Los Altos City Council
January 24, 2023

Approximately 150 households attended the meeting. The meeting agenda is outlined below:

1. Welcome & Introductions

2. Agenda & Logistics

3. Presentation on Site Analysis

4. Group Q&A

5. Overview & Opening of Breakout Rooms

6. Breakout Rooms Report Back

7. Closing and Next Steps

ATTENDANCE
Meeting participants: approximately 150 households
City Staff
● Laura Simpson – Interim Planning Director
● Sonia Lee – Public Information Officer
Consultant Team
● Lisa Wise Consulting, Inc. – David Bergman, Jennifer Murillo, Stefano Richichi, Olivia Salter
● Plan to Place – Dave Javid, Paul Kronser, Rachael Sharkland LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 1 Public Participation Summaries City of Los Altos | E-18 City of Los Altos | E-18 287
Agenda Item # 3.

WORKSHOP SUMMARY
Laura Simpson opened the meeting by welcoming attendees and introduced the team. Dave provided an agenda overview and conducted the demographic live poll. The following is a summary of the results from the demographic poll that was administered at the beginning of the meeting:

Demographic Live Poll (full results in the appendix)

1. What is your age?
○ 2% are 18 and under
○ 2% are 25-44
○ 52% are 45-65
○ 43% are 64-84
○ 2% are 85 and over

2. What is the primary language spoken in your house?
○ 97% speak English
○ 2% speak Cantonese
○ 2% speak Vietnamese

3. Which category best describes you?
○ 2% identify as American Indian/Alaska Native
○ 13% identify as Asian
○ 2% identify as Black or African American
○ 6% identify as Hispanic or LatinX
○ 71% identify as White
○ 6% Other

4. Where do you live? (select one)
○ 95% live in Los Altos
○ 3% live in Santa Clara County but not Los Altos
○ 2% live outside of Santa Clara County

5. Where do you work?
○ 29% work In Los Altos (including remote work)
○ 28% do not work Los Altos, but in Santa Clara
○ 6% work outside Santa Clara
○ 34% are retired
○ 2% do not work or are looking for work
○ 2% do not work and are not looking for work

6. If you work in Los Altos, how long is your commute?
○ 31% travel less than 20 minutes for work
○ 6% travel 20-30 minutes for work
○ 2% travel 40-50 minutes for work
○ 39% don’t work in Los Altos
○ 22% Other
LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 2 Public Participation Summaries City of Los Altos | E-19 City of Los Altos | E-19 288
Agenda Item # 3.

7. If you live in Los Altos, what is your current housing situation? ○ 97% own a home
○ 2% live with family/friends (don’t own or rent)
○ 2% don’t live in Los Altos

8. If you live in Los Altos, how long have you lived there? ○ 3% have lived in Los Altos for 3-5 years
○ 6% have lived in Los Altos for 6-10 years
○ 89% have lived in Los Altos for 10+ years
○ 2% don’t live in Los Altos

9. If you live in Los Altos, what kind of housing do you live in? ○ 88% live in a house
○ 9% live in a duplex/townhome/condo
○ 2% don’t live in Los Altos
○ 2% other

10. Have you participated in other Los Altos Housing Element events? ● 54% no
● 46% yes
After the poll closed, Jennifer Murillo from Lisa Wise Consulting, Inc. (LWC) gave a presentation that included a brief overview of the Housing Element, but focused primarily on the approach for the Sites Inventory Analysis. The Housing Element Overview included background, purpose, update process, and state requirements.

Jennifer then provided an explanation of the key screening criteria and assumptions that informed the sites analysis and policy considerations for providing additional housing capacity.

To guide feedback, the policy considerations were divided into five topics including the Commercial Thoroughfare zone (El Camino Real), the Public and Community Facilities Zone (focused on the properties of Los Altos United Methodist Church, Los Altos Christian Schools, and vacant property at Grant Road and Fremont Avenue), the Office Administrative Zone (primarily along San Antonio Road east of downtown and on Los Altos Oaks), the Commercial Retail Sales Zone (in the downtown area focused on Main Street and State Street), and the area of the Loyola Corners Specific Plan. Each of the areas was illustrated with a map(s) and included a question that was used as a discussion prompt for the breakout rooms (see below).

This was followed by an opportunity for any clarifying questions from the meeting participants through the virtual chat feature. To find a list of all the comments and questions asked, please see the Appendix.

Following the presentation portion of the workshop, Dave gave an overview of the small group breakout room logistics and then opened the rooms which participants were randomly assigned.

A facilitator and note taker from the project team were assigned to each breakout room. The project website (https://www.losaltoshousing.org/) currently houses an online feedback form to allow members of the community that did not participate at the workshop an opportunity to provide input. These online responses will be collated and added to this summary.

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Agenda Item # 3.

MAIN ROOM CHAT SUMMARY
The summary below captures takeaways from the main room chat that was open to participants before breaking into small groups. These comments and questions do not pertain to specific discussion prompts, but have been organized into broad themes. In response to the participants’ request for a complete record of the meeting chat, a transcript of all of the comments and questions from the main room that were fielded during the upfront presentation can be found in the Appendix.

Main Takeaways
Request for more information and/or clarification regarding site inventory ● Request for explanation of and interest in contesting RHNA numbers. ● Request for a spreadsheet of the site inventory with addresses and capacity. o Are the identified sites sufficient to meet the RHNA target? ● Request for clarification on assumptions that went into site selection and feasibility of sites being developed.
o Is there any evidence that the churches are interested in developing housing? o Is Los Altos going to invoke eminent domain in order to force current businesses out?
● Request for what constitutes "substantial evidence" that the city must provide to show that non-vacant sites can be developed.
● Desire to understand how property owners and their willingness to sell impacts the site analysis.
● Confirm viability of developing housing on parking plazas. ● Confirm feasibility of alternatives to increasing parking (underground parking, shuttles to reduce VMT).

Suggestions for future workshops
● Desire to see more diverse participants, especially those that will be most affected by the proposed changed zoning (e.g. below 45, renters, young families, and professionals). ● Request for more time in the breakout rooms with fewer questions so discussion can be more in depth.
● Clearer maps so feedback can be more directed.
o Do you realize that we can't read these zoning maps (street names illegible)? Request for more information about BMR housing
● Clarification request for BMR requirements as they impact density bonuses and additional height.
o When you remove caps, and assuming BMR units are included in a project, can developers add another story for a total of 4 stories?
● Concern that BMR housing is concentrated in one location (South Los Altos).

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Agenda Item # 3.
● More information about specified rental/purchase rates for very-low income units. ● Request for identification of developers that will build BMR units. o Please provide specifics of how 501 very-low income units will be built? What are the specified rental/purchase rates? Which identified developers might build these and where?
Advocacy for housing if coupled with other amenities, services, and infrastructure ● More information on how urban transit infrastructure, amenities, and schools will be part of the planning process.
o Where will the new schools for new residents be located? ● Support for mixed-use buildings with commercial/ retail on the ground floor and housing above.
o Can we convert commercial zones to mixed use?
● Support for the City to establish large-scale upzones, rather than parcel by parcel.

Opposition to increased density
● Opposition to additional height generally and its impact on the neighborhood.

Commercial Thoroughfare (CT) District
● Support for increasing density in the downtown area.

Community Facilities Zone (Including Grant Road and Fremont Avenue) ● Grant and Fremont, northeast corner, would be better served by an open space and a bike lane for bicyclists to get them away from the commuter Fremont/Grant road traffic. ● Concern that developing housing at Grant and Fremont will change neighborhood character, will cause more traffic congestion and is isolated from services. ○ Why are we considering the Grant/Fremont and the Magdalena churches, and other areas, which will just contribute to more traffic and disrupt existing neighborhoods?
Loyola Corner Specific Plan (LCSP)
● Concern for developing LCSP because height and traffic may disrupt existing character. o How will parking be accommodated at LCSP?
● Support for more housing and services at LCSP.

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Agenda Item # 3.

SMALL GROUP DISCUSSION SUMMARY
The remainder of the meeting was devoted to gathering input from meeting participants through facilitated small group discussions. Feedback was recorded in four breakout rooms on a virtual whiteboard (see snapshot below) in response to the discussion prompts below. The summary below provides a high-level overview of themes that emerged from the small group discussions.

The numbers in parentheses indicate the number of breakout rooms in which the referenced comment was expressed. A full transcript of all of the char comments from each breakout room can be found in the Appendix.

Example of notes taken on virtual whiteboard during the small group discussion LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 6 Public Participation Summaries City of Los Altos | E-23 City of Los Altos | E-23 292
Agenda Item # 3.

Small Group Discussion Prompts

1. Allow higher density in the Commercial Thoroughfare (CT) District?

2. Allow residential uses on certain Public and Community Facilities (PCF) zoned parcels?

3. Allow residential uses in the Office Administrative (OA) District?

4. Establish a minimum density and allow 3 stories (or 100% residential uses) in the Commercial Retail Sales (CRS) District?

5. Remove the density cap and allow 3 stories (or 100% residential uses) in the Loyola Corners Specific Plan (LCSP)?
Main Takeaways
General (not in response to a specific question)
● More information on the implications of CA state laws (SB9, SSB10, SB35) on Los Altos, and how Los Altos will meet the state's requirements for substantive evidence that a parcel can be redeveloped. (4)
● Request for more specific and clear information on site inventory (e.g. addresses with proposed capacity). (3)
● Clarification request for BMR requirements. (4)
● Clarification needed for this discussion to differentiate between height, stories, density, and what ‘multifamily’ means and looks like. (4)
● Concern that high density will negatively impact current residents’ neighborhood aesthetics and real estate investment. (4)
● Concern that BMR housing will be concentrated in certain areas creating "ghettos,” aesthetically poor housing, and/or places that reflect isolation of persons that live in affordable housing. (3)
● Concentrate density where it's already commercially viable, eg. large parcels, or parcels that can be aggregated and are near transit and amenities. (4) ● Up zoning in the El Camino area to increase density is appropriate. (4) ● How is school capacity being taken into account? (3)
Allow Higher Density in the Commercial Thoroughfare (CT) District? ● Density and height should be concentrated along El Camino commercial thoroughfare because it is near transit and services. (4)
● Request to include buffer zoning to mitigate impact of height on El Camino on surrounding SFH neighborhoods. (2)
● Desire to see a traffic study on El Camino that accommodates increased density. (3) ● Request for more information about density bonus as it relates to BMR housing and which developers are interested in building units with presumably these deed-restricted rents. (2)
● Request to include open space near San Antonio in the site inventory. (1) LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 7 Public Participation Summaries City of Los Altos | E-24 City of Los Altos | E-24 293
Agenda Item # 3.

Allow residential uses on certain Public and Community Facilities (PCF) zoned parcels? ● More information about the Fremont and Grant parcel needed to understand what appropriate density would be, whether services could be added to this area, and how traffic would be accommodated. (4)
● No high density on Fremont, may negatively impact existing neighborhood ambiance and kids walk and bike along the street to and from schools. (2) ● Request for more information about how housing would be built on church property and why these sites were selected, and whether loss of churches might have a negative impact on the community. (2)
● Concern that these properties are isolated and not near amenities. (2) ● Support for more housing along Grant and Fremont. (2) Allow residential uses in the office administrative (OA) district? ● Rancho is a historic structure and serves as a central location for various amenities, don’t remove this resource. (3)
● South San Antonio road has small lots that directly impact single family homes, don't increase density here. (2)
● San Antonio is a good place for housing because it is near transit; commercial on the ground floor and housing above would be appropriate. (3) Establish a minimum density and allow 3 stories (or 100% residential uses) in the Commercial Retail Sales (CRS) District?
● Support increased density here as long as parking is considered. (1) ● Consider building on top of existing parking garages or on parking plazas. (3) ● Clarification on the height implication of 3 stories (34 or 38’, does this include retail etc.). (1)
● Request for a more creative and inclusive approach to neighborhood planning with multiple kinds of housing. (1)
● Concern about design standards and setbacks. (1)
Remove the density cap and allow 3 stories (or 100% residential used) in the Loyola Corners Specific Plan (LCSP)?
● Consider a tiered approach to mitigate height. (2)
● We have already spent time on this specific plan as a community, why is this being re-opened? (2)
● Yes, to 3 stories here. (3)
● No to 3 stories here, concern about impact on aesthetics and privacy. (3) ● In favor of building on parking lots. (1)
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Agenda Item # 3.
● No high density on Main or First, unless design standards include setbacks to improve the pedestrian experience. (1)
● Concern about intersection and bridge over expressway. (1) LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 9 Public Participation Summaries City of Los Altos | E-26 City of Los Altos | E-26 295
Agenda Item # 3.

Appendix

DEMOGRAPHIC LIVE POLL RESULTS

1. What is your age?
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Agenda Item # 3.

2. What is the primary language spoken in your house (Choose all that apply)?

3. Which category best describes you?
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Agenda Item # 3.

4. Where do you live?

5. Where do you work?
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Agenda Item # 3.

6. If you work in Los Altos, how long is your commute?

7. If you live in Los Altos, what is your current housing situation? LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 13 Public Participation Summaries City of Los Altos | E-30 City of Los Altos | E-30 299
Agenda Item # 3.

8. If you live in Los Altos, how long have you lived there?

9. If you live in Los Altos, what kind of housing do you live in? LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 14 Public Participation Summaries City of Los Altos | E-31 City of Los Altos | E-31 300
Agenda Item # 3.

10. Have you participated in other Los Altos Housing Element events?
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Agenda Item # 3.

TRANSCRIPT OF ALL CHAT COMMENTS

MAIN ROOM CHAT COMMENTS
Can we see the images of attendees while we wait?
What state law is mandating this need for more housing? Why is English “as expected” the primary language spoken in the homes of L A? Will the answers to these questions be summarized and distributed? The most important thing we need tonight is a spreadsheet of the site inventory, even if preliminary, so your community can do independent analysis of whether or not you are meeting the HCD criteria to create a feasible HE. We don't want the state to reject our HE, even at the 1st pass.

I agree with Jeanine. We need to know the preliminary sites, and how many homes are expected out of each site
Outreach has been pretty broad… glad we want beyond the TC! The slides identify sites and a range of numbers of possible new housing (of each type), but there is no table that summarizes the totals. I think we’ll first see that with the Draft Housing Element.

If we can’t get a legal, feasible housing element, we will be in for lots of legal fees and perhaps lose any local control
How are you talking about numbers, then, if you don’t know what they are? How do you know the preliminary sites are enough?
Since we have no vacant sites of material import, we need to see upzoning everywhere.

Upzoning does not mean automatic development. But it does show the state commitment to housing opportunity.

Presentation states " Over 80% of RHNA estimated to be accommodated through existing zoning and ADU's and pipeline projects" Would like to see how consultants arrived to this conclusion/Spreadsheet and Assumptions made (i.e City spoke with property owners that are willing to sell or develop their parcel). Thanks.

Curtis, agree, but we need that spreadsheet sooner.

Who set our RHNA and the percentages, and is there any ability to change it? MJ Loptin: Every city that has tried to lower their RHNA has failed.

Right, Mircea. If the city thinks 80% of RHNA will be accommodated by existing zoning, then why are we not developing at 80% of our required rate, even for market rate housing LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 16 Public Participation Summaries City of Los Altos | E-33 City of Los Altos | E-33 302
Agenda Item # 3.

What participant Mircea seeks, as do many of us, is the "substantive evidence" the city must provide to show that that non-vacant sites can actually be developed. because Anne, it is developers who develop properties, not the city “Substantial evidence"
That 80% number is absurd unless eminent domain will be applied to all strip malls and churches in town.

MJ: Los Altos and many cities appealed to change their allocation and lost that ask. These are our final numbers.

But the exact percentages for the different RHNA categories can be adjusted? Some of those would be quite challenging here
MJ Lopatin: This is all challenging, but together we can rise to the challenge and house the people who work here.

I believe even parking plazas re also considered non-vacant.

MJ: no adjustment of that allocation either, and I agree.

Jon, it is the city, not the developers, who zones at a density that is feasible, or does not. If the city doesn’t zone for enough housing, then the site will not be developed. See the Village Court for an example.

These RHNA numbers need to be challenged. No scientific formula but everyone just seems to accept them. ABAG has a committee made up of local officials, staff and stakeholders.

Stakeholders meaning people who have a vested interest. the parking lots are considered non vacant because cars really do park there and merchants downtown depend upon people coming downtown
There are 4 maps that show where the city is planning, at this point, to locate the RHNA + buffer units. North, North Central, South Central and South. The types of units by income are color coded. Why are the vast majority of low income RHNA units assigned to South Central and South Los Altos - both sections considered South Los Altos. Low Income and Moderate Income housing units should be distributed equally throughout Los Altos. https://static1.squarespace.com/static/612fc0231c3b5b71bdaee404/t/621953fd6ed5e56712590 95b/1645827079609/LWC_LosAltos_HEU_Wkshp2_PPT_Final_022522_w_maps.pdf The maps are in this link.

As far as I reviewed on what was presented to date is a wishful thinking by hired consultants.

Presentation with no backing/data. How would you know how many ADU's will build through 2031? Last 5 years average?/Extrapolation etc. How about how many condominiums projects LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 17 Public Participation Summaries City of Los Altos | E-34 City of Los Altos | E-34 303
Agenda Item # 3.
are upcoming besides what is in a current building-construction phase? Have they talked to property owners and have commitments otherwise is all a big "estimate". challenging the numbers at this point, based on the bundle of legal precedent that such efforts are guaranteed failures, is a fool's follow. Let's spend our calories solving the housing problem.

We don't need lawsuits and loss of local control where developers come in with license to build what they want. Just look at what happened to us with 40Main! it is a little disappointing that we do not have more 45 and younger and less than 10 participating in this workshop
we have few under 45 participating because most homeowners are older. and young folks, by and large, don't see the value in participating in this process. my kids don't see how they will be able to buy a house anywhere, much less los altos
I agree Freddie
Potential site 61 has significant environmental issues that I think should disqualify it as a potential site at this time. The site has an identified riparian stream flowing into a stormwater detention basin with two dams that prevent flooding of downstream residential areas. It appears that this has not been properly evaluated. This is known as 2100 Woods Lane Seas of asphalt for parking are a blight, climate-negative, and a waste of space. Put the parking in puzzlers or underground. Make Los Altos more walkable and use shuttles.

I agree that the Woods Lane site is not a good one for housing.

Agree with Freddie
Instead the city could use the large property it owns at the corner of Green Oak Lane and Bendigo Dr
and Jeanine, who will pay for the parking that needs to be built-will you, will the city, cost is 100K per underground space
Agree that we have WAY too much parking downtown and need more green space and mixed use housing, including on existing parcels zoned for commercial only (along San Antonio near 1st)
The people who use the parking should pay for it, that is a great way to disincentivize way too much parking downtown? yes, right now, but when things go back to a more normal pace, I don't think so
Not everyone can ride a bike!
Elaine-they do-its called parking permits
Jon, we have to move our city forward.

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Agenda Item # 3.

The city needs to either commit to putting housing on the parking plazas (and this would be legally binding) or remove them from the sites inventory Jeanine-that is rhetoric and nonsense. I am asking pragmatic questions and you talk moving forward???
Jeanine - perhaps not everyone agrees about what constitutes “forward.” The statement that CT/El Camino Real will accommodate properties on El Camino is not correct. The properties identified on the virtual map are not happening/development potential.

Those owners are not selling. PAMF specifically.

We need to see the formula that says we need this much housing based people working remotely. We don't have the schools to accommodate this housing. we are not the first city to do this. If other small-medium cities can do it, why can't we? Do the Magdalena churches plan on leaving?
we are going to ban religious services so we can get more housing :) because it’s not what we want for our city?
I hope not
Is there any evidence that either the Methodist church or Bridges have any interest at all in developing housing? I hope they are interested, but when Los Altos Affordable Housing Alliance inquired, they said they were not
Moving forward means preparing our city for the next generations. We 60plus year olds need to think about how damaging to our community it is to be missing two generations behind us in terms of our demographics. The city will lose its vibrancy, its sustainability, and it self-sufficiency for lack of revenue.

Where do you expect cars to be parked near the proposed Loyola Corners development? There is no public transit, so at least 2 cars will be needed for each unit. Also, is Los Altos going to invoke eminent domain in order to force current businesses out? I was wondering that as well. That's our church
Exactly. City needs to confirm they spoke with the churches.

No eminent domain. That is not how it works.

The housing has to go somewhere. Most likely large undeveloped properties. Wherever there are large spans of asphalt that is underutilized.

Millenials are moving into my neighborhood. They want bigger houses and yards.

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Agenda Item # 3.

Downtown needs to be preserved.

It is paramount the city provide "substantive evidence" of feasibility: talk to parcel owners, offer incentives, look at existing leases, etc.as
Millennials who are moving into your neighborhood want what is in your neighborhood, obviously, but that doesn’t mean they represent what other millennials want Jeanine-people do move here, typically they have lots more money than the poor folks who currently live here, myself included. los altos was not my first house purchase-it took decades for me to afford this town. there is no free lunch
Sandy: The parking can go underground and many of the housing units will be studios and one bedrooms so one slab of asphalt per unit is sufficient
Are we considering a lot of this development in the downtown triangle? Increasing density there, where it is close to downtown services and transit - and not backing up against residences - seems a win for the town meeting our RHNA numbers and the downtown businesses having more customers. Why are we considering the Grant/Fremont and the Magdalena churches, and other areas, which will just contribute to more traffic and disrupt existing neighborhoods?
In the CRS zone, the property next door to our Legion Hall, 347 1st Street is planning a 5 story building. (corner of 1st and Whitney). I don't understand how the housing element suggests 3 stories. Is this a reduction from current zoning?
El Rancho Shopping Center needs to be preserve
Or turned into BCS new campus
State and Main are the heart of what is Los Altos the village. Any intensified unit capacity should be at the perimeter not in the core
Loyola Corners near my house is severely in need of a makeover.

When you talk about removing caps, then developers get to add another story beyond the 3 stories if they have enough BMR without any approval, so are you including those 4 stories in your estimates, or just the new 3 story limit you are proposing Loyola Corners, near my house, needs to be updated, and three or four stories with first floor retail would be great
The Rancho shopping center and downtown will remain, just small parts of them will have people living there.

Where will the new schools for all of these new residents be located? LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 20 Public Participation Summaries City of Los Altos | E-37 City of Los Altos | E-37 306
Agenda Item # 3.

Jon, yes, the very wealthy millennials can move here. But we need a middle class and we need to house workers. It's the right thing to do by climate action. We need to think of urban planning and a wholistic view. Not to protect fiefdoms.

So as she is saying it’s capacity not proposed developments The "candidate parcels" are not correct. Those owners cannot sell they are locked in with the buildings to the left and right on a parking sharing agreement. Not happening.

Yes!!! Anne. What a great development that would be
Thank you pbressack. I should have stated that I meant the downtown periphery, not the triangle.

The city is not going to develop the parking plazas and should not pretend they will No height increase please, stop trying to destroy Los Alto’s charm, these tall building are ruining it and making it look like a ugly mess.

I do not agree that 4 stories in Loyola Corners would be good. We just went through all this for the Special plan in 2017. Our current 2 stories will automatically become 3 stories with BMRs These maps are not that helpful. Just feedback, not meant to be critical.

We have to put the housing somewhere. We need to allow for 1958 homes. Where do you propose they go?
Another tactic that needs to change: these patchwork upzones are counterproductive. The city must establish large-scale upzones. For example, make the San Antonio proposed area a large mixed use zone, not parcel by parcel. All of downtown should be zoned for mixed use.

Three stories is not what most people want in Loyola corners. We are not Palo Alto.

Agree Jeanine
Calling this ‘conservative’ is, well, something
What happens to the stores like Luckys that are developed? Do we order from Amazon for groceries?
From Pat: Do you realize that we can't tell much of anything from those zoning maps? We can't see what's there now, can't see the street names. Meaningless -- and yet you want feedback. well those who live off of San Antonio respectfully disagree-it is our backyard and sideyard. if you want more housing, put it in your backyard, not mine.

Potential for 2100 Woods Lane must address ongoing violation of environmental regulations, and threats to neighborhoods because of flood control basin located there.

We just keep the village characteristics in Los Altos. That’s why we chose to purchase a house LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 21 Public Participation Summaries City of Los Altos | E-38 City of Los Altos | E-38 307
Agenda Item # 3.
and live here. We have been living here over 28 years
All of our grocery stores should be on first floors with housing above. Imagine how wonderful that'd be. Community, no driving, instant customer bases. the current proposal for 2100 Woods Lane (it’s up on the city website) is laughable and will never, ever be approved by the city
Figures
Agree Jeanine.

Happy Mardi Gras everyone!
Why are we focusing only on existing residential zones? Why not convert commercial zones to mixed use?
I would like to understand the specifics on how 501 very-low income units will be built. What are the specified rental/purchase rates for very-low income units? Which identified developers might build these and where?
There was talk of converting OA to residential, which we should definitely do We just respect the current real estate price fir our current residents. It’s not fair to build condo units to bring down our real estate prices.

When I bought my home here in 1989, the city looked quite different. So many of your homes weren't here. Your homes in which many of you live were the result of larger lot buys and subdivisions. I hold no ill will against all the beneficiaries of this increased density. Virtually EVERY single house in Los Altos is the result of subdivision.

Yes, thank you Jill, for asking that.
and your point Jeanine is that we should look like San Francisco, the Bronx or Mumbai? wow, Jon,
The point is that subdividing lots is our heritage
A little hyperbole, for sure, but things must change.

Wow? What a stretch. How is sub-diving lots a heritage? Maybe when parcels were huge it made sense to sub-divide but now we are down to a 1/4 acre. Anything smaller is like SF.

It'd be nice if more people can share feedback. This was billed as a community feedback workshop. I worry that it's unwise to take 1-2 inputs on a topic & run w/that as though it reflects a broad base of input or consensus of opinion. Perhaps the breakouts need a little more time & fewer questions so we can discuss them in more depth.

Can we get the complete Chats for all the Breakout Rooms? LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 22 Public Participation Summaries City of Los Altos | E-39 City of Los Altos | E-39 308
Agenda Item # 3.

Loyola Corner there many single dwelling houses and this is not something that we approve of any 3 story building.

Thank you Stefano for your excellent moderation.

Loyola Corners would be great with retail businesses on the first floor, housing on 2 stories above, and a park-like area between the new development and the residential area.

Yes, Joe!
We used to have a limit on single family housing stories--depending on the character of the community. If no other 2 story houses in area, you could not develop a 2 story house there.

How things have changed!
Love the forward looking ideas Joe!
Joe-to do so requires a mass that doesn't work for the neighborhood and is underparked. it was proposed several y ears ago
No 3 storeys in Loyola corner pls. We live on Miramonte Ave. Parking and privacy are concerns. Your consideration will be greatly appreciated One speaker wasn't sure Loyola Corners had residential units. It indeed does have lots of residential units. As previously mentioned by sev'l participants, it is an area busy w/pedestrian, bike, & auto traffic. Parking is already challenging there. Raising the height limit is not appropriate given the negative impacts it would have to the existing neighborhoods. single story R! overlays still exist, Carol. But the irony is that many owners who moved in after the overlay was instituted don't like the restriction.
@Jon I respectfully disagree. Those buildings should be condemned and replaced. Lots of buffer area available in the back parking lot.

Most that live in Loyola Corners do not want anything over 30 ft.

We want to see the “uncharted Chat”. Please provide it in its raw form. Thanks Joe-look at the proposal that was made and figure out how to address the legitimate issues, which were non trivial
@Nancy the housing has to go somewhere. Where do you propose? I just met someone this week who lives in Loyola Corners and wants to build R-3 where their house is now.
minimum parcel size can be reduced, R-3 can be allowed everywhere. construction doesn't happen overnight, and this is how you get "gentle density" @Joe, I would be happy to give you my choices. Fell free to contact me.

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Agenda Item # 3.

Grant and Fremont, northeast corner, would be better served by a park, dog park, and transition for bicyclists to get them away from the commuter Fremont/Grant road traffic. It ties into that recently improved Fremont Avenue with bike lane and beautiful trees.

Forgot to ask if there are any school sties on the list? We might be able to add in parking lots @nancy you should put them here so the public can se your ideas. Why withhold? I live near Loyola Corners and go there frequently. Would love to have more options for shopping
I wonder if all of the toxic waste from the gas station in that area was removed.

It'd be nice if more people can share feedback. This was billed as a community feedback workshop. I worry that it's unwise to take 1-2 inputs on a topic & run w/that as though it reflects a broad base of input or consensus of opinion. Perhaps the breakouts need a little more time & fewer questions so we can discuss them in more depth. Folks need to see whose raising their hand & trying to share in feedback. Please don't screen that off in future mtgs. we can see who raises their hands.

I'd be interesting to hear from young people who don't own yet.

Thank you City Staff: Laura and Sonia; Thank you Lisa Wise Consulting and Thank you Plan-to-Place.

I think the city has a responsibility to proactively reach out to those who will be most affected by the proposed changed zoning. they should have a say as well @Elizabeth M: the breakouts where good, but a bit scripted. Not clear they addressed what people were most concerned about.

Of course! I'm in favor of flag lots and two story townhomes that match the home heights and more.

There is great interest from the two younger generations and from workers in rental solutions.

There should be an in person community workshops where we use scaled lego blocks to place housing on large map tables. Not joking.

Yes, thank you for this session and the quality. Important work.

I'm in my early 30s and an fortunate enough to own, but all my friends who don't yet are moving away.
great interest from younger generation and workers, but the solution should not be at the expense of disadvantaging those who live here
we need these people to live here.

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Agenda Item # 3.

BREAKOUT ROOM CHAT COMMENTS
ROOM 1 CHAT COMMENTS
I agree with both Abby and Elizabeth that height on El Camino, if too high, will block light and definitely need a buffer zone to the nearby single story houses.

I heard, secondhand, that Biden said the country needs 3.8 million new homes. CA is demanding 3.5 million new homes. So, CA requirements seem way out of line if these figures are true.

The Fremont and Grant parcel should not have high density development. It would be completely out of character with that whole area, and we need more parks Grant fremont parcel—how many units and where would they park? That is such a busy corner with lots of bikes and pedestrians and we just redid Fremont there.

Having a lot of residents going in and out at Grant and Fremont would be very problematic Good point MJ. I agree with both of your points about not having high density & the need for more parks. Additionally, due to the adjacent residential areas height increases would be problematic to the established neighborhoods there. It is a very busy part of town in terms of pedestrian, bikes, & auto use.

From Pat: Do people understand that no one would force the churches to build houses on their property? It would just change the zoning and IF a church wanted to build housing, it could.

From Pat: 12 units on 1/2 acre? Would it be six stories tall? Have you actually seen this corner? (reference to Grant and Fremont)
There are so many kids walking and biking to and from schools there, along Grant and Fremont, it would be very dangerous
are we going to cover the South Area? Specific 2100 Woods Lane? From Pat: In order to meet the RHNA numbers, the charm and character of every city in CA is going to change. Check out SB9 and SSB10 and SB35 and all the other laws coming from Sacramento.

I think this area would be a good place for more development, since everyone loves to be near downtown, so a higher development here would be good. Not tall but more than single family.

I would like to point out that Rancho already is a two story building, but it is such a good design, that it is not obvious. This is not just a “strip Mall” or the site of a grocery store. There are dozens of businesses and services, some of which are essential, that are all located in one LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 25 Public Participation Summaries City of Los Altos | E-42 City of Los Altos | E-42 311
Agenda Item # 3.
place. It is a central location that is used by thousands of people on both sides of the expressway. It serves as a community center that is used by residents of all ages, including the school age children who often congregate their after school. Many of my neighbors walk and/or bike to Rancho. We live about a mile away, and my husband bikes there every day. Sometimes he walks, if we are having the car repaired by Jerry, who is an excellent mechanic at the Rancho service station. He can drop off the car, walk home—then walk back when the car is ready. Everyone I know uses Rancho extensively, both for essential and non-essential purposes.

From pat: You're not controlling the conversation, Jen. You're letting people ramble. And it's not really clear exactly what you want. Are you asking if this is a good location? Are you asking how high buildings should be? Or what density? From pat: Just asking for "reactions" lets people ramble.

We are very concerned about setbacks, which make huge difference when buildings start to get higher. And if 3 stories is the new limit, as others have said, the developers will get to build 4 by including a BMR or two.

From Pat: Re Loyola Corners. We already have a 3-story building (with CA Density Bonus) in play. Yes, I would change the density to allow more housing.

Did I miss the part on wood’s lane?
Loyola Corner there many single dwelling houses and this is not something that we approve of any 3 story building.

ROOM 2 CHAT COMMENTS
Agreed with Roberta. LWC should disclose excel sheets and shapefiles to get better community input on the site inventory.

I support all the proposals for higher density.

I’m in favor of higher density
of course you do salim, because you don't personally get disadvantaged by a big building in your backyard.

This area of El Camino is already more built up, so the cost of replacement is high and therefore redevelopment is unlikely. It's great to zone for higher density, but doing that in larger areas with less already built will be more effective.

I actually support it, too, for many reasons. We have tiny cottages in our neighborhood that are wonderful, but couldn’t even be replaced at the same density if they needed to be rebuilt. Our LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 26 Public Participation Summaries City of Los Altos | E-43 City of Los Altos | E-43 312
Agenda Item # 3.
zoning is unreasonably inflexible and doesn’t even reflect actuality. there is an amazing willingness to destroy the backyard and neighborhood of others. just because you don't live in the ct zone doesn't give you license to advocate for bulldozing neighborhoods and replacing those single family homes with tall multifamily buildings Agree that more development should take place along El Camino rather than taking away what open areas we have.

Why aren't you looking at more church parking lots?
Alice Shyu: 1) Questions - parking and traffic will be more congested. Any solution? 2) real estate prices - will high density condos bring down our current residents’ real estate investment?
3) sharing. (Less than half acre lot. 0.476 acre). Our own house remodeling. We need to bring down our front entrance design to blend into our neighborhood landscaping. Please don’t have double standard and bring in high density condos in very residential area. Thank you for listening.

Corner of Grant and Fremont used to be a gas station. How high will the building be? Fremont Avenue was gridlocked pre COVID times--where will extra cars go ? I agree with Cindy P.

Has the city considered capping building heights to 2 story on Main St. or possibly protecting that small street as a historic district. The rest of downtown can go 4+ stories.

South San Antonio Rd is a bad place to target for housing. It already has parking problems. It abuts single l family homes and no land buffer is proposed.

South San Antonio road has lots that aren't deep and directly impact on single family backyards and side yards. the oa zone should not allow housing. keep the downtown, downtown.

The general plan already permits residential uses in OA San Antonio as a transit route is another great reason to put housing there.

Where on Fremont ave is there OA?
It's worth reminding that if planning doesn't plan for the requisite homes, state law will bypass local planning entirely.
san Antonio isn't a transit route. there is one bus that has infrequent service. Jill, suggest you get your facts right
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Agenda Item # 3.
viable ideas-housing in the parking plazas as long as the parking gets replaced viable ideas-redevelop homestead plaza
I am well aware of that Jon, but it will change. Your tone is inappropriate and rude It’d be great if we knew how all of these numbers were calculated.

Why Homestead Plaza? There is little parking there as is. What happens to the stores there? I agree Salim. Why these particular numbers? The State has taken too much control over local zoning laws. ^^
Why doesn’t the city protect the old, potentially historic buildings on Main St? well there seem to be a willingness to get rid of retail and services, so that is a big site. I think where we are heading is insane. it is furthermore insane since we have to meet numbers without the inevitable density bonuses that always occur When my husband lived in Switzerland there was a butcher shop a block away in the middle of his neighborhood. It was wonderful.

The state is taking it away a little tiny bit at a time because municipalities aren't allowing houses to get built
the debate isn't about multifamily housing-its is about 50 and 60 foot buildings, which is the inevitable result of allowing housing in most of these area I'm in favor of multi-story high residential on top of the City parking lots, so they are more interior, behind the storefronts. However, I'm against high density along Main or First because the city allows building next to sidewalk because of mixed use, and density bonus. It destroys the pedestrian level view when you allow buildings right up to the sidewalk even if they throw in a few BMR.

And even the kindergartners walk alone to school. They closed the downtown Friday to sunday night to cars and made it pedestrian and bus only. Such a nice, safe, vibrant way of life.

Cindy, I agree with the unpleasant walk along 1st. The city needs to implement a sidewalk policy with a tree strip and landscape buffer.

No overdevelopment of Loyola Corners.

I am against destroying the things that make our downtown along main and state streets charming and inviting. 50 and 60 foot buildings fit that categoyr No overdevelopment of Loyola Corners.

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Agenda Item # 3.

Parking along curb side is dangerous especially at night. Not enough parking. Miramonte Ave could not be expanded.
the consensus is everyone (myself included) wants develop to occur somewhere, as long as it isn't in their neighborhood.
3 storeys buildings? 3rd floor residents can see through the windows in their neighborhood. We need privacy. Thank you for your consideration
the old math was 3 stories was 30 feet, now 3 stories can be 45 feet before bonuses and waivers which bring total height to 65 feet. we are being hoodwinked I agree with Debbie Skelton. I'm particularly concerned about the intersection and bridge over the expressway. Lots of traffic/ped/bike conflicts now. why not blanket R-3?
you can build one house on an r-3 if you want
no actually you cannot
Citizens don't really have control over the State law
Loyola Corner there many single dwelling houses and this is not something that we approve of any 3 story building.

ROOM 3 CHAT COMMENTS
The el Camino corridor is much more able to support high density buildings. Still lacks adequate public transport, etc. Much better than cramming ADU’s in residential neighborhoods.

There are a number of city-owned lots that are not on the current site list. Just in my neighborhood, there is the bordered up coffee stop in Loyola Corners, the vacant lot on the corner of Green Oak Lane and Bendigo Dr, and the vacant lot at the SW Corner of Grant and Fremont (kitty corner from the site that is on the site map.

Since these are all owned by the city right now, there is no reason these should not be used for housing now.

Across the street Density is 60-90DU/AC Los Altos is at 38 DU/AC Using the 30% of income for Very Low Income level, that would mean: $2K/month rent for a family of 4
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Agenda Item # 3.

Agree with Freddie, have to choose carefully on el Camino to consider existing single family homes
Whoops: sent too fast. Family of 4 would require $2K rents/month. For family of 2, it would be $1.7K monthly rents. I would like to understand which identified developer will build these units with presumably these deed-restricted rents?
I don’t think that Rancho Shopping Center will be developed for anything because I don’t think the owner wants to build, but it’s one parcel, and if a developer (market or affordable) built it, they’d build the entire lot
Barry, the developer who builds those units is any developer in Los Altos, because they are required to build 15% or more affordable units in every project Has anyone done a traffic study on El Camino? I feel like it is going to be gridlock when all the proposed housing units are finished. We all want the high density housing away from us but it was already gridlock at 5:00 PM before Covid. I agree with you Cindy. That open space is lovely.

More housing (especially within walking distance of services) lowers traffic because people don’t need to drive to work, grocery, etc
Curious about SB9 and if homeowners/developers might build 4 units on a SF lot. How do we forecast the new housing unit potential here?
Those churches are across the street from a grocery store! Rancho is right there.

Thanks Anne, where is it mandated that a developer must build 15% very low income units? Didn’t know this existed.

I agree with David. Is there an overall urban planning document to put the proposed sites in context?
Downtown is the place that needs “vibrancy” in order to support shops and restaurants.

Consider putting 4 story housing units all over downtown and build 3 or more parking garages at least two on what was the parking plazas
Barry, it’s called “inclusionary zoning” and most cities around here that are not named Los Altos Hills have it. The actual details vary, but nobody’s building a 20 unit project in Los Altos, Mountain View or Palo Alto without building some affordable homes Developers must provide 15% affordable units on each condominium project and pay $55-60K/unit on park fees traffic impact fees plus school fees EST $2-3/SF per SF of building or something like that
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Agenda Item # 3.

I agree, no zoning on OA
3 stories, but what max height?
35 ft max in downtown
3 stories 35 ft
Mircea, can you build 3 stories with lower one retail in 35 feet? Barely? Not when you add in density bonuses
11 ft commercial /1st 8ft-1-2-3 so with commercial is hard. they will need about 38 ft to make it decent.
@Mircea: is that 15% referring to SB35 projects, or all projects. Does Los Altos require this 15% for all projects?
15% BMR on all developments - Outside any SB35
@Anne, @Mircea, how many very low income units have been built in Los Altos in the past few years?
Mircea: plus elevator shaft,... 😬 I seen too many Developments which tend to end up as 10’ per floor plus 10-15’ extra
Besides parking, how is school capacity planning being taking into account? They allow elevator shaft additional height up to 8ft on top of the roof @Mircea. Thanks. But presumably all developments then utilize SB35 in order to gain projects benefits? Are there non-SB35 projects that provide 15%BMR units? On a 3 story building the elevator profile is not that bad I agree with KirkM. Thanks
Rancho Shopping Center needs preservation as it is historically significant and serves a large spectrum of the community 3 miles from the downtown. A large repertoire of needs are met for the community surrounding it. It is “vibrant” and is “utilized” extensively. Many citizens walk and bike to it. Take a look at the myriad of services to get an idea of what I am saying. The redwood tree is huge, as are the white oaks. It is park-like and unique.

All non-SB35 projects must provide 15% BMR
For question 5, yes absolutely allow 3 stories at Loyola Corners. That property is underutilized.

I agree that Rancho is special and those services essential. Is there a way to build mixed-use on that site with new housing and still keep those services? I like to hope so.

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Agenda Item # 3.

I’m in favor of putting housing on parking plazas, but we shouldn’t put the parking plazas on the housing element site inventory unless the city has a plan, with deadlines and commitments, and puts that plan in the housing element where it will be legally binding No to three stories.

No, 2 stories only in Loyola corners
@tom Why 2 stories vs. 3 in Loyola Corners? Imagine 3 stories at Loyola Corners with a park like area between the development and the R1 housing
Agree on Loyola corners, way under utilized and old, hasn’t changed in 25 years @Mircea, the Los Altos number is 501 for very low income units. Are you or some other developer likely to build these?
The problem is if we allow the more then two stories, the developers can ask for bonuses and it will end up a huge buildings with no set backs. Two story duplexes would be fine Many of the San Antonio offices have homes right behind the site. Local residents are concerned about parking and traffic in Hillview neighborhood.

Loyola Corners is not a commercial zone, it’s commercial neighborhood, for good reason. Look at specific plan - it was created with a great deal of thought and consideration. It’s not downtown
@Anne, are you asking for legally binding commitments for all of the housing element? I’m saying that if the city tries to put parking plazas on the site inventory, but does not make a commitment in the housing element to actually develop the parcels, then the state will reject the housing element and make the city take those sites off the housing element. Like they did with Santa Monica
You’ve got to consider the creek and impact on building right on the creek for the old bank site.

Plus people have single family homes on the other side of creek, so a large building would have BIG impact
If the city puts programs to develop the parking plazas in the housing element, it IS legally binding
@Mircea, I am interpreting your comments correctly. There is no 15% requirement unless developers use SB35, and that provides developers the ability to exceed local zoning requirements.

ROOM 4 CHAT COMMENTS
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Agenda Item # 3.
"I think the diocese of San Jose is looking at what they can do with their lands. Saint Nicholas and Saint Williams and Saint Simons in LA"
"Up zoning in this area is completely appropriate, El Camino commercial thoroughfare should be dense especially since it is near transit and services Not sure they are looking at all those sites but those are the sites
Opposition to density and increase to height limits but not in opposition to more housing on the whole
"The church on Grant Rd. between Fremont and Foothill might be one to consider as well." "To Teresa’s point can we caveat the heights to be max after density bonus just to clarify for people"
What is the highest building on El Camino?
"I'm going to guess 5 stories"
"And Mountain View is at 5 including rooftop I think"
"Oh except the one large apartment and office across from Jordan" "How short are we from the mandated number?" 500 short
"Thanks. What is the downside of showing properties like B of A as potential sites even if B of A says it is not interested?"
"The downside is that the state rejects the siting...bad." "Thanks. What happens if the state rejects the siting? What makes this bad?" "Upzoning along El Camino thoroughfare is a good idea, the residents will be near stores, services and public transportation, and close to downtown Mountain View, will be quite convenient location for residents (and probably also for business)" "In order for the Housing Element to be accepted by HCD, the sites listed as able to be developed must be feasible. There must be evidence that the parcel can be developed." "Get your friends to look at it" I’m guessing the church isn’t planning on closing. Just making room for housing
"Michael, back to the topic of what happens when the state rejects our HE: at first, warnings, then fines, then bigger fines, then we lose our local control (they give developers the permission to come in and build without our input), and then the state comes in and, at the extreme, can put our city into receivership to tell us where we will build housing and what density it will be.They could even put halts on requests for private owners to revise their property pending the consideration of whether or not housing can be put there. It is imperative we make a feasible Housing Element and keep things under our control." LOS ALTOS HOUSING ELEMENT UPDATE | COMMUNITY WORKSHOP #2 SUMMARY - 33 Public Participation Summaries City of Los Altos | E-50 City of Los Altos | E-50 319
Agenda Item # 3.
"Michael, we also lose state funding...oh he's dealing with this" "All cities adopt housing elements. We want to be a city that has one" "Are you familiar with the situation at 40 Main?"
"Schools are not full
"our schools are not full"
"when you create demand for schools, schools happen. same goes for transit." "The schools come at great cost to our community"
"Why aren't apartments family oriented? Lots of families live in apartments" "Agree merchants benefit it we add housing downtown"
"I agree with Julie! Our privilege has allowed many of us to characterize family life unreasonably elite. I admit sometimes I even have to check myself on this. The merchants (existing and future) in South los altos would be thrilled with more customers.

Safeway/Andronicos is barely hanging on.

Fremont/Grant would be a nice site for a 4- or 6 plex. The conifers along the periphery would make it invisible to adjacent neighbors.

I do not think that the Fremont/Grant site is perfect, but at this stage in the housing crisis, I don't think we have the luxury of finding perfect. There is a bus route that goes right past that corner, and it would be easy to have an entrance on Fremont and an exit on Grant. A vacant lot with a few townhomes houses people
I like thinking about organic growth in ADUs and sprinkling a 4 or 6-plex where we can. It’s more work to plan the sites throughout the city but also more welcoming than placing it all at El Camino
The presentation shows something like 30 to 40 units per acre so that 0.5 acre site would likely have 15 to 20 units as I read the documents.

Agree with Julie as well. A 4 or 6-plex is much more palatable to areas with family homes than a bulky apartment building
Most of the El Camino residential units are condos, not rentals. Only Colonnade is rentals and is owned by Stanford.

I also like taking 1-acre lots in the R1 area (upzone to R2) and creating cute little 2/1 bungalow courts like in the old days. These are great for starter families. I'd rather have a bungalow court next to me than a 2 story mcmansion (no disrespect to my neighbors where I live!).

Ooh sounds nice. I’ll move in Jeanine. Would be nice to have places to downsize for this largely over 60 crowd
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Agenda Item # 3.

Great suggestion by Jeanine Valadez, creative and very appealing The orchard site is historical and has limitations because it was donated to city (or sold?) with limitations that it must remain an orchard.

I love walking through the Dos Pueblos neighborhood. Small lots, gorgeous cute new and old small homes, great community.
the orchard at the civic center has an historic designation The proposal it so build 30 to 40 units per acre not low density like "2/1 bungalow courts like in the old days"
Great suggestion, Jeanine. Could be great for older folks who are downsizing (count me in when I’m 75!)
we should protect the orchard; I believe in locational history. I have a vestigial appie in my backyard.

Generally, I hope the new housing re-uses parking lots, instead cutting down trees. The corner at Grant/Fremont seems to be a nice piece of land for trees to make the area green Agree with dongzheng on making best use of parking lots and NOT giving up greenspace wherever we can avoid it.

Support upzoning to allow mixed use everywhere.

Absolutely upzone OA to mixed use.

Absolutely support the upzoning of parcels in the ‘administrative’ area (the purple area) which you just mentioned.

Yes, OA should allow residential
In fact those offices on Altos Oaks used to be housing in the old days.

Check out Midpen housing at 2510 Soquel Ave. in Santa Cruz. It is very low profile but has a good number of units.

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Agenda Item # 3.

LOS ALTOS HOUSING ELEMENT UPDATE | 3/22/22 CITY COUNCIL SUMMARY - 1 City Council Meeting
Format: Zoom Virtual Meeting | March 22, 2022, 7:00 pm
The purpose of the City Council’s March 22, 2022 Housing Element Update agenda item was to provide a brief overview of the Housing Element Update process, describe the sites inventory analysis methodology and preliminary findings, and to receive direction from the City Council regarding potential zoning modification options to address an anticipated shortfall in Regional Housing Needs Allocation (RHNA) capacity.

The City Council Meeting was held via Zoom at 7:00 pm and was facilitated by City staff and the consultant team (Lisa Wise Consulting, Inc.). The meeting agenda, staff report, and PowerPoint presentation were made available online prior to the meeting. Approximately 40 members of the public attended the meeting. The presentation for this agenda item is outlined below:

1. Housing Element Overview

2. Sites Inventory Analysis

3. Community Feedback

4. Next Steps

ATTENDANCE
Meeting participants: approximately 40 attendees
City Staff
● Gabriel Engeland – City Manager
● Jon Maginot – Assistant City Manager
● Laura Simpson – Interim Planning Director
Consultant Team
● Lisa Wise Consulting, Inc. – David Bergman, Jennifer Murillo, Stefano Richichi

MEETING SUMMARY
Laura Simpson opened the meeting and introduced the team. Jennifer Murillo from Lisa Wise Consulting, Inc. gave a presentation that included a brief overview of the Housing Element and process, but focused primarily on approach, methodology, and assumptions for the sites inventory analysis. Jennifer then described various policy considerations for preliminary zoning modification options. The following questions were posed in the presentation:

1. Allow higher density in the Commercial Thoroughfare (CT) District?

2. Allow residential on certain Public and Community Facilities (PCF)-Zoned Parcels?

3. Allow residential in the Office Administrative (OA) District?

4. Establish a minimum density and allow 3 stories (or 100% residential uses) in the Commercial Retail Sales (CRS) District?

5. Remove the density cap and allow 3 stories (or 100% residential uses) in the Loyola Corners Specific Plan?
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Agenda Item # 3.

LOS ALTOS HOUSING ELEMENT UPDATE | 3/22/22 CITY COUNCIL SUMMARY - 2 Preliminary sites maps were presented, noting that community feedback has been and continues to be received and will inform revisions to the preliminary sites maps.

Following the presentation, City Councilmembers asked questions and requested additional information regarding the methodology used for identification of preliminary sites. No further direction was provided.

Comments from members of the public are summarized below:
• If density isn’t modified in the R-1 districts, changes will have to made in other zoning districts.
• Being identified as a preliminary site does not mean that an existing building on the property will be torn down or that the existing use will be removed. • Requests for additional information and a detailed list of preliminary sites. • Concern that Rancho Shopping Center, Lucky’s, State Street Market, City parking spaces, Packard Foundation garden, and St. Nicholas’s parking lot are not going to redevelop as housing.
• The OA District has narrow lots and shouldn’t be rezoned to allow residential. • Concern about allowing residential in the OA District and insufficient parking. • The outreach strategy should include banners, sandwich boards, etc. • Support for the need to upzone. The Housing Element should be a plan to build more housing, not just a plan to please HCD. We’re not telling businesses to go away; office and retail can coexist with housing.
• Some zoning modifications should be implemented. This could be through wholesale changes to zoning or overlays to promote redevelopment of certain properties. • Concern about limited access and safety/evacuation issues regarding the 2100 Woods Lane site.

Public Participation Summaries City of Los Altos | E-54 City of Los Altos | E-54 323
Agenda Item # 3.

LOS ALTOS HOUSING ELEMENT UPDATE | 7/7/22 PLANNING COMMISSION SUMMARY - 1 Planning Commission Meeting
Format: Zoom Virtual Meeting | July 7, 2022, 7:00 pm
The purpose of the Planning Commission’s July 7, 2022, Housing Element Update agenda item was to present the Public Review Draft Housing Element Update and provide an opportunity for Planning Commission discussion and public comments.

The Planning Commission Meeting was held via Zoom at 7:00 pm and was facilitated by City staff and the consultant team (Lisa Wise Consulting, Inc.). The meeting agenda and staff report were made available online prior to the meeting, and the PowerPoint presentation was made available online the following day. Approximately 30 members of the public attended the meeting. The presentation for this agenda item is outlined below:

1. Housing Element Overview and Outreach

2. Sites Inventory

3. Goals, Policies, and Programs

4. Process & Next Steps

5. Questions and Comments

ATTENDANCE
Meeting participants: approximately 40 attendees
City Staff
• Nick Zornes – Development Services Director
• Jolie Houston – City Attorney
Consultant Team
• Lisa Wise Consulting, Inc. – David Bergman, Stefano Richichi • Plan to Place – Rachael Sharkland

MEETING SUMMARY
Chair Shelley Doran opened the meeting and Director Nick Zornes introduced the team and goals of the meeting. David Bergman and Stefano Richichi from Lisa Wise Consulting, Inc. gave a presentation that included a brief overview of the Housing Element, but focused primarily on community outreach, the methodology and results of the sites inventory analysis (including a discussion of the sites inventory maps), and the various goals and programs proposed in the draft Housing Element. The team emphasized that community feedback has been and continues to be solicited and received and will continue to inform the Housing Element Update.

Following the presentation, Planning Commissioners asked questions regarding the rezoning process in relation to the site inventory analysis, the proposed sites inventory buffer, the potential impact to commercial areas, the role of SB 9, next steps in the process, and whether property owner consent is needed for inclusion of a property as an identified site. A Planning Commissioner expressed support for a downtown parking garage in the CRS District.

Public Participation Summaries City of Los Altos | E-55 324
Agenda Item # 3.

LOS ALTOS HOUSING ELEMENT UPDATE | 7/7/22 PLANNING COMMISSION SUMMARY - 2 Comments from members of the public are summarized below:
• Support for the proposed draft Housing Element.
• Belief that the Housing Element fulfills the City’s RHNA obligation. • Concern about allowing residential use in the OA District, citing narrow configuration of lots, potential height increases, and insufficient parking. • Concern on the impact of new residential developments to existing residents and commercial centers.
• Support for townhomes.
• Support for Programs 1.B and 1-H, to allow more housing along El Camino Real and to develop housing on City-owned parking lots in Downtown, respectively. • Suggestion for the OA District to include a housing overlay to more strictly regulate development standards.
• Concern that the maps incorrectly show the Village Court area identified to be rezoned, and a request to specifically analyze Rilma Lane.
• Support for further analysis to find parking solutions downtown. • Requests for additional information on how the sites were chosen. • Requests for the outreach strategy to engage a greater number of residents. • Support for inclusion of additional church parking lots in the sites inventory. • Requests that community outreach further include low-income workers and support these community members, such as by increasing forms of public transportation.

Public Participation Summaries City of Los Altos | E-56 325
Agenda Item # 3.

LOS ALTOS HOUSING ELEMENT UPDATE | 7/12/22 CITY COUNCIL SUMMARY - 1 City Council Meeting
Format: Zoom Virtual Meeting | July 12, 2022 at 7:00 pm The purpose of the City Council’s July 12, 2022 Housing Element Update agenda item was to discuss the Public Review Draft Housing Element Update, provide an opportunity for City Council and public comments, and obtain City Council direction to submit the Draft Housing Element Update to the California Department of Housing and Community Development (HCD) following the completion of the 30-day public comment period and 10 business days to consider and incorporate public comments.

The City Council Meeting was held via Zoom at 7:00 pm and was facilitated by City staff and the consultant team (Lisa Wise Consulting, Inc.). The meeting agenda and staff report were made available online prior to the meeting, and the PowerPoint presentation was made available online the following day. Approximately 35 members of the public attended the meeting. The presentation for this agenda item is outlined below:

1. Housing Element Overview and Outreach

2. Sites Inventory

3. Goals, Policies, and Programs

4. Process & Next Steps

5. Questions and Comments

ATTENDANCE
Meeting participants: approximately 50 attendees
City Staff
• Nick Zornes – Development Services Director
• Gabriel Engeland – City Manager
• Jolie Houston – City Attorney
Consultant Team
• Lisa Wise Consulting, Inc. – David Bergman, Jennifer Murillo, Stefano Richichi

MEETING SUMMARY
Director Nick Zornes introduced Jennifer Murillo, David Bergman, and Stefano Richichi from Lisa Wise Consulting, Inc. (LWC) to present the Housing Element draft update. LWC gave a presentation that included a brief overview of the Housing Element, but focused primarily on community outreach, the methodology and results of the sites inventory analysis (including a discussion of the sites inventory maps), and the various goals and programs proposed in the Draft Housing Element.

Public Participation Summaries City of Los Altos | E-57 326
Agenda Item # 3.

LOS ALTOS HOUSING ELEMENT UPDATE | 7/12/22 CITY COUNCIL SUMMARY - 2 Following the presentation, the public provided comments and City Councilmembers presented their questions and comments.

Comments from members of the public are summarized below:
• Modify Program 3.A (Downtown parking plan and update parking requirements) to require a secure bike room and bike valet for new multi-family developments. • Support for the proposed Draft Housing Element.
• Opposition to Planning Commission being delegated authority to approve housing projects since the Planning Commission is not elected.
• Support for Planning Commission authority to approve housing projects based on expertise; otherwise Planning Commission’s authority is undercut and application processing delays result.
• Support for low-income housing to be distributed throughout the city. • Proposal that height be limited to 30 feet in the OA District. • Proposal for low-income housing at vacant lots near to public transportation. • Support for affordable housing development because it will add income and ethnic diversity to the city.
• Support for the proposed Draft Housing Element, and understanding that HCD’s certification is required for a legally compliant Housing Element. • Comment that the City should do more to address underutilized homes; opposition to short-term rentals.
• Support for strict regulation of housing to promote orderly development; comment that this has made Los Altos is a high resource area.
• Concern that the Draft Housing Element does not address the needs of the community or safeguard the existing quality of life.
• Both opposition to and support for the City’s current story pole requirement. • Disappointment in the grocery stores being included as sites.

Comments from the City Councilmembers are summarized below:
• Although there is more work to be done, the Draft Housing Element is excellent and tailored to the needs of the community.
• The Design Review Commission is a constraint.
• The Housing Element should mention housing consultants generally (i.e., not Alta Housing specifically).
• Reporting on page C-24 does not accurately reflect net new units built; this should be corrected.
• Other technical errors in the Draft Housing Element should be corrected.

Public Participation Summaries City of Los Altos | E-58 327
Agenda Item # 3.

LOS ALTOS HOUSING ELEMENT UPDATE | 7/12/22 CITY COUNCIL SUMMARY - 3 The City Council voted unanimously (5-0) to make factual corrections and minor edits to the Draft Housing Element and submit the revised Draft Housing Element to HCD.

Public Participation Summaries City of Los Altos | E-59 328
Agenda Item # 3.

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Affirmatively Furthering Fair Housing City of Los Altos | F-1 Appendix F: Affirmatively Furthering
Fair Housing (AFFH)
Contents
Appendix F: Affirmatively Furthering Fair Housing (AFFH).......................... 1 Section F.1 Introduction............................................................................................................ 2 F.1.1 Notes on Figures and Analysis.............................................................................. 2 Section F.2 Assessment of Fair Housing.................................................................................. 3 F.2.1 History of Fair Housing Issues............................................................................... 3 F.2.2 Fair Housing Outreach and Enforcement.............................................................. 4 F.2.3 Integration and Segregation .................................................................................. 6 F.2.4 Racially or Ethnically Concentrated Areas of Poverty .........................................18 F.2.5 Access to Opportunity .........................................................................................22 F.2.6 Disproportionate Housing Needs.........................................................................31 F.2.7 Other Relevant Factors .......................................................................................42 F.2.8 Summary of Fair Housing Issues ........................................................................43 Section F.3 Sites Inventory.....................................................................................................45 F.3.1 Sub-Area Analysis...............................................................................................45 F.3.2 Potential Effects on Patterns of Segregation.......................................................51 F.3.3 Potential Effects on Access to Opportunity .........................................................54 Section F.4 Contributing Factors and Meaningful Actions......................................................57 330
Agenda Item # 3.

F-2 | City of Los Altos Affirmatively Furthering Fair Housing Section F.1 Introduction
Assembly Bill 686, signed in 2018, establishes a statewide framework to affirmatively further fair housing (AFFH) with the goal of achieving better economic and health outcomes for all Californians through equitable housing policies. AB 686 defined “affirmatively furthering fair housing” to mean “taking meaningful actions, in addition to combat discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity” for persons of color, persons with disabilities, and other protected classes. AB 686 requires cities and counties to take deliberate actions to foster inclusive communities, advance fair and equal housing choice, and address racial and economic disparities through local policies and programs. Housing elements are now required to address the following five components:
• Inclusive and Equitable Outreach: A summary of fair housing outreach and capacity that includes all economic segments of the community.
• Assessment of Fair Housing: An assessment of fair housing issues, including integration and segregation patterns, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs for all identified populations.
• Analysis of Sites Inventory: An evaluation of whether the Housing Element’s sites inventory improves or exacerbates conditions for fair housing. • Identification of Contributing Factors: The identification and prioritization of contributing factors related to fair housing issue.
• Priorities, Goals, and Actions to AFFH: The identification of fair housing goals and actions that directly address the contributing factors outlined above. The housing element should include metrics and milestones for evaluating progress and fair housing results.

This section documents four of the five components of the AFFH components. The summary of AFFH-related outreach is included in Housing Element Section I.E (Summary of Public Participation).

F.1.1 Notes on Figures and Analysis
This Appendix contains geospatial data downloaded from HCD’s AFFH Data and Mapping Resources Hub. Additional analysis is sourced from the Census American Community Survey and HCD’s pre-certified data, where appropriate.
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Affirmatively Furthering Fair Housing City of Los Altos | F-3 Section F.2 Assessment of Fair Housing
F.2.1 History of Fair Housing Issues
Los Altos occupies land that was inhabited by the indigenous Ohlone people. According to the City of Los Altos Historic Context statement1
, evidence of their presence on the land has been
confirmed by the discovery of human and cultural remains within the City Limits. This population began to be displaced from the territory that includes Los Altos with the establishment of La Purisima Conception Rancho and Rancho San Antonio during the period of Spanish and Mexican occupation. The Los Altos region began to attract significant Euro-American settlement after California’s entry into the United Sates in 1850. This population growth was accelerated by the arrival of the railroad into the area in 1864. The region remained primarily agricultural with large land holdings owned by Euro-American landowners. The first urban lots were subdivided in 1906 by the Altos Land Company on what is currently referred to as the Downtown triangle. The remainder of the area of Los Altos was largely agricultural. The large agricultural holdings were generally owned by Euro-American families who would employ ethnic Japanese and Chinese persons as domestic labor.
2 Census provides insight into the racial and ethnic composition of the Los Altos area in the early 20th century. The census did not record any Black or African Americans in Los Altos until 1920 when three individuals were recorded as being present. The largest non-white population in the area were ethnic Japanese. By 1920 this population comprised 22 percent of the foreign-born population in Los Altos. Much of this population was engaged in agricultural production on leased land due to explicitly racist land ownership laws, ethnic Japanese farmers were not able to own land outright.
3 Discrimination against ethnic Asians was a feature of the land tenure system that effected Los Altos’ development. The Chinese exclusion act of 1882, which was not repealed until 1943, formalized discrimination against ethnic Chinse persons and limited their ability to own land in Los Altos; and the internment of Japanese Americans during the Second World War removed many ethnic Japanese families from Los Altos.
4 The practice of formal exclusion based on race and ethnicity effected the ability of a non-white population to own property in Los Altos until these legal exclusions were invalidated by the federal Fair Housing Act (also known as Title VIII of the Civil Rights Act of 1968). At the State level, the California Fair Employment and Housing Act also provided legal remedies to address housing discrimination on the basis of race and ethnicity. Despite these legal protections, the legacy of 1 City of Los Altos, Historic Resources Inventory, Section II Los Altos: Historic Context April 2011 2 Ibid p.19 3 Ibid p. 20 4 Los Altos Historical Society Finding Asian America in the Museum April 15, 2021 332
Agenda Item # 3.

F-4 | City of Los Altos Affirmatively Furthering Fair Housing racialized control of land in Los Altos can be observed in contemporary patterns of residential composition within Los Altos and the greater region.

F.2.2 Fair Housing Outreach and Enforcement
Fair housing complaints can be an indicator of housing discrimination in contemporary Los Altos.

Fair housing issues can arise through discrimination against an individual based on disability, race, national origin, familial status, disability, religion, or sex when renting or selling a dwelling unit.

The U.S. Department of Housing and Urban Development’s (HUD) Office of Fair Housing and Equal Opportunity (FHEO) is the federal agency responsible for eliminating housing discrimination, promote economic opportunity, and achieving diverse, inclusive communities. FHEO services and activities include investigating fair housing complaints, conducting compliance reviews, ensuring civil rights in HUD programs, and managing fair housing grants.

The Office of Supportive Housing provides fair housing services to urban and unincorporated areas of Santa Clara County. They provide information and services on tenants’ rights, fair housing, and local tenant protections. The non-profit organization Project Sentinel provides fair housing services to residents of Santa Clara County that include assisting individuals with housing discrimination complaints. From 2004 to 2021, there were nine fair housing cases in Los Altos.

These cases related to protected categories as follows: familial status (five cases, 56 percent), disability (two cases, 22 percent), and race (two cases, 22 percent). All cases were counseled and closed; no cases are currently pending in Los Altos. 5 Comments during the Housing Element Update process identified a need for providing more information about available services to residents, particularly seniors. Housing Element programs are included to promote awareness of available resources, information, and services related to fair housing and affordable housing generally.

The City does not have any pending lawsuits, enforcement actions, judgements, settlements, or findings related to fair housing and civil rights. The City does not currently have any local fair housing laws or programs to specifically address fair housing issues.

The city complies with State and federal housing laws as follows:
• Fair Housing Act; Title VI of the Civil Rights Act of 1964 – the City complies by ensuring its actions related to housing are not discriminatory through City protocols, decision-making procedures, and adhering to non-discrimination requirements of federal funding programs.
5 Elizabeth Sanchez, Supervising Fair Housing Coordinator, Project Sentinel, May 2022. 333
Agenda Item # 3.

Affirmatively Furthering Fair Housing City of Los Altos | F-5 • Rehabilitation Act of 1973 – see Fair Housing Act; also, the City complies through its accessibility protocols, administered and enforced by the City’s ADA/504 Coordinator and Building Official.
• American Disabilities Act – the City complies with the ADA through building permit review and issuance and as described in Appendix C (Housing Constraints, Section C.2.2, Housing for Persons with Disabilities).
• California Fair Employment and Housing Act (FEHA) and FEHA Regulations – the City complies with FEHA and its regulations through established City protocols for hiring and decision making, mandatory trainings for City staff, and legal counsel and advisement. • Government Code Section 65008 – the City ensures that the City’s actions are not discriminatory through training programs conducted by the City’s Human Resources Department. Programs are included in this Housing Element to facilitate housing for all households, including protected classes (e.g., programs regarding residential care facilities, reasonable accommodation, and emergency shelters). • Government Code Section 8899.50 – Appendix F of this Housing Element documents compliance with Affirmatively Furthering Fair Housing requirements. • Government Code Section 11135 et. seq. – the City complies with anti-discrimination requirements through the City’s Human Resources programs and the City’s procurement protocols.
• Density Bonus Law (Government Code Section 65915) – the City must update its density bonus provisions in compliance with the Density Bonus Law as described in Appendix C (Housing Constraints) and Program 3.E.
• Housing Accountability Act (Government Code Section 65589.5) – the City has documented compliance with the HAA as described in Appendix C (Housing Constraints). • No-Net-Loss Law (Government Code Section 65863) – the City has documented compliance with sufficient capacity for RHNA and will ensure compliance with no-net-loss via programs (Program 1.J).
• Least Cost Zoning Law (Government Code Section 65913.1) – the City includes programs in this Housing Element to ensure that sufficient land is zoned with appropriate standards to accommodate its RHNA.
• Excessive subdivision standards (Government Code Section 65913.2) – the City’s subdivision standards are typical or not excessive in compliance with the Government Code (see Appendix C, Section C.2.5).
• Limits on growth control (Government Code Section 65302.8) – the City complies as it has no growth control measures.
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F-6 | City of Los Altos Affirmatively Furthering Fair Housing • Housing Element Law (Government Code Section 65583) – this Housing Element documents compliance with Housing Element Law.

F.2.3 Integration and Segregation
This section analyzes integration and segregation, including patterns and trends, related to people with protected characteristics.

Race and Ethnicity
According to the American Community Survey (ACS), Los Altos had a lower proportion of racial and ethnic groups than Santa Clara County in 2019. Approximately 38.4 percent of the Los Altos population belonged to a racial minority group compared to 55.5 percent of the county population at that time. The largest minority group was Asian in both the city and county at 31.4 percent and

36.5 percent, respectively. Residents identifying as Hispanic or Latino was 4.4 percent in the city and 25.5 percent in the county.

Figure F-1 provides historical non-white population percentages by block group based on 2010 ACS data. At this time, the northern portion of the city had the lowest non-white percentages with less than 20 percent in two northern block groups. Most of the city had non-white percentages in the 21 to 40 percent range. In 2010, two block groups in the southern portion of the city had nonwhite percentages above 40 percent.

Figure F-2 shows the non-white population percentage by census block group for 2018. Most block groups in the city had a non-white population in the range of 21 to 40 percent at that time.

Ten block groups had non-white population percentages in the next highest category with most of them located in the southern portion of the city.

The city had higher percentages of non-white population overall in 2018 as compared to 2010 according to ACS data. The 2018 ACS data showed an increase in non-white population percentage in most block groups in the city compared to 2010 data. The southern portion of the city bordered by Interstate 280 contained the highest non-white percentages in both periods. Nonwhite population percentages are generally higher outside of the city to the north, east, and south. 335
Agenda Item # 3.

Affirmatively Furthering Fair Housing City of Los Altos | F-7 Figure F-1: Non-White Population (2010)
Source: HCD AFFH Spatial Data
336
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F-8 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-2: Non-White Population (2018)
Source: HCD AFFH Spatial Data
Disability
People are considered to have a disability if they have one or more of the following: hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self-care difficulty, and independent living difficulty.

Figure F-3 presents the ACS 2010 to 2014 data for percentage of population with a disability and Figure F-4 shows the ACS 2015 to 2019 data for percentage of population with a disability.

According to 2015 to 2019 ACS data, approximately 5.7 percent of Los Altos residents have a disability, compared to 8.0 percent countywide (Table F-1). All census tracts in Los Altos consisted of less than 10 percent of residents experiencing disability during both five-year time periods except for the southernmost tract that extends beyond City limits. Surrounding areas exhibit similar disability levels in the 2019 data with most adjacent census tracts in the same quintile range as the city. Two tracts adjacent to the north and southwest of the city have disability population estimates in the next highest range of 10 to 20 percent (Figure F-4). 337
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Affirmatively Furthering Fair Housing City of Los Altos | F-9 Although Los Altos has a lower proportion of population with a disability compared to the county, comments during the Housing Element update process reflected the desire to prioritize housing that serves young families, low-income households, seniors, and those with disabilities.

Table F-1: Percentage of Population with a Disability (2019) Los Altos Santa Clara County
Number Percentage Percentage
1,739 5.7% 8.0%
Source: ACS 2019 5-Year Estimates, Table S1810
Figure F-3: Percent of Population with a Disability (2010 - 2014) Source: HCD AFFH Spatial Data
338
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F-10 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-4: Percent of Population with a Disability (2015 - 2019) Source: HCD AFFH Spatial Data
In Los Altos, there are differences in disability status by race and ethnicity. White individuals are far more likely to have disabilities than Black individuals, with the incidence of disabilities among the larger Asian and Hispanic populations in between. It is likely that the very small number of Black residents and disparities in age (which is highly correlated with disability status) between White, Asian, and Hispanic residents explains much of the disparity. The median age of Hispanic residents of Los Altos is 36.6, while the median age for White residents of Los Altos is 50.1. 339
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Affirmatively Furthering Fair Housing City of Los Altos | F-11 Table F-2: Disability Status by Race and Ethnicity (2019) Race or Ethnicity Total Population Number with a
Disability % with a Disability
White Alone, Not Hispanic or Latino 17,543 1,284 7.3%
Black or African American Alone 129 0 0.0%
Asian Alone 9,562 342 3.6%
Hispanic or Latino (of any race) 1,341 60 4.5%
Source: Lawyer’s Committee, Baird + Driskell Community Planning; ACS 2019 5-Year Estimates Input during the Housing Element process included that housing stock should accommodate the ageing population and prioritize people with disabilities, as well as young families and low-income households.

Familial Status
Familial status protection covers households in which one or more minor children live with: a parent, a person who has legal custody (including guardianship) of a minor child or children, or the designee of a parent or legal custodian, with the written permission of the parent or legal custodian. Examples of familial status discrimination include refusal to rent to families with children, eviction of families once a child joins, and confinement of families to specific floors of a building.

According to 2019 ACS data, 39.4 percent of all households in Los Altos have one or more children under the age of 18, which is about a two percent increase from the 2010 estimate (37.3 percent). The city’s share of all households with children is higher than that of the county overall at 36.3 percent and the Bay Area region at 32 percent. It is also higher than the surrounding neighboring jurisdictions of Palo Alto (34.0 percent), Mountain View (27.4 percent), and Sunnyvale (33.9 percent). The rate for married couple households with their own children in the city is 34.8 percent compared to 27.0 percent in the county and 22.3 percent in the Bay Area according to ACS 2019 data (Table F-3).

Figure F-5 shows the percentages of children in married couple households in Los Altos by quintile. The percentage of children living in married couple households is uniformly high across the city, exceeding 80 percent in all tracts. Most census tracts adjacent to these areas also have high levels at over 80 percent. As noted in Section F.2.2, most fair housing complaints in Los Altos have been related to familial status. Furthermore, comments during the Housing Element process identified that the availability of housing for young families is a critical issue.

Single-parent households are also a fair housing protected class. Los Altos has 2.2 percent of households consisting of single-parent households according to the ACS data. Female-headed households are more likely to experience greater housing affordability challenges due to typically lower household incomes compared to two-parent households. ACS data indicates that 1.9 340
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F-12 | City of Los Altos Affirmatively Furthering Fair Housing percent of households in Los Altos are single female-headed households with children compared to 3.3 percent in the county and 3.7 percent across the Bay Area region (Table F-4).

ACS five-year data for 2015 to 2019 is presented by quintile for the percentages of children in single female-headed households in Los Altos is shown in Figure F-6. This map shows that all census tracts within the city have percentages of children in single female-headed households below 20 percent. Every adjacent tract to the city contains similar levels of these types of households, with the exception of one tract to the north of the city. This tract contains percentages of children in single female-headed households in the next highest quartile at approximately 24.8 percent.

Table F-3: Percentage of Married-Couple Households with Children (2019) Los Altos Santa Clara County Bay Area

34.8% 27.0% 22.3%
Source: ACS 2019 5-Year Estimates, Table DP02
Table F-4: Percentage of Female-Headed Households with Children, No Spouse/Partner Present (2019) Los Altos Santa Clara County Bay Area

1.9% 3.3% 3.7%
Source: ACS 2019 5-Year Estimates, Table DP02
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Affirmatively Furthering Fair Housing City of Los Altos | F-13 Figure F-5: Children in Married-Couple Households (2015 - 2019) Source: HCD AFFH Spatial Data
342
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F-14 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-6: Children in Female-Headed Households with No Partner Present (2015-2019) Source: HCD AFFH Spatial Data
Income
According to the 2015 to 2019 ACS, the median household income in Los Altos was $235,278, which was more than Santa Clara County at $124,055 during the same period (Table F-5).

Figure F-7 displays the distribution of median household income by census tract in Los Altos for 2010 to 2014. Household income was approximately uniform across the city during that time period at $100,000 or above. Most tracts adjacent to the city exhibited similar incomes at that time.

Figure F-8 presents median household income by block group for 2015 to 2019. Household incomes in the city remained at similar levels compared to 2010 to 2014 data. Several block groups did not have household income data for that period, so tract level data was used instead as indicated in Figure F-8. Household income was lower in about half of the surrounding block groups outside city in the 2015 to 2019 ACS data compared to the previous period. 343
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Affirmatively Furthering Fair Housing City of Los Altos | F-15 Table F-5: Median Household Income (2019)
Los Altos Santa Clara County
$235,278 $124,055
Source: ACS 2019 5-Year Estimates, Table S1901
Figure F-7: Median Household Income (2010 - 2014)
Source: HCD AFFH Spatial Data
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F-16 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-8: Median Household Income (2015 - 2019)
Source: HCD AFFH Spatial Data
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Affirmatively Furthering Fair Housing City of Los Altos | F-17 Figure F-9: Low to Moderate Income Population (2015 - 2019) Source: HCD AFFH Spatial Data
Figure F-9 presents the distribution of LMI households in the city by quartile. The amount of LMI households is low across the city at less than 25 percent. Census tracts adjacent to the city to the north have much higher levels of LMI populations than the city. A tract to the southeast of the city contains a higher LMI population percentage. This follows the observed regional pattern of LMI household percentages generally increasing to the north.

Income can also be disaggregated by race and ethnicity to further understand local patterns of segregation and integration. The citywide poverty rate was 2.8 percent according to 2015 to 2019 ACS data, compared to 7.5% countywide. The rate by race/ethnic group in Los Altos is shown in Table F-6. Residents who identify as two or more races experience poverty at a higher rate than other racial or ethnic groups in the city at about 7.8 percent. The poverty rate for this group is notable because of the number of individuals and that they represented about 5.5 percent of the total population according to the 2019 ACS data. Black and American Indian residents also experience elevated poverty rates relative to their population share (also see Appendix A, Housing Needs Assessment, Section A.3.4, Residents Living Below the Poverty Level). 346
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F-18 | City of Los Altos Affirmatively Furthering Fair Housing Table F-6: Persons in Poverty by Race/Ethnicity (2019)
Number of
Persons
Poverty Rate by
Race/Ethnicity
% Of Total
Population
Below poverty level estimate 856 2.8% -
White alone 484 2.6% 61.6%
Black or African American alone 7 5.4% 0.5%
American Indian and Alaska Native alone 2 6.5% 0.1%
Asian alone 232 2.4% 31.4%
Native Hawaiian/Other Pacific Islander alone 0 - 0.0%
Some other race alone 2 0.7% 0.9%
Two or more races 129 7.8% 5.5%
Hispanic or Latino origin (of any race) 30 2.2% 4.4%
Source: ACS 2019 5-Year Estimates, Table S1701
Segregation Report
The AFFH Segregation Report for Los Altos has been prepared by the University of California Merced Urban Policy Lab in cooperation with the Association of Bay Area Governments and the Metropolitan Transportation Commission. The key findings from the report include the observations that both neighborhood racial segregation and income segregation in Los Altos declined since 2010. Another key finding states that “segregation between lower-income residents and residents who are not lower-income has decreased between 2010 and 2015”.

These findings are consistent with figures provided in this section, and the report is attached to this appendix.

F.2.4 Racially or Ethnically Concentrated Areas of Poverty Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) Racially or Ethnically Concentrated Areas of Poverty (R/ECAP) are areas that exhibit both high racial/ethnic concentrations and high poverty rates. HUD defines R/ECAPs as census tracts with a majority non-white population (50 percent or more) and a poverty rate that exceeds 40 percent or is three times the average poverty rate for the county, whichever is lower.

R/ECAPs may indicate the presence of disadvantaged households facing housing insecurity and need. They identify areas whose residents may have faced historical discrimination and who continue to experience economic hardship, furthering entrenched inequities in these communities.

According to Figure F-10, there are no R/ECAPs in Los Altos or in the surrounding area. 347
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Affirmatively Furthering Fair Housing City of Los Altos | F-19 Figure F-10: Racially/Ethnically Concentrated Areas of Poverty (2009-2013) Source: HCD AFFH Spatial Data
Racially or Ethnically Concentrated Areas of Affluence (RCAAs) Racially or Ethnically Concentrated Areas of Affluence (RCAAs) are neighborhoods in which there are both high concentrations of non-Hispanic White households and high household income rates.

Based on research from the University of Minnesota Humphrey School of Public Affairs, RCAAs are defined as census tracts where 80 percent or more of the population is white, and the median household income is $125,000 or greater (which is slightly more than double the national median household income in 2016).

However, HCD adjusted the RCAA methodology to track more closely with California’s higher levels of diversity by setting the white population threshold to 50 percent. According to 2010 data available from HCD and provided in Figure F-11, Los Altos had two white-majority census tracts in the Predominant category at about 52 percent each, with the remaining areas between 10 and 50 percent categorized as Sizeable white-majority gap. Those two white-majority tracts have household incomes greater than $125,000 and are therefore RCAAs by the HCD criteria. One of 348
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F-20 | City of Los Altos Affirmatively Furthering Fair Housing these RCAA tracts is situated between El Monte Avenue and Almond Avenue and the other RCAA tract is located in the northwestern portion of the city to the west of San Antonio Road.

Since release of the draft Housing Element in June 2022, HCD released new RCAA data that better reflects California’s relative diversity and regional conditions and is derived from ACS 2015 - 2019 data. The new data is shown in Figure F-12 for Santa Clara County and indicates that all of Los Altos is a RCAA except for a small portion in the south of the city (e.g., Foothill Crossing Shopping Center).

RCAAs within Santa Clara County are mostly concentrated in the western region of the county from the northwest portion to the southwest portion. Los Altos is situated within this regional grouping of RCAAs with Los Altos Hills and unincorporated areas to the west being all RCAAs.

Areas to the north, which include Palo Alto and northern portions of the county, are mostly RCAAs.

Neighboring areas to the east including Mountain View contain some RCAAs, while the cities of Sunnyvale and Cupertino to the east and southeast do not contain any RCAAs. This regional pattern indicates that the concentration of RCAAs decreases from west to east in the vicinity of Los Altos and across the county and suggests that Los Altos is less inclusive compared to the region.
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Affirmatively Furthering Fair Housing City of Los Altos | F-21 Figure F-11: White Majority Tracts (2010)
Source: HCD AFFH Spatial Data
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F-22 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-12: Santa Clara County RCAAs (2015-2019)
Source: HCD AFFH Spatial Data
F.2.5 Access to Opportunity
One important component of fair housing is a neighborhood’s access to opportunity, which correlates relative place-based characteristics of an area, such as education, employment, safety, and the environment, with critical life outcomes, such as health, wealth, and life expectancy.

Ensuring access to opportunity means both investing in existing low-income and underserved communities, as well as supporting residents’ mobility and access to ‘high resource’ neighborhoods.

In February 2017, the Department of Housing and Community Development (HCD) and the California Tax Credit Allocation Committee (TCAC) convened the California Fair Housing Task Force to provide research and evidence-based policy recommendations to further HCD’s fair housing goals of (1) avoiding further segregation and concentration of poverty and (2) 351
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Affirmatively Furthering Fair Housing City of Los Altos | F-23 encouraging access to opportunity through land use policy and affordable housing, program design, and implementation.

HCD and TCAC prepared opportunity maps to identify census tracts with the highest and lowest resources. High resource areas are areas with high index scores for a variety of opportunity indicators. Examples of indicators of high resources areas include high employment rates, low poverty rates, proximity to jobs, high educational proficiency, and limited exposure to environmental health hazards. High resources tracts are areas that offer low-income residents the best chance of a high quality of life, whether through economic advancement, high educational attainment, or clean environmental health. Census tracts in the city that are categorized as moderate resource areas have access to many of the same resources as the high resource areas but may have fewer job opportunities, lower performing schools, lower median home values, or other factors that lower their indexes across the various economic, educational, and environmental indicators.

Low resources areas are characterized as having fewer opportunities to employment and education, or a lower index for other economic, environmental, and educational indicators. These areas have greater quality of life needs and should be prioritized for future investment to improve opportunities for current and future residents.

The opportunity maps inform TCAC, which oversees the Low-Income Housing Tax Credit (LIHTC) Program, to distribute funding more equitably for affordable housing in areas with the highest opportunity. The analysis evaluates total access to opportunity (e.g., high, moderate, low), but also individually assesses opportunity access across more specific indicators, such as education, transportation, economic development, and environment.

TCAC Opportunity Areas – Composite Score
The 2022 TCAC Opportunity Areas Composite Score provides an aggregate index of three domains: economic, education, and environmental. Census tracts with higher composite scores indicate higher resource areas overall. As shown in Figure F-13, most tracts in Los Altos are in the highest resource category. The northeastern tract, bordered by El Camino Real, San Antonio Road, and Almond Avenue, is a high resource area. This tract scores relatively lower than other areas of Los Altos due to less positive education outcomes and more exposure to environmental hazards for residents in those areas as evidenced by lower education and environmental scores.

See below discussions on individual categories that comprise the composite score, including education and environmental conditions. These two characteristics result in a relatively lower Composite Score for this tract.

Areas outside of the city to the north have lower composite scores which reflects the regional trend of generally lower scores in the north and eastern portions of the county. Lower composite scores outside of the city to the north along El Camino Real are mostly the result of much lower environmental and educational ratings with a low economic rating further reducing the composite score to low resource in one tract. Two factors likely contributing to the lower environmental 352
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F-24 | City of Los Altos Affirmatively Furthering Fair Housing scores in this area are higher traffic volumes and higher concentrations of commercial and industrial land use.

Figure F-13: TCAC Opportunity Areas 2022 - Composite Score Source: HCD AFFH Spatial Data
Economic Score
The 2022 TCAC Opportunity Areas Economic Score for a census tract is based on poverty, adult education, employment, job proximity, and median home value indicators. The score is broken up by quartiles, with the highest quartile indicating more positive economic outcomes and the lowest score indicating least positive outcomes. The city’s census tracts have the highest economic scores of 0.75 to 0.99 as shown in Figure F-14. The high economic scores result from overall high employment and adult education levels (bachelor's degree or above) as well as very low poverty rates. Most of the surrounding areas also have the highest economic scores. Two tracts to the northeast (across El Camino Real in Mountain View) have lower economic scores than Los Altos in the second and third quartile ranges. As noted in the previous section, these areas have higher concentrations of commercial land use and have some apartment developments. However, 353
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Affirmatively Furthering Fair Housing City of Los Altos | F-25 surrounding census tracts are otherwise in the same highest economic score range as Los Altos (see below Figure F-14).

Figure F-14: TCAC Opportunity Areas 2022 - Economic Score Source: HCD AFFH Spatial Data
Education Score
The 2022 TCAC Opportunity Areas Education Score for a census tract is based on math and reading proficiency, high school graduation rate, and student poverty rate indicators. The score is broken up by quartiles, with the highest quartile indicating more positive education outcomes and the lowest quartile signifying less positive outcomes.

As shown in Figure F-15, most census tracts in the city have a good education score between

0.50 and 0.75. Three tracts in the south have scores greater than 0.75. These scores suggest that the city generally has positive educational outcomes for students.

Los Altos contains seven school enrollment zones in total with some of their boundaries partially overlapping the city. Six of the seven zones are within the 0.50 and 0.75 education score range. 354
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F-26 | City of Los Altos Affirmatively Furthering Fair Housing Only one Los Altos school, Oak Avenue School, located north of Fremont Avenue, is within the highest education score area for the city. The two other high education score tracts are outside of Los Altos school districts.

Lower education scores are observed to the northeast in Mountain View. These areas also have higher levels of LMI households so the lower education scores may be the result of higher student poverty rates and reflects elementary schools with higher concentrations of Hispanic or Latino students.
6 Cities to the southwest including Sunnyvale and Cupertino have high education scores similar to those of Los Altos, and likewise, Los Altos Hills to the west has a similar education score to Los Altos.

Figure F-15: TCAC Opportunity Areas 2022 - Education Score Source: HCD AFFH Spatial Data
6 City of Mountain View, Public Review Draft 2023-2031 Housing Element, May 6, 2022. 355
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Affirmatively Furthering Fair Housing City of Los Altos | F-27 Environmental Score
Environmental scores for census tracts presented in Figure F-16 are based on 2022. TCAC Opportunity Areas Environmental Scores that reflect environmental risk. The scores are divided into quartiles with higher scores representing more positive environmental outcomes and lower scores indicating least positive environmental outcomes for residents living there.

The city contains two ranges of high environmental scores indicating that residents have generally positive environmental conditions. As shown in Figure F-16, the highest environmental scores are mostly in the western portions of the city. These tracts also score higher than the surrounding areas. Environmental scores decrease to the north and east across Santa Clara County due in part to higher levels of traffic and air pollution within transportation corridors in more concentrated areas.

Figure F-16: TCAC Opportunity Areas 2021 - Environmental Score Source: HCD AFFH Spatial Data
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F-28 | City of Los Altos Affirmatively Furthering Fair Housing Jobs Proximity Index
HUD’s Jobs Proximity Index for a census tract measures the area’s distance from employment.

This index can be used as a proxy to indicate relative transportation needs in a community. The score is broken up by quintiles, with the highest quintile representing areas closest to job centers.

The Jobs Proximity Index score is relatively high across Los Altos with most of the city in the 60 to 80 quintile range as shown in Figure F-17. Scores are highest in the north and lowest in the south. Scores are generally similar in adjacent tracts to the east and west outside of the city while they are lower to the north and south.

Approximately 769 people are both employed and live in Los Altos, which is 6.4 percent of employed Los Altos residents according to 2019 employment data7. The largest proportion of employed Los Altos residents work in the City of San Jose (19.5 percent), followed by the City of Mountain View (7.7 percent), the City of Sunnyvale (6.9 percent), and the City of Los Altos (6.4 percent).
7 Longitudinal Employer-Household Dynamics (LEHD), OnTheMap, 2019. 357
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Affirmatively Furthering Fair Housing City of Los Altos | F-29 Figure F-17: Jobs Proximity Index (HUD, 2014-2017)
Source: HCD AFFH Spatial Data
Disparities in Access to Opportunity for Persons with Disabilities People with disabilities often experience challenges with accessibility, discrimination, and housing choice that make it difficult to find suitable housing to meet their needs. According to the Needs Assessment (Appendix A, Figure A-23), the most common types of disabilities in Los Altos in 2018 were ambulatory disabilities followed by hearing and independent living disabilities.

The California Department of Developmental Services (DDS) currently provides communitybased services to approximately 350,000 persons with developmental disabilities and their families through a statewide system of regional centers, developmental centers, and communitybased facilities. The San Andreas Regional Center serves individuals and families in Monterey, San Benito, Santa Clara, and Santa Cruz counties. DDS provides data on developmental disabilities by age and type of residence. According to DDS and as shown in the Needs Assessment (Appendix A, Table A-7), there are about 95 residents with a development disability in Los Altos, with most of them (93) able to live in a home with their parent or guardian. 358
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F-30 | City of Los Altos Affirmatively Furthering Fair Housing During the Housing Element process, a service provider for the San Andreas Regional Center described the heightened need for accessible units coupled with coordinated supportive services and access to public transit for people with developmental disabilities, who are more likely than the general population to have an accompanying physical disability.

There are a variety of housing types appropriate for people with disabilities, such as licensed and unlicensed single-family homes, group homes, and transitional and supportive housing. The design of housing-accessibility modifications, proximity to services and transit, and the availability of group living opportunities represent some of the types of considerations that are important in serving this need group. The Housing Constraints Appendix (Appendix C) discusses how the City permits various housing types, including the allowance for reasonable accommodations.

Additionally, the Santa Clara County Social Services Agency operates the In-Home Supportive Services (IHSS) program for low-income seniors or people with disabilities. This program provides support for individuals such as meal preparation, laundry, house cleaning, and personal care to enable them to live at home.

Disparities in Access to Transportation Opportunities
The HUD Low Transportation Cost Index is based on estimates of transportation costs for a family that meets the following description: a 3-person single-parent family with income at 50 percent of the median income for renters for the region. These estimates originate from the Location Affordability Index (LAI). Transportation costs are modeled for census tracts as a percent of income for renters in these households. Index values are inverted, and percentile ranked nationally, with values ranging from 0 to 100. Higher index values indicate lower transportation costs in that neighborhood. Transportation costs may be low within a tract for a range of reasons, including greater access to public transportation and the density of homes, services, and jobs in that area.

Figure F-18 displays the Transportation Cost Index ranges in Los Altos. The index values are at or above 89 across the city indicating that Los Altos has lower transportation costs than that percentage of the nation. Transportation costs are therefore estimated to be low for a 3-person single-parent family with income at 50 percent of the median income. Transportation costs for renters in the city and access to transportation opportunities are relatively even and closely match adjacent areas outside of the city.

Residents of Los Altos have access to various transit modes. The city contains part of the Santa Clara County bike path network, and some roads have bike lanes for cyclists. According to the Valley Transportation Authority, bus routes within Los Altos include service along San Antonio Road, El Monte Road, and El Camino Real. Bus routes connect Los Altos to the larger Santa Clara Valley Transportation Authority network and CalTrain. As suggested by the uniformity of transportation costs throughout Los Altos shown in Figure F-18 below, issues surrounding access to transportation do not appear to disproportionately impact protected groups or classes. However, 359
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Affirmatively Furthering Fair Housing City of Los Altos | F-31 the Community Services Agency of Mountain View and Los Altos noted the importance of walkability and transit for seniors and encouraged the integration of housing into existing commercial areas where shopping, services, and amenities area available. The housing sites inventory reflects integration of housing into commercial areas, including Downtown Los Altos and along key transit corridors such as Foothill Expressway, San Antonio Road, and El Camino Real.

Additionally, comments during the Housing Element process included focusing housing, particularly affordable housing, in areas with transit options and that are walkable with access to services. Several comments requested that additional transportation services for seniors should be addressed. Under Program 4.J the City will implement it’s Complete Streets Masterplan and facilitate safe alternative modes of transportation, such as through capital improvement projects and funding of community service organizations to offer rides.

Figure F-18: HUD Low Transportation Cost Index
Source: HUD Spatial Data
F.2.6 Disproportionate Housing Needs
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F-32 | City of Los Altos Affirmatively Furthering Fair Housing Overpayment
HUD defines overpayment, or “housing cost burden”, as households paying 30 percent or more of their gross income on housing expenses, including rent or mortgage payments and utilities.

Housing cost burden is considered a housing need because households that overpay for housing costs may have difficulty affording other necessary expenses, such as childcare, transportation, and medical costs.

Renters are typically more likely to overpay for housing costs than homeowners. The percentage of renter households exhibiting cost burden varies across the city from less than 20 percent to between 40 and 60 percent (Figure F-19). The highest renter overpayment percentage is in the northwestern area of the city that ranks relatively high on both the Location Affordability Index and the Jobs Proximity Index, which indicates that rental costs are elevated closer to job centers and around half of renter households find it difficult to afford those costs.

Figure F-19: Overpayment by Renters (2015 - 2019)
Source: HCD AFFH Spatial Data
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Affirmatively Furthering Fair Housing City of Los Altos | F-33 Homeowners generally experience a lower rate of cost burden than renters. Figure F-20 shows the percentages of homeowners experiencing overpayment for the 2015 to 2019 time period.

Percentages of homeowners with overpayment range from approximately 20 percent to 60 percent across the city, the same ranges as renters experiencing overpayment. The area with the highest percentages of homeowner overpayment are high resource areas with high education scores. Homeowner overpayment areas also score relatively high on the Location Affordability Index which indicates that some homeowners experience difficulty affording their combined living costs for housing and transportation.

Although Los Altos has a lower proportion of cost-burdened households compared to the county and the Bay Area (Housing Needs Assessment, Appendix A, Section A.5.3), housing affordability of housing was a key issue raised throughout the Housing Element update process. Housing in Los Altos is unaffordable to many households, including critical workers (e.g., teachers, firefighters, service industries, etc.), and not just lower income households. This was also reflected in responses to the community feedback form/questionnaire distributed to businesses and workers, where limited availability of affordable units, lack of resources to find affordable housing, and long waitlists were identified as barriers. 362
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F-34 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-20: Overpayment by Owners (2015 - 2019)
Source: HCD AFFH Spatial Data
Overcrowding
Overcrowding is defined by the Census as a unit in which more than one person occupies a room (excluding bathrooms and kitchens) while severe overcrowding occurs when more than 1.5 people occupy a room. Overcrowded households are an indicator of housing needs, as lower income families or individuals may choose to live together in smaller spaces to save money on housing costs.

In addition to the strain on residents’ mental and physical health, overcrowding can also lead to more rapid deterioration of the property due to increased usage. Overall 0.6 percent of households in Los Altos experienced overcrowding and 0.1 percent experienced severe overcrowding according to ACS 2019 five-year data. The city’s overcrowding rates are lower than Santa Clara County overcrowding and severe overcrowding rates of 5.2 and 4.7 percent, respectively (Table F-7). Overcrowding is more prevalent in renter households (see Housing Needs Assessment, Appendix A, Section A.3.2).
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Affirmatively Furthering Fair Housing City of Los Altos | F-35 Table F-7: Overcrowding and Severe Overcrowding Rates
Los Altos Santa Clara County
Occupants Per Room Units Percentage Percentage

1.01 to 1.5 68 0.6% 5.2%

1.51 or more 13 0.1% 2.9%
Source: ACS 2019 5-Year Estimates, Table DP04
Estimated percentages of overcrowded households in Los Altos by census tract are shown in Figure F-21. The highest overcrowding percentage is about 2.5 percent and is found in the southernmost tract located south of Foothill Expressway. Half of the tracts contain overcrowding rates of zero percent. Overcrowding levels in adjacent areas are mostly similar to the city but are higher in some areas to the north and south.

The statewide spatial data for severe overcrowding did not contain any values in the vicinity of Los Altos as shown in Figure F-22.
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F-36 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-21: Overcrowded Households HUD, CHAS, ACS (2020) Source: HCD AFFH Spatial Data
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Affirmatively Furthering Fair Housing City of Los Altos | F-37 Figure F-22: Severely Overcrowded Households HUD, CHAS, ACS (2020) Source: HCD AFFH Spatial Data
In Los Altos, rates of overcrowding are highest for Hispanic households, followed by Asian households. As with disability status, age likely plays some role in explaining racial and ethnic disparities in overcrowding. Relatively younger adults, around the age of the median-age Hispanic households, are more likely to have minor children in their households, which, in turn, increases the likelihood of overcrowding. Conversely, older adults closer to the median-age of White households, are more likely to reside in one- or two-person households. 366
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F-38 | City of Los Altos Affirmatively Furthering Fair Housing Table F-8: Occupants per Room for Households by Race and Ethnicity Race or Ethnicity Total Households % in Overcrowded
Units*
White Alone, Not
Hispanic or Latino 6.,903 0.3%
Black or African
American Alone 40 0.0%
Asian Alone 3,111 1.4%
Hispanic or Latino (of
any race) 334 2.4%
* Overcrowded units defined as 1.01 or more occupants per room.

Source: Lawyer’s Committee, Baird + Driskell Community Planning; ACS 2019 5-Year Estimates
Location Affordability Index
Figure F-23 shows HUD’s Location Affordability Index for 2012 to 2016 in Los Altos. This index estimates household housing and transportation cost on a neighborhood-scale. As shown in this figure, the index in half of the tracts have values up to $3,000 per month. The city contains higher index values (greater than $3,000) in two census tracts in the southern portion of the city, south of Fremont Avenue. These tracts score highest for this index but are not the highest areas for overpayment, however. Adjacent tracts generally have lower Location Affordability Index scores than the city.
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Affirmatively Furthering Fair Housing City of Los Altos | F-39 Figure F-23: Location Affordability Index HUD (2012 – 2016) Source: HCD AFFH Spatial Data
Substandard Housing
Incomplete plumbing or kitchen facilities can be used as a proxy to indicate substandard housing conditions. Los Altos and Santa Clara County have very similar substandard housing rates as summarized in Table F-9. According to the 2015 to 2019 ACS, 0.2 percent of Los Altos households lacked complete plumbing installations, which is slightly lower than Santa Clara County overall at 0.3 percent. The estimate of Los Altos households without complete kitchen facilities is 0.8 percent while the county estimate is at 0.9 percent. Substandard housing, which exist at very low percentages in Los Altos and the region, is not concentrated in any one area within the city.
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F-40 | City of Los Altos Affirmatively Furthering Fair Housing Table F-9: Substandard Housing Rates
Los Altos Santa Clara County
Substandard Housing Units Percentage Percentage
Lacking complete plumbing facilities 18 0.2% 0.3%
Lacking complete kitchen facilities 85 0.8% 0.9%
Source: ACS 2019 5-Year Estimates, Table DP04
The age of housing stock can also be an indicator of substandard housing. As homes get older, there is a greater need for maintenance and repair. If not properly addressed, an aging housing stock can result in poorer living standards, incur more expensive repair costs and, under certain conditions, lower overall property values. See Housing Needs Assessment (Appendix A, Section A.4.4) for additional information on housing stock age and condition.

Displacement Risk
The University of California Berkeley’s Urban Displacement Project (UDP) uses data-driven research to produce maps identifying sensitive communities that are at-risk of displacement. UDP defines sensitive communities as currently having “populations vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost”. Vulnerability was determined based on the following characteristics:
• The share of very low-income residents is above 20 percent; AND
• The tract meets two of the following criteria:
o Share of renters is above 40 percent
o Share of people of color is above 50 percent
o Share of very low-income households that are severely rent burdened households is above the county median
o Percent change in rent is above county median rent increase o Rent gap, which is the difference between tract median rent and median rent for surrounding areas
UDP has not identified any vulnerable communities at-risk of displacement within the city (Figure F-24). Furthermore, the environmental analysis for this Housing Element does not identify any risk of displacement to groups with protected characteristics on account of any natural disasters.

Although several faults are located near Los Altos, no part of Los Altos is located within an identified earthquake fault zone.
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Affirmatively Furthering Fair Housing City of Los Altos | F-41 Figure F-24: Vulnerable Communities
Source: HCD AFFH Spatial Data
Homelessness
Information on homelessness and resources for persons experiencing homelessness in Los Altos is described in the Housing Needs Assessment (Appendix A, Section A.3.4, People Experiencing Homelessness).

Between 2017 and 2019, Los Altos saw its homeless population increase over tenfold, from six to 76 people. This is higher than the rate of increase in the county, 31 percent, during the same period (7,394 to 9,706 people experiencing homelessness). Los Altos’ homeless population is less than one percent of the county’s homeless population. While White residents represent the largest proportion of Santa Clara County residents experiencing homelessness, making up just under 44 percent of the homeless population, Black or African American and American Indian or Alaska Native residents are overrepresented – accounting for 18.8 and 8.1 percent of the homeless population while only making up 2.5 and 0.5 percent of the overall population of the county respectively.
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F-42 | City of Los Altos Affirmatively Furthering Fair Housing Los Altos is part of the Santa Clara County Continuum of Care (CoC) in the Office of Supportive Housing, which is a regional planning body funded by HUD that coordinates housing and services funding across its partner jurisdictions.

F.2.7 Other Relevant Factors
Rates of Homeownership by Race and Ethnicity
The home ownership rate is about 81 percent in Los Altos compared to about 56 percent for Santa Clara County. The 2019 ACS data for percentages of occupied housing units by race is presented in Table F-10.

Not all racial and ethnic groups in Los Altos have a similar likelihood of owning a home. The rates of home ownership are lower than renting for Blacks, American Indians, residents of two or more races, and Latinos according to the ACS data. The ownership rate is similar to renting for other ethnic groups. Racial and ethnic groups that have much lower rates of homeownership are more at risk of being displaced due to rising rental prices.

Table F-10: Housing Tenure by Race/Ethnicity in Los Altos (2019) Los Altos
Renter Occupied Units Owner Occupied Units Total Occupied Units
Number % of Total Number % of Total
White alone, not Latino 1,254 62.0% 5,649 65.5% 7,166
Black or African American alone 31 1.5% 9 0.1% 40
American Indian and Alaska
Native alone 7 0.3% 0 0.0% 7
Asian alone 496 24.5% 2,615 30.3% 3,111
Native Hawaiian/Other Pacific
Islander alone 0 0.0% 0 0.0% 0
Some other race alone 10 0.5% 61 0.7% 71
Two or more races 103 5.1% 154 1.8% 257
Hispanic or Latino origin 149 7.4% 185 2.1% 334
TOTAL 2,050 19% 8,673 79% 10,986
Source: ACS 2019 5-Year Estimates, Table S2502
One obstacle to home ownership is lack of access to the first tier of the financial system to obtain banking services and loans. The Federal Financial Institutions Examination Council's (FFIEC) provides the Community Reinvestment Act (CRA) July 2021 census tract spatial data known as CRAMap 2021 (www.ffiec.gov/cra/). Included in the CRAMap 2021 spatial data is the Unbanked index (developed by RPM Consulting) which provides an estimate of households lacking access 371
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Affirmatively Furthering Fair Housing City of Los Altos | F-43 to the primary banking system. This index estimates the likelihood of a household will lack both a savings and checking account with a bank, thrift, or credit union.

Figure F-25 presents estimates for the percentages of households that lack access to banking and credit from the CRAMap 2021 Unbanked index. Identifying areas with relatively higher levels of residents without access to the primary banking system can facilitate the process of providing them first-tier financial services. This may aid lower income residents in avoiding a dependency on second-tier services, particularly predatory lenders. Estimates for the percentages of households without access to primary banking and credit is very low across the city.

Figure F-25: Percentage of Households without Access to Banking or Credit Source: FFIEC CRAMap 2021 Spatial Data
F.2.8 Summary of Fair Housing Issues
Access to opportunity in Los Altos is approximately evenly distributed across the city as evidenced by the relatively consistent TCAC scores citywide. However, the northwest area of the city, including Downtown, meets the criteria to be considered a Racially or Ethnically Concentrated Areas of Affluence (RCAA), evidence that some non-white residents may experience different 372
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F-44 | City of Los Altos Affirmatively Furthering Fair Housing economic conditions than white residents. Black, American Indians, and residents of two or more races are more like to experience poverty and are less likely to own their home than other racial groups.

A citywide fair housing issue is overpayment by renters and homeowners, although homeowners are more cost burdened than renters. Almost 23 percent of renters (457 households) are cost burdened, compared to 28 percent of homeowners (2,416 households). The city also contains high to very high Location Affordability Index rates.

The primary fair housing issue in Los Altos is disproportionate housing needs because it is likely to affect the most residents and protected classes. The contributing factor to this primary issue is land use and zoning laws either limiting where multi-family housing can be built or procedures resulting in a protracted entitlement effort. This contributing factor is evident due to the high levels of overpayment by homeowners and renters within both higher and lower income households.

The data indicates that higher and lower income households, encompassing various household sizes and characteristics, may choose more affordable housing if available.

The second fair housing issue is also disproportionate housing needs due to the contributing factor of a lack available affordable units in a range of sizes. A combination of very high Location Affordability Index rates and high levels of overpayment indicate the need for more affordable housing, which could be provided through smaller unit sizes and a mix of housing types. The number of cost-burdened households indicates that many residents are struggling to afford housing costs which can lead to increased homelessness rates for at-risk populations.

The third fair housing issue is segregation and integration because of community opposition to building more affordable housing in the city. This is evident in the development review process, which requires multiple review bodies and meetings (often with City Council approval) and cumbersome requirements (e.g., installation of story poles). Public comments expressed that the City’s review process, ranging from accessory dwelling units to large projects, is a challenge to building housing in Los Altos.

The fourth fair housing issue is also segregation and integration due to the contributing factor of limited options for affordable housing, as clearly demonstrated by public comments throughout the Housing Element process. Comments identified that the availability of affordable housing is a critical issue, and housing affordable to low and moderate-income households, families, essential workers, and seniors is needed. New residential development throughout Los Altos would provide housing in high and highest resources areas, as well as in Racially or Ethnically Concentrated Areas of Affluence (RCAA). The RCAAs in Los Altos include Downtown, San Antonio Road, and the west portion of El Camino Real, where various housing sites are located. 373
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Affirmatively Furthering Fair Housing City of Los Altos | F-45 Section F.3 Sites Inventory
AB 686 requires a jurisdiction’s site inventory to be consistent with its duty to affirmatively further fair housing. This section evaluates the city’s site inventory locations against various measures in the Assessment of Fair Housing that includes income level, racially and ethnically concentrated areas of poverty, access to opportunity, and environmental risk to determine any socio-economic patterns or implications.

F.3.1 Sub-Area Analysis
This section describes the three sub-areas of Los Altos that were analyzed to compare conditions across the city. The Los Altos Sub-Areas include Sub-Area 1 in the north, Sub-Area 2 located centrally, and Sub-Area 3 in the south. The sub-area geographies reflect areas that share similar qualities such as income levels, race and ethnicity, and concentrated areas of poverty, although some characteristics are quite similar across Los Altos. The sub-area boundaries are also based on census tract boundaries that approximate the City’s boundaries. The goal of the sub-area analysis is to ensure that the City’s housing policies do not contribute to existing fair housing challenges.
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F-46 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-26: Los Altos Sub-Areas
As shown in Table F-11, demographics characteristics and other conditions are mostly similar across Los Altos. All three sub-areas score as Highest Resource TCAC areas and are predominantly White. The percentage of Non-White for Sub-Areas 1, 2, and 3, are 37.6 percent,

35.3 percent, and 41.8 percent respectively. However, there are some moderate differences among the sub-areas. Sub-Area 2 has a notably lower share of renters that are cost-burdened compared to the other sub-areas, and Sub-Area 3 has a slightly higher share of homeowners that cost-burdened relative to the other sub-areas. The percentage of renter households that are overpaying is 20.2 percent in Sub-Area 2 compared to 32.1 percent in Sub-Area 1 and 35.2 percent in Sub-Area 3. The percentage of homeowners overpaying in Sub-Area 3 is 39.3 percent compared to around 33 percent in Sub-Areas 1 and 2. Sub-Area 3 also has a greater share of households that are overcrowded at 3.8 percent compared to 0.8 percent in Sub-Area 1 and 0.7 percent in Sub-Area 2. As such, the distribution of housing sites does not perpetuate segregation or isolate the RHNA, and programs would promote lower and moderate-income housing throughout Los Altos, such as through the inclusionary zoning, accessory dwelling units, SB 9 implementation, and other programs that facilitate the development of below market rate housing. 375
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Affirmatively Furthering Fair Housing City of Los Altos | F-47 Table F-11: Sub-Area Analysis Summary
376
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F-48 | City of Los Altos Affirmatively Furthering Fair Housing 377 Agenda Item # 3.

Affirmatively Furthering Fair Housing City of Los Altos | F-49 378
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F-50 | City of Los Altos Affirmatively Furthering Fair Housing 379 Agenda Item # 3.

Affirmatively Furthering Fair Housing City of Los Altos | F-51 F.3.2 Potential Effects on Patterns of Segregation
A comparison of a jurisdiction’s site inventory against its LMI households and R/ECAP area can reveal if the city’s accommodation of housing is exacerbating or ameliorating segregation and social inequity. Figure F-27 shows the locations of Los Altos’ sites inventory relative to LMI concentrations, and Figure F-28 shows the distribution of sites area relative to the area of LMI concentrations.

The city contains two LMI percentage quartiles, less than 25 percent and 25 to 50 percent.

The city’s lowest LMI percentage category of less than 25 percent covers almost all of the city.

The amount city area within this area is 100 percent when rounded to the nearest whole percentage, and about 95 percent of the sites inventory area is in this category.

The other LMI category (25 to 50 percent) covers less than one percent of city area and is in the very southern portion of the city. This LMI category contains five percent of site inventory area.

Figure F-27: Site Inventory including Rezone Sites and LMI Households Source: HCD AFFH Spatial Data and LWC
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F-52 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-28: Distribution of Site Inventory including Rezone Sites across LMI Population Percentages Source: HCD AFFH Spatial Data and LWC
Figures F-29 and F-30 show the site inventory area associated with R/ECAPs. As previously noted, Los Altos does not have any R/ECAPs within its boundaries. The amount of city and site inventory areas not within a R/ECAP is therefore 100 percent. 100
0 0 0
95 5
0 0
0 25
50 75
100
<25% 25 - 50% 50% - 75% 75% - 100%
Percentage of Total Area
Low to Moderate Income Population Percentages
Percentage of City Area Percentage of Site Inventory Area 381
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Affirmatively Furthering Fair Housing City of Los Altos | F-53 Figure F-29: Site Inventory including Rezone Sites and R/ECAPs Source: HCD AFFH Spatial Data and LWC
Figure F-30: Distribution of Site Inventory including Rezone Sites across R/ECAP Source: HCD AFFH Spatial Data and LWC
0 25
50 75
100
0 - Not a R/ECAP 1 - R/ECAP Area
Percentage of Total Area
Percentage of City Area Percentage of Site Inventory Area 0% 0%
100% 100%
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F-54 | City of Los Altos Affirmatively Furthering Fair Housing F.3.3 Potential Effects on Access to Opportunity
Figure F-31 shows sites inventory locations across the city’s TCAC Opportunity Areas. As mentioned earlier, the city is categorized as either highest or high resource areas based on the TCAC Composite Score. These areas have been scored based on very good access to high quality schools, economic opportunities, and low environmental risk.

Figure F-31: Site Inventory including Rezone Sites and TCAC Composite Scores Source: HCD AFFH Spatial Data and LWC
Figure F-32 shows the distribution of Los Altos sites across the TCAC Opportunity Area Composite Score categories. The city is comprised of two categories: highest resource (89 percent of the city) and high resource (11 percent of the city). The sites inventory area distribution is aligned with the city’s Opportunity Areas. In this respect, the sites inventory is considered to 383
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Affirmatively Furthering Fair Housing City of Los Altos | F-55 mitigate fair housing concerns regarding access to opportunity because housing development potential in the city is equitably located in high resource neighborhoods overall.

Figure F-32: Distribution of Site Inventory including Rezone Sites across TCAC Opportunity Areas Source: HCD AFFH Spatial Data and LWC
Figure F-33 shows the sites inventory across the city’s CalEnviroScreen scores. The city contains two CalEnviroScreen scores ranging from the lowest one to 10 percent (first decile, lowest risk) and 21 to 30 percent (third decile, lower risk).

Figure F-34 shows the distribution of sites across the range of CalEnviroScreen scores presented as deciles in Los Altos. The city contains two decile scores: 1 and 3. The highest environmental risk to residents (score three) accounts for less than one percent of city area and makes up five percent of the sites inventory area.

89 11
0 0 0 0
84 16
0 0 0 0
0 25
50 75
100

1. Highest
Resource

2. High
Resource

3. Moderate
Resource
(Rapidly
Changing)

4. Moderate
Resource

5. Low
Resource

6. High
Segregation &
Poverty
Percentage of Total Area
TCAC Composite Score
Percentage of City Area Percentage of Site Inventory Area 384
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F-56 | City of Los Altos Affirmatively Furthering Fair Housing Figure F-33: Site Inventory including Rezone Sites and CalEnviroScreen Scores Source: HCD AFFH Spatial Data and LWC
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Affirmatively Furthering Fair Housing City of Los Altos | F-57 Figure F-34: Distribution of Site Inventory including Rezone Sites across CalEnviroScreen Scores

Source: HCD AFFH Spatial Data and LWC
Note: CalEnviroScreen Score 3 represents less than 1% of total area within the city; therefore, is rounded to 0.

Section F.4 Contributing Factors and Meaningful
Actions
Table F-12 lists the most prevalent fair housing issues and their corresponding contributing factors for the City of Los Altos, as prioritized through the findings from the City’s outreach efforts and the above assessment, as outlined in Section F.2.8.

Table F-12: Contributing Factors
Priority Contributing Factor Fair Housing Issue
1 Land use and zoning laws Disproportionate Housing Needs 2 Availability of affordable units in a range of sizes Disproportionate Housing Needs 3 Community opposition Segregation and Integration
4 Location and type of affordable housing Segregation and Integration Table F-13 consists of proposed housing programs the City will pursue to specifically overcome identified patterns and trends from the above assessment and proactively affirmatively further fair housing in Los Altos. The programs are detailed metrics and milestones in Section IV of the Housing Element.
100
0 0 0 0 0 0 0 0 0
95 0
5 0 0 0 0 0 0 0
0 25
50 75
100
1 2 3 4 5 6 7 8 9 10
Percentage of Total Area
CalEnviroScreen Score
Percentage of City Area Percentage of Site Inventory Area (Lowest Risk) (Highest Risk)
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F-58 | City of Los Altos Affirmatively Furthering Fair Housing Table F-13: Meaningful Actions
Contributing
Factor
AFFH
Strategy Housing Implementation Programs
Land use and
zoning laws
New housing
choices and
affordability in
areas of
opportunity

1.A: Rezone for RHNA shortfall

1.C: Allow housing in the Office Administrative (OA) District

1.E: Update the Loyola Corners Specific Plan
Availability of
affordable units
in a range of
sizes
New housing
choices and
affordability in
areas of
opportunity

1.B: Facilitate higher density housing in the Commercial Thoroughfare (CT) District

1.H Facilitate housing on City-owned sites

2.D: Encourage and streamline Accessory Dwelling Units (ADUs)

6.A: Assist residents with housing discrimination and landlord-tenant complaints
Community
opposition
New housing
choices and
affordability in
areas of
opportunity

2.A: Continue to implement and enhance inclusionary housing requirements

3.F: Reduce Conditional Use Permit requirement for residential mixed-use and multi-family

3.H: Amend design review process and requirements

3.K: Standardize multimodal transportation requirements Location and
type of
affordable
housing
New housing
choices and
affordability in
areas of
opportunity

1.D: Allow housing on certain Public and Community Facility District sites and facilitate housing on religious institution properties

6.B: Maintain and expand an inventory of affordable housing funding sources

6.C: Target housing development in highest resource areas

6.F: Affirmatively market physically accessible units
Protect
existing
residents from
displacement

5.A: Monitor condominium conversions

6.E: Prepare and distribute anti-displacement information Housing
mobility
strategies

4.J: Facilitate alternate modes of transportation for residents

5.B: Continue to administer the City’s affordable housing programs

6.D: Promote Housing Choice (Section 8) rental assistance program Attachment: AFFH Segregation Report, Los Altos
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1 AFFH SEGREGATION REPORT: LOS
ALTOS
UC Merced Urban Policy Lab and ABAG/MTC Staff
Version of Record: March 06, 15:57:45
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2 0.1 Table of content

0.1 Table of content .................................................................................................... 2

0.2 List of figures ....................................................................................................... 3

0.3 List of tables ........................................................................................................ 3 1 Introduction .............................................................................................................. 4

1.1 Purpose of this Report ............................................................................................. 4

1.2 Defining Segregation ............................................................................................... 5

1.3 Segregation Patterns in the Bay Area ........................................................................... 5

1.4 Segregation and Land Use ......................................................................................... 6 2 Racial Segregation in City of Los Altos .............................................................................. 8

2.1 Neighborhood Level Racial Segregation (within City of Los Altos) ......................................... 8

2.2 Regional Racial Segregation (between Los Altos and other jurisdictions) ...............................16 3 Income Segregation in City of Los Altos .......................................................................... 21

3.1 Neighborhood Level Income Segregation (within Los Altos) ................................................21

3.2 Regional Income Segregation (between Los Altos and other jurisdictions) ..............................27 4 Appendix 1: Summary of Findings ................................................................................. 31

4.1 Segregation in City of Los Altos .................................................................................31

4.2 Segregation Between City of Los Altos and Other jurisdictions in the Bay Area Region ..............31 5 Appendix 2: Segregation Data ...................................................................................... 33 6 References .............................................................................................................. 37 389
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3 0.2 List of figures
Figure 1: Racial Dot Map of Los Altos (2020) .............................................................................. 9 Figure 2: Racial Isolation Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2020) ........11 Figure 3: Racial Dissimilarity Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2020) ...14 Figure 4: Theil’s H Index Values for Racial Segregation in Los Altos Compared to Other Bay Area Jurisdictions (2020) ...........................................................................................................................15 Figure 5: Racial Dot Map of Los Altos and Surrounding Areas (2020) .................................................16 Figure 6: Racial Demographics of Los Altos Compared to All Bay Area Jurisdictions (2020) ......................18 Figure 7: Comparing the Share of People of Color in Los Altos and Vicinity to the Bay Area (2020) ............19 Figure 8: Income Dot Map of Los Altos (2015) ............................................................................22 Figure 9: Income Group Isolation Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2015) ...................................................................................................................................24 Figure 10: Income Group Dissimilarity Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2015) ...........................................................................................................................26 Figure 11: Income Group Theil’s H Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2015) ...........................................................................................................................27 Figure 12: Income Dot Map of Los Altos and Surrounding Areas (2015) ..............................................28 Figure 13: Income Demographics of Los Altos Compared to Other Bay Area Jurisdictions (2015) ...............29

0.3 List of tables
Table 1: Racial Isolation Index Values for Segregation within Los Altos .............................................10 Table 2: Racial Dissimilarity Index Values for Segregation within Los Altos .........................................13 Table 3: Theil’s H Index Values for Racial Segregation within Los Altos .............................................15 Table 4: Population by Racial Group, Los Altos and the Region .......................................................17 Table 5: Regional Racial Segregation Measures ..........................................................................20 Table 6: Income Group Isolation Index Values for Segregation within Los Altos ....................................23 Table 7: Income Group Dissimilarity Index Values for Segregation within Los Altos ...............................25 Table 8: Theil’s H Index Values for Income Segregation within Los Altos............................................26 Table 9: Population by Income Group, Los Altos and the Region .....................................................28 Table 10: Regional Income Segregation Measures .......................................................................30 Table 11: Neighborhood Racial Segregation Levels in Los Altos .......................................................33 Table 12: Neighborhood Income Segregation Levels in Los Altos ......................................................34 Table 13: Regional Racial Segregation Measures .........................................................................35 Table 14: Regional Income Segregation Measures .......................................................................35 Table 15: Population by Racial Group, Los Altos and the Region .....................................................36 Table 16: Population by Income Group, Los Altos and the Region ....................................................36 390
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4 1 INTRODUCTION
The requirement to Affirmatively Further Fair Housing (AFFH) is derived from The Fair Housing Act of 1968, which prohibited discrimination concerning the sale, rental, and financing of housing based on race, color, religion, national origin, or sex—and was later amended to include familial status and disability.1 The 2015 U.S. Department of Housing and Urban Development (HUD) Rule to Affirmatively Further Fair Housing and California Assembly Bill 686 (2018) mandate that each jurisdiction takes meaningful action to address significant disparities in housing needs and access to opportunity.23 AB 686 requires that jurisdictions incorporate AFFH into their Housing Elements, which includes inclusive community participation, an assessment of fair housing, a site inventory reflective of AFFH, and the development of goals, policies, and programs to meaningfully address local fair housing issues. ABAG and UC Merced have prepared this report to assist Bay Area jurisdictions with the Assessment of Fair Housing section of the Housing Element.

Assessment of Fair Housing Components
The Assessment of Fair Housing includes five components, which are discussed in detail on pages 22-43 of HCD’s AFFH Guidance Memo:

A: Summary of fair housing enforcement and outreach capacity B: Integration and segregation patterns, and trends related to people with protected characteristics
C: Racially or ethnically concentrated areas of poverty D: Disparities in access to opportunity
E: Disproportionate housing needs, including displacement risk

1.1 Purpose of this Report
This report describes racial and income segregation in Bay Area jurisdictions. Local jurisdiction staff can use the information in this report to help fulfill a portion of the second component of the Assessment of Fair Housing, which requires analysis of integration and segregation patterns and trends related to people with protected characteristics and lower incomes. Jurisdictions will still need to perform a similar analysis for familial status and populations with disability.

This report provides segregation measures for both the local jurisdiction and the region using several indices. For segregation between neighborhoods within a city (intra-city segregation), this report includes isolation indices, dissimilarity indices, and Theil’s-H index. The isolation index measures

1 https://www.justice.gov/crt/fair-housing-act-2
2 HCD AFFH Guidance Memo
3 The 2015 HUD rule was reversed in 2020 and partially reinstated in 2021. 391
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5 segregation for a single group, while the dissimilarity index measures segregation between two groups.

The Theil’s H-Index can be used to measure segregation between all racial or income groups across the city at once. HCD’s AFFH guidelines require local jurisdictions to include isolation indices and dissimilarity indices in the Housing Element. Theil’s H index is provided in addition to these required measures. For segregation between cities within the Bay Area (inter-city segregation), this report includes dissimilarity indices at the regional level as required by HCD’s AFFH guidelines. HCD’s AFFH guidelines also require jurisdictions to compare conditions at the local level to the rest of the region; and this report presents the difference in the racial and income composition of a jurisdiction relative to the region as a whole to satisfy the comparison requirement.

1.2 Defining Segregation
Segregation is the separation of different demographic groups into different geographic locations or communities, meaning that groups are unevenly distributed across geographic space. This report examines two spatial forms of segregation: neighborhood level segregation within a local jurisdiction and city level segregation between jurisdictions in the Bay Area.

Neighborhood level segregation (within a jurisdiction, or intra-city): Segregation of race and income groups can occur from neighborhood to neighborhood within a city. For example, if a local jurisdiction has a population that is 20% Latinx, but some neighborhoods are 80% Latinx while others have nearly no Latinx residents, that jurisdiction would have segregated neighborhoods.

City level segregation (between jurisdictions in a region, or inter-city): Race and income divides also occur between jurisdictions in a region. A region could be very diverse with equal numbers of white, Asian, Black, and Latinx residents, but the region could also be highly segregated with each city comprised solely of one racial group.

There are many factors that have contributed to the generation and maintenance of segregation.

Historically, racial segregation stemmed from explicit discrimination against people of color, such as restrictive covenants, redlining, and discrimination in mortgage lending. This history includes many overtly discriminatory policies made by federal, state, and local governments (Rothstein 2017).

Segregation patterns are also affected by policies that appear race-neutral, such as land use decisions and the regulation of housing development.

Segregation has resulted in vastly unequal access to public goods such as quality schools, neighborhood services and amenities, parks and playgrounds, clean air and water, and public safety (Trounstine 2015). This generational lack of access for many communities, particularly people of color and lower income residents, has often resulted in poor life outcomes, including lower educational attainment, higher morbidity rates, and higher mortality rates (Chetty and Hendren 2018, Ananat 2011, Burch 2014, Cutler and Glaeser 1997, Sampson 2012, Sharkey 2013).

1.3 Segregation Patterns in the Bay Area
Across the San Francisco Bay Area, white residents and above moderate-income residents are significantly more segregated from other racial and income groups (see Appendix 2). The highest levels of racial segregation occur between the Black and white populations. The analysis completed for this report indicates that the amount of racial segregation both within Bay Area cities and across jurisdictions in the region has decreased since the year 2000. This finding is consistent with recent research from the Othering and Belonging Institute at UC Berkeley, which concluded that “[a]lthough 7 392
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6 of the 9 Bay Area counties were more segregated in 2020 than they were in either 1980 or 1990, racial residential segregation in the region appears to have peaked around the year 2000 and has generally declined since.”4
However, compared to cities in other parts of California, Bay Area jurisdictions have more neighborhood level segregation between residents from different racial groups. Additionally, there is also more racial segregation between Bay Area cities compared to other regions in the state.

1.4 Segregation and Land Use
It is difficult to address segregation patterns without an analysis of both historical and existing land use policies that impact segregation patterns. Land use regulations influence what kind of housing is built in a city or neighborhood (Lens and Monkkonen 2016, Pendall 2000). These land use regulations in turn impact demographics: they can be used to affect the number of houses in a community, the number of people who live in the community, the wealth of the people who live in the community, and where within the community they reside (Trounstine 2018). Given disparities in wealth by race and ethnicity, the ability to afford housing in different neighborhoods, as influenced by land use regulations, is highly differentiated across racial and ethnic groups (Bayer, McMillan, and Reuben 2004).5 ABAG/MTC plans to issue a separate report detailing the existing land use policies that influence segregation patterns in the Bay Area.

4 For more information, see https://belonging.berkeley.edu/most-segregated-cities-bay-area-2020. 5 Using a household-weighted median of Bay Area county median household incomes, regional values were $61,050 for Black residents, $122,174 for Asian/Pacific Islander residents, $121,794 for white residents, and $76,306 for Latinx residents. For the source data, see U.S. Census Bureau, American Community Survey 5-Year Data (2015- 2019), Table B19013B, Table B19013D, B19013H, and B19013I. 393
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7 Definition of Terms - Geographies
Neighborhood: In this report, “neighborhoods” are approximated by tracts.6 Tracts are statistical geographic units defined by the U.S. Census Bureau for the purposes of disseminating data. In the Bay Area, tracts contain on average 4,500 residents. Nearly all Bay Area jurisdictions contain at least two census tracts, with larger jurisdictions containing dozens of tracts.

Jurisdiction: Jurisdiction is used to refer to the 109 cities, towns, and unincorporated county areas that are members of ABAG. Though not all ABAG jurisdictions are cities, this report also uses the term “city” interchangeably with “jurisdiction” in some places.

Region: The region is the nine-county San Francisco Bay Area, which is comprised of Alameda County, Contra Costa County, Marin County, Napa County, San Francisco County, San Mateo County, Santa Clara County, Solano County, and Sonoma County.

6 Throughout this report, neighborhood level segregation measures are calculated using census tract data.

However, the racial dot maps in Figure 1 and Figure 5 use data from census blocks, while the income group dot maps in Figure 8 and Figure 12 use data from census block groups. These maps use data derived from a smaller geographic scale to better show spatial differences in where different groups live. Census block groups are subdivisions of census tracts, and census blocks are subdivisions of block groups. In the Bay Area, block groups contain on average 1,500 people, while census blocks contain on average 95 people. 394
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8 2 RACIAL SEGREGATION IN CITY OF LOS ALTOS
Definition of Terms - Racial/Ethnic Groups
The U.S. Census Bureau classifies racial groups (e.g. white or Black/African American) separately from Hispanic/Latino ethnicity.7 This report combines U.S. Census Bureau definitions for race and ethnicity into the following racial groups:

White: Non-Hispanic white
Latinx: Hispanic or Latino of any race8
Black: Non-Hispanic Black/African American
Asian/Pacific Islander: Non-Hispanic Asian or Non-Hispanic Pacific Islander People of Color: All who are not non-Hispanic white (including people who identify as “some other race” or “two or more races”)9

2.1 Neighborhood Level Racial Segregation (within City of Los Altos) Racial dot maps are useful for visualizing how multiple racial groups are distributed within a specific geography. The racial dot map of Los Altos in Figure 1 below offers a visual representation of the spatial distribution of racial groups within the jurisdiction. Generally, when the distribution of dots does not suggest patterns or clustering, segregation measures tend to be lower. Conversely, when clusters of certain groups are apparent on a racial dot map, segregation measures may be higher.

7 More information about the Census Bureau’s definitions of racial groups is available here:
https://www.census.gov/topics/population/race/about.html. 8 The term Hispanic has historically been used to describe people from numerous Central American, South American, and Caribbean countries. In recent years, the term Latino or Latinx has become preferred. This report generally uses Latinx to refer to this racial/ethnic group. 9 Given the uncertainty in the data for population size estimates for racial and ethnic groups not included in the Latinx, Black, or Asian/Pacific Islander categories, this report only analyzes these racial groups in the aggregate People of Color category.
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9 Figure 1: Racial Dot Map of Los Altos (2020)
Universe: Population. Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: The plot shows the racial distribution at the census block level for City of Los Altos and vicinity. Dots in each census block are randomly placed and should not be construed as actual placement of people.

There are many ways to quantitatively measure segregation. Each measure captures a different aspect of the ways in which groups are divided within a community. One way to measure segregation is by using an isolation index:
• The isolation index compares each neighborhood’s composition to the jurisdiction’s demographics as a whole.
• This index ranges from 0 to 1. Higher values indicate that a particular group is more isolated from other groups.
• Isolation indices indicate the potential for contact between different groups. The index can be interpreted as the experience of the average member of that group. For example, if the isolation index is .65 for Latinx residents in a city, then the average Latinx resident in that city lives in a neighborhood that is 65% Latinx.

Within City of Los Altos the most isolated racial group is white residents. Los Altos’s isolation index of

0.530 for white residents means that the average white resident lives in a neighborhood that is 53.0% white. Other racial groups are less isolated, meaning they may be more likely to encounter other racial groups in their neighborhoods. The isolation index values for all racial groups in Los Altos for the years 2000, 2010, and 2020 can be found in Table 1 below. Among all racial groups in this jurisdiction, the white population’s isolation index has changed the most over time, becoming less segregated from other racial groups between 2000 and 2020.
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10 The “Bay Area Average” column in this table provides the average isolation index value across Bay Area jurisdictions for different racial groups in 2020.10 The data in this column can be used as a comparison to provide context for the levels of segregation experienced by racial groups in this jurisdiction. For example, Table 1 indicates the average isolation index value for white residents across all Bay Area jurisdictions is 0.491, meaning that in the average Bay Area jurisdiction a white resident lives in a neighborhood that is 49.1% white.

Table 1: Racial Isolation Index Values for Segregation within Los Altos Los Altos Bay Area
Average
Race 2000 2010 2020 2020
Asian/Pacific Islander 0.167 0.247 0.358 0.245
Black/African American 0.005 0.005 0.008 0.053
Latinx 0.034 0.042 0.053 0.251
White 0.784 0.682 0.530 0.491
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Figure 2 below shows how racial isolation index values in Los Altos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each racial group, the spread of dots represents the range of isolation index values among Bay Area jurisdictions.

Additionally, the black line within each racial group notes the isolation index value for that group in City of Los Altos, and each dashed red line represents the Bay Area average for the isolation index for that group. Local staff can use this chart to contextualize how segregation levels for racial groups in their jurisdiction compare to other jurisdictions in the region.

10 This average only includes the 104 jurisdictions that have more than one census tract, which is true for all comparisons of Bay Area jurisdictions’ segregation measures in this report. The segregation measures in this report are calculated by comparing the demographics of a jurisdiction’s census tracts to the jurisdiction’s demographics, and such calculations cannot be made for the five jurisdictions with only one census tract (Brisbane, Calistoga, Portola Valley, Rio Vista, and Yountville).
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11 Figure 2: Racial Isolation Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Another way to measure segregation is by using a dissimilarity index:
• This index measures how evenly any two groups are distributed across neighborhoods relative to their representation in a city overall. The dissimilarity index at the jurisdiction level can be interpreted as the share of one group that would have to move neighborhoods to create perfect integration for these two groups.
• The dissimilarity index ranges from 0 to 1. Higher values indicate that groups are more unevenly distributed (e.g. they tend to live in different neighborhoods). 398
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12 Dissimilarity Index Guidance for Cities with Small Racial Group Populations The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if that group represents approximately less than 5% of the jurisdiction’s total population.

HCD’s AFFH guidance requires the Housing Element to include the dissimilarity index values for racial groups, but also offers flexibility in emphasizing the importance of various measures. ABAG/MTC recommends that when cities have population groups that are less than 5% of the jurisdiction’s population (see Table 4), jurisdiction staff use the isolation index or Thiel’s H-Index to gain a more accurate understanding of their jurisdiction’s neighborhood-level segregation patterns (intra-city segregation).

If a jurisdiction has a very small population of a racial group, this indicates that segregation between the jurisdiction and the region (inter-city segregation) is likely to be an important feature of the jurisdiction’s segregation patterns.

In City of Los Altos, the Latinx group is 4.9 percent of the population, and the Black/African American group is 0.6 percent of the population - so staff should be aware of this small population size when evaluating dissimilarity index values involving these groups.

Table 2 below provides the dissimilarity index values indicating the level of segregation in Los Altos between white residents and residents who are Black, Latinx, or Asian/Pacific Islander. The table also provides the dissimilarity index between white residents and all residents of color in the jurisdiction, and all dissimilarity index values are shown across three time periods (2000, 2010, and 2020).

In Los Altos the highest segregation is between Black and white residents (see Table 2). Los Altos’s Black /white dissimilarity index of 0.124 means that 12.4% of Black (or white) residents would need to move to a different neighborhood to create perfect integration between Black residents and white residents. However, local jurisdiction staff should note that this dissimilarity index value is not a reliable data point due to small population size. See callout box above for more information.

The “Bay Area Average” column in this table provides the average dissimilarity index values for these racial group pairings across Bay Area jurisdictions in 2020. The data in this column can be used as a comparison to provide context for the levels of segregation between communities of color are from white residents in this jurisdiction.
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13 For example, Table 2 indicates that the average Latinx/white dissimilarity index for a Bay Area jurisdiction is 0.207, so on average 20.7% of Latinx (or white residents) in a Bay Area jurisdiction would need to move to a different neighborhood within the jurisdiction to create perfect integration between Latinx and white residents in that jurisdiction.

Table 2: Racial Dissimilarity Index Values for Segregation within Los Altos Los Altos Bay Area
Average
Race 2000 2010 2020 2020
Asian/Pacific Islander vs. White 0.126 0.086 0.068 0.185 Black/African American vs. White 0.177* 0.144* 0.124* 0.244 Latinx vs. White 0.138* 0.120* 0.089* 0.207
People of Color vs. White 0.113 0.080 0.064 0.168
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Note: If a number is marked with an asterisk (*), it indicates that the index is based on a racial group making up less than 5 percent of the jurisdiction population, leading to unreliable numbers.

Figure 3 below shows how dissimilarity index values in City of Los Altos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each racial group pairing, the spread of dots represents the range of dissimilarity index values among Bay Area jurisdictions. Additionally, the black line within each racial group pairing notes the dissimilarity index value in Los Altos, and each dashed red line represents the Bay Area average for the dissimilarity index for that pairing. Similar to Figure 2, local staff can use this chart to contextualize how segregation levels between white residents and communities of color in their jurisdiction compare to the rest of the region. However, staff should be mindful of whether a racial group in their jurisdiction has a small population (approximately less than 5% of the jurisdiction’s population), as the dissimilarity index value is less reliable for small populations.
400
Agenda Item # 3.
14 Figure 3: Racial Dissimilarity Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if that group represents approximately less than 5% of the jurisdiction’s total population. ABAG/MTC recommends that when cities have population groups that are less than 5% of the jurisdiction’s population (see Table 4), jurisdiction staff could focus on the isolation index or Thiel’s H-Index to gain a more accurate understanding of neighborhood-level racial segregation in their jurisdiction.

The Theil’s H Index can be used to measure segregation between all groups within a jurisdiction:
• This index measures how diverse each neighborhood is compared to the diversity of the whole city. Neighborhoods are weighted by their size, so that larger neighborhoods play a more significant role in determining the total measure of segregation. • The index ranges from 0 to 1. A Theil’s H Index value of 0 would mean all neighborhoods within a city have the same demographics as the whole city. A value of 1 would mean each group lives exclusively in their own, separate neighborhood.
• For jurisdictions with a high degree of diversity (multiple racial groups comprise more than 10% of the population), Theil’s H offers the clearest summary of overall segregation.

The Theil’s H Index values for neighborhood racial segregation in Los Altos for the years 2000, 2010, and 2020 can be found in Table 3 below. The “Bay Area Average” column in the table provides the average Theil’s H Index across Bay Area jurisdictions in 2020. Between 2010 and 2020, the Theil’s H Index for racial segregation in Los Altos declined, suggesting that there is now less neighborhood level racial segregation within the jurisdiction. In 2020, the Theil’s H Index for racial segregation in Los Altos 401
Agenda Item # 3.
15 was lower than the average value for Bay Area jurisdictions, indicating that neighborhood level racial segregation in Los Altos is less than in the average Bay Area city.

Table 3: Theil’s H Index Values for Racial Segregation within Los Altos Los Altos Bay Area
Average
Index 2000 2010 2020 2020
Theil's H Multi-racial 0.012 0.009 0.006 0.042
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Figure 4 below shows how Theil’s H index values for racial segregation in Los Altos compare to values in other Bay Area jurisdictions in 2020. In this chart, each dot represents a Bay Area jurisdiction.

Additionally, the black line notes the Theil’s H index value for neighborhood racial segregation in Los Altos, and the dashed red line represents the average Theil’s H index value across Bay Area jurisdictions. Local staff can use this chart to compare how neighborhood racial segregation levels in their jurisdiction compare to other jurisdictions in the region.

Figure 4: Theil’s H Index Values for Racial Segregation in Los Altos Compared to Other Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. 402
Agenda Item # 3.
16 2.2 Regional Racial Segregation (between Los Altos and other jurisdictions)
At the regional level, segregation is measured between cities instead of between neighborhoods. Racial dot maps are not only useful for examining neighborhood racial segregation within a jurisdiction, but these maps can also be used to explore the racial demographic differences between different jurisdictions in the region. Figure 5 below presents a racial dot map showing the spatial distribution of racial groups in Los Altos as well as in nearby Bay Area cities.

Figure 5: Racial Dot Map of Los Altos and Surrounding Areas (2020) Universe: Population.

Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: The plot shows the racial distribution at the census block level for City of Los Altos and vicinity. Dots in each census block are randomly placed and should not be construed as actual placement of people.

To understand how each city contributes to the total segregation of the Bay Area, one can look at the difference in the racial composition of a jurisdiction compared to the racial composition of the region as a whole. The racial demographics in Los Altos for the years 2000, 2010, and 2020 can be found in Table 4 below. The table also provides the racial composition of the nine-county Bay Area. As of 2020, Los Altos has a higher share of white residents than the Bay Area as a whole, a lower share of Latinx residents, a lower share of Black residents, and a higher share of Asian/Pacific Islander residents. 403
Agenda Item # 3.
17 Table 4: Population by Racial Group, Los Altos and the Region Los Altos Bay Area
Race 2000 2010 2020 2020
Asian/Pacific Islander 15.4% 23.6% 35.4% 28.2%
Black/African American 0.5% 0.5% 0.6% 5.6%
Latinx 3.0% 3.9% 4.9% 24.4%
Other or Multiple Races 3.0% 4.2% 6.6% 5.9%
White 78.2% 67.8% 52.6% 35.8%
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Figure 6 below compares the racial demographics in Los Altos to those of all 109 Bay Area jurisdictions.11 In this chart, each dot represents a Bay Area jurisdiction. For each racial group, the spread of dots represents the range of that group’s representation among Bay Area jurisdictions.

Additionally, the black line within each racial group notes the percentage of the population of City of Los Altos represented by that group and how that percentage ranks among all 109 jurisdictions. Local staff can use this chart to compare the representation of different racial groups in their jurisdiction to those groups’ representation in other jurisdictions in the region, which can indicate the extent of segregation between this jurisdiction and the region.

11 While comparisons of segregation measures are made only using the 104 jurisdictions with more than one census tract, this comparison of jurisdiction level demographic data can be made using all 109 jurisdictions. 404
Agenda Item # 3.
18 Figure 6: Racial Demographics of Los Altos Compared to All Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

The map in Figure 7 below also illustrates regional racial segregation between Los Altos and other jurisdictions. This map demonstrates how the percentage of people of color in Los Altos and surrounding jurisdictions compares to the Bay Area as a whole:
• Jurisdictions shaded orange have a share of people of color that is less than the Bay Area as a whole, and the degree of difference is greater than five percentage points. • Jurisdictions shaded white have a share of people of color comparable to the regional percentage of people of color (within five percentage points). • Jurisdictions shaded grey have a share of people of color that is more than five percentage points greater than the regional percentage of people of color. 405
Agenda Item # 3.
19 Figure 7: Comparing the Share of People of Color in Los Altos and Vicinity to the Bay Area (2020)
Universe: Population.

Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: People of color refer to persons not identifying as non-Hispanic white. The nine-county Bay Area is the reference region for this map.

Segregation between jurisdictions in the region can also be analyzed by calculating regional values for the segregation indices discussed previously. Table 5 presents dissimilarity index, isolation index, and Theil’s H index values for racial segregation for the entire nine-county Bay Area in 2010 and 2020. In the previous section of this report focused on neighborhood level racial segregation, these indices were calculated by comparing the racial demographics of the census tracts within a jurisdiction to the demographics of the jurisdiction as a whole. In Table 5, these measures are calculated by comparing the racial demographics of local jurisdictions to the region’s racial makeup. For example, looking at the 2020 data, Table 5 shows the white isolation index value for the region is 0.429, meaning that on average white Bay Area residents live in a jurisdiction that is 42.9% white in 2020. An example of regional dissimilarity index values in Table 5 is the Black/white dissimilarity index value of 0.459, which means that across the region 45.9% of Black (or white) residents would need to move to a different jurisdiction to evenly distribute Black and white residents across Bay Area jurisdictions. The dissimilarity index values in Table 5 reflect recommendations made in HCD’s AFFH guidance for calculating dissimilarity at the region level.12 The regional value for the Theil’s H index measures how

12 For more information on HCD’s recommendations regarding data considerations for analyzing integration and segregation patterns, see page 31 of the AFFH Guidance Memo. 406
Agenda Item # 3.
20 diverse each Bay Area jurisdiction is compared to the racial diversity of the whole region. A Theil’s H Index value of 0 would mean all jurisdictions within the Bay Area have the same racial demographics as the entire region, while a value of 1 would mean each racial group lives exclusively in their own separate jurisdiction. The regional Theil’s H index value for racial segregation decreased slightly between 2010 and 2020, meaning that racial groups in the Bay Area are now slightly less separated by the borders between jurisdictions.

Table 5: Regional Racial Segregation Measures
Index Group 2010 2020
Isolation Index Regional Level
Asian/Pacific Islander 0.317 0.378
Black/African American 0.144 0.118
Latinx 0.283 0.291
White 0.496 0.429
People of Color 0.629 0.682
Dissimilarity Index Regional Level
Asian/Pacific Islander vs. White 0.384 0.369
Black/African American vs. White 0.475 0.459
Latinx vs. White 0.301 0.297
People of Color vs. White 0.296 0.293
Theil's H Multi-racial All Racial Groups 0.103 0.097
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4. 407
Agenda Item # 3.
21 3 INCOME SEGREGATION IN CITY OF LOS ALTOS
Definition of Terms - Income Groups
When analyzing segregation by income, this report uses income group designations consistent with the Regional Housing Needs Allocation and the Housing Element:

Very low-income: individuals earning less than 50% of Area Median Income (AMI)
Low-income: individuals earning 50%-80% of AMI
Moderate-income: individuals earning 80%-120% of AMI
Above moderate-income: individuals earning 120% or more of AMI Additionally, this report uses the term “lower-income” to refer to all people who earn less than 80% of AMI, which includes both low-income and very low-income individuals.

The income groups described above are based on U.S. Department of Housing and Urban Development (HUD) calculations for AMI. HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and VallejoFairfield Metro Area (Solano County).

The income categories used in this report are based on the AMI for the HUD metro area where this jurisdiction is located.

3.1 Neighborhood Level Income Segregation (within Los Altos) Income segregation can be measured using similar indices as racial segregation. Income dot maps, similar to the racial dot maps shown in Figures 1 and 5, are useful for visualizing segregation between multiple income groups at the same time. The income dot map of Los Altos in Figure 8 below offers a visual representation of the spatial distribution of income groups within the jurisdiction. As with the racial dot maps, when the dots show lack of a pattern or clustering, income segregation measures tend to be lower, and conversely, when clusters are apparent, the segregation measures may be higher as well.
408
Agenda Item # 3.
22 Figure 8: Income Dot Map of Los Altos (2015)
Universe: Population.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

Note: The plot shows the income group distribution at the census block group level for City of Los Altos and vicinity. Dots in each block group are randomly placed and should not be construed as actual placement of individuals.

The isolation index values for all income groups in Los Altos for the years 2010 and 2015 can be found in Table 6 below.13 Above Moderate-income residents are the most isolated income group in Los Altos.

Los Altos’s isolation index of 0.758 for these residents means that the average Above Moderate-income resident in Los Altos lives in a neighborhood that is 75.8% Above Moderate-income. Among all income groups, the Above Moderate-income population’s isolation index has changed the most over time, becoming less segregated from other income groups between 2010 and 2015.

Similar to the tables presented earlier for neighborhood racial segregation, the “Bay Area Average” column in Table 6 provides the average isolation index value across Bay Area jurisdictions for different income groups in 2015. The data in this column can be used as a comparison to provide context for the levels of segregation experienced by income groups in this jurisdiction. For example, Table 6 indicates the average isolation index value for very low-income residents across Bay Area jurisdictions is 0.269,

13 This report presents data for income segregation for the years 2010 and 2015, which is different than the time periods used for racial segregation. This deviation stems from the data source recommended for income segregation calculations in HCD’s AFFH Guidelines. This data source most recently updated with data from the 2011-2015 American Community Survey 5-year estimates. For more information on HCD’s recommendations for calculating income segregation, see page 32 of HCD’s AFFH Guidelines. 409
Agenda Item # 3.
23 meaning that in the average Bay Area jurisdiction a very low-income resident lives in a neighborhood that is 26.9% very low-income.

Table 6: Income Group Isolation Index Values for Segregation within Los Altos Los Altos Bay Area
Average
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 0.090 0.099 0.269
Low-Income (50%-80% AMI) 0.058 0.053 0.145
Moderate-Income (80%-120% AMI) 0.090 0.109 0.183
Above Moderate-Income (>120% AMI) 0.803 0.758 0.507
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

Figure 9 below shows how income group isolation index values in Los Altos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each income group, the spread of dots represents the range of isolation index values among Bay Area jurisdictions.

Additionally, the black line within each income group notes the isolation index value for that group in Los Altos, and each dashed red line represents the Bay Area average for the isolation index for that group. Local staff can use this chart to contextualize how segregation levels for income groups in their jurisdiction compare to the rest of the region.
410
Agenda Item # 3.
24 Figure 9: Income Group Isolation Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

Table 7 below provides the dissimilarity index values indicating the level of segregation in Los Altos between residents who are lower-income (earning less than 80% of AMI) and those who are not lowerincome (earning above 80% of AMI). This data aligns with the requirements described in HCD’s AFFH Guidance Memo for identifying dissimilarity for lower-income households.14 Segregation in Los Altos between lower-income residents and residents who are not lower-income decreased between 2010 and 2015. Additionally, Table 7 shows dissimilarity index values for the level of segregation in Albany between residents who are very low-income (earning less than 50% of AMI) and those who are above moderate-income (earning above 120% of AMI). This supplementary data point provides additional nuance to an analysis of income segregation, as this index value indicates the extent to which a jurisdiction’s lowest and highest income residents live in separate neighborhoods.

Similar to other tables in this report, the “Bay Area Average” column shows the average dissimilarity index values for these income group pairings across Bay Area jurisdictions in 2015. For example, Table 7 indicates that the average dissimilarity index between lower-income residents and other residents in a Bay Area jurisdiction is 0.198, so on average 19.8% of lower-income residents in a Bay Area jurisdiction would need to move to a different neighborhood within the jurisdiction to create perfect income group integration in that jurisdiction.

14 For more information, see page 32 of HCD’s AFFH Guidance Memo. 411
Agenda Item # 3.
25 In 2015, the income segregation in Los Altos between lower-income residents and other residents was lower than the average value for Bay Area jurisdictions (See Table 7). This means that the lowerincome residents are less segregated from other residents within Los Altos compared to other Jurisdictions in the region.

Table 7: Income Group Dissimilarity Index Values for Segregation within Los Altos
Los Altos Bay Area
Average
Income Group 2010 2015 2015
Below 80% AMI vs. Above 80% AMI 0.201 0.120 0.198
Below 50% AMI vs. Above 120% AMI 0.187 0.152 0.253
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

Figure 10 below shows how dissimilarity index values for income segregation in Los Altos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each income group pairing, the spread of dots represents the range of dissimilarity index values among Bay Area jurisdictions. Additionally, the black line within each income group pairing notes the dissimilarity index value in Los Altos, and each dashed red line represents the Bay Area average for the dissimilarity index for that pairing. Local staff can use this chart to contextualize how segregation levels between lower-income residents and wealthier residents in their jurisdiction compared to the rest of the region.
412
Agenda Item # 3.
26 Figure 10: Income Group Dissimilarity Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

The Theil’s H Index values for neighborhood income group segregation in Los Altos for the years 2010 and 2015 can be found in Table 8 below. The “Bay Area Average” column in this table provides the average Theil’s H Index value across Bay Area jurisdictions for different income groups in 2015. By 2015, the Theil’s H Index value for income segregation in Los Altos was less than it had been in 2010. In 2015, the Theil’s H Index value for income group segregation in Los Altos was lower than the average value for Bay Area jurisdictions, indicating there is less neighborhood level income segregation in Los Altos than in the average Bay Area city.

Table 8: Theil’s H Index Values for Income Segregation within Los Altos Los Altos Bay Area
Average
Index 2010 2015 2015
Theil's H Multi-income 0.029 0.012 0.043
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data. 413
Agenda Item # 3.
27 Figure 11 below shows how Theil’s H index values for income group segregation in Los Altos compare to values in other Bay Area jurisdictions in 2015. In this chart, each dot represents a Bay Area jurisdiction.

Additionally, the black line notes the Theil’s H index value for income group segregation in Los Altos, and the dashed red line represents the average Theil’s H index value across Bay Area jurisdictions.

Local staff can use this chart to compare how neighborhood income group segregation levels in their jurisdiction compare to other jurisdictions in the region.

Figure 11: Income Group Theil’s H Index Values for Los Altos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

3.2 Regional Income Segregation (between Los Altos and other jurisdictions)
At the regional level, segregation is measured between jurisdictions instead of between neighborhoods.

Income dot maps are not only useful for examining neighborhood income segregation within a jurisdiction, but these maps can also be used to explore income demographic differences between jurisdictions in the region. Figure 12 below presents an income dot map showing the spatial distribution of income groups in Los Altos as well as in nearby Bay Area jurisdictions. 414
Agenda Item # 3.
28 Figure 12: Income Dot Map of Los Altos and Surrounding Areas (2015) Universe: Population.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

Note: The plot shows the income group distribution at the census block group level for City of Los Altos and vicinity. Dots in each block group are randomly placed and should not be construed as actual placement of individuals.

When looking at income segregation between jurisdictions in the Bay Area, one can examine how Los Altos differs from the region. The income demographics in Los Altos for the years 2010 and 2015 can be found in Table 9 below. The table also provides the income composition of the nine-county Bay Area in 2015. As of that year, Los Altos had a lower share of very low-income residents than the Bay Area as a whole, a lower share of low-income residents, a lower share of moderate-income residents, and a higher share of above moderate-income residents.

Table 9: Population by Income Group, Los Altos and the Region Los Altos Bay Area
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 7.86% 9.3% 28.7%
Low-Income (50%-80% AMI) 4.4% 4.84% 14.3%
Moderate-Income (80%-120% AMI) 7.96% 10.43% 17.6%
Above Moderate-Income (>120% AMI) 79.78% 75.42% 39.4%
415
Agenda Item # 3.
29 Universe: Population.

Source: Data for 2015 is from Housing U.S. Department of and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

Figure 13 below compares the income demographics in Los Altos to other Bay Area jurisdictions.15 Like the chart in Figure 3, each dot represents a Bay Area jurisdiction. For each income group, the spread of dots represents the range of that group’s representation among Bay Area jurisdictions. The smallest range is among jurisdictions’ moderate-income populations, while Bay Area jurisdictions vary the most in the share of their population that is above moderate-income. Additionally, the black lines within each income group note the percentage of Los Altos population represented by that group and how that percentage ranks among other jurisdictions. Local staff can use this chart to compare the representation of different income groups in their jurisdiction to those groups’ representation in other jurisdictions in the region, which can indicate the extent of segregation between this jurisdiction and the region.

Figure 13: Income Demographics of Los Altos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

15 While comparisons of segregation measures are made only using the 104 jurisdictions with more than one census tract, this comparison of jurisdiction level demographic data can be made using all 109 jurisdictions. 416
Agenda Item # 3.
30 Income segregation between jurisdictions in the region can also be analyzed by calculating regional values for the segregation indices discussed previously. Similar to the regional racial segregation measures shown in Table 5, Table 10 presents dissimilarity index, isolation index, and Theil’s H index values for income segregation for the entire nine-county Bay Area in 2010 and 2015. In the previous section of this report focused on neighborhood level income segregation, segregation indices were calculated by comparing the income demographics of the census tracts within a jurisdiction to the demographics of the jurisdiction as a whole. In Table 10, these measures are calculated by comparing the income demographics of local jurisdictions to the region’s income group makeup. For example, looking at 2015 data, Table 10 shows the regional isolation index value for very low-income residents is

0.315 for 2015, meaning that on average very low-income Bay Area residents live in a jurisdiction that is 31.5% very low-income. The regional dissimilarity index for lower-income residents and other residents is 0.194 in 2015, which means that across the region 19.4% of lower-income residents would need to move to a different jurisdiction to create perfect income group integration in the Bay Area as a whole. The regional value for the Theil’s H index measures how diverse each Bay Area jurisdiction is compared to the income group diversity of the whole region. A Theil’s H Index value of 0 would mean all jurisdictions within the Bay Area have the same income demographics as the entire region, while a value of 1 would mean each income group lives exclusively in their own separate jurisdiction. The regional Theil’s H index value for income segregation decreased slightly between 2010 and 2015, meaning that income groups in the Bay Area are now slightly less separated by the borders between jurisdictions.

Table 10: Regional Income Segregation Measures
Index Group 2010 2015
Isolation Index Regional Level
Very Low-Income (<50% AMI) 0.277 0.315
Low-Income (50%-80% AMI) 0.157 0.154
Moderate-Income (80%-120% AMI) 0.185 0.180
Above Moderate-Income (>120% AMI) 0.467 0.435
Dissimilarity Index Regional Level
Below 80% AMI vs. Above 80% AMI 0.186 0.194
Below 50% AMI vs. Above 120% AMI 0.238 0.248
Theil's H Multi-income All Income Groups 0.034 0.032
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data. 417
Agenda Item # 3.
31 4 APPENDIX 1: SUMMARY OF FINDINGS

4.1 Segregation in City of Los Altos
• The isolation index measures the segregation of a single group, and the dissimilarity index measures segregation between two different groups. The Theil’s H-Index can be used to measure segregation between all racial or income groups across the city at once. • As of 2020, white residents are the most segregated compared to other racial groups in Los Altos, as measured by the isolation index. White residents live in neighborhoods where they are less likely to come into contact with other racial groups. • Among all racial groups, the white population’s isolation index value has changed the most over time, becoming less segregated from other racial groups between 2000 and 2020. • According to the dissimilarity index, within Los Altos the highest level of racial segregation is between Black and white residents.16 However, local jurisdiction staff should note that this dissimilarity index value is not a reliable data point due to small population size. • According to the Theil’s H-Index, neighborhood racial segregation in Los Altos declined between 2010 and 2020. Neighborhood income segregation declined between 2010 and 2015. • Above Moderate-income residents are the most segregated compared to other income groups in Los Altos. Above Moderate-income residents live in neighborhoods where they are less likely to encounter residents of other income groups.
• Among all income groups, the Above Moderate-income population’s segregation measure has changed the most over time, becoming less segregated from other income groups between 2010 and 2015.
• According to the dissimilarity index, segregation between lower-income residents and residents who are not lower-income has decreased between 2010 and 2015. In 2015, the income segregation in Los Altos between lower-income residents and other residents was lower than the average value for Bay Area jurisdictions.

4.2 Segregation Between City of Los Altos and Other jurisdictions in the Bay Area Region
• Los Altos has a higher share of white residents than other jurisdictions in the Bay Area as a whole, a lower share of Latinx residents, a lower share of Black residents, and a higher share of Asian/Pacific Islander residents.

16 The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if that group represents approximately less than 5% of the jurisdiction’s total population. ABAG/MTC recommends that when cities have population groups that are less than 5% of the jurisdiction’s population (see Table 15 in Appendix 2), jurisdiction staff could focus on the isolation index or Thiel’s H-Index to gain a more accurate understanding of neighborhood-level racial segregation in their jurisdiction. 418
Agenda Item # 3.
32 • Regarding income groups, Los Altos has a lower share of very low-income residents than other jurisdictions in the Bay Area as a whole, a lower share of low-income residents, a lower share of moderate-income residents, and a higher share of above moderate-income residents. 419
Agenda Item # 3.
33 5 APPENDIX 2: SEGREGATION DATA
Appendix 2 combines tabular data presented throughout this report into a more condensed format. This data compilation is intended to enable local jurisdiction staff and their consultants to easily reference this data and re-use the data in the Housing Element or other relevant documents/analyses.

Table 11 in this appendix combines data from Table 1, Table 2, and Table 3 in the body of the report.

Table 12 in this appendix combines data from Table 6, Table 7, and Table 8 in the body of the report.

Table 13 represents a duplication of Table 5 in the body of the report; Table 14 represents a duplication of Table 10 in the body of the report; Table 15 in this appendix represents a duplication of Table 4 in the body of the report, while Table 16 represents a duplication of Table 9 in the body of the report.

Table 11: Neighborhood Racial Segregation Levels in Los Altos Los Altos Bay Area
Average
Index Race 2000 2010 2020 2020
Isolation
Asian/Pacific Islander 0.167 0.247 0.358 0.245
Black/African American 0.005 0.005 0.008 0.053
Latinx 0.034 0.042 0.053 0.251
White 0.784 0.682 0.530 0.491
Dissimilarity
Asian/Pacific Islander vs. White 0.126 0.086 0.068 0.185 Black/African American vs. White 0.177* 0.144* 0.124* 0.244 Latinx vs. White 0.138* 0.120* 0.089* 0.207
People of Color vs. White 0.113 0.080 0.064 0.168
Theil's H Multi-racial All 0.012 0.009 0.006 0.042
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Note: If a number is marked with an asterisk (*), it indicates that the index is based on a racial group making up less than 5 percent of the jurisdiction population, leading to unreliable numbers. 420
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34 Table 12: Neighborhood Income Segregation Levels in Los Altos Los Altos Bay Area
Average
Index Income Group 2010 2015 2015
Isolation
Very Low-Income (<50% AMI) 0.090 0.099 0.269
Low-Income (50%-80% AMI) 0.058 0.053 0.145
Moderate-Income (80%-120% AMI) 0.090 0.109 0.183
Above Moderate-Income (>120% AMI) 0.803 0.758 0.507
Dissimilarity
Below 80% AMI vs. Above 80% AMI 0.201 0.120 0.198
Below 50% AMI vs. Above 120% AMI 0.187 0.152 0.253
Theil's H Multi-racial All 0.029 0.012 0.043
Universe: Population.

Source: Income data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data. 421
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35 Table 13: Regional Racial Segregation Measures
Index Group 2010 2020
Isolation Index Regional Level
Asian/Pacific Islander 0.317 0.378
Black/African American 0.144 0.118
Latinx 0.283 0.291
White 0.496 0.429
People of Color 0.629 0.682
Dissimilarity Index Regional Level
Asian/Pacific Islander vs. White 0.384 0.369
Black/African American vs. White 0.475 0.459
Latinx vs. White 0.301 0.297
People of Color vs. White 0.296 0.293
Theil's H Multi-racial All Racial Groups 0.103 0.097
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4.

Table 14: Regional Income Segregation Measures
Index Group 2010 2015
Isolation Index Regional Level
Very Low-Income (<50% AMI) 0.277 0.315
Low-Income (50%-80% AMI) 0.157 0.154
Moderate-Income (80%-120% AMI) 0.185 0.180
Above Moderate-Income (>120% AMI) 0.467 0.435
Dissimilarity Index Regional Level
Below 80% AMI vs. Above 80% AMI 0.186 0.194
Below 50% AMI vs. Above 120% AMI 0.238 0.248
Theil's H Multi-income All Income Groups 0.034 0.032
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data. 422
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36 Table 15: Population by Racial Group, Los Altos and the Region Los Altos Bay Area
Race 2000 2010 2020 2020
Asian/Pacific Islander 15.35% 23.64% 35.36% 35.8%
Black/African American 0.46% 0.47% 0.56% 5.6%
Latinx 2.97% 3.91% 4.86% 28.2%
Other or Multiple Races 3.02% 4.19% 6.63% 24.4%
White 78.2% 67.79% 52.58% 5.9%
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Table 16: Population by Income Group, Los Altos and the Region Los Altos Bay Area
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 7.86% 9.3% 28.7%
Low-Income (50%-80% AMI) 4.4% 4.84% 14.3%
Moderate-Income (80%-120% AMI) 7.96% 10.43% 17.6%
Above Moderate-Income (>120% AMI) 79.78% 75.42% 39.4%
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data. 423
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37 6 REFERENCES
Ananat, Elizabeth Oltmans. 2011. “The wrong side(s) of the tracks: The causal effects of racial segregation on urban poverty and inequality,” American Economic Journal: Applied Economics 3: 34-

66. Bayer, Patrick, Robert McMillan, and Kim S. Rueben. 2004. “What Drives Racial Segregation? New Evidence using Census Microdata,” Journal of Urban Economics 56(3): 514-535.

Burch, Traci. 2014. “The Old Jim Crow: Racial Residential Segregation and Imprisonment,” Law and Policy 36(3): 223-255.

Chetty, Raj and Nathanial Hendren. 2018. “The Impacts of Neighborhoods on Intergenerational Mobility I: Childhood Exposure Effects,” The Quarterly Journal of Economics 133(3):1107-1162 Cutler, David M., and Edward L. Glaeser. 1997. “Are ghettos good or bad?,” The Quarterly Journal of Economics 112(3): 827-72.

Lens, Michael and Paavo Monkkonen. 2016. “Do Strict Land Use Regulations Make Metropolitan Areas More Segregated by Income?,” Journal of the American Planning Association 82(1): 6–21.

Pendall, Rolf. 2000. “Local Land-Use Regulation and the Chain of Exclusion,” Journal of the American Planning Association 66(2): 125-142.

Rothstein, Richard. 2017. The Color of Law: A Forgotten History of how our Government Segregated America. New York: Liveright Publishing.

Sampson, Robert J. 2012. Great American city: Chicago and the enduring neighborhood effect.

Chicago: University of Chicago Press.

Sharkey, Patrick. 2013. Stuck in place: Urban neighborhoods and the end of progress toward racial equality. Chicago: University of Chicago Press.

Trounstine, Jessica. 2015. “Segregation and Inequality in Public Goods,” American Journal of Political Science 60(3): 709-725.

Trounstine, Jessica. 2018. Segregation by Design: Local Politics and Inequality in American Cities. New York: Cambridge University Press.
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Appendix G: Housing Resources
Contents
Appendix G: Housing Resources ................................................................. 1 Section G.1 Financial and Administrative Resources ............................................................... 2 G.1.1 Local Resources.................................................................................................... 2 G.1.2 Regional Resources .............................................................................................. 2 G.1.3 State Resources.................................................................................................... 6 G.1.4 Federal Resources ................................................................................................ 9 Section G.2 Opportunities for Energy Conservation ...............................................................10 G.2.1 Silicon Valley Clean Energy Resources ..............................................................11 G.2.2 Pacific Gas and Electric Resources ....................................................................12 G.2.3 State Energy Resources .....................................................................................12 G.2.4 Federal Energy Resources..................................................................................13 426
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G-2 | City of Los Altos Housing Resources
Section G.1 Financial and Administrative Resources
G.1.1 Local Resources
Below Market Rate (BMR) Housing Rental Program
Alta Housing administers the City of Los Altos’ Below Market Rate (BMR) Housing Rental Program, a program that provides rental apartments in Los Altos for low and moderate-income households. BMR rental units are leased at rates below prevailing market rents, and rent increases are subject to certain limitations. BMR renters are selected from a waiting list and must meet special income and other eligibility requirements. There are currently 51 BMR rental units managed by Alta Housing for the City.

Inclusionary Housing Program
Multi-family projects that propose five or more market-rate units in Los Altos must include some affordable housing units under the City’s Zoning Code (Municipal Code Chapter 14.28); this is the primary source of affordable housing in Los Altos. Affordable housing units are deed restricted to moderate, low, and very low-income levels. The City has 54 BMR ownership units, for a total of 105 deed restricted BMR units, including the 51 rental units (noted above), managed by Alta Housing for the City.

G.1.2 Regional Resources
Santa Clara County
• Measure A: In November 2016, Santa Clara County voters approved Measure A – the $950 million affordable housing bond. The housing bond provides the County with an unprecedented opportunity to partner with cities, residents, and the affordable and supportive housing community to significantly address the housing needs of the community’s poorest and most vulnerable residents. It will provide affordable housing for vulnerable populations including veterans, seniors, the disabled, low and moderateincome individuals or families, foster youth, victims of abuse, the homeless and individuals suffering from mental health or substance abuse illnesses. The bond proceeds would contribute to the creation and/or preservation of approximately 4,800 affordable housing units. As of March 31, 2021, $607.85 million has been allocated to various Measure A programs, including $570.95 million toward 46 housing projects throughout Santa Clara County (no Measure A housing projects have currently been approved for Los Altos). $25 million has been committed to the first-time homebuyer loan program, and $11.9 million has been committed to a supportive housing fund for predevelopment loans. As of March 2021, $342.15 million approved by Measure A has yet to be allocated. Eligible applicants include non-profit organizations, tax-credit limited partnerships, or limited liability 427
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corporations, mission aligned for-profit affordable housing developers, public agencies, other local jurisdictions, and joint ventures of the above. • Empower Homebuyers County of Santa Clara Program: Empower Homebuyers SCC is a program of the County of Santa Clara administered by Housing Trust Silicon Valley. It provides down payment assistance loans to first-time homebuyers in the county and is funded by the 2016 Measure A Affordable Housing Bond. The program is aimed at assisting low to moderate income County residents – including employees at nonprofit organizations, teachers, healthcare professionals, County employees and others. The loan can be for up to 17 percent of a home’s purchase price – which means an additional three percent from a first-time homebuyer would reach a down payment of 20 percent.

Regardless of the amount borrowed, there are no monthly payments or interest with an Empower Homebuyers loan. The Empower loan plus a share of the appreciation on the home is repaid when the loan matures, or the homeowner decides to sell or refinance the mortgage.
• HomeFirst Homeless Helpline: HomeFirst’s Outreach team provides access to emergency shelter, showers, laundry, meals, medical services, case management, and employment training in Santa Clara County.
• Housing and Community Development Asset Management: The Santa Clara County Department of Office of Supportive Housing, Housing and Community Development Asset Management team oversees and monitors the operation and financial performance of the affordable and multifamily rental projects that have been developed with financial and other forms of support from the County of Santa Clara. These projects serve a variety of low-income populations: families, seniors, disabled individuals, veterans, chronically homeless people, transition-age youth, and people with HIV/AIDS, among others. The Asset Management Team's primary responsibility is to service loans and grants provided for these projects to various non-profit and for-profit organizations. The Team is also responsible for monitoring the compliance of each project with a host of obligations that borrowers and grantees agreed to as a condition of County’s financing/support. • Santa Clara County's Mortgage Credit Certificate (MCC) Program: This program provides income eligible first-time home buyers the opportunity to reduce the amount of federal income tax they owe each year they own and live in their home. The Mortgage Credit Certificate (MCC) assists a family in qualifying for a higher first mortgage with no effect on monthly expenses. Refinanced Mortgage Credit Certificates (RMCC) are also available when the homeowner refinances their original MCC Loan. A RMCC must be issued for each refinance for the homeowner to continue receiving their federal tax credit.

The estimated number of MCCs to be issued from the March 20, 2019, CDLAC allocation was 16. Funding for this program is provided by the California Debt Limit Allocation Committee (CDLAC).
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• Santa Clara County Shelter List: The County maintains a list of shelters for families with children, shelters for adults without children, and shelters for veterans on its Office of Supportive Housing website.
• Warming and Cooling Center Information: The County of Santa Clara Office of Supportive Housing works with service providers to open warming/cooling centers during inclement weather episodes (such as rain events, or extreme cold or heat events). In the event of an emergency, inclement weather episodes and shelter availability, or housingrelated issues, the Office of Supportive Housing has arranged with the County Office of Emergency Services to be able to send text messages to the homeless, service providers, and anyone else who has requested to receive the messages. The County Library located in Los Altos (13 South San Antonio Road) is identified as a warming center during regular Library business hours.

Santa Clara County Housing Authority
• Section 8 Chronically Homeless Direct Referral Program: SCCHA’s Chronically Homeless Direct Referral (CHDR) program is a locally designed voucher referral program for the chronically homeless population in Santa Clara County. A partnership between SCCHA and the County of Santa Clara ensures that chronically homeless families who receive vouchers are connected to supportive programs and case management services. • Section 8 Family Unification Program: The Family Unification Program (FUP) is a partnership between SCCHA and Santa Clara County through its Social Services Agency, Department of Family and Children Services (DFCS). FUP provides rental assistance for families whose lack of adequate housing is a primary factor in the placement of their children in out-of-home care or in the delay of their children returning home. SCCHA administers FUP Housing Choice Vouchers (HCV) rental assistance. DFCS refers FUPeligible families to SCCHA and provides case management and supportive services before and after the family is housed.
• Section 8 Family Self-Sufficiency: The Family Self Sufficiency (FSS) program provides case management and advocacy to current program participants in order to help them attain self-sufficiency goals. Families enroll and sign a five-year contract to participate in the program. After enrolling in the program, participants set goals such as finishing their education, obtaining job training, and/or employment. During the contract term, participants who increase their earned income can receive cash bonuses. When the family reports an increase in earned income, SCCHA calculates a monthly bonus amount that is deposited into an ‘escrow’ account which the family can receive upon program graduation. • Section 8 Homeownership Program: The Homeownership program is an optional U.S.

Department of Housing and Urban Development (HUD) program that permits housing authorities to assist Housing Choice Voucher (Section 8) households in the purchase of their first homes. Participants in this program receive housing assistance payments to use 429
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toward their homeownership expenses. SCCHA administers this program for current participants but no longer accepts new applications.
• Section 8 Housing Choice Voucher Program: The Housing Choice Voucher (Section 8) program is SCCHA’s largest rental assistance program with about 17,000 participants.

The “housing choice voucher” is a 100 percent federally funded rental subsidy for lowincome households living in privately owned rental units. SCCHA voucher holders in the Moving to Work (MTW) program pay 32 percent of their gross income toward rent (or a minimum rent of $50, whichever is higher), and the agency pays the balance of the rent directly to the landlords on behalf of the families. Voucher holders are also required to pay that portion of their lease contract rent that is above SCCHA’s payment standard for their unit size. Currently, there are six households in Los Altos participating in the Section 8 Housing Choice Voucher Program1.
• Section 8 Mainstream Voucher Program: The Mainstream Voucher program provides vouchers for low-income households that include a person(s) with disabilities. The program is designed to help tenants with disabilities live independently in the community. • Section 8 Moderate Rehabilitation Program: The Moderate Rehabilitation (Mod Rehab) program attaches Housing Choice Voucher (HCV) rental assistance to privately owned units that are rehabilitated. Under the Mod Rehab program, SCCHA enters into a Housing Assistance Payments contract with the property owner for a specified unit and for a specified term. Mod Rehab assistance is tied to the unit, as opposed to the tenant. A family who moves from a Mod Rehab unit is not eligible to receive tenant-based HCV assistance.

SCCHA administers this program for current Mod Rehab properties but no longer accepts new/additional units under this program.
• Section 8 Non-Elderly Disabled Program: The Non-Elderly Disabled (NED) program provides assistance to non-elderly persons with disabilities who are currently residing in long-term care facilities. This voucher program is intended to help participants leave the long-term care facility and live independently. The NED program is a partnership between SCCHA and the Silicon Valley Independent Living Center (SVILC). SVILC provides NED program applicant referrals, case management, and supportive services. • Section 8 Project-Based Voucher Program: The Project Based Voucher (PBV) program attaches the rental assistance voucher to private (including SCCHA-owned/operated) housing units. Under the PBV program, SCCHA enters into a Housing Assistance Payments contract with the property owner for specified units and for a specified term.

PBV units are leased to eligible low-income tenants from SCCHA’s PBV Waiting List or in some cases referred by the property owner. PBV rental assistance is contractually tied to 1 Santa Clara County Housing Authority, email correspondence with Ricardo Alvarez, Housing Programs Manager (March 14, 2022). 430
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G-6 | City of Los Altos Housing Resources
the unit, as opposed to the tenant. A family who moves from the project-based unit may be eligible to receive HCV (tenant-based) assistance, if available. • Section 8 VASH Program: The HUD-VASH program provides assistance to homeless veterans by combining rental assistance with case management and clinical services. The HUD-VASH program is a partnership between the Veterans Affairs Palo Alto Health Care System (VA Palo Alto) and SCCHA. The VA Palo Alto refers homeless veterans to the HUD-VASH program and provides case management, while SCCHA administers rental assistance to eligible veterans.

G.1.3 State Resources
• Affordable Housing and Sustainable Communities Program (AHSC): Administered by the Strategic Growth Council, this program provides grants and/or loans to fund landuse, housing, transportation, and land preservation projects that support infill and compact development that reduce greenhouse gas emissions.
• CalHome: HCD provides grants to local public agencies and non-profit housing developers to assist first-time homebuyers become or remain homeowners through deferred-payment loans. Funds can also be used to assist in the development of multipleunit homeownership programs. • California Emergency Solutions and Housing (CESH): This program provides funds for a variety of activities to assist persons experiencing or at risk of homelessness, such as housing relocation and stabilization services (including rental assistance), operating subsidies for permanent housing, flexible housing subsidies, emergency housing operating support, and homeless delivery systems.
• California Housing Finance Agency (CalHFA): CalHFA offers a variety of low-cost loan programs to support the development of affordable multi-family rental housing, mixedincome housing, and special needs housing. • California Housing Finance Agency (CalHFA), Mortgage Credit Certificate Program:

The MCC program is a homebuyer assistance program designed to help lower‐income families afford home ownership. The program allows home buyers to claim a dollar‐for‐ dollar tax credit for a portion of mortgage interest paid per year, up to $2,000. The remaining mortgage interest paid may still be calculated as an itemized deduction. • California Self-Help Housing Program (CSHHP): Provides grants for sponsor organizations that provide technical assistance for low and moderate-income families to build their homes with their own labor.
• Elderlink: A senior care referral service licensed by the Department of Public Health. This organization provides independent and free personalized senior care placement services to fully screened and approved nursing home, board and care, and assisted living facilities. 431
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• Golden State Acquisition Fund (GSAF): This $93 million fund provides low-cost financing aimed at supporting the creation and preservation of affordable housing across the state. GSAF makes up to five-year loans to developers for acquisition or preservation of affordable housing.
• Homekey: Homekey provides grants to acquire and rehabilitate a variety of housing types, such as hotels and residential care facilities, to serve people experiencing homelessness or who are also at risk of serious illness from COVID-19. • Housing for a Healthy California (HHC) Program: This program provides funding to deliver supportive housing opportunities to developers using the federal National Housing Trust Funds (NHTF) allocations for operating reserve grants and capital loans. The HHC program is intended to create supportive housing for individuals who are recipients of or eligible for health care provided through the California Department of Health Care Services’ Medi-Cal program.
• Housing Navigator’s Program: This grant program allocates funding to counties for the support of housing navigators to help young adults aged 18 to 21 years secure and maintain housing, with priority for individuals in the foster care system. • Infill Infrastructure Grant Program (IIG): This program promotes infill housing development by providing grant funding, in the form of gap assistance, for infrastructure improvements required for qualifying multi-family or mixed-use residential development. • Joe Serna, Jr. Farmworker Housing Grant (FWHG) Program: This program provides deferred payment loans for both owner-occupied and rental housing for agricultural workers, with a priority for lower income households.
• Local Housing Trust Fund (LHTF) Program: This program provides matching funds to local or regional housing trust funds for the creation, preservation, and rehabilitation of affordable housing, transitional housing, or emergency shelters. • Mills Act: The Mills Act is an economic incentive programs for the restoration and preservation of qualified historic buildings by private property owners. It grants local governments the authority to enter into contracts with owners of qualified historic properties who actively participate in the restoration and maintenance of their historic properties while receiving property tax relief. Los Altos administers a Mills Act program, which furthers housing affordability by reducing property taxes and preserving existing housing stock.
• Mobilehome Park Rehabilitation and Resident Ownership Program (MPRROP): This program provides financing to support the preservation of affordable mobilehome parks through conversion of the park to ownership or control by resident organizations, nonprofit housing sponsors, or local public entities.
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• Multifamily Housing Program (MHP): This program provides deferred payment loans for the construction, preservation, and rehabilitation of permanent and transitional rental housing for lower-income households.
• No Place Like Home Program: This program invests in the development of permanent supportive housing for persons who are in need of mental health services and are experiencing homelessness, chronic homelessness, or who are at risk of chronic homelessness.
• National Housing Trust Fund: This program provides deferred payment or forgivable loans for the construction of permanent housing for extremely low-income households.

The required affordability covenant is for 55 years.
• Permanent Local Housing Allocation (PLHA) Program: This program provides a permanent source of funding to all local governments in California to help cities and counties implement plans to increase affordable housing stock. Funding for this program is provided through a $75 recording fee on real estate transactions. • Predevelopment Loan Program (PDLP): This program provides financing to cover predevelopment costs to construct, preserve, or rehabilitate assisted housing. • Supportive Housing Multifamily Housing Program (SHMHP): This program provides low interest deferred loan payments to developers building affordable rental housing that contain supportive housing units.
• Transit-Oriented Development (TOD) Housing Program: This program provides lowinterest loans as gap financing for higher density affordable rental housing within onequarter mile of transit stations. Grants are also available to localities and transit agencies for infrastructure improvements necessary for the development of specified housing developments or to facilitate connections between these developments and the transit station. The maximum total award amount for a single project is $15 million. • Transitional Housing Program (THP): This program provides funding to counties for child welfare services agencies to help young adults aged 18 to 25 years find and maintain housing, with priority given to those formerly in the foster care or probation systems. • Veterans Housing and Homelessness Prevention Program (VHHP): This program supports the acquisition, construction, rehabilitation, and preservation of affordable multifamily housing for veterans and their families. 433
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G.1.4 Federal Resources
• Community Development Block Grant (CDBG): The Community Development Block Grant (CDBG) Program was created by the Housing and Community Development (HCD) Act of 1974. In the County of Santa Clara, the CDBG Program is operated by the Office of Supportive Housing. The County CDBG Program is federally funded by the United States Department of Housing and Urban Development (HUD) to assist lower-income and special needs persons to address housing and community development needs. The County of Santa Clara administers CDBG on behalf of the Unincorporated Areas of Santa Clara County and the Cities of Campbell, Los Altos, Los Altos Hills, Los Gatos, Monte Sereno, Morgan Hill, and Saratoga, also known as the Urban County Program. • Continuum of Care (CoC) Program: The Continuum of Care (CoC) Program is designed to promote communitywide commitment towards ending homelessness. It provides funding to nonprofits, state, and local governments to provide shelter and services to people experiencing homelessness.
• Emergency Solutions Grants (ESG) Program: This program provides funding for cities, counties, and states to engage homeless individuals and families living on the street; improve the number and quality of emergency shelters for homeless individuals and families; help operate these shelters; provide essential services to shelter residents; rapidly rehouse homeless individuals and families; and prevent families/individuals from becoming homeless.
• Home Investment Partnerships Program (HOME Program): The Home Investment Partnerships Program ("HOME Program") is federally funded by the United States Department of Housing and Urban Development (HUD). Participating jurisdictions may use HOME funds for a variety of housing activities, according to local housing needs.

Eligible uses of funds include tenant-based rental assistance; housing rehabilitation; assistance to homebuyers; and new construction of housing. HOME funding may also be used for site acquisition, site improvements, demolition, relocation, and other necessary and reasonable activities related to the development of non-luxury housing. Funds may not be used for public housing development, public housing operating costs, or for Section 8 tenant-based assistance, nor may they be used to provide non-federal matching contributions for other federal programs, for operating subsidies for rental housing, or for activities under the Low-Income Housing Preservation Act. The HOME Program is administered by the County of Santa Clara Office of Supportive Housing on behalf of the Urban County cities and the Cities of Cupertino, Gilroy, and Palo Alto. • Low-Income Housing Preservation and Residential Home Ownership Act (LIHPRHA): This program requires all eligible HUD Section 236 and Section 221(d) projects at risk of conversion to market-rate rentals from mortgage pre-payments be 434
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subject to LIHPRHA incentives, which include subsidies to guarantee an eight percent annual return on equity.
• Low-Income Housing Tax Credit: Administered through the California Tax Credit Allocation Committee (TCAC), the Low-Income Housing Tax Credit (LIHTC) subsidizes the acquisition, construction, and rehabilitation of affordable housing by providing a tax credit to construct or rehabilitate affordable rental housing for low-income households. • Section 108 Loan Guarantee Program: Allows CDBG entitlement jurisdictions to leverage their annual grant allocations to access low-cost financing for capital improvement projects. Eligible activities include housing, economic development, public facility, and infrastructure. This program is often used to catalyze private investment in underserved communities or as gap financing.
• Section 202 Supportive Housing for the Elderly Program: Provides an interest-free capital advance to cover the costs of construction, rehabilitation, or acquisition of very lowincome senior housing. The program is available to private, nonprofit sponsors; public sponsors are not eligible for the program.
• Section 811 Project Rental Assistance: HUD offers long-term project-based rental assistance through a NOFA published by the California Housing Finance Agency (CalHFA).
• U.S. Department of Agriculture (USDA) Housing Programs: These programs provide homeownership opportunities for individuals and below market-rate loans/grants to public and nonprofit organizations for new construction, preservation, or rehabilitation of farmworker/rural multi-family rental housing.
• Veterans Affairs Supportive Housing (VASH) Program: HUD-VASH is a collaborative program between HUD and VA combines HUD housing vouchers with VA supportive services to help veterans who are homeless and their families find and sustain permanent housing.

Section G.2 Opportunities for Energy Conservation
The cost of energy can greatly impact housing affordability, as energy costs can constitute a significant portion of total housing costs. High energy costs also particularly impact low-income households that are less likely to have the ability to cover increased expenses.

The City encourages energy conservation in all projects consistent with the California Building Code (CBC) and Municipal Code Chapters 12.22 and 12.26 (Energy Code and California Green Building Standards Code, respectively). The City’s website includes green building resources and informational handouts. Additionally, in 2013, the City adopted its Climate Action Plan (CAP). The CAP responds to the impacts of climate change through local actions that promote adaptation 435
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and resilience by reducing greenhouse gas (GHG) emissions. This will be done by implementing policies that relate to transportation, energy use, resource conservation, green communities, and municipal operations. Moreover, the City is currently modifying its CAP to prepare a Climate Action and Adaptation Plan (CAAP) to update its greenhouse gas inventory and evaluate its sources of impact in order to determine implementation actions to reduce emissions.

The City promotes various energy conservation programs, including the Bay Area Regional Energy Network (BayREN) and Property Assessed Clean Energy (PACE) Financing. BayREN is a collaboration of the nine counties that comprise the San Francisco Bay Area. BayREN provides regional-scale energy efficiency programs, services, and resources. BayREN is funded by utility ratepayer funds through the California Public Utilities Commission and other sources. PACE is a mechanism for property owners to finance renewable energy, energy efficiency, and water conservation improvements to their properties and repay the loan via an annual assessment on the owner’s property tax bill. This allows the financing to be extended over multiple years and also allows a home to be sold with that assessment assigned to the new owner. Unlike traditional forms of credit that are dependent on individual credit rating, PACE financing is primarily based on a property owner’s equity in the building.

G.2.1 Silicon Valley Clean Energy Resources
Silicon Valley Clean Energy (SVCE) is a public, not-for-profit community choice aggregation (CCA) electricity provider that serves 13 communities within Santa Clara County, including Los Altos. SVCE provides residential and commercial electricity customers with clean, carbon-free electricity options at competitive prices from sources like solar, wind, and hydropower. SVCE sources the electricity, while PG&E delivers it over existing utility lines, and provides maintenance, billing, and customer service. SVCE has several programs designed to serve low-income customers, including:
• Arrearage Management Plan (AMP): The AMP is a 12-month program that provides up to $8,000 of bill forgiveness to each eligible customer that owes at least $500 on their electricity bill (or $250 for gas-only customers) for more than 90 days. To be eligible for AMP, customers must also ne enrolled in California Alternative Rates for Energy (CARE) or Family Electric Rate Assistance (FERA).
• CARE (California Alternate Rates for Energy): The CARE program provides a 20 percent discount or more on monthly bills for qualified low- or fixed-income households and housing facilities. Qualifications are based on the number of people living in the home and total annual household income.
• FERA (Family Electric Rate Assistance): Family Electric Rate Assistance provides an 18 percent discount on electricity bills for large households of three or more people with low- to middle-income. Qualifications are based on household income guidelines. 436
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• On-Bill Credit: COVID-19 Customer Relief: SVCE provides a $100 credit for residential customers enrolled under California Alternative Rates for Energy (CARE) and Family Electric Rate Assistance as of May 10, 2020.
• Medical Baseline Allowance: SVCE Medical Baseline customers do not incur the typical Power Charge Indifference Adjustment (PCIA), a fee charge by PG&E, and therefore receive over 15 percent savings on their monthly electric bill. To qualify for Medical Baseline, a California-licensed physician must certify that a full-time resident in the home has a serious medical condition such being dependent on life-support equipment while at home.

G.2.2 Pacific Gas and Electric Resources
Pacific Gas and Electric (PG&E) also provides electricity service for Los Altos. PG&E assists lowincome, disabled, and senior citizen customers through several programs and community outreach projects, including:
• CARE (California Alternate Rates for Energy): See CARE under Silicon Valley Clean Energy Resources, above.
• FERA (Family Electric Rate Assistance): See FERA under Silicon Valley Clean Energy Resources, above.
• Energy Partners Program: The Energy Partners Program provides qualified low-income customers free weatherization measures and energy-efficient appliances to reduce gas and electricity usage.
• Medical Baseline Allowance: See Medical Baseline Allowance under Silicon Valley Clean Energy Resources, above.
• Relief for Energy Assistance through Community Help (REACH): This is a one-time energy-assistance program sponsored by PG&E and administered through the Salvation Army from 170 offices in Northern and Central California. Those who have experienced an uncontrollable or unforeseen hardship may receive an energy grant of up to $300.

Generally, recipients can receive REACH assistance only once within a 12-month period, but exceptions can be made for seniors, the physically challenged, and the terminally ill.

G.2.3 State Energy Resources
• California Department of Community Services & Development Programs LowIncome Weatherization Program (LIWP): California’s Low-Income Weatherization Program (LIWP) provides low-income households with solar photovoltaic (PV) systems and energy efficiency upgrades at no cost to residents. LIWP is the only program of its kind in California that focuses exclusively on serving low-income households with solar 437
Agenda Item # 3.

Housing Resources City of Los Altos | G-13
PV and energy efficiency upgrades at no cost. The program reduces greenhouse gas emissions and household energy costs by saving energy and generating clean renewable power. LIWP currently operates three program components: Multi-Family, Community Solar, and Farmworker Housing. According to CDS’s Nov. 2020 Low-Income Weatherization Program Impact Report, LIWP has received $212 million from the Greenhouse Gas Reduction Fund since 2014. Note: The multi-family energy efficiency and renewables program component is estimated to end in June 2022. • California Public Utilities Commission Energy Savings Assistance Program (ESA):

ESA provides no-cost weatherization services to low-income households who meet the CARE income guidelines. Services provided include attic insulation, energy efficient refrigerators, energy efficient furnaces, weatherstripping, caulking, low-flow showerheads, water heater blankets, and door and building envelope repairs which reduce air infiltration.

G.2.4 Federal Energy Resources
• Federal Housing Administration Energy Efficient Mortgage Program (EEM): This program helps families save money on their utility bills by enabling them to finance energy efficient improvements with their FHA-insured mortgage. The EEM program recognizes that an energy-efficient home will have lower operating costs, making it more affordable for the homeowners. Cost-effective energy improvements can lower utility bills and make more income available for the mortgage payment.
• Low-Income Home Energy Assistance Program (LIHEAP): The program is funded by the federal government and the State Department of Community Services & Development (CSD) administers LIHEAP. The federal Department of Health and Human Services distributes funds to states annually to assist with energy bills and offset heating and/or cooling energy costs for eligible low-income households. California’s annual share is approximately $89 million which CSD distributes to contracted community energy service providers. Active. During March 2020, the CARES Act allocated California an additional $49 million to supplement its LIHEAP program, which totaled $203 million for Federal Fiscal Year 2019-2020.
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1 North San Antonio Road
Los Altos, California 94022-3087

NOTICE OF INTENT TO ADOPT

AN INITIAL STUDY-MITIGATED NEGATIVE DECLARATION
Notice is hereby given that an Initial Study–Mitigated Negative Declaration (IS-MND) has been prepared for the proposed 2023-2031 Housing Element in accordance with the provisions of the California Environmental Quality Act (CEQA), as set forth in the Public Resources Code, Sections 21000 to 21174, as amended. It is the intent of the City of Los Altos to adopt an Initial Study-Negative Declaration for proposed Housing Element.

Date: Wednesday, November 30, 2022
Lead Agency: City of Los Altos, 1 North San Antonio Road Los Altos, CA, 94022, (650) 947-2625 Project Title: City of Los Altos 2023-2031 Housing Element Update City/County: City of Los Altos, Santa Clara County, CA
Public Review Period: A 30-day public review period will begin on November 30, 2022, and end on December 30, 2022, at 5:00 p.m. Please address comments to Nick Zornes, Development Services Director via email at [email protected] or by mail at 1 North San Antonio Road, Los Altos, CA, 94022 prior to the close of the comment period on December 30, 2022.

Availability of CEQA Document: Copies of the Draft Initial Study–Mitigated Negative Declaration are available for review at City offices located at 1 North San Antonio Road Los Altos, CA, 94022 and online at http://www.losaltosca.gov/development-services/page/environmental-documents and https://www.losaltoshousing.org.

Project Location: The City of Los Altos 2023-2031 Housing Element applies to the entirety of the City of Los Altos.

Project Description: The proposed project involves a comprehensive update to the Housing Element of the City of Los Altos General Plan. State law requires that housing elements be updated every eight years (California Government Code Sections 65580 to 65589.8). The Housing Element Update establishes goals, policies, and actions including rezoning of parcels and General Plan amendments, to meet the City’s 6th Cycle Regional Housing Needs Allocation (RHNA). Los Altos’ latest RHNA calls for 1,958 new housing units.

The proposed HEU does not propose any specific development and adoption of the proposed HEU would not approve any physical development (e.g., construction of housing or infrastructure). However, it envisions development including the proposed rezoning of sites for the potential development of additional housing units to meet the City’s RHNA. Therefore, the CEQA analysis assumes that construction of housing is a reasonably foreseeable future outcome of the HEU. The buildout assumptions for use in this CEQA 440
Agenda Item # 3.

Notice of Intent to Adopt an Initial Study-Mitigated Negative Declaration November 30, 2022

document include 1,048 units that can be accommodated on undeveloped and underdeveloped sites and 600 units that can be accommodated through rezoning for a total of 1,648 units.

More information about the proposed project can be found on the City’s website:
https://www.losaltoshousing.org/
Environmental Determination: The City of Los Altos has completed an IS-MND for the proposed project.

The IS-MND concluded that the project would have less-than-significant impacts or less than significant impacts with mitigation in the various topic areas required by CEQA Guidelines Appendix G, including Aesthetics, Agriculture/Forestry Resources, Air Quality, Biological Resources, Cultural Resources, Energy, Geology/Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology/Water Quality, Land Use/Planning, Mineral Resources, Noise, Population/Housing, Public Services, Recreation, Transportation, Tribal Cultural Resources, Utilities/Service Systems, and Wildfire. As such, the City of Los Altos has determined that an Initial Study-Mitigated Negative Declaration is appropriate CEQA assessment.

Hazardous Waste Sites: Pursuant to Section 15087(c)(6) of the CEQA Guidelines, there are numerous sites on a list enumerated under Section 65962.5 of the Government Code in Los Altos.

Public Hearings: The City of Los Altos Planning Commission is anticipated to take public comments and consider the proposed Housing Element on Thursday, January 5, 2023. The meeting will start at 7:00 PM and be held via video and teleconference only. Interested parties should check the Planning Commission website for information on how to join the meeting and to confirm the meeting date, time, and agenda:
https://www.losaltosca.gov/planningcommission
The City Council is also anticipated to take public comments and consider the proposed Housing Element on Tuesday, January 10, 2023, and Tuesday, January 24, 2023. The meetings will start at 7:00 PM and be held via video and teleconference only. Interested parties should check the City Council website for information on how to join the meeting and to confirm the meeting date, time, and agenda:
https://www.losaltosca.gov/citycouncil
Nick Zornes, Development Services Director Date
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Agenda Item # 3.
2023-2031 Housing Element Update
Initial Study – Mitigated Negative Declaration
prepared by
City of Los Altos
1 North San Antonio Road
Los Altos, California 94022
Contact: Nick Zornes, Development Services Director
prepared with the assistance of
Rincon Consultants, Inc.
445 15th Street, Suite 303
Oakland, California 94612
November 2022
442
Agenda Item # 3.
2023-2031 Housing Element Update
Initial Study – Mitigated Negative Declaration
prepared by
City of Los Altos
1 North San Antonio Road
Los Altos, California 94022
Contact: Nick Zornes, Development Services Director
prepared with the assistance of
Rincon Consultants, Inc.
445 15th Street, Suite 303
Oakland, California 94612
November 2022
443
Agenda Item # 3.

This report prepared on 50% recycled paper with 50% post-consumer content. 444
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Table of Contents
Initial Study – Mitigated Negative Declaration i
Table of Contents
Acronyms and Abbreviations.................................................................................................................. v Initial Study.............................................................................................................................................1

1. Project Title.........................................................................................................................1

2. Lead Agency Name and Address.........................................................................................1

3. Contact Person and Phone Number ...................................................................................1

4. Project Location and Setting ...............................................................................................1

5. Description of Project .........................................................................................................4

6. Required Approvals.......................................................................................................... 15

7. Have California Native American Tribes Traditionally and Culturally Affiliated with the Project Area Requested Consultation Pursuant to Public Resources Code Section 21080.3.1? ....................................................................................................................... 16 Environmental Factors Potentially Affected........................................................................................ 17 Determination ..................................................................................................................................... 17 Environmental Checklist...................................................................................................................... 19 1 Aesthetics......................................................................................................................... 19 2 Agriculture and Forestry Resources................................................................................. 27 3 Air Quality ........................................................................................................................ 29 4 Biological Resources......................................................................................................... 45 5 Cultural Resources ........................................................................................................... 55 6 Energy .............................................................................................................................. 63 7 Geology and Soils............................................................................................................. 69 8 Greenhouse Gas Emissions.............................................................................................. 85 9 Hazards and Hazardous Materials ................................................................................... 91 10 Hydrology and Water Quality ........................................................................................ 103 11 Land Use and Planning................................................................................................... 111 12 Mineral Resources ......................................................................................................... 115 13 Noise .............................................................................................................................. 117 14 Population and Housing................................................................................................. 133 15 Public Services................................................................................................................ 137 16 Recreation...................................................................................................................... 143 17 Transportation ............................................................................................................... 147 18 Tribal Cultural Resources............................................................................................... 155 19 Utilities and Service Systems ......................................................................................... 159 20 Wildfire .......................................................................................................................... 167 21 Mandatory Findings of Significance............................................................................... 171 References ......................................................................................................................................... 175 445
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City of Los Altos
2023-2031 Housing Element Update
ii
Bibliography............................................................................................................................... 175 List of Preparers......................................................................................................................... 179 Tables
Table 1 Residential Development Potential and RHNA – With Potential Rezoning........................5 Table 2 Baseline Sites ......................................................................................................................6 Table 3 Rezone Sites..................................................................................................................... 11 Table 4 Project Consistency with the General Plan...................................................................... 23 Table 5 Health Effects Associated with Non-Attainment Criteria Pollutants............................... 30 Table 6 BAAQMD Criteria Air Pollutant Screening Levels............................................................. 33 Table 7 BAAQMD Criteria Air Pollutant Significance Thresholds ................................................. 34 Table 8 BAAQMD Odor Source Thresholds .................................................................................. 35 Table 9 Project Consistency with Applicable 2017 Clean Air Plan Control Measures.................. 37 Table 10 Consistency with State Renewable Energy and Energy Efficiency Plans......................... 66 Table 11 Project Consistency with Applicable General Plan Policies ............................................. 68 Table 12 Los Altos Soil Parameters................................................................................................. 73 Table 13 2018 Community GHG Emissions Inventory Results by Sector ....................................... 86 Table 14 Operational GHG Emissions............................................................................................. 88 Table 15 Project Consistency with Applicable Climate Action and Adaptation Plan Actions ............................................................................................................................. 88 Table 16 Project Consistency with Relevant General Plan Goals and Policies............................. 112 Table 17 Building Vibration Damage Potential............................................................................. 120 Table 18 Vibration Annoyance Potential...................................................................................... 120 Table 19 City of Los Altos Municipal Code Exterior Noise Limits by Zone.................................... 122 Table 20 City of Los Altos Maximum Mobile Equipment Noise Levels......................................... 123 Table 21 City of Los Altos Maximum Stationary Equipment Noise Levels ................................... 124 Table 22 Construction Equipment Noise Levels........................................................................... 125 Table 23 Typical Construction Noise Level at 50 Feet.................................................................. 126 Table 24 Typical Construction Equipment Vibration Levels......................................................... 130 Table 25 Current Population and Housing Stock for Los Altos..................................................... 133 Table 26 2050 Plan Bay Area Population, Housing, and Employment Projections for Northwest Santa Clara County....................................................................................... 133 Table 27 Cumulative Vehicle Miles Traveled Analysis.................................................................. 150 Table 28 Estimated Water Use for the Proposed HEU................................................................. 163 Table 29 Estimated Solid Waste Generation................................................................................ 165 446
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Table of Contents
Initial Study – Mitigated Negative Declaration iii
Figures
Figure 1 City of Los Altos Regional Location .....................................................................................2 Figure 2 City of Los Altos Location....................................................................................................3 Figure 3 Baseline Sites Locations................................................................................................... 10 Figure 4 Rezone Sites Locations..................................................................................................... 13 Figure 5 Los Altos Creeks and Flood Zones.................................................................................... 47 Figure 6 Faults, Landslide Zones, and Liquefaction Zones in Los Altos.......................................... 71 Figure 7 Soils Types in Los Altos..................................................................................................... 74 Figure 8 Geologic Map and Paleontological Sensitivity of Los Altos ............................................. 82 Figure 9 Known Hazardous Sites and Hazardous Sites Located Within 0.25 Mile of a School............................................................................................................................... 95 Figure 10 Examples of Typical Noise Levels................................................................................... 121 Appendices
Appendix A Vehicle Miles Traveled (VMT) Analysis Memorandum Appendix B Age-Eligible Housing Inventory Sites
Appendix C Greenhouse Gas Modeling Results
Appendix D Construction Noise Modeling Results
Appendix E AB 52 Correspondence
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2023-2031 Housing Element Update
iv
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Acronyms and Abbreviations
Initial Study – Mitigated Negative Declaration v
Acronyms and Abbreviations
AB Assembly Bill
ABAG Association of Bay Area Governments
ADU accessory dwelling units
AMI area median income
APN Assessor’s Parcel Number
BAAQMD Bay Area Air Quality Management District
BERD Built Environment Resource Directory
BFE base flood evaluations
BMPs best management practices
CAA Clean Air Act
CAAP Climate Action and Adaptation Plan
CAAQS California Ambient Air Quality standards
CAL FIRE California Department of Forestry and Fire Protection CALGreen California’s Green Building Standards Code
CalOSHA California Occupational Safety and Health Administration CARB California Air Resources Board
CalRecycle California Department of Resources, Recycling, and Recovery Caltrans California Department of Transportation
Cal Water California Water Service
CBC California Building Code
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CFCG California Fish and Game Commission
CFR Code of Federal Regulations
CHRIS California Historical Resources Information System CH4 methane
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
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City of Los Altos
2023-2031 Housing Element Update
vi
CRHR California Register of Historical Resources
dB decibel
DOC California Department of Conservation
DOT Department of Transportation
DPM diesel particulate matter
DTSC California Department of Toxic Substances Control
DUA dwelling units per acre
EO Executive Order
EPA United States Environmental Protection Agency
FEMA Federal Emergency Management Agency
FHSZ fire hazard severity zone
FHWA United States Department of Transportation Federal Highway Administration FTA Federal Transit Administration
FUHSD Fremont Union High School District
FWS Fish and Wildlife Service
GHG greenhouse gas
GPCD gallons per capita per day
GSA Valley Water Groundwater Sustainability Agency
GWh gigawatt hours
GWP global warming potential
HCD California Department of Housing and Community Development HEU Housing Element Update
HFCs hydrofluorocarbons
HFHSZ high fire hazard severity zone
HMTA Hazardous Materials Transportation Act
HRA health risk assessment
HRI Historic Resources Inventory
HWCL Hazardous Waste Control Law
IPaC Information for Planning and Consultation
IPCC Intergovernmental Panel on Climate Change
IS-MND Initial Study-Mitigated Negative Declaration
kWh kilo-watts per hour
LAMC Los Altos Municipal Code
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Acronyms and Abbreviations
Initial Study – Mitigated Negative Declaration vii
LASD Los Altos Elementary School District
LOS level of service
LRA local responsibility area
MERV minimum efficiency reporting value
Mgd million gallons per day
MLD most likely descendent
MRP municipal regional stormwater permit
MT metric ton
MTC Metropolitan Transportation Commission
MVLASD Mountain View-Los Altos Union High School District NAHC Native American Heritage Commission
NAAQS National Ambient Air Quality Standards
NOx nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
NWIC Northwest Information Center
OEHHA California Office of Environmental Health Hazard Assessment OHP Office of Historic Preservation
OPR Office of Planning and Research
PBDB Paleobiology Database
PG&E Pacific Gas and Electric
PDA priority development area
PFCs perfluorocarbons
PM2.5 particulate matter less than 2.5 microns in diameter PM10 particulate matter less than 10 microns in diameter PPV peak particle velocity
PQS professional qualification standards
PRA paleontological resources assessment
PRC Public Resources Code
RHNA Regional Housing Needs Allocation
RMS root mean squared
ROG Reactive Organic Gases
RWQCB Regional Water Quality Control Board
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City of Los Altos
2023-2031 Housing Element Update
viii
SB Senate Bill
SCCFD Santa Clara County Fire District
SCH State Clearinghouse
SCVURPPP Santa Clara Valley Urban Runoff Pollution Prevention Program SCVWD Santa Clara Valley Water District
SF6 sulfur hexafluoride
SFBAAB San Francisco Bay Area Air Basin
SFBRWQCB San Francisco Bay Regional Water Quality Control Board SFHA special flood hazard areas
SIP State Implementation Plan
SMP Soil Management Plan
SRA state responsibility area
SVCE Silicon Valley Clean Energy
SVP Society of Vertebrate Paleontology
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminant
TDF travel demand forecasting
TDM Transportation Demand Management
TPA Transit Priority Area
UCMP University of California Museum of Paleontology
USFWS United States Fish and Wildlife Service
USACE U.S. Army Corp of Engineers
USEPA U.S. Environmental Protection Agency
USGS United States Geological Survey
UWMP Los Altos Suburban District Urban Water Management Plan VHFHSZ very high fire hazard severity zone
VMT Vehicle Miles Traveled
VOC Volatile Organic Compounds
VTA Valley Transportation Authority
WEAP Worker Environmental Awareness Program
WPCP Sunnyvale water pollution control plant
WTP water treatment plan
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Initial Study
Initial Study – Mitigated Negative Declaration 1
Initial Study

1. Project Title
City of Los Altos 2023-2031 Housing Element Update

2. Lead Agency Name and Address
City of Los Altos
1 North San Antonio Road
Los Altos, California 94022

3. Contact Person and Phone Number
Nick Zornes, Development Services Director, (650) 947-2625

4. Project Location and Setting
The City of Los Altos is located in the northwest portion of Santa Clara County, approximately five miles west of San Francisco Bay at the southern end of the peninsula. The regional location is shown in Figure 1.

Los Altos encompasses approximately seven square miles. The Housing Element planning boundaries coincide with the City’s limits, as depicted in Figure 2.

Los Altos is surrounded by Mountain View and Palo Alto to the north, Sunnyvale to the east, Cupertino to the south, and Los Altos Hills to the west. The city is bound by State Route 82 (SR 82) to the north, SR 85 to the east, and U.S. Interstate 280 (I-280) to the southwest, which provide regional access to the City.

Most of the city’s urban development is residential, with small neighborhood commercial areas. Los Altos is served by seven small retail districts, primarily in the downtown area and on Foothill Expressway and El Camino Real.

Los Altos is located approximately 5 miles from the San Francisco Bay with an elevation of 150 feet or more above sea level. The majority of Los Altos is relatively flat terrain, with rolling terrain in the southwest portion of the city. Three creeks that flow north to San Francisco Bay traverse Los Altos:

Adobe Creek on its western boundary, Stevens Creek on its eastern boundary, and Permanente Creek running through middle. All three creeks originate on the flanks of Black Mountain, located approximately 4 miles southwest of the city.
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City of Los Altos
2023-2031 Housing Element Update
2 Figure 1 City of Los Altos Regional Location
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Initial Study
Initial Study – Mitigated Negative Declaration 3
Figure 2 City of Los Altos Location
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City of Los Altos
2023-2031 Housing Element Update
4 5. Description of Project
The proposed 2023-2031 Housing Element Update (HEU), herein referred to as the “proposed HEU” or “proposed project,” would amend the City of Los Altos’ General Plan by replacing the current Housing Element with the proposed 2023-2031 Housing Element and amending the City’s General Plan as needed for consistency and HEU implementation.

The Housing Element is one of the State-mandated elements of the General Plan. The current Housing Element was adopted in 2015 and is in effect through 2023. The Housing Element identifies the city’s housing conditions and needs and establishes the policies and programs that comprise the city’s housing strategy to accommodate projected housing needs, including the provision of adequate housing for low-income households and for special-needs populations (e.g., unhoused people, seniors, single-parent households, large families, and persons with disabilities).

The 2023-2031 Housing Element would bring the element into compliance with State legislation passed since adoption of the 2015-2023 Housing Element and with the current Association of Bay Area Governments’ (ABAG’s) Regional Housing Needs Allocation (RHNA). On December 16, 2021, the ABAG Executive Board adopted the 6th Cycle Final RHNA, which includes a “fair share” allocation for meeting regional housing needs for each community in the ABAG region.

The 2023-2031 Housing Element includes the following components, as required by State law:
 Assessment of the city’s population, household, and housing stock characteristics, existing and future housing needs by household types, and special needs populations.  Analysis of resources and constraints related to housing production and preservation, including governmental regulations, infrastructure requirements and market conditions such as land, construction, and labor costs as well as restricted financing availability.  Identification of the city’s quantified objectives for the 6th cycle RHNA and inventory of sites determined to be suitable for housing.
 Creation or maintenance of opportunities for energy conservation in residential development.

State housing element law requires cities to identify opportunities for energy conservation in residential development.
 Review of the 2013-2021 Housing Element to identify progress and evaluate the effectiveness of previous policies and programs.
 A Housing Plan to address the city’s identified housing needs, including housing goals, policies, and programs to facilitate the 2023 Housing Element Update (6th Cycle).

The draft Housing Element Update establishes objectives, policies, and programs to assist the City in achieving state-mandated housing goals. The City’s implementation of these policies and programs includes future amendments to other elements of the General Plan (e.g., Land Use Element and Land Use/Zoning Map) and the rezoning of sites identified in the housing site inventory to meet the city’s RHNA obligation.

Accommodation of the Regional Housing Needs Allocation (RHNA) The Regional Housing Needs Allocation (RHNA) reflects the California Department of Housing and Community Development’s (HCD’s) determination of the projected housing needs in a region by household income level as a percent of the Area Median Income. ABAG was tasked with allocating the RHNA among the jurisdictions in the ABAG region, which includes the City of Los Altos. 456
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Initial Study – Mitigated Negative Declaration 5
Los Altos’ RHNA for the current planning period is 1,958 units, which includes:
 501 extremely low- and very low-income housing units,  288 low-income housing units,
 326 moderate-income housing units,
 843 above moderate-income housing units.

The heart of a housing element is an inventory of sites within the jurisdiction available for redevelopment to accommodate the jurisdiction’s RHNA targets. If a jurisdiction does not have adequate available sites to accommodate its RHNA targets, then it is required to upzone land to sufficient densities to accommodate the targets. To assess options for accommodating its RHNA targets, the City compiled an inventory of candidate housing sites, which includes properties throughout Los Altos. Each site has undergone an assessment to determine development potential and residential unit capacity given existing zoning standards, potential capacity under new zoning regulations, and development trends.

Table 1 summarizes the City’s plans for accommodating its RHNA targets. Of the required RHNA of 1,958 units, Los Altos can accommodate 322 units with accessory dwelling unit (ADU) projections1 and 587 units with entitled and proposed projects. Based on the sites inventory, an additional 1,048 units can be accommodated with available undeveloped or underdeveloped sites. The “baseline sites” for the purposes of this analysis include undeveloped or underdeveloped sites that are included in the sites inventory. The baseline sites are listed in Table 2 and shown on Figure 3.

As shown in Table 1, without a rezoning program, Los Altos is one unit short of meeting the overall RHNA capacity and is 52 units short in the above-moderate income category.

Table 1 Residential Development Potential and RHNA – With Potential Rezoning Site Category Extremely Low Very Low Low Moderate
Above
Moderate
Total
Units
RHNA Required See Very Low 501 288 326 843 1,958
Accessory Dwelling Units See Very Low 16 97 161 48 322
Approved/Entitled Projects 22 77 30 38 420 587
RHNA Remaining Need See Very Low 386 161 127 375 1,049
Sites Inventory See Very Low/Low 557 168 323 1,048
Surplus/(Shortfall) See Very Low/Low 10 41 (52) (1)
Rezone Sites (Net New) See Very Low/Low 408 128 64 600
Surplus/(Shortfall)
with Rezone Sites
See Very Low/Low 418 169 12 599
Source: Adapted from Table III-1 of the proposed HEU
1 This assumes a continuation of past trends and represents the number of ADUs anticipated to be constructed through 2031 even in the absence of the updated Housing Element.
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City of Los Altos
2023-2031 Housing Element Update
6 Table 2 Baseline Sites
APN
Parcel Size
(acres) Existing Use
Existing
Zoning
Potential
Buildout
(# of Units)
16710094 0.51 Commercial and surface parking CT 16
17003084 0.54 Surface parking lot CT 16
17002023 0.55 Individual retail stores CT 17
16712045 0.56 Multiple or strip stores CT 17
17004050 0.62 Fast food eatery CT 19
17003077 0.69 Medical, dental, veterinary CT 21
31816020 0.71 Commercial building and surface parking lot CN 14 17064120 0.78 General office CT 24
31816019 0.88 Supermarket with surface parking lot CN 14 17064119 0.94 General office CT 29
17003073 1.05 Restaurant and surface parking lot CT 32
16712047 1.69 Commercial building and surface parking lot CT 51 32601052 2.08 Shopping center with large surface parking lot CN 57 32601053 2.94 Shopping center with large surface parking lot CN 80 31816022 3.34 Supermarket with surface parking lot CN 68 18956014 6.07 Strip mall with surface parking lot CN 82 16741007 0.26 Offices or commercial with surface parking CD/R3 11 16738020 0.28 Large building CRS 4
16741065 0.29 Surface parking lot CRS 4
17001088 0.29 Offices or commercial and surface parking lot CN 8 31816011 0.30 Offices or commercial and surface parking lot CN 8 16738008 0.30 Multiple or strip stores CRS 4
17001047 0.31 Residential or commercial with surface parking CN 8 31816009 0.31 Commercial building with surface parking CN 8 17004065 0.31 Individual retail stores CT 10
31816015 0.32 Auto service, garages, and surface parking CN 9 16738038 0.34 Surface parking CRS 5
31816008 0.44 Offices and surface parking lot CN 12
16739057 0.57 Surface parking lot CRS 8
16738029 0.58 Surface parking lot CRS 8
16738028 0.58 Surface parking lot CRS 8
16739069 0.60 Surface parking lot CRS 8
16741003 1.00 Supermarket with surface parking lot CRS 14 16739032 1.04 Surface parking lot CRS 15
16739007 1.18 Surface parking lot CRS 16
16739060 0.05 Restaurants, bars CRS 1
16738024 0.05 Commercial and surface parking lot CRS 1
16739105 0.05 Commercial CRS 1
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Initial Study – Mitigated Negative Declaration 7
APN
Parcel Size
(acres) Existing Use
Existing
Zoning
Potential
Buildout
(# of Units)
16739089 0.05 Commercial and surface parking lot CRS 1
16739084 0.05 Commercial CRS 1
16739085 0.05 Commercial and surface parking lot CRS 1
17001029 0.05 Commercial and surface parking lot CN 1
16739075 0.06 Commercial and surface parking lot CRS 1
17001045 0.06 Surface parking lot CN 2
16739091 0.06 Commercial CRS 1
16739011 0.06 Restaurants, bars CRS 1
16739012 0.06 Restaurants, bars CRS 1
16740004 0.06 Commercial with surface parking lot CRS 1 16738057 0.06 Office or church CRS/OAD 1
16738053 0.06 Commercial or offices CRS 1
17001036 0.07 Commercial and surface parking lot CN 2
17001035 0.07 Surface parking lot CN 2
16741021 0.07 Restaurant and surface parking lot CD/R3 3 16741022 0.07 Office and surface parking lot CD/R3 3
16739074 0.07 Commercial or office with surface parking CRS 1 16739043 0.08 Auto service, garages CD/R3 4
16739042 0.08 General office CD/R3 4
17001030 0.08 Surface parking lot CN 2
16738025 0.09 Bank and surface parking CRS 1
16741006 0.10 Surface parking lot CD/R3 4
16738052 0.10 Commercial/restaurant CRS 1
16738013 0.10 Commercial stores CRS 1
17001026 0.10 Dentist office and surface parking CN 3
16738051 0.10 Surface parking lot CRS 1
16738012 0.10 Commercial and restaurant CRS 1
16741016 0.11 Surface parking lot CD/R3 5
16739064 0.11 Stores CRS 2
17001064 0.11 Offices CN 3
16739076 0.11 Commercial and surface parking CRS 2
17001042 0.12 Surface parking lot CN 3
17001049 0.12 Surface parking lot CN 3
16739097 0.12 Commercial CRS 2
16740003 0.12 Commercial CRS 2
16741018 0.12 Stores and surface parking CD/R3 5
16741051 0.12 Commercial or office with surface parking CD/R3 5 16738021 0.12 Office or commercial building with surface parking CRS 2 16738011 0.13 Commercial building CRS 2
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City of Los Altos
2023-2031 Housing Element Update
8 APN
Parcel Size
(acres) Existing Use
Existing
Zoning
Potential
Buildout
(# of Units)
17001023 0.14 Commercial and surface parking lot CN 4
16740073 0.14 Parking for existing office buildings CD 2 16738010 0.15 Commercial CRS 2
16741054 0.16 Surface parking lot CD 2
16740050 0.16 Commercial or industrial building CD/R3 7 16740051 0.16 Auto service, garages CD/R3 7
16740052 0.16 Auto service, garages CD/R3 7
16740042 0.16 Surface parking lot CD 2
16739045 0.16 Restaurants, bars CD/R3 7
16739041 0.16 Restaurants with surface parking CD/R3 7
16739040 0.16 Store and surface parking CD/R3 7
16739044 0.16 Individual retail stores CD/R3 7
16738050 0.16 Surface parking lot CRS 2
16739127 0.17 Offices or commercial and surface parking CD/R3 7 17516020 0.18 Surface parking lot R1-10 1
16738049 0.18 Surface parking lot CRS 3
17001043 0.18 Commercial or residential CN 5
17001032 0.19 Restaurants, bars, and surface parking CN 5 16716018 0.20 Surface parking lot CT 6
17001027 0.21 Restaurant and surface parking CN 6
34224058 0.22 Undeveloped land R1-10 1
18918102 0.23 Undeveloped land R1-10 1
31807008 0.23 Undeveloped lot R1-10 1
17001051 0.23 Home or commercial building with surface parking CN 6 17001086 0.23 Surface parking lot CN 6
34205032 0.24 Undeveloped land R1-10 1
16736068 0.24 Undeveloped land R1-10 1
17001025 0.24 Offices or commercial with surface parking CN 7 17516088 0.24 Undeveloped land R1-10 1
19344033 0.24 Undeveloped land R1-10 1
18919003 0.25 Undeveloped land R1-10 1
17514021 0.29 Undeveloped land R1-10 1
16736008 0.30 Undeveloped lot R1-10 1
16741072 0.30 Restaurants, bars CD 4
34210088 0.30 Undeveloped lot R1-10 1
33603030 0.30 Undeveloped land R1-10 1
16741046 0.33 General Office and surface parking CD 5
34209045 0.35 Undeveloped lot R1-10 1
16737034 0.36 Undeveloped lot R1-10 1
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APN
Parcel Size
(acres) Existing Use
Existing
Zoning
Potential
Buildout
(# of Units)
17028058 0.45 Vacant flag lot R1-10 1
19341039 0.45 Vacant flag lot R1-10 1
16738065 0.46 Bank and surface parking lot CD 6
16720050 0.46 Undeveloped lot R1-10 1
33602008 0.48 Undeveloped lot R1-H 1
16735076 0.72 Undeveloped lot R1-10 1
16740056 0.80 Commercial building and surface parking lot CD 11 16740039 1.06 Surface parking lot CD 15
16740072 1.07 Commercial open space uses, public parking lots CD 15 34204078 1.12 Undeveloped lot R1-10 1
31801036 1.56 Medical, dental, veterinary with surface parking lot CN 4 17012042 1.70 Church with surface parking lot R1-10 5
16738002 2.03 Surface parking lot CD 28
34204089 7.97 Potentially a school with a playground related to a church R1-10 10 Total Baseline Sites 1,048
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City of Los Altos
2023-2031 Housing Element Update
10 Figure 3 Baseline Sites Locations
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To accommodate the remaining above moderate-income RHNA of 52 units, the Housing Element Update includes a program to rezone sufficient vacant land or land with redevelopment potential to provide capacity for this shortfall. Table 3 identifies potential parcels for rezoning to address this shortfall and provide excess capacity throughout the planning period. Excess capacity is recommended because of “no net loss” laws that require the City to update its inventory with additional sites to accommodate its RHNA targets if sites identified in the inventory ultimately develop with fewer units than anticipated and. The rezone sites are shown on Figure 4.

Separate programs detail specifics of various rezoning actions that would provide additional capacity for all income levels. Potential rezone of vacant and nonvacant parcels to allow higher residential densities and heights would accommodate 600 units.

Table 3 Rezone Sites
APN
Parcel
Size Existing Use
Existing
Zoning
Proposed
Zone
Potential Buildout
(Number of Units)
18915088 0.09 Surface parking lot CN CN1 2
18915090 0.11 Offices and surface parking lot CN CN1 3
18915042 0.12 Office and surface parking CN CN1 3
18915026 0.12 Undeveloped land CN CN1 3
18915041 0.12 Restaurant and surface parking lot CN CN1 3 18915038 0.13 Office and surface parking CN CN1 4
18915059 0.17 Commercial and surface parking CN CN1 5
18915063 0.17 Offices or commercial and surface parking CN CN1 5 18915103 0.21 Medical, dental, veterinary and surface parking CN CN1 6 18915102 0.26 Offices or commercial with surface parking CN CN1 7 16710094 0.51 Commercial and surface parking CT CT2 4
17003084 0.54 Surface parking lot CT CT2 6
16716018 0.20 Surface parking lot CT CT2 2
17003083 0.20 General office CT CT2 8
17004065 0.31 Individual retail stores CT CT2 3
17002023 0.55 Individual retail stores CT CT2 5
17001055 0.56 General office OA OA/Overlay 11
17004045 0.56 General office OA OA/Overlay 11
16712045 0.56 Multiple or strip stores CT CT2 6
17041086 0.60 General office OA OA/Overlay 12
17004050 0.62 Fast food eatery CT CT2 6
17003077 0.69 Medical, dental, veterinary CT CT2 7
18915106 0.70 Bank and surface parking lot CN CN1 19
17040082 0.76 Mortuaries OA OA/Overlay 15
17064120 0.78 General office CT CT2 7
17039053 0.13 General office OA OA/Overlay 3
17038062 0.15 R-1 converted to office OA OA/Overlay 3
17041037 0.19 R-1 converted to office OA OA/Overlay 4
17041065 0.22 General office OA OA/Overlay 4
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2023-2031 Housing Element Update
12 APN
Parcel
Size Existing Use
Existing
Zoning
Proposed
Zone
Potential Buildout
(Number of Units)
17041068 0.24 General office OA OA/Overlay 5
17039058 0.24 General office OA OA/Overlay 5
17040072 0.26 General office OA OA/Overlay 5
17041014 0.28 General office OA OA/Overlay 6
18916006 0.32 Medical, dental, veterinary OA OA/Overlay 6 18916005 0.32 Medical, dental, veterinary OA OA/Overlay 6 18916017 0.32 Medical, dental, veterinary OA OA/Overlay 6 18916008 0.32 Medical, dental, veterinary OA OA/Overlay 6 18916004 0.33 Medical, dental, veterinary OA OA/Overlay 7 18916013 0.33 Medical, dental, veterinary OA OA/Overlay 7 18916016 0.33 Medical, dental, veterinary OA OA/Overlay 7 18916014 0.33 Medical, dental, veterinary OA OA/Overlay 7 18916009 0.34 Medical, dental, veterinary OA OA/Overlay 7 18916018 0.34 Medical, dental, veterinary OA OA/Overlay 7 18916012 0.34 Medical, dental, veterinary OA OA/Overlay 7 17040062 0.38 General office OA OA/Overlay 8
18916010 0.40 Medical, dental, veterinary OA OA/Overlay 8 18916003 0.42 Medical, dental, veterinary OA OA/Overlay 8 16716022 0.49 General office OA OA/Overlay 10
17042028 0.90 General office OA OA/Overlay 18
17064119 0.94 General office CT CT2 9
17041079 0.99 Bank, savings and loan OA OA/Overlay 20
17003073 1.05 Restaurant and surface parking lot CT CT2 10 31801036 1.56 Medical, dental, veterinary with surface parking lot
CN CN1 39
16712047 1.69 Commercial building and surface parking lot CT CT2 16 18914081 1.85 Medical, dental, veterinary OA OA/Overlay 37 33609023 6.06 Churches PCF PCF/Overlay 15
33609018 6.50 Churches PCF PCF/Overlay 20
16712042 2.78 Specialty shopping centers (Town and Country Village, El Paseo de Saratoga)
R1-10 CT2 111
Total Rezone Sites 600
Some APNs are both baseline and rezone sites. The buildout assumptions for these rezone sites would be in addition to the allowable baseline units for particular APNs.
1 The Loyola Corners Specific Plan (LCSP) will be amended to remove the 20-unit density cap. This affects parcels in the LCSP zoned CN (Program 1.E).
2 The CT zone will be amended to remove or increase the density maximum and increase allowable height (Program 1.B).

The OA rezone sites will be amended to include an overlay to allow residential at a minimum of 20 dwelling units per acre (dua) and maximum of 30 dua (Program 1.C).

The two PCF rezone sites will have an overlay to allow residential at a minimum of 20 dua and maximum of 30 dua (Program 1.D).

The zoning for APN 16712042 will change from R1-10 to CT with the changes to CT noted above. 464
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Initial Study
Initial Study – Mitigated Negative Declaration 13
Figure 4 Rezone Sites Locations
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City of Los Altos
2023-2031 Housing Element Update
14 Buildout Assumptions
The proposed HEU does not propose any specific development and adoption of the proposed HEU would not approve any physical development (e.g., construction of housing or infrastructure).

However, it envisions development including the proposed rezoning of sites for the potential development of additional housing units to meet the City’s RHNA. Therefore, this analysis assumes that construction of housing is a reasonably foreseeable future outcome of the HEU.

The buildout assumptions for use in this CEQA document include development of the baseline sites shown in Table 2 of 1,048 units plus the buildout associated with the rezones shown in Table 3 of 600 units, for a total of 1,648 units. Together, the baseline sites and rezone sites constitute the “housing inventory sites” for the purposes of this analysis.

According to the California Department of Finance, as of May 2022 there were an estimated 11,841 housing units in Los Altos. The HEU analyzes the development of up to 1,648 net additional units by 2031. If all units were to be permitted and built, there would be a total of 13,489 housing units in Los Altos by 2031. The pace of development is difficult to predict, but the inventory demonstrates more than sufficient capacity to meet the 6th cycle RHNA.

This analysis also accounts for potential increases in allowable height that could occur under the proposed HEU. Program 1.B of the proposed HEU would involve increasing the maximum height in the CT Zone (along El Camino Real) by 10 feet from 45 feet maximum height to 55 feet maximum height. In addition, Program 3.B of the proposed HEU would involve increasing the maximum allowable height in the CN Zone (Downtown area) by 10 feet from 30 feet maximum height to 40 feet maximum height.

Density Bonus
Residential projects proposed in the 2023-2031 Housing Element cycle may be eligible to use provisions of the State Density Bonus (California Government Code Sections 65915 – 65918). The State Density Bonus encourages the development of affordable and senior housing, including up to a 50 percent increase in project densities for most projects, depending on the amount of affordable housing provided, and up to an 80 percent increase in density for certain projects which are 100 percent affordable. The State Density Bonus also includes a package of incentives intended to help make the development of affordable and senior housing economically feasible. These include waivers and concessions, such as reduced setback, increased height or modified open space and other requirements.

Whether an individual project will use the State Density Bonus, or which aspects of State Density Bonus law an individual project would utilize, is difficult to predict. However, based on recent experience, multi-family residential projects in higher density residential and commercial zoning districts are most likely to utilize the State Density Bonus for concessions, such as increased height.

The analysis in this document assesses a development potential greater than the projected housing need (RHNA); some of these units may be accommodated through State Density Bonus provisions, such as increased building height.
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Zoning Ordinance Amendments
The project includes Housing Element programs that direct amendments to the Los Altos Municipal Code (LAMC) and the Los Altos Zoning Map. LAMC Chapters that would likely be amended include:
 Chapter 2.08, “City Commissions Generally”
 Chapter 14.02, Article 2, “Definitions”
 Chapter 14.04, “Zoning Districts Designated”
 Chapter 14.28, Article 2, “Density Bonus Ordinance”
 Chapter 14.34, “OA Office-Administrative District”
 Chapter 14.34, “OA-1/OA-4.5 Office-Administrative District”  Chapter 14.40, “CN Commercial Neighborhood District”
 Chapter 14.44, “CD Commercial Downtown District”
 Chapter 14.48, “CRS Commercial Retail Sales District”  Chapter 14.50, “CT Commercial Thoroughfare District”
 Chapter 14.52, “CD/R3 Commercial Downtown/Multiple Family District”  Chapter 14.54, “CRS/OAD Commercial Retail Sales/Office-Administrative District”  Chapter 14.74, “Off-Street Parking and Loading”
 Chapter 14.78, “Design and Transportation Review – Multiple-Family, Public and Community Facilities, Office and Administrative, and Commercial Districts”  Chapter 14.80, “Use Permits”
 Residential zone chapters necessary for programs associated with allowing transitional and supportive housing, residential care facilities, and employee/farmworker housing.

Other General Plan Element Amendments
The Land Use Element is a guide for the city’s future development. It designates the distribution and general location of land uses, such as residential, retail, industrial, open space, recreation, and public uses. The Land Use Element also addresses the permitted density and intensity of the various land use designations as reflected on the City’s General Plan Land Use Map.

The Land Use Element likely would be amended to include modifications to land use classifications to maintain consistency with the policies and zoning amendments in the updated Housing Element.

Additionally, the Community Design and Historic Resource Element likely would be modified to maintain consistency with the updated Housing Element.

6. Required Approvals
Implementation of the draft Housing Element Update would require the following discretionary actions by the City of Los Altos Planning Commission and/or City Council:
 Adoption of the 2023-2031 Housing Element
In addition, implementation of the draft Housing Element Update would require the following discretionary actions by the City of Los Altos Planning Commission and/or City Council either at the same time as the Housing Element is adopted or following adoption as policies and programs of the Housing Element are implemented:
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City of Los Altos
2023-2031 Housing Element Update
16  Adoption of a resolution amending the General Plan to update the Housing Element;  Adoption of an ordinance (two readings) amending the City’s zoning ordinance and the City’s zoning map, and
 Adoption of a resolution making corresponding changes to the Land Use Element and General Plan Land Use Map and Community Design and Historic Resource Element required to preserve internal consistency and to reflect the location and density of land uses permitted by the Housing Element and City’s zoning ordinance.

The 2023-2031 Housing Element will be submitted to HCD for review and comment prior to review and recommendation to the Planning Commission, followed by action by the City Council.

7. Have California Native American Tribes Traditionally and Culturally Affiliated with the Project Area
Requested Consultation Pursuant to Public Resources
Code Section 21080.3.1?
On March 10, 2022, the City of Los Altos contacted California Native American Tribal governments by sending a Senate Bill (SB) 18 and Assembly Bill (AB) 52 notification letters to tribes with an affiliation with the project area based on a list provided by the Native American Heritage Commission (NAHC). Under AB 52, Native American tribes have 30 days to respond and request further project information and request formal consultation. Under SB 18, Native American tribes have 90 days to respond and request further project information and request formal consultation.

The City did not receive a request for formal consultation under AB 52 or SB 18. Therefore, no California Native American Tribes traditionally or culturally affiliated with the project area have requested consultation pursuant to Public Resources Code Section 21080.3.1 and Government Code Section 65352.3.
468
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Environmental Factors Potentially Affected
Initial Study – Mitigated Negative Declaration 17
Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry Resources
■ Air Quality
■ Biological Resources ■ Cultural Resources □ Energy
■ Geology/Soils □ Greenhouse Gas
Emissions
■ Hazards & Hazardous
Materials
□ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources ■ Noise □ Population/Housing □ Public Services
□ Recreation ■ Transportation ■ Tribal Cultural Resources □ Utilities/Service Systems □ Wildfire ■ Mandatory Findings of Significance
Determination
Based on this initial evaluation:
□ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
■ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
□ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
□ I find that the proposed project MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. 469
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2023-2031 Housing Element Update
18 470
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Environmental Checklist
Aesthetics
Initial Study – Mitigated Negative Declaration 19
Environmental Checklist
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Except as provided in Public Resources Code
Section 21099, would the project:
a. Have a substantial adverse effect on a
scenic vista? □ □ ■ □
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings
within a state scenic highway? □ □ □ ■
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those
that are experienced from a publicly
accessible vantage point). If the project is
in an urbanized area, would the project
conflict with applicable zoning and other
regulations governing scenic quality? □ □ □ ■
d. Create a new source of substantial light or
glare that would adversely affect daytime
or nighttime views in the area? □ □ ■ □
Environmental Setting
The City of Los Altos is largely built out with residential neighborhoods. The majority of Los Altos is relatively flat terrain, with rolling terrain in the southwest portion of the city. According to the Community Design and Historic Resources Element of the City’s General Plan, the visual character of Los Altos is “an established low-density residential community with mature landscape and small neighborhood commercial areas.” According to the General Plan, the distinctive design features of the city are:
 Relatively flat terrain with mature trees and landscape;  Established low density residential neighborhoods, many having streets without sidewalks;  Predominantly low profile, single-story structures throughout the community;  Tree-lined collector and arterial streets leading to commercial and public activities;  Vital Downtown core with village atmosphere created by contiguous storefronts, wide; sidewalks, and pedestrian plazas reflective of traditional historic commercial development; and, 471
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City of Los Altos
2023-2031 Housing Element Update
20  Smaller neighborhood commercial centers developed at a human scale that is pedestrianfriendly.

The City’s General Plan does not identify specific scenic vistas, but rather lists the City’s parks, open space, and creeks as its most valuable assets. Interstate 280 (I-280), an eligible State Scenic Highway (Caltrans 2019), traverses the southern portion of the City.

Regulatory Setting
Senate Bill 743 (California Public Resources Code Section 21099) passed in 2013, made changes to the CEQA for projects located in transit-oriented development areas. Among these changes are that a project’s aesthetics impacts are no longer considered significant impacts on the environment if the project is a residential, mixed-use residential, or employment center project and if the project is located on an infill site within a transit priority area (TPA). Pursuant to Section 21099 of the California Public Resources Code, a “transit priority area” is defined in as an area within 0.5 mile of an existing or planned major transit stop. A "major transit stop" is defined in Section 21064.3 of the California Public Resources Code as a rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.

According to the Association of Bay Area Governments (ABAG)/Metropolitan Transportation Commission (MTC) Transit Priority Area (TPA) Map (ABAG/MTC 2021), housing sites located along the El Camino Real corridor are within a TPA. Because implementation of the proposed rezoning would facilitate residential development on infill sites within a TPA, aesthetics impacts of development of those locations within a TPA may not be considered significant impacts on the environment. Therefore, this analysis focuses on portions of Los Altos where the proposed HEU facilitates new housing development not within a TPA.

Los Altos General Plan
The Land Use Element of the Los Altos General Plan includes the following goals and policies related to aesthetics:

Goal 2: Plan for a compatible and harmonious arrangement of land uses by providing a mix of uses consistent with projected future social and economic conditions in Los Altos.

Policy 2.3: Continue to conduct design review of residential and nonresidential development applications to ensure compatibility with surrounding property and neighborhoods.

Goal 3: Allow for intensification of development within the Downtown Core in keeping with the existing character of the area.

Policy 3.5: Continue to review development plans to ensure compliance with the Downtown Urban Design Plan.
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Aesthetics
Initial Study – Mitigated Negative Declaration 21
Goal 4: Improve the land use mix along El Camino Real to ensure fiscal stability, encourage affordable housing, and to allow for development intensification along this corridor in a manner that is compatible with the adjacent residential neighborhoods and the local circulation system.

Policy 4.6: Continue to review development proposals to ensure a balance between development rights and impact on surrounding residential neighborhoods.

The Community Design and Historic Resources Element of the Los Altos General Plan includes the following goals and policies related to aesthetics:

Goal 1: Preserve and enhance the identity and unique character of Los Altos.

Policy 1.4: Promote pride in community and excellence in design in conjunction with attention to and compatibility with existing residential and commercial environments.

Policy 1.7: Enhance neighborhood character by promoting architectural design of new homes, additions to existing homes, and residential developments that is compatible in the context of surrounding neighborhoods.

Goal 5: Maintain and enhance the attractiveness of neighborhood shopping centers and businesses throughout the community.

Policy 1.4: Promote pedestrian-friendly site design, circulation, building orientation, parking, landscape, and site amenities (including pedestrian plazas, where feasible).

Impact Analysis
a. Would the project have a substantial adverse effect on a scenic vista? A scenic vista is a view from a public place (roadway, designated scenic viewing spot, etc.) that is expansive and considered important. It can be obtained from an elevated position (such as from the top of a hillside) or it can be seen from a trail, park or roadway with a longer-range view of the landscape. A viewshed is an area of the landscape visible from a particular location or series of points (e.g., an overlook or a trail, respectively) (United States Department of Transportation Federal Highway Administration [FHWA] 2015). A viewshed may be divided into viewing distances called foreground, middle ground, and background. Usually, the closer a resource is to the viewer, the more dominant it appears visually, and thus it has greater importance to the viewer than something farther away. A common set of criteria identifies the foreground as 0.25 to 0.5 mile from the viewer; the middle ground is 3 to 5 miles away, and the background extends away to the horizon.

An adverse effect would occur if a proposed plan or project would block or otherwise damage the scenic vista upon implementation. Los Altos does not contain designated scenic views or scenic vistas. However, some areas of the city and some roadway corridors have background views of the hills on the western portion of the city and of Black Mountain.

The proposed HEU would facilitate increased density and height to accommodate the RHNA allocation in Los Altos. This would consist mostly of infill development, as Los Altos is largely built out. According to Program 1.B of the proposed HEU, allowable maximum height in the CT Zone (along El Camino Real) would be increased by 10 feet and Program 3.B of the proposed HEU would increase allowable height by 10 feet in the Downtown area. As shown on Figure 3 and Figure 4, the 473
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City of Los Altos
2023-2031 Housing Element Update
22 housing inventory sites are largely concentrated along corridors (such as El Camino Real, Foothill Expressway, San Antonio Road) and in the Downtown. Any impact of proposed height increases in the absence of specific project proposals would be wholly speculative, and CEQA does not require a public agency to speculate about environmental impacts. Additionally, a height increase of 10 feet or one additional story along El Camino Real or in the Downtown compared to what is currently allowed would not substantially block views, as most views are already fully or intermittently impeded by mature trees and existing buildings. Although additional future development along roadway corridors could potentially block views from roadways due to increased height facilitated under the proposed HEU, many of these views are limited, are oriented away from background views of the hills, or are already fully or intermittently impeded by mature trees and buildings.

For the east-west oriented roadways, such as El Camino Real and Foothill Expressway, views of the hills to the southwest are already largely blocked by existing development, overhead transmission lines, and mature trees on private properties and beside roadways. For the north-south oriented roadways such as San Antonio Road, views of scenic resources are limited and already blocked by existing development and mature trees, and therefore the incremental increase of the scale of allowable development would not substantially block views. Overall, in the limited areas where views are available from public roadways, these views are already blocked by existing urban development and landscaping and an increase in that development would not directly or substantially block those views. Impacts to scenic vistas would be less than significant.

LESS THAN SIGNIFICANT IMPACT
b. Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? There are no designated state scenic highways within or adjacent to the city. Therefore, development under the proposed HEU would not substantially damage scenic resources within a state scenic highway and there would be no impact.

Although there are no designated state scenic highways, as shown in Figure 3, two housing sites are located adjacent to or near I-280, an eligible State Scenic Highway, in the southern portion of Los Altos. I-280 is elevated through Los Altos and crosses through the city for approximately 1 mile, or approximately two minutes at freeway speeds. Existing views from I-280 are mostly of mature trees or retaining/sound walls surrounding the highway and rooftops of existing development. Therefore, views from I-280 are limited to views within the freeway corridor and expansive views of Los Altos are not available. Development on the two housing inventory sites adjacent to I-280 would not be visible from freeway motorists.

NO IMPACT
c. Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Los Altos is a largely built-out, urbanized area surrounded by other urban communities to the north, east, and south, and open space and mountains to the west. As such, the following analysis focuses on whether the 2023-2031 Housing Element would conflict with applicable zoning and other regulations governing scenic quality. Scenic quality refers to the character of Housing Element’s plan 474
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Environmental Checklist
Aesthetics
Initial Study – Mitigated Negative Declaration 23
area, in this case the Los Altos community, or existing development in the surrounding area and existing natural topography.

Consistency with the City of Los Altos General Plan
The Land Use Element and Community Design and Historic Resources Element of the City’s existing General Plan contain implementing policies related to aesthetics. Those policies and the proposed HEU’s consistency with those policies are shown below in Table 4.

Table 4 Project Consistency with the General Plan
Implementing Policy Consistency
Land Use Element
Policy 2.3: Continue to conduct design
review of residential and nonresidential
development applications to ensure compatibility
with surrounding property and neighborhoods.

Consistent. Development facilitated by the project would be required to conform with applicable height, use, and intensity limits, as well as general design standards pursuant to LAMC Chapter 14.66. Future development would also be subject to the City’s design review process pursuant to Section 14.78.020 of the LAMC, as applicable.

Policy 3.5: Continue to review development plans
to ensure compliance with the Downtown Urban
Design Plan.

Consistent. Development facilitated by the project in the Downtown Plan Area would be required to comply with the Downtown Urban Design Plan and Downtown Design Guidelines, where applicable, which outline guidelines and recommendations for improving the visual quality of the area. Future development may also be subject to the City’s design review process.

Policy 4.6: Continue to review development
proposals to ensure a balance between
development rights and impact on surrounding
residential neighborhoods.

Consistent. Development facilitated by the project would be required to conform with applicable height, use, and intensity limits for development, and would be subject to the City’s design review process as applicable.

Community Design and Historic Resources Element
Policy 1.4: Promote pride in community and
excellence in design in conjunction with attention
to and compatibility with existing residential and
commercial environments.

Consistent. Development facilitated by the proposed HEU would be subject to the City’s design review process as applicable.

Policy 1.7: Enhance neighborhood character by
promoting architectural design of new homes,
additions to existing homes, and residential
developments that is compatible in the context of
surrounding neighborhoods.

Consistent. Development facilitated by the proposed HEU would add new residences that would be subject to the City’s design review process, as applicable, and LAMC Chapter 14.66.

Policy 5.2: Promote pedestrian-friendly site design,
circulation, building orientation, parking,
landscape, and site amenities (including pedestrian
plazas, where feasible).

Consistent. Development facilitated by the proposed HEU in the Downtown would be located within transit priority areas and be designed to ensure transit is accessible, which would promote walkability.

Source: City of Los Altos 2002
Consistency with Los Altos Municipal Code
The City’s Zoning Ordinance, Title 14 of the Los Altos Municipal Code (LAMC), aims to ensure a harmonious, convenient relationship among land uses and to conserve the City’s natural beauty and preserve and enhance its distinctive physical character. The Zoning Ordinance sets forth regulations controlling the uses of land, the uses and locations of structures, the height and bulk of structures, 475
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2023-2031 Housing Element Update
24 the open spaces about structures, the areas of sites in the districts, and the external appearance of structures in certain districts. Implementation of the proposed HEU would involve changes to the LAMC, as detailed under the Project Description, to encourage the development of housing; however, development facilitated by the project would be required to comply with zoning standards pertaining to the preservation of visual character. Development facilitated by the project would be reviewed by the City and evaluated for consistency with the City’s Zoning Ordinance prior to approval. Therefore, the proposed HEU would be consistent with LAMC.

Consistency with Downtown Land Use Plan
A majority of the housing inventory sites are located within the Downtown Land Use Plan, which sets design guidelines in order to preserve and enhance the special qualities of the Downtown Los Altos village scale and character and serves to provide fairness and consistency in the City’s downtown developmental review and approval process. Appendix II of the Downtown Land Use Plan provides Downtown design guidelines for architecture, landscaping, signage, building material, and appearance, and Appendix III provides a Downtown Design Plan to improve the visual quality of the Downtown Area. Development proposed on housing sites within the Downtown Land Use Plan Area would be subject to design standards within the Downtown Land Use Plan, as applicable under the plan and state planning and zoning laws. Conformance with requirements and guidelines established in this specific plan would further ensure that development facilitated by the proposed HEU would not conflict with the Downtown Land Use Plan.

Consistency with Sherwood Gateway Specific Plan
A few housing inventory sites are located within the Sherwood Gateway Specific Plan, which aims to provide a clear vision and direction for future development and improvements within the neighborhood with an emphasis on the maintenance of residential character and quality of life in the area. Chapter IV of the Sherwood Gateway Specific Plan includes land use and development standards while Chapter V sets forth guidelines for the design of appropriate development including architectural characteristics, site planning, parking, landscaping, and signs. Development proposed on housing sites within the Sherwood Gateway Specific Plan Area would be subject to the development standards and design guidelines as established by the specific plan, where applicable and subject to state planning and zoning laws. Conformance with the requirements of the specific plan would ensure that development facilitated by the proposed HEU would not conflict with the Sherwood Gateway Specific Plan.

Therefore, implementation of the proposed HEU would not conflict with the City’s General Plan, Specific Plans, or LAMC. No impact with respect to the proposed HEU’s impacts consistency with applicable zoning and other regulations governing scenic quality would occur.

NO IMPACT
d. Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
For the purposes of this analysis, light refers to light emissions (brightness) generated by a source of light. Stationary sources of light include exterior parking lot and building security lighting; moving sources of light include the headlights of vehicles driving on roadways within Los Altos. Streetlights and other security lighting also serve as sources of light in the evening hours. 476
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Aesthetics
Initial Study – Mitigated Negative Declaration 25
Glare is defined as focused, intense light emanated directly from a source or indirectly when light reflects from a surface. Daytime glare is caused in large part by sunlight shining on highly reflective surfaces at or above eye level. Reflective surfaces are associated with buildings that have expanses of polished or glass surfaces, light-colored walls or pavement, and the windshields of parked cars.

Los Altos is an urbanized area that is largely built out with residential, commercial, and public uses with commensurate levels of light and glare. New development facilitated by the proposed HEU would mostly occur as infill on or among already developed parcels within Los Altos along transportation corridors and in the Downtown. New lighting could occur on buildings for safety and in pedestrian walkways, and light could be emitted from interior sources through windows on upper stories of taller buildings. The main source of glare would likely be from the sun shining on vehicles and reflective or light-colored building materials and glazing.

Development facilitated by the proposed HEU would mainly occur as redevelopment of existing built sites or infill development of unused parcels between existing built sites. When facilities such as parking lots are replaced with buildings, these replacements may reduce nighttime sources of light, because parking lots are often more brightly lit at night than many buildings. Development of underutilized or vacant parcels may result in new light sources, but they would likely be congruous with nearby light sources (e.g., lighting from residential windows). Furthermore, as the development facilitated by the project would be residential, light from windows would be mostly filtered or obscured by window coverings. Light spillover from exterior residential lighting is typically blocked by adjacent structures or trees.

Further, the LAMC has requirements to reduce the potential for new or substantial sources of light pollution. Title 24 of the LAMC provides regulations concerning interior and exterior lighting and effects of glare for each zoning district. Pursuant to LAMC Title 24 for each zoning district, lighting within any lot that unnecessarily illuminates any other lot or substantially interferes with the use or enjoyment of the other lot is prohibited. Additionally, lighting shall be designed to minimize glare and intensity of external illumination and to respect the privacy of adjacent neighbors by avoiding direct and reflected illumination onto adjacent properties. Development facilitated by the proposed HEU would be required to conform with these standards, which would ensure that the project would not result in substantial or adverse new sources of light or glare.

Therefore, new residential development would be in existing residential neighborhoods or along corridors or in the Downtown area where sources of light and glare already exist. Accordingly, implementation of the proposed HEU would not create new sources of substantial light or glare that would adversely affect daytime or nighttime views in the area and this impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
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Agriculture and Forestry Resources
Initial Study – Mitigated Negative Declaration 27
2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use? □ □ □ ■
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ □ ■
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in
Public Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or
conversion of forest land to non-forest
use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest
use? □ □ □ ■
Environmental Setting
The City of Los Altos is categorized as “Urban and Built-Up Land,” according to maps prepared by the California Department of Conservation (DOC 2016a). The city does not contain farmland as defined in the Farmland Mapping and Monitoring Program. 479
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28 Impact Analysis
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? The City of Los Altos is categorized as “Urban and Built-Up Land;” there is no farmland as defined by the Department of Conservation in Los Altos. No proposed housing sites are located on or near Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Therefore, the proposed project would not result in the conversion of Farmland to non-agricultural use. No impact would occur.

NO IMPACT
b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract?
The City of Los Altos is categorized as “Urban and Built-Up Land;” there is no farmland as defined by the Department of Conservation in Los Altos. No proposed housing sites are located on or near farmland. Furthermore, no parcels in Los Altos are currently enrolled in a Williamson Act contract (DOC 2016b). Therefore, the proposed project would not conflict with existing zoning for agricultural use or a Williamson Act contract. No impact would occur.

NO IMPACT
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use? Los Altos is predominantly urbanized and does not contain forest or timberland resources according to the California Department of Fish and Wildlife (CDFW 2015). The City’s zoning map indicates that there are no areas within Los Altos zoned for forestry, timberland, or timberland production.

Therefore, the proposed HEU would not result in an impact related to the conversion or rezoning of forest land, timberland, or areas zoned for timberland production, and there would be no impact.

NO IMPACT
e. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
As discussed under checklist questions (a) through (d), there would be no impacts associated with agricultural or forest lands. The proposed HEU would not involve other changes in the existing environment that could result in the conversion of farmland to non-agricultural use or the conversion of forest land to non-forest use. No impact would occur.

NO IMPACT
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Air Quality
Initial Study – Mitigated Negative Declaration 29
3 Air Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Conflict with or obstruct implementation
of the applicable air quality plan? □ □ ■ □
b. Result in a cumulatively considerable net
increase of any criteria pollutant for
which the project region is nonattainment under an applicable federal or state ambient air quality standard? □ ■ □ □
c. Expose sensitive receptors to substantial
pollutant concentrations? □ ■ □ □
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ ■ □
Environmental Setting
Overview of Air Pollution
The federal and State Clean Air Acts (CAA) mandate the control and reduction of certain air pollutants. Under these laws, the U.S. Environmental Protection Agency (USEPA) and the California Air Resources Board (CARB) have established the National Ambient Air Quality Standards (NAAQS) and the California Ambient Air Quality Standards (CAAQS) for “criteria pollutants” and other pollutants. Some pollutants are emitted directly from a source (e.g., vehicle tailpipe, an exhaust stack of a factory, etc.) into the atmosphere, including carbon monoxide (CO), volatile organic compounds (VOC)/reactive organic gases (ROG),2 nitrogen oxides (NOX), particulate matter with diameters of ten microns or less (PM10) and 2.5 microns or less (PM2.5), sulfur dioxide, and lead.

Other pollutants are created indirectly through chemical reactions in the atmosphere, such as ozone, which is created by atmospheric chemical and photochemical reactions primarily between ROG and NOX. Secondary pollutants include oxidants, ozone, and sulfate and nitrate particulates (smog).
2 CARB defines VOC and ROG similarly as, “any compound of carbon excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate,” with the exception that VOC are compounds that participate in atmospheric photochemical reactions. For the purposes of this analysis, ROG and VOC are considered comparable in terms of mass emissions, and the term ROG is used in this IS-MND.
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30 Air pollutant emissions are generated primarily by stationary and mobile sources. Stationary sources can be divided into two major subcategories:
 Point sources occur at a specific location and are often identified by an exhaust vent or stack.

Examples include boilers or combustion equipment that produce electricity or generate heat.  Area sources are widely distributed and include such sources as residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and some consumer products.

Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and can also be divided into two major subcategories:
 On-road sources that may be legally operated on roadways and highways.  Off-road sources include aircraft, ships, trains, and self-propelled construction equipment.

Air pollutants can also be generated by the natural environment, such as when high winds suspend fine dust particles.

Air Quality Standards and Attainment
Los Altos is located within the San Francisco Bay Area Air Basin (SFBAAB), which is under the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). As the local air quality management agency, BAAQMD is required to monitor air pollutant levels to ensure that the NAAQS and CAAQS are met and, if they are not met, to develop strategies to meet the standards.

Depending on whether the standards are met or exceeded, the U.S. EPA classifies specific geographic areas as “attainment area” or “nonattainment area” for each pollutant. Under state law, air districts are required to prepare a plan for air quality improvement for pollutants for which the district is in non-compliance. BAAQMD is in nonattainment for the ozone NAAQS and CAAQS, the PM2.5 NAAQS and CAAQS, and the PM10 CAAQS and is required to prepare a plan for improvement.3 The health effects associated with criteria pollutants for which the Basin is in non-attainment are described in Table 5.

Table 5 Health Effects Associated with Non-Attainment Criteria Pollutants Pollutant Adverse Effects
Ozone (1) Short-term exposures: (a) pulmonary function decrements and localized lung edema in humans and animals and (b) risk to public health implied by alterations in pulmonary morphology and host defense in animals; (2) long-term exposures: risk to public health implied by altered connective tissue metabolism and altered pulmonary morphology in animals after long-term exposures and pulmonary function decrements in chronically exposed humans; (3) vegetation damage; and (4) property damage.

Suspended particulate
matter (PM10)
(1) Excess deaths from short-term and long-term exposures; (2) excess seasonal declines in pulmonary function, especially in children; (3) asthma exacerbation and possibly induction; (4) adverse birth outcomes including low birth weight; (5) increased infant mortality; (6) increased respiratory symptoms in children such as cough and bronchitis; and (7) increased hospitalization for both cardiovascular and respiratory disease (including asthma). 3 Bay Area Air Quality Management District (BAAQMD). 2017a. BAAQMD CEQA Air Quality Guidelines. https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en (accessed July 2022). 482
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Pollutant Adverse Effects
Suspended particulate
matter (PM2.5)
(1) Excess deaths from short- and long-term exposures; (2) excess seasonal declines in pulmonary function, especially in children; (3) asthma exacerbation and possibly induction; (4) adverse birth outcomes, including low birth weight; (5) increased infant mortality; (6) increased respiratory symptoms in children, such as cough and bronchitis; and (7) increased hospitalization for both cardiovascular and respiratory disease, including asthma.1 1 More detailed discussion on the health effects associated with exposure to suspended particulate matter can be found in the following documents: EPA, Air Quality Criteria for Particulate Matter, October 2004.

Source: Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gases. Last updated April 2021. https://www.epa.gov/climate-indicators/climate-change-indicators-atmospheric-concentrations-greenhouse-gases (accessed July 2022).

The Bay Area 2017 Clean Air Plan (the 2017 Plan) provides a plan to improve Bay Area air quality and protect public health as well as the climate. The legal impetus for the 2017 Plan is to update the most recent ozone plan - the 2010 Clean Air Plan - to comply with state air quality planning requirements as codified in the California Health & Safety Code. Although steady progress in reducing ozone levels in the SFBAAB has been made, the region continues to be designated as non‐ attainment for both the one‐hour and eight‐hour ozone CAAQS. In addition, emissions of ozone precursors in the Bay Area contribute to air quality problems in neighboring air basins. Under these circumstances, state law requires the 2017 Plan to include all feasible measures to reduce emissions of ozone precursors.4

In 2006, the USEPA reduced the 24-hour PM2.5 NAAQS regarding short-term exposure to fine particulate matter from 65 micrograms per cubic meter (µg/m3 ) to 35 µg/m3. Based on air quality
monitoring data for the 2006-2008 cycle showing that the region was slightly above the standard, in December 2008 the USEPA designated the SFBAAB as non-attainment for the 24-hour PM2.5 NAAQS.

This triggered the requirement for the BAAQMD to prepare a State Implementation Plan (SIP) to demonstrate how the region would meet the standard. However, data for both the 2008-2010 and the 2009-2011 cycles showed that PM2.5 levels in the SFBAAB currently meet the standard. On October 29, 2012, the USEPA issued a proposed rulemaking to determine that the SFBAAB now meets the 24-hour PM2.5 NAAQS. The SFBAAB will continue to be designated as nonattainment for the 24-hour PM2.5 NAAQS until such time as the BAAQMD elects to submit a “redesignation request” and a “maintenance plan” to the USEPA, and the USEPA approves the proposed redesignation.

Regulatory Setting
Los Altos General Plan
The Natural Environment and Hazards Element of the Los Altos General Plan includes the following goals and policies related to air quality:

Goal 8: Maintain or improve air quality in Los Altos.

Policy 8.1: Support the principles of reducing air pollutants through land use, transportation, and energy use planning.

Policy 8.2: Encourage transportation modes that minimize contaminant emissions from motor vehicle use.
4 Bay Area Air Quality Management District (BAAQMD). 2017b. Final 2017 Clean Air Plan. https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-plan/attachment-a_-proposed-final-cap-vol-1- pdf.pdf (accessed July 2022).
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32 Policy 8.3: Interpret and implement the General Plan to be consistent with the regional Bay Area Air Quality Management Plan, as periodically updated.

Policy 8.4: Ensure location and design of development projects so as to conserve air quality and minimize direct and indirect emissions of air contaminants.

Los Altos Municipal Code
Title 14 of the LAMC states that any use that emits any air contaminant as defined by BAAQMD shall comply with applicable State standards concerning air pollution. Additionally, no use may generate any odor that reasonably may be found objectionable as determined by an appropriate agency such as the Santa Clara County health department and the Bay Area Air Quality Management District beyond the boundary occupied by the enterprise generating the odor. All mechanical, venting, and/or exhausting equipment that generates odors shall be located away from residential properties.

BAAQMD Significance Thresholds
This analysis uses the BAAQMD’s May 2017 CEQA Air Quality Guidelines to evaluate air quality. The plan-level thresholds specified in the May 2017 BAAQMD CEQA Air Quality Guidelines were used to determine whether the proposed project impacts exceed the thresholds identified in CEQA Guidelines Appendix G.

Consistency with Air Quality Plan
Under BAAQMD’s methodology, a determination of consistency with CEQA Guidelines thresholds should demonstrate that a project:

1. Supports the primary goals of the 2017 Clean Air Plan

2. Includes applicable control measures from the 2017 Clean Air Plan

3. Does not disrupt or hinder implementation of any 2017 Clean Air Plan control measures Short-Term Emissions Thresholds
The BAAQMD’s May 2017 CEQA Air Quality Guidelines have no plan-level significance thresholds for construction air pollutants emissions. However, they do include project-level screening and emissions thresholds for temporary construction-related emissions of air pollutants. These thresholds represent the levels at which a project’s individual emissions of criteria air pollutants or precursors would result in a cumulatively considerable contribution to the SFBAAB‘s existing air quality conditions and are discussed in detail below (BAAQMD 2017a). Construction emissions associated with plan implementation are discussed qualitatively to evaluate potential air quality impacts.

The BAAQMD developed screening criteria in the 2017 CEQA Air Quality Guidelines to provide lead agencies and project applicants with a conservative indication of whether a project could result in potentially significant air quality impacts. The screening criteria for residential land uses are shown in Table 6.
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Table 6 BAAQMD Criteria Air Pollutant Screening Levels
Land Use Type
Operational Criteria
Pollutant Screening Size (du)
Construction Criteria
Pollutant Screening Size (du)
Single-family 325 (NOX) 114 (ROG)
Apartment, low-rise 451 (ROG) 240 (ROG)
Apartment, mid-rise 494 (ROG) 240 (ROG)
Apartment, high-rise 510 (ROG) 249 (ROG)
Condo/townhouse, general 451 (ROG) 240 (ROG)
Condo/townhouse, high-rise 511 (ROG) 252 (ROG)
Mobile home park 450 (ROG) 114 (ROG)
Retirement community 487 (ROG) 114 (ROG)
Congregate care facility 657 (ROG) 240 (ROG)
du = dwelling unit; NOX = oxides of nitrogen; ROG = reactive organic gases Source: BAAQMD 2017a
If a project meets the screening criteria, then the lead agency or applicant would not need to perform a detailed air quality assessment of their project’s air pollutant emissions. These screening levels are generally representative of new development on greenfield sites without any form of mitigation measures taken into consideration (BAAQMD 2017a).

In addition to the screening levels above, several additional factors are outlined in the 2017 CEQA Air Quality Guidelines that construction activities must satisfy for a project to meet the construction screening criteria:
 All basic construction measures from the 2017 CEQA Guidelines must be included in project design and implemented during construction
 Construction-related activities would not include any of the following:
 Demolition
 Simultaneous occurrence of more than two construction phases (e.g., paving and building construction would occur simultaneously)
 Simultaneous construction of more than one land use type (e.g., project would develop residential and commercial uses on the same site) (not applicable to high density infill development)
 Extensive material transport (e.g., greater than 10,000 cubic yards of soil import/export) requiring a considerable amount of haul truck activity
For projects that do not meet the screening criteria above, the BAAQMD construction significance thresholds for criteria air pollutants, shown in Table 7, are used to evaluate a project’s potential air quality impacts.
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34 Table 7 BAAQMD Criteria Air Pollutant Significance Thresholds Pollutant
Construction Thresholds
Average Daily Emissions (lbs/day)
Operational Threshold
Average Daily Emissions (lbs/day)
Operational Threshold
Maximum Annual
Emissions (tons/year)
ROG 54 54 10
NOX 54 54 10
PM10 82 (exhaust) 82 15
PM2.5 54 (exhaust) 54 10
Fugitive Dust Construction Dust Ordinance or
other Best Management Practices
Not Applicable Not Applicable
lbs = pounds; NOX = oxides of nitrogen; ROG = reactive organic gases; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than 2.5 microns
Source: BAAQMD 2017a
For all projects in the SFBAAB, the BAAQMD 2017 CEQA Air Quality Guidelines recommends implementation of the Basic Construction Mitigation Measures listed in Table 8-2 of the Guidelines (BAAQMD 2017b). For projects that exceed the thresholds in Table 7, the BAAQMD 2017 CEQA Air Quality Guidelines recommends implementation of the Additional Construction Mitigation Measures listed in Table 8-3 of the Guidelines (BAAQMD 2017a).

Operation Emissions Thresholds
The BAAQMD’s 2017 CEQA Air Quality Guidelines contain specific operational plan-level significance thresholds for criteria air pollutants. Plans must show the following over the planning period:
 Consistency with current air quality plan control measures, and  Vehicle miles traveled (VMT) or vehicle trips increase is less than or equal to the plan’s projected population increase.

If a plan can demonstrate consistency with both criteria, then impacts would be less than significant.

The current air quality plan is the 2017 Clean Air Plan.

For project-level thresholds, the screening criteria for operational emissions are shown in Table 6.

For projects that do not meet the screening criteria, the BAAQMD operational significance thresholds for criteria air pollutants, shown in Table 7, are used to evaluate a project’s potential air quality impacts.

Carbon Monoxide Hotspots
BAAQMD provides a preliminary screening methodology to conservatively determine whether a proposed project would exceed CO thresholds. If the following criteria are met, a project would result in a less than significant impact related to local CO concentrations:

1. The project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads or highways, regional transportation plan, and local congestion management agency plans.

2. Project traffic would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour.
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3. Project traffic would not increase traffic volumes at affected intersections to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade roadway).

Toxic Air Contaminants
For health risks associated with TAC and PM2.5 emissions, the BAAQMD May 2017 CEQA Air Quality Guidelines state a project would result in a significant impact if the any of the following thresholds are exceeded (BAAQMD 2017b):
 Non-compliance with Qualified Community Risk Reduction Plan;  Increased cancer risk of > 10.0 in a million;
 Increased non-cancer risk of > 1.0 Hazard Index (Chronic or Acute); or  Ambient PM2.5 increase of > 0.3 µg/m3 annual average
Odors
The BAAQMD provides minimum distances for siting of new odor sources shown in Table 8. A significant impact would occur if the project would result in other emissions (such as odors) affecting substantial numbers of people or would site a new odor source as shown in Table 8 within the specified distances of existing receptors.

Table 8 BAAQMD Odor Source Thresholds
Odor Source Minimum Distance for Less than Significant Odor Impacts (in miles) Wastewater treatment plant 2
Wastewater pumping facilities 1
Sanitary Landfill 2
Transfer Station 1
Composting Facility 1
Petroleum Refinery 2
Asphalt Batch Plant 2
Chemical Manufacturing 2
Fiberglass Manufacturing 1
Painting/Coating Operations 1
Rendering Plant 2
Source: BAAQMD 2017a
Methodology
Construction Emissions
Construction-related emissions are temporary but may still result in adverse air quality impacts.

Construction of development facilitated by the project would generate temporary emissions from three primary sources: the operation of construction vehicles (e.g., scrapers, loaders, dump trucks, etc.); ground disturbance during site preparation and grading, which creates fugitive dust; and the application of asphalt, paint, or other oil-based substances. 487
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36 At this time, there is not sufficient detail to provide analysis of individual construction projects that would be facilitated by the project, and thus it would be speculative to analyze project-level impacts. Rather, consistent with the programmatic nature of the project, construction impacts for the project are discussed qualitatively and emissions are not compared to the project-level thresholds.

Operation Emissions
Based on plan-level guidance from the BAAQMD 2017 CEQA Air Quality Guidelines, long-term operational emissions associated with implementation of the proposed project are discussed qualitatively by comparing the proposed project to the 2017 Clean Air Plan goals, policies, and control measures. In addition, comparing the rate of increase of plan VMT and population is recommended by BAAQMD for determining significance of criteria pollutants. If the proposed project does not meet either criterion then impacts would be potentially significant. a. Would the project conflict with or obstruct implementation of the applicable air quality plan? Project Consistency with the Current Air Quality Plan
A project that supports the goals within the 2017 Clean Air Plan would be consistent with the 2017 Clean Air Plan. Consistency with BAAQMD quantitative thresholds is interpreted as demonstrating support for the 2017 Clean Air Plan goals. Assumed buildout under the proposed HEU involves a net increase of 1,648 residential units mainly located within the Downtown Land Use Plan Area which is a Priority Development Area (PDA).
5 Inventory sites are also located in the Sherwood Gateway Specific Plan Area and along transportation corridors within the city, which would encourage denser housing on sites in proximity to services, transit, and bicycle routes. By allowing for the easier use of alternative modes of transportation, the proposed HEU could reduce the use of personal vehicles and subsequent mobile emissions than if the residential units were placed farther from transit. As shown in the VMT analysis memorandum prepared by Hexagon Transportation Consultants, included in Appendix A (Hexagon Transportation Consultants 2022a), the proposed HEU would reduce VMT per resident by 0.17 VMT compared to VMT per resident without implementation of the HEU. In addition, development facilitated by the project would be required to comply with the latest Title 24 regulations, including requirements for residential indoor air quality. The analysis is based on compliance with 2019 Title 24 requirements although individual projects developed under the plan would be required to comply with the most current version of Title 24 at the time of project construction. These requirements currently mandate Minimum Efficiency Reporting Value (MERV)-13 (or equivalent) filters for heating/cooling systems and ventilation systems in residences (Section 150.0[m]) or implementation of future standards that would be anticipated to be equal to or more stringent than current standards. Therefore, the project would improve air quality compared to development farther from transit and services through reducing VMT and would protect public health through stringent requirements for MERV-13 filters or equivalent indoor air quality measures, which would be consistent with the primary goals of the 2017 Clean Air Plan.

The 2017 Clean Air Plan includes 85 control measures under the following sectors: stationary sources, transportation, energy, buildings, agriculture, natural and working lands, waste management, water, and super-GHG pollutants. Many of these measures are industry-specific and would not be applicable to development facilitated by the proposed HEU (e.g., stationary sources, 5 PDAs are places near public transit planned for new homes, jobs, and community amenities. All PDAs are created and planned by local governments, which nominate eligible areas to ABAG for adoption (ABAG 2022). 488
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agriculture, and natural and working lands). Measures from transportation, energy, building, water, waste, and super-GHG pollutants sectors are focused on larger-scale planning efforts (e.g., transit funding, utility energy procurement, regional energy plans) and would not directly apply to development facilitated by the proposed HEU. Table 9 shows project consistency with applicable control measures from the 2017 Clean Air Plan.

Table 9 Project Consistency with Applicable 2017 Clean Air Plan Control Measures Control Measures Consistency
Transportation
TR9: Bicycle and Pedestrian Access and
Facilities. Encourage planning for bicycle and
pedestrian facilities in local plans, e.g., general
and specific plans, fund bike lanes, routes,
paths and bicycle parking facilities.

Consistent: The proposed HEU would facilitate development of housing within the city’s Priority Development Area (the Downtown area), as well as the Sherwood Gateway Specific Plan Area and near or adjacent to transportation corridors currently served by Class II and Class III bicycle lanes such as San Antonio Road and Foothill Expressway, which would encourage the use of bicycles and reduce reliance on single-occupancy vehicles. Future residents would also be able to utilize bicycle parking facilities around the city which would encourage residents to bicycle and walk to transit and services (City of Los Altos 2012).

Energy
EN2: Decrease Electricity Demand. Work with
local governments to adopt additional energyefficiency policies and programs. Support local government energy efficiency program via
best practices, model ordinances, and
technical support. Work with partners to
develop messaging to decrease electricity
demand during peak times.

Consistent. Development facilitated by the project would be required to comply with the LAMC Chapter 12.22, which mandates the implementation of Title 24. Compliance would include complying with the most updated rooftop solar requirements at the time of construction. Future development would also be required to comply with the City’s Reach Code which is currently being revised, but would require all-electric construction for all newly constructed buildings. Electricity would be provided either by Silicon Valley Clean Energy (SVCE) or PG&E, which are required to generate electricity that would increase renewable energy resources to 60 percent by 2030 and 100 percent by 2045. As the City’s main electricity provider, SVCE enrolls new customers in their GreenStart program, which sources 50 percent of electricity from renewable energy sources and 50 percent from carbon-free sources. Customers have the option to upgrade to SVCE’s GreenPrime program which sources 100 percent of electricity from renewable energy sources (SVCE 2022).

Buildings
BL1: Green Buildings. Collaborate with
partners such as KyotoUSA to identify energyrelated improvements and opportunities for on-site renewable energy systems in school
districts; investigate funding strategies to
implement upgrades. Identify barriers to
effective local implementation of the
CALGreen (Title 24) statewide building energy
code; develop solutions to improve
implementation/enforcement. Work with
ABAG’s BayREN program to make additional
funding available for energy-related projects in
the buildings sector. Engage with additional
partners to target reducing emissions from
specific types of buildings.

Consistent: Development facilitated by the project would be required to comply with the energy and sustainability standards of Title 24 (including the California Energy Code and CALGreen) and the City’s associated amendments that are in effect at that time. For example, the current 2019 CALGreen standards and the LAMC Chapter 6.14 require a minimum of 65 percent diversion of construction and demolition debris. New low-rise residential buildings would also be required to install solar photovoltaic (PV) panels. The Title 24 standards are updated every three years and become increasingly more stringent over time. Future development would also be required to comply with the City’s Reach Code which would require all-electric construction for all newly constructed buildings. 489
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
38 Control Measures Consistency
Water
WR2: Support Water Conservation. Develop a
list of best practices that reduce water
consumption and increase on-site water
recycling in new and existing buildings;
incorporate into local planning guidance.

Consistent: Future development that needs new or expanded water service would be required to comply with the California Water Service Company’s and CALGreen’s water efficiency regulations, and the state’s Model Water Efficiency Landscape Ordinance to reduce indoor and outdoor water use.

Source: BAAQMD 2017b
As shown in Table 9, the project would be consistent with the applicable measures as development facilitated by the project would be required to comply with the latest Title 24 regulations and would increase density in Downtown and along transportation corridors, allowing for greater use of alternative modes of transportation. Development facilitated by the project would not contain elements that would disrupt or hinder implementation of a 2017 Clean Air Plan control measures.

Therefore, the project would be consistent with the 2017 Clean Air Plan.

Project VMT and Population Growth
According to the BAAQMD 2017 CEQA Air Quality Guidelines, the threshold for criteria air pollutants and precursors includes an assessment of the rate of increase of plan VMT versus population growth. As discussed above under Environmental Setting, to result in a less than significant impact, the analysis must show that the project’s projected VMT increase would be less than or equal to its projected population increase. Put another way, the project’s projected VMT per resident must be less than what would occur without the project. As shown in Table 27 in Section 17, Transportation, 2031 conditions without the project would involve a VMT per resident of 12.85 whereas 2031 conditions with the project would result in VMT per resident of 12.71. Therefore, compared to 2031 without the project, the proposed HEU would reduce VMT per resident. Therefore, the project’s VMT increase would not conflict with the BAAQMD’s 2017 CEQA Air Quality Guidelines operational plan-level significance thresholds for criteria air pollutants and would be consistent with the 2017 Clean Air Plan. Accordingly, impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Construction
Development facilitated by the proposed HEU would involve activities that result in air pollutant emissions. Construction activities such as demolition, grading, construction worker travel, delivery and hauling of construction supplies and debris, and fuel combustion by on-site construction equipment would generate pollutant emissions. These construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants, particularly during site preparation and grading. The extent of daily emissions, particularly ROGs and NOX emissions, generated by construction equipment, would depend on the quantity of equipment used and the hours of operation for each project. The extent of PM2.5 and PM10 emissions would depend upon the following factors: 1) the amount of disturbed soils; 2) the length of disturbance time; 3) whether existing structures are demolished; 4) whether excavation is involved; and 5) whether transporting 490
Agenda Item # 3.

Environmental Checklist
Air Quality
Initial Study – Mitigated Negative Declaration 39
excavated materials offsite is necessary. Dust emissions can lead to both nuisance and health impacts. According to the 2017 BAAQMD CEQA Air Quality Guidelines, PM10 is the greatest pollutant of concern during construction (BAAQMD 2017a).

As discussed above under BAAQMD Significance Thresholds, BAAQMD’s 2017 CEQA Air Quality Guidelines have no plan-level significance thresholds for construction air pollutant emissions that would apply to the project. However, the guidelines include project-level thresholds for construction emissions. If an individual project’s construction emissions fall below the project-level thresholds, the project’s impacts on regional air quality would be individually and cumulatively less than significant. Mitigation Measure AQ-1 would require future development that does not meet the BAAQMD construction screening criteria under Table 6 to conduct individual air quality analysis and compare emissions to BAAQMD significance thresholds as detailed under Table 7, and to implement mitigation measures to reduce emissions.

Construction of development envisioned under the project would temporarily increase air pollutant emissions, possibly creating localized areas of unhealthy air pollution concentrations or air quality nuisances. Therefore, construction air quality impacts would be potentially significant. Furthermore, site preparation and grading during construction activities facilitated by development under the proposed project may cause wind-blown dust that could contribute particulate matter into the local atmosphere. The BAAQMD has not established a quantitative threshold for fugitive dust emissions but rather states that projects that incorporate best management practices (BMPs) for fugitive dust control during construction would have a less-than-significant impact related to fugitive dust emissions. The BAAQMD has identified feasible fugitive dust control measures for construction activities. These Basic Construction Mitigation Measures are recommended for all projects (BAAQMD 2017a). In addition, the BAAQMD and CARB have regulations that address the handling of hazardous air pollutants such as lead and asbestos, which could be aerially disbursed during demolition activities. BAAQMD rules and regulations address both the handling and transport of these contaminants. Implementation of Mitigation Measure AQ-2 would be required to ensure incorporation of BAAQMD Basic Construction Mitigation Measures to reduce temporary construction impacts and fugitive dust emissions. Every use in the City is also mandated to comply with rules, regulations, and standards of the BAAQMD pursuant to Policy NEH 29 of the Los Altos General Plan Natural Environment and Hazards Element. Construction activities from development facilitated under the project may also potentially result in a cumulatively considerable net increase in criteria pollutants, which would be addressed by Mitigation Measure AQ-2.

Operation
According to the BAAQMD 2017 CEQA Air Quality Guidelines, the threshold for criteria air pollutants and precursors requires an assessment of the rate of increase of plan VMT and population. As discussed under checklist question (a), the VMT per resident in Los Altos would decrease with the proposed HEU compared to conditions without the HEU. VMT increases at a lower percentage because the proposed project would change land uses to concentrate growth and residences to jobs and services to reduce singular vehicle trips and encourage alternative models of travel. Therefore, impacts concerning criteria pollutants generated from operation of the project would be less than significant.

Although operational impacts from emissions of criteria pollutants would be less than significant, future projects that do not satisfy the BAAQMD operational screening criteria as shown in Table 6 would also be required to implement Mitigation Measure AQ-1, which would ensure emissions from individual projects are reduced to below thresholds detailed under Table 7. 491
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
40 Mitigation Measures
The following mitigation measures are required:

AQ-1 Individual Air Quality Analysis
The City shall establish the following Standard Condition of Approval for projects requiring City approval:

For individual projects subject to CEQA that do not meet the BAAQMD construction and/or operational screening criteria under Table 6, individual air quality analysis shall be conducted to determine project significance. Where individual projects exceed BAAQMD significance thresholds detailed under Table 7, mitigation measures shall be incorporated to reduce emissions to below thresholds. Construction mitigation measures may include, but are not limited to, incorporation of Tier 4 and/or alternative fueled equipment, use of onsite power sources instead of generators, and use of low/no-VOC content architectural coatings.

Operational mitigation measures may include, but are not limited to, increased incorporation of photovoltaic systems (PV) beyond regulatory requirements, increased incorporation of EV charging stations and/or infrastructure beyond regulatory requirements, incorporation of a development-wide ride-share system, or elimination of natural gas usage within residential developments. Individual project analysis and accompanying emission-reduction measures shall be approved by the City prior to issuance of a permit to construct or permit to operate.

AQ-2 Construction Emissions Measures
The City shall establish the following Standard Condition of Approval for projects requiring City approval:

Project applicants shall comply with the current Bay Area Air Quality Management District’s basic control measures for reducing construction emissions of PM10 (Table 8-2, Basic Construction Mitigation Measures Recommended for All Proposed Projects, of the May 2017 BAAQMD CEQA Guidelines), outlined below.

1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times a day.

2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.

3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.

4. All vehicle speeds on unpaved roads shall be limited to 15 miles per hour.

5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.

Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.

6. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California Airborne Toxics Control Measure Title 13, Section 2485 of California Code of Regulations). Clear signage shall be provided for construction workers at all access points.

7. All construction equipment shall be maintained and properly tuned in accordance with manufacture’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper conditions prior to operation. 492
Agenda Item # 3.

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Air Quality
Initial Study – Mitigated Negative Declaration 41

8. Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. BAAQMD’s number shall also be visible to ensure compliance with applicable regulations.

Significance After Mitigation
Implementation of mitigation measures AQ-1 and AQ-2 would require individual air quality analysis and incorporation of BAAQMD Basic Construction Measures which reduce temporary construction impacts and fugitive dust emissions to a less than significant level.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
c. Would the project expose sensitive receptors to substantial pollutant concentrations? Carbon Monoxide Hotspots
A CO hotspot is a localized concentration of CO that is above a CO ambient air quality standard. The entire Basin is in conformance with state and federal CO standards (BAAQMD 2017c). There are no current exceedances of CO standards within the BAAQMD jurisdiction and have not had a CO exceedance in the Bay Area since before 1994.6 For 2019 the Bay Area’s reported maximum 1-hour and average daily concentrations of CO were 5.6 ppm and 1.7 ppm respectively (BAAQMD 2019).7 These are well below the respective 1-hour and 8-hour standards of 20 ppm and 9 ppm. Given the ambient concentrations, which include mobile as well as stationary sources, a project in the Bay Area would need to emit concentrations three times the hourly maximum ambient emissions for all sources before project emissions would exceed the 1-hour standard. Additionally, the project would need to emit seven times the daily average for ambient concentrations to exceed the 8-hour standards. Typical development projects, even plan level growth, would not emit the levels of CO necessary to result in a localized hot spot. Therefore, impacts to CO hotspots would be less than significant.

Toxic Air Contaminants
Construction
Construction-related activities would result in short-term emissions of diesel particulate matter (DPM) exhaust emissions from off-road, heavy-duty diesel equipment for site preparation (e.g., excavation, grading, and clearing), building construction, and other miscellaneous activities. DPM was identified as a TAC by CARB in 1998. The potential cancer risk from the inhalation of DPM, as discussed below, outweighs the potential non-cancer8 health impacts (CARB 2021).

Generation of DPM from construction typically occurs in a single area for a short period.

Construction of development facilitated by the project would occur over approximately a decade, but use of diesel-powered construction equipment in any one area would likely occur for no more than a few years for an individual project and would cease when construction is completed in that area. It is impossible to quantify risk without identified specific project details, timelines, and locations.
6 BAAQMD only has records for annual air quality summaries dating back to 1994. 7Data for 2019 was used as the data for 2020 and 2021 are not currently available. 8 Non-cancer risks include premature death, hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma, increased respiratory symptoms, and decreased lung function (CARB 2021a). 493
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
42 Each project developed under the proposed HEU would be required to comply with applicable BAAQMD regulatory requirements and control strategies and the CARB In-Use Off-Road Diesel Vehicle Regulation, which are intended to reduce emissions from construction equipment and activities. Additionally, future development facilitated by the proposed HEU would be required to comply with Mitigation Measure AQ-2 requiring implementation of construction emission measures that would reduce construction-related TACs. According to the OEHHA, construction of individual projects lasting longer than two months or placed within 1,000 feet of sensitive receptors could potentially expose nearby sensitive receptors to substantial pollutant concentrations and therefore could result in potentially significant risk impacts (OEHHA 2015). These projects could exceed BAAQMD’s thresholds of an increased cancer risk of greater than 10.0 in a million and an increased non-cancer risk of greater than 1.0 Hazard Index (Chronic or Acute). Therefore, construction impacts from TAC emissions would be potentially significant and Mitigation Measure AQ-3 would be required.

Operation
In the Bay Area, there are several urban or industrialized communities where the exposure to TACs is relatively high in comparison to others. The City of Los Altos is not located in an impacted community according to BAAQMD CEQA Guidelines. Sources of TACs include, but are not limited to, land uses such as freeways and high-volume roadways, truck distribution centers, ports, rail yards, refineries, chrome plating facilities, dry cleaners using perchloroethylene, and gasoline dispensing facilities (BAAQMD 2017a). Operation of development facilitated by the project would not involve these uses, and therefore, would not be considered a source of TACs. In addition, residences do not typically include new stationary sources onsite, such as emergency diesel generators. However, if a residential project did include a new stationary source onsite, it would be subject to BAAQMD Regulation 2, Rule 2 (New Source Review) and require permitting. This process would ensure that the stationary source does not exceed applicable BAAQMD health risk thresholds. Development facilitated by the project would be required to comply with the residential indoor air quality requirements in the Title 24 Building Energy Efficiency Standards, which currently require Minimum Efficiency Reporting Value 13 (or equivalent) filters for heating/cooling systems and ventilation systems in residences (Section 150.0[m])). Therefore, this impact would be less than significant.

Mitigation Measures
The following mitigation measure is required.

AQ-3 Construction Health Risk Assessment
The City shall establish the following Standard Condition of Approval for projects requiring City approval:

For individual projects where construction activities would last longer than two months and where construction would occur within 1,000 feet of sensitive receptors, Tier 4 equipment and/or alternative fuel construction equipment shall be used.
494
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Environmental Checklist
Air Quality
Initial Study – Mitigated Negative Declaration 43
Significance After Mitigation
Implementation of Mitigation Measure AQ-3 would require use of Tier 4 or alternative fuel construction equipment for projects with construction timelines greater than two months and within 1,000 feet of sensitive receptors, in order to reduce potential risk associated with diesel fuel emissions exposure to nearby sensitive receptors to a less than significant level.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
During construction activities, heavy equipment and vehicles would emit odors associated with vehicle and engine exhaust both during normal use and when idling. However, these odors would be temporary and transitory and would cease upon completion. Therefore, development facilitated by the project would not generate objectionable odors affecting a substantial number of people.

BAAQMD includes odor screening distances for land uses with the potential to generate substantial odor complaints. Those uses include wastewater treatment plants, landfills or transfer stations, refineries, composting facilities, confined animal facilities, food manufacturing, smelting plants, and chemical plants. The proposed HEU would facilitate residential development which does not have the potential to generate substantial odor emissions. Therefore, development facilitated by the project would not generate objectionable odors affecting a substantial number of people during operation. This impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
495
Agenda Item # 3.

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2023-2031 Housing Element Update
44 This page intentionally left blank.
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Biological Resources
Initial Study – Mitigated Negative Declaration 45
4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ ■ □ □
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service? □ ■ □ □
c. Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means? □ ■ □ □
d. Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites? □ ■ □ □
e. Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance? □ □ ■ □
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan? □ □ □ ■
497
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
46 Environmental Setting
Vegetation and Wildlife
The City of Los Altos is urbanized and significant vegetation communities and biological resources have not been identified and are not likely to exist. However, there are riparian corridors and stands of mature trees along creek corridors and within the Redwood Grove Nature Preserve, which provide habitat for animal species. Mature trees are also scattered throughout the city’s low-density residential neighborhoods, parks, and school sites.

According to a search on the California Department of Fish and Wildlife’s (FWS) Information for Planning and Consultation (IPaC) database, the following endangered species could potentially be present within City limits: Salt marsh harvest mouse (Reithrodontomys raviventris), California clapper rail (Rallus longirostris obsoletus), California least tern (Sterna antillarum browni), San Francisco garter snake (Thamnophis sirtalis tetrataenia), Vernal pool tadpole shrimp (Lepidurus packardi), Fountain thistle (Cirsium fontinales var. fontinales), San Mateo thronmint (Acanthomintha obovate ssp. Duttonii), and Showy Indian clover (Trifolium amoenum) (FWS 2022).

Creek Channels
Four creeks are located within the city: Adobe Creek, Hale Creek, Permanente Creek, and Stevens Creek. The creeks provide open space for preservation of biological resources and riparian habitat.

The City’s creeks and flood zones are shown in Figure 5.

Impact Analysis
a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Special-status species are those plants and animals listed, proposed for listing, or candidates for listing as Threatened or Endangered by the United States Fish and Wildlife Service (USFWS) under the Federal Endangered Species Act. According to the USFWS Critical Habitat for Threatened & Endangered Species Map, there is no critical habitat within the city (USFWS 2022).

Future development projects would be subject to federal and State laws, regulations, and management policies regarding biological resources, such as the federal and State Endangered Species Act and permitting pursuant to California Fish and Game Commission (CFGC) Section 1600 et seq.

Although special-status species would be protected by the California Fish and Game Code or the Migratory Bird Treaty Act regulations, special-status bat species could potentially be present in Los Altos and may be affected by proposed projects where they occur in buildings or similar structures or in native habitat adjacent to construction areas. Therefore, impacts to these species are potentially significant and Mitigation Measure BIO-1 would be required. 498
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Environmental Checklist
Biological Resources
Initial Study – Mitigated Negative Declaration 47
Figure 5 Los Altos Creeks and Flood Zones
499
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
48 Mitigation Measures
The following mitigation measure is required:

BIO-1 Special-status Bat Species Avoidance and Minimization The City shall establish the following Standard Condition of Approval for projects requiring approval:

For projects that involve demolition of uninhabited buildings or removal of mature trees large enough to contain crevices and hollows that could support bat roosting, focused surveys to determine the presence/absence of roosting bats shall be conducted prior to demolition or tree removal. If active maternity roosts are identified, a qualified biologist shall establish avoidance buffers applicable to the species, the roost location and exposure, and the proposed construction activity in the area. If active non-maternity day or night roosts are found on the project site, measures shall be implemented to passively relocate bats from the roosts prior to the onset of construction activities. Such measures may include removal of roosting site during the time of day the roost is unoccupied or the installation of one-way doors, allowing the bats to leave the roost but not to re-enter. These measures shall be presented in a Bat Passive Relocation Plan that shall be submitted to, and approved by, CDFW.

Significance After Mitigation
Implementation of Mitigation Measure BIO-2 would reduce impacts to roosting bats to a less than significant level.
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? The four creeks in Los Altos (Adobe Creek, Hale Creek, Permanent Creek, and Stevens Creek) may provide corridors for wildlife movement and may provide refugia and habitat for wildlife. Common and special-status wildlife and plant species that have acclimated to urban areas could be present on the housing sites at the time of development, particularly on parcels that are located in proximity to the creeks. The four creeks present within Los Altos could provide a wildlife corridor for fish and other aquatic species, and construction activities from future development could potentially result in impacts to the movement of native fish.

Since the proposed HEU would mostly facilitate infill development in already developed areas and increase of density and height on sites to accommodate the City’s RHNA numbers, there is a low likelihood that habitat for listed species to occur on the sites. However, as shown in Figure 5, two housing sites would be located adjacent to Permanente Creek, two would be located adjacent to Hale Creek, and several housing sites would be located in proximity to the four creeks, which could result in impacts to sensitive biological resources during construction-related activities such as vegetation removal and result in degradation to plant and wildlife habitat.

Future development would be required to comply with LAMC Chapter 6.32, which outlines watercourse protection regulations and prohibits modification and pollution of the creeks. Section

6.32.030 prohibits residents of properties through which a watercourse passes from polluting the specific part of the watercourse, and prohibits residents from removing healthy vegetation on or adjacent to the watercourse bank; and Section 6.32.040 outlines setback requirements along Adobe Creek. Additionally, LAMC Chapter 10.16 details requirements for stormwater pollution prevention measures which would reduce stormwater runoff from polluting the creeks. This would reduce the 500
Agenda Item # 3.

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Biological Resources
Initial Study – Mitigated Negative Declaration 49
potential for modifications to the waterways that would prohibit wildlife movement or affect riparian habitat or sensitive species.

Future development proposals would also be subject to the Los Altos General Plan and its policies regarding the protection of biological resources. Specifically, Policies 2.3 and 2.7 of the Open Space Element aim to protect creeks, creek-side areas, and riparian habitats in their natural state and establish buffers from adjoining land uses to protect creek-side areas. Additionally, housing sites near creeks and streams would be subject to the Santa Clara Valley Water Resources Protection Collaborative’s (Water Collaborative) Guidelines and Standards for Land Use Near Streams manual during the City’s development review process (Water Collaborative 2007), which are designed to protect creeks and riparian habitats.

Nonetheless, because implementation of the proposed HEU could encourage development and rezone sites that contain waterways and may contain sensitive species or habitat, this impact is potentially significant and Mitigation Measure BIO-3 would be required.

Mitigation Measures
The following mitigation measure is required:

BIO-2 Biological Resources Screening and Assessment
The City shall establish the following Standard Condition of Approval for projects requiring approval:

For projects on sites located on or adjacent to a creek, the project applicant shall hire a qualified biologist to perform a preliminary biological resources screening, for the City’s review and approval, to determine whether the project has the potential to impact special status biological resources, inclusive of special status plants and animals, sensitive vegetation communities, jurisdictional waters (including creeks, drainages, streams, ponds, vernal pools, riparian areas and other wetlands), critical habitat, wildlife movement area, or biological resources protected under local or regional ordinances or an existing HCP or NCCP. If it is determined that the project has no potential to impact biological resources, no further action is required.

If the project would have the potential to impact biological resources, prior to construction, a qualified biologist shall conduct a project-specific biological analysis to document the existing biological resources within a project footprint plus a minimum buffer of 50 feet around the project footprint, as is feasible, and to determine the potential impacts to those resources, as approved by the City. The project-specific biological analysis shall evaluate the potential for impacts to all biological resources including, but not limited to special status species, nesting birds, wildlife movement, sensitive plant communities, critical habitats, and other resources judged to be sensitive by local, State, and/or federal agencies. If the project would have the potential to impact these resources, recommendations developed to enhance wildlife movement (e.g., installation of wildlife friendly fencing), as applicable, to reduce impacts to less than significant levels. Pending the results of the project-specific biological analysis, City review, design alterations, further technical studies (e.g., protocol surveys) and consultations with the USFWS, NMFS, CDFW, and/or other local, State, and federal agencies may be required.

Significance After Mitigation
Implementation of Mitigation Measure BIO-2 would reduce impacts to special status species by requiring biological resources studies for projects located on or adjacent to creeks and implementation of further requirements to avoid or reduce impacts on a project-by-project basis. 501
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
50 c. Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Adobe Creek, Hale Creek, Permanente Creek, and Stevens Creek are the four creeks present within the City. Hale Creek and Permanente Creek traverse the middle of the City, while Adobe Creek runs along the northwestern border of the City and Stevens Creek runs along the southeastern border of the City, as shown in Figure 5. The four creeks eventually flows into San Francisco Bay, a Traditional Navigable Water, and therefore are potentially under the jurisdiction of the U.S. Army Corps of Engineers (USACE), California Department of Fish and Wildlife (CDFW), and/or Regional Water Quality Control Board (RWQCB). Although the 2023-2031 would facilitate development on or adjacent to the four creeks, especially Hale Creek and Permanente Creek, future development would be required to comply with Water Collaborative’s Guidelines and Standards for Land Use Near Streams manual during the City’s development review process (Water Collaborative 2007), which involve the protection of creeks and water quality. Future development would also be required to adhere to LAMC Chapter 6.32, which outlines watercourse protection regulations.

Specifically, Section 6.32.030 prohibits residents of properties through which a watercourse passes from polluting the specific part of the watercourse and prohibits residents from removing healthy vegetation on or adjacent to the watercourse bank; and LAMC Section 6.32.040 outlines setback requirements along Adobe Creek. Additionally, LAMC Chapter 10.16 details requirements for stormwater pollution prevention measures which would reduce stormwater runoff from polluting the creeks. Therefore, adherence to federal, State, and local regulations, would reduce impacts to wetlands and creeks. Nonetheless, as implementation of the proposed project would involve development on sites adjacent to creeks and the exact design of such development is unknown at this time, impacts to waters and wetlands would be potentially significant and mitigation measures BIO-3 and BIO-4 would be required.

Mitigation Measures
The following mitigation measures are required:

BIO-3 Jurisdictional Delineation
The City shall establish the following Standard Condition of Approval for projects requiring approval:

If potentially jurisdictional waters and/or wetlands are identified by the project-specific analysis (as required by Mitigation Measure BIO-3), for projects on sites that are on or adjacent (within 200 feet) to a creek, a qualified biologist shall complete a jurisdictional delineation to determine the extent of the jurisdictions for CDFW, USACE, and/or RWQCB. This delineation shall be conducted in accordance with the requirements set forth by each agency. The result shall be a preliminary jurisdictional delineation report that shall be submitted to the City, USACE, RWQCB, and CDFW, as appropriate, for review and approval. Jurisdictional areas shall be avoided. If jurisdictional areas are expected to be impacted, then the RWQCB would require a Waste Discharge Requirements (WDRs) permit and/or Section 401 Water Quality Certification (depending upon whether the feature falls under federal jurisdiction). If CDFW asserts its jurisdictional authority, then a Streambed Alteration Agreement pursuant to Section 1600 et seq. of the CFGC would also be required prior to construction within the areas of CDFW jurisdiction. If the USACE asserts its authority, then a permit pursuant to CWA Section 404 would likely be required. Furthermore, a compensatory mitigation program shall be implemented in accordance with Mitigation Measure BIO-4 and the measures set forth by the aforementioned regulatory 502
Agenda Item # 3.

Environmental Checklist
Biological Resources
Initial Study – Mitigated Negative Declaration 51
agencies during the permitting process. Compensatory mitigations for all permanent impacts to waters of the U.S. and waters of the state shall be completed at a ratio as required in applicable permits but shall not be less than a minimum ratio of 1:1. All temporary impacts to waters of the U.S. and waters of the State shall be fully restored to natural condition. The project applicant shall submit the report documenting restoration activities and monitoring to the City for review and approval.

BIO-4 General Avoidance and Minimization
The City shall establish the following Standard Condition of Approval for projects requiring approval:

Potential jurisdictional features on sites identified in jurisdictional delineation reports shall be avoided. Projects that may impact jurisdictional features shall include a report detailing how all identified jurisdictional features will be avoided, including groundwater draw down. The project applicant shall submit this report to the City for review and approval prior to construction.  Material/spoils generated from project activities shall be located away from jurisdictional areas or special-status habitat and protected from storm water run-off using temporary perimeter sediment barriers such as berms, silt fences, fiber rolls (non- monofilament), covers, sand/gravel bags, and straw bale barriers, as appropriate.  Materials shall be stored on impervious surfaces or plastic ground covers to prevent any spills or leakage from contaminating the ground and generally at least 50 feet from the top of bank.
 Any spillage of material will be stopped if it can be done safely. The contaminated area will be cleaned, and any contaminated materials properly disposed. For all spills, the project foreman or designated environmental representative will be notified.

Significance After Mitigation
Implementation of mitigation measures BIO-3 and BIO-4 would reduce impacts to State and federally protected waters and wetlands by requiring jurisdictional delineations for projects within the housing inventory sites on or adjacent to creeks, and implementation of further requirements to avoid or reduce impacts on a project-by-project basis. Impacts to waters and wetlands would be mitigated to less than significant levels.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
d. Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? The City of Los Altos is largely built-out and does not function as a significant regional or local wildlife movement corridor. Wildlife corridors often overlap land designated as open space, but as there are limited wildland open spaces with connectivity to larger undeveloped open spaces within urban Los Altos, natural wildlife corridors are not present in most parts of the city. As discussed in checklist question (b) above, the city’s four creeks could provide a wildlife corridor for fish and other aquatic species, and construction activities from future development could potentially result in impacts to the movement of native fish. However, adherence to State and local regulations discussed above and implementation of Mitigation Measure BIO-2 would reduce impacts to a less than significant level.
503
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City of Los Altos
2023-2031 Housing Element Update
52 Los Altos contains mature groves of trees that could provide suitable nesting substrates for birds protected under the MBTA and CFGC. In addition, mature tree groves exist along creek corridors, which could be used for nursery sites by native bird species. Future development would be required to comply with tree protection regulations pursuant to LAMC Section 11.08.120, which would preserve existing trees. Furthermore, sensitive species such as nesting birds and roosting bats would be protected by the California Fish and Game Code or the Migratory Bird Treaty Act regulations.

Nonetheless, if construction of specific development projects implemented under the proposed project occurs during the breeding season, impacts to nesting birds may occur. Impacts may include direct impacts to active nests, including eggs or young, if nesting substrates are removed as part of the project. Indirect impacts may result if noise, vibration, and human presence cause adult birds to abandon the nests for prolonged periods of time, preventing them from incubating eggs, brooding chicks, and defending the nest from predators.

Therefore, this impact is potentially significant and Mitigation Measure BIO-5 would be required.

Mitigation Measures
The following mitigation measure is required:

BIO-5 Preconstruction Surveys for Nesting Birds
The City shall establish the following Standard Condition of Approval for projects requiring City approval:

For projects that would involve native or naturalized vegetation or tree removal, a general preconstruction nesting bird survey shall be conducted by a qualified biologist within 14 days prior to the initiation of construction activities. If construction is stopped for more than 14 days during the nesting season, a pre-construction survey shall be conducted prior to the re-start of construction activities. Surveys shall include the disturbance area plus a 50-foot buffer for passerine species, and a 500-foot buffer for raptors.

If active nests are located, an appropriate avoidance buffer shall be established within which no work activity would be allowed that would impact these nests. The avoidance buffer shall be established by the qualified biologist on a case-by-case basis based on the species and site conditions. Larger buffers may be required depending upon the status of the nest and the construction activities occurring in the vicinity of the nest. The buffer area(s) shall be closed to all construction personnel and equipment until juveniles have fledged and/or the nest is inactive. A qualified biologist shall confirm that breeding/nesting is complete, and the nest is no longer active prior to removal of the buffer. If work within a buffer area cannot be avoided, then a qualified biologist shall be present to monitor all project activities that occur within the buffer.

The biological monitor shall evaluate the nesting avian species for signs of disturbance and shall have the ability to stop work.

Significance After Mitigation
Implementation of Mitigation Measure BIO-5 would reduce impacts to nesting birds to a less than significant level.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
504
Agenda Item # 3.

Environmental Checklist
Biological Resources
Initial Study – Mitigated Negative Declaration 53
e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Future development in Los Altos may involve the removal of mature trees during construction. As outlined in the City’s Tree Protection Ordinance (LAMC Chapter 11.08), all trees, regardless of species, that are 48-inches or larger in circumference are protected would require a Tree Removal Permit before they can be removed. Additionally, future development would be required to comply with Section 11.08.120 of the LAMC which outlines tree protection measures during construction such as installing protective fencing and repairing damaged trees. Therefore, with required adherence to the City’s Tree Protection Ordinance, this impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
There are no habitat conservation plans or natural community conservation plans adopted in Los Altos. The city is also located outside of the Santa Clara Valley Habitat Conservation Plan. There would be no impact.

NO IMPACT
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54 This page intentionally left blank.
506
Agenda Item # 3.

Environmental Checklist
Cultural Resources
Initial Study – Mitigated Negative Declaration 55
5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Cause a substantial adverse change in the
significance of a historical resource
pursuant to §15064.5? □ □ ■ □
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5? □ ■ □ □
c. Disturb any human remains, including
those interred outside of formal
cemeteries? □ □ ■ □
Regulatory Setting
California Environmental Quality Act
The California Environmental Quality Act (CEQA) requires a lead agency determine whether a project may have a significant effect on historical resources (Public Resources Code (PRC), Section 21084.1). A historical resource is a resource listed in, or determined by the California Historical Resources Commission to be eligible for listing, in the California Register of Historical Resources (CRHR), a resource included in a local register of historical resources, or any object, building, structure, site, area, place, record, or manuscript that a lead agency determines on the basis of substantial evidence to be historically significant (State CEQA Guidelines, Section 15064.5(a)(1-3)).

Historical resources may include eligible built environment resources and archaeological resources from any time period.

If a resource has sufficient integrity to convey information about the past, it may be considered historically significant based on substantial evidence that it:

1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. Is associated with the lives of persons important in our past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. Has yielded, or may be likely to yield, information important in prehistory or history.

CEQA Guidelines Section 15064.5(c) provides further guidance on the consideration of archaeological resources. If an archaeological resource does not qualify as a historical resource, it may meet the definition of a “unique archaeological resource” as identified in PRC Section 21083.2.

If it can be demonstrated that a project would cause damage to a unique archaeological resource, 507
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
56 the lead agency may require reasonable efforts be made to permit any or all these resources to be preserved in place or left in an undisturbed state. To the extent that resources cannot be left undisturbed, mitigation measures are required (PRC, Section 21083.2[a], [b]).

PRC, Section 21083.2(g) defines a unique archaeological resource as an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it:

1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information;

2. Has a special and particular quality such as being the oldest of its type or the best available example of its type; or

3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

CEQA Guidelines Section 15064.5 also provides guidance for addressing the potential presence of human remains, including those discovered during the implementation of a project.

City of Los Altos Municipal Code
The City of Los Altos’ Municipal Code Chapter 12.44 Historic Preservation defines the criteria for historic resource and historic landmark designation and procedures for the treatment of historic resources. Section 12.44.040 establishes the criteria for designation. A structure, property or object may be eligible for designation as a historic resource or historic landmark, if it/they satisfy each of the three criteria listed below:

A. Age. A structure or property should be more than fifty (50) years in age. (Exceptions can be made to this rule if the building(s) or site(s) is/are truly remarkable for some reason - such as being associated with an outstanding architect, personage, usage or event).

B. Determination of Integrity. A structure or property should retain sufficient historic integrity in most of the following areas:

Design: The combination of elements that create the form, plan, space, structure and style of a property.

Setting: The physical environment of a historic property.

Materials: The physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.

Workmanship: The physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.

Feeling: A property's expression of the aesthetic or historic sense of a particular period of time.

C. Historic Significance. A structure or property should be clearly associated with one or more of the following areas of significance:

Event: Associated with a single significant event or a pattern of events that have made a significant contribution to broad patterns of local or regional history, or cultural heritage of California or the United States;
Person/People: Associated with the lives of persons important to the local, California or national history;
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Cultural Resources
Initial Study – Mitigated Negative Declaration 57
Architecture/Design: Embodies the distinctive characteristics of a design-type, period, region or method of construction, or represents the work of a master or possesses high artistic value; or
Archaeology: Yields important information about prehistory or history of the local area, California or the nation.

City of Los Altos Housing Development Permit Application Requirements While not part of the City’s adopted Municipal Code, Los Altos’ Housing Development Project Application process includes a requirement for historic resources evaluations for certain projects involving properties over 50 years of age. Permit applications are required to include a set of State of California Department of Parks and Recreation (DPR) Series Forms 523A and 523B, documenting a historic resource evaluation in the following project scenarios:

Environmental Setting
The environmental setting research completed for this analysis included a review of the National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR), the California Office of Historic Preservation (OHP) Built Environment Resource Directory (BERD) for all previously evaluated historic properties within the City of Los Altos, including the 1,048 baseline housing opportunity sites and the 600 rezone sites located throughout the City, and comprising of a total of 175 parcels. It also included a review of the City’s Historic Resources Inventory (HRI), which identifies designated Historic Landmarks in addition to Historic Resources and designated Historic Districts that are significant at the local level. All properties on the HRI are subject to the City’s Historic Preservation Ordinance. Properties on the HRI are potentially eligible for designation as Historic Landmarks (City of Los Altos Historic Resources Inventory, 2012). The research identified a number of properties that are listed in or eligible for listing in the NRHP, CRHR, or the City’s HRI ; of these, two historical resources are located on housing opportunity sites, as described below.  625 Palm Avenue (APN 17516088) consists of a landscaped area presumed to be associated with the Lanthier House, with which it shares an address. Lanthier House is listed on the City’s Historic Inventory and is identified in the BERD with an OHP status of 5S2, meaning it is individually eligible for local listing or designation.  398 Main Street (APN 16739091) contains the Altos Land Company Building which is designated locally as a landmark and identified in the BERD with a status code of 5S2.

A review of parcel data and historical aerial photographs of the properties comprising the housing opportunity sites identified 116 parcels with properties that have not been subject to previous historical resources evaluation and currently meet the 45-year threshold which, pursuant to guidance from OHP, generally triggers the need for evaluation as part of review of a proposed project on those sites, recognizing there is commonly a lag between resource identification and when planning decisions are made. Of these, 13 properties were previously analyzed as part of the environmental review for the 5th Cycle Housing Element (2015-2023). An additional 12 properties would become 45 years of age during the 2023-2031 planning period of the 2023-2031 Housing Element. Two of these were previously included in the 5th Cycle Housing Element. Pending further analysis there is a potential for these properties to qualify as historical resources pursuant to CEQA.

All previously unevaluated properties that are currently aged 45 years and those that will become age-eligible during the 2023-2031 planning period of the Housing Element are listed in Appendix B. 509
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
58 Checklist question (a) broadly refers to historical resources. To more clearly differentiate between archaeological and built environment resources, analysis under checklist question (a) is limited to built environment resources. Archaeological resources, including those that may be considered historical resources pursuant to Section 15064.5 and those that may be considered unique archaeological resources pursuant to Section 21083.2, are considered under checklist question (b).

Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
The proposed HEU does not propose any specific development. However, it envisions development including the proposed rezoning of sites for the potential development of additional housing units to meet the City’s RHNA needs on parcels that contain buildings that meet the age threshold for potential historical resources pursuant to CEQA. Development on these parcels could be proposed by a property owner or project applicant with or without the City’s adoption of the HEU; still, development associated with the proposed HEU could result in the material impairment of historical resources, which CEQA Guidelines Section 15064.5(b)(2)(A) defines as the demolition or alteration in an adverse manner of those characteristics of a historical resource that convey its historical significance and that justify its inclusion in, or eligibility for inclusion in, the CRHR or a local register.

The City of Los Altos’ Historic Preservation Ordinance provides procedures for designating a property as part of the local Historic Inventory and provisions to review and regulate proposed changes, including demolition, new construction, or alteration to designated properties (Chapter

12.44). Additionally, the City has submittal requirements in place for housing development project applications for any building listed or determined eligible for listing at the national, state, or local level or that contains any building, structure, or permanently located object that has been in existence for at least 45 years. The City’s regulations would mitigate impacts to historical resources listed in the NRHP, CRHR, as a City Landmark or on the City’s HRI. Additionally, buildings 45 years or older, are subject to planning review requiring a historical resource evaluation to be prepared by a professional architect or someone with at least one year of graduate study in architectural preservation, American architectural history, preservation planning, or closely related field or at least one year of full-time professional experience on historic preservation projects. This is to identify any property that may qualify as a historic resource that has not previously been identified as such, to ensure that any redevelopment of such a property either: (1) will not impair those elements or aspects of the property that convey historic significance, or (2) is done in accordance with the Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer.

With compliance with the City’s regulations and application requirements and State and federal regulations, this impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Although the City of Los Altos does not maintain an inventory of archaeological sites, it is understood that archaeological sites are present in the City of Los Altos and the surrounding areas. 510
Agenda Item # 3.

Environmental Checklist
Cultural Resources
Initial Study – Mitigated Negative Declaration 59
Therefore, there is potential to encounter archaeological resources in the City of Los Altos and on residential opportunity sites specified in the 2023-2031 Housing Element. Undeveloped properties in the housing inventory sites have a higher probability of containing previously unidentified archaeological resources given the probable lack of previous ground-disturbing activities on those properties. However, ground-disturbance into native soils on housing inventory sites could encounter prehistoric or historic-period archaeological resources.

Because the proposed HEU is a policy document and does not include specific development proposals, it cannot be ascertained with certainty where ground-disturbing activities could occur in these areas. Specific impacts to archaeological resources are therefore unknown at this time and would be determined by project-level analysis. Effects on archaeological resources can only be known once a specific project has been proposed, because potential effects are highly dependent on the individual project site conditions and the characteristics of proposed ground-disturbing activity. However, the proposed HEU would prioritize the development of new housing near areas that have previously been developed and disturbed and away from undeveloped land and/or environmentally sensitive resources. Therefore, it is likely that on future development sites under the proposed project, prior grading, construction, and modern use of the sites would have either removed or impacted archaeological resources within surficial soils.

Nonetheless, there is the potential for archaeological resources to exist below the ground surface throughout the City of Los Altos, which could be disturbed by grading and excavation activities associated with new housing development. As such, individual development projects under the proposed project that would involve ground disturbing activities would have the potential to damage or destroy archaeological resources, especially if they occur below the existing road base or in less disturbed or native soils.

Consequently, damage to, or destruction of previously unknown sub-surface archaeological resources could occur as a result of development implemented under the proposed HEU. This represents a potentially significant impact and mitigation measures CUL-1 and CUL-2 are required.

Mitigation Measures
The following mitigation measures are required:

CUL-1 Archaeological Resources Assessment
The City shall establish the following Standard Condition of Approval for projects requiring City approval:

Prior to approval of any individual development projects under the 2023-2031 Housing Element that will involve ground disturbance activities that may include, but are not limited to, grading and excavation, an archaeological resources assessment shall be performed under the supervision of an archaeologist that meets the Secretary of the Interior’s Professional Qualifications Standards in either prehistoric or historic archaeology. Assessments shall include a California Historical Resources Information System (CHRIS) records search at the Northwest Information Center (NWIC) and a Sacred Lands File Search maintained by the Native American Heritage Commission (NAHC). The records searches shall characterize the results of previous cultural resource surveys and disclose any cultural resources that have been recorded and/or evaluated in and around the project site. A Phase I pedestrian survey shall be undertaken in proposed project sites that are undeveloped to identify the presence or absence of any surface cultural materials. By performing a records search, a Sacred Lands File search, and a Phase I 511
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
60 survey, a qualified archaeologist will classify the project site as having high, medium, or low sensitivity for archaeological resources.

If the Phase I archaeological survey identifies resources that may be affected by the project, the archaeological resources assessment shall also include Phase II testing and evaluation. If resources are determined significant or unique through Phase II testing and site avoidance is not possible, appropriate site-specific mitigation measures shall be identified in the Phase II evaluation. These measures may include, but would not be limited to, a Phase III Data Recovery Program, avoidance, or other appropriate actions to be determined by a qualified archaeologist.

If significant archaeological resources cannot be avoided, impacts may be reduced to less than significant by adding fill soils on top of the resources rather than cutting into the cultural deposits. Alternatively, and/or in addition, a data collection program may be warranted, including mapping the location of artifacts, surface collection of artifacts, or excavation of the cultural deposit to characterize the nature of the buried portions of sites. Curation of the excavated artifacts or samples would occur as specified by the archaeologist in consultation with the City of Los Altos and with other relevant parties.

CUL-2 Unanticipated Discoveries of Archaeological Resources The City shall establish the following Standard Condition of Approval for projects requiring City approval:

In the event that archaeological resources are unexpectedly encountered during grounddisturbing activities associated with the 2023-2031 Housing Element, work within 50 feet of the find shall halt and an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for archaeology (National Park Service 1983) shall be contacted immediately to evaluate the resource. If the resource is determined by the qualified archaeologist to be prehistoric, then a Native American representative shall also be contacted to participate in the evaluation of the resource. If the qualified archaeologist and/or Native American representative determines it to be appropriate, archaeological testing for CRHR eligibility shall be completed. If the resource proves to be eligible for the CRHR and significant impacts to the resource cannot be avoided via project redesign, a qualified archaeologist shall prepare a data recovery plan tailored to the physical nature and characteristics of the resource, per the requirements of California Code of Regulations (CCR) Guidelines Section 15126.4(b)(3)(C).

The data recovery plan shall identify data recovery excavation methods, measurable objectives, and data thresholds to reduce any significant impacts to cultural resources related to the resource. Pursuant to the data recovery plan, the qualified archaeologist and Native American representative, as appropriate, shall recover and document the scientifically consequential information that justifies the resource’s significance. The City of Los Altos shall review and approve the treatment plan and archaeological testing as appropriate, and the resulting documentation shall be submitted to the regional repository of the California Historical Resources Information System, per CCR Guidelines Section 15126.4(b)(3)(C).

Significance After Mitigation
Mitigation measures CUL-1 and CUL-2 would reduce potential impacts to a less than significant level by requiring the identification and evaluation of any archaeological resources that may be present prior to project construction and by providing steps for the evaluation and protection of unanticipated finds encountered during construction.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
512
Agenda Item # 3.

Environmental Checklist
Cultural Resources
Initial Study – Mitigated Negative Declaration 61
c. Would the project disturb any human remains, including those interred outside of formal cemeteries?
Human burials outside of formal cemeteries often occur in prehistoric archaeological contexts.

Although much of Los Altos is developed and the City of Los Altos does not have records of burial sites within Los Altos, the potential still exists for these resources to be present. Excavation during construction activities in Los Altos related to the proposed HEU would have the potential to disturb these resources, including Native American burials.

Human burials, in addition to being potential archaeological resources, have specific provisions for treatment in PRC Section 5097. The California Health and Safety Code (Section 7050.5, 7051, and 7054) has specific provisions for the protection of human burial remains. Existing regulations address the illegality of interfering with human burial remains, and protect them from disturbance, vandalism, or destruction. They also include established procedures to be implemented if Native American skeletal remains are discovered. PRC Section 5097.98 also addresses the disposition of Native American burials, protects such remains, and established the NAHC to resolve any related disputes.

Development projects are subject to State of California Health and Safety Code Section 7050.5 which states that, if human remains are unearthed, no further disturbance can occur until the county coroner has made the necessary findings as to the origin and disposition of the remains pursuant to the PRC Section 5097.98. If the remains are determined to be of Native American descent, the coroner has 24 hours to notify the Native American Heritage Commission which will determine and notify a most likely descendant (MLD). The MLD shall complete the inspection of the site and make recommendations to the landowner within 48 hours of being granted access. If the landowner rejects the MLD’s recommendations, the landowner shall reinter the human remains and items associated with Native American human remains with appropriate dignity on the property in a location not subject to further and future subsurface disturbance and shall take additional steps outlined in the statute for protecting the site where the human remains and associated items are reinterred. With adherence to these existing regulations impacts to human remains would be less than significant. No mitigation is required.

LESS THAN SIGNIFICANT IMPACT
513
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2023-2031 Housing Element Update
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514
Agenda Item # 3.

Environmental Checklist
Energy
Initial Study – Mitigated Negative Declaration 63
6 Energy
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation? □ □ ■ □
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ ■ □
Environmental Setting
California is one of the lowest per-capita energy users in the United States, ranked 48th in the nation, due to its energy efficiency programs and mild climate. Most of the electricity generated in California is from natural gas-fired power plants, which provided approximately 48 percent of total electricity generated in 2020. According to the California Energy Commission (CEC), in 2020 California used 272,575 gigawatt hours (GWh) of electricity and produced 70 percent (190,913 GWh) of the electricity it used and imported the rest from outside the state (CEC 2020). In 2018, SB 100 accelerated the state’s Renewable Portfolio Standards Program, codified in the Public Utilities Act, by requiring electricity providers to increase procurement from eligible renewable energy and zero-carbon resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

Energy consumed by the transportation sector accounts for roughly 39.5 percent of California’s energy demand, amounting to approximately 3,073.3 trillion Btu in 2019. Petroleum-based fuels are used for approximately 98.4 percent of the state’s transportation activity. Most gasoline and diesel fuel sold in California for motor vehicles is refined in California to meet state-specific formulations required by the California Air Resources Board (CARB). California’s transportation sector, including on-road and rail transportation, consumed approximately 662 million barrels of petroleum fuels in 2019 (EIA 2021).

According to the CEC, Santa Clara County consumed approximately 16,436 giga-watts per hour (GWh) of electricity and 419 million of therms of natural gas in 2020 (CEC 2022a; CEC 2022b). The City of Los Altos residential sector consumed approximately 80,391,486 kilo-watts per hour (kWh) of electricity and 6,640,225 therms of natural gas in 2018 (City of Los Altos 2022a).

Electricity and natural gas service in Los Altos is supplied by SVCE and PG&E, with SVCE being the main provider. As the City’s main electricity provider, SVCE enrolls new customers in their GreenStart program, which sources 50 percent of electricity from renewable energy sources and 50 percent from carbon-free sources. Customers have the option to upgrade to SVCE’s GreenPrime program which sources 100 percent of electricity from renewable energy sources (SVCE 2022). 515
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City of Los Altos
2023-2031 Housing Element Update
64 The City is currently updating its Reach Code, which, if adopted, would require all-electric construction for all building types along with additional EV-charging infrastructure. The Reach Code would also prohibit extension of gas service lines to new outdoor appliances and equipment such as pool and spa equipment or barbecues.

Impact Analysis
a. Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Energy consumption is directly related to environmental quality in that the consumption of nonrenewable energy resources releases criteria air pollutant and GHG emissions into the atmosphere. The environmental impacts of air pollutant and GHG emissions associated with the project’s energy consumption are discussed in detail in Section 3, Air Quality, and Section 8, Greenhouse Gas Emissions, respectively.

Los Altos demonstrates its commitment to energy efficiency and renewable energy via implementation of CALGreen and State-mandated Energy Efficiency Requirements for new development and retrofits. The proposed HEU would facilitate development of projects to encourage housing on vacant or underutilized sites, as well as rezoning to allow for higher residential densities. When proposed, individual projects would be required, pursuant to the requirements of CALGreen, to comply with the zero-net energy requirements, where new development combines energy efficiency and renewable energy generation to consume only as much energy as can be produced on-site through renewable resources over a specified period.

However, development under the proposed HEU would consume energy during construction and operation, using petroleum fuel, natural gas, and electricity, as discussed below.

Energy use during construction associated with future development under the proposed HEU would be in the form of fuel consumption (e.g., gasoline and diesel fuel) to operate heavy equipment, light-duty vehicles, machinery, and generators for lighting. Temporary grid power may also be provided to construction trailers or electric construction equipment. Energy use during the construction of individual projects would be temporary in nature, and equipment used would be typical of construction projects in the region. Construction contractors would be required to demonstrate compliance with applicable CARB regulations that restrict the idling of heavy-duty diesel motor vehicles and govern the accelerated retrofitting, repowering, or replacement of heavyduty diesel on- and off-road equipment. Construction activities associated with reasonably foreseeable development under the proposed HEU would be required to utilize fuel-efficient equipment consistent with federal and State regulations and would comply with State measures to reduce the inefficient, wasteful, or unnecessary consumption of energy. In addition, individual projects would be required to comply with construction waste management practices to divert at least 65 percent of construction and demolition debris pursuant to LAMC Chapter 6.14. These practices would result in efficient use of energy during construction of future development under the proposed HEU. Furthermore, in the interest of both environmental awareness and cost efficiency, construction contractors would not utilize fuel in a manner that is wasteful or unnecessary. Therefore, future construction activities associated with development under the proposed HEU would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant. 516
Agenda Item # 3.

Environmental Checklist
Energy
Initial Study – Mitigated Negative Declaration 65
Long-term operation of future development under the proposed HEU would require permanent grid connections for electricity and natural gas service to power internal and exterior building lighting, and heating and cooling systems. Electricity and natural gas service in Los Altos is supplied by SVCE and PG&E, with SVCE being the main provider. Development facilitated by the proposed HEU would be subject to the energy conservation requirements of the California Energy Code (Title 24, Part 6 of the California Code of Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings), the California Green Building Standards Code (CALGreen, Title 24, Part 11 of the California Code of Regulations). The California Energy Code provides energy conservation standards for all new and renovated commercial and residential buildings constructed in California.

This code applies to the building envelope, space-conditioning systems, and water-heating and lighting systems of buildings and appliances and provides guidance on construction techniques to maximize energy conservation. Minimum efficiency standards are given for a variety of building elements, including appliances; water and space heating and cooling equipment; and insulation for doors, pipes, walls, and ceilings. The code emphasizes saving energy at peak periods and seasons and improving the quality of installation of energy efficiency measures. Furthermore, the 2019 Building Energy Efficiency Standards (California Code of Regulations, Title 24, Part 6) requires newly constructed buildings to meet energy performance standards set by the CEC such as installing PV systems on all low-rise residential structures up to three stories equal to the expected electricity usage. CALGreen sets targets for energy efficiency, water consumption, dual plumbing systems for potable and recyclable water, diversion of construction waste from landfills, and use of environmentally sensitive materials in construction and design, including ecofriendly flooring, carpeting, paint, coatings, thermal insulation, and acoustical wall and ceiling panels. These standards for new buildings are designed for energy efficient performance, using clean electricity, so that the buildings do not result in wasteful, inefficient, or unnecessary consumption of energy.

Additionally, pursuant to the City’s Reach Code, future new development would be required to be all-electric and would not include natural gas.

The housing inventory sites are located in the Downtown as well as near or adjacent to transportation corridors, which would reduce trip distances and encourage the use of alternative modes of transportation such as bicycling and walking. These factors would minimize the potential of the proposed project to result in the wasteful or unnecessary consumption of vehicle fuels. As a result, operation of development projects under the proposed HEU would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Several State plans as well as the City’s adopted General Plan include energy conservation and energy efficiency strategies intended to enable the State and the City to achieve GHG reduction and energy conservation goals. A full discussion of the proposed project’s consistency with GHG reduction plans is included in Section 8, Greenhouse Gas Emissions. As shown in Table 10, the project would be consistent with applicable State renewable energy and energy efficiency plans. 517
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City of Los Altos
2023-2031 Housing Element Update
66 Table 10 Consistency with State Renewable Energy and Energy Efficiency Plans Renewable Energy or Energy Efficiency Plan Proposed Project Consistency Assembly Bill 2076: Reducing Dependence on
Petroleum. Pursuant to AB 2076, the CEC and CARB
prepared and adopted a joint-agency report,
Reducing California’s Petroleum Dependence, in
2003. Included in this report are recommendations to
increase the use of alternative fuels to 20 percent of
on-road transportation fuel use by 2020 and 30
percent by 2030, significantly increase the efficiency
of motor vehicles, and reduce per capita VMT. One of
the performance-based goals of AB 2076 is to reduce
petroleum demand to 15 percent below 2003
demand.

Consistent. The project would facilitate development of housing within the city’s Downtown, as well as the Sherwood Gateway Specific Plan Area and near or adjacent to
transportation corridors currently served by bus stops and Class II and Class III bicycle lanes, which supports Policy 1.2, Programs under Goal 1, and Program 4.J of the proposed HEU which aims to promote mixed uses to reduce VMT. All housing units constructed under the proposed HEU would be subject to the requirements of the most recent iteration of CALGreen and locally adopted amendments, which include provisions for electric vehicle charging infrastructure, reducing dependence on gasoline powered vehicles.
2019 Integrated Energy Policy Report. The 2019
report highlights the implementation of California’s
innovative policies and the role they have played in
establishing a clean energy economy, as well as
provides more detail on several key energy policies,
including decarbonizing buildings, increasing energy
efficiency savings, and integrating more renewable
energy into the electricity system.

Consistent. Development facilitated by the project would be required to comply with the LAMC Chapter 12.22, which
mandates the implementation of Title 24. Compliance would include complying with the most updated rooftop solar
requirements at the time of construction. Future development would also be required to comply with the City’s Reach Code which is currently being revised, but would require all-electric construction for all newly constructed buildings. Electricity would be provided either by Silicon Valley Clean Energy (SVCE) or PG&E, which are required to generate electricity that would increase renewable energy resources to 60 percent by 2030 and 100 percent by 2045. As the City’s main electricity provider, SVCE enrolls new customers in their GreenStart program, which sources 50 percent of electricity from
renewable energy sources and 50 percent from carbon-free sources. Customers have the option to upgrade to SVCE’s GreenPrime program which sources 100 percent of electricity from renewable energy sources (SVCE 2022). Additionally, Policies 7.1 and 7.2 aim to ensure the inclusion of energy efficiency measures in future development.

California Renewable Portfolio Standard. California’s
RPS obligates investor-owned utilities, energy service
providers, and community choice aggregators to
procure 33 percent total retail sales of electricity
from renewable energy sources by 2020, 60 percent
by 2030, and 100 percent by 2045.

Consistent. Electricity for future development would be provided either by Silicon Valley Clean Energy (SVCE) or PG&E, which are required to generate electricity that would increase renewable energy resources to 60 percent by 2030 and 100 percent by 2045. As the City’s main electricity provider, SVCE enrolls new customers in their GreenStart program, which sources 50 percent of electricity from renewable energy sources and 50 percent from carbon-free sources. Customers have the option to upgrade to SVCE’s GreenPrime program which sources 100 percent of electricity from renewable energy sources (SVCE 2022).

Energy Action Plan. In the October 2005, the CEC and
CPUC updated their energy policy vision by adding
some important dimensions to the policy areas
included in the original EAP, such as the emerging
importance of climate change, transportation-related
energy issues, and research and development
activities. The CEC adopted an update to the EAP II in
February 2008 that supplements the earlier EAPs and
examines the State’s ongoing actions in the context
of global climate change. The nine major action areas
in the EAP include energy efficiency, demand
Consistent. Future development facilitated by the proposed project would be required to be constructed in accordance with the latest iteration of CALGreen, the California Energy Code, and any locally adopted amendments, which include requirements for the use of energy-efficient design and technologies as well as provisions for incorporating renewable energy resources into building design. Additionally, Policies 7.1 and 7.2 would ensure implementation of energy efficiency measures in all development facilitated under the project.

Electricity would be provided by SVCE, which sources 50 percent of electricity from renewable energy sources and 50 518
Agenda Item # 3.

Environmental Checklist
Energy
Initial Study – Mitigated Negative Declaration 67
Renewable Energy or Energy Efficiency Plan Proposed Project Consistency response, renewable energy, electricity
adequacy/reliability/infrastructure, electricity market structure, natural gas supply/demand/infrastructure,
transportation fuels supply/demand/infrastructure,
research/development/demonstration, and climate
change.
percent from carbon-free sources under their GreenStart program. Customers have the option to upgrade to SVCE’s GreenPrime program which sources 100 percent of electricity from renewable energy sources (SVCE 2022). Given these
features, the project would facilitate implementation of the nine major action areas in the EAP.

AB 1007: State Alternative Fuels Plans. The State
Alternative Fuels Plan assessed various alternative
fuels and developed fuel portfolios to meet
California’s goals to reduce petroleum consumption,
increase alternative fuels use, reduce GHG emissions,
and increase in-State production of biofuels without
causing a significant degradation of public health and
environmental quality.

Bioenergy Action Plan, EO S-06-06. The EO
establishes the following targets to increase the
production and use of bioenergy, including ethanol
and biodiesel fuels made from renewable resources:
produce a minimum of 20 percent of its biofuels in
California by 2010, 40 percent by 2020, and 75
percent by 2050.

Consistent. The project would not interfere with or obstruct the production of biofuels in California. Vehicles used by future residents would be fueled by gasoline and diesel fuels blended with ethanol and biodiesel fuels as required by CARB
regulations. Pursuant to the City’s Reach Code, new multifamily residences with less than or equal to 20 dwelling units would be required to install at least one Level 2 EV Ready space for each dwelling unit. For multi-family residences with more than 20 units, 25 percent of the dwelling units with parking spaces must include at least one Level 2 EV Ready space, and each remaining dwelling unit with parking spaces must include one Level 1 EV Ready space. Future development would also be required to comply with LAMC Chapter 12.22, which mandates the implementation of the most current version of Title 24.

Title 24 contains requirements for EV spaces in new
construction. Future development facilitated by the project would be required to comply with the most updated EV
requirements in both the City’s Reach Code and Title 24 at the time of construction.

Title 24, CCR – Part 6 (Building Energy Efficiency
Standards) and Part 11 (CALGreen). The 2019
Building Energy Efficiency Standards move toward
cutting energy use in new homes by more than 50
percent and will require installation of solar
photovoltaic systems for single-family homes and
multi-family buildings of three stories and less. The
CALGreen Standards establish green building criteria
for residential and nonresidential projects. The 2019
Standards include the following: increasing the
number of parking spaces that must be prewired for
electric vehicle chargers in residential development;
requiring all residential development to adhere to the
Model Water Efficient Landscape Ordinance; and
requiring more appropriate sizing of HVAC ducts.

Consistent. Development facilitated by the project would be required to comply with the LAMC Chapter 12.22, which
mandates the implementation of Title 24.

Furthermore, the City’s General Plan and Climate Action Plan (CAP) also contains goals and policies related to energy efficiency and renewable energy. As discussed under Table 15 in Section 8, Greenhouse Gas Emissions, the proposed project would be consistent with recommended goals, policies, and actions in the City’s CAP related to energy efficiency and renewable energy. Table 11 summarizes the project’s consistency with the applicable General Plan policy. As shown therein, the proposed project would be consistent with the applicable General Plan policy and therefore would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. This impact would be less than significant.
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City of Los Altos
2023-2031 Housing Element Update
68 Table 11 Project Consistency with Applicable General Plan Policies Policies Project Consistency
Natural Environment and Hazards Element
Policy 8.1: Support the principles of
reducing air pollutants through land
use, transportation, and energy use
planning.

Consistent: Future development facilitated by the proposed project would be required to be constructed in accordance with the latest iteration of CALGreen, the California Energy Code, and any locally adopted amendments, which include green building practices. Future development would also be required to comply with the City’s Reach Code which would require all-electric construction for all newly constructed buildings. Additionally, Policies 7.1 and 7.2 would ensure implementation of energy efficiency measures in all development facilitated under the project.

Source: City of Los Altos 2002

LESS THAN SIGNIFICANT IMPACT
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Geology and Soils
Initial Study – Mitigated Negative Declaration 69
7 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:

1. Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial evidence
of a known fault? □ □ □ ■

2. Strong seismic ground shaking? □ □ □ ■

3. Seismic-related ground failure,
including liquefaction? □ □ □ ■

4. Landslides? □ □ ■ □
b. Result in substantial soil erosion or the
loss of topsoil? □ □ ■ □
c. Be located on a geologic unit or soil that
is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading, subsidence,
liquefaction, or collapse? □ □ □ ■
d. Be located on expansive soil, as defined
in Table 18-1-B of the Uniform Building
Code (1994), creating substantial direct
or indirect risks to life or property? □ □ □ ■
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater? □ □ □ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ ■ □ □
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City of Los Altos
2023-2031 Housing Element Update
70 Environmental Setting
Regional and Local Geology
The City of Los Altos is part of the Coast Ranges geomorphic province. A geomorphic province is a naturally defined geologic region that displays a distinct landscape or landform according to its geology, faults, topographic relief and climate (Department of Conservation [DOC] 2002). The Coast Ranges are Northwest trending mountain ranges and valleys, running subparallel to the San Andreas Fault. They are composed of thick Mesozoic and Cenozoic sedimentary strata (DOC 2002).

The City of Los Altos is located in the northwest portion of Santa Clara County, approximately five miles west of San Francisco Bay at the southern end of the peninsula. The City’s boundaries extend from Mountain View and Palo Alto to the north, Sunnyvale to the east, Cupertino to the south, and the town of Los Altos Hills to the west. The city spans an area of around 6.5 square miles, and has relatively low topography, with rolling terrain only in the southwest portion of the city.

Fault Zones
Similar to much of California, Los Altos is located in a seismically active region. The USGS defines Holocene-active faults as those that are likely to have moved one or more times (surface displacement) in the last 10,000 years (USGS, n.d.), while inactive faults have not had surface displacement within that period. Several faults are located near Los Altos. These major faults and fault zones include:
 The San Andreas Fault: Located around 5 miles west of Los Altos. The San Andreas Fault is the primary surface boundary between the Pacific and the North American plates. There have been numerous historic earthquakes along the San Andreas Fault, and it generally poses the greatest earthquake risk to California. The probability of experiencing a Magnitude 6.7 or greater earthquake along the San Andreas Fault within the next 30 years is 22 percent (Office of Emergency Services 2017).
 The Hayward Fault: Located around 16 miles east of Los Altos. The Hayward Fault is part of the wide plate boundary between the Pacific and the North American plates. The probability of experiencing a Magnitude 6.7 or greater earthquake along the Hayward Fault in the next 30 years is 33 percent (Office of Emergency Services 2017).  The Calaveras Fault: Located around 23 miles Northeast from the City of Los Altos. The probability of experiencing a Magnitude 6.7 or greater earthquake along the Calaveras Fault in the next 30 years is 26 percent (Office of Emergency Services 2017).

In addition to primary hazards like surface fault ruptures, earthquakes also result in secondary hazards and impacts such as ground shaking, landslides, and liquefaction, which could cause widespread damage. No part of Los Altos is located within an identified earthquake fault zone as delineated on the Alquist-Priolo Earthquake Fault Zoning Map (DOC 2022a). An inactive quaternary fault9 runs parallel to El Camino Real, as shown in Figure 6. 9 A Quaternary fault is one that has been recognized at the surface and that has moved in the past 1.6 million years. That places fault movement within the Quaternary Period, which covers the last 2.6 million years (United States Geological Survey [USGS] 2022). 522
Agenda Item # 3.

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Geology and Soils
Initial Study – Mitigated Negative Declaration 71
Figure 6 Faults, Landslide Zones, and Liquefaction Zones in Los Altos 523
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City of Los Altos
2023-2031 Housing Element Update
72 Ground Shaking
Seismically induced ground shaking covers a wide area and is greatly influenced by the distance of the site to the seismic source, soil conditions, and depth to groundwater. The USGS and Associated Bay Area Governments (ABAG) have worked together to map the likely intensity of ground-shaking throughout the Bay Area under various earthquake scenarios. The most intense ground-shaking scenario mapped in the vicinity assumes a 8.2 magnitude earthquake on the San Andreas Fault system (northern and peninsula segments). The predicted ground-shaking level from such an earthquake would be “severe shaking” throughout the city (ABAG 2022).

Liquefaction and Seismically Induced Settlement
Liquefaction is defined as the sudden loss of soil strength due to a rapid increase in soil pore water pressure resulting from seismic ground shaking. Liquefaction potential is dependent on such factors as soil type, depth to ground water, degree of seismic shaking, and the relative density of the soil.

When liquefaction of the soil occurs, buildings and other objects on the ground surface may tilt or sink, and lightweight buried structures (such as pipelines) may float toward the ground surface.

Liquefied soil may be unable to support its own weight or that of structures, which could result in loss of foundation bearing or differential settlement. Liquefaction may also result in cracks in the ground surface followed by the emergence of a sand-water mixture.

Los Altos sits on the very deep alluvial soils of the Santa Clara Valley floor, the soils of which contains silt, clay, sand, and gravel deposits, extending up to a depth of 4,000 to 5,000 feet throughout most of the city. Therefore, most of the city has low risk for liquefaction. According to the DOC, only a small portion of the western portion of the city near Foothill Expressway and University Avenue is subject to liquefaction (DOC 2022). As shown in Figure 6, one site in the northwestern portion of the city as well as several sites in the southern portion of the city and near Hale Creek and Permanente Creek are located on medium and very high liquefaction zones.

Seismically induced settlement occurs in loose to medium dense unconsolidated soil above groundwater. These soils compress (settle) when subject to seismic shaking. The settlement can be exacerbated by increased loading, such as from the construction of buildings. Settlement can also result solely from human activities including improperly placed artificial fill, and structures built on soils or bedrock materials with differential settlement rates.

Landslides
Landslides result when the driving forces that act on a slope (i.e., the weight of the slope material, and the weight of objects placed on it) are greater than the slope’s natural resisting forces (i.e., the shear strength of the slope material). Slope instability may result from natural processes, such as the erosion of the toe of a slope by a stream, or by ground shaking caused by an earthquake. Slopes can also be modified artificially by grading, or by the addition of water or structures to a slope.

Development that occurs on a slope can substantially increase the frequency and extent of potential slope stability hazards.

Areas susceptible to landslides are typically characterized by steep, unstable slopes in weak soil/bedrock units which have a record of previous slope failure. There are numerous factors that affect the stability of the slope, including: slope height and steepness, type of materials, material strength, structural geologic relationships, ground water level, and level of seismic shaking.

As shown in Figure 6, there are minimal landslide zones located within Los Altos. No housing inventory sites are located in a landslide zone.
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Geology and Soils
Initial Study – Mitigated Negative Declaration 73
Expansive Soils
Expansive soils can change dramatically in volume depending on moisture content. When wet, these soils can expand; conversely, when dry, they can contract or shrink. Sources of moisture that can trigger this shrink-swell phenomenon include seasonal rainfall, landscape irrigation, utility leakage, and/or perched groundwater. Expansive soil can develop wide cracks in the dry season, and changes in soil volume have the potential to damage concrete slabs, foundations, and pavement. Special building/structure design or soil treatment are often needed in areas with expansive soils. Expansive soils are typically very fine-grained with a high to very high percentage of clay. The clay minerals present typically include montmorillonite, smectite, and/or bentonite. Linear extensibility is used to determine the shrink-swell potential of soils. The shrink-swell potential or expansivity is low if the soil has a linear extensibility of less than 3 percent; moderate if 3 to 6 percent; high if 6 to 9 percent; and very high if more than 9 percent. Figure 7 shows soil types within the city and Table 12 lists those soil types and describes their expansivity.

Table 12 Los Altos Soil Parameters
Map Unit # Name Expansivity1
130 Urban Land Still-Complex, 0 to 2 percent slopes Moderate 131 Urban Land Elpaloalto Complex, 0 to 2 percent slopes Moderate to Very High 135 Urban Land-Stevenscreek Complex, 0 to 2 percent slopes Moderate 136 Urban Land-Stevenscreek Complex, 2 to 9 percent slopes Moderate 140 Urban Land-Flaskan Complex, 0 to 2 percent slopes Low to Moderate 141 Urban Land-Flaskan Complex, 2 to 9 percent slopes Low to Moderate 170 Urban-Landelspark Complex, 0 to 2 percent slopes Low 175 Urbanland-Botella Complex, 0 to 2 percent slopes Low 317 Urbanland-Cropley Complex, 0 to 2 percent slopes High 320 Literr-Merbeth Complex, 15 to 30 percent slopes Moderate to High 327 Literr-Urbanland-Merbeth Complex, 9 to 15 percent slopes Moderate to High 330 Montavista Clay Loam, 15 to 30 percent slopes Low to Moderate 331 Urbanland-Montavista Complex, 15 to 30 percent slopes Moderate to High 332 Urbanland-Montavista Complex, 2 to 9 percent slopes Moderate to High 334 Urban Land-Montavista-Togasara Complex, 9 to 15 percent slopes Moderate to High 337 Urban Land-Togasara-Montavista Complex, 2 to 9 percent slopes Moderate to High 1 Low expansivity: <3% linear extensibility
Moderate expansivity: 3-6% linear extensibility
High expansivity: 6-9% linear extensibility
Very high expansivity: >9% linear extensibility
Sources: USDA 2022, UC Davis 2022
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City of Los Altos
2023-2031 Housing Element Update
74 Figure 7 Soils Types in Los Altos
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Geology and Soils
Initial Study – Mitigated Negative Declaration 75
Erosion
Erosion is the wearing away of the soil mantle by running water, wind or geologic forces. It is a naturally occurring phenomenon and ordinarily is not hazardous. However, excessive erosion can contribute to landslides, siltation of streams, undermining of foundations, and ultimately the loss of structures. Removal of vegetation tends to heighten erosion hazards.

Regulatory Setting
California Building Code
The California Building Code (CBC), Title 24, Part 2 provides building codes and standards for the design and construction of structures in California. It requires, among other things, seismically resistant construction and foundation and soil investigations prior to construction. The CBC also establishes grading requirements that apply to excavation and fill activities and requires the implementation of erosion control measures. The City is responsible for enforcing the CBC within Los Altos. Chapter 12.08 of the LAMC enforces the adoption of the California Building Code (Title 24, Part 2).

The referenced codes and standards include requirements for evaluations of geologic conditions at future project sites and design and construction standards to address geologic hazards.

Geotechnical investigations are performed to identify the geologic conditions at a site and to evaluate whether a proposed project is feasible given the existing geological conditions. The Geotechnical report must be completed by a California licensed professional and must provide recommendations for foundation and structural design to address any geologic hazards. Such reports are required under the following conditions:
 New structures designed under the California Building Code in accordance with CBC 1803.5.11 and CBC 1803.5.12.
 New structures designed under the California Residential Code and located in a seismic hazard zone in accordance with CRC R401.4. This requirement does not apply to new accessory structures including utility sheds, garages and accessory dwelling units.  New structures within a delineated earthquake fault zone:
 A single-family wood-frame or steel-frame dwelling exceeding two stories or when any dwelling is part of a development of four or more dwellings. Public Resources Code Chapter 7.5  Multi-family and commercial of any kind.
 Alterations or additions to any structure within a seismic hazard zone which exceed either 50 percent of the value of the structure or 50 percent of the existing floor area of the structure.

Public Resources Code Chapter 7.8
 In accordance with CBC 1803.5.2 and CRC R401.4.1 where design values exceed the presumptive values or the classification, strength or compressibility of the soil is in doubt.  Where deep foundations will be used, a geotechnical investigation shall be conducted in accordance with CBC 1803.5.5.
 For new structures assigned to Seismic Design Category C, D, E or F, a geotechnical investigation shall be conducted in accordance with CBC 1803.5.11
527
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
76 Los Altos General Plan
The Natural Environment and Hazards Element of the Los Altos General Plan includes the following goals and policies related to geologic hazards:

Goal 1: Minimize risks of personal injury and property damage associated with seismic activity, landslides, and other geologic hazards.

Policy 1.1: Update acceptable levels of risk/life safety standards when necessary, and see that buildings are brought up to those standards, consistent with state law.

Policy 1.2: Avoid placement of critical facilities and high occupancy structures in areas known to be prone to ground failure during an earthquake.

Policy 1.3: Require soil analysis and erosion mitigation for all development proposed on sites known to be prone to erosion or ground failure.

Impact Analysis
a.1. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? There are no earthquake fault zones as delineated on the Alquist-Priolo Earthquake Fault Zoning Map in Los Altos (DOC 2021a). The closest active fault is the San Andreas Fault which is located approximately 5 miles west of the city. As a result, the likelihood of surface rupture occurring from active faulting that would affect future development under the proposed HEU is remote. No impact would occur.

NO IMPACT
a.2. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? CEQA is concerned with the impacts of a project on the environment, and not the impacts of the environment on a project. Therefore, a project would not have a significant environmental effect involving strong seismic ground shaking unless the project would increase the risk of harm to surrounding properties from such ground shaking. Any such impacts from any development project facilitated by the HEU is unlikely, not currently known, and wholly speculative at this time based upon available evidence. Therefore, the project would not have any known environmental impact involving strong seismic ground shaking.

Even if CEQA were concerned with impacts of the environment on projects, the impact would be less than significant. As with any site in the Bay Area region, development under the proposed HEU is susceptible to strong seismic ground shaking in the event of a major earthquake. Nearby faults include the San Andreas Fault, the Hayward Fault and the Calaveras Fault. These faults are capable of producing strong seismic ground shaking in the city.

Although nothing can ensure that residences and infrastructure do not fail under seismic stress, proper engineering can minimize the risk to life and property. Accordingly, building standards have been developed for construction in areas subject to seismic ground-shaking. Development facilitated by the proposed HEU would be required to comply with standards established by LAMC 528
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Geology and Soils
Initial Study – Mitigated Negative Declaration 77
Chapter 12.08 and 12.10, which adopts the California Building Code and the California Residential Code, respectively. The requirements of the California Building Code ensure that new habitable structures are engineered to withstand the expected ground acceleration at a given location.

Further, California Building Code Chapter 18 requires that actions recommended in a site-specific soil investigation are incorporated into the construction of each structure. Additionally, the project would promote infill development, which may involve replacing older buildings subject to seismic damage with newer structures built to current seismic standards that could better withstand the adverse effects of strong ground shaking. Although the risk of sustaining an earthquake with higher ground accelerations can never be completely eliminated, compliance with all applicable provisions of the California Building Code and the LAMC would ensure that potential impacts from groundshaking would be minimized to the extent possible.

Conformance with the requirements of the California Building Code, the California Residential Code, and LAMC would reduce impacts related to seismic ground shaking.

NO IMPACT
a.3. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction? CEQA is concerned with the impacts of a project on the environment, and not the impacts of the environment on a project. Therefore, a project would not have a significant environmental effect involving seismic-related ground failure, including liquefaction, unless the project would increase the risk of harm to surrounding properties from such geologic hazards. Any such impacts from any development project facilitated by the HEU is unlikely, not currently known, and wholly speculative at this time based upon available evidence. Therefore, the project would not have any known environmental impact involving seismic-related ground failure, including liquefaction.

Even if CEQA were concerned with impacts of the environment on projects, the impact would be less than significant. As shown on Figure 6, although the majority of inventory sites are not located in liquefaction zones, some would be located on high to very high liquefaction zones within the City.

However, future development facilitated by the proposed HEU would be subject to applicable policies within the Natural Environment and Hazards Element of the Los Altos General Plan, specifically Policy 1.3, requires soil analysis and erosion mitigation for all development proposed on sites know to be prone to erosion or ground failure. In addition, LAMC Section 13.20.070 (Required Soil Report) requires preparation of a preliminary soils report to identify soil problems which would lead to structural defects and incorporate corrective actions to prevent structural damage. Policy

1.3 and LAMC Section 13.20.070 would require preparation of a soils analysis, which would identify potentially liquefiable soils on the housing sites. Chapter 18 of the California Building Code also requires that actions recommended in a site-specific soil investigation are incorporated into the construction of each structure. Compliance with State and City requirements would reduce seismic ground shaking impacts with current engineering practices and the project would not exacerbate liquefaction potential in the area. As such, the proposed HEU would not directly or indirectly cause substantial adverse effects from liquefaction risk.

NO IMPACT
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City of Los Altos
2023-2031 Housing Element Update
78 a.4. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides?
As shown in Figure 6, no proposed housing sites are located on or in proximity to landslide-prone areas. Also, development facilitated by the proposed HEU would be required to comply with the Public Resources Code (PRC) Section 2690-2699.6, Seismic Hazards Mapping Act, Chapter 12.08 and

12.10 of the LAMC, which adopts the California Building Code (CBC) and the California Residential Code, respectively, and the City’s design review process, which regulates and provides requirements for development on steeper slopes. Furthermore, development facilitated by the proposed HEU would be required to adhere to Policy 1.3 of the Natural Environment and Hazards Element of the Los Altos General Plan and LAMC Section 13.20.070 which would require soil analysis and erosion mitigation and would reduce impacts to landslides to a less than significant level. Therefore, the impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
b. Would the project result in substantial soil erosion or the loss of topsoil? The proposed HEU would mostly include infill development in undeveloped and underutilized areas and rezoning to allow for increased density. Demolition and construction activities would be required to comply with CBC, Appendix Section J110, Erosion Control Standards, pursuant to Chapter 12.08 of the LAMC, which ensures appropriate erosion and stormwater pollution control during grading and construction activities.

Construction activities that occur on more than one acre are required to obtain a National Pollutant Discharge Elimination System (NPDES) Construction General Permit. NPDES requires the development of a storm water pollution prevention plan (SWPPP), which includes best management practices (BMP) to reduce erosion and topsoil loss from stormwater runoff. BMP examples generally include an effective combination of erosion and sediment controls, which include barriers such as silt fences, hay bales, drain inlet protection, or gravel bags.

As discussed under checklist questions (a.3), (a.4), and (c) above, development facilitated under the proposed HEU would also be required to comply with Policy 1.3 of the Natural Environment and Hazards Element of the Los Altos General Plan, which would require soil analysis and erosion mitigation in order to prevent excessive erosion and runoff. Therefore, this impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
c. Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
CEQA is concerned with the impacts of a project on the environment, and not the impacts of the environment on a project. Therefore, a project would not have a significant environmental effect involving landslides, lateral spreading, subsidence, liquefaction, or collapse, unless the project would increase the risk of harm to surrounding properties from such geologic hazards. Any such impacts from any development project facilitated by the HEU is unlikely, not currently known, and wholly speculative at this time based upon available evidence. Therefore, the project would not have any known environmental impact involving landslides, lateral spreading, subsidence, liquefaction, or collapse.
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Geology and Soils
Initial Study – Mitigated Negative Declaration 79
Moreover, as shown in Figure 6, no proposed housing sites are located on or in proximity to landslide-prone areas. Development facilitated by the proposed HEU would be required to comply with the Public Resources Code (PRC) Section 2690-2699.6, Seismic Hazards Mapping Act, Chapter

12.08 and 12.10 of the LAMC, which adopts the California Building Code (CBC) and the California Residential Code, respectively, and the City’s design review process, which regulates and provides requirements for development on steeper slopes. The project would also facilitate development that would replace older buildings subject to seismic damage with newer structures built to current seismic standards that could better withstand the adverse effects associated with unstable soils and liquefaction. Furthermore, development facilitated by the proposed HEU would be required to adhere to Policy 1.3 of the Natural Environment and Hazards Element of the Los Altos General Plan and LAMC Section 13.20.070 which would require soil analysis and erosion mitigation and would reduce impacts to landslides, lateral spreading, subsidence, liquefaction, and collapse.

NO IMPACT
d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Soils that volumetrically increase (swell) or expand when exposed to water and contract when dry (shrink) are considered expansive soils. The potential for soil to shrink and swell depends on the amount and types of clay in the soil. Highly expansive soils can cause structural damage to foundations and roads without proper structural engineering and are less suitable or desirable for development than non-expansive soils because of the necessity for detailed geologic investigations and costlier grading applications.

CEQA is concerned with the impacts of a project on the environment, and not the impacts of the environment on a project. Therefore, a project would not have a significant environmental effect involving expansive soils unless the project would increase the risk of harm to surrounding properties from such geologic hazards. Any such impacts from any development project facilitated by the HEU is unlikely, not currently known, and wholly speculative at this time based upon available evidence. Therefore, the project would not have any known environmental impact involving expansive soils.

Even if CEQA were concerned with impacts of the environment on projects, the impact would be less than significant. As shown in Table 12, only map unit 130 (Urban Land Elpaloalto Complex, 0 to 2 percent slopes) has moderate to very high soil expansivity. As shown in Figure 7, no housing sites are located on map unit 130. Table 12 also shows moderate to high soil expansivity in map units 320 (Literr-Merbeth Complex, 15 to 30 percent slopes), 327 (Literr-Urbanland-Merbeth Complex, 9 to 15 percent slopes), 331 (Urbanland-Montavista Complex, 15 to 30 percent slopes), 332 (UrbanlandMontavista Complex, 2 to 9 percent slopes), 334 (Urban Land-Montavista-Togasara Complex, 9 to 15 percent slopes), and 337 (Urban Land-Togasara-Montavista Complex, 2 to 9 percent slopes).

According to Figure 7, only three housing sites are located on map unit 327, two housing sites on map unit 331, and one housing site on map unit 334. Future development would be required to comply with the Natural Environment and Hazards Element of the Los Altos General Plan, which includes goals and policies designed to address potential geologic impacts. Consistent with Section 1803 of the CBC, Policy 1.3 of the Los Altos General Plan would require soil analysis and erosion mitigation which would identify areas of expansive soils and require corrective action to reduce impacts to a less than significant level. Further, LAMC Section 13.20.070 (Required Soil Report) requires preparation of a preliminary soils report to identify the presence of expansive soils which would lead to structural defects and incorporate corrective actions to prevent structural damage. 531
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
80 The CBC also includes requirements to address soil-related hazards. Typical measures to treat hazardous soil conditions involve removal of soil or fill materials, proper fill selection, and compaction. In cases where soil remediation is not feasible, the CBC requires structural reinforcement of foundations to resist the forces of expansive soils. This would ensure that the potential for projects to occur on expansive soils such that substantial direct or indirect risks to life or property to occur would be reduced.

NO IMPACT
e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
Los Altos is served by the City’s established wastewater system. The proposed HEU would facilitate development on undeveloped or underutilized sites and would rezone sites to allow for increased density. These sites are and would continue to be served by the City’s wastewater system. The project would not include the use of septic tanks or alternative wastewater disposal systems. There would be no impact.

NO IMPACT
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Paleontological resources, or fossils, are the evidence of once-living organisms preserved in the rock record. They include both the fossilized remains of ancient plants and animals and the traces thereof (e.g., trackways, imprints, burrows, etc.). Paleontological resources are not found in “soil” but are contained within the geologic deposits or bedrock that underlies the soil layer. Typically, fossils are greater than 5,000 years old (i.e., older than middle Holocene in age) and are typically preserved in sedimentary rocks. Although rare, fossils can also be preserved in volcanic rocks and low-grade metamorphic rocks under certain conditions (Society of Vertebrate Paleontology [SVP] 2010). Fossils occur in a non-continuous and often unpredictable distribution within some sedimentary units, and the potential for fossils to occur within sedimentary units depends on several factors. It is possible to evaluate the potential for geologic units to contain scientifically important paleontological resources, and therefore evaluate the potential for impacts to those resources and provide mitigation for paleontological resources if they are discovered during construction of a development project.

Rincon Consultants evaluated the paleontological sensitivity of the geologic units that underlie the project site to assess the project’s potential for significant impacts to scientifically important paleontological resources. The analysis was based on the results of a paleontological locality search and a review of existing information in the scientific literature regarding known fossils within geologic units mapped at the project site. According to the SVP (2010) classification system, geologic units can be assigned a high, low, undetermined, or no potential for containing scientifically significant nonrenewable paleontological resources. Following the literature review, a paleontological sensitivity classification was assigned to each geologic unit mapped within the project site. This criterion is based on rock units within which vertebrate or significant invertebrate fossils have been determined by previous studies to be present or likely to be present. The potential for impacts to significant paleontological resources is based on the potential for ground disturbance to directly impact paleontologically sensitive geologic units. 532
Agenda Item # 3.

Environmental Checklist
Geology and Soils
Initial Study – Mitigated Negative Declaration 81
According to the geologic map of Brabb et al. (2000) and as shown on Figure 8, the City of Los Altos is underlain by five geologic units: Quaternary stream channel deposits, Quaternary natural levee deposits, Quaternary (Holocene) alluvial fan and fluvial deposits, Quaternary (Pleistocene) alluvial fan and fluvial deposits, and the Santa Clara Formation.

Quaternary stream channel deposits underlie the various creeks in Los Altos including Stevens Creek, Permanente Creek, Hale Creek, and Adobe Creek. Quaternary stream channel deposits consist of poorly to well-sorted silt, sand, or sandy gravel with some cobbles and are Holocene in age (Brabb et al. 2000). Quaternary stream channel deposits are too young (i.e., less than 5,000 years old) to preserve paleontological resources (SVP 2010). Therefore, Quaternary stream channel deposits have low paleontological sensitivity.

Quaternary natural levee deposits are found along Stevens Creek in eastern Los Altos. Quaternary natural levee deposits consist of loose, moderately to well-sorted sandy silt grading upward to silty clay and are Holocene in age (Brabb et al. 2000). Quaternary natural levee deposits are too young (i.e., less than 5,000 years old) to preserve paleontological resources (SVP 2010). Therefore, Quaternary natural levee deposits have low paleontological sensitivity.

Quaternary (Holocene) alluvial fan and fluvial deposits underlie much of eastern Los Altos.

Quaternary (Holocene) alluvial fan and fluvial deposits consist of brown or tan, sand or gravel that grades upward to sandy or silty clay and are Holocene in age (Brabb et al. 2000). Fossil discoveries in areas mapped as Holocene alluvial sediments in Santa Clara County demonstrate that Holoceneaged alluvial fan and fluvial deposits may be as thin as 9 feet in some areas and are underlain by Pleistocene-aged sediments (Maguire and Holroyd 2016). Quaternary (Holocene) alluvial fan and fluvial deposits are too young (i.e., less than 5,000 years old) to preserve paleontological resources (SVP 2010). Therefore, Quaternary (Holocene) alluvial fan and fluvial deposits have low paleontological sensitivity.

Quaternary (Pleistocene) alluvial fan and fluvial deposits underlie large portions of Los Altos.

Quaternary (Pleistocene) alluvial fan and fluvial deposits consist of brown, gravelly or clayey sand that grades upward into sandy clay and are Pleistocene in age (Brabb et al. 2000). Pleistocene alluvial sediments have produced significant vertebrate fossils throughout Santa Clara County, including mammoth (Mammuthus), ground sloth (Paramylodon), camel (Camelops), peccary (Platygonus), pronghorn (Capromeryx), rabbit, rodents, and reptiles (Jefferson 2010; Maguire and Holroyd 2016; Paleobiology Database [PBDB] 2022; University of California Museum of Paleontology [UCMP] 2022). Given this fossil-producing history, Quaternary (Pleistocene) alluvial fan and fluvial deposits have high paleontological sensitivity.

The Santa Clara Formation underlies portions of southern and western Los Altos. The Santa Clara Formation consists of gray to reddish-brown, moderately consolidated, conglomerate, sandstone, and mudstone arranged in irregular and lens-like beds and is Pleistocene to Pliocene in age (Brabb et al. 2000). The Santa Clara Formation contains several significant paleontological resources in Santa Clara County yielding taxa such as American cheetah (Miracinonyx), bison (Bison), horse (Equus), deer (Cervidae), fish, plants, and invertebrates (PBDB 2022; UCMP 2022). Given this fossil, producing history, the Santa Clara Formation has high paleontological sensitivity. 533
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
82 Figure 8 Geologic Map and Paleontological Sensitivity of Los Altos 534
Agenda Item # 3.

Environmental Checklist
Geology and Soils
Initial Study – Mitigated Negative Declaration 83
Ground disturbance in previously undisturbed sediments with high paleontological sensitivity may result in significant impacts to paleontological resources. However, potentially significant impacts to paleontological resources can only be determined once a specific project has been proposed because the effects are highly dependent on both the individual project site conditions (e.g., presence of previously disturbed sediments or artificial fill) and the characteristics of the proposed ground disturbance (e.g., depth, total volume, type of construction). Ground disturbing activities associated with construction facilitated by this project, particularly in areas that have not previously been developed with urban uses, have the potential to damage or destroy paleontological resources that may be present on or below the ground surface in areas of high paleontological sensitivity.

Consequently, damage to or destruction of fossils could occur due to development under the proposed HEU. This impact would be potentially significant.

Mitigation Measures
The following mitigation measure is required:

GEO-1 Protection of Paleontological Resources
The City shall establish the following Standard Condition of Approval for projects requiring approval in areas of high paleontological sensitivity (Quaternary (Pleistocene) alluvial fan and fluvial deposits and Santa Clara Formation) and that involve ground disturbance below the level of past disturbance:

PALEONTOLOGICAL RESOURCES ASSESSMENT
Prior to initial ground disturbance, the applicant shall retain a Qualified Professional Paleontologist, as defined by the SVP (2010), to conduct a paleontological resources assessment (PRA). The PRA shall determine the age and paleontological sensitivity of geologic formations underlying the proposed disturbance area, consistent with SVP (2010) guidelines for categorizing paleontological sensitivity of geologic units within a project area.

If underlying formations are found to have a high potential for paleontological resources, the Qualified Professional Paleontologist shall create a Paleontological Mitigation and Monitoring Program, which will be approved by the City and contain the following elements:

PALEONTOLOGICAL WORKER ENVIRONMENTAL AWARENESS PROGRAM (WEAP) Prior to the start of construction, the Qualified Professional Paleontologist or their designee shall conduct a paleontological Worker Environmental Awareness Program (WEAP) training for construction personnel regarding the appearance of fossils and procedures for notifying paleontological staff should fossils be discovered by construction staff.

PALEONTOLOGICAL MONITORING
Full-time paleontological monitoring shall be conducted during ground disturbing construction activities (i.e., grading, trenching, foundation work) in sediments assigned a high paleontological sensitivity. Paleontological monitoring shall be conducted by a qualified Paleontological Resources Monitor, as defined by the SVP (2010). The duration and timing of the monitoring will be determined by the Qualified Professional Paleontologist based on the observation of the geologic setting from initial ground disturbance, and subject to the review and approval by the City. If the Qualified Professional Paleontologist determines that full-time monitoring is no longer warranted, based on the specific geologic conditions once the full depth of excavations 535
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
84 has been reached, they may recommend that monitoring be reduced to periodic spot-checking or ceased entirely. Monitoring shall be reinstated if any new ground disturbances are required, and reduction or suspension shall be reconsidered by the Qualified Professional Paleontologist at that time. In the event of a fossil discovery by the paleontological monitor or construction personnel, all work in the immediate vicinity of the find shall cease. A Qualified Professional Paleontologist shall evaluate the find before restarting construction activity in the area. If it is determined that the fossil is scientifically significant, then it shall be salvaged, identified to the lowest possible taxonomic level, and curated in a scientific institution with a permanent paleontological collection along with all pertinent field notes, photos, data, and maps.

Upon completion of ground disturbing activity (and curation of fossils if necessary) the Qualified Professional Paleontologist shall prepare a final report describing the results of the paleontological monitoring efforts associated with the project. The report shall include a summary of the field and laboratory methods, an overview of the project geology and paleontology, a list of taxa recovered (if any), an analysis of fossils recovered (if any) and their scientific significance, and recommendations. The report shall be submitted to the City. If the monitoring efforts produced fossils, then a copy of the report shall also be submitted to the designated museum repository.

Significance After Mitigation
Implementation of Mitigation Measure GEO-1 would ensure procedures are in place to avoid destruction of paleontological resources. Impacts would be less than significant with mitigation.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
536
Agenda Item # 3.

Environmental Checklist
Greenhouse Gas Emissions
Initial Study – Mitigated Negative Declaration 85
8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment? □ □ ■ □
b. Conflict with an applicable plan, policy, or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases? □ □ ■ □
Environmental Setting
Gases that absorb and re-emit infrared radiation in the atmosphere are called GHGs. The gases widely seen as the principal contributors to human-induced climate change include carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O), fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere, and natural processes, such as oceanic evaporation, largely determine its atmospheric concentrations. GHGs are emitted by natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are usually by-products of fossil fuel combustion, and CH4 results from off-gassing associated with agricultural practices and landfills. Human-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and SF6 (U.S. EPA 2021). Different types of GHGs have varying global warming potentials (GWP). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emitted, referred to as “carbon dioxide equivalent” (CO2e), which is the amount of GHG emitted multiplied by its GWP.

Carbon dioxide has a 100-year GWP of one. By contrast, methane has a GWP of 30, meaning its global warming effect is 30 times greater than CO2 on a molecule per molecule basis (IPCC 2021).10 In 2018, Los Altos generated approximately 1,128 MT CO2e from government activities, and 110,192 MT CO2e from community activities, for a total of 111,320 MT CO2e. For the community sector, onroad motor vehicles were the largest source of GHG emissions within Los Altos, generating approximately 65 percent of total community GHG emissions. Residential energy was the second largest GHG emission source, generating approximately 32 percent of total community GHG emissions. Commercial energy contributed approximately 7 percent, while solid waste and water 10 The Intergovernmental Panel on Climate Change’s (2021) Sixth Assessment Report determined that methane has a GWP of 30.

However, the 2017 Climate Change Scoping Plan published by the California Air Resources Board uses a GWP of 25 for methane, consistent with the Intergovernmental Panel on Climate Change’s (2007) Fourth Assessment Report. Therefore, this analysis utilizes a GWPs from the Fourth Assessment Report.
537
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
86 and wastewater represented the smallest GHG emissions sources at 2 percent and 1 percent, respectively. Table 13 provides a summary of the 2018 government and community GHG emissions inventory results by GHG emission sector.

Table 13 2018 Community GHG Emissions Inventory Results by Sector GHG Emissions Sector
GHG Emissions
(MT CO2e)
Percent of
GHG Emissions Totals
Government 1,128 100%
Employee Commute 445 39%
Vehicle Fleet 351 31%
Solid Waste Facilities 172 15%
Buildings and Facilities 134 12%
Process and Fugitive Emissions 21 2%
Water and Wastewater Treatment Facilities 5 <1%
Community 110,192 100%
Transportation and Mobile Sources 71,531 65%
Residential Energy 35,661 32%
Commercial Energy 7,535 7%
Solid Waste 2,653 2%
Water and Wastewater 1,063 1%
MT CO2e = metric tons of carbon dioxide equivalent
Totals may not add due to rounding.

Source: City of Los Altos 2022a
Impact Analysis
a. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
In response to climate change, California implemented AB 32, the “California Global Warming Solutions Act of 2006.” AB 32 requires the reduction of statewide GHG emissions to 1990 emissions levels (essentially a 15 percent reduction below 2005 emission levels) by 2020 and the adoption of rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emissions reductions. On September 8, 2016, the Governor signed SB 32 into law, extending AB 32 by requiring the State to further reduce GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On December 14, 2017, the CARB adopted the 2017 Scoping Plan, which provides a framework for achieving the 2030 target. The 2017 Scoping Plan relies on the continuation and expansion of existing policies and regulations, such as the Capand-Trade Program and the Low Carbon Fuel Standard, and implementation of recently adopted policies and legislation, such as SB 1383 (aimed at reducing short-lived climate pollutants including methane, hydrofluorocarbon gases, and anthropogenic black carbon) and SB 100 (discussed further below). The 2017 Scoping Plan also puts an increased emphasis on innovation, adoption of existing technology, and strategic investment to support its strategies. As with the 2013 Scoping Plan Update, the 2017 Scoping Plan does not provide project-level thresholds for land use development.

Instead, it recommends local governments adopt policies and locally appropriate quantitative thresholds consistent with a statewide per capita goal of 6 metric tons MT CO2e by 2030 and 2 MT 538
Agenda Item # 3.

Environmental Checklist
Greenhouse Gas Emissions
Initial Study – Mitigated Negative Declaration 87
CO2e by 2050 (CARB 2017). On September 10, 2018, the Governor signed Executive Order (EO) B-55- 18, which identifies a new goal of carbon neutrality by 2045 and supersedes the goal established by EO S-3-05.11 CARB has been tasked with including a pathway toward the EO B-55-18 carbon neutrality goal in the next Scoping Plan update which is currently being drafted.

BAAQMD recently adopted updated thresholds for evaluating the significance of climate impacts from plan-level projects on April 20, 2022. The updated thresholds state that a plan-level project must either meet the State’s goals to reduce emissions to 40 percent below 1990 levels by 2030 and carbon neutrality by 2045; or be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).

The City of Los Altos adopted its Climate Action and Adaptation Plan (CAAP) in March 2022 as an update to the 2013 Climate Action Plan (CAP), which aims to achieve carbon neutrality by 2035.

Although the City’s CAAP includes a GHG emissions inventory; a reduction target of 67,000 MT CO2e by 2035; forecast projected emissions for activities covered by the CAAP; reduction measures in the form of strategies, goals, and actions; and a monitoring and reporting process, it was not adopted in following comprehensive environmental review and therefore conservatively does not consider it to be a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b) for the purpose of this analysis. However, the CAAP outlines guidance to reduce the emissions in Los Altos by approximately 67,000 MT CO2e by 2035 in order to reach the goal of carbon neutrality by 2035. Therefore, the CAAP is consistent with the State’s goals to reduce emissions to 40 percent below 1990 levels by 2030 and carbon neutrality by 2045, and the project would result in a less than significant impact if it would be consistent with the City’s CAAP. As shown below under checklist question (b), the proposed HEU would be consistent with applicable CAAP strategies and actions. Therefore, impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
Potential Emissions Generated by the Proposed HEU
For informational purposes, GHG emissions associated with development under the proposed HEU are shown in Table 14. Since the city’s Reach Code requires all-electric units in future construction, it was assumed that the natural gas demand estimated for the project would instead be supplied by electricity to account for increased electricity usage. As shown in the table, annual emissions from full buildout of the project’s envisioned increase of 1,648 dwelling units over existing conditions would be 8,011 MT of CO2e per year. With a project increase in population of 4,582 over existing conditions, this would result in an increase of 1.7 MT of CO2e per service population per year. This analysis is provided for informational purposes only because the BAAQMD significance thresholds are based on consistency with the City’s CAAP, as discussed above. 11 Executive Order (EO) S-3-05, signed by Governor Arnold Schwarzenegger in 2005, proclaims that California is vulnerable to the impacts of climate change. It declares that increased temperatures could reduce the Sierra Nevada snowpack, further exacerbate California’s air quality problems, and potentially cause a rise in sea levels. To combat those concerns, the EO established total GHG emission targets for the state. Specifically, emissions are to be reduced to the 2000 level by 2010, the 1990 level by 2020, and to 80 percent below the 1990 level by 2050.
539
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
88 Table 14 Operational GHG Emissions
Emission Source Annual Emissions (MT of CO2e)
Operational
Area 20
Energy 3
Mobile 7,481
Waste 439
Water 67
Operational Total 8,011
Project Population Increase 4,582
MT of CO2e per Service Population 1.7
Source: See Appendix C for modeling results. Trip generation information provided by Hexagon Transportation Consultants, Inc.

LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
As discussed under checklist question (a) above, the City of Los Altos adopted its Climate Action and Adaptation Plan (CAAP) in March 2022 as an update to the 2013 Climate Action Plan (CAP), which aims to achieve carbon neutrality by 2035. Table 15 shows the project’s consistency with applicable CAAP strategies and actions. As shown in Table 15, the proposed HEU would be consistent with applicable goals and actions from the City’s CAAP. This impact would be less than significant.

Table 15 Project Consistency with Applicable Climate Action and Adaptation Plan Actions
Recommended Actions Project Consistency
Transportation
Action 1.2A: Support transit-oriented development.

Require increased residential and commercial
density and diversity along main corridors and
commercial areas, including affordable multi-family
housing and mixed-use developments. Encourage
Transit-Oriented Development along major bus
routes within and outside of the City to attract new
employers and better serve the daily needs of
residents and employees. Set a target of at least a
20% increase in the percent of the city’s population
living in high-density Transit-Oriented Development
by 2035. Integrate with the City’s Housing Element
(ensure meeting RHNA commitments encourages
high-density & affordable housing in transitaccessible/walkable areas).

Consistent: The project would facilitate development of housing in the Downtown, near commercial areas, and near or adjacent to transportation corridors currently served by bus stops and Class II and Class III bicycle lanes.
540
Agenda Item # 3.

Environmental Checklist
Greenhouse Gas Emissions
Initial Study – Mitigated Negative Declaration 89
Recommended Actions Project Consistency
Action 1.5A: Increase the number of available Level
2 EV charging stations in workplace, commercial
and multifamily areas. Increase the number of
available Level 2 EV charging stations at businesses
with >50 employees, multifamily homes of >10 units,
and in commercial areas. Adopt an Electric Vehicle
Supply Equipment Master Plan to identify number
and location of EVSE.

Consistent: Pursuant to the City’s Reach Code, new multifamily residences with less than or equal to 20 dwelling units would be required to install at least one Level 2 EV Ready space for each dwelling unit. For multi-family residences with more than 20 units, 25 percent of the dwelling units with parking spaces must include at least one Level 2 EV Ready space, and each remaining dwelling unit with parking spaces must include one Level 1 EV Ready space. Future
development would also be required to comply with LAMC
Chapter 12.22, which mandates the implementation of the most current version of Title 24. Title 24 contains
requirements for EV spaces in new construction. Future
development facilitated by the project would be required to comply with the most updated EV requirements in both the City’s Reach Code and Title 24 at the time of construction.

Action 1.6A: Phase out off-road fossil fuel engines
such as landscaping equipment. Accelerate phaseout of small off-road fossil fuel engines such as landscaping equipment through bans, replacement
ordinances, and/or incentives for electric
alternatives. Work to reduce construction-related
emissions. Form an Environmental Commission
subcommittee to develop rules and/or ordinances.

Consistent: Pursuant to LAMC Section 6.16.070, residents of new future development are prohibited from using gasolinepowered leaf blowers. Additionally, as discussed in Section 6, Energy, construction activities associated with reasonably foreseeable development under the proposed HEU would be required to utilize fuel-efficient equipment consistent with federal and State regulations, which would reduce the usage of energy and emittance of GHG.

Energy
Action 2.1B: Increase residential and commercial
energy efficiency. Develop a program to increase
energy efficiency in existing residential buildings
including wall and ceiling insulation, roof
replacements, new ducting and windows, lighting
upgrades, and outdoor amenities upgrades. Identify
outside funding to perform upgrades identified in
energy audits performed under action 2.1 A, and
ensure eligible residents and businesses take
advantage of all available energy efficiency incentive
programs.

Consistent. Development facilitated by the project would be required to comply with the LAMC Chapter 12.22, which
mandates the implementation of Title 24. Compliance would include complying with the most updated rooftop solar
requirements at the time of construction. Future
development would also be required to comply with the
City’s Reach Code which is currently being revised, but would require all-electric construction for all newly constructed buildings. Electricity would be provided either by Silicon Valley Clean Energy (SVCE) or PG&E, which are required to generate electricity that would increase renewable energy resources to 60 percent by 2030 and 100 percent by 2045. As the City’s main electricity provider, SVCE enrolls new
customers in their GreenStart program, which currently
sources 50 percent of electricity from renewable energy sources and 50 percent from carbon-free sources. Customers have the option to upgrade to SVCE’s GreenPrime program which sources 100 percent of electricity from renewable energy sources (SVCE 2022).

Action 2.5A: Increase community solar capacity.

Increase solar panel requirements in new
construction from 4kW to 6kW minimum, and add
solar panel requirement for large additions and
remodels (>4kW). Ensure residents and businesses
are aware of and take advantage of incentive
programs for solar panels.

Consistent. Pursuant to Title 24, most residences would be required to include rooftop solar systems. LAMC Chapter

12.70 serves to expedite and streamline the solar permitting process for small residential rooftop solar systems in order to incentivize new construction to include solar.
541
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City of Los Altos
2023-2031 Housing Element Update
90 Recommended Actions Project Consistency
Resource Conservation
Action 3.1A: Increase the landfill diversion rate.

Increase landfill diversion rate to 90% by 2030 and
95% by 2035, negotiated in the next Franchise
Agreement. Launch an education and awareness
campaign for residents and businesses to help
promote best practices.

Consistent: In accordance with LAMC Section 6.12.050,
multi-family residences with five or more units would be required to provide recycling service for tenants. Future residents would also be required to recycle organics
pursuant to SB 1383.

Action 3.1C: Reduce waste from demolition,
construction and building materials. Develop an
ordinance requiring the deconstruction of old
buildings instead of demolition and the recycling/reuse of materials. Provide incentives to builders for the use of environmentally friendly construction
materials.

Consistent: Pursuant to Chapter 6.14 of the LAMC, future projects would be required to comply with construction
waste management practices to divert at least 65 percent of construction and demolition debris.

Action 3.2A: Increase communitywide water
efficiency. Increase education and awareness of
water efficiency programs through Calwater and
other organizations. Continue to support
implementation of the 2015 UWMP through
enforcement of the 2015 Model Water Efficient
Landscape Ordinance. Develop an ordinance
requiring conversion of grass lawns to low-water
landscaping. Consider an update to the building code
prohibiting new grass lawns.

Consistent: Future development that needs new or
expanded water service would be required to comply with the California Water Service Company’s and CALGreen’s
water efficiency regulations, and the state’s Model Water Efficiency Landscape Ordinance to reduce indoor and
outdoor water use.

Climate Risk
Action 6.1C: Expand green infrastructure program
to reduce impermeable surface areas and capture
runoff from paved areas. Implement porous paving
in sidewalks, parking lots and driveways, and other
water percolation methods like bioswales to reduce
stormwater runoff to streets.

Consistent: Future development facilitated by the proposed HEU would be required to comply with stormwater pollution prevention measures outlined in Chapter 10.16 of the LAMC, which would reduce stormwater runoff to streets.

Source: City of Los Altos 2022a

LESS THAN SIGNIFICANT IMPACT
542
Agenda Item # 3.

Environmental Checklist
Hazards and Hazardous Materials
Initial Study – Mitigated Negative Declaration 91
9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ ■ □
b. Create a significant hazard to the public
or the environment through reasonably
foreseeable upset and accident
conditions involving the release of
hazardous materials into the
environment? □ □ ■ □
c. Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within

0.25 mile of an existing or proposed
school? □ ■ □ □
d. Be located on a site that is included on a
list of hazardous material sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment? □ ■ □ □
e. For a project located in an airport land
use plan or, where such a plan has not
been adopted, within two miles of a
public airport or public use airport, would
the project result in a safety hazard or
excessive noise for people residing or
working in the project area? □ □ □ ■
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan? □ □ ■ □
g. Expose people or structures, either
directly or indirectly, to a significant risk
of loss, injury, or death involving wildland
fires? □ □ ■ □
543
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
92 Regulatory Setting
Toxic Substances Control Act (1976) and the Resource Conservation and Recovery Act of 1976 (RCRA)
These acts established a program administered by the USEPA for the regulation of the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA was amended in 1984 by the Hazardous and Solid Waste Act, which affirmed and extended the “cradle to grave” system of regulating hazardous wastes. Among other things, the use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by the Hazardous and Solid Waste Act.

U.S. Department of Transportation Regulations
DOT prescribes strict regulations for the safe transportation of hazardous materials, including requirements for hazardous waste containers and licensed haulers that transport hazardous waste on public roads. The Secretary of the DOT receives the authority to regulate the transportation of hazardous materials from the Hazardous Materials Transportation Act (HMTA), as amended and codified in in 49 U.S. Code (U.S.C.) Section 5101 et seq. The Secretary is authorized to issue regulations to implement the requirements of 49 U.S.C. The Pipeline and Hazardous Materials Safety Administration, formerly the Research and Special Provisions Administration, was delegated the responsibility to write the hazardous materials regulations, which are contained in Title 49 of the CFR Parts 100-180. Title 49 of the CFR, which contains the regulations set forth by the HMTA, specifies requirements and regulations with respect to the transport of hazardous materials. It requires that every employee who transports hazardous materials receive training to recognize and identify hazardous materials and become familiar with hazardous materials requirements. Under the HMTA, the Secretary "may authorize any officer, employee, or agent to enter upon, inspect, and examine, at reasonable times and in a reasonable manner, the records and properties of persons to the extent such records and properties relate to: (1) the manufacture, fabrication, marking, maintenance, reconditioning, repair, testing, or distribution of packages or containers for use by any 'person' in the transportation of hazardous materials in commerce; or (2) the transportation or shipment by any 'person' of hazardous materials in commerce.

Department of Toxic Substances Control
As a department of the California Environmental Protection Agency, the DTSC is the primary agency in California that regulates hazardous waste, cleans up existing contamination, and looks for ways to reduce the hazardous waste produced in California. DTSC regulates hazardous waste in California primarily under the authority of RCRA and the California Health and Safety Code.

The DTSC also administers the California Hazardous Waste Control Law (HWCL) to regulate hazardous wastes. While the HWCL is generally more stringent than RCRA, until the USEPA approves the California program, both state and federal laws apply in California. The HWCL lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills.

Government Code Section 65962.5 requires the DTSC, the State Department of Health Services, the State Water Resources Control Board, and CalRecycle to compile and annually update lists of hazardous waste sites and land designated as hazardous waste sites throughout the state. The Secretary for Environmental Protection consolidates the information submitted by these agencies 544
Agenda Item # 3.

Environmental Checklist
Hazards and Hazardous Materials
Initial Study – Mitigated Negative Declaration 93
and distributes it to each city and county where sites on the lists are located. Before the lead agency accepts an application for any development project as complete, the applicant must consult these lists to determine if the site at issue is included.

If any soil is excavated from a site containing hazardous materials, it would be considered a hazardous waste if it exceeded specific criteria in Title 22 of the California Code of Regulations.

Remediation of hazardous wastes found at a site may be required if excavation of these materials is performed, or if certain other soil disturbing activities would occur. Even if soil or groundwater at a contaminated site does not have the characteristics required to be defined as hazardous waste, remediation of the site may be required by regulatory agencies subject to jurisdictional authority.

Cleanup requirements are determined on a case-by-case basis by the agency taking jurisdiction.

California Occupational Safety and Health Act – California Labor Code, Section 6300 et seq.

The California Occupational Safety and Health Act of 1973 addresses California employee working conditions, enables the enforcement of workplace standards, and provides for advancements in the field of occupational health and safety. The Act also created CalOSHA, the primary agency responsible for worker safety in the handling and use of chemicals in the workplace. CalOSHA’s standards are generally more stringent than federal regulations. Under the former, the employer is required to monitor worker exposure to listed hazardous substances and notify workers of exposure. The regulations specify requirements for employee training, availability of safety equipment, accident-prevention programs, and hazardous substance exposure warnings. At sites known or suspected to be contaminated by hazardous materials, workers must have training in hazardous materials operations and a Site Health and Safety Plan must be prepared, which establishes policies and procedures to protect workers and the public from exposure to potential hazards at the contaminated site.

California Code of Regulations, Title 22, Hazardous Waste Management At the State level, under Title 22, Division 4.5 of the CCR, DTSC regulates hazardous waste in California primarily under the authority of the Federal RCRA and the California Health and Safety Code. The HWCL, under CCR 22, Chapter 30, establishes regulations that are similar to RCRA but more stringent in their application and empowers the DTSC to administer the State’s hazardous waste program and implement the federal program in California. The DTSC is responsible for permitting, inspecting, ensuring compliance, and imposing corrective action programs to ensure that entities that generate, store, transport, treat, or dispose of potentially hazardous materials and waste comply with federal and State laws. The DTSC defines hazardous waste as waste with a chemical composition or other properties that make it capable of causing illness, death, or some other harm to humans and other life forms when mismanaged or released into the environment.

The DTSC shares responsibility for enforcement and implementation of hazardous waste control laws with the SWRCB and, at the local level, the LARWQCB, and city and county governments.

California Code of Regulations Title 23, Chapter 15 Discharges of Hazardous Waste to Land Section 2511(b)
CCR 23, Chapter 15 Discharges of Hazardous Waste to Land Section 2511(b) pertains to water quality aspects of waste discharge to land. The regulation establishes waste and site classifications as well as waste management requirements for waste treatment, storage, or disposal in landfills, surface impoundments, waste piles, and land treatment facilities. Requirements are minimum 545
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
94 standards for proper management of each waste category, which allows regional water boards to impose more stringent requirements to accommodate regional and site-specific conditions. In addition, the requirements of CCR 23, Chapter 15 applies to cleanup and abatement actions for unregulated hazardous waste discharges to land (e.g., spills).

Environmental Setting
The assessment of potential to encounter hazardous materials in soil and groundwater in the city is generally based on a search of federal, State, and local regulatory databases that identify permitted hazardous materials uses, environmental cases, and spill sites. The Department of Toxic Substances Control (DTSC) EnviroStor database contains information on properties in California where hazardous substances have been released or where the potential for a release exists. The California State Water Resources Control Board (SWRCB) GeoTracker database contains information on properties in California for sites that require cleanup, such as LUST sites, which may impact, or have potential impacts, to water quality, with emphasis on groundwater.

According to databases of hazardous material sites maintained by the DTSC (EnviroStor) and the SWRCB (GeoTracker), Los Altos has five active cleanup sites and one active school cleanup site (DTSC 2021; SWRCB 2021). As shown in Figure 9, these sites are mostly located along Foothill Expressway.

Impact Analysis
a. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Construction Activities
Construction associated with future development under the proposed HEU may include the temporary transport, storage, and use of potentially hazardous materials including fuels, lubricating fluids, cleaners, or solvents. If spilled, these substances could pose a risk to the environment and to human health. However, the transport, storage, use, or disposal of hazardous materials is subject to various federal, State, and local regulations designed to reduce risks associated with hazardous materials, including potential risks associated with upset or accident conditions. Specifically, as discussed under Regulatory Setting, DOT regulations would regulate the transportation process of hazardous materials and reduce the risk of accidental release into the environment.

Compliance with existing regulations would reduce the risk of potential release of hazardous materials during construction.

In addition, grading or excavation on sites with existing contamination may result in the transport and disposal of hazardous materials if they are unearthed and removed from the site. Potential health and environmental concerns related to contaminated groundwater and soil may occur during excavation and dewatering for new construction. However, future development under the project would be subject to regulatory programs such as those listed in the Regulatory Setting and overseen by the RWQCB and the DTSC.
546
Agenda Item # 3.

Environmental Checklist
Hazards and Hazardous Materials
Initial Study – Mitigated Negative Declaration 95
Figure 9 Known Hazardous Sites and Hazardous Sites Located Within 0.25 Mile of a School
547
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
96 These agencies require applicants for development of potentially contaminated properties to perform investigation and cleanup if the properties are contaminated with hazardous substances.

The removal, transport, storage, use, or disposal of hazardous materials would be subject to federal, state, and local regulations pertaining to the transport, use, storage, and disposal of hazardous materials.

Los Altos contains numerous residential and commercial buildings that, due to their age, may contain asbestos and/or lead-based paint. Structures built before the 1970s typically contained asbestos containing materials. Demolition or redevelopment of these structures could result in health hazard impacts to workers if not remediated prior to construction activities. Future development would be required to adhere to BAAQMD Regulation 11, Rule 2, which governs the proper handling and disposal of asbestos containing materials for demolition, renovation, and manufacturing activities in the Bay Area, and California Occupational Safety and Health Administration (CalOSHA) regulations regarding lead-based materials. The California Code of Regulations, Section 1532.1, requires testing, monitoring, containment, and disposal of lead-based materials, such that exposure levels do not exceed CalOSHA standards. Therefore, with adherence to State and local regulations listed in the Regulatory Setting, risk of public exposure to hazardous materials would be greatly reduced, and impacts related to hazards and hazardous materials during construction would be less than significant.

Operation
The proposed HEU is intended to expand housing capacity and would not facilitate the establishment of uses that would sell, use, store, transport, or release substantial quantities of hazardous materials such as industrial, warehouse, auto-service, or manufacturing uses. Residential uses do not typically use hazardous materials other than small amounts for cleaning and landscaping. These materials would not be different from household chemicals and solvents already in wide use throughout the Los Altos. Residents are anticipated to use limited quantities of products routinely for periodic cleaning, repair, and maintenance or for landscape maintenance/pest control that could contain hazardous materials. Those using such products would be required to comply with all applicable regulations regarding the disposal of household waste. Therefore, operation of new residential uses poses little risk of exposing the public to hazardous materials, and impacts would be less than significant.

CEQA is concerned with the impacts of a project on the environment, and not the impacts of the environment on a project. However, for informational purposes, the effects of the location of new housing units is analyzed. Although the project would place new housing units in areas near major transportation corridors where hazardous materials may be transported, the DOT’s Office of Hazardous Materials Safety regulates the transportation of hazardous materials, as described in Title 49 of the CFR, and implemented by Title 13 of the CCR, would reduce the chances of hazardous release during transport. Additionally, all new development that uses hazardous materials would be required to comply with the regulations, standards, and guidelines established by the USEPA, the State, and the City of Los Altos related to storage, use, and disposal of hazardous materials. Goal 3 and Policies 3.1 and 3.2 of the Natural Environment and Hazards Element of the Los Altos General Plan also aim to regulate the use, storage, transport, and disposal of hazardous materials.

Therefore, with adherence to State and local regulations, impacts related to hazards and hazardous materials during operation would be less than significant.

LESS THAN SIGNIFICANT IMPACT
548
Agenda Item # 3.

Environmental Checklist
Hazards and Hazardous Materials
Initial Study – Mitigated Negative Declaration 97
b. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
As discussed under checklist question (a) above, grading or excavation on sites with existing contamination may result in the transport, disposal, and release of hazardous materials if they are unearthed and removed from the site. However, future development under the project would be subject to regulatory programs such as those overseen by the RWQCB and the DTSC. These agencies require applicants for development of potentially contaminated properties to perform investigation and cleanup if the properties are contaminated with hazardous substances. Additionally, future development would be required to comply with Chapter 6.15 of the LAMC which requires building demolition permit applicants to conduct a screening assessment of polychlorinated biphenyls in priority building materials to reduce the risk of release into the environment. Therefore, impacts would be less than significant.

Residential uses do not typically use hazardous materials other than small amounts for cleaning and landscaping. These materials would not be different from household chemicals and solvents already in wide use throughout Los Altos. Residents and workers are anticipated to use limited quantities of products routinely for periodic cleaning, repair, and maintenance or for landscape maintenance/pest control that could contain hazardous materials. Those using such products would be required to comply with all applicable regulations regarding the disposal of household waste.

Therefore, operation of new residential uses poses little risk of exposing the public to hazardous materials. Impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school? Several housing sites are located within a 0.25 mile of an existing school, such as Montclaire Elementary School; Loyola Elementary School; Santa Rita Elementary School; and Bullis Charter School, North Campus. The proposed HEU would not involve new industrial or manufacturing uses, or involve the use, storage, disposal, or transportation of significant quantities of hazardous materials. They may involve use and storage of some materials considered hazardous, though primarily these would be limited to solvents, paints, chemicals used for cleaning and building maintenance, and landscaping supplies. These materials would not be different from household chemicals and solvents already in general and wide use throughout the city. Development accommodated under the project therefore would not pose as a health risk to nearby schools or childcare facilities.

Additionally, as mentioned above under impacts a and b, construction activities associated with future development may include the temporary transport, storage, and use of potentially hazardous materials including fuels, lubricating fluids, cleaners, or solvents. Specifically, demolition of existing buildings and grading and excavation activities associated with new construction may result in emissions and transport of hazardous materials within one-quarter mile of existing schools. As discussed under checklist question (d), two housing inventory sites overlap cleanup sites. One of these sites is within 0.25 mile of a school. Therefore, grading or excavation on a site included on a list of hazardous materials sites may expose contamination within proximity of a school. However, adherence to applicable requirements, including DOT and DTSC regulations, as well as implementation of mitigation measures HAZ-1, HAZ-2, and HAZ-3 below would reduce impacts to less than significant levels. Mitigation Measure HAZ-1 would require regulatory database review 549
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
98 and/or investigation, and HAZ-2 requires preparation of a Soil Management Plan (SMP) if impacted soils or wastes are discovered at a project site, which would require the establishment of remedial measures and/or soil management practices to ensure construction worker safety, the health of future workers and visitors, and the off-site migration of contaminants from the site. Mitigation Measure HAZ-3 would require conduction of additional analytical testing and recommendation of soil disposal methods or other remedial engineering controls in order to reduce impacts from hazardous soils and wastes. Compliance with existing applicable regulations and policies and mitigation measures would minimize risks from routine use, transport, handling, storage, disposal, and release of hazardous materials. Oversight by the appropriate federal, State, and local agencies and compliance by new development with applicable regulations related to the handling and storage of hazardous materials would minimize the risk of the public’s potential exposure to these substances. Overall, impacts related to release of hazardous materials within 0.25 mile of an existing or proposed school would be less than significant with mitigation.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
d. Would the project be located on a site that is included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
As shown in Figure 9, above, there are five active cleanup sites in Los Altos, three of which are located within or adjacent to housing inventory sites. There are also closed LUST cleanup sites and EnviroStor sites that are located in proximity to housing sites. One housing inventory site (APN 18956014) would overlap two closed LUST cleanup sites and one housing inventory site (APN 16741007) would overlap an active cleanup site (Los Altos Cleaners). Development facilitated by the proposed HEU may involve ground disturbance on sites where soil, soil vapor, or groundwater contamination is present such that hazardous materials are released. This could expose construction workforce and or nearby occupants to hazardous materials, and impacts could potentially be significant. Implementation of mitigation measures HAZ-1, HAZ-2, and HAZ-3 would be required.

Mitigation Measure HAZ-1 would require regulatory database review and/or investigation, and HAZ2 would require preparation of a SMP if impacted soils or wastes are discovered at a project site, which would require the establishment of remedial measures and/or soil management practices to ensure construction worker safety, the health of future workers and visitors, and the off-site migration of contaminants from the site. Mitigation measure HAZ-3 would require conduction of additional analytical testing and recommendation of soil disposal methods or other remedial engineering controls in order to reduce impacts from hazardous soils and wastes.

Mitigation Measures
The following mitigation measures are required prior to development on sites listed on a hazardous materials database or where contamination may be present:

HAZ-1 Database Review and Investigation
The City shall establish the following Standard Condition of Approval for projects requiring approval:

Prior to issuance of a grading permit, the SWRCB’s GeoTracker database and DTSC’s EnviroStor database shall be consulted by City staff or consultant to determine whether or not the site to be graded is within 500 feet of an identified active hazardous material site. 550
Agenda Item # 3.

Environmental Checklist
Hazards and Hazardous Materials
Initial Study – Mitigated Negative Declaration 99
If the site is identified in the GeoTracker or EnviroStor databases within 500 feet of an identified active hazardous material site, or if the site to be graded is located on a site that:
 Was currently and/or historically used for railroad, agricultural, or industrial uses.  Was previously or is currently utilized to store, handle, and/or generate hazardous materials.  Has unknown previous site uses; and/or
 Was previously or is currently utilized as a manufacturing facility, a gasoline station, automobile repair shop (or similar), or dry cleaner,
The following process shall be followed prior to issuance of a grading permit:
 The project applicant shall retain a qualified environmental professional (Professional Geologist or Professional Civil Engineer) to prepare a Phase I ESA in accordance with current ASTM standards.
 If the Phase I ESA identifies any potential contamination sources, the project applicant shall retain a qualified environmental consultant to prepare a Phase II ESA (subsurface investigation) to determine whether the identified potential sources have resulted in soil, groundwater, or soil vapor contamination exceeding regulatory action levels.  If the Phase II ESA identifies contamination exceeding applicable regulatory screening levels for construction workers and future site users published by the Regional Water Quality Control Board (RWQCB), Department of Toxic Substances Control (DTSC), and/or Environmental Protection Agency (EPA), a Soil Management Plan shall be prepared (see HAZ-2).
 If the Phase II ESA identifies contamination exceeding hazardous waste screening thresholds for contaminants in soil (California Code of Regulations [CCR] Title 22, Section 66261.24), remediation shall be conducted (see HAZ-3).

The project applicant shall provide written evidence of regulatory database review and investigation. The City of Los Altos shall ensure that evidence of regulatory database review and investigation has been provided by the project applicant prior to project approval.

HAZ-2 Soil Management Plan for Impacted Soils
The City shall establish the following Standard Condition of Approval for projects requiring City approval:

If impacted soils or other impacted wastes are present at the project site, the project applicant shall retain a qualified environmental professional to prepare a Soil Management Plan (SMP) prior to construction. The SMP, or equivalent document, shall be prepared to address onsite handling and management of impacted soils or other impacted wastes and reduce hazards to construction workers and offsite receptors during construction. The plan must establish remedial measures and/or soil management practices to ensure construction worker safety, the health of future workers and visitors, and the off-site migration of contaminants from the site. These measures and practices may include, but are not limited to:
 Stockpile management including stormwater pollution prevention and the installation of BMPs
 Guidance regarding proper disposal procedures of contaminated materials  Guidance regarding monitoring, reporting, and regulatory agency notification 551
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2023-2031 Housing Element Update
100
 A health and safety plan (HASP) for contractors working at the site that addresses the safety and health hazards of each phase of site construction activities with the requirements and procedures for employee protection
 The HASP shall also outline proper soil handling procedures and health and safety requirements to minimize worker and public exposure to hazardous materials during construction.

The project applicant shall prepare and implement a written Soil Management Plan and ensure that an appropriate regulatory oversight agency, such as Santa Clara County Department of Environmental Health, reviews and approves the development site Soil Management Plan, HASP, and remedial measures for impacted soils.

The City of Los Altos shall ensure that a written Soil Management Plan, HASP, and remedial measures for impacted soils has been prepared and approved prior to issuance of a grading permit.

HAZ-3 Remediation
The City shall establish the following Standard Condition of Approval for projects requiring City approval:

If soil present within the construction envelope at the development site contains chemicals at concentrations exceeding hazardous waste screening thresholds for contaminants in soil (California Code of Regulations [CCR] Title 22, Section 66261.24), the project applicant shall retain a qualified environmental consultant (PG or PE), to conduct additional analytical testing and recommend soil disposal recommendations, or consider other remedial engineering controls, as necessary.

The qualified environmental consultant shall use the development site analytical results for waste characterization purposes prior to offsite transportation or disposal of potentially impacted soils or other impacted wastes. The qualified environmental consultant shall provide disposal recommendations and arrange for proper disposal of the waste soils or other impacted wastes (as necessary), and/or provide recommendations for remedial engineering controls, if appropriate.

The project applicant or their contractors shall provide evidence that remediation reduced contaminant levels to below applicable federal, State, and local regulations for human and environmental health, and below hazardous materials threshold concentrations. Evidence of compliance may include, but is not limited to, notifying the appropriate oversight agency (e.g., SCCDEH) of the contamination, hiring a qualified environmental professional to conduct the necessary assessments and abatement (including soil sampling, preparing a remediation plan to adequately abate the hazardous materials, and ultimately obtaining necessary clearance letters from the oversight agency), and issuance of a No Further Action letter, if applicable.

City of Los Altos shall ensure that evidence of remediation compliance has been provided by the project applicant, prior to issuing an occupancy permit.

Significance After Mitigation
Development of identified hazard sites would be preceded by investigation, remediation and cleanup under the supervision of the RWQCB or DTSC before construction activities could begin as currently required by federal, State, and local regulations. The agency responsible for oversight 552
Agenda Item # 3.

Environmental Checklist
Hazards and Hazardous Materials
Initial Study – Mitigated Negative Declaration 101
would determine the types of remediation and cleanup required and could include excavation and off-haul of contaminated soils, installation of vapor barriers beneath habitable structures, continuous monitoring wells onsite with annual reporting requirements, or other mechanisms to ensure the site does not pose a health risk to workers or future occupants. Compliance with federal, State, and local regulations would apply to development. Mitigation Measure HAZ-1 would address the onsite handling and management of impacted soils or other impacted wastes and would reduce hazards to construction workers and offsite receptors during construction. Where remediation of onsite soils or other impacted wastes is necessary, implementation of mitigation measure HAZ-2 would address the offsite removal and proper disposal of impacted soils or other impacted wastes.

Therefore, implementation of mitigation measures HAZ-1 and HAZ-2 would identify, manage onsite, and/or remove hazardous material impacted soils prior to construction (demolition and grading) and would reduce exposure to hazards resulting from development of a potential hazardous materials site to a less than significant level.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? There are no public or private airports within Los Altos. The nearest airport is the San Jose International Airport which is located 7 miles east of the City limits. The project would have no impact related to a safety hazard or excessive noise hazards within airport land use plan areas or in proximity to airports. There would be no impact.

NO IMPACT
f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The City has adopted its Emergency Preparedness Plan (Los Altos PREPARES) implemented by the local police and fire departments, in conjunction with the Santa Clara County Office of Emergency Services. Los Altos PREPARES provides guidance for City response to emergency situations such as natural disasters and other large-scale incidents. Construction of housing development facilitated by the proposed HEU could interfere with implementation of the Los Altos PREPARES during a disaster event, as construction may involve lane closures. However, lane closures would be coordinated with the City prior to permit issuance, and land closures would be temporary. Therefore, the plan would not substantially impair an adopted emergency response or evacuation plan, and impacts would be less than significant.

The City has also identified primary North/South evacuation routes at Arastradero Road, West Fremont Road, San Antonio Road, South El Monte Avenue, Magdalena Avenue, South Springer Road, and Grant Road; and primary East/West evacuation routes at Foothill Expressway, El Camino Real, Cuesta Drive, Fremont Avenue, Interstate 280, and Highway 101 (City of Los Altos 2022b).

Many of the housing sites are located along access and evacuation routes including North San Antonio Road, Springer Street, and Foothill Expressway. While traffic increases associated with the proposed project may affect streets within the city, North San Antonio Road, Springer Street, and Foothill Expressway would still serve as evacuation routes in case of emergency. 553
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
102
Additionally, Policy 5.3 of the Los Altos General Plan Natural Environment and Hazards Element aims to encourage key emergency personnel to live within the community by allowing development of mixed-use housing in the Downtown area and along El Camino Real, Foothill Plaza, and other appropriate commercial districts. The proposed HEU would facilitate development in the Downtown Land Use Plan Area and the Sherwood Gateway Specific Plan Area, providing more housing opportunities for emergency personnel and further reducing impacts to hazards and emergency response. Therefore, development facilitated by implementation of the proposed HEU would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. This impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
Wildfire impacts are discussed in detail under Section 20, Wildfire. As discussed therein, the proposed HEU would result in less than significant impacts related to wildfire.

LESS THAN SIGNIFICANT IMPACT
554
Agenda Item # 3.

Environmental Checklist
Hydrology and Water Quality
Initial Study – Mitigated Negative Declaration 103
10 Hydrology and Water Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface
or ground water quality? □ □ ■ □
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin? □ □ ■ □
c. Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:
(i) Result in substantial erosion or
siltation on- or off-site; □ ■ □ □
(ii) Substantially increase the rate or
amount of surface runoff in a
manner which would result in
flooding on- or off-site; □ ■ □ □
(iii) Create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or □ ■ □ □
(iv) Impede or redirect flood flows? □ ■ □ □
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation? □ □ □ ■
e. Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan? □ □ ■ □
555
Agenda Item # 3.

City of Los Altos
2023-2031 Housing Element Update
104
Environmental Setting
Los Altos is under the jurisdiction of the San Francisco Bay Regional Water Quality Control Board (SFBRWQCB), which is responsible for the preparation and implementation of the water quality control plan, also known as the Basin Plan, for the region. Four creeks are located within the City of Los Altos, including Adobe Creek, Stevens Creek, Permanente Creek, and Hale Creek as shown on Figure 5.

California Water Service Company (Cal Water) is the primary water provider within Los Altos Limits.

Los Altos is located in Cal Water’s Los Altos Suburban District. The Los Altos Suburban District sources water supply through a combination of groundwater from the Santa Clara Subbasin, recycled water, and purchased water from the Santa Clara Valley Water District (Cal Water 2021).

Regulatory Setting
Santa Clara Valley Water District
The Santa Clara Valley Water District (Valley Water) operates as the flood control agency for Santa Clara County. They manage creek restoration, pollution prevention efforts, and groundwater recharge. Permits for well construction and destruction work, most exploratory boring for groundwater exploration, and projects within Valley Water property or easements are required under Valley Water’s Water Resources Protection Ordinance and District Well Ordinance.

Impact Analysis
a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Construction Impacts
Construction activities associated with development facilitated under the proposed HEU would have the potential to cause soil erosion from exposed soil, and accidental release of hazardous materials used for equipment such as vehicle fuels and lubricant, or temporary siltation from storm water runoff. Soil disturbance would occur during excavation for proposed building foundations, demolition of existing buildings, and grading for improvements to public spaces and landscaped areas or development projects. However, future development facilitated by the proposed project would be required to comply with State and local water quality regulations designed to control erosion and protect water quality during construction. This includes compliance with the requirements of the SWRCB Construction General Permit and LAMC Section 10.08.430, which requires preparation and implementation of a SWPPP for projects that disturb one acre or more of land. The SWPPP must include erosion and sediment control BMPs that would meet or exceed measures required by the Construction General Permit, as well as those that control hydrocarbons, trash, debris, and other potential construction-related pollutants. Construction BMPs would include scheduling inlet protection, silt fencing, fiber rolls, stabilized construction entrances, stockpile management, solid waste management, and concrete waste management. Post-construction stormwater performance standards are also required to specifically address water quality and channel protection events. Implementation of these BMPs would prevent or minimize environmental impacts and ensure that discharges during the construction phase of new development facilitated by the proposed project would not cause or contribute to the degradation of water quality in receiving waters.
556
Agenda Item # 3.

Environmental Checklist
Hydrology and Water Quality
Initial Study – Mitigated Negative Declaration 105
Should dewatering be necessary during construction, it may result in the discharge of potentially contaminated groundwater to surface water and may degrade the water quality of surrounding watercourses and waterbodies. However, future development projects would be subject to the San Francisco Bay Regional Water Quality Control Board Order No. R2-2012-0060, General Waste Discharge Requirements for Discharge or Reuse of Extracted Brackish Groundwater, Reverse Osmosis Concentrate Resulting from Treated Brackish Groundwater, and Extracted Groundwater from Structural Dewatering Requiring Treatment (Groundwater General Permit). The Groundwater General Permit requires dischargers to obtain an Authorization to Discharge, treat effluent to meet water quality-based effluent limitations, and comply with the Monitoring and Reporting Program.

Pumped groundwater must be tested and if determined to be contaminated, the water must be collected and either treated or disposed of according to waste discharge requirements of Order No.

R2-2012-0060. Future applicants are required to comply with all requirements of the Groundwater General Permit. Additionally, future development would be required to adhere to stormwater requirements for construction operations pursuant to LAMC Section 10.08.430. Therefore, construction-related water quality impacts would be less than significant.

Operational Impacts
Los Altos is urbanized, and the majority of housing sites are almost entirely covered with impervious surfaces except for landscaped areas. Development under the proposed HEU would involve infill and redevelopment of existing sites. Future development would be required to be implemented in compliance with existing programs and permits, including the LAMC, the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP), and the Municipal Regional Stormwater NPDES Permit (No. CAS612008). Development design would include BMPs to avoid adverse effects associated with stormwater runoff quality. Specifically, future development facilitated by the proposed project would be required to implement LID Measures and on-site infiltration, as required under the C.3 provisions of the Municipal Regional Stormwater Permit (MRP) and SCVURPPP (SCVURPPP 2016). Implementation of LID measures would reduce water pollution from stormwater runoff as compared to existing conditions. For example, on-site infiltration would improve the water quality of stormwater prior to infiltration or discharge from the site.

The City of Los Altos is responsible for enforcing the requirements of the MRP. Compliance with the MRP must include operational and maintenance control measures, or BMPs and constructionrelated BMPs. Provisions specified in the MRP that affect construction projects generally include but are not limited to Provision C.3 (New Development and Redevelopment), Provision C.6 (Construction Site Control), and Provision C.15 (Exempted and Conditionally Exempted Discharges).

Provision C.3 of the MRP addresses post-construction stormwater requirements for new development and redevelopment projects that add and/or replace 10,000 square feet or more of impervious area or special land use categories that create and/or replace 5,000 square feet of impervious surfaces, such as auto service facilities, retail gas stations, restaurants, and uncovered parking lots. These “regulated” projects are required to meet certain criteria: 1) incorporate site design, source control, and stormwater treatment measures into the project design; 2) minimize the discharge of pollutants in stormwater runoff and non-stormwater discharge; and 3) minimize increases in runoff flows as compared to pre-development conditions. Additionally, future development would be required to comply with Chapter 10.16 of the LAMC which outlines the requirements for permanent stormwater pollution prevention measures, hydromodification management measures, and site design measures.
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Compliance with the MRP and LAMC would increase infiltration of stormwater, decrease stormwater runoff, and would reduce the risk of water contamination from operation of new developments to the maximum extent practicable, and the project would reduce water pollution from stormwater runoff as compared to existing conditions. Therefore, the proposed project would not violate water quality standards or waste discharge requirements, would not significantly contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff, and would not substantially degrade water quality. Impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Cal Water supplies water to the Los Altos, and its 2020 Los Altos Suburban District Urban Water Management Plan (UWMP) anticipates future growth in the city through 2045. The Los Altos Suburban District currently pumps groundwater from the Santa Clara Subbasin (DWR Basin No.2- 009.02) of the Santa Clara Valley Basin. The Santa Clara Subbasin is not considered by DWR to be critically over drafted; however, the Santa Clara Subbasin has been prioritized by DWR as “high” priority. Cal Water coordinates with the Valley Water Groundwater Sustainability Agency (GSA), which manages the Santa Clara Subbasin, to protect and maintain the sustainability of the Basin.

The GSA completed an Alternative Groundwater Sustainability Plan in December 2016 per the Sustainable Groundwater Management Act. According to the UWMP, available groundwater supplies are expected to be sufficient to meet the projected future demands of the Los Altos Suburban District in normal and multiple dry year periods through 2045.

Development facilitated by the proposed HEU may increase the amount of impervious surfaces on individual development sites throughout Los Altos which may incrementally affect groundwater recharge on these sites. However, future projects would not include installation of new groundwater wells or use groundwater from existing wells. As discussed under checklist question (a) above, development would be required to comply with Provision C.3 requirements of the MRP as well as Chapter 10.16 of the LAMC, which outlines the requirements for permanent stormwater pollution prevention measures, hydromodification management measures, and site design measures. Compliance with the MRP and LAMC would increase absorption of stormwater runoff and the potential for groundwater recharge. Water that does not recharge into the groundwater would be released into the City’s existing storm drain system.

Los Altos is under the jurisdiction of the SFBRWQCB, which is responsible for preparing the Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan). The Basin Plan designates beneficial uses of water in the region and establishes narrative and numerical water quality objectives. The Basin Plan serves as the basis for the SFBRWQCB’s regulatory programs and incorporates an implementation plan for achieving water quality objectives. With adherence to the State and local water quality standards discussed above, the project would not have an adverse effect on water quality and would not interfere with the objectives and goals in the Basin Plan.

Therefore, development under the proposed HEU would not result in a net deficit in aquifer volume or a lowering of the groundwater table and would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. Impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
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Agenda Item # 3.

Environmental Checklist
Hydrology and Water Quality
Initial Study – Mitigated Negative Declaration 107
c.(i) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
Construction
Construction activities would involve stockpiling, grading, excavation, paving, and other earthdisturbing activities, which may result in the alteration of existing drainage patterns. As described under checklist question (a) above, compliance with the NPDES Construction General Permit, NPDES MS4 General Permit, and the LAMC would reduce risk of short-term erosion and increased runoff resulting from drainage alterations during construction. Therefore, construction related impacts would be less than significant.

Operation
As discussed in Section 4, Biological Resources, several inventory sites are located on or adjacent to creeks. Future development would be required to comply with Chapter 6.32 of the LAMC, which outlines watercourse protection regulations and prohibits modification and pollution of the creeks.

Section 6.32.030 prohibits residents of properties through which a watercourse passes from polluting the specific part of the watercourse and prohibits residents from removing healthy vegetation on or adjacent to the watercourse bank, and Section 6.32.040 outlines setback requirements along Adobe Creek. Additionally, Chapter 10.16 of the LAMC details requirements for stormwater pollution prevention measures which would reduce stormwater runoff from polluting the creeks. This would reduce the potential for modifications to the waterways that would prohibit wildlife movement or affect riparian habitat or sensitive species. Additionally, housing sites near creeks and streams would be subject to the Santa Clara Valley Water Resources Protection Collaborative’s (Water Collaborative) Guidelines and Standards for Land Use Near Streams manual during the City’s development review process (Water Collaborative 2007), which are designed to protect creeks and riparian habitats. Nonetheless, mitigation measures BIO-4 and BIO-5 are requires to prevent impacts to creeks.

Development could potentially alter the exiting drainage patterns at the future development sites through the introduction of new impervious surfaces and infrastructure. However, the future development sites and vicinities are generally urbanized and future development would be required to implement stormwater pollution prevention measures which would reduce erosion and stormwater pollutants. The introduction of impervious surfaces on these sites would not substantially affect the drainage patterns of the area or stormwater runoff volumes due to the relatively minor change in impervious surface area in the larger context. Although site-specific drainage pattern alterations could occur with development facilitated by the proposed project, such alterations would not result in substantial adverse effects. The inventory sites are mostly covered with impervious surfaces, and development under the proposed project would not introduce new impervious areas to the extent that the rate or amount of surface runoff would substantially increase. Development that could be facilitated by the proposed project would not introduce substantial new surface water discharges and would not result in flooding on- or off-site. Overall drainage patterns, including direction of flow and conveyance to stormwater infrastructure, would not be modified by the project, and the runoff volume and rate from the project would be reduced compared to existing conditions. Furthermore, MRP-regulated projects would be required must treat 80 percent or more of the volume of annual runoff for volume-based treatment measures.

Projects that create or replace 2,500 square feet or more, but less than 10,000 square feet, of 559
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impervious surface must implement site design measures to reduce stormwater runoff. All future development that satisfies Provision C.3 of the SCVURPPP would be required to implement postconstruction stormwater controls into the design of the project. Compliance with State and local regulations as well as the LAMC would increase infiltration of stormwater and reduce stormwater runoff from operation of new developments to the extent practicable. Additionally, future development facilitated under the proposed HEU would be required to comply with Policy 3.3 of the Infrastructure and Waste Disposal Element of the Los Altos General Plan, which aims to minimize the amount of impervious surfaces in areas of new development and maximize on-site infiltration of stormwater runoff.

Therefore, with compliance with existing regulations and implementation of mitigation measures BIO-4 and BIO-5, development that could be facilitated by the proposed HEU would not substantially alter the existing drainage pattern of the site or area or alter the course of any stream or river in a manner that would substantially increase the rate or amount of surface runoff in a manner which would result in substantial erosion or siltation on- or off-site. This impact would be less than significant with mitigation.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
c.(ii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? For the same reasons outlined above under checklist question (c.i), with compliance with existing regulations and implementation of mitigation measures BIO-4 and BIO-5, development that could be facilitated by the proposed HEU would not substantially alter the existing drainage pattern of the site or area or alter the course of any stream or river in a manner which would result in flooding onor off-site. This impact would be less than significant with mitigation.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
c.(iii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
For the same reasons outlined above under checklist question (c.i), with compliance with existing regulations and implementation of mitigation measures BIO-4 and BIO-5, development that could be facilitated by the proposed HEU would not substantially alter the existing drainage pattern of the site or area or alter the course of any stream or river in a manner which would create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. This impact would be less than significant with mitigation.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
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Agenda Item # 3.

Environmental Checklist
Hydrology and Water Quality
Initial Study – Mitigated Negative Declaration 109
c.(iv) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows? For the same reasons outlined above under checklist question (c.i), with compliance with existing regulations and implementation of mitigation measures BIO-4 and BIO-5, development that could be facilitated by the proposed HEU would not substantially alter the existing drainage pattern of the site or area or alter the course of any stream or river in a manner which would impede or redirect flood flows. This impact would be less than significant with mitigation.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
Los Altos does not contain large surface water bodies that would result in seiches and is not located in a tsunami zone (DOC 2022b). The Federal Emergency Management Agency (FEMA) establishes base flood elevations (BFE) for 100-year and 500-year flood zones and establishes Special Flood Hazard Areas (SFHA). SFHAs are those areas within 100-year flood zones or areas that will be inundated by a flood event having a one percent chance of being equaled or exceeded in any given year. The 500-year flood zone is defined as the area that could be inundated by the flood which has a 0.2 percent probability of occurring in any given year, or once in 500 years, and is not considered an SFHA. As shown in Figure 5, almost the entire City and all the housing sites under the proposed HEU are located in a 500-year flood zone, with the exception of two housing sites which are located in a 100-year flood zone on Permanente Creek. Development in flood zones is regulated through Chapter 12.60 of the LAMC, which outlines requirements for management of and development in flood hazard areas, such as obtaining permits for floodplain development, elevation requirements, and using flood damage-resistant materials for new construction. Therefore, development under the proposed HEU on these sites would be designed to withstand flooding hazards, including FEMAdesignated Flood Hazard Areas. Additionally, the development facilitated by the proposed project would be required to adhere to existing federal, State, and local laws and regulations that address the management and control of pollutants, including regulations addressing the proper disposal, transportation, storage, and handling of potentially hazardous materials, including the California Health and Safety Code and Division 7 of the California Water Code. Adherence to existing regulations would reduce the risk of the release of pollutants. This impact would be less than significant.

LESS THAN SIGNIFICANT IMPACT
e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
As discussed under checklist question (b), Cal Water’s Los Altos Suburban District currently pumps groundwater from the Santa Clara Subbasin (DWR Basin No.2-009.02) of the Santa Clara Valley Basin. Cal Water coordinates with the Valley Water Groundwater Sustainability Agency (GSA), which manages the Santa Clara Subbasin, to protect and maintain the sustainability of the Basin. The GSA completed an Alternative Groundwater Sustainability Plan in December 2016 and a Groundwater Management Plan (GWMP) for the Santa Clara and Llagas Subbasin in 2021 (Valley Water 2021) per the Sustainable Groundwater Management Act.
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Los Altos is under the jurisdiction of the SFBRWQCB, which is responsible for preparing the Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan). The Basin Plan designates beneficial uses of water in the region and establishes narrative and numerical water quality objectives. The Basin Plan serves as the basis for the SFBRWQCB’s regulatory programs and incorporates an implementation plan for achieving water quality objectives.

As discussed under checklist question (b), future development would not include installation of new groundwater wells or use groundwater from existing wells. Additionally, with adherence to the State and local water quality standards such as Provision C.3 requirements of the MRP as well as Chapter 10.16 of the LAMC, development under the proposed HEU would not interfere with the objectives and goals in the GWMP or the Basin Plan. Therefore, impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
562
Agenda Item # 3.

Environmental Checklist
Land Use and Planning
Initial Study – Mitigated Negative Declaration 111
11 Land Use and Planning
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Physically divide an established
community? □ □ □ ■
b. Cause a significant environmental impact
due to a conflict with any land use plan,
policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect? □ □ ■ □
a. Would the project physically divide an established community? The proposed HEU would not divide a community; rather, it is designed to meet the City’s RHNA and includes implementation programs that would promote the development of existing vacant, underdeveloped, or underutilized properties, as well as implement a rezoning program to increase allowed density and height, thereby locating people closer to existing employment, goods and services within an established community. The proposed HEU involves policies and programs that would increase the potential number of dwelling units in Los Altos and intensify development in existing urban areas. The proposed HEU does not involve the construction of barriers, such as new roads or other linear development or infrastructure, that would divide the existing communities or neighborhoods. Existing roadways would not be permanently blocked, and temporary construction would not limit access to a community or restrict movement within a community. No impact related to dividing an established community would occur.

NO IMPACT
b. Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
The proposed HEU would provide a framework for introducing new housing at all levels of affordability that is within access to transit, jobs, services, and open spaces. Through its identification of sites for future development and implementation of housing programs, the project would encourage development of up to 1,648 new residential units, which would address the City’s fair share housing needs as quantified in the RHNA.

The proposed HEU would also include zoning ordinance and zoning map amendments to increase permitted densities in the CN, CT, OA, and PCF districts and height in the CT district The following analysis discusses the project’s consistency with applicable policies in the Los Altos General Plan, presented in Table 16, and the LAMC.
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City of Los Altos General Plan
As shown in Table 16, the project would be consistent with the goals, policies, and actions within the Los Altos General Plan. As noted under Government Code Section 65589.5(a), the Legislature has concluded that “the lack of housing, including emergency shelters, is a critical problem that threatens the economic, environmental, and social quality of life in California.” More specifically, the Legislature’s stated intent is “to assure that counties and cities recognize their responsibilities in contributing to the attainment of the state housing goal…to assure that counties and cities will prepare and implement housing elements which…will move toward attainment of the state housing goal” (Government Code Section 65581). The project would help meet the City’s RHNA allocation, as well as efficiently utilize vacant, underutilized, and underdeveloped lots within Los Altos to increase the supply of housing. The project would encourage development of housing, which is supportive of the City’s goal and policies.

Table 16 Project Consistency with Relevant General Plan Goals and Policies General Plan Policy Proposed HEU Project Consistency
Community Design and Historic Resources Element
Policy 1.6: Continue to provide for site planning and
architectural design review within the City, with a
focus on mass, scale, character, and materials.

Policy 1.7: Enhance neighborhood character by
promoting architectural design of new homes,
additions to existing homes, and residential
developments that is compatible in the context of
surrounding neighborhoods.

Consistent. Future development facilitated by the project would be subject to the City’s existing general development standards (Title 14 of the LAMC, also known as the Zoning Code), to ensure that buildings are compatible with neighboring land uses, architectural design, and scale. Future development would also be required to undergo the City’s design review process, where applicable, in order to ensure compatibility with surrounding property and use.

Downtown
Policy 3.3: Encourage pedestrian and bicycleoriented design in the Downtown.

Consistent. The proposed HEU would facilitate development within the City’s Downtown Area in proximity to transit, which would encourage bicycling and walking to jobs and services.

Development would be required to comply with the Downtown Design Guidelines, where applicable, as listed in Appendix II of the Downtown Land Use Plan.

Policy 3.3: Encourage the development of
affordable housing above the ground floor
throughout the Downtown.

Consistent. The proposed HEU would increase the number of market-rate and affordable housing within the city and in the Downtown Area. As discussed under Program 1.H of the
proposed HEU, City-owned Downtown Parking Plazas 7 and 8 would be used to accommodate affordable housing.

El Camino Real Commercial Corridor
Policy 4.2: Evaluate site development and design to
ensure consistency in site design.

Consistent. Future individual projects located along the El Camino Real Commercial Corridor would be required to undergo the City’s design review process, where applicable, in order to ensure compatibility with surrounding property and use.

Land Use Element
Policy 2.2: Encourage a variety of residential
housing opportunities by allowing residential uses
with adequate parking in appropriate commercial
areas, including sections of the Downtown area,
Foothill Plaza and along El Camino Real.

Consistent. As shown in Figures 3 and 4 of the Project
Description, the proposed HEU would facilitate development on undeveloped or underutilized sites and increase allowed density and height on housing sites located within or adjacent to the Downtown area, Foothill Plaza area, and El Camino Real
Corridor.
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Environmental Checklist
Land Use and Planning
Initial Study – Mitigated Negative Declaration 113
General Plan Policy Proposed HEU Project Consistency
Policy 2.3: Continue to conduct design review of
residential and nonresidential development
applications to ensure compatibility with
surrounding property and neighborhoods.

Consistent. Future development facilitated by the project would be subject to the City’s existing general development standards (Title 14 of the LAMC, also known as the Zoning Code), to ensure that buildings are compatible with neighboring land uses, architectural design, and scale. Future development would also be required to undergo the City’s design review process, where applicable, in order to ensure compatibility with surrounding property and use.

Downtown
Policy 3.1: Encourage residential development
above the ground floor that includes affordable
housing units.

Consistent. The proposed HEU would increase the number of market-rate and affordable housing within the Los Altos and in the Downtown. As discussed under Program 1.H of the proposed HEU, City-owned Downtown Parking Plazas 7 and 8 would be used to accommodate affordable housing.

Policy 3.5: Continue to review development plans
to ensure compliance with the Downtown Urban
Design Plan.

Consistent. Future development located within the Downtown area would be required to comply with design guidelines listed in the Downtown Urban Design Plan, where applicable.

Additionally, projects in a non-single-family district may be subject to design review approval pursuant to Chapter 14.78 of the LAMC (City of Los Altos 2022c).

El Camino Real
Policy 4.3: Encourage residential development on
appropriate sites within the El Camino Real corridor.

Policy 4.4: Encourage the development of
affordable housing.

Consistent. The proposed HEU would increase the number of market-rate and affordable housing within the city and in the El Camino Real area. Program 1.B of the 2023-2031 Housing
Element Update aims to facilitate higher density housing in the Commercial Thoroughfare (CT) Zone located along El Camino Real and Program 1.F aims to rezone the Village Court parcel at 4546 El Camino Real to CT.

Policy 4.6: Continue to review development
proposals to ensure a balance between
development rights and impact on surrounding
residential neighborhoods.

Consistent. Future development located within or along the El Camino Corridor would be subject to the City’s design review process, where applicable, in order to ensure compatibility with surrounding property and use.

Circulation Element
Policy 2.4: Require development projects to
mitigate their respective traffic and parking impacts
by implementing practical and feasible street
improvements.

Policy 2.5: Ensure that new development or
redevelopment projects provide adequate property
dedication to accommodate future roadway
improvements at key intersections and other
problem areas.

Policy 2.6: Implement and require developers to
implement street improvements that accommodate
and encourage the use of non-automobile travel
modes including walking, bicycling, and transit.

Consistent. The proposed HEU would facilitate development within the Downtown Land Use Plan Area and the Sherwood Gateway Specific Plan Area, as well as along transportation corridors, which would encourage the use of non-automobile travel and encourage walking and bicycling. Future development would be required to mitigate their respective traffic and parking impacts and provide the appropriate dedication of property for future roadway improvements.
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LAMC Consistency
As current zoning would not be able to deliver the level of deed-restricted affordable housing and economic and geographic diversity that the project aims to achieve, the proposed HEU would contain implementation programs and zoning policies to encourage additional housing, especially affordable housing that would support a diversity of income levels and household types.

Additionally, under the proposed HEU, CN, CT, OA, and PCF districts are anticipated to increase in allowed density and CT district in height to facilitate increased development. All future development under the project would be required to comply with zoning requirements as described in Title 14, Zoning, of the LAMC.

Upon adoption of the proposed HEU and the associated zoning and General Plan amendments, the project would comply with the land use requirements set forth by the Los Altos General Plan and the LAMC, and therefore, would result in less than significant adverse physical land use impacts.

LESS THAN SIGNIFICANT IMPACT
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Agenda Item # 3.

Environmental Checklist
Mineral Resources
Initial Study – Mitigated Negative Declaration 115
12 Mineral Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Result in the loss of availability of a
known mineral resource that would be of
value to the region and the residents of
the state? □ □ □ ■
b. Result in the loss of availability of a
locally important mineral resource
recovery site delineated on a local
general plan, specific plan, or other land
use plan? □ □ □ ■
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Los Altos does not have significant mineral resources or active mining sites within its boundaries. No mineral resources are identified in the City’s General Plan (City of Los Altos 2002). The proposed HEU applies to an urban area which is not compatible with, identified for, or used for mineral extraction. Development under the proposed HEU would not result in the loss of availability of a known mineral resource that would be of value to the region and residents of the state. Therefore, there would be no impacts related to mineral resources.