Floor: 60 dBA
2nd Floor: 67 dBA
1st Floor: 60 dBA
2nd Floor: 69 dBA
1st Floor: 59 dBA
2nd Floor: 68 dBA
1st Floor: 62 dBA
2nd Floor: 74 dBA
1st Floor: 63 dBA
2nd Floor: 71 dBA
1st Floor: 62 dBA
2nd Floor: 70 dBA
1st Floor: 61 dBA
2nd Floor: 69 dBA
1st Floor: 62 dBA
2nd Floor: 65 dBA
1st Floor: 61 dBA
2nd Floor: 73 dBA

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12 Attachment E
Updated Noise Assessment Peer
Review

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P.O. Box 7968  Auburn, CA 95604  Phone: (530) 537-2328  WWW.BACNOISE.COM November 4, 2024
Mr. Rod Stinson
Raney Planning & Management, Inc.
1501 Sports Drive, Suite A
Sacramento, CA 95834
Transmitted via email: [email protected]
Subject: Bollard Acoustical Consultants, Inc. (BAC) Peer Review of the Bridle Gate Residential Environmental Noise Assessment update prepared by Saxelby Acoustics dated October 11, 2024.

Dear Mr. Stinson,
As you are aware, Bollard Acoustical Consultants, Inc. (BAC) previously conducted an extensive peer review of the Saxelby Acoustics noise study prepared for the Bridle Gate Residential project (Initial Saxelby report dated February 18, 2022). Following that peer review, BAC reached the following conclusions:

Overall, it is BAC’s professional opinion that the information provided in the Saxelby Acoustics noise study report is clearly presented, that ambient data was appropriately collected, that computations were accurately performed, and that the potential impacts were properly addressed. It is BAC’s opinion that there the SoundPLAN model inputs should, nonetheless, be provided to further verify the conclusions presented therein and to support the report’s recommended sound walls. In addition, justification for the assumed 1 dBA increase in Highway 4 traffic noise levels over the next 20 years should be provided and consideration should be given to utilizing a more conservative assumption if the 1 dBA assumption cannot practically be relied upon.

In response to BAC’s conclusions, the Saxelby report was revised to increase the Highway 4 traffic noise increase to 2 dBA in the future (from the original 1 dBA increase), and the traffic noise modelling assumptions were provided. BAC concluded that the revised Saxelby report dated January 26, 2023, adequately addressed the noise impacts of the project and provided appropriate noise mitigation measures for mitigating all identified noise impacts.

The project site plan has since been redesigned to include a secondary access to Sand Creek Road. Saxelby Acoustics prepared a letter dated October 11, 2024 stating that the previous noise analysis had been properly prepared to address all requirements of the City of Brentwood, that the study had been peer reviewed by BAC, and that peer review found that the Saxelby analysis satisfied all of the City’s requirements. BAC conclusion that Saxelby’s January 26, 2023 noise analysis was adequate has not changed.

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Mr. Rod Stinson
November 4, 2024

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Saxelby’s October 11, 2024 letter also included an updated noise contour and noise mitigation graphic (Figure 4), which shows the change in site plan indicating the location of the secondary access to Sand Creek Road.

BAC carefully reviewed Saxelby’s updated Figure 4 and concluded there were no substantive changes to either predicted future traffic noise levels at the proposed residences or appreciable changes in required noise mitigation measures. The only difference noted by BAC staff was the break in the 8-foot tall San Creek Road noise barrier required to accommodate the secondary access to Sand Creek Road. BAC agrees with the wrapping of the noise barrier at that secondary access as indicated by Saxelby’s updated Figure 4.

Because there were no other apparent differences in the project site plan which affected Saxelby’s noise analysis, nor any changes in Saxelby’s predicted noise levels or recommended mitigation measures, BAC’s conclusions regarding the previous Saxelby noise study prepared for the project remain valid. Based on BAC’s review of Saxelby’s October 11, 2024 letter and attached updated Figure 4, it is BAC’s professional opinion that the Saxelby Acoustics assessment has been properly prepared to address City of Brentwood requirements and BAC has no recommendations for modifications to the most recent Saxelby correspondence.

This concludes BAC’s review and comments regarding the environmental noise analysis update prepared by Saxelby Acoustics dated October 11, 2024 for the Bridle Gate Residential project in Brentwood, CA. Please contact BAC at (530) 537-2328 or [email protected] with any comments or questions regarding the results of the peer review.

Sincerely,
Bollard Acoustical Consultants, Inc.

Paul Bollard
President

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PREVIOUS ACTIONS
Previous City Council actions related to this agenda item are listed below. To view prior actions and materials, and Brentwood Municipal Code references in the staff report, as applicable:
 Visit www.brentwoodca.gov/meetings, and select the meeting date(s) desired to see the reference materials and videos.
 Visit www.brentwoodca.gov/municipalcode to research references to the Brentwood Municipal Code and search by the code section(s) cited.

On April 19, 2005, the Planning Commission held a public hearing on a request for a General Plan Amendment (GPA 01-01), a Rezone (RZ 05-04), a Development Agreement (DA 04-02), a Vesting Tentative Subdivision Map (VTSM 8606) for 166 residential lots, and a Design Review (DR 01-02) for the first iteration of the Bridle Gate project (“2006 Project”) and continued the item to a date uncertain.

On April 27, 2005, Discovery Builders appealed the Planning Commission continuance to the City Council.

On May 24, 2005, the City Council continued a public hearing on the appeal to its meeting of June 14, 2005, due to noticing requirements.

On June 14, 2005, the City Council held a public hearing on the appeal and referred the project back to the Planning Commission for additional consideration.

On November 1, 2005, the Planning Commission held a public hearing on a General Plan Amendment (GPA 01-01), a Rezone (RZ 05-04), a Development Agreement (DA 04-02), a Vesting Tentative Subdivision Map (VTSM 8606) for 166 residential lots, and a Design Review (DR 01-02) for the 2006 Project and requested staff to prepare the necessary resolution for denial of the general plan amendment and rezone.

On November 15, 2005, the Planning Commission adopted Resolution No. 05-82 denying General Plan Amendment No. 01-01 and Rezone No. 05-04.

On January 10, 2006, the City Council held a public hearing to consider the appeal by Discovery Builders and directed staff to prepare the necessary resolutions for approval of the appeal.

On May 23, 2006, the City Council held a continued public hearing on the appeal and approved the mitigated negative declaration, General Plan amendment, and introduced and waived the first reading of the ordinance for the Rezone, by Resolution Nos. 2006-124 and 2006-125 and Ordinance No. 827, respectively, and referred the development agreement, vesting tentative subdivision map, and design review application back to the Planning Commission for action.

On June 6, 2006, the Planning Commission held a public hearing and approved Development Agreement No. 04-02, Vesting Tentative Subdivision Map No. 8506,

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and Design Review No. 01-12 by Resolution Nos. 06-47, 06-48, and 06-49, respectively for the 2006 Project.

On July 22, 2014, the City Council adopted a resolution amending the City’s General Plan and designating the project site as R-LD (Residential Low-Density).

On November 10, 2015, the City Council adopted Ordinance No. 960, which among other things replaced the Planned Development map for the project site, PD-36, which map previously denoted the various subareas within PD-36, with a map that outlined the entire area of PD-36 and did not include any internal subarea boundaries.

In June 2017, Discovery Builders, Inc., submitted an application to the City of Brentwood seeking approval of a General Plan amendment (GPA 17-001), a rezone (RZ 17-004), a vesting tentative subdivision map (VTSM 8506), design review for 252 single-family homes (DR 17-007), and design review for up to 258 multi-family homes (DR 17-008) (the “2020 Project”), along with the required environmental review pursuant to the California Environmental Quality Act.

In 2019, West Coast Home Builders, Inc. (“WCHB”), submitted an application to the City of Brentwood seeking approval of a Development Agreement (DA 19-001) as a further element of the 2020 Project, as a co-applicant with Discovery Builders, Inc.

On August 18, 2020, the Planning Commission was scheduled to hold a public hearing to consider the applicant’s request for certification of a Final Environmental Impact Report, General Plan Amendment No. 17-001, Rezone No. 17-004, Development Agreement No. 19-001, Vesting Tentative Subdivision Map No. 8506, Design Review No. 17-007, and Design Review No. 17-008 for the 2020 Project.

However, on August 18, 2020, the City received notice that Pacific Gas & Electric had planned for potential rolling blackouts in and around the city of Brentwood on that day. Given that the Planning Commission meeting was being conducted remotely as a result of the COVID-19 pandemic, and the possibility that a blackout could disrupt a remote meeting, City staff and the applicant agreed to request that the item be continued to the Planning Commission’s September 1, 2020 meeting.

The Planning Commission voted unanimously to continue the public hearing on the matter to its meeting of September 1, 2020.

On September 1, 2020, the Planning Commission held a public hearing on the 2020 Project and voted unanimously to recommend that the City Council deny General Plan Amendment No. 17-001, Rezone No. 17-004, Development Agreement No. 19- 001, Vesting Tentative Subdivision Map No. 8506, Design Review No. 17-007, and Design Review No. 17-008 for the 2020 Project, as well as take no action to certify the Final Environmental Impact Report prepared for the project.

The City Council was scheduled to hold a public hearing on the 2020 Project at a special meeting set for September 15, 2020, and all requisite public hearing notices were provided accordingly. However, on that day, the applicant notified the City

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that it wished to continue the City Council’s public hearing on the matter to February 9, 2021.

In December 2020, the Applicant notified the City that it wished to modify the 2020 Project by no longer including a request to include multi-family uses. The Applicant ultimately submitted a revised proposed VTSM 8506 on January 29, 2021, formally amending the application for the 2020 Project. As a result of this amendment, the applicant and City agreed to move the City Council’s planned public hearing on the 2020 Project, as revised, from February 9, 2021, to March 9, 2021.

On March 9, 2021, the City Council held a public hearing on the revised 2020 Project and voted unanimously to direct staff to prepare a resolution to deny the project.

On March 23, 2021, the City Council adopted Resolution No. 2021-36 denying applications for a General Plan Amendment (GPA 17-001), Rezone (RZ 17-004), Development Agreement (DA 19-001), Vesting Tentative Subdivision Map (VTSM 8506), and Design Review for Single-Family Development (DR 17-007) for the 2020 Project, and taking no further action on the Environmental Impact Report prepared for the 2020 Project.

On June 7, 2021, Discovery Builders, Inc. filed a lawsuit challenging the City’s denial of the 2020 Project, and also alleging constitutional violations based on the City’s denial (“2020 Project Litigation”).

On October 22, 2021, WCHB Development, LLC submitted an SB 330 preliminary application and formal development applications seeking approval of a vesting tentative subdivision map and design review to develop the Bridle Gate site with a 292-unit residential project (“Current Project”).

On June 3, 2022, the City provided notice that WCHB Development, LLC’s application was complete, and that City staff would notify them of any inconsistencies with applicable standards within 60 days in accordance with state law.

On August 2, 2022, as required by state law, the City provided staff’s written assessment of the Project’s inconsistencies with applicable standards for PD-36 zoning and additional regulations.

On August 31, 2022, Discovery Builders, Inc, and WCHB filed a lawsuit regarding the City’s processing of the current project application, among other things, requesting the court to require the City to deem the Project consistent with applicable regulations (“Current Project Litigation”).

On November 1, 2022, the 2020 Project Litigation was resolved with the Court entering judgment in the City’s favor.

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On April 27, 2023, the Court held a hearing on the Current Project Litigation, where the court rejected Discovery Builders and WCHB’s contention that none of the PD36 standards, specifically the subarea C standards, apply. Although the City prevailed on this point, the lawsuit is still active, with certain claims against the City still pending.

On September 5, 2023, the Planning Commission held a public hearing to consider the Revised EIR, VTSM 9586, and DR 21-010. After closing the public hearing and deliberating, the Planning Commission continued the item to an unspecified future meeting.

On July 16, 2024, the Planning Commission held a public hearing to consider the Revised EIR, VTSM 9586, and DR 21-010. After closing the public hearing and deliberating, the Planning Commission adopted Resolution No. 23-032, denying VTSM 9586 and DR 21-010, and taking no further action on the Revised EIR.

On August 27, 2024, the City Council held a public hearing on the appeal filed by the project applicant of the Planning Commission’s denial. After closing the public hearing and deliberating, the City Council unanimously passed a motion to deny the appeal and uphold the Planning Commission’s denial of the project, but no final action was taken.

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CITY COUNCIL AGENDA ITEM NO. F.1
08/27/2024
SUBJECT: An application for the Bridle Gate project, including a Revised Environmental Impact Report, Vesting Tentative Subdivision Map, and Design Review.

DEPARTMENT: Community Development
STAFF: Alexis Morris, Community Development Director
Erik Nolthenius, Planning Manager

TITLE/RECOMMENDATION
Staff recommends that the City Council consider the following two options:

1. Deny the appeal, upholding the Planning Commission’s action to deny the project by adopting a resolution supported by factual finds; or

2. Approve the appeal, reversing the Planning Commission’s action to deny the project by adopting three resolutions: (1) certifying the Revised EIR (REIR) and making CEQA findings, (2) approving the Vesting Tentative Subdivision Map (VTSM 9586), and (3) approving the Design Review (DR 21-010).

The proposed project would include subdivision of the site for development of 272 single-family detached residences, as well as associated improvements within the project site, including two parks, open space, stormwater detention and treatment areas, utility connections, and construction of an internal roadway network on approximately 92.96 acres. The 36.82 acres of land located north of the future Sand Creek Road extension are on a separate legal parcel shown as a designated remainder on the vesting tentative subdivision map (VTSM), and are therefore not proposed to be developed as part of this application. The project site is bounded by Old Sand Creek Road to the north, State Route (SR) 4 to the east, a single-family residential development (Brentwood Hills) to the south, and the edge of the Brentwood Planning Area and the City of Antioch’s city limits to the west (APNs: 019-082-009 and 019- 082-00).

The City prepared a Revised Environmental Impact Report (REIR) for this project in accordance with the requirements of the California Environmental Quality Act (CEQA, codified at Public Resources Code §§ 21000, et seq., and as further governed by the State CEQA Guidelines, found at 14 CCR §§ 15000, et seq.). Several potentially significant impacts are identified; however, mitigation measures are proposed to reduce those impacts to less-than-significant levels.

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CITY COUNCIL AGENDA ITEM NO. F.1
08/27/2024

FISCAL IMPACT
The applicant, WCHB Development, LLC, has paid approximately $300,000 to process the application. These fees fully cover staff and consultant’s time spent processing the application, including preparation of the REIR.

BACKGROUND

PLANNING COMMISSION ACTION AND APPEAL
On July 16, 2024, the Planning Commission held a continued public hearing on the proposed project. After extensive deliberation, the Commission voted unanimously to deny the proposed project. Because a denial does not require CEQA review, the Planning Commission took no action regarding the project’s REIR. The Planning Commission provided findings for denial which were incorporated into the resolution (Attachment 6). The Planning Commission meeting is discussed in more detail below.

On July 24, 2024, WCHB Development, LLC, filed a timely appeal of the Planning Commission action with the City Clerk.

PROJECT DESCRIPTION
The project site is bounded by Old Sand Creek Road to the north, State Route (SR) 4 to the east, a single-family residential development (Brentwood Hills) to the south, and the edge of the Brentwood Planning Area and the City of Antioch’s city limits to the west. A small segment of existing San Jose Avenue bounds the project site at its farthest southeastern corner. The western terminus of Sand Creek Road, constructed as part of the interchange with SR 4, is located adjacent to the eastern site boundary.

The single-family residential area would be developed with lot sizes ranging from 5,000 to 15,930 square feet (sf). The application proposes one- to three-story residences ranging from 1,808 sf to 3,222 sf. As noted below, staff is recommending a condition to limit the residences to two stories consistent with Planned Development (PD) 36 Subarea C standards. Overall, a total of 67.96 acres of the project site would be developed with residential uses. Therefore, buildout of the single-family residential

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CITY COUNCIL AGENDA ITEM NO. F.1
08/27/2024
development would result in a density of approximately 4.0 dwelling units per acre (du/ac). The density calculation included here is based only on the portions of the site dedicated to residential use and not designated as Permanent Open Space, consistent with the City’s General Plan.

One parcel totaling six acres (northwest portion of the site) and a second parcel totaling 2.49 acres (southeast portion of the site), respectively, would be dedicated to the City of Brentwood for use as public parks. The parks would provide recreational amenities for residents of the proposed single-family subdivision. Landscaping elements would be provided throughout the proposed park areas and all other developed portions of the site consistent with City requirements. An additional 25 acres of permanent open space would be located within the southwestern portion of the site. Sand Creek currently flows from west to east through the northern portion of the proposed project site, and primarily through the 36.82-acre designated remainder.

The proposed project would include water, sewer, and stormwater utility improvements. Stormwater draining off impervious surfaces within the site would be directed to two bio-retention basins located in the northwestern portion of the site, southeast of the proposed six-acre park (Parcel B), and along the southeast boundary of the site (Parcel E), respectively. Water and sewer service for the proposed project would be provided by the City of Brentwood.

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CITY COUNCIL AGENDA ITEM NO. F.1
08/27/2024
FIGURE 1: AERIAL PHOTOGRAPH OF THE PROJECT SITE AND SURROUNDING AREA

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CITY COUNCIL AGENDA ITEM NO. F.1
08/27/2024

APPLICABLE STATE HOUSING LAW
The applicant submitted a preliminary application for this project under SB 330 (Government Code § 65941.1). By submitting a preliminary application and complying with the timelines set forth in the law, applicants can vest or “lock in” the City ordinances and regulations, including zoning and objective design standards, in effect at the time of application (Government Code § 65589.5(o)). In this case, the application must be processed under the City ordinances and regulations in effect as of submittal of the preliminary application, October 22, 2021.

Review of the application must also comply with all of the provisions SB 330, including the following:
 If the application complies with the applicable objective general plan, zoning, and subdivision standards and criteria, including design review standards, the City cannot deny or condition the project in a manner that would lessen the intensity of housing, such as decreasing the density or number of units (Government Code § 65589.5(j)). Therefore, the City cannot require compliance with the City’s General Plan “mid-range” policy or require that the applicant obtain conditional use permits for any units over a certain density.

The “mid-range” policy requires that applicants meet subjective criteria to develop above the mid-point of the applicable General Plan density range, and is, therefore, contrary to the requirement that cities cannot limit density through subjective criteria. The Brentwood Municipal Code (BMC) also requires that residential projects obtain CUPs for units over a certain density range, for PD-36 over 3.5 units per gross acre (see BMC §§ 17.130(B),

17.486.004(B)(1)). This provision is also contrary to current state law and therefore cannot be imposed.
 The City cannot impose the maximum number of primary dwelling units set forth in PD-36 (see BMC § 17.486.004(C)(12)), as it is directly contrary to SB 330, which states that a city may not impose a housing cap (Government Code § 66300(b)(1)(D)(ii)).
 Any decision to deny or lower the density of a project that is consistent with applicable objective City standards must be supported by a preponderance of evidence that both: (1) the project has a specific adverse impact upon public health or safety based on objective, identified written public health or safety standards; and (2) there is no feasible way to mitigate the impact other than denial or approval at a lower density. (Government Code § 65589.5(j)(1).)

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CITY COUNCIL AGENDA ITEM NO. F.1
08/27/2024

PROJECT SUMMARY
General Plan & Zoning Consistency
The project is consistent with the General Plan. As shown in the figure below, the General Plan designates the overall project site for a variety of land uses, including Residential Low Density (R-LD) on the majority of the site and south of Sand Creek Road, which allows for development between 1.1 and 5.0 dwelling units per gross acre. The northern portion of the site, which includes a single parcel of 36.82 acres, is shown on the vesting tentative subdivision map as a designated remainder with no specific development proposed as part of this application1 The General Plan also designates approximately six acres of the site as Park and approximately 25 acres of the site as Permanent Open Space, all of which are located south of Sand Creek Road along the western boundary of the site.

Figure 2: General Plan Land Use Designations
The zoning for the project site is PD-36, which is set forth in BMC Chapter 17.486 and includes a map that does not show any subarea boundaries. Chapter 17.486 does; however, include objective zoning standards for PD-36 that are consistent with the General Plan designation. The fact that the map for PD-36 does not include

1 The applicant has filed separate preliminary applications under SB 330 for development of this area, but no formal development applications have been submitted to date. The applicant is required to submit the required development applications by September 21, 2024 (within 180 days of submittal of a qualifying preliminary application to the City).

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CITY COUNCIL AGENDA ITEM NO. F.1
08/27/2024
locations for the various subareas was one of the subjects of a lawsuit concerning this application. In that lawsuit, the City maintained that appropriate residential development standards are those in BMC Section 17.486.004, referring to Subarea C. This was consistent with the property’s General Plan designation of Residential Low Density, which allows for residential development densities ranging from 1.1 to

5.0 units per acre. The court hearing the lawsuit did not raise concerns with using these objective standards to review the subject application, and so these have been applied.

The minimum lot size for PD-36, Subarea C is 5,000 sf. The applicant thus provided a revised VTSM on August 4, 2023 to comply with BMC Section 17.486.004, including a minimum lot size of 5,000 sf, which resulted in a reduction in the number of lots from 286 (October 2021) to 272, remaining consistent with the density identified in the General Plan designation of Residential Low Density. The project also complies with the PD-36 development standards pertaining to open space and recreation.

It should be noted that the City cannot impose certain PD-36 standards that are inconsistent with State law (e.g., Subarea C’s requirements regarding a housing cap or the requirement to obtain a CUP for residential units over a certain density).

A detailed analysis of the project’s General Plan and Zoning consistency can be found starting on page 21 in the Planning Commission staff report (Attachment 7).

Vesting Tentative Subdivision Map
The project site consists of a total of 135.31 acres. Of this acreage, 25 acres (Parcel I) are preserved as permanent open space, the majority of which is located along the western property line corresponding to hillside ridgelines. The remaining acreage located south of Sand Creek Road includes a ten-foot trail connection (Parcel H) to the Brentwood Hills subdivision to the south, two park locations (6.0 acre Parcel A and 2.49 acre Parcel G, resulting in 4.35 acres of useable park space with less than three percent slope), per the Parks, Recreation and Trails Master Plan, and the 272 single-family residential lots. The trail connection is clarified in draft condition of approval #12b on the tentative map resolution to be relocated to Parcel I, connecting to Sand Creek Road; therefore, Parcel H can be eliminated and absorbed into the adjacent lots.

The single-family lot sizes would range from 5,000 sf to 15,930 sf. The remaining parcels are to be utilized for landscaping or bioretention areas for stormwater treatment. Along the northern property line and north of Sand Creek is a 36.82-acre designated remainder parcel, which is not proposed to be developed as part of this project.

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Figure 3: VTSM 9586
Access to the single-family development would be through a signalized intersection with Sand Creek Road from the north (located just west of the SR 4 interchange) and another via the extension of San Jose Avenue from the south.

A more detailed description of the Vesting Tentative Subdivision Map can be found starting on page 9 in the attached Planning Commission staff report (Attachment 7).

Affordable Housing

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Under SB 330, the project must comply with the affordable housing ordinance in place at the time of application submission. Ordinance No. 1014 was in place at the time of project application and requires 10% of the total units within a project to be affordable to various income categories. The applicant originally proposed less than the required number of affordable units, but has since agreed to comply with Ordinance No. 1014. A draft condition of approval is included to require the Applicant to enter into an Affordable Housing Agreement with the City to provide a minimum of 27 affordable units at the required affordability levels. Compliance with this condition, per the City’s Affordable Housing Ordinance, is required prior to final map approval and will ensure, among other things, that the affordable units are spaced appropriately throughout the subdivision. The affordability levels for the 27 units are broken down as follows:

Affordability Level Requirement
Very Low Income 3% of 272 = 8 units
Low Income 4% of 272 = 11 units
Moderate Income 3% of 272 = 8 units
Total 10% = 27 units
Design Review
The proposed design review includes 13 distinct floor plans with four alternative elevations per plan, except for Floor Plan 13, which has two elevations. The project includes only two units to be built according to Floor Plan 13, which shows it as a three-story unit. Three of the plans, Plans 1, 2, and 3, are single-story homes, with the remaining plans all two-story homes with a two-car front-on garage. Due to the relatively small minimum lot size (5,000 sf), alternative garage configurations are difficult to accomplish; however, the homes are designed to minimize the garage by setting it back from the front plane of the living spaces, thereby minimizing its prominence in the front elevation, and all of the plans show decorative garage doors to match the architectural style of the home. As mentioned, each plan has four distinct architectural styles, including Tuscan, Craftsman, French Cottage, and Bay Area Modern. The master plotting plan shown below, depicts the variation of the different home plans and elevations to ensure that no two identical homes are located next to each other. A more detailed explanation can be found starting on page 25 in the attached Planning Commission staff report (Attachment 7) for more information.

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Figure 4: Master Plotting Plan

PLANNING COMMISSION MEETINGS
The Planning Commission held a public hearing on September 5, 2023, at which many items were discussed. The Planning Commission continued the item and directed staff to work with the applicant on options to address concerns regarding traffic due to the extension of San Jose Avenue and the potential additional traffic on St. Regis Avenue.

On July 16, 2024, the Planning Commission held a continued public hearing on the proposed project which included a discussion of several options related to the St.

Regis Avenue/San Jose Avenue intersection as well as other topics which are summarized below. It should be noted that the July 2024 hearing reiterated many topics which had been raised at the September 2023 hearing, so the summary below encompasses both hearings.

St. Regis Avenue and San Jose Avenue Circulation Options As noted above, after the previous hearing, the Planning Commission directed staff to work with the applicant on options to address the concerns regarding traffic.

Consistent with the Planning Commission’s motion, the applicant prepared a memo (dated October 12, 2023) to address the options for minimizing additional traffic on St. Regis Avenue (included in Attachment 13). Five options were evaluated in the memo and are summarized in the table below.

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Table 1: St. Regis Avenue/San Jose Avenue Intersection Options Option Summary
Option 1 Would prohibit (a) eastbound right turns from the planned San Jose Avenue extension onto St. Regis Avenue, and (b) southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue Option 2 Like Option 1, would prohibit (a) eastbound right turns from the planned San Jose Avenue extension onto St. Regis Avenue, and (b) southbound through traffic from Chestnut Oak Drive onto St.

Regis Avenue, but would additionally prohibit (c) southbound leftturns from Chestnut Oak Drive to eastbound San Jose Avenue Option 3 Would restrict a one-block section of the San Jose Avenue extension (immediately west of St. Regis Avenue) to one-way westbound traffic flow only and prohibit southbound left-turns from Chestnut Oak Drive to eastbound San Jose Avenue
Option 4 Full or partial closure at the south end of Chestnut Oak Drive Option 5 Would include an additional access point from the Bridle Gate Project to Sand Creek Road
A summary of the options from the memo is provided below.  Option 1: Turn Restrictions Alternative A
Two components make up Option 1. The first component is a prohibition of eastbound right turns from the planned San Jose Avenue extension onto St. Regis Avenue. A preliminary design for this is presented below. This plan would include an extension of the curb on the southwest corner to not allow right turns and increase compliance with the prohibition on right turns from eastbound San Jose Avenue onto southbound St. Regis Avenue. The second component of Option 1 is preventing southbound traffic from Chestnut Oak Drive from accessing St.

Regis Avenue. With the turn restrictions at the St. Regis Avenue/San Jose Avenue intersection, traffic on southbound Chestnut Oak Drive would only be able to turn left or right onto San Jose Avenue and southbound through traffic onto St. Regis Avenue would be prohibited. In addition to signage, all-way stop control, and pavement markings, this plan would include a splitter island on the southbound Chestnut Oak Drive approach that would preclude through traffic onto St. Regis Avenue.

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Figure 5: Option 1: Turn Restrictions Alternative A
 Option 2: Turn Restrictions Alternative B
Option 2 is essentially the same as Option 1, with the exception that southbound left-turns from Chestnut Oak Drive to eastbound San Jose Avenue would also be prohibited. A preliminary design for accomplishing this is presented below. This plan would include the same extension of the curb on the southwest corner of the intersection to not allow right turns and increase compliance with the prohibition on right turns from eastbound San Jose Avenue onto southbound St. Regis Avenue. However, under this option on the northern side of the intersection all southbound traffic would be required to turn right onto San Jose Avenue. Left turns onto San Jose Avenue and southbound through traffic onto St. Regis Avenue would both be prohibited.

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Figure 6: Option 2: Turn Restrictions Alternative B
 Option 3: One-Way Street
Option 3 includes two components. The first is to restrict the first segment of the San Jose Avenue extension to one-way westbound traffic only to the west of its intersection with St. Regis Avenue. The one-way section would extend from St.

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is the same as for the above-described turn restrictions option. In addition to restricting a one-block segment of San Jose Avenue to eastbound traffic only, this option would also include the same prohibition to southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue. Traffic on southbound Chestnut Oak Drive would only be able to turn right onto San Jose Avenue, while left-turns and through traffic would be prohibited. A preliminary design for accomplishing this is presented below.

Figure 7: Option 3: One Way Street
 Option 4: Full or Partial Street Closure
This option involves a full or partial closure at the south end of Chestnut Oak Drive. A partial closure would involve closing only the southbound direction of Chestnut Oak Drive at San Jose Avenue. Under this option, traffic would still be permitted to travel northbound onto Chestnut Oak Drive from the San Jose Avenue/St. Regis Avenue intersection. In the other direction, southbound traffic would be prohibited using a design to block traffic that would be acceptable to the Fire District. The roadway would be designed to effectively block any

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southbound traffic from entering the intersection from Chestnut Oak Drive. A full closure would involve closing both directions of Chestnut Oak Drive just north of San Jose Avenue. Under this option Chestnut Oak Drive would become a dead end just north of the San Jose Avenue/St. Regis Avenue intersection. This would include a connection to San Jose Avenue for emergency vehicles only, designed in a manner that would be acceptable to the Fire District. The southern end of the roadway would be designed to effectively block any Chestnut Oak Drive traffic from traveling to or from San Jose Avenue or St. Regis Avenue. The intersection of St. Regis Avenue with San Jose Avenue would become a three-way intersection, with no northern leg connecting to Chestnut Oak Drive. Note, the applicant’s consultant did not prepare a corresponding figure for Option 4.  Option 5: Additional Access to Sand Creek Road
Option 5 would create a new right-in/right out only access point onto Sand Creek Road between Bridle Gate Drive and the intersection with the State Route 4 (SR 4) eastbound ramps. A full-access intersection is not feasible because intersection spacing standards cannot be met. In addition, there are significant topography issues, with the grade difference between the Bridle Gate roadway system and the final alignment of Sand Creek Road being substantial. Therefore, the only potential option to consider would be a new right-in/right out only access onto Sand Creek Road to the east of Bridle Gate Drive. Note, the applicant’s did not prepare a corresponding figure for Option 5.
 Planning Commission Discussion of Options
The Planning Commission reviewed the options and determined that none of them reduced existing traffic that turns left (south) onto St. Regis Avenue. Staff explained that the options were designed to reduce the project’s traffic on St.

Regis Avenue and that the applicant is not responsible for solving existing traffic issues or concerns. The Planning Commission discussed many options, including closing St. Regis completely and time restrictions on westbound left-turns from San Jose Avenue onto St. Regis Avenue.

Traffic
The Planning Commission expressed concerns with the use of a traffic study from 2020. Staff explained that the traffic counts conducted were still valid because of the limited changes in the immediate vicinity. Further, the traffic study looked at a significantly larger version of the project so any impacts would likely be reduced from what was identified in the study. Finally, staff explained that CEQA no longer allows analysis of environmental impacts based on level of service (LOS), and currently uses

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a methodology based on vehicle miles traveled (VMT). The CEQA analysis of traffic and transportation can be found beginning on page 245 of the REIR, which can be accessed by clicking on the following link and scrolling to “Bridle Gate:” https://www.brentwoodca.gov/government/communitydevelopment/planning/ceqa-documents.

Parks
The Planning Commission had concerns that the proposed project includes two parks rather than a central larger park. The proposed subdivision includes two designated park parcels. Parcel A, located northwest of the main access at Sand Creek Road (as shown in the General Plan), is six acres and will be designed as a neighborhood park2.

The smaller park is Parcel G, which encompasses 2.49 acres and will also be designed as a neighborhood park. Staff has calculated the required park acreage based on an expected population within the subdivision of 870 (272 units x 3.2 persons per unit).

Using the City’s formula of providing 5 acres of park for every 1,000 residents, a total of 4.35 acres of park is required.

Parcel A is identified as a park consisting of six acres. Of this six acres, 1.94 acres will be graded to less than 3% slope, which is considered usable park land. Parcel G is identified as a park consisting of 2.49 acres, of which 2.41 acres will be graded to less than 3% slope, and thus considered usable park land. The two parks combined result in 4.35 acres, consistent with the required acreage.

Staff explained that the Parcel A park is consistent with the General Plan and to require a larger centrally located park would require a General Plan Amendment, which the City cannot require the developer to do. Staff further explained that having two parks allows greater access for the entire subdivision and described various park programming that might be placed in each park. In addition, there is no objective standard requiring one larger park.

Affordable Housing Locations
The applicant provided a preliminary concept of the locations of the affordable units within the subdivision at the Planning Commission hearing at the request of staff (Attachment 15); however, staff was not able to review the plan before the hearing.

At the hearing, staff noted that, should the project be approved, the final location of

2 According to the City’s Parks, Trails & Recreation Master Plan Update (p. 22), neighborhood parks are parks that typically serve the surrounding neighborhood for multiple uses. Park development may include play areas, small fields, benches, picnic tables, and improved paths but do not include restroom facilities. Geographic range of users is generally up to one-half-mile as the crow flies.

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the units would be determined as part of the Affordable Housing Agreement with the City Council. The Planning Commission suggested that the units be further spread throughout the subdivision when it was reviewed by City Council. The conceptual plan provided by the applicant does not distribute the units throughout the development as required by the Affordable Housing Ordinance. A condition on the VTSM (Condition #20) requires compliance with the Affordable Housing Ordinance, including its provisions as to spacing of the affordable units.

Hillside Preservation
The Commission expressed concerns that PD-36 was designed to preserve hillsides and that the proposed project would be constructed in a manner that does not preserve the hillside, which is inconsistent with the General Plan. Staff explained that the General Plan policy focuses on the unnecessary grading of a hillside.

Noise
The Commission discussed the required noise mitigation and questioned the adequacy of the analysis, the varying heights of the wall, and the adequacy of the STC rating. Commissioners expressed concern that in order to meet the standards, windows must remain closed. Staff explained the methodology of the noise analysis, as well as the applicable City noise standards. The Commission noted that these homeowners would be aware of the noise situation when purchasing a home. The CEQA analysis of noise can be found beginning on page 222 of the REIR, which can be accessed by clicking on the following link and scrolling to “Bridle Gate:” https://www.brentwoodca.gov/government/communitydevelopment/planning/ceqa-documents.

EIR
The Planning Commission expressed concerns regarding the number of potentially significant impacts identified in the EIR. Staff explained that the document they were referring to was the Initial Study prepared to determine areas that required further analysis in the EIR. Each of the environmental areas were analyzed in the EIR and, if necessary, mitigation measures were imposed to reduce the impacts to a less-thansignificant level. The EIR did not identify any significant and unavoidable impacts.

The Commission specifically questioned the impacts of abandoned oil wells. Staff explained that the wells have been abandoned to the standards of the State of California and were revisited again prior to the preparation of the EIR and found to be in compliance. Mitigation measures are included to require no structures within a 10-foot radius around the wells as required by the BMC and to require disclosure of the wells to future owners.

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Questions were also raised regarding the adequacy of the biological mitigation measures and the loss of habitat. Staff explained that the purpose of the HCP is to cumulatively be able to purchase habitat that would not be fragmented and allow adequate preservation of habitat.

The REIR for the project can be accessed by clicking on the following link and scrolling to “Bridle Gate:” https://www.brentwoodca.gov/government/communitydevelopment/planning/ceqa-documents.

Landscape and Defensible Space
The Commission raised concerns regarding defensible space around the homes and whether homeowners will be able to obtain insurance if there is not sufficient defensible space around the homes, particularly related to the proposed front yard landscaping. The Commission ultimately wanted to ensure that homes would be able to procure insurance, and therefore wanted to add a condition of approval to require a minimum of five feet of defensible space around the homes. Additionally, the Commission discussed the concern that the proposed trees may cause the sidewalks to buckle over time.

Zoning Standards
The Planning Commission noted that they were concerned with the application of the PD-36 Sub Area C standards and noted that Sub Area D standards are objective and would also be consistent with the General Plan. As noted above under the Zoning discussion, staff explained that the court hearing the lawsuit did not have objection to the imposition of the Sub Area C standards, but did not explicitly address the Sub Area D standards. The PD-36 Zoning standards can be found at the following link:
https://ecode360.com/43621934.

Planning Commission Action
After deliberation, including the discussion mentioned above, the Planning Commission voted unanimously to deny the proposed project. Because a denial does not require CEQA review, the Planning Commission took no action regarding the EIR.

The Planning Commission provided findings for denial which were incorporated into the resolution (Attachment 6).

CITY COUNCIL OPTIONS
Several resolutions are attached which provide the City Council with two options for the proposed Bridle Gate project.

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 Option 1: Deny the Project:

Attachment 2 is a draft resolution that would deny the appeal and uphold the Planning Commission’s denial of the project. The draft resolution denies the proposed vesting tentative subdivision map and the design review. The resolution further notes that CEQA is not required for denial and therefore takes no action related to the REIR. The draft resolution includes the list of required findings that must be made for the project. The City Council will need to determine which of these findings cannot be made based upon the evidence and the facts in the record. If the Council opts for Option 1, staff would recommend that the City Council provide direction to staff regarding the evidence to support the findings and staff would then bring a final resolution back to the City Council for adoption.  Option 2: Approve the Project
Attachments 3 through 5 are draft resolutions that would uphold the appeal, overturn the Planning Commission’s decision and approve the project. Attachment 3 certifies the EIR. Attachment 4 approves the vesting tentative subdivision map, including findings of fact and conditions of approval. Attachment 5 approves the design review, including findings of fact and conditions of approval. These resolutions were originally included in the Planning Commission packet based upon the staff recommendation for approval and have been modified to include recitations related to Planning Commission action and the appeal.

CITY COUNCIL STRATEGIC INITIATIVE
Not applicable.

PREVIOUS ACTION
Previous Actions are included as Attachment 1.

DATE OF NOTICE
The City of Brentwood published a public hearing notice in the Brentwood Press and mailed it to all property owners within 300 feet of the site on August 16, 2024.

ENVIRONMENTAL DETERMINATION
The Bridle Gate Project has been previously proposed and evaluated in past EIRs. A new project-level REIR has been prepared for the currently proposed project. In order to differentiate the current analysis from previous EIRs, although an REIR is not a technical CEQA term, the current analysis has been labeled as such in order to further denote that the Bridle Gate Project has been revised and is now subject to new

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analysis. The REIR (SCH# 2022120683) for this project was prepared in accordance with the requirements of CEQA. Several potentially significant impacts are identified; however, mitigation measures are incorporated to reduce those impacts to less-thansignificant levels. All mitigation measures not addressed by the standard conditions of approval are included as recommended conditions of approval. The Draft REIR was available for review and comment from May 26, 2023 to July 10, 2023. Several comments were received and addressed in the Final REIR. The Draft REIR and Final REIR may be reviewed by clicking on the link below and scrolling to “Bridle Gate:” https://www.brentwoodca.gov/government/communitydevelopment/planning/ceqa-documents In addition, the City’s CEQA consultant, Raney Planning & Management, Inc., prepared a memorandum (Attachment 13), to analyze whether any of the proposed traffic calming options, which are described in detail below, would alter the conclusions of the REIR (“CEQA Traffic Options Memo”). The CEQA Traffic Options Memo concluded that none of the options alter the conclusions of the REIR.

ATTACHMENT(S)

1. Previous Actions

2. Draft City Council Resolution Denying VTSM 9586 and DR 21-010

3. Draft City Council Resolution Certifying the EIR

4. Draft City Council Resolution Approving VTSM 9586

5. Draft City Council Resolution Approving DR 21-010

6. Planning Commission Resolution No. 23-032 (adopted July 16, 2024)

7. Planning Commission Staff Report without attachments (July 16, 2024)

8. Final Revised EIR (see link embedded on page 19 of the staff report)

9. Draft Revised EIR (see link embedded on page 19x of the staff report)

10. VTSM 9586 and Preliminary Grading & Utility Plan

11. Bridle Gate Design Review Booklet

12. Preliminary Landscape Plans

13. Raney Memorandum on Traffic Calming Options (July 9, 2024)

14. City Council Ordinance No. 1014

15. Preliminary Affordable Housing Site Layout

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PLANNING COMMISSION AGENDA ITEM NO. E.1
07/16/2024
SUBJECT: Bridle Gate - Revised Environmental Impact Report, Vesting Tentative Subdivision Map, and Design Review
DEPARTMENT: Community Development
STAFF: Erik Nolthenius, Planning Manager
Cindy Gnos, Contract Planner (Raney Planning & Management)

TITLE/RECOMMENDATION
Staff recommends that the Planning Commission adopt the attached Resolutions, thereby certifying the Revised EIR and making CEQA findings, and approving a Vesting Tentative Subdivision Map and Design Review for the Bridle Gate Project proposed by WCHB Development, LLC. Consideration of this project was continued to a date uncertain at the Planning Commission meeting on September 5, 2023.

A Revised Final Environmental Impact Report (RFEIR) has been prepared for this project pursuant to the California Environmental Quality Act, and the Planning Commission will consider whether to certify the document and make required findings.

OWNER/APPLICANT
WCHB Development, LLC

GENERAL PLAN
As shown in Figure 1 below, the General Plan designates the overall project site for a variety of land uses, including Residential Low Density (R-LD) on the majority of the site and south of Sand Creek Road, which allows for development between 1.1 and 5.0 dwelling units per gross acre. The northern portion of the site, which includes a single parcel of 36.82 acres, is shown on the vesting tentative subdivision map as a designated remainder with no specific development proposed as part of this application (the applicant has filed separate preliminary applications under SB 330 for development of this area, but no formal development applications have been submitted to date.) The General Plan also designates approximately six acres of the site as Park and approximately 25 acres of the site as Permanent Open Space, all of which are located south of Sand Creek Road along the western boundary of the site.

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Figure 1: General Plan Land Use Designations

ZONING/SURROUNDING LAND USES
The zoning for the project site is PD-36, which is set forth in Brentwood Municipal Code (BMC) Chapter 17.486 and includes a map that does not show any subarea boundaries. Chapter 17.486 does; however, include objective zoning standards for PD-36 that are consistent with the General Plan designation. The fact that the map for PD-36 does not include locations for the various subareas was one of the subjects of a lawsuit concerning this application. In that lawsuit, the City took the position

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that the appropriate residential development standards are those in BMC Section

17.486.004, referring to Subarea C. This conclusion was consistent with the property’s General Plan designation of Residential Low Density, which allows for residential development densities ranging from 1.1 to 5.0 units per acre. The court hearing the lawsuit did not raise concerns with using these objective standards to review the subject application, and so these have been applied.

Furthermore, the only other residential subarea in PD-36 is Subarea D, which requires a minimum lot size of 10,000 sf, which, if applied to this project, would substantially decrease the density such that it would also be inconsistent with State law.

Surrounding Land Uses
North – vacant land within the Priority Area 1 (PA-1) Specific Plan area identified for future Employment Center/Light Industrial development (ECLI) East – State Route 4, with The Streets of Brentwood and vacant commercial property beyond
South – two City-owned parcels for permanent open space and a water tank, as well as single-family homes in the Brentwood Hills subdivision West – city limits, with the city of Antioch beyond

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Figure 2: Aerial Photograph of Project Site and Surrounding Area

PREVIOUS ACTION(S)
See attached.

BACKGROUND
The applicant, WCHB Development, LLC, seeks to subdivide the Bridle Gate site to allow for a variety of uses, notably 272 single-family homes.

PREVIOUS PLANNING COMMISSION ACTION
On September 5, 2023, the Planning Commission held a public hearing on the proposed Bridle Gate project and took testimony from the applicant, as well as 11

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members of the public. After noting several concerns about the project (most notably traffic and specifically the intersection of St. Regis Avenue/San Jose Avenue) and a lengthy deliberation, the Commission ultimately adopted the following motion by a 4-0 vote to continue the item (Chairperson Roberts was absent):

Continue the item to a date uncertain and direct staff to work with the applicant to evaluate the intersection of St. Regis Avenue/San Jose Avenue for a possible gate or emergency vehicle access only, with the understanding that staff will evaluate any other viable solution that would lessen the impact of traffic on the existing residential areas to the south (i.e., Brentwood Hills and Shadow Lakes).

Since that time, staff has been working with the applicant pursuant to the Planning Commission’s direction and has been addressing issues that arose from a change in the parties representing the applicant.

In addition, it is important to note that state law, namely SB 330, only allows a maximum of five public hearings on a project that does not require legislative approvals, such as this project. A hearing includes any public hearing, continuances of a hearing, workshop, or similar meeting, including any appeal. This meeting represents the second public hearing on the project, leaving only three other public hearings available, including any subsequent consideration by the City Council by way of a call for review or an appeal.

PRIOR APPLICATIONS
This application represents the latest in a long series of land use applications submitted for this site (see the attached list of Previous Actions). 2006 Project
On June 6, 2006, the Planning Commission approved the first version of the Bridle Gate project. Commensurate with that approval, an Initial Study/Mitigated Negative Declaration (IS/MND) was adopted, which identified that all impacts resulting from the project could be reduced to a less-than-significant level with implementation of mitigation measures. The 2006 project included the following approvals by the City Council: (1) a General Plan Amendment to modify the text of the existing Special Planning Area E land use designation; (2) a Rezone of the project site to establish standards and subareas for the Planned Development No. 36 (PD-36) zoning designation; and (3) a Development Agreement. The approved Tentative Subdivision Map for the project was never finalized or recorded and ultimately expired. The

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Development Agreement also subsequently expired. The General Plan and zoning changes, however, remain generally in place, except as modified in 2014. 2014 General Plan Update
In 2014, the City adopted a comprehensive update to the General Plan and revised certain land use designations applicable to the Bridle Gate project site. These changes included the designation of the entire project site to Residential Low-Density, which was requested by the project applicant. Further, the zoning for the project site was amended to include a PD map that encompassed the entire site and did not include mapped boundaries for the various Subareas that were previously identified in the zoning for PD-36 in 2006.
2020 Project
A revised version of the Bridle Gate Project was proposed in 2020 (the 2020 Bridle Gate Project), and, due to substantial changes to the project, an EIR was prepared.

The requested entitlements included:
 A General Plan Amendment to (1) change the land use designation for the northwesterly 13.98 acres of the site from Regional Commercial (RC) to Planned Development (PD) to allow for up to 258 multi-family units; (2) change the land use designation for 4.3 acres of the site south of the Sand Creek Road alignment to Park (P) to allow for two public parks associated with the single-family units; and (3) revise the planned alignment of the proposed San Jose Avenue extension in the Circulation Element;
 A Rezone of the site to modify the existing development standards for PD-36 to accommodate the single-family and multi-family portions of the site;  A Development Agreement between the City of Brentwood and the project applicant;
 A Vesting Tentative Subdivision Map (VTSM) to subdivide the approximately 137.3-acre project site into 4.3 acres for public parks, 13.98 acres for up to 258 multi-family units, approximately 28.35 acres for permanent open space, 252 single-family units, an 11.35-acre elementary school site (or alternatively, a residential overlay that could accommodate an additional 63 single-family units if the school was not constructed), and 19.59 acres for future commercial development; and
 A Design Review for the single-family and multi-family portions of the site.

The project included the development of 252 single-family residences and the dedication of two parcels to the City of Brentwood for use as public parks. The project

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also included an 11.35-acre parcel to be sold to the Brentwood Union School District for development as an elementary school or, alternatively in the event the school construction did not proceed, development with an additional 63 single-family residences. As of the date the Planning Commission considered the proposed project, the project included future development of a 258-unit apartment complex, as well as one parcel designated for future Regional Commercial development. However, subsequent to the Planning Commission hearing on the proposed project, the applicant notified the City that it wished to modify the project to no longer include the 258-unit apartment complex. The applicant ultimately submitted a revised proposed VTSM on January 29, 2021, formally amending the application for the 2020 Bridle Gate Project. As a result of the project amendment, the requested General Plan Amendment, Rezoning, and Design Review requests were also modified to eliminate the multi-family component. The City Council denied the modified project on March 9, 2021, and the 2020 EIR that analyzed the 2020 Bridle Gate Project was not certified.

Current 2021 Application
A third application for the project, which is currently under consideration, was submitted to the City of Brentwood in late 2021 and was deemed complete in June 2022. This application differs from the prior applications in that, unlike the prior applications, the applicant is not seeking any legislative or discretionary entitlements.

Rather, the developer is seeking only vesting tentative subdivision map and design review approvals since the proposed project would be consistent with the General Plan and zoning for the site, as discussed in more detail below. As such, the Planning Commission is limited in its decision-making to determining whether the findings for approval of the vesting tentative subdivision map and design review can be made.

There are also state law limitations on the Planning Commission’s discretion, as described in more detail below.

Review of the application must also comply with SB 330. Most importantly, if the application complies with the applicable objective general plan, zoning, and

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subdivision standards and criteria, including design review standards, the City cannot deny or condition the project in a manner that would lessen the intensity of housing, such as decreasing the density or number of units (Government Code § 65589.5(j)).

Therefore, the City cannot require compliance with the City’s General Plan “midrange” policy or require that the applicant obtain conditional use permits for any units over a certain density. The “mid-range” policy requires that applicants meet subjective criteria to develop above the mid-point of the applicable General Plan density range, and is, therefore, contrary to the requirement that cities cannot limit density through subjective criteria. The BMC also requires that residential projects obtain CUPs for units over a certain density range, for PD-36 over 3.5 units per gross acre (see BMC §§ 17.130(B), 17.486.004(B)(1)). This provision is also contrary to current state law and therefore cannot be imposed. Further, the City cannot impose the maximum number of primary dwelling units set forth in PD-36 (see BMC §

17.486.004(C)(12)), as it is directly contrary to SB 330, which states that a city may not impose a housing cap (Government Code § 66300(b)(1)(D)(ii)).

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(du/ac). The density calculation included here is based only on the portions of the site dedicated to residential use and not designated as Permanent Open Space, consistent with the City’s General Plan.

In accordance with State law, the City can only require that impacts related to schools be mitigated by the applicant’s payment of fees, prior to any building permit issuance.

Impacts related to fire protection services would be mitigated by the requirement to annex into the current Emergency Medical and Fire Protection Service Funding Community Facilities District (CFD).

ANALYSIS

VESTING TENTATIVE SUBDIVISION MAP
The project site consists of a total of 135.31 acres. Of this acreage, 25 acres (Parcel I) are preserved as permanent open space, the majority of which is located along the western property line corresponding to hillside ridgelines. The remaining acreage located south of Sand Creek Road includes a ten-foot trail connection (Parcel H) to the Brentwood Hills subdivision to the south, two park locations (6.0 acre Parcel A and 2.49 acre Parcel G), per the Parks, Recreation and Trails Master Plan, and the 272 single-family residential lots. The trail connection is clarified in draft condition of approval #12b on the tentative map resolution. The single-family lot sizes would range from 5,000 sf to 15,930 sf. The remaining parcels are to be utilized for

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landscaping or bioretention areas for stormwater treatment. Along the northern property line and north of Sand Creek is a 36.82-acre designated remainder parcel (formerly the proposed multi-family site as part of the prior development application), which is not proposed to be developed as part of this project.

Access to the single-family development would be through a signalized intersection with Sand Creek Road from the north (located just west of the SR 4 interchange) and another via the extension of San Jose Avenue from the south.

Figure 3: Proposed Vesting Tentative Subdivision Map

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BMC Section 16.050.040(B) identifies seven findings applicable to a decision to approve or deny a subdivision map. In the interest of space, each of these findings is analyzed in the attached draft tentative map resolution. In sum, each of the required findings can be made. Recommended conditions of approval are also attached to the draft resolution to mitigate the impacts of the project.

Roadway Improvements and Frontage
The proposed project would include construction of new internal roadways and the extension of San Jose Avenue to the west. It should be noted that a separate Cityinitiated capital improvement project, Sand Creek Road Extension, is currently underway that will extend two lanes of Sand Creek Road from the westerly existing terminus of SR 4 to Heidorn Ranch Road to the northwest. The City project is on schedule for completion in September 2024 and will extend along the northern boundary of the proposed single-family residential portion of the project and connect to one of the new internal roadways (Bridle Gate Drive) to provide site access. Site access would also be provided by the proposed extension of San Jose Avenue. The proposed internal circulation system would be located throughout the proposed single-family residential subdivision, and would be designed to meet current City standards and would include sidewalks on both sides. Pedestrian access would be provided in the form of sidewalks and trails throughout the proposed development, in conformance with City standards.

As proposed, lots 237 through 257 are considered double frontage lots, with frontage along San Jose Avenue/Bridle Gate Drive and Mill Brook Drive, respectively. Lots 47 through 59 and lots 115 through 133 are also double frontage lots, with frontage along San Jose Avenue/Bridle Gate Drive and Woodglen Drive/Cottonwood Avenue, respectively. A draft condition of approval is included to prohibit vehicular access to the double frontage lots from Bridle Gate Avenue and San Jose Avenue. Access to double frontage lots would be provided by the more interior roadway, such as Millbrook Drive and Cottonwood Avenue. In addition, a draft condition of approval requires the frontage along San Jose Avenue/Bridle Gate Avenue to include a sidewalk and landscaping for the double frontage lots.

Landscaping of the frontage along San Jose Avenue and Bridle Gate Drive would be privately maintained through a perpetual funding mechanism such as a homeowners’ association, which will be required in a draft condition of approval.

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The City received several comment letters on the Draft REIR from residents of the neighborhood to the south of the project expressing concern about the extension of San Jose Avenue and the project’s impacts to increased traffic volumes for San Jose Avenue. The extension of San Jose Avenue was also a significant topic of discussion at the September 5, 2023 Planning Commission hearing. It should be noted that the extension of San Jose Avenue is included in the General Plan Circulation Element.

The proposed circulation would be beneficial to both the proposed homes and existing neighborhoods, as it would provide a direct vehicular connection to Sand Creek Road for more efficient access to PA-1 (the Innovation Center), emergency health services at Kaiser Hospital, and State Route 4. In addition, as determined in the Bridle Gate REIR, with incorporation of mitigation measures, the proposed project would result in a less-than-significant impact for transportation.

Consistent with the Planning Commission’s motion, the applicant prepared a memo (dated October 12, 2023) to address the options for minimizing additional traffic on St. Regis Avenue (Attachment 11). Five options were evaluated in the memo:

Table 1: St. Regis Avenue/San Jose Avenue Intersection Options Option Summary
Option 1 Would prohibit (a) eastbound right turns from the planned San Jose Avenue extension onto St. Regis Avenue, and (b) southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue Option 2 Like Option 1, would prohibit (a) eastbound right turns from the planned San Jose Avenue extension onto St. Regis Avenue, and (b) southbound through traffic from Chestnut Oak Drive onto St.

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Option 1: Turn Restrictions Alternative A
Two components make up Option 1. The first component is a prohibition of eastbound right turns from the planned San Jose Avenue extension onto St. Regis Avenue. A preliminary design for this is presented in Figure 3. This plan would include an extension of the curb on the southwest corner to not allow right turns and increase compliance with the prohibition on right turns from eastbound San Jose Avenue onto southbound St. Regis Avenue. The second component of Option 1 is a prohibition to southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue. With the turn restrictions at the St. Regis Avenue/San Jose Avenue intersection, traffic on southbound Chestnut Oak Drive would only be able to turn left or right onto San Jose Avenue and southbound through traffic onto St. Regis Avenue would be prohibited. In addition to signage, all-way stop control, and pavement markings, this plan would include a splitter island on the southbound Chestnut Oak Drive approach that would preclude through traffic onto St. Regis Avenue.

Figure 4: Turn Restrictions Alternative A

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Option 2: Turn Restrictions Alternative B
Option 2 is essentially the same as Option 1, with the exception that southbound leftturns from Chestnut Oak Drive to eastbound San Jose Avenue would also be prohibited. A preliminary design for accomplishing this is presented in Figure 4. This plan would include the same extension of the curb on the southwest corner of the intersection to not allow right turns and increase compliance with the prohibition on right turns from eastbound San Jose Avenue onto southbound St. Regis Avenue.

However, under this option on the northern side of the intersection all southbound traffic would be required to turn right onto San Jose Avenue. Left turns onto San Jose Avenue and southbound through traffic onto St. Regis Avenue would both be prohibited.

Figure 5: Turn Restrictions Alternative B

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Option 3: One-Way Street
Option 3 includes two components. The first is to restrict the first segment of the San Jose Avenue extension to one-way westbound traffic only to the west of its intersection with St. Regis Avenue. The one-way section would extend from St.

Regis Avenue to the first intersection within the Bridle Gate Project (Rose Wood Drive). All eastbound traffic on San Jose Avenue would then have to turn left or right at Rose Wood Drive within the Bridle Gate Project. The second component is the same as for the above-described turn restrictions option. In addition to restricting a one-block segment of San Jose Avenue to eastbound traffic only, this option would also include the same prohibition to southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue. Traffic on southbound Chestnut Oak Drive would only be able to turn right onto San Jose Avenue, while left-turns and through traffic would be prohibited. A preliminary design for accomplishing this is presented in Figure 5.

Figure 6: One-Way Street

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Option 4: Full or Partial Street Closure1
This option involves a full or partial closure at the south end of Chestnut Oak Drive.

A partial closure would involve closing only the southbound direction of Chestnut Oak Drive at San Jose Avenue. Under this option, traffic would still be permitted to travel northbound onto Chestnut Oak Drive from the San Jose Avenue/St. Regis Avenue intersection. In the other direction, southbound traffic would be prohibited using a design to block traffic that would be acceptable to the Fire District. The roadway would be designed to effectively block any southbound traffic from entering the intersection from Chestnut Oak Drive. A full closure would involve closing both directions of Chestnut Oak Drive just north of San Jose Avenue. Under this option Chestnut Oak Drive would become a dead end just north of the San Jose Avenue/St.

Regis Avenue intersection. This would include a connection to San Jose Avenue for emergency vehicles only, designed in a manner that would be acceptable to the Fire District. The southern end of the roadway would be designed to effectively block any Chestnut Oak Drive traffic from traveling to or from San Jose Avenue or St.

Regis Avenue. The intersection of St. Regis Avenue with San Jose Avenue would become a three-way intersection, with no northern leg connecting to Chestnut Oak Drive.

Option 5: Additional Access to Sand Creek Road1
Option 5 would create a new right-in/right out only access point onto Sand Creek Road between Bridle Gate Drive and the intersection with the State Route 4 (SR 4) eastbound ramps. A full-access intersection is not feasible because intersection spacing standards cannot be met. In addition, there are significant topography issues, with the grade difference between the Bridle Gate roadway system and the final alignment of Sand Creek Road being substantial. Therefore, the only potential option to consider would be a new right-in/right out only access onto Sand Creek Road to the east of Bridle Gate Drive.

Staff Analysis of Options
Staff continues to recommend approval of the proposed project with full access at the St. Regis Avenue/San Jose Avenue intersection. This provides enhanced circulation for the entire area, allowing residents to the south to access Sand Creek Road and regional destinations, and is also consistent with the General Plan.

However, staff is cognizant of the concerns noted by the Planning Commission and residents. If the Planning Commission decides to approve the project using one of the alternatives to full access, staff would recommend Option 2. The reduced turning

1 There are no corresponding figures for Option 4 or Option 5

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movements will slightly reduce traffic from the Bridle Gate project traveling south but will still allow residents from the south to travel north. Option 2 maintains pedestrian and bicycle connections and is still consistent with the General Plan. There is concern, however, that a significant amount of the traffic traveling south will use the Sand Creek Crossing Shopping Center as an alternative means of access or make a u-turn on San Jose Avenue, both of which are undesirable.

Option 1 would not be effective in reducing traffic to the south. Options 3 and 4 are inconsistent with the General Plan and, therefore, cannot be imposed upon the applicant. Option 5 to provide additional access on Sand Creek Road would not result in reduced traffic going south.

The proposed resolutions attached to this staff report continue to reflect approval with the proposed full access shown at the St. Regis Avenue/San Jose Avenue intersection pursuant to staff’s recommendation. However, staff will be prepared with alternative language at the hearing in the event that the Planning Commission desires to approve the project with one of the options noted above.

Traffic Impact Study
Timing of Traffic Impact Study
At the Planning Commission hearing on September 5, 2023, several comments and questions expressed concern regarding the timing of the Traffic Impact Study (TIS) prepared for the proposed project. By way of background, in April 2020, KimleyHorn and Associates completed a TIS for an earlier iteration of the project. As set forth in the Executive Summary of the TIS, that document analyzed two potential development scenarios:

Table 2: Development Scenarios Analyzed in 2020 Traffic Impact Study Uses Scenario One Scenario Two
Single Family Homes 328 2652
Multi-Family Units 258 258
Commercial Uses 199,940 sf 199,940 sf
Public School None 900 student K-5 public school

2 The Traffic Impact Study studied 265 units but the project was later revised to reduce the unit count to 252

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The TIS was prepared using traffic counts generated in 2017. In February 2022, Abrams Associates Traffic Engineering, Inc., and staff analyzed the TIS, and determined that it remains applicable to the proposed project for the following reasons:
 The traffic data generated from traffic counts collected in 2017 continues to represent typical conditions for the area because there has not been any new development in the TIS study area since the 2017 counts were conducted. As a result, there have not been new sources of traffic introduced into the area that would appreciably change the traffic counts collected in 2017.  In addition, the onset of the COVID-19 pandemic in 2020 significantly changed traffic patterns and volumes throughout the Bay Area. According to the Metropolitan Transportation Commission (MTC), in 2017, when the TIS’s traffic counts were taken, only 7.5% of Contra Costa workers worked from home. By 2021, the most recent year for which comparable data is available, that number had risen to 28%.3
 Finally, the TIS analyzed two different scenarios of a project considerably larger than the current project. Therefore, the TIS reflects a very conservative analysis of the current project. Table 3 below illustrates the difference between what was originally studied in the TIS and what is now being proposed:

Table 3: Development Scenarios Analyzed in 2020 Traffic Impact Study Compared to Current Project
Uses Scenario
One
Scenario
Two
Current
Project
Difference
Single Family
Homes
328 2652 272 Current Project is
56 fewer homes
than Scenario
One, and 7 more
than Scenario Two
Multi-Family
Units
258 258 - Current Project is
258 units less than
both Scenarios
Commercial
Uses
199,940 sf 199,940 sf - Current Project is
199,940 sq ft less

3 See MTC ‘Commute Mode Choice’ report (updated February 2023), available online at:
https://vitalsigns.mtc.ca.gov/indicators/commute-mode-choice

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than both
Scenarios
Public School - 900 student K5 public school- Current Project includes no
students
Thus, the circulation analysis within the Draft REIR is adequate for CEQA purposes.

Further, in the cumulative scenario, the TIS relies upon the Contra Costa Transportation Authority (CCTA) model for traffic volume projections. The CCTA model utilizes General Plan buildout assumptions to inform growth projections from surrounding communities, as well as the city of Brentwood. The General Plan assumptions include buildout of the Innovation Center. Thus, traffic assumptions for that area of the city are included within the TIS prepared for the proposed project.

Traffic Volume/Trip Generation Projections
Trip generation figures in the TIS are determined based on trip generation rates provided through the Institute of Transportation Engineers (ITE) Trip Generation Manual. Planners and engineers use the trip generation rates for single-family homes to estimate traffic impacts of residential developments. The trip generation rate for a single family home is determined primarily through:
 Site Selection – ITE selects and analyzes sites of various sizes, densities, regions and regions to capture a diverse range of travel behaviors.  Collected Data – ITE performs traffic counts that captures the number of trips and the time of day of each trip.

The collected data is then analyzed and standardized to a common unit of measurement (i.e. trips per dwelling unit) which can then be used to estimate how much traffic a project will produce.

Example trip generation rates for single family homes:
 Average Daily Trips: The ITE Trip Generation Manual provides an average daily trip rate for single-family detached housing units. For example, a typical singlefamily home generates around 9-10 vehicle trips per day per dwelling unit.

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 Peak Hour Trips: During the AM peak hour, a single-family home may generate approximately 0.7 trips per dwelling unit, and during the PM peak hour, it may generate about 1.02 trips per dwelling unit.

During the Planning Commission meeting, there was significant discussion with regard to southbound traffic from the proposed project. As detailed in the TIS, the estimated southbound volume at the St. Regis Avenue and San Jose Avenue intersection is 59 vehicles during the busiest one-hour period in the AM and 177 vehicles during the busiest one-hour period in the PM. These figures represent the anticipated vehicle count, for either Scenario One or Two of a larger project (as described above), that could be expected during the busiest single hour of an average day, when congestion is projected to be at its highest. These estimates do not reflect the total number of trips to be generated on a daily basis.

As detailed previously, if the Planning Commission chooses to restrict southbound traffic then the traffic is expected to be split heading east on San Jose Avenue if similarly allowed by Planning Commission or north onto Sand Creek Road.

Vehicle Miles Traveled Analysis
It should also be noted that traffic congestion can no longer be considered part of CEQA review. Subsequent to preparation of the original TIS, the CEQA statute was amended to require analysis of vehicle miles traveled (VMT) only. Thus, for the purposes of CEQA analysis, a VMT analysis was prepared for the current project, based on the metrics adopted by CCTA. VMT is a metric that captures the total amount of vehicular travel by estimating the number of vehicle trips generated and the length or distance of those trips. VMT is usually measured on a typical weekday, and can be expressed in several ways, such as total VMT, total VMT per service population, home-based VMT per resident, and home-based work VMT per employee.

In compliance with Senate Bill (SB) 743 and following the Governor’s Office of Planning and Research (OPR) guidance, CCTA implemented VMT analysis methodologies. CCTA’s methodology uses the Home-Based VMT per capita metric for residential projects. Home-based VMT is the VMT for trips that begin and end at the residence. The recommended threshold of significance is that the project generated home-based VMT not exceed 85% of the same in the city. The city of Brentwood has a citywide average of 29.6 VMT per capita, which results in a 25.2 VMT per capita threshold to achieve the 15% reduction (i.e., to not exceed 85% of the average).

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Table 4: Project VMT Analysis Results
City of Brentwood
Proposed Project
Before Mitigation
VMT/Resident
Threshold of
Significance VMT/Resident

29.6 25.2 27.0
The project meets the VMT threshold with the implementation of mitigation measures identified in the REIR. Further, an analysis was done to determine if any of the circulation options described above would affect the VMT analysis in the REIR (Attachment 13). According to the analysis, none of the options would be expected to cause significant increases in VMT. Therefore, any additional CEQA analysis of the circulation options above cannot be required.

Other Roadway Issues
The proposed VTSM indicates that the applicant plans for Old Sand Creek Road (located along the north boundary of the overall project site) to be abandoned. A draft condition of approval is included; however, indicating that Old Sand Creek Road is a portion of a collector street in the Innovation Center Specific Plan and shall not be abandoned.

In addition, consistent with BMC Section 12.04.040, a draft condition of approval is included to require the applicant to construct sidewalk, frontage, and median island landscaping and irrigation, and a second westbound vehicle travel lane along the Sand Creek Road project frontage. The City is currently constructing two lanes of Sand Creek Road, but the ultimate width of the road is four lanes, with two lanes in each direction. The applicant is required to add one additional eastbound lane to this route and is eligible for reimbursement for these improvements per the City’s Development Fee Program.

CONSISTENCY WITH GENERAL PLAN REQUIREMENTS
All proposed subdivisions must be consistent with the City’s General Plan in order to be approved. The proposed project demonstrates this consistency in various ways, including:

Table 5: Consistency with General Plan Requirements
General Plan Provision Project Implementation Consistent? Land use designations:
 Residential Low Density
Project as proposed: Yes

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General Plan Provision Project Implementation Consistent?  Regional Commercial
 Park
 Permanent Open Space
 Low density, single-family
residential use
 Regional commercial to
remain undeveloped
 Two neighborhood parks
(8.49 acres total)
 Permanent open space (25
acres)
Density: 1.1-5.0 units/acre Density: 4.0 units/acre Yes Goals and Policies:
 Policy LU 2-1: Maintain
Brentwood’s predominant
land use of single family
residential, while providing
for a mix of housing types
throughout the community,
in accordance with the
Housing Element
 Goal LU-4: Maintain a high
quality natural environment
and recreational
opportunities in and around
Brentwood
 Policy IF 1-7: Require the
payment of impact fees for
all new development.
 The project proposes to build
272 single-family homes
 The project includes 25 acres
of permanent open space,

8.49 gross acres of
neighborhood parkland, and is
conditioned to provide
approximately 2,500 linear
feet of improved trail to
augment Sand Creek Trail
and Black Gold Trail
 The project is conditioned to
pay all relevant impact fees,
including those pertaining to
water, wastewater, roadways,
parks and trails. It is also
required to annex into both
the City CFD and the CFD
Yes
Yes
Yes
Yes

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General Plan Provision Project Implementation Consistent? established for fire and
emergency medical services
ZONING
As noted above, the project’s residential component is subject to the development standards set forth in Subarea C of Planned Development No. 36 (BMC Section

17.486.004). The project meets these requirements as demonstrated below.

Table 6: Consistency with PD, Subarea C Standards
Requirement Proposed Consistent?
Minimum lot
size
5,000 sq. ft. 5,000-15,863 sq. ft. Yes
Minimum lot
width
50’ 50’ – 160’ Yes
Minimum lot
frontage
35’ at the front
property line for lots on
culs-de-sac, knuckles,
or curvilinear street
35’ minimum Yes
Minimum front
yard setback
20’ for front-facing
garages; fifteen feet
for building walls and
porches
Minimum 20’ for frontfacing garages and
minimum 15’ for
building walls and
porches
Yes
Minimum side
yard setback
5’, with the sum of
both sides 12’; corner
lots shall maintain a
minimum setback of
10’ on the street side
yard
Minimum 5’ on one
side and 7’ on other
side with 10’ on street
side for corner lot
Yes
Minimum rear
yard setback
15’, with an average of
20’
15’ minimum with
average of 20’
Yes
Maximum
building height
2 stories, not to
exceed 30’
As conditioned, the
project will include
homes of no more than
2 stories, ranging in
height from 22’11”-30’
Yes, with
conditions

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Requirement Proposed Consistent?
Corner lot fence
setback
5’ from the street side
property line; all other
fence regulations must
meet BMC Chapter

17.660
Dimension not shown,
but conditioned to
meet standard
Yes, with
conditions
Lots adjacent to
open space
Shall utilize a 6’ open
space fence along the
common property
line(s), as approved
through VTSM 8506
Not shown Yes, with
conditions
Accessory
structures
Prohibited in side or
rear yards for areas
exceeding a 3:1 slope
No accessory
structures are
proposed at this time
Yes
Maximum lot
coverage
40% for two-story
homes and 45% for
single-story homes
10-45% (all lots over
40% are single-story)
Yes
According to BMC Section 17.486.006, which governs the uses and development standards applicable to the project, open space (as a reserve for fire protection, etc.) and parks, playgrounds, and recreational trails, are permitted uses in the “open space” area. The applicant proposes to leave this area undeveloped, except for the trail improvements discussed above. As such, this is consistent with the regulations for this open space area.

AFFORDABLE HOUSING
Under SB 330, the project must comply with the affordable housing ordinance in place at the time of application submission. Ordinance No. 1014 was in place at the time of project application and requires 10% of the total units within a project to be affordable to various income categories. The applicant originally proposed less than the required number of affordable units, but has since agreed to comply with Ordinance No. 1014. A condition of approval is included to require the Applicant to enter into an Affordable Housing Agreement with the City to provide a minimum of 27 affordable units at the required affordability levels. Compliance with this condition, per the City’s Affordable Housing Ordinance, is required prior to final map approval and will ensure, among other things, that the affordable units are spaced appropriately throughout the subdivision. The affordability levels for the 27 units are broken down as follows:

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Table 7: Affordable Housing Fulfillment
Affordability Level Requirement Complies?
Very Low Income 3% of 272 = 8 units Yes, as conditioned Low Income 4% of 272 = 11 units Yes, as conditioned
Moderate Income 3% of 272 = 8 units Yes, as conditioned

DESIGN REVIEW
The applicant seeks design review approval for the single-family development on the site. This design review is subject to the approval criteria set out in BMC Section

17.820.007 and the PD-36 standards for Subarea C found in BMC Section

17.486.004. The project’s conformance to those criteria is analyzed in the attached resolution for the design review, with various design elements also evaluated further below.

Architecture
The proposed design review includes 13 distinct floor plans with four alternative elevations per plan, except for Floor Plan 13, which has two elevations. The project includes only two units to be built according to Floor Plan 13, which shows it as a three-story unit. Three of the plans, Plans 1, 2, and 3, are single-story homes, with the remaining plans all two-story homes with a two-car front-on garage. Due to the relatively small minimum lot size (5,000 sf), alternative garage configurations are difficult to accomplish; however, the homes are designed to minimize the garage by setting it back from the front plane of the living spaces, thereby minimizing its prominence in the front elevation, and all of the plans show decorative garage doors to match the architectural style of the home.

As mentioned, each plan has four distinct architectural styles, including Tuscan, Craftsman, French Cottage, and Bay Area Modern. Exterior materials, massing, roof shapes and pitches, trim shapes and materials, and colors vary by these elevation styles. The rear elevations vary by elevation style as well, with accent gable and hip roofs, accent trim, and a variety of roof pitches and massing styles. The trim around the windows is shown as being carried around all windows at the sides and streetfacing rears to match the style of the window trim on the front elevation. This means that the window trim at the side and rear elevations is different by elevation style, but only if it can be viewed from an adjacent street.

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 Tuscan. The Tuscan style elevations combine stucco and stone exteriors with decorative wrought iron trim elements. The rooflines feature both modified hip and gable ends and are finished with curved villa concrete tile roofing.  French Cottage. The French Cottage style elevations include stucco body and trim elements with mock shutters. Stone veneer trim elements are included along the front elevations. Also included are simulated wood siding and trim elements at various locations along the front elevation. The gable roofs are finished with flat concrete tile roofing.
 Craftsman. The Craftsman elevations combine horizontal siding and stucco.

In addition, there are stone trim elements either at the front or on the column bases on the porch posts. Front elevations feature a full grid pattern for the window fenestration, unique to this style. The gable roofs are accented with corbels and have flat concrete tile roofing.
 Bay Area Modern. The Bay Area Modern elevations have stucco finishes with horizontal/vertical siding, stone, and brick trim elements. Windows are both horizontal and vertical to create a varied fenestration style. This elevation includes shed, flat, and pitched roof elements.

Exterior materials, massing, roof shapes and pitches, trim shapes and material, and colors vary by these elevation styles. The rear elevations vary by elevation style as well, with accent gable and hip roofs, accent trim, and a variety of roof pitches and massing styles. The plans include both villa style and flat tile roof elements. To be consistent with the high-quality of materials expected in Brentwood, all proposed roofing materials are concrete tile. In accordance with draft condition of approval #9 of the design review resolution, the accent trim around the windows and the varied window grid patterns would be carried around to windows at the sides and rears on all the homes, not just those that abut streets. The color schemes assist in further differentiating the styles. The developer has proposed a total of 24 different color schemes to be used throughout the project.

Building Design and Massing
A summary of the proposed home models is included below:

Table 8: Single-Family Home Models
Plan
#
Home
Size (sf)
Bed/
Bath
Garage
Spaces
Stories Max.

Height Complies?
1 1,808 3/2 2 1 22’ 11” Yes
2 1,848 3/2 2 1 23’ 0” Yes
3 1,943 4/3 2 1 23’ 2” Yes

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Plan
#
Home
Size (sf)
Bed/
Bath
Garage
Spaces
Stories Max.

Height Complies?
4 2,223 4/3 2 2 25’ 11” Yes
5 2,292 4/3 2 2 28’ 1” Yes
6 2,439 5/3 2 2 27’ 0” Yes
7 2,644 4/3 2 2 29’ 3” Yes
8 2,772 4/3 2 2 27’ 9” Yes
9 2,787 5/4 2 2 27’ 3” Yes
10 2,788 5/4 2 2 30’ 6” No
11 2,831 5/4 2 2 30’ 2” No
12 3,100 5/3 2 2 29’ 4” Yes
13 3,222 4/3 3 3 32’ 1” No
BMC § 17.486.004 outlines the standards for Subarea C of PD-36 and limits the homes to two stories and 30 feet. Therefore, Plans 10, 11, and 13 would need to be modified to meet these standards and a draft condition of approval to that effect is included.

Preliminary/Master Plotting Plan
The master plotting plan depicts which home plans would be constructed on each particular lot. Each plan would be plotted between 7.4 percent and 9.1 percent of the time within the subdivision, with the exception of Plan 13, which only includes 2 units total (0.7 percent). The streetscape varies the plans fairly evenly throughout the subdivision. See discussion below under the Residential Design Guidelines section regarding compliance with the guidelines and proposed conditions of approval.

Parks, Landscaping, and Walls
Parks
The proposed subdivision includes two designated park parcels. Parcel A, located northwest of the main access at Sand Creek Road (as shown in the General Plan), is six acres and will be designed as a neighborhood park. The smaller park is Parcel G, which encompasses 2.49 acres and will also be designed as a neighborhood park.

The landscape plans submitted with this application for a VTSM are preliminary only and pursuant to BMC § 2.46.020G, a conceptual park plan is conditioned to be submitted to the Park and Recreation Commission for review and final approval of the park design, programming, and amenities. The Park and Recreation Commission’s approval will ensure conformance with all aspects of the Parks, Trails and Recreation Master Plan for Neighborhood Parks. As with all new projects, the final landscape

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plans will be reviewed against the City’s Water Efficient Landscape Ordinance to ensure conformance with these regulations.

Staff has calculated the required park acreage based on an expected population within the subdivision of 870 (272 units x 3.2 persons per unit). Using the City’s formula of providing 5 acres of park for every 1,000 residents, a total of 4.35 acres of park is required. Parcel A is identified as a park consisting of six acres. Of this six acres, 1.94 acres will be graded to less than 3% slope, which is considered usable park land. Parcel G is identified as a park consisting of 2.49 acres, of which 2.41 acres will be graded to less than 3% slope, and thus considered usable park land.

The two parks combined result in 4.35 acres, consistent with the required acreage.

Building these two parks offers the Park and Recreation Commission an opportunity to be creative with adding amenities, including those that have been previously identified in the Master Plan Update, such as sport courts, exercise stations, play structures, and trail connections to Sand Creek Road and Black Gold Park. These are recreation activities that the new residents would not have access to if the developer is not required to install these two parks.

Landscaping
The preliminary landscape plan includes conceptual plantings for the Sand Creek Road frontage, the two park parcels, street trees, and typical front yards. It also includes a conceptual design for the masonry wall. Final plans will be reviewed by staff prior to building permit issuance to ensure compliance with all City standards, including water efficiency.

Walls
The project includes a conceptual wall design for the required sound wall locations identified in the acoustical analysis done for the project (see Figure 1). These locations are adjacent to Sand Creek Road and SR 4. The wall design will be masonry block units with a wall cap and appropriately spaced columns with caps (see Figure 2). All other fencing for the project would need to adhere to the City’s standard for good-neighbor fencing between lots, and enhanced good neighbor fencing between lots and City-owned open space where trails or trail connections are adjacent. Open tube steel or wire fencing will be installed by the developer between City open space parcels and lots elsewhere.

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Figure 7: Sound Wall Locations
Figure 8: Conceptual Sound Wall Elevation
A draft condition of approval is included that requires dedication of Parcel I to the City for open space and trail purposes, as well as construction of a 10-foot wide

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asphalt multi-use trail from the southern boundary of the project at the existing terminus of Black Gold Trail to the extension of Sand Creek Road or a portion of the Sand Creek Trail. This is consistent with the Parks, Trails and Recreation Master Plan and will provide trail connections called for in that Plan.

Design Guidelines
The City adopted a set of Residential Design Guidelines in 20064. These address all aspects of residential design, including project layout and composition, as well as architectural design and features for a wide range of residential unit types. It is important to note that the intent of the design guidelines is not to ensure that every detail is included, but rather provide guidance to the developer regarding the types of features that should be considered when developing the project. In other words, the guidelines are generally suggestions of good design, not rules that need to be followed for every development. Further, it should be noted that, pursuant to State law, the City cannot apply non-objective design guidelines in a manner that would lessen the intensity of housing, such as by reducing density, size of units, or setbacks.

Table 9: Residential Design Guidelines Consistency
Residential Design
Guideline Provision Project Design Consistent?
Single-family residential units
must include one distinct plan
with four unique elevations for
every 25 units in the project
This 272-unit single-family
project has proposed a total of
13 models, with four elevation
styles
Yes
50% of corner lots within a
development must be single-story
units
Of the 26 lots that could be
considered corner lots, 13 of
these have been plotted with
single-story plans
Yes
Garage doors with decorative
features including glass windows
shall be provided for 60% or more
of the units
The proposed garages include
decorative doors with windows
Yes

4 The Objective Design Standards adopted by urgency ordinance on June 27, 2023, and extended on August 8, 2023, do not apply to this project, as the applicant submitted a preliminary application that vested the standards applicable in 2021, as discussed above.

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Residential Design
Guideline Provision Project Design Consistent?
Front-facing garages should be
set back from the front façade of
the living space
The majority of plans include
front-facing garages that are
set back a minimum of 3 feet
from the front plane of the
house
Yes
Materials and detailing shall be
consistently used on all sides of
the structure
The plans include materials and
detailing consistently on all
sides as conditioned
Yes
Provide variation in roof heights The plans include a variety of roof heights and styles, ranging
from approximately 22’ to 30’
Yes
Maintain architectural style
integrity
The architectural style of each
elevation type remains
consistent with the traditional
examples on which the style is
based and the elements evident
on the front façade are
proposed to be carried around
to the less-prominent side and
rear elevations
Yes
OTHER ISSUES DISCUSSED AT SEPTEMBER 5, 2023 PLANNING COMMISSION Noise
As noted in the September 5, 2023 Planning Commission staff report, a noise study was prepared for the project by the applicant. The City hired an independent thirdparty noise consultant to peer review the noise study. Both noise experts concluded that a combination of sound wall and STC ratings of 34 for second floor windows are adequate to reduce noise levels in compliance with the General Plan standards. This issue was raised at the Planning Commission meeting. Staff will verify compliance for specialized materials during the review of construction documents, as a matter of standard practice.

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Park Size and Locations
The proposed 6-acre park (Parcel A) in the northwest corner of the subdivision is consistent with the location identified in the General Plan. The parcel will include a

1.94-acre portion of the park that will be graded to a less than 3% slope. An additional 2.49-acre park (Parcel G) is proposed to be located in the center of the project and will be graded such that 2.41 acres have less than a 3% slope. Previous concerns had been raised about having this park on the edge of the site and it has been located in the center to better serve the community. Park credit will only be given to those portions of the park that are less than 3% slope, which totals 4.35 acres between the two parcels. The park design elements, as is typical for all subdivisions, will be determined later by City staff and the Park and Recreation Commission.

Trail Connection to La Sata Court
The applicant agreed to eliminate the pedestrian connection (Parcel H) to La Sata Court. VTSM Condition #13b requires a multi-use trail on Parcel I from the existing terminus of Black Gold Trail to the extension of Sand Creek Road adjacent to the park Parcel A.

Architecture
The applicant agreed to the Design Review condition #10 requiring architectural elements to be provided on all sides and rears of the homes and will update the building plans accordingly.

DATE OF NOTICE
The City published a notice of public hearing in the Brentwood Press and mailed it to property owners within 300 feet of the site on July 5, 2024. In addition, the project site is posted with the required signage along Sand Creek Road as well as San Jose Avenue/St. Regis Avenue.

ENVIRONMENTAL DETERMINATION
The Bridle Gate Project has been previously proposed and evaluated in past EIRs. A new project-level Revised EIR (REIR) has been prepared for the currently proposed project. In order to differentiate the current analysis from previous EIRs, although an REIR is not a technical CEQA term, the current analysis has been labeled as such in order to further denote that the Bridle Gate Project has been revised and is now subject to new analysis. The REIR (SCH# 2022120683) for this project was prepared in accordance with the requirements of CEQA. Several potentially significant impacts are identified; however, mitigation measures are incorporated to reduce those impacts to less-than-significant levels. All mitigation measures not addressed by the

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standard conditions of approval are included as recommended conditions of approval.

The Draft REIR was available for review and comment from May 26, 2023 to July 10, 2023. Several comments were received and addressed in the Final REIR. The Draft REIR and Final REIR may be reviewed by clicking on the link below and scrolling to “Bridle Gate:”
https://www.brentwoodca.gov/government/communitydevelopment/planning/ceqa-documents In addition, the City’s CEQA consultant, Raney Planning & Management, Inc., prepared a memorandum (Attachment 11), to analyze whether any of the proposed traffic calming options, which are described in detail below, would alter the conclusions of the REIR (“CEQA Traffic Options Memo”). The CEQA Traffic Options Memo concluded that none of the options alter the conclusions of the REIR.

ATTACHMENT(S)

1. Previous Actions

2. City Council Ordinance No. 1014

3. Resolution No. 23-032 certifying the Revised EIR

4. Final Revised EIR (see link embedded above)

5. Draft Revised EIR (see link embedded above)

6. Resolution No. 23-033 approving Vesting Tentative Subdivision Map No. 9586

7. VTSM 9586 & Preliminary Grading/Utility Plan

8. Resolution No. 23-034 approving Design Review No. 21-010

9. Bridle Gate design review booklet

10. Preliminary landscape plans

11. Raney Memorandum on Traffic Calming Options, dated July 9, 2024

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Elevation A - Tuscan Elevation B - French Cottage

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TYPICAL LOT SIZES
45' x 100' = 4,500 SQ. FT. 2,236 SQ. FT. 49%

LOT COVERAGE

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1-STORY: 50% max
PLAN 1
SitePlan

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BRENTWOOD, CA

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APPROX.

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1.3

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Elevation A

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Roof Plan 'A'
Right
Rear
Left
Front - Tuscan

1.4

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Elevation B

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Left
Front - French Cottage

1.5

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Left
Front - Craftsman

1.6

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Elevation D

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Front - Bay Area Modern

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Elevation C - Craftsman

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Elevation A - Tuscan Elevation B - French Cottage

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45' x 100' = 4,500 SQ. FT. 2,277 SQ. FT. 50%

LOT COVERAGE

FOOTPRINT COVERAGE
1-STORY: 50% max
PLAN 2
Site Plan

STONEBROOK

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APPROX.

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2.4

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TYPICAL LOT SIZES
50' x 100' = 5,000 SQ. FT. 2,392 SQ. FT. 48%

LOT COVERAGE

FOOTPRINT COVERAGE
1-STORY: 50% max
PLAN 3
Site Plan

STONEBROOK

3.2 City of Brentwood
APPROX.

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45' x 100' = 4,500 SQ. FT. 1,810 SQ. FT. 40%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
PLAN 4
Site Plan

STONEBROOK

4.2 City of Brentwood
APPROX.

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PLAN 4
Elevation D

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4.8

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PLAN 5
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City of Brentwood

TYPICAL LOT SIZES
45' x 100' = 4,500 SQ. FT. 1,592 SQ. FT. 35%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
PLAN 5
Site Plan

STONEBROOK

5.2 APPROX.

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LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
PLAN 6
Site Plan

STONEBROOK

6.2 City of Brentwood
APPROX.

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PLAN 6
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PLAN 6
Elevation D

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Elevation C - Craftsman 7.1
PLAN 7
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TYPICAL LOT SIZES
45' x 100' = 4,500 SQ. FT. 1,826 SQ. FT. 40%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
City of Brentwood

7.2 PLAN 7
SitePlan

STONEBROOK
APPROX.

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7.3 PLAN 7
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Elevation A

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Right
Rear
Left
Front - French Cottage

7.6 PLAN 7
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Right
Rear
Left
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Right
Rear
Left
Front - Bay Area Modern

7.8 PLAN 7
Elevation D

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45' x 100' = 4,500 SQ. FT. 1,829 SQ. FT. 40%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
PLAN 8
Site Plan

STONEBROOK

8.2 City of Brentwood
APPROX.

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Front - French Cottage

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Front - Craftsman

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Elevation D

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Rear
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Front - Bay Area Modern

8.8

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PLAN 9
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TYPICAL LOT SIZES
45' x 103'-9" = 4,668 SQ. FT. 1,858 SQ. FT. 40%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
PLAN 9
Site Plan

STONEBROOK

9.2 City of Brentwood
APPROX.

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PLAN 9
First Floor

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PLAN 9
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PLAN 9
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Left
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9.5

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9.6

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PLAN 9
Elevation C

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Rear
Left
Front - Craftsman

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PLAN 9
Elevation D

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Right
Rear
Left
Front - Bay Area Modern

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PLAN 10
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STONEBROOK
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TYPICAL LOT SIZES
45' x 100' = 4,500 SQ. FT. 1,828 SQ. FT. 40%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
PLAN 10
Site Plan

STONEBROOK

10.2 City of Brentwood
APPROX.

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PLAN 10
First Floor

STONEBROOK

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PLAN 10
Second Floor

STONEBROOK

10.4

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PLAN 10
Elevation A

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Right
Rear
Left
Front - Tuscan

10.5

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Left
Front - French Cottage

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GARAGE

BRENTWOOD, CA
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PLAN 10
Elevation C

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Roof Plan 'C'
Right
Rear
Left
Front - Craftsman

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GARAGE

BRENTWOOD, CA
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DESIGN GROUP

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PLAN 10
Elevation D

STONEBROOK
Roof Plan 'D'
Right
Rear
Left
Front - Bay Area Modern

10.8

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Elevation C - Craftsman 11.1
PLAN 11
Front Elevations

STONEBROOK
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TYPICAL LOT SIZES
45' x 100' = 4,500 SQ. FT. 1,822 SQ. FT. 40%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
City of Brentwood

11.2 PLAN 11
Site Plan

STONEBROOK
APPROX.

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First Floor

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Second Floor

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Roof Plan 'A'
Right
Rear
Left
Front - Tuscan

11.5 PLAN 11
Elevation A

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Right
Rear
Left
Front - French Cottage

11.6 PLAN 11
Elevation B

STONEBROOK

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Right
Rear
Left
Front - Craftsman

11.7 PLAN 11
Elevation C

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Roof Plan 'D'
Right Front - Bay Area Modern
Rear
Left

11.8 PLAN 11
Elevation D

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Elevation C - Craftsman 12.1
PLAN 12
Front Elevations

STONEBROOK
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TYPICAL LOT SIZES
45' x 100' = 4,500 SQ. FT. 1,833 SQ. FT. 40%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
PLAN 12
Site Plan

STONEBROOK
City of Brentwood

12.2 APPROX.

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Elevation A

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Front - Tuscan

12.5

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Front - French Cottage

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12.7

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Elevation D

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Right
Rear
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Front - Bay Area Modern

12.8

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13.1 PLAN 13
Front Elevations

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Elevation A - Tuscan

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TYPICAL LOT SIZES
114'-5" x 117'-3" = 13,414 SQ. FT. 2,073 SQ. FT. 15%

LOT COVERAGE

FOOTPRINT COVERAGE
2-STORY: 40% max
City of Brentwood

13.2 PLAN 13
Site Plan

STONEBROOK
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Entry Level

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Main Level

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13.5 PLAN 13
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Right
Rear
Left
Front - Tuscan

13.6 PLAN 13
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Right
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Front - Craftsman

13.7 PLAN 13
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1 July 9, 2024
Erik Nolthenius,
Planning Manager
City of Brentwood Community Development Department
150 City Park Way
Brentwood, CA 94513
Re: Traffic-Calming Options at the proposed St. Regis Avenue/Chestnut Oak Drive/San Jose Avenue intersection for the Bridle Gate Project
Dear Mr. Nolthenius,
Raney Planning and Management, Inc. has prepared this Memorandum to address if alterations to the design of the proposed St. Regis Avenue/Chestnut Oak Drive/San Jose Avenue intersection that would be constructed as part of the Bridle Gate Project (proposed project) would alter the conclusions of the Bridle Gate Project Draft Revised Environmental Impact Report (REIR), such that recirculation of the Draft REIR would be necessary. As discussed herein, the City of Brentwood’s approval of any of the five traffic-calming options at the proposed St. Regis Avenue/Chestnut Oak Drive/San Jose Avenue intersection would not result in a new significant impact or an increase in the severity of an impact previously identified in the Draft REIR. Therefore, each of the five traffic-calming options would be consistent with the analyses and conclusions presented in the Final REIR and do not necessitate recirculation of the Draft REIR, as none trigger the criteria for recirculation established by CEQA Guidelines Section 15088.5(a).

Project Background
The Draft REIR prepared for the proposed project evaluated all potential environmental effects required for analysis under the California Environmental Quality Act (CEQA), including those associated with the project’s westerly extension of San Jose Avenue and construction of the new north-south Chestnut Oak Drive. The two new roadways would serve as the northern and western legs of the new four-way St. Regis Avenue/Chestnut Oak Drive/San Jose Avenue intersection, which would allow for vehicle access from the proposed residences to the existing Brentwood Hills neighborhood adjacent to the south of the project site.

As discussed in Chapter 1, Introduction, Description of Project Changes, and List of Commenters, of the Final REIR, following the release of the Draft REIR for public review, the proposed project was further refined as part of the Final REIR to comply with applicable development standards for Planned Development-36 (PD-36), Subarea C, set forth in Brentwood Municipal Code Section

17.486.004. The project refinements reduced the number of proposed residential lots from 286 to 272. In addition, Millbrook Court, which was previously proposed for east of Park Parcel G, was reconfigured such that the cul-de-sac would now be extended and renamed Millbrook Drive, connecting to Rosewood Drive to the north and east.

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2 Due to the Millbrook Drive reconfiguration, Park Parcel G was reduced from 3.39 acres to 2.49 acres.

The lots surrounding Park Parcel G were also moved to be located north of Millbrook Drive and south of the park. The public review period for the Final REIR occurred from August 25 to September 5, 2023. Since the release of the Final REIR, changes to the project components have not occurred.

As detailed in the Draft REIR and Final REIR, all potential impacts associated with the proposed project, including those related to vehicle miles traveled (VMT), would either be less than significant or would be reduced to a less-than-significant level through implementation of the mitigation measures set forth therein.

On September 5, 2023, the Planning Commission held a public hearing on the potential certification of the Final REIR and heard testimony from the project applicant, as well as 11 members of the public. After noting several concerns about the proposed project – most notably, the potential effect of project-generated through traffic entering the Brentwood Hills neighborhood through the proposed St. Regis Avenue/Chestnut Oak Drive/San Jose Avenue intersection – the Planning Commission adopted a motion to continue the item to an unspecified future hearing. As part of the motion, the Planning Commission directed staff to work with the applicant to evaluate the intersection of St. Regis Avenue/San Jose Avenue for a possible gate or restriction to only an emergency vehicle access, with the understanding that staff would evaluate any other viable solution that would lessen the impact of traffic on the existing residential areas to the south (i.e., Brentwood Hills and Shadow Lakes).

In response, Abrams Associates prepared an assessment of five traffic-calming options that could be implemented at the proposed St. Regis Avenue/Chestnut Oak Drive/San Jose Avenue intersection, which is attached as Attachment A to this Memorandum. 1 DKS Associates prepared
an assessment of the impact of the options on VMT (see Attachment B of this Memorandum), 2 which has been independently peer reviewed by Kimley-Horn on behalf of the City (see Attachment C of this Memorandum).
3 The traffic-calming options include the following:
• Option 1: Turn Restrictions Alternative A;
• Option 2: Turn Restrictions Alternative B;
• Option 3: One Way Street;
• Option 4: Full or Partial Street Closure; and
• Option 5: Additional Access to Sand Creek Road.

Pursuant to CEQA Guidelines Section 15088.5(a), a lead agency is required to recirculate a Draft EIR if significant new information is added after the Draft EIR is circulated but before certification.

Significant new information is defined as information that changes a Draft EIR “…in a way that deprives the public of a meaningful opportunity to comment on…” a significant impact, a feasible way to mitigate an impact, or a feasible way to avoid an impact. The following identifies circumstances that would be considered “significant new information” that would trigger recirculation:
1 Abrams Associates. Review of Potential Options for Minimizing Additional Traffic on St. Regis Avenue. October 12, 2023. 2 DKS Associates. Assessment of Traffic Calming Options. October 16, 2023. 3 Kimley-Horn. Final Vehicle Miles Traveled (VMT) Assessment of Traffic Calming Options Peer Review, Bridle Gate Residential Development, City of Brentwood. June 19, 2024.

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3 • Information that shows a new significant impact;
• Information that shows an increase in the severity of an impact (unless mitigation measures are identified to reduce it to acceptable levels);
• Information that identifies a feasible new alternative or mitigation measure considerably different from other analyzed alternatives or mitigation measures that would clearly lessen project impacts and the applicant declines to implement the measure; and/or • Information that demonstrates that the Draft EIR was fundamentally flawed, basically inadequate, and conclusory in nature, thus, precluding meaningful public review and comment.

Pursuant to CEQA Guidelines Section 15088.5(b), recirculation is not required if the information added to an EIR merely clarifies, amplifies, or makes insignificant modifications. The aforementioned five traffic-calming options are discussed further below with respect to how each option could affect the Draft REIR’s VMT conclusion under Impact 4.5-3 (Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision [b]), to determine if the traffic-calming options would constitute significant new information should any one of them be selected for implementation. The analysis below is based on the conclusions of the DKS Associates assessment and peer review conducted by Kimley-Horn. The discussions are then followed by an evaluation of how any changes in VMT as a result of the foregoing traffic-calming options could affect other environmental issue areas required for analysis under CEQA, which would primarily include air quality, greenhouse gas (GHG) emissions, and noise.

Option 1: Turn Restrictions Alternative A
Under this option, eastbound traffic along the new leg of San Jose Avenue within the project site would be prohibited from making right turns onto St. Regis Avenue. Southbound through traffic from Chestnut Oak Drive would similarly be prohibited from continuing onto St. Regis Avenue. Because the San Jose Avenue-St. Regis Avenue connection was not included in the traffic network model employed as part of the VMT Assessment prepared for the Draft REIR (see Appendix J of the Draft REIR), approval of Option 1 would not alter the conclusion of Impact 4.5-3, which was found to be less than significant with implementation of Mitigation Measure 4.5-3. Mitigation Measure 4.5-3 requires that the project include an additional full intersection along the internal project roadway network to achieve a project-wide intersection density of 61.5, which would be sufficient to reduce project VMT to below the applicable threshold of 25.2 VMT per resident. Because the San Jose Avenue-St. Regis Avenue connection was not included in the traffic network model, DKS Associates concluded that Option 1 is consistent with the Impact 4.5-3 analysis, which was affirmed by KimleyHorn. Thus, approval of Option 1 would be consistent with the conclusion of Impact 4.5-3 of the Draft REIR.

Option 2: Turn Restrictions Alternative B
Option 2 would include the same restrictions as Option 1, but would also prohibit southbound left turns from Chestnut Oak Drive onto the existing segment of eastbound San Jose Avenue. While the traffic network model used in the VMT Assessment prepared for the Draft REIR included the Chestnut Oak Drive-San Jose Avenue connection, DKS Associates determined that Option 2 would not increase VMT beyond that which was identified in the Draft REIR, as alternatively accessing locations east of State Route (SR) 4 by way of San Creek Road (as necessitated by this option) would not be significantly longer for motorists. Kimely-Horn affirmed the foregoing conclusion. Thus,

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4 approval of Option 2 would be consistent with the analysis and conclusion of Impact 4.5-3 of the Draft REIR.

Option 3: One Way Street
Option 3 would restrict the new leg of San Jose Avenue west of St. Regis Drive to one-way westbound traffic only. This option would also include prohibiting southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue. Similar to Option 2, the traffic network model used in the VMT Assessment prepared for the Draft REIR included the Chestnut Oak Drive-San Jose Avenue connection. However, DKS Associates concluded that Option 3 would not increase VMT beyond that which was identified in the Draft REIR, as alternatively accessing locations east of SR 4 by way of Sand Creek Road would not be significantly longer, as discussed above with respect to Option 2. In addition, Option 3 would allow for vehicle trips returning to the proposed project through westbound San Jose Avenue. Thus, Option 3 would be consistent with the analysis and conclusion of Impact

4.5-3 of the Draft REIR.

Option 4: Full or Partial Street Closure
Option 4 would require either a partial (southbound) or full closure of Chestnut Oak Drive at San Jose Avenue. In the traffic network model used in the VMT Assessment prepared for the Draft REIR, Chestnut Oak Drive is represented as a centroid connected to the San Jose Avenue extension.

However, similar to Options 2 and 3, DKS Associates concluded that alternatively requiring motorists to access locations east of SR 4 by way of Sand Creek Road would not significantly lengthen trips, and Option 4 would not substantially increase VMT beyond that which was identified in the Draft REIR. Thus, Option 4 would be consistent with the analysis and conclusion of Impact 4.5-3 of the Draft REIR.

Option 5: Additional Access to Sand Creek Road
Option 5 would include an additional right-in/right-out access point to Sand Creek Road between Bridle Gate Drive and the eastbound SR 4 ramps; however, it should be noted that Abrams Associates concluded that Option 5 would be unlikely to gain City approval, as another full-access intersection would be unlikely to meet the California Department of Transportation’s (Caltrans) intersection spacing standards for a divided arterial roadway such as Sand Creek Road. In addition, the road’s topography would discourage the City from approving new connections to Sand Creek Road west of San Jose Avenue, as the grade between the proposed roadway network and the final alignment of Sand Creek Road would be substantial.

Option 5 would slightly reduce a portion of the vehicle trips accessing eastbound SR 4 and eastbound Sand Creek Road, resulting in a slight (albeit minimal) decrease in VMT. Thus, approval of Option 5 would be consistent with the analysis and conclusion of Impact 4.5-3 of the Draft REIR.

Air Quality, Greenhouse Gas Emissions, and Noise
Potential increases in VMT would result in an associated potential increase in air quality pollutants, GHG emissions, and noise level increases. With respect to air quality and GHG emissions, as discussed above, Options 2 through 5 would not substantially increase VMT beyond that which was identified in the Draft REIR, as Options 2, 3, and 4 would require motorists to access locations east of SR 4 by way of Sand Creek Road, which would not significantly lengthen trips, and Option 5 would slightly reduce a portion of the vehicle trips accessing eastbound SR 4 and eastbound Sand Creek

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5 Road. In addition, Option 1 would not increase VMT. Thus, none of the traffic-calming options would result in substantial increases to project-generated criteria pollutants during project operation, which were concluded under Impact 4.1-2 of the Draft REIR to be less than significant. In addition, the Draft REIR determined that with implementation of Mitigation Measure 4.5-3 (pursuant to Mitigation Measure 4.1-6[a]) and prohibition of natural gas within the proposed structures as required by Mitigation Measure 4.1-6(b), the potential impact related to GHG emissions would be reduced to a less-than-significant level. Therefore, approval of any of the traffic-calming options would similarly result in a less-than-significant impact with implementation of Mitigation Measures 4.1-6(a) and 4.1- 6(b). Based on the above, approval of the traffic-calming options would be consistent with the analyses and conclusions related to air quality and GHG emissions in the Draft REIR.

With respect to noise, the Draft REIR determined under Impact 4.4-2 that noise-level increases at existing sensitive receptors in the project vicinity as a result of project-generated traffic would be, at most, 0.9 dB, with most noise-level increases projected to not exceed 0.4 dB. Thus, the Draft REIR concluded that with regard to noise-level increases related to traffic, the proposed project would not exceed the applicable threshold of 1.5 dB and a less-than-significant impact would occur. According to the California Department of Transportation (Caltrans), increasing traffic-generated noise levels by 3.0 dB requires a doubling of traffic levels.4 While approval of the traffic-calming options would redistribute the foregoing vehicle trips to other roads in the project vicinity, such an amount would not result in a doubling of the volumes anticipated in the Draft REIR. Thus, should any of the trafficcalming options be selected, none would result in an increase to existing roadway traffic volumes such that the proposed project would be anticipated to result in a new significant impact related to traffic noise beyond what was identified in the Draft REIR. Thus, approval of the traffic-calming options would be consistent with the analyses and conclusions related to noise in the Draft REIR.

Remaining Environmental Issue Areas
With respect to the remaining environmental issue areas addressed in the Draft REIR, approval of the traffic-calming options would not a new or substantially more severe significant impact beyond what was identified in the Draft REIR or Final REIR or information that identifies a feasible new alternative or mitigation measure that would clearly lessen project impacts or demonstrates that the Draft REIR and Final REIR are fundamentally flawed. For example, alterations to the routing of project-generated traffic as a result of the traffic-calming options would not necessitate the construction of roadways that were not previously proposed and analyzed in the Draft REIR or Final REIR, or any other alterations to the previously evaluated area of disturbance. Thus, the trafficcalming options would not result in new or substantially more severe significant impacts related to agriculture and forestry resources, biological resources, cultural and tribal cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, or mineral resources. The traffic-calming options would not result in new residential units and associated population increases beyond what was evaluated in the Draft REIR and Final REIR. Therefore, new or substantially more severe significant impacts would not occur related to energy consumption, land use and planning, population and housing, public services, recreation, utilities and service systems, or wildfire. Finally, as the alterations to the routing of project-generated traffic as a result of the traffic-calming options would only add a slight increase of project-generated traffic to previously proposed and/or existing roadways in the project vicinity, new or substantially more severe significant impacts would not occur 4 California Department of Transportation. Technical Noise Supplement [page 6-5]. September 2013.

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6 related to aesthetics. Thus, approval of the traffic-calming options would be consistent with the analyses and conclusions related to the Draft REIR’s remaining environmental issue areas.

Conclusion
As demonstrated above, the traffic-calming options are consistent with the analyses and conclusions of the Draft REIR and revisions to the Draft REIR and/or Final REIR are not required. Thus, the traffic-calming options do not constitute significant new information and recirculation of the Draft REIR is not warranted.

If you have any questions regarding the contents of this document, please do not hesitate to contact me at (916) 372-6100, or via email at [email protected].

Thank you,
Rod Stinson
Vice President/Air Quality Specialist
1501 Sports Drive, Suite A
Sacramento, CA 95834
Office: (916) 372-6100
www.raneymanagement.com
Attachments:

Attachment A Review of Potential Options for Minimizing Additional Traffic on St. Regis Avenue Attachment B Assessment of Traffic Calming Options
Attachment C Final Vehicle Miles Traveled (VMT) Assessment of Traffic Calming Options Peer Review

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7 Attachment A
Review of Potential Options for
Minimizing Additional Traffic on St.

Regis Avenue

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Abrams Associates
TRAFFIC ENGINEERING, INC.
1875 Olympic Boulevard, Suite 210 Walnut Creek, CA 94596 925.945.0201 Fax: 925.945.7966 October 12, 2023
Louis Parsons
Discovery Builders, Inc.
3240 Stone Valley Road
Alamo, CA 94507
Re: Review of Potential Options for Minimizing Additional Traffic on St. Regis Avenue This report presents the results of a review of potential options for minimizing additional traffic on St. Regis Avenue, given the additional roadway connections that would be constructed as part of the Bridle Gate Project. Figure 1 identifies the locations of the various options being reviewed and shows both the existing and planned roadways in the study area. This review includes the potential effects on trip distribution from the Bridle Gate project that could result if any of the potential options are implemented. The intersection of San Jose Avenue and St.

Regis Avenue has not yet been completed and, once fully constructed as part of the Bridle Gate Project, would become a four-way intersection with all-way stop control. Both San Jose Avenue and St. Regis Avenue would be extended through this intersection as part of the Bridle Gate Project. San Jose Avenue would be extended through the project from St. Regis Avenue, it would then transition into Bridle Gate Drive and connect to Sand Creek Road. St. Regis Avenue would extend through the intersection to the north into the Bridle Gate Project, but the roadway would change names to Chestnut Oak Drive north of San Jose Avenue.

Five options were evaluated for minimizing traffic on St. Regis Avenue, and all would be subject to City approval. The first two options consist of potential turn restrictions at the intersection of St. Regis Avenue and San Jose Avenue. The third option involves restricting a one-block section of the San Jose Avenue extension (just west of St. Regis Avenue) to one-way westbound traffic flow. The fourth option involves a full or partial closure at the south end of Chestnut Oak Drive. The fifth option is to potentially include an additional access point from the Bridle Gate Project to Sand Creek Road.

Option 1 - Turn Restrictions Alternative A – Turn restrictions at the intersection of St. Regis Avenue and San Jose Avenue were evaluated as one possibility to help minimize the amount of traffic from the Bridle Gate project that might travel to the south on St. Regis Avenue towards Balfour Road. The first turn restriction option being evaluated (Alternative A) in this report has two components:
1) The first component is a potential prohibition of eastbound right turns from the planned San Jose Avenue Extension onto St. Regis Avenue. A preliminary design for this is presented in Figure 2. This plan would include an extension of the curb on the southwest corner to not allow right turns and increase compliance with the prohibition on right turns from eastbound San Jose Avenue onto southbound St. Regis Avenue.

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Loma Vista
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Right-In / Right-Out
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Option 5
Potential One-Way
Street Segment on
San Jose Ave
Option 4
Options 1 & 2
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REVIEW OF OPTIONS FOR MINIMIZING TRAFFIC ON ST. REGIS AVENUE City of Brentwood
FIGURE 1 PROJECT LOCATION AND FUTURE ROADWAYS
Abrams Associates
TRAFFIC ENGINEERING, INC. Page 625 of 962
Source: APEX Civil Engineering and Surveying
Bridle Gate Project
REVIEW OF OPTIONS FOR MINIMIZING TRAFFIC ON ST. REGIS AVENUE City of Brentwood
FIGURE 2 OPTION 1 - TURN RESTRICTIONS ALTERNATIVE A
Abrams Associates
TRAFFIC ENGINEERING, INC. Page 626 of 962
Abrams Associates Page 4 of 12 – Bridle Gate Project Traffic Review TRAFFIC ENGINEERING, INC.

2) The second component of Option A is a potential prohibition to southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue. With the potential turn restrictions at the St. Regis Avenue/San Jose Avenue intersection traffic on southbound Chestnut Oak Drive would only be able to turn left or right onto San Jose Avenue and southbound through traffic onto St. Regis Avenue would be prohibited. In addition to signage, all-way stop control, and pavement markings, this plan would include a splitter island on the southbound Chestnut Oak Drive approach that would preclude through traffic onto St. Regis Avenue.

Option 2 - Turn Restrictions Alternative B – The second turn restriction option being evaluated (Alternative B) is essentially the same as the first option with the exception that southbound left-turns from Chestnut Oak Drive to eastbound San Jose Avenue would also be prohibited. A preliminary design for accomplishing this is presented in Figure 3. This plan would include the same extension of the curb on the southwest corner of the intersection to not allow right turns and increase compliance with the prohibition on right turns from eastbound San Jose Avenue onto southbound St. Regis Avenue. However, under this option on the northern side of the intersection all southbound traffic would be required to turn right onto San Jose Avenue. Left turns onto San Jose Avenue and southbound through traffic onto St. Regis Avenue would both be prohibited.

Under both of the turn restriction options the prohibited movements are proposed to be clearly signed and marked. However, it is assumed that some motorists would ignore these prohibitions and/or make a U-turns on San Jose Avenue so they could come back and make the permitted westbound left turn movement onto St. Regis Avenue.

Shifts in Traffic Patterns with the Turn Restriction Alternatives A and B (Options 1 and 2) – The most significant effect of the potential turn restrictions would likely be to discourage traffic from traveling through the Bridle Gate Project from Sand Creek Road and State Route 4. The previously considered Bridle Gate Project proposal from 2020-2022 included retail and school uses that were assumed to draw a significant amount of traffic from St. Regis Avenue and the neighborhoods to the south. The original project with the school site and apartments was included was forecast to generate almost 1,500 trips per hour in the April 2020 Traffic Impact Study prepared for the project.1 The revised project is forecast to generate less than 20% of the PM peak hour traffic that would have been generated by the previous proposal for the site.2 The TIA for the previous project also specified that a substantial portion of the elementary school traffic (20%) would originate from the neighborhoods to the south off of St. Regis Avenue, in addition to a portion of the shopping center traffic. 1 Bridle Gate Traffic Impact Study, Kimley Horn, Pleasanton, CA, April, 2020. 2 Technical Memorandum - Review of Changes to the Trip Generation and Potential Traffic Impacts Resulting from Revision of 2020 Bridle Gate Project (VTM 9586) to include only Single-Family Homes, Abrams Associates Traffic Engineering, Walnut Creek, CA, February 15, 2022.

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Source: APEX Civil Engineering and Surveying
Bridle Gate Project
REVIEW OF OPTIONS FOR MINIMIZING TRAFFIC ON ST. REGIS AVENUE City of Brentwood
FIGURE 3 OPTION 2 - TURN RESTRICTIONS ALTERNATIVE B
Abrams Associates
TRAFFIC ENGINEERING, INC. Page 628 of 962
Abrams Associates Page 6 of 12 – Bridle Gate Project Traffic Review TRAFFIC ENGINEERING, INC.

The current version of the Bridle Gate project includes only single-family homes (272 units) and the prior TIA assumed that about only 4% of the project’s residential traffic would be to and from the south on St. Regis Avenue. However, to be conservative, based on US census data on the average number of students per household it is assumed that up to 25% of the AM peak hour traffic generated by the Bridle Gate project could be school-related traffic bound for St. Regis Avenue and the existing schools to the south. Brentwood School District attendance boundaries indicate Bridle Gate Students would attend Adams Middle School and Heritage High School. However, the attendance boundaries indicate elementary students would theoretically be assigned to Loma Vista Elementary school (to the east on San Jose Avenue).

Based on the AM peak hour trip generation forecasts for the current residential project (200 trips per hour) the proposed Bridle Gate residential project could generate up to 40 trips per hour to and from St. Regis Avenue to the south. Figure 4 presents the forecast changes to the AM peak hour turning movements that would result from the various options that were studied in this report. An analysis of options for school traffic to get from the Bridle Gate Project to Adams Middle School and Heritage High School indicates that approximately 75% of this traffic would be expected to cut through the Sand Creek Crossings Shopping Center to come back to St.

Regis Avenue due to congestion and travel times on other alternate routes. In other words, although about 40 trips per hour may be restricted from turning straight out of the Bridle Gate Project with the turn restrictions, about 30 trips per hour would still make their way to St. Regis Avenue anyway (via Sand Creek Road and the shopping center). Therefore, the net decrease due to the potential turn restrictions is estimated to be more around 10 trips per hour once the school traffic going through the shopping center is accounted for. The potential turn restrictions would also affect the southbound through traffic that would otherwise pass through the Bridle Gate Project from Sand Creek Road and the State Route 4 freeway.

It is important to note that the potential turn restrictions would only affect southbound traffic from the Bridle Gate Project. Traffic from St. Regis Avenue or San Jose Avenue that wants to access (or pass through) the Bridle Gate Project to Sand Creek Road and the State Route 4 freeway would not be restricted and/or discouraged by the proposed turn restrictions. The restrictions as currently presented would only be expected to affect southbound traffic onto St.

Regis Avenue.

The more significant effect of the turn restrictions would be to discourage any external traffic from Sand Creek Road or State Route 4 from heading south through the Bridle Gate Project to St. Regis Avenue. It is our understanding that some of the traffic that might travel through the Bridle Gate Project to St. Regis Avenue currently travels through the Sand Creek Crossing (Raley’s) Shopping Center to get to San Jose Avenue. Some of this traffic also appears to use Highland Way and Meadowgate Way to reach St. Regis Avenue via San Jose Avenue. These routes have the potential to have increased safety issues with this additional traffic, when compared to having this traffic travel through the Bridle Gate Project on a newly constructed

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+ 30
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SAN JOSE AVE ST REGIS AVE
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TURN RESTRICTIONS

ALTERNATIVE A
OPTION 1

TURN RESTRICTIONS

ALTERNATIVE B
OPTION 2

ONE WAY STREET OR

PARTIAL STREET CLOSURE
OPTION 3

FORECAST CHANGES TO

AM PEAK HOUR TURNING MOVEMENTS
Bridle Gate Project
REVIEW OF OPTIONS FOR MINIMIZING TRAFFIC ON ST. REGIS AVENUE City of Brentwood
Abrams Associates
TRAFFIC ENGINEERING, INC.

FIGURE 4 FORECAST CHANGES TO THE AM PEAK HOUR TURNING MOVEMENTS

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Abrams Associates Page 8 of 12 – Bridle Gate Project Traffic Review TRAFFIC ENGINEERING, INC. section of San Jose Avenue/Bridle Gate Drive that is designed to safely accommodate through traffic with a wide cross-section and no homes fronting on it.

Both of the routes from the SR 4 freeway to St. Regis Avenue (on the east side of SR 4) have speed bumps to discourage speeding and external through traffic. The Highland Way/Meadowgate Way route passes right by the Loma Vista Park Playground and also Loma Vista Elementary School. However, most southbound traffic destined for St. Regis Avenue appears to travel through Sand Creek Crossings Shopping Center. Motorists destined for St.

Regis Avenue that pass through the Sand Creek Crossings Shopping Center must navigate seven pedestrian crosswalks along with a roundabout and multiple speed bumps when cutting through from Sand Creek Road down to San Jose Avenue.

Option 3 - One-Way Street – A one-way street option was evaluated as another way to potentially help minimize the amount of traffic that might travel south on St. Regis Avenue. A preliminary design for accomplishing this is presented in Figure 5. This option also includes two components:
1) The first component would be to restrict the first segment of the San Jose Avenue Extension to one-way westbound traffic only to the west of its intersection with St. Regis Avenue. The one-way section would extend from St. Regis Drive to the first intersection within the Bridle Gate Project (Rose Wood Drive). All eastbound traffic on San Jose Avenue would then have to turn left or right at Rose Wood Drive within the Bridle Gate Project. Since the segment to the east of Rose Wood Drive (to St. Regis Avenue) would become one-way westbound, it would be clearly signed as “Do Not Enter” and “Right or Left Turn Only” for eastbound traffic on San Jose Avenue within the Bridle Gate Project. 2) The second component is exactly the same as for the above-described turn restrictions option. In addition to restricting a one-block of San Jose Avenue to eastbound traffic only, this option would also include the same prohibition to southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue. Traffic on southbound Chestnut Oak Drive would only be able to turn left or right onto San Jose Avenue, through traffic would be prohibited. In addition to signage, all-way stop control, and pavement markings, this plan would include a splitter island (as shown in Figure 2) on the southbound Chestnut Oak Drive approach to help further discourage through traffic onto St. Regis Avenue.

Shifts in Traffic Patterns with the One-Way Street Option (Option 3) – As with the turn restrictions option, the most significant effect of the potential one-way street segment would likely be to discourage traffic from traveling through the Bridle Gate Project from Sand Creek Road and State Route 4. Figure 4 presents the forecast changes to the AM peak hour turning movements that would result from the one-way street option. Although about 40 trips per hour may be restricted from coming out of the Bridle Gate Project the one-way street, about 30 trips per hour would still be forecast make their way back to St. Regis Avenue anyway (via Sand

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Source: APEX Civil Engineering and Surveying
FIGURE 5
REVIEW OF OPTIONS FOR MINIMIZING TRAFFIC ON ST. REGIS AVENUEBridle Gate ProjectCity of Brentwood OPTION 3 - ONE WAY STREET Abrams Associates
TRAFFIC ENGINEERING, INC.

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Abrams Associates Page 10 of 12 – Bridle Gate Project Traffic Review TRAFFIC ENGINEERING, INC.

Creek Road and the shopping center). Therefore, the net decrease due to the potential turn restrictions is estimated to be more around 10 trips per hour once the school traffic going through the shopping center is accounted for.

Option 4 - Full or Partial Street Closure – A full or partial closure at the south end of Chestnut Oak Drive was another option that was evaluated to potentially help minimize the amount of traffic that might travel south on St. Regis Avenue.
1) A partial closure would involve closing only the southbound direction of Chestnut Oak Drive at San Jose Avenue. Under this option traffic would still be permitted to travel northbound onto Chestnut Oak Drive from the San Jose Avenue/St. Regis Avenue intersection. In the other direction southbound traffic would be prohibited using a design to block traffic that would be acceptable to the fire department. The roadway would be designed to effectively block any southbound traffic from entering the intersection from Chestnut Oak Drive. With the partial closure option, no southbound traffic would be able to travel through the Bridle Gate Project on Chestnut Oak Drive to San Jose Avenue, so it would be clearly signed as “Local Traffic Only” and “No Outlet”. 2) A full closure would involve closing both directions of Chestnut Oak Drive just north of San Jose Avenue. Under this option Chestnut Oak Drive would become a dead end just north of the San Jose Avenue/St. Regis Avenue intersection. This would include a connection to San Jose Avenue for emergency vehicles only, designed in a manner that would be acceptable to the fire department. The southern end of roadway would be designed to effectively block any Chestnut Oak Drive traffic from traveling to or from San Jose Avenue or St. Regis Avenue. The intersection of St. Regis Avenue with San Jose Avenue would become a three-way intersection, with no northern leg connecting to Chestnut Oak Drive. With this full closure option traffic would not be able to travel through the Bridle Gate Project on Chestnut Oak Drive to San Jose Avenue, so it would be clearly signed as “Local Traffic Only” and “No Outlet”.

Shifts in Traffic Patterns with the Full or Partial Street Closure Option (Option 4) – As with the other options, the most significant effect of a full or partial closure of Chestnut Oak Drive would likely be to discourage external traffic from traveling through the Bridle Gate Project from Sand Creek Road and State Route 4. Figure 4 presents the forecast changes to the AM peak hour turning movements that would result from the partial street closure, which is the same as would be forecast for the one-way street option. Again, although about 40 trips per hour may be restricted from coming out of the Bridle Gate Project the one-way street, about 30 trips per hour would still be forecast make their way back to St. Regis Avenue anyway (via Sand Creek Road and the shopping center). Therefore, the net decrease due to the potential turn restrictions is estimated to be more around 10 trips per hour once the school traffic back going through the shopping center is accounted for.

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Abrams Associates Page 11 of 12 – Bridle Gate Project Traffic Review TRAFFIC ENGINEERING, INC.

Option 5 - Additional Access to Sand Creek Road Option – Another option that was evaluated was to potentially create an additional access from the Bridle Gate Project onto Sand Creek Road. Any additional connections to Sand Creek Road would require approval from the City and this preliminary review is intended only to provide guidance on what other access options the City might consider accepting. Based on our preliminary review of the designs for the Sand Creek Road Extension and the Bridle Gate Project site plan there is only really one option for additional access to Sand Creek Road that appears to be potentially viable and might be acceptable to the City. This would be to create a new right-in/right out only access point onto Sand Creek Road between Bridle Gate Drive and the intersection with the State Route 4 eastbound ramps. Our review indicates it is unlikely the City would permit another new full movement intersection (i.e. an intersection allowing left turns) on Sand Creek Road anywhere along the Bridle Gate project frontage. The main reason for this conclusion is that another fullaccess intersection would be unlikely to meet Caltrans’ intersection spacing standards for a divided arterial roadway like Sand Creek Road. Intersections (especially signalized intersections) require sufficient spacing to allow for back-to-back turn lanes in the median and they also need sufficient spacing for safety reasons and to ensure vehicle queuing does not impact adjacent intersections.

In addition to insufficient spacing from the adjacent intersections, there are also some significant topography issues that appear to make it unlikely the City would or could feasibly approve any new connections to Sand Creek Road to the west of San Jose Avenue. The grade difference between the Bridle Gate roadway system and the final alignment of Sand Creek Road is substantial in this area. Therefore, it is our conclusion that the only new connection that might potentially be acceptable to the City would be a new right-in/right out only access onto Sand Creek Road to the east of Bridle Gate Drive.

Shifts in Traffic Patterns with the Additional Access to Sand Creek Option – A review of the project trip generation and external through traffic for the Bridle Gate Project indicates a new right-in/right-out access to Sand Creek Road would not have any significant changes to the potential future traffic on St. Regis Avenue. Almost all of the traffic using any new right-in/rightout access would be expected to be simply shifted over from the future turn volumes at the Bridle Gate Drive intersection. The northbound right turn from Bridle Gate Drive to Sand Creek Road and the eastbound right-turn onto Bridle Gate Drive are both forecast to operate with little delay under Cumulative Plus Project conditions. Because of this, and the lack of an inbound left turn movement (for traffic from State Route 4), it appears unlikely the City would ultimately identify any substantial benefits to traffic on St. Regis Avenue from a new connection to Sand Creek Road. In summary, it appears unlikely that a new access point would provide sufficient benefits to warrant having the City make substantial changes to the final design of the Sand Creek Road Extension.

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Abrams Associates Page 12 of 12 – Bridle Gate Project Traffic Review TRAFFIC ENGINEERING, INC.

Review of Potential Changes to the 2020 Traffic Impact Study Conclusions – Subject to City approval, it is our conclusion that the various options being reviewed would not result in any significant shifts in traffic that would warrant further analysis of traffic operations. None of the options include any substantial modifications to the overall planned roadway system in the project area. Based on our review there should be no new or increased hazards, or changes affecting emergency access, subject to City approval. The potential turn restrictions would not increase the severity of any previously identified Level of Service ("LOS") impacts at intersections or ramps in the area3; nor would they cause any new impacts related to LOS.

However, by discouraging through traffic from traveling south through the Bridle Gate Project there would potentially be a missed opportunity to reduce the external through traffic that currently passes through the Sand Creek Crossings Shopping Center.

Please don’t hesitate to contact me if you have any questions or need additional information.

Sincerely,
Stephen C. Abrams
President, Abrams Associates
T.E. License No. 1852
3 While the Bridle Gate EIR used LOS as one of its thresholds of significance, it should be noted that the General Plan does not include an objective mandate of compliance with any LOS Standards. The City of Brentwood’s General Plan LOS policies generally state that specified standards "should" be met rather than mandating conformance with set standards, and thus are directive as opposed to mandatory.

While the General Plan establishes Level of Service standards, Policy CIR 1-6 indicates that intersections may be exempted from the LOS standards in cases where the City Council finds that the infrastructure improvements needed to maintain vehicle LOS (such as roadway or intersection widening) would be in conflict with goals of improving multimodal circulation or would lead to other potentially adverse environmental impacts. (General Plan, p. 2-5.).

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8 Attachment B
Assessment of Traffic Calming Options

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ASSESSMENT OF TRAFFIC CALMING OPTIONS
DATE: October 16, 2023
TO: Louis Parsons | Discovery Builders
FROM: Erin Vaca | DKS Associates
SUBJECT: Brentwood Bridle Gate – Traffic Calming Improvements Project #22265-000

BACKGROUND AND INTRODUCTION
DKS Associates prepared a VMT analysis for the proposed Bridle Gate residential development in Brentwood, CA. The analysis was documented in a report dated March 2, 2023, with findings of less than significant impacts with mitigation.

Subsequently, traffic calming improvements have been proposed to minimize cut-through traffic on St. Regis Avenue, impacting the existing residential neighborhood to the south of the proposed project. The proposed traffic calming improvements are documented in a letter from Abrams Associates dated October 12, 2023. This memorandum reviews the proposed traffic calming improvements to assess whether any of these improvements would affect the VMT characteristics of the proposed project.

TRAFFIC CALMING IMPROVEMENTS
OPTION 1 – TURN RESTRICTIONS ALTERNATIVE A
Under this option, right turns would be prohibited from eastbound San Jose Avenue onto St. Regis Avenue. Southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue would also be prohibited. Note that the San Jose Avenue-St. Regis Avenue connection was not included in the traffic network model used for the VMT analysis. Therefore, the VMT analysis effectively reflects this traffic calming alternative and would not impact the VMT analysis results.

OPTION 2 – TURN RESTRICTIONS ALTERNATIVE B
This alternative is the same as Alternative A but with an additional restriction prohibiting southbound left turns from Chestnut Oak Drive onto eastbound San Jose Avenue. While the traffic network model used in the VMT analysis did include the San Jose Avenue connection, the

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BRENTWOOD BRIDLE GATE PROJECT • ASSESSMENT OF TRAFFIC CALMING OPTIONS• OCTOBER 2023 2
alternative path to access locations east of State Route 4 via San Creek Road would not be significantly longer and thus this option would be expected to have a neutral effect on VMT.

OPTION 3 – ONE WAY STREET
This alternative would restrict the segment of the San Jose Avenue extension west of St. Regis Drive to one-way westbound traffic only. This alternative would also include the prohibition of southbound through traffic from Chestnut Oak Drive onto St. Regis Avenue. Like Option 2, while the traffic network model used in the VMT analysis did include the San Jose Avenue connection, the alternative path to access locations east of State Route 4 via San Creek Road would not be significantly longer and thus this option would be expected to have a neutral effect on VMT. Note that this option would leave the path open for vehicle trips returning to the Bridle Gate neighborhood via westbound San Jose Avenue.

OPTION 4 – FULL OR PARTIAL STREET CLOSURE
This alternative proposes either a partial (southbound) or full closure of Chestnut Oak Drive at San Jose Avenue. In the traffic network model used for the VMT analysis, Chestnut Oak Drive is represented as a centroid connected to the San Jose Avenue extension. Again, the alternative path via Sand Creek Road is not significantly longer and this option would not be expected to have a significant VMT effect.

OPTION 5 – ADDITIONAL ACCESS TO SAND CREEK ROAD
This option proposes an additional right in-right-out access point to Sand Creek Road between Bridle Gate Drive and the eastbound State Route 4 ramps. This option would have the effect of slightly shortening some of vehicle trips accessing eastbound State Route 4 or eastbound Sand Creek Road with resulting minimal VMT effects.

SUMMARY
DKS has reviewed the proposed traffic calming alternatives; none of the alternatives would be expected to cause significant increases in VMT. Furthermore, all the alternatives will leave full access movement open for bicyclists and pedestrians. This will be an important consideration in providing a relatively low-stress route for Bridle Gate residents to bicycle or walk to the commercial land use along Balfour Road to the south as well as the Sand Creek Crossing shopping center to the east. In addition, it will be important to maintain bicycle and pedestrian access to Loma Vista Elementary School on San Jose Avenue to minimize VMT.

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9 Attachment C
Final Vehicle Miles Traveled (VMT)
Assessment of Traffic Calming Options
Peer Review

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FINAL Vehicle Miles Traveled (VMT) Assessment of Traffic Calming Options Peer Review June 19, 2024 Bridle Gate Residential Development Page 1 of 1
Memorandum
To: Rod Stinson
From: Chris Gregerson, P.E., T.E., ACIP
Tyler Mickelson, EIT
Ben Huie, P.E.

Re: FINAL Vehicle Miles Traveled (VMT) Assessment of Traffic Calming Options Peer Review Bridle Gate Residential Development, City of Brentwood
Date: June 19, 2024
This memorandum documents a peer review completed by Kimley-Horn of a VMT assessment for the proposed traffic calming options at the Bridle Gate Residential development in Brentwood, CA dated November 10, 2023, completed by DKS Associates1. This memorandum summarizes the initial comments prepared by Kimley-Horn.

Peer Review Comments
A. Background and Introduction

1. The DKS memo references three previous analyses to provide context for analysis completed in this update.

B. Traffic Calming Improvements

1. Kimley-Horn agrees that the first traffic calming alternative is reflected in the original analysis performed for the project.

C. Analysis Steps

1. Kimley-Horn agrees that the steps described in this section correctly model the analysis scenario comprising Option 2.

2. Kimley-Horn agrees with the methodology outlined in this section to determine the change in VMT relative to Option 2.

D. Results

1. Kimley-Horn confirms that the output from the VMT excel file matches that reported in the memo for Option 2.

2. Kimley-Horn agrees that the implementation of Option 2 traffic calming causes an insignificant change in VMT and the original findings of the Project’s VMT analysis would remain the same under this scenario, namely that of less than significant with mitigation. 1 Assessment of Traffic Calming Options for Brentwood Bridle Gate – Traffic Calming Improvements, DKS Associates, November 10, 2023.

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ORDINANCE NO. 1014
AN ORDINANCE AMENDING CHAPTER 17. 725 OF THE CITY OF BRENTWOOD MUNICIPAL CODE (" AFFORDABLE HOUSING").

WHEREAS, the City of Brentwood, California ( the " City") is a general law city, duly organized under the constitution and laws of the State of California; and WHEREAS, California Government Code Section 65800, et seq. authorizes cities to adopt and administer zoning laws, ordinances, rules and regulations as a means of implementing that city' s general plan; and
WHEREAS, on September 9, 2003, the City Council of the City of Brentwood adopted Ordinance 756, establishing the Affordable Housing Program, as recommended by the Planning Commission; and
WHEREAS, the City Council adopted Ordinance No. 790 on January 11, 2005, and amended in its entirety Chapter 17. 725 of the City of Brentwood Municipal Code ( the Affordable Housing Ordinance"); and
WHEREAS, the City Council adopted Ordinance No. 842 on April 27, 2007, amending the Affordable Housing Ordinance; and
WHEREAS, the City Council adopted Ordinance No. 874 on July 28, 2009, amending the City' s Affordable Housing Ordinance; and
WHEREAS, the City Council adopted Ordinance No. 909 on November 13, 2012, further amending the City' s Affordable Housing Ordinance; and
WHEREAS, on October 23, 2018, the City Council conducted an affordable housing workshop and appointed an ad hoc Housing Policy Committee; and WHEREAS, on April 1, 2019, the Housing Policy Committee held a meeting to receive further information from staff on the City' s Regional Housing Needs Allocation (" RHNA") attainment, the provisions of the City' s Affordable Housing Ordinance, and statewide affordable housing efforts; and
WHEREAS, on May 28, 2019, the City Council heard a presentation from staff on meeting the City' s RHNA and local affordable housing needs and directed staff to begin crafting potential Affordable Housing Ordinance amendments for Council consideration; and WHEREAS, on June 24, 2019, the City hosted a meeting with local stakeholders regarding potential amendments to the Affordable Housing Ordinance; and WHEREAS, on July 16, 2019, staff presented information on the City's RHNA attainment and affordable housing needs to the Planning Commission; and WHEREAS, on September 10, 2019, the City Council provided further direction to staff on its desired revisions to the Affordable Housing Ordinance; and

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WHEREAS, acting on such Council direction, staff prepared the ordinance attached hereto and incorporated herein as Exhibit ' 1' ( the " Ordinance"); and WHEREAS, at its meeting of March 3, 2020, the Planning Commission conducted a public hearing to consider the Ordinance, and, by adoption of Resolution No. 20- 008, recommended the City Council adopt said Ordinance; and
WHEREAS, the Ordinance is appropriate and in the public interest, as required by Brentwood Municipal Code Section 17. 870. 008. This is demonstrated by its consistency with the General Plan of the City of Brentwood, which consistency may be found with regard to multiple General Plan goals and policies, including, but not limited to:
a. Policy LU 2. 1 Maintain Brentwood' s predominant land use of single family residential while providing for a mix of housing types throughout the community, in accordance with the Housing Element, insomuch as the Ordinance will allow for the construction of a variety of affordable housing types in conjunction with market rate developments throughout the City.
b. Policy LU 2. 8 Provide for a variety of residential products through the Zoning Ordinance in order to accommodate the housing needs of all segments of the city' s population, in that the Ordinance will require eligible residential developers to construct or otherwise contribute to housing affordable to specified income ranges, thereby increasing the variety of households for which housing will be available within the city.

NOW, THEREFORE, the City Council of the City of Brentwood does ordain as follows:

SECTION 1. The text of Chapter 17. 725 of the Brentwood Municipal Code is hereby repealed in its entirety and is replaced as set forth in Exhibit " 1" attached hereto and incorporated herein.

SECTION 2. The Ordinance shall be published in accordance with Government Code Section 36933 by either posting or publishing the Ordinance in accordance with that law.

Further, the City Clerk is directed to cause the text adopted in Section 1 above to be entered in the City of Brentwood Municipal Code. This Ordinance shall take effect and be in force 30 days following its adoption.

SECTION 3. The Ordinance is exempt from review under the California Environmental Quality Act ( Public Resources Code §§ 21000, et seq., and the Guidelines for CEQA, 14 CCR 15000, et seq.) because it has no potential to result in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment, per 14 CCR § 15061( b)( 3). Further, the Ordinance is also exempt because it does not apply to any particular housing project at this time and it is thus speculative to evaluate any such future project in the context of consideration of this Ordinance.

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THE FOREGOING ORDINANCE was introduced with the first reading waived at a regular meeting of the Brentwood City Council on the
14th
day of April, 2020, by the following
vote:

AYES: Bryant, Rarey, Rodriguez, Staton, Taylor
NOES: None
ABSENT: None
RECUSE: None
And was adopted at a regular meeting of the Brentwood City Council on the 28th day of
April, 2020, by the following vote:

AYES: Bryant, Rarey, Rodriguez, Staton, Taylor
NOES: None
ABSENT: None
RECUSE: None
1 : 1324 .-11
anl a0
Robert Taylor Dat
Mayor
ATTEST:

Margaret Wi jy.erly, MMC
City Clerk b

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DRAFT/ PROPOSED CHANGES TO
CHAPTER 17. 725
Chapter 17. 725, as Amended by Proposed Ordinance
Chapter 17. 725 AFFORDABLE HOUSING

17. 725. 001 Title and purpose of provisions.

A. Title. The provisions of this chapter shall be known as the "affordable housing program" of this title.

B. Purpose. The purpose of this affordable housing program is to:

1. Enhance the public welfare and assure that further housing development contributes to the attainment of the City' s housing goals as described in the housing element of the general plan, by creating, preserving, maintaining, and protecting housing affordable for households of Very Low-, Low- and Moderate- Income;

2. Assure that the remaining developable land in the City' s planning area is utilized in a manner consistent with the city' s housing policies and needs.

3. Increase the number of affordable housing units in Brentwood in recognition of the insufficient number of existing affordable housing units in relation to the community' s current and future needs, and

4. Assure that new affordable housing units that are constructed are distributed throughout the city as part of mixed- income developments in order to obtain the benefits that flow from economically diverse communities, increase access to opportunity, and affirmatively further fair housing.

17.725. 002 Definitions.

As used in this chapter, each of the following terms shall be defined as follows:

Affordable Housing Agreement" means a recorded agreement between the City and a residential developer setting forth the residential developer' s compliance with the requirements of this chapter.

Affordable Housing Cost" means the cost defined in the California Health and Safety Code Sections 50052. 5 and 50053 ( as may be amended from time to time) for owner- occupied and tenant- occupied units, respectively, and adjusted for Assumed Household Size. The housing manager, on or about July 1 of each calendar year shall publish the maximum Affordable Housing Costs for sales prices and rents as calculated in accordance with the applicable provisions of the California Health and Safety Code.

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Affordable Unit" means an ownership or rental- housing unit, including senior housing, occupied by and available to households of very low-, low- and moderate- incomes at an affordable housing cost, adjusted for Assumed Household Size as defined in this chapter, with deed restrictions as defined in this chapter in favor of the City.

Assumed Household Size" means the assumed number of persons residing within a dwelling unit. For the purposes of this chapter, Assumed Household Sizes for Affordable Units for a given number of bedrooms are as follows, or as may be amended by the California Health and Safety Code.

Assumed 1 2 3 4 5 6 or
Household more
Size
Unit Size Studio 1 2 3 4 5
Bedroom Bedroom Bedroom Bedroom Bedroom
Custom Home Development" means any residential development being subdivided by one party and sold as individual lots or parcels to separate owners for construction and development of dwelling units.

Divided In- Lieu Fee" means the total amount of the In- Lieu Fees due for the residential development at the time of first building permit issuance divided by the total number of Market Rate Units in the residential development. The Divided In- Lieu Fee shall be adjusted annually in accordance with appropriate factors or indexes as adopted by the Cost Allocation Plan.

Dwelling Unit" means a dwelling designed and intended for occupancy by one household.

First Time Homebuyer" means a household which has not owned its principal place of residence within the last three years.

In- Lieu Fee" means a fee paid to the City by an applicant in lieu of providing the required Affordable Units.

Low- Income Household" means a household whose annual income does not exceed the qualifying limits set for " lower income households" in Section 50079. 5 of the California Health and Safety Code.

Market- Rate Unit" is defined as a residential unit that is not an Affordable Unit.

Moderate- Income Household" means a household whose annual income does not exceed the qualifying limits set for " moderate- income households" in Section 50093 of the California Health and Safety Code and does not include a very low- or low- income household.

Ownership Development" means any Residential Development that includes the creation of one or more additional dwelling units that may be sold individually. An Ownership Development also includes the conversion of a residential rental development to a residential ownership development.

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Refinance and Resale Limitation Agreement and Option to Purchase" means a recorded agreement between the City and an individual homebuyer of an ownership Affordable Unit documenting resale controls and/ or rent restrictions.

Rental Development" means any Residential Development that creates one or more additional dwelling units that cannot be lawfully sold individually in conformance with the Subdivision Map Act.

Resale Controls and/ or Rent Restrictions" means legal restrictions by which Affordable Units shall be restricted to ensure that the unit remains affordable to very low-, low- or moderateincome households, as applicable, for a period of not less than forty-five years for ownership units and not less than fifty-five years for rental units, or longer periods if required by state housing or federal law or a financing assistance program. Resale controls for owner-occupied units shall be in the form of resale restrictions, deeds of trust, and/ or other similar documents recorded against the subject property. Rent restrictions for rental units shall be in the form of a regulatory agreement recorded against the subject property.

Residential Development" means and includes, without limitation, for- sale single- family dwellings, multiple- family dwellings, groups of dwellings, condominium or townhouse developments, condominium conversions, cooperative developments, mixed use developments that include housing units, manufactured housing, mobile homes, and residential land subdivisions intended to be sold, leased or rented to the general public.

Very Low- income Household" means a household whose annual income does not exceed the qualifying limits set for " very low- income households" in Sections 50093 and 50105 of the California Health and Safety Code. " Very Low Income Households" include " extremely lowincome households" as defined in Sections 50093 and 50106 of the California Health and Safety Code.

17. 725. 003 General requirements.

A. Applicability. This chapter shall apply to all new Residential Developments of five or more lots or Dwelling Units designed and intended for residential occupancy in the city. No Residential Development, other than that exempted in subsection C of this section, shall be undertaken, and no building permits shall be accepted for processing or issued, unless the development has been approved in accordance with this chapter.

B. Affordability Requirement. Developers of Residential Developments of five or more lots or Dwelling Units designed and intended for residential occupancy shall construct or make possible the construction of a minimum of six percent of the total number of Dwelling Units within the Residential Development as Affordable Units, allocated to income levels as set forth in this chapter, or as provided in an Affordable Housing agreement which specifies the means of satisfying this chapter. Commencing on January 1, 2021, the required percentage of Affordable Units shall be increased to ten percent of the total number of Dwelling Units for any Residential Development of five or more lots, unless the application was determined to be complete by December 31, 2020 under Government Code Section 65589. 5( o). The foregoing requirement shall be applied prior to the application of a density bonus and no more than once to an

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approved Residential Development regardless of changes in its character or ownership, provided that the total number of Dwelling Units does not change.

1. Residential Developments of Five to Nine Dwelling Units. Developers of Residential Developments consisting of five to nine Dwelling Units may either construct one lowincome Affordable Unit, pay a fee equal to 50% of the low- income In- Lieu Fee, as established by resolution of the City Council, or provide an " Alternative Equivalent" as established in this chapter. However, if all or any portion of a Residential Development of five to nine Dwelling Units is later re- subdivided into ten or more parcels or Dwelling Units, the City' s affordable housing requirement may not be satisfied by payment of an In- Lieu Fee.

2. Application to Residential Development of Ten or More Dwelling Units. In applying this requirement to residential development consisting of ten or more dwelling units, any decimal fraction less than 0. 50 dwelling units shall be disregarded and any decimal fraction equal to or greater than 0. 50 dwelling units shall be construed as one dwelling unit.

C. Exemptions. The following are exempt from the provisions of this chapter:

1. Residential Development governed by a development agreement expressly precluding compliance with this chapter or an ordinance of this nature. In cases in which the development agreement does not expressly preclude compliance with this chapter, the project shall comply with this chapter;

2. Replacement housing due to natural disaster on a one for one basis ( i. e., one dwelling unit replaced for each legally existing Dwelling Unit);

3. Modifications to existing properties or structures that do not increase the number of Dwelling Units;

4. Residential care facilities with Dwelling Units that are nonself- sufficient units; that is, they do not include kitchen facilities ( if a project includes both self- sufficient and nonselfsufficient units, only the latter are exempt);

5. Subdivisions consisting of between one and four lots or Dwelling Units.

6. Development of up to four new Dwelling Units on an existing residential lot of record;

7. Development of up to three additional Dwelling Units on a lot zoned to accommodate up to a maximum of four Dwelling Units, and which already contains at least one existing Dwelling Unit, provided that the maximum limit of Dwelling Units is not increased;

8. A residential second unit or accessory dwelling unit ( as defined by state law) on an existing residential lot, subject to compliance with the zoning ordinance;

9. Residential Developments whose applications were determined to be complete under Government Code Section 65943 or any successor provision prior to the effective date of

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this Ordinance No. 1014, provided that such Residential Developments shall comply with the predecessor ordinance, resolution, or policy in effect immediately prior to the effective date of Ordinance No. 1014;

10. Residential Developments exempted by California Government Code Section 65589. 5( o) or successor provision, provided that such Residential Development shall comply with any predecessor ordinance, resolution, or policy in effect on the date a preliminary application for the development containing all of the information required by Government Code Section 65941. 1 was submitted to the City.

D. Allocation of Affordable Units to Income Levels. Dwelling units located within the Brentwood city limits for Very Low-, Low and Moderate Income Households as required by this chapter shall be allocated as follows:

Allocation through December 31, 2020 ( 6% affordability requirement):

Ownership Development
Moderate- Income Households 1%
Low- Income Households 4%
Very Low- Income Households 1%
Rental Development
Low- Income Households 3%
Very Low Income Households 3%
Allocation applicable commencing January 1, 2021 ( 10% affordability requirement):

Ownership Development
Moderate- Income Households 3%
Low- Income Households 4%
Very Low-income Households 3%
Rental Development
Low- Income Households 5%
Very Low- Income Households 5%
E.

E. Concurrent Construction. All Affordable Units in a Residential Development or phase of a Residential Development shall be constructed prior to or concurrently with Market-Rate Units, as set forth, and in the location specified, in a schedule of construction approved by the City and set forth in the Affordable Housing Agreement. The building permits for the last ten percent of

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the Market Rate Units shall not be issued until the last Affordable Unit has been issued a building permit and construction of the last Affordable Unit has begun.

F. Design and Distribution of Affordable Units. All Affordable Units within a Residential Development shall be comparable to the Market- Rate Units in exterior design, quality, materials, architectural elements and overall construction quality, as well as number and proportion of bedroom types. If approved by the Planning Commission in the design review approval process as specified in Section 17. 725. 006( D), the developer may request an exception to the foregoing in order to reduce the cost of the Affordable Units by permitting reduced front, side and backyard landscaping and smaller square footage for bedrooms. Otherwise, Affordable Units shall be comparable to the approved landscape plans, exterior elevations, and bedroom square footage found in the approved plans for the remainder of the Residential Development. In addition, all Affordable Units shall include the same or similar interior amenities offered for Market Rate Units within a Residential Development. Affordable Units shall be dispersed throughout the Residential Development so as to prevent the concentration of Affordable Units, unless the planning commission has approved an exception to this standard to accommodate senior housing or to reduce Affordable Unit costs as described above, or approval of an off- site location has been granted.

1. Very Low to Medium- Density Zoning. For residential developments with very lowto medium- density zoning designations as defined by the general plan, the Affordable Unit may be smaller in size than other models in the Residential Development. The minimum permissible Affordable Unit size is one thousand six hundred square feet on a three thousand square foot parcel. As a means to provide massing and lot proportions consistent with the Residential Development, a duet unit will satisfy the City' s affordable housing requirement. For example, a duet unit can be located on a corner with each duet unit being one thousand six hundred square feet on two separate three thousand square foot parcels.

2. High to Very High- Density Zoning. For Residential Developments with high to very high- density zoning designations as defined by the general plan, the Affordable Units shall be comparable to Market- Rate Units in square footage.

G. Length of Affordability. All Affordable Ownership Units shall remain affordable for a period of at least forty-five years from date of original occupancy and each subsequent ownership, and any Affordable Rental Units provided as an agreed- upon alternative equivalent proposal pursuant to Section 17.725.004 shall remain affordable for a period of at least fifty-five years from the date of the initial rental or leasing period, or longer periods as may be required by state housing law.

H. Concurrently with applicant' s submission of a Universal Application to the City with respect to any proposed Residential Development subject to the Chapter, applicant shall also submit a narrative describing how the proposed Residential Development will comply with the requirements of this chapter.

17. 725. 004 Alternative equivalent proposal.

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As an alternative to constructing Affordable Units on- site, a residential developer may propose one of the alternative equivalents set forth below to meet the requirements of Section

17. 725. 003. Such proposed alternative shall be processed in accordance with Section

17.725. 005 of this Chapter. An alternative equivalent proposal may include, but is not limited to, payment of an In- Lieu Fee for Ownership Development, dedication of vacant developable land, dedication of constructed units to the City' s Rental Housing Program, construction of Affordable Units on another site, or conversion of existing Market Rate Units ( either for-sale or for-rent) within the city to Affordable Units through acquisition and enforcement of required affordability restrictions consistent with this chapter. All alternative equivalent proposals must be submitted in writing, demonstrate that the alternative equivalent will provide as much or more affordable housing in the city as would be achieved through the construction of required on- site Affordable Units required under Sections 17. 725. 003( D), be consistent with the city' s housing element, and not increase residential segregation. Additionally, for Ownership Developments, an alternative equivalent proposal must result in an approximately equal geographic distribution of Affordable Units throughout the city.

A. Approval of Payment of In- Lieu Fees. In- Lieu Fees may be paid for ( 1) Residential Developments consisting of between five and nine Dwelling Units or ( 2) the Very Low- Income requirement for a Residential Development consisting of ten or more Dwelling Units. The amount of the In- Lieu Fee shall be adopted by resolution of the City Council, and may be amended from time to time.

1. In- Lieu Fees for Custom Home Developments shall be paid at time of building permit issuance for each custom home. For each permit pulled, the developer shall pay either the divided In- Lieu Fee or in a lump sum with the total fee, as elected by the developer.

2. In- Lieu Fees for all other Residential Developments shall be paid at building permit issuance for each Market Rate Unit constructed within the development. For each permit pulled, the developer shall pay either the Divided In- Lieu Fee or in a lump sum as with the total fee, as elected by the developer.

3. Except as may otherwise be required by law, the amount of the fee shall be as set forth in the In- Lieu Fee resolution in effect at the time of payment. In- Lieu Fees paid to the City shall be deposited into the Affordable Housing In- Lieu Fee Fund in accordance with Section

17. 725. 007.

4. The In- Lieu Fee paid by the developer of an Ownership Development shall be calculated using a Market Rate median sales price based in- lieu fee. This fee is based on the 12- month median sales price for a 3- bedroom, 1, 500 — 1, 700 square foot, Market Rate home in Brentwood, minus the current Affordable Housing Cost as defined in the California Health and Safety Code for owner- occupied units for the applicable household income level.

The amount of the In- Lieu Fee for each Affordable Unit shall be the difference between the Market Rate median sales price, calculated as above, and the Affordable Housing Cost for a forsale 3- bedroom unit.

5. Developers of Rental Developments must construct Affordable Units on- site or satisfy the affordable requirements through an alternative equivalent proposal other than

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payment of In- Lieu Fees unless, prior to the last discretionary approval for the development, the applicant requests a waiver under Section 17. 725. 011, and the City Council approves the InLieu Fee based on specific findings demonstrating that the City' s goals of increasing affordable housing production are equally met through use of applicant' s proposed alterative.

B. Dedication of Vacant Developable Land. An applicant may dedicate vacant developable land to the City or City- approved nonprofit housing developer in- lieu of constructing a portion of the required Affordable Units, if the City Council finds all of the following:

1. The dedication of vacant land in lieu of constructing Affordable Units is consistent with this chapter' s goal of creating, preserving, maintaining, and protecting housing for very lowlow- and moderate- income households;

2. The dedicated vacant land is large enough and appropriately zoned to accommodate the number of Affordable Units that the applicant would otherwise be required to construct by Sections 17. 725. 003( D);

3. The dedicated vacant land is improved with infrastructure and utilities required to serve the property, including, but not limited to, power, telephone, cable, gas, water, sewer and fiber optics, grading, and all applicable fees, taxes, and assessments, including, but not limited to, school and flood control fees, and excluding any affordable housing In- Lieu Fees, have been or will be paid by the applicant;

4. The dedicated vacant land is located inside the city, or the vacant land will be annexed to the city prior to issuance of any building permits to the applicant for his/ her related Market Rate Dwelling Unit( s).

5. That the off- site location would not increase segregation; and

6. That the development of Affordable Units on the dedicated land will be financially feasible.

C. Off- Site Construction of For- Sale or For- Rent Affordable Units or Conversion of Market Rate For-Sale or For- Rent Units to Affordable Units. An applicant may construct the required Affordable Units off- site from the proposed Market- Rate development site by causing the construction of new ownership or rental Affordable Units or convert existing Market- Rate ownership or rental Affordable Units with the approval of the City Council and subject to the City Council' s approval of each of the following findings and imposition of the following conditions of approval on each tentative map or other entitlement:

1. Required Findings for construction and conversion.
a. The construction of the Affordable Units off-site or conversion of the existing Market- Rate Units, excluding mobile- home units and units within cooperative developments, in lieu of constructing Affordable Units on- site is consistent with this chapter.

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b. The developer has submitted documentation to the satisfaction of the City Manager or designee that demonstrates that the construction of the Affordable Units onsite would be impractical or that off- site construction or conversion of Market Rate Units to Affordable Units will significantly benefit the city.
c. The Residential Development will be subject to the conditions of approval set forth in subsection( C)( 3) of this section. The conditions of approval for the market rate development shall require that any off- site affordable units be governed by resale controls and/ or rent restrictions similar to those required for on- site Affordable Units. d. The quality and quantity of affordable Units constructed off- site and Market Rate Units converted to Affordable Units shall be equivalent to Affordable Units that would have been constructed on- site to satisfy the city's Affordable Housing requirement.

2. Additional finding required for construction of ownership or rental Affordable Units.
a. The conditions of approval and subdivision guarantee for a residential project, or other security such as a cash deposit, are adequate to provide for the construction of the off- site Affordable Units prior to or concurrently with the completion of the on- site construction of the Market Rate Units.

3. Required Conditions.
a. Affordable Units constructed off- site shall be constructed at the time specified in the Affordable Housing Agreement.
b. Affordable Units converted from Market- Rate Units shall be both converted and inspected at the time specified in the Affordable Housing Agreement. MarketRate Units converted to Affordable Units shall require inspection by the Community Development Department to ensure that the Affordable Units are in good condition and repair, and conform to all applicable city building and zoning codes. c. Existing Very Low-, Low, or Moderate - Income- Households that occupy Market- Rate Units being converted to Affordable Units shall not be displaced from those units. If temporary or permanent displacement occurs while the converted units are being repaired or rehabilitated, the developer shall be responsible to pay relocation and moving benefits to the displaced households in accordance with the California Code of Regulations, Title 25, Chapter 6, ( California Relocation Assistance Guidelines). The calculation of relocation and moving benefits to be provided by developers to temporarily or permanently displaced households shall be submitted to and approved by the city for verification of compliance with the California relocation assistance guidelines.

D. Dedication of Affordable Units to the City of Brentwood. An applicant may dedicate constructed or converted on- site or off- site Affordable Units to the City' s rental housing Program to satisfy the requirements of this Chapter. Mobile homes and units within cooperative developments are excluded from dedication. Each unit dedicated to the City shall equate to the

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construction of 2 Affordable Units that would otherwise be required pursuant to Section

17. 725. 003 ( D). Any units dedicated to the City' s rental housing program shall be from the rental stream from these affordable rental units shall be deposited into a Brentwood Rental Housing Trust Fund administered by the City' s Finance Director in accordance with Section

17.725. 008.

All units dedicated to the City pursuant to this Chapter shall meet the following requirements prior to acceptance by the City:

1. All applicable fees ( including development impact fees), Capital Improvement Financing Program assessments, and bond interest payments shall have been prepaid by the developer.

2. The units shall be less than 20 years old and in good condition and repair, as verified by an inspection conducted by the Community Development Department.

A second such inspection may need to be performed to confirm that any repair punchlist generated by the initial inspection is completed prior to the City's acceptance of the unit into the Rental Housing Program.

3. The developer shall have installed any front yard, sideyard, any backyard landscaping and the unit' s interior shall meet the City' s minimum interior finish and appliance requirements.

4. The sprinkler system, window coverings, and all appliances shall have been installed in the unit in accordance with the list of required items maintained by the City Manager or designee.

5. Each unit must be on a subdivided parcel in accordance with Government Code sections 66426, 66427, or 66428.

6. The developer shall pay all recording, escrow and title fees involved in the transfer of title to the City, including the costs of a title policy insuring City' s title in a form and with exceptions approved by the City.

E. Other Means of Fulfilling Affordable Housing Requirements. Subject to City Manager or designee approval, any developer may fulfill its affordable housing requirement through additional alternative equivalent methods not specifically mentioned in this chapter, including through the provision of rental Affordable Units by developers of Ownership Development projects ( in accordance with Government Code Section 65589. 8), provided that the City Council determines such alternative results in the same number of Affordable Units that would have

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been provided with on- site construction of Affordable Units and that the Affordable Units otherwise meet all requirements of subsections F through G of Section 17.725.003.

17.725. 005 Implementation procedures.

A. Satisfaction of Affordable Housing Requirement. Each proposal for satisfying the city' s affordable housing requirement, together with a proposed affordable housing agreement per subsection B of this section, shall be reviewed by the City Manager or designee, considered for recommendation by the City Council Committee having jurisdiction, and forwarded to the City Council for approval on its consent calendar agenda. The requirements of this chapter shall be satisfied by all Ownership and Rental Developments subject to this chapter, the applicant receives a waiver under Section 17. 725. 011.

B. Agreements. Prior to the approval of a final map for any Residential Development, or issuance of a building permit for a unit within a Residential Development, to which this chapter applies, whichever comes first, the City and the residential developer shall enter into an Affordable Housing Agreement in a form approved by the City Attorney. For those Residential Developments for which Affordable Units will be constructed or converted on- or off-site, the Affordable Housing Agreement shall include appropriate resale controls and/ or rent restrictions.

For ownership Affordable Units, the City and the individual homebuyer shall be required to enter into a recorded refinance and resale limitation agreement in a form approved by the City Attorney. The City Manager or his or her designee is authorized to execute Affordable Housing Agreements, resale controls and/ or rent restrictions and any other documents necessary to effectuate the implementation of this chapter, provided such agreements and documents are consistent with the requirements of this chapter.

C. Annual Monitoring and Transfer Fees. Agreements involving rental units provided off- site or by conversion of market rate units as specified in 17. 725. 004( C) shall require the owner of the Affordable Rental Units to submit an annual monitoring report to the Housing Division, in a format approved by the City Manager. For each Affordable Rental unit provided hereunder, the current owner may be required to pay an annual monitoring fee for the term of required affordability in the amount set forth in the Affordable Housing Agreement. For each owneroccupied Affordable Unit provided under this chapter, the current owner may be required to pay a transfer fee for any change of ownership as adopted from time to time by the City Council during the term of required affordability in the amount set forth in the Refinance and Resale Limitation Agreement.

D. Resale Prices for Affordable Ownership Units. The maximum resale price for an Affordable Ownership Unit and terms of resale to an eligible household shall be set by the Community Development Director pursuant to the Affordable Housing Cost as defined in Section 17. 725. 002( A) and as set forth in a Refinance and Resale Limitation Agreement.

E. City' s Right of Option to Purchase Affordable Ownership Units. The Resale Restrictions as set forth in the Refinance and Resale Limitation Agreement shall provide that in the event the owner cannot in good faith and despite his/ her best reasonable efforts, locate an eligible household to purchase an Affordable Ownership Unit at an Affordable Housing Cost, the owner shall give written notice of such circumstances, and an option to purchase, to the City. The City

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shall also have an option to purchase the Affordable Unit at the maximum resale price, as limited by any applicable affordability restrictions, if the owner defaults on the terms of the Refinance and Resale Limitation Agreement.

F. Selection Criteria for Rental or Ownership Units. No household at the time of move- in shall be permitted to rent, purchase or occupy an Affordable Unit that is required under this chapter unless its qualifications are consistent with this chapter and the housing manager has approved the household' s eligibility. Eligible potential occupants of ownership Affordable Units must be first-time homebuyers and will be qualified on the basis of household income as defined in this chapter, including all sources of income and assets, the relationship between household size and the size of the available units, and any further criteria required by law and/ or established by the City Council. The affordable housing developer shall use an equitable selection method established in conformance with the terms of this chapter and in compliance with state and federal law. Selection of qualified households shall be based on the affordable housing priorities established below:

Priority 1. Eligible applicants for an Affordable Unit that live or work within Brentwood city limits. Preference will not be allowed if not permitted by state or federal law or other fair housing restrictions.

Priority 2. Other Qualified Applicants that do not live or work within Brentwood' s City Limits.

The Community Development Director shall establish and maintain eligibility selection contact lists for qualified households based on the two housing priority groups mentioned in subsection F of this section. Proof of qualification for a priority group shall be provided by a household before placement on one of the selection contact lists. The lists shall be updated as needed.

By virtue of their position or relationship, City senior management employees and officials and their children, or members of the city' s agencies, authorities, or commissions who have, by the authority of their position, policy making authority or influence affecting city housing programs, are ineligible to occupy an Affordable Unit.

17.725.006 Affordable unit concessions and construction incentives.

For any Residential Development meeting the requirements specified in Section 17. 725. 003 of this chapter, the city may offer incentives or financial assistance to encourage compliance with this chapter to the extent resources for this purpose are available and approved for such use by the City. In order to provide flexibility in the application of these concessions and incentives, and to ensure that they fit the variety of circumstances and different development projects regularly processed by the City, such incentives may include, but shall not be limited to any of the following items, applied alone or in any combination upon the City Council' s finding that a developer has proven that the incentive is necessary to the financial feasibility of the residential development.

A. Development Processing Fee Deferral. The City Manager or designee may approve deferring payment of City processing and plan check fees applicable to the review and

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processing of the project. The terms and payment schedule of the deferred processing fees shall be subject to the approval of the City Manager or designee. In no case shall deferred development processing fees be paid later than occupancy of any of the units in the Residential Development. In no case shall fees be waived.

B. Development Impact Fee Deferral. The City Manager or designee may authorize the deferred payment of development impact fees applicable to the Affordable Units. Approval of this incentive requires demonstration by the applicant that the deferral increases the project' s feasibility. The applicant must provide appropriate security to ensure future payment of applicable development impact fees. In no case shall deferred development impact fees be paid later than occupancy of any of the units in the Residential Development. In no case shall fees be waived.

C. Density Bonus. Concurrently with consideration of an application for a residential growth management program allocation, the city may award a density bonus for developments that comply with the very low-, low or moderate income affordability provisions of this chapter by constructing units on- site, paying the appropriate in lieu fee, providing an acceptable alternative equivalent proposal, or a combination of the above, in accordance with this chapter. In the event that a development is also eligible for a density bonus pursuant to Government Code Section 65915, the density bonus authorized pursuant to this chapter shall be included in any density bonus obtained pursuant to state law and shall not increase the amount of the density bonus above that afforded by state law. An application for a density bonus must be received concurrently with an application for residential growth management program allotments. The density bonus provided shall initially be set at nine percent above the midpoint of the density range established in the general plan and zoning code. Fractional density bonus units shall be rounded in the manner set forth in Section 17.725. 003( B)( 2) of this chapter. The density bonus amount shall be periodically reviewed by the city engineer, the community development director, and the housing manager, who will recommend that adjustments, as appropriate, be adopted by resolution of the city council. Density bonus units authorized under this chapter shall be excluded from the affordability requirements specified in Section 17. 725. 003 of this code.

D. Flexible Design Standards. The approving body may modify city standards, including design guidelines, for Affordable Units that reduce the costs of and are necessary to result in identifiable and actual cost reductions to provide for affordable housing, including but not limited to, the following:

1. Reduced lot sizes;

2. Reduced setback requirements;

3. Reduced open space requirements;

4. Construction of duets, duplexes, triplexes or fourplexes on corner lots within single- family areas;

5. Reduced landscaping requirements;

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6. Reduced parking requirements;

7. Height restriction waivers.

The applicant shall be responsible for documenting to the satisfaction of City Manager or designee, that the modification is necessary for the financial or other feasibility of the Residential Development. Except for any standards modified by the planning commission, the Residential Development must otherwise be consistent with all required general plan, zoning code, Uniform Building Code, and other applicable city regulations and policies.

E. Fast Track Processing. The City Manager or designee may authorize prioritized application review and project processing including environmental review, report preparation, entitlement meetings, plan checks and project inspections.

F. Direct Financial Assistance. The City Council may authorize provision of direct financial assistance in the form of a loan or grant from collected affordable housing trust funds as described in Section 17. 725. 007 of this code for developments which include Dwellings Units affordable to Very Low-, Low, or Moderate- Income- Households that exceed minimum Affordable Unit counts required under Section 17. 725. 003 of this code.

G. Additional Concessions and Incentives. The City Council may consider, on a case- bycase basis, at its sole discretion, the provision of additional concessions or incentives consistent with state law and the housing element of the City of Brentwood general plan for residential development projects that exceed the requirements of this chapter.

17.725.007 Affordable housing in lieu fee fund.

A. Creation. In- Lieu Fees shall be deposited into the Affordable Housing In- Lieu Fee fund, which is part of the housing enterprise.

B. Use. The Finance Director shall administer all monies in this fund including any interest earnings. Funds shall be disbursed at the discretion of the City Council for the purpose of assisting in the construction of Very Low-, Low or Moderate- Income Dwelling Units, or helping with other affordable housing opportunities. Use of this fund may include the provision of loans to help fund rental housing projects. The Finance Director is authorized to utilize the City Council approved budget to annually fund the city housing operating costs. In addition, the Finance Director is authorized to make budget adjustments as required to forgive the interfund receivable that has accumulated prior to the adoption of this Ordinance codified in this chapter.

17. 725. 008 Brentwood rental housing trust fund.

A. Creation. Net rental income from all rental units dedicated to the City' s previous rental housing program shall be deposited into a Brentwood rental housing trust fund, which is part of the housing enterprise.

B. Use. The Finance Director shall administer all monies in this fund including any interest earnings. All funds other than those specified in subsection C of this section shall be utilized

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to purchase, construct or repair single- or multi-family rental unit inside the city limits. One- half of the rental income may be utilized from time to time at the City Council' s discretion to further the provision of affordable housing in the city of Brentwood so long as sufficient funds remain to pay for the maintenance and operation of existing affordable housing in the city' s rental housing program.

C. Withholding. The Finance Director is authorized to utilize the City Council approved budget to annually fund the City housing operating costs from the rental stream of these affordable rental units to fund City housing personnel and administrative costs directly related to management and administration of the Brentwood rental housing trust fund and program. The Finance Director is further authorized to withhold up to an additional fifteen percent of net proceeds from the rental stream to reimburse city development fees and agricultural mitigation fees for these units until the City development fee accounts are whole.

17.725.009 First time homebuver fund.

A. Creation. Contributions to the city' s first time homebuyer program in accordance with Section 17. 725. 004( D) shall be deposited into the first time homebuyer fund, which is part of the housing enterprise.

B. Use. The Finance Director shall administer all monies in this fund, including any interest earnings. All monies in the fund, other than those specified in Section 17. 725. 009( C) shall be loaned to first time homebuyers that qualify as a Moderate Income, Low-Income or Very LowIncome Household, in accordance with terms and provisions of the approved first time homebuyer program approved by the City Council.

C. Withholding. The Finance Director is authorized to utilize the City Council approved budget to annually fund the City housing personnel and administrative costs directly related to the management and administration of the first time homebuyer fund and program.

17. 725. 010 Enforcement.

A. General. The City shall enforce this chapter, and its provisions shall be binding on all agents, successors, and assigns of an applicant. The City may suspend or revoke any building permit or approval upon finding a violation of any provision of this chapter. No land use approval, building permit, or occupancy approval shall be granted for any residential development unless it is in compliance herewith, including but not limited to, actions to revoke, deny, or suspend any permit or development approval.

B. Excessive Sales Price and Rents/ Legal Action. It is unlawful, a public nuisance and a misdemeanor for any person to sell or rent an Affordable Unit at a price or rent exceeding the maximum allowed under this chapter or to a household not qualified under this chapter, and such person shall be subject to a five hundred dollar fine per month from the date of original noncompliance until the Affordable Unit is in compliance with this chapter. If the City determines that the sales price or rents_in excess of those allowed by operation of this chapter have been charged to a household residing in an Affordable Unit, the City may take appropriate legal action.

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C. Violation Abatement. The City of Brentwood City Attorney or the Contra Costa County District Attorney, as appropriate, shall be authorized to abate violations of this chapter and to enforce the provisions of this chapter and all implementing regulatory agreements and affordability controls placed on Affordable Units by civil action, injunctive relief, and any other proceeding or method permitted by law. Remedies provided for in this chapter shall not preclude the city from any other remedy or relief to which it otherwise would be entitled under law or equity.

17.725. 011 Waiver.

A. A developer of any project subject to the requirements of this chapter may request that the requirements of this section be waived or modified by the City Council, based upon a showing that applying the requirements of this section would result in an unconstitutional taking of property or would result in any other unconstitutional result.

B. Any such request for a waiver shall be made in writing to the City Council, submitted to the City concurrently with applicant' s submission of a Universal Application for any proposed Residential Development subject to this chapter.

C. The request for waiver shall set forth in detail the factual and legal basis for the claim of waiver or modification. The City Council shall consider the request at the public hearing on the permit application. The applicant shall bear the burden of presenting substantial evidence to support the waiver request, including comparable technical information to support applicant' s position.

D. A waiver of an affordable housing requirement may only be approved by the City Council to the extent necessary to avoid an unconstitutional result, based upon legal advice provided by or at the behest of the City Attorney, after adoption of written findings, based on legal analysis and substantial evidence. The decision of the City Council shall be final. If a modification or waiver is granted, any change in use within the project shall invalidate the waiver or modification of the affordable housing requirement, and a new application shall be required for any waiver or modification under this section.

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CITY COUNCIL AGENDA ITEM NO. I.1
12/10/2024
SUBJECT: Independent Auditors’ Reports and Annual Comprehensive Financial Report for Fiscal Year 2023/24; and Report on the Financial Awards received by the City
DEPARTMENT: Finance and Information Systems
STAFF: Kerry Breen, Director of Finance and Information Systems Sonia Agostini, Accounting Manager

TITLE/RECOMMENDATION
Independent Auditors’ Reports and Annual Comprehensive Financial Report for Fiscal Year 2023/24; and Report on the Financial Awards received by the City.

Staff recommends the City Council receive the Independent Auditors’ Reports and Annual Comprehensive Financial Report for Fiscal Year 2023/24 and the report on the Financial Awards received by the City.

FISCAL IMPACT
There is no fiscal impact with receipt of the Independent Auditor’s Reports and Annual Comprehensive Financial Report.

Recognition of the City’s adherence to the highest standards of Governmental Reporting continues to promote trust and transparency with the public and have a significant impact on the City’s ability to obtain favorable financing through the credit market. This has proven to be historically beneficial to the City, as refunding of bonds has resulted in the City reducing interest rates on certain debt and generating savings. The savings the City has been able to achieve would not have been possible without a strong reputation for strength, reliability, and transparency in financial management reporting.

BACKGROUND
The Annual Comprehensive Financial Report (ACFR) contains a comprehensive and complete report of financial information for the City for the fiscal year ended on June 30, 2024. A discussion of the key information about the financial statements can be found in the Management’s Discussion and Analysis starting on page 20 of the ACFR.

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CITY COUNCIL AGENDA ITEM NO. I.1
12/10/2024
At fiscal year-end, the City’s General Fund had a fund balance of $29.4 million. Of this amount, $7.0 million has been set aside for specific use, such as the Successor Agency repayment plan, costs associated with the Police Department 5th geographical beat, and future capital projects. The remaining $22.4 million comprises the General Fund 30% reserve, as required by Budget and Fiscal Policy.

General Fund revenues exceeded expenses and amounts set aside for the 30% reserve by $2.7 million during the fiscal year. Two factors contributed to this surplus, $1.1 million in one-time investment fair market value gains and $1.2 million generated from a Council-directed reduction in planned project spending. Budget and Fiscal Policy requires that half of any annual surplus be used to reduce unfunded pension obligations and half be transferred to the Pension/Other-Post Employment Benefit Obligation Fund, known as the Budget Stabilization Fund. Via resolution, City Council directed the exclusion of $1.2 million in reduced project spending from the calculation of the required pension obligation payment. As a result, $733,826 of the surplus will be used for the pension payment and $1,933,826 will be transferred to the Budget Stabilization Fund to be used to offset rising pension and retiree medical costs in the intermediate-term.

Staff recognizes that the ACFR is a complex financial document. To provide more focused and timely information, the Finance Department published the Fiscal Year 2023/24 Financial Snapshot (“Snapshot”) in October 2024. The Snapshot summarizes the City’s year-end results in an easy to understand format, with major financial trends and key metrics in just nine pages.

The Finance Department also provides other regular financial reports and updates including quarterly Financial Dashboard, Sales Tax and Investment reports, along with annual Budget-in-Brief, Development Impact Fee and the Combined Community Facilities District Annual Reports. All of these reports and updates can be found on the City’s website at Financial Documents.

Finally, a comprehensive budget update is provided to the City Council every six months via the Mid-Year and Mid-Term Budget review processes. The next update presented to the City Council will be on January 28, 2025 at the Mid-Year 2024/25 Budget review.

Audit and ACFR
The independent audit firm, Maze & Associates, has completed its review and examination of the City’s financial transactions and statements for the year ended June 30, 2024 and will be presenting the results of their audit during discussion of this agenda item. The audit was conducted in accordance with generally accepted auditing standards. It is the opinion of the auditors that the financial statements fairly represent the financial position of the City as of June 30, 2024 and that the

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12/10/2024
statements were prepared in conformity with generally accepted accounting principles. In addition, in any year the City receives funding from the Transportation Development Act program, a separate audit report is required by the State Controller’s Office. This audit report was also prepared by Maze & Associates and is an attachment to this staff report.

The Finance Department was responsible for the coordination of the audit process, the completion of year-end closing, and the preparation of the ACFR.

Each fiscal year, the City is required to have an independent audit of its financial statements and the Finance Department consolidates the City’s financial statements into an ACFR. The purpose of the ACFR is to provide citizens, grantor agencies, and other interested parties with reliable financial information about the City.

The ACFR has three main components: the introductory section, the financial section, and the statistical section.
 The Introductory section includes the Letter of Transmittal, which provides an analysis of the City’s economic condition and financial outlook, as well as information on the City’s long-term financial planning.  The Financial Section includes the primary financial statements of the City.  The Statistical Section provides current and historical trend information for the City.

System of Internal Controls
In simple terms, internal controls are the methods and procedures designed by management to safeguard assets and manage resources. They include how management "sets the tone", providing discipline and structure, and the means for communication up, down, and across the City’s organizational structure to meet the City's stated goals and objectives. In the context of the annual external financial audit, internal controls are the system of checks and balances designed to minimize the likelihood of errors in the accounting records and deter fraud, embezzlement, and theft by employees, customers, and vendors. These goals are generally accomplished by incorporating control activities into the organization's operations. The most common activities include approvals and verifications, reconciliations, reviews, and segregation of duties.

It is the City's obligation to establish the system of internal controls, not the City’s outside auditors, Maze & Associates.

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12/10/2024
When considering a system of internal controls, it is important to consider the risk a control activity proposes to reduce, against the cost of the activity itself. More controls may not always be better; both the law of diminishing returns and resource limitations can significantly affect the decision of which activities to employ in each situation. It is also important to carefully balance the need for adequate controls against the creation of unnecessary bureaucracy, as efficiency is also an important organizational objective.

In addition to performing the audit and offering an opinion on the City’s financial statements, the City's auditors perform an assessment of the City's internal controls as part of the audit each year. The independent auditors may note certain matters involving internal control and other operational concerns. These items are not considered “findings” but rather recommendations for improvement. In addition, the auditors are required to communicate specific information to the legislative body.

The information to be communicated is included in the Memorandum on Internal Control and the Required Communications attached to this report.

Financial Awards
The Finance Department takes great pride in publishing documents that adhere to the highest standards of governmental budgeting and accounting excellence. Receipt of financial awards is indicative of the high standards expected by the City Council and serve to reaffirm the validity and integrity of the City’s financial reporting and budgeting to the citizens, staff, and outside agencies.

Since Fiscal Year 2000/01, the City has received the Certificate of Achievement for Excellence in Financial Reporting from the Government Finance Officers Association (GFOA) for the ACFR. The GFOA award is a prestigious national award recognizing the use of high standards in preparing state and local government financial reports.

Participation in this program has several benefits. An award-winning ACFR shows dedication to fiscal responsibility and outstanding financial management and reporting. Producing an ACFR confirms that the City operates at the highest level for financial reporting standards and this award has helped the City receive strong bond ratings and favorable interest rates from the debt investment community. As opposed to being prepared by the auditors as a separate contract for service, the ACFR was prepared and published in-house and reflects the work of the entire Finance Department staff.

Following are the awards that were received during the past year:
 Excellence in Capital Budgeting from the California Society of Municipal Finance Officers (CSMFO) for the FY 2023/24 Capital Improvement Program.

This State Award was established by CSMFO to recognize those agencies whose

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CITY COUNCIL AGENDA ITEM NO. I.1
12/10/2024
capital improvement program documents meet certain state-wide standards and requirements considered to be of the highest quality.  Excellence in Financial Reporting from the GFOA for the Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2023. This national award was established by GFOA to recognize individual governments that prepare annual financial reports that exemplify the spirit of transparency and full disclosure. The City’s ACFR is reviewed by selected members of the GFOA professional staff and the GFOA Special Review Committee, which comprises individuals with expertise in public-sector financial reporting and includes financial statement preparers, independent auditors, academics, and other financial professionals.
 Distinguished Budget Presentation Award from the GFOA for the 2024/25 – 2025/26 Operating Budget. This national award was established by GFOA to recognize individual governments that prepare Operating Budgets of the very highest quality and reflect both the guidelines established by the National Advisory Council on State and Local Budgeting and the GFOA’s recommended practices on budgeting. The City’s Operating Budget is reviewed by selected members of the GFOA professional staff and by outside reviewers with experience in public sector budgeting.

CITY COUNCIL STRATEGIC INITIATIVE
Not Applicable

PREVIOUS ACTION
Attachment 1

DATE OF NOTICE
Not Applicable

ENVIRONMENTAL DETERMINATION
Not Applicable

ALTERNATIVE OPTION(S)

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CITY COUNCIL AGENDA ITEM NO. I.1
12/10/2024
Not Applicable

ATTACHMENT(S)

1. Previous Action

2. 2023/24 ACFR

3. Memorandum on Internal Control

4. Required Communications

5. CSMFO Capital Budget Award

6. GFOA ACFR Award Certificate

7. GFOA 2024/25 – 2025/26 Operating Budget Award

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ATTACHMENT 1 – PREVIOUS ACTION
Previous actions related to this agenda item that were taken by the Council are listed below. To view prior actions and materials, and Brentwood Municipal Code references in the staff report, as applicable:
 Visit www.brentwoodca.gov/meetings, and select the meeting date(s) desired to see the reference materials and videos.
 Visit www.brentwoodca.gov/municipalcode to research references to the Brentwood Municipal Code and search by the code section(s) cited.

On February 25, 2020, the City Council approved Resolution 2020-19, approving and authorizing the City Manager or designee to execute a professional services agreement with Maze & Associates as the City’s independent external audit firm for the fiscal years ending June 30, 2020 through June 30, 2021 in an amount not to exceed $146,434, with an option to execute amendments for an additional three fiscal years in an amount not to exceed $228,922 upon satisfactory completion of the services.

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150 City Park Way
Brentwood, CA 94513
ANNUAL

COMPREHENSIVE

FINANCIAL REPORT
Fiscal Year Ended
June 30, 2024

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2 2023/24 Annual Comprehensive Financial Report
Table of Contents
For Fiscal Year Ended June 30, 2024

INTRODUCTORY SECTION
Table of Contents ............................................................................................................................................................................... 2 Letter of Transmittal ......................................................................................................................................................................... 5 Certificate of Achievement – Government Finance Officers Association ................................................................. 11 City Council and Executive Team ............................................................................................................................................. 12 City Organizational Chart ............................................................................................................................................................ 13 Community Services Location Map ........................................................................................................................................ 14 Mission Statement/Core Values/Vision and Culture ........................................................................................................ 15 Awards ................................................................................................................................................................................................ 16

FINANCIAL SECTION
INDEPENDENT AUDITORS REPORT ................................................................................................................................... 17 MANAGEMENT’S DISCUSSION AND ANALYSIS .......................................................................................................... 20

BASIC FINANCIAL STATEMENTS
Government-Wide Financial Statements
Statement of Net Position ............................................................................................................................................. 35 Statement of Activities and Changes in Net Position ......................................................................................... 36 Fund Financial Statements
Governmental Fund Financial Statements
Balance Sheet – Governmental Funds ....................................................................................................................... 37 Reconciliation of the Governmental Funds Balance Sheet to the Government-Wide Statement of Net Position ............................................................................................................................................. 38 Statement of Revenues, Expenditures and Changes in
Fund Balances – Governmental Funds ...................................................................................................................... 39 Reconciliation of the Governmental Funds Statement of Revenues, Expenditures and Changes in Fund Balances to the Government-Wide Statement of Activities and Changes in Net Position ................................................................................................................................................. 40 Proprietary Fund Financial Statements
Statement of Net Position ............................................................................................................................................. 41 Statement of Revenues, Expenses and Changes in Fund Net Position ........................................................ 42 Statement of Cash Flows ................................................................................................................................................ 43 Fiduciary Fund Financial Statements
Statement of Fiduciary Net Position .......................................................................................................................... 44 Statement of Changes in Fiduciary Net Position ................................................................................................... 45 Notes to the Basic Financial Statements
Index of Notes to the Basic Financial Statements ................................................................................................ 46

REQUIRED SUPPLEMENTARY INFORMATION
Budgetary Comparison Schedule, General Fund ........................................................................................................ 117 Budgetary Comparison Schedule, Landscape and Lighting Assessment Districts ......................................... 118

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3 2023/24 Annual Comprehensive Financial Report
Table of Contents
Note to the Required Supplementary Information .................................................................................................... 119 Schedule of Changes in Net OPEB Liability/(Assets) and Related Ratios .......................................................... 120 Schedule of Employer OPEB Contributions ................................................................................................................... 121 Miscellaneous Plan Schedule of Changes in the Net Pension Liability and Related Ratios ....................... 122 Miscellaneous Plan Schedule of Contributions ............................................................................................................ 123 Safety Plan Schedule of Proportionate Share of the Net Pension Liability ...................................................... 125 Safety Plan Schedule of Contributions ........................................................................................................................... 125

SUPPLEMENTAL INFORMATION

COMBINING AND INDIVIDUAL FUND STATEMENTS AND SCHEDULES
Non-Major Governmental Funds
Combining Balance Sheet ............................................................................................................................................ 126 Combining Statement of Revenues, Expenditures and Changes in Fund Balances .............................. 131 Budgeted Schedule of Revenues, Expenditures and Changes in Fund Balances – Budget and Actual ......................................................................................................................... 136 Internal Service Funds
Combining Statement of Net Position .................................................................................................................... 145 Combining Statement of Revenues, Expenses and Changes in Fund Net Position .............................. 147 Combining Statement of Cash Flows ...................................................................................................................... 149 Fiduciary Funds
Combining Statement of Fiduciary Net Position ................................................................................................ 151 Combining Statement of Changes in Fiduciary Net Position ........................................................................ 152 STATISTICAL SECTION (Unaudited)
Statistical Section Contents ...................................................................................................................................................... 153 Net Position by Component - Schedule 1 ......................................................................................................................... 154 Changes in Net Position – Governmental Activities - Schedule 2a .......................................................................... 155 Changes in Net Position – Business-Type Activities - Schedule 2b ......................................................................... 156 Fund Balances – Governmental Funds - Schedule 3 ...................................................................................................... 157 Changes in Fund Balances – Governmental Funds - Schedule 4 .............................................................................. 158 Assessed Value and Estimated Actual Value of Taxable Property - Schedule 5 ................................................. 159 Direct and Overlapping Property Taxes - Schedule 6 ................................................................................................... 160 Principal Property Taxpayers - Schedule 7 ......................................................................................................................... 161 Property Tax Levies and Collections - Schedule 8 .......................................................................................................... 162 Taxable Sales by Category - Schedule 9 ............................................................................................................................. 163 Direct and Overlapping Sales Tax Rates - Schedule 10 ................................................................................................ 164 Top 25 Sales Tax Producers - Schedule 11 ........................................................................................................................ 165 Water Use Revenue by Customer Type - Schedule 12 .................................................................................................. 166 Water Rates - Schedule 13 ....................................................................................................................................................... 167 Ratios of Outstanding Debt by Type - Schedule 14 ....................................................................................................... 168 Ratios of General Bonded Debt Outstanding - Schedule 15 ...................................................................................... 169 Direct and Overlapping Governmental Activities Debt - Schedule 16 ................................................................... 170 Legal Debt Margin Information - Schedule 17 ................................................................................................................. 171 Pledged Revenue Coverage - Schedule 18 ........................................................................................................................ 172 Demographic and Economic Statistics - Schedule 19 ................................................................................................... 173

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4 2023/24 Annual Comprehensive Financial Report
Table of Contents
Principal Employers - Schedule 20 ........................................................................................................................................ 174 Authorized Full-Time Equivalent City Government Employees by Function/Program - Schedule 21 .................................................................................................................................... 175 Operating Indicators by Function/Program - Schedule 22 ......................................................................................... 176 Capital Asset Statistics by Function/Program - Schedule 23 ...................................................................................... 177 General Information - Schedule 24 ....................................................................................................................................... 178

OTHER AUDIT REPORT
Independent Auditor’s Report on Internal Control Over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements performed in Accordance with Government Auditing Standards ......................................................................................................................................................................................... 179

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5 2023/24 Annual Comprehensive Financial Report
Letter of Transmittal
December 10, 2024
The Honorable Mayor, Members of the City Council and Citizens of Brentwood Brentwood, California 94513
Dear Mayor, Members of the City Council and Citizens of Brentwood:

We are pleased to submit the Annual Comprehensive Financial Report for the City of Brentwood, California (“the City”), for the fiscal year (FY) ended June 30, 2024. Each year, the City publishes a complete set of financial statements that are presented in conformity with Generally Accepted Accounting Principles (GAAP) and audited by an independent, certified public accounting firm.

The City’s Finance and Information Systems Department prepared this report. Responsibility for both the accuracy of the data and the completeness and fairness of the information, including all disclosures, rests with the City. To the best of the City staff’s knowledge and belief, the enclosed data is accurate in all material respects and is reported in a manner to fairly present the financial position and results of the operations of the various entities of the City. All disclosures necessary for the reader to understand the City’s financial activities have been included. GAAP requires that management provide a narrative introduction overview and analysis to accompany the basic financial statements in the form of a Management’s Discussion and Analysis (MD&A). This letter of transmittal complements the MD&A, which can be found immediately following the report of the independent auditors.

INTERNAL CONTROLS
The Finance and Information Systems Department accounts for the City’s programs and activities. In conjunction with the City’s management, the Finance and Information Systems Department is responsible for maintaining the integrity of the City’s recorded financial data and establishing and maintaining an internal control structure to ensure that the City’s assets are protected from loss, theft or misuse. The internal control structure is designed to provide reasonable assurance these objectives are met, while recognizing that this assurance is not absolute. The concept of reasonable assurance recognizes: 1) the cost of a control should not exceed the benefits likely to be derived and 2) the valuation of costs and benefits requires estimates and judgments by management. City management believes the existing internal control systems are adequate to provide reasonable assurance the City’s assets are safeguarded against loss and that the financial records are reliable for preparing financial statements and maintaining accountability for assets. This belief is supported by the “unmodified” audit opinion issued by the City’s independent external auditors for the fiscal year ended June 30, 2024.

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6 2023/24 Annual Comprehensive Financial Report
Letter of Transmittal

INDEPENDENT AUDIT
The City Council is responsible for: 1) assuring the City’s management fulfills its responsibilities in the preparation of the financial statements and 2) engaging certified public accountants with whom the City Council reviews the scope of the audit and the accounting principles to be applied in financial reporting.

The Government Code of the State of California requires general law cities, such as the City, to have its financial statements audited by an independent certified public accountant. Accordingly, this year’s audit was completed by the accounting firm of Maze & Associates. The firm was engaged by the City Council to render an opinion on the City’s financial statements in accordance with auditing standards generally accepted in the United States of America. To ensure complete independence, Maze & Associates presents the results of their assessment of the adequacy of internal accounting controls and the quality of financial reporting directly to the City Council. The auditor’s report on the basic financial statements is the first item in the accompanying Financial Section.

In addition to meeting the requirements set forth in state statutes, the audit meets the requirements of the Federal Single Audit Act, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). The standards governing Single Audit engagements require the independent auditor to report both on the fair presentation of the financial statements and on the audited government’s internal controls and compliance with legal requirements.

PROFILE OF BRENTWOOD
The City was founded in 1878 and incorporated in 1948 as a general law city under the laws of the State of California. Brentwood encompasses approximately 14.83 square miles and is located in eastern Contra Costa County, 55 miles east of San Francisco and 62 miles south of Sacramento. The City is governed by a five-member City Council, under the Council-Manager form of government. As of January 1, 2024, the City had an estimated population of 64,811.

The City provides a full range of services including: Police, Public Works, Economic Development, Planning, Building, Community Enrichment, Engineering and Inspection, Parks and Recreation, Housing and General Administrative services. The City also operates public water and wastewater utilities, as well as solid waste collection and disposal services and a recycling program. All of these services are accounted for in the City’s financial statements.

The City was financially accountable for the Brentwood Redevelopment Agency prior to its dissolution, effective February 1, 2012 as a matter of State law. At that time, the City opted to become the Successor Agency to the Brentwood Redevelopment Agency (“Successor Agency”). Financial data of the Successor Agency has been segregated in a private-purpose trust fund. In addition, the City is financially accountable for the Brentwood Infrastructure Financing Authority (the “Authority”), a component unit of the City. Although a legally separate entity, this blended component unit is also substantively part of the government’s operations. Financial data for the Authority is combined with the data of the primary government. For accounting purposes, the Authority, the Successor Agency and the City all have a June 30 year-end date. See Note #1A for a more detailed discussion of the reporting entity.

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7 2023/24 Annual Comprehensive Financial Report
Letter of Transmittal
The City’s annual budget serves as the foundation for planning and controlling the City’s finances. As such, the City maintains extensive budgetary controls. The objective of these budgetary controls is to ensure compliance with legal provisions embodied in the annual appropriated budget approved by the City Council. For additional budgetary information, see Note #2A. The City operates on a two-year budget cycle with the budget process beginning in November and culminating with final Council approval in June. The adopted two-year budget is then formally reviewed by the City Council at a public meeting every six months for adjustments. The City’s adopted budget includes legally required budgets for the activities of the General Fund, Special Revenue Funds, Fiduciary Funds, Internal Service Funds and certain Capital Project Funds. Additionally, although not legally required, Debt Service budget information is also included.

ECONOMIC CONDITION AND FINANCIAL OUTLOOK
Despite significant challenges, the U.S, economy has remained solid and periods of high inflation and geopolitical turmoil have not yet resulted in the recession that many economists had projected. Despite this strength, there are declines in leading economic indicators that may indicate potential weakness in the overall economy. There is a good possibility of a coming general economic slowdown, as the higher cost of both government and personal borrowing may crowd out consumer spending - the primary driver of the US economy.

Although inflationary pressures appear to be cooling and have fallen below 3%, the recent period of persistently high inflation has led to a substantial increase in the City’s cost to provide services to the public and build infrastructure. With limitations on the ability of the City to increase revenues, income growth may not be sufficient to cover cost increases driven by high inflation in the past few fiscal years.

Adding to the economic uncertainty, the State continues to pass regulatory requirements without accompanying funding. Costs for compliance in the area of solid waste organics processing has already had impacts on the budget. Similarly, additional regulation that mandates electric vehicle fleets for public entities is among the many factors that could add significant infrastructure and ongoing operational costs.

The General Fund provides funding for the majority of City services, including street maintenance, parks and police. General Fund operations for FY 2023/24 resulted in a surplus, with revenues exceeding expenses and amounts set aside for reserves by $2.7 million. Included in these results are $1.1 million in one-time investment fair market value gains and $1.2 million released from a future planned project.

Pursuant to City Council policy and as a part of the City’s long-term fiscal sustainability strategy, half of the surplus will be used to reduce unfunded pension obligations. Via resolution, City Council directed exclusion of the $1.2 million in reduced project spending from the calculation of the required pension payment. As a result, $733,826 of the surplus will be used for a pension paydown.

Property taxes, the General Fund’s top revenue source, has risen by an average of approximately 5% per year over the past five years, providing the City with a means to offset some of the inflationary cost pressures. Property tax revenue growth rates are projected to slow to the 3%-4% range over the next few fiscal years due to higher mortgage rates and declining housing affordability. A sign of potential stress in the real estate market is evident in declining property turnover rates during FY 2023/24, which are now at historically low levels. Sales tax, the General Fund’s second largest revenue source, has rebounded to surpass pre-pandemic levels. However, sales tax growth for FY 2023/24 was flat when compared to the prior fiscal year. Revenues are expected to grow modestly in future fiscal years, although the City is expecting a significant boost from the planned opening of a new Costco location in the spring of 2025.

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Brentwood City CouncilDecember 10, 2024

Brentwood City Council
December 10, 2024