Statement of Hammett & Edison, Inc., Consulting Engineers The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained on behalf of AT&T Mobility, a wireless telecommunications carrier, to evaluate the base station (Site No. CCL06325) proposed to be located at 707 Fremont Avenue in Los Altos, California, for compliance with appropriate guidelines limiting human exposure to radio frequency (“RF”) electromagnetic fields.
Executive Summary
AT&T proposes to install directional panel antennas on a tall steel pole, configured to resemble a pine tree, to be sited at 707 Fremont Avenue in Los Altos. The proposed operation will comply with the FCC guidelines limiting public exposure to RF energy.
Prevailing Exposure Standard
The U.S. Congress requires that the Federal Communications Commission (“FCC”) evaluate its actions for possible significant impact on the environment. A summary of the FCC’s exposure limits is shown in Figure 1. These limits apply for continuous exposures and are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or health. The most restrictive limit for exposures of unlimited duration at several wireless service bands are as follows:
Transmit “Uncontrolled” Occupational Limit
Wireless Service Band Frequency Public Limit (5 times Public) Microwave (point-to-point) 1–80GHz 1.0 mW/cm2 5.0 mW/cm2 Millimeter-wave 24–47 1.0 5.0
Part 15 (WiFi & other unlicensed) 2–6 1.0 5.0
C-Band 3,700 MHz 1.0 5.0
DoD-Band 3,450 1.0 5.0
WCS (Wireless Communication) 2,305 1.0 5.0
AWS (Advanced Wireless) 2,110 1.0 5.0
PCS (Personal Communication) 1,930 1.0 5.0
Cellular 869 0.58 2.9
FNET (Public Safety Priority) 758 0.50 2.5
Band 17 734 0.49 2.45
Band 29 717 0.48 2.4
600 MHz 617 0.41 2.05
[most restrictive frequency range] 30–300 0.20 1.0
General Facility Requirements
Base stations typically consist of two distinct parts: the electronic transceivers (also called “radios”) that are connected to the traditional wired telephone lines, and the antennas that send the wireless signals created by the radios out to be received by individual subscriber units. The transceivers are 227
Agenda Item # 5.
AT&T Mobility • Proposed Base Station (Site No. CCL06325) 707 Fremont Avenue • Los Altos, California
N0T7
often located at ground level and are connected to the antennas by coaxial cables. Because of the short wavelength of the frequencies assigned by the FCC for wireless services, the antennas require line-of-sight paths for their signals to propagate well and so are installed at some height above ground.
The antennas are designed to concentrate their energy toward the horizon, with very little energy wasted toward the sky or the ground. This means that it is generally not possible for exposure conditions to approach the maximum permissible exposure limits without being physically very near the antennas.
Computer Modeling Method
The FCC provides direction for determining compliance in its Office of Engineering and Technology Bulletin No. 65, “Evaluating Compliance with FCC-Specified Guidelines for Human Exposure to Radio Frequency Radiation,” dated August 1997. Figure 2 describes the calculation methodologies, reflecting the facts that a directional antenna’s radiation pattern is not fully formed at locations very close by (the “near-field” effect) and that at greater distances the power level from an energy source decreases with the square of the distance from it (the “inverse square law”). This methodology is an industry standard for evaluating RF exposure conditions and has been demonstrated through numerous field tests to be a conservative prediction of exposure levels.
Site and Facility Description
Based upon information provided by AT&T, including zoning drawings by Spectrum Services, LLC, dated May 24, 2024, it is proposed to install twelve directional panel antennas – six each Quintel Model QD8612-2 and Ericsson Model AIR6419 – on a 75-foot steel pole, configured to resemble a pine tree,* to be sited near the northeast corner of the parking lot at McKenzie Park, located at 707 Fremont Avenue in Los Altos, California. The Quintel antennas would employ up to 12° downtilt and would be mounted at an effective height of about 70 feet above ground. The Ericsson antennas would employ up to 19° downtilt and would be mounted in stacked pairs at effective heights of about 69 and 72½ feet above ground. The twelve antennas would be oriented in identical groups of four (two of each model) toward 20°T, 130°T, and 260°T. The maximum effective radiated power in any direction would be 62,940 watts, representing simultaneous operation at 24,290 watts for C-Band,
† 11,740 watts for DoD-Band,† 7,220 watts for AWS, 6,770 watts for PCS, 5,040 watts for cellular, 3,150 watts for FirstNet, and 4,730 watts for Band 17 service. There are reported no other wireless telecommunications base stations at the site or nearby. * Foliage atop the pole puts the overall height at about 80 feet. † AT&T reports maximum effective radiated power of 101,200 watts in C-Band and 48,900 watts in DoD-Band, to which a duty cycle of 75% is applied; a statistical factor of 32% is also included, to account for spatial distribution of served users, based on the United Nations International Telecommunication Union ITU-T Series K, Supplement 16, dated May 20, 2019.
228
Agenda Item # 5.
AT&T Mobility • Proposed Base Station (Site No. CCL06325) 707 Fremont Avenue • Los Altos, California
N0T7
Study Results
For a person anywhere at ground, the maximum RF exposure level due to the proposed AT&T operation is calculated to be 0.11 mW/cm2, which is 17% of the applicable public exposure limit.
The maximum calculated level at the second-floor elevation of any nearby building‡ is 23% of the public exposure limit. The maximum calculated level at the second-floor elevation of any nearby residence§ is 10% of the public exposure limit. It should be noted that these results include several “worst-case” assumptions and therefore are expected to overstate actual power density levels from the proposed operation.
No Recommended Mitigation Measures
Due to their mounting location and heights, the AT&T antennas would not be accessible to unauthorized persons, and so no measures are necessary to comply with the FCC public exposure guidelines. It is presumed that AT&T will, as an FCC licensee, take adequate steps to ensure that its employees or contractors receive appropriate training and comply with FCC occupational exposure guidelines whenever work is required near the antennas themselves.
Conclusion
Based on the information and analysis above, it is the undersigned’s professional opinion that operation of the base station proposed by AT&T Mobility at 707 Fremont Avenue in Los Altos, California, will comply with the prevailing standards for limiting public exposure to radio frequency energy and, therefore, will not for this reason cause a significant impact on the environment. The highest calculated level in publicly accessible areas is much less than the prevailing standards allow for exposures of unlimited duration. This finding is consistent with measurements of actual exposure conditions taken at other operating base stations.
Authorship
The undersigned author of this statement is a qualified Professional Engineer, holding California Registration Nos. E-13026 and M-20676, which expire on June 30, 2025. This work has been carried out under his direction, and all statements are true and correct of his own knowledge except, where noted, when data has been supplied by others, which data he believes to be correct.
William F. Hammett, P.E.
May 31, 2024 707/996-5200
‡ Located at least 90 feet away, based on photographs from Google Maps. § Located at least 325 feet away, based on photographs from Google Maps. 229
Agenda Item # 5.
FCC Guidelines
Figure 1
1000
100
10 1
0.1 0.1 1 10 100 103 104 105
Occupational Exposure
Public Exposure
PCS
Cell
FM
Power
Density
(mW/cm2
)
FCC Radio Frequency Protection Guide
The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission (“FCC”) to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a significant impact on the environment. The FCC adopted the limits from Report No. 86, “Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields,” published in 1986 by the Congressionally chartered National Council on Radiation Protection and Measurements (“NCRP”).
Separate limits apply for occupational and public exposure conditions, with the latter limits generally five times more restrictive. The more recent standard, developed by the Institute of Electrical and Electronics Engineers IEEE C95.1-, “Safety Levels with Respect to Human Exposure to &MFDUSJD
.BHOFUJD
BOE Electromagnetic Fields, )[ to 300 GHz,” includes similar limits. These limits apply for continuous exposures from all sources and are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or health.
As shown in the table and chart below, separate limits apply for occupational and public exposure conditions, with the latter limits (in italics and/or dashed) up to five times more restrictive:
Frequency Electromagnetic Fields (f is frequency of emission in MHz) Applicable
Range
(MHz)
Electric
Field Strength
(V/m)
Magnetic
Field Strength
(A/m)
Equivalent Far-Field
Power Density
(mW/cm2
)
0.3 – 1.34 614 614 1.63 1.63 100 100
1.34 – 3.0 614 823.8/ f 1.63 2.19/ f 100 180/ f 2
3.0 – 30 1842/ f 823.8/ f 4.89/ f 2.19/ f 900/ f 2 180/ f 2 30 – 300 61.4 27.5 0.163 0.0729 1.0 0.2
300 – 1,500 3.54 f 1.59 f f /106 f /238 f/300 f/1500
1,500 – 100,000 137 61.4 0.364 0.163 5.0 1.0
Frequency (MHz)
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230
Agenda Item # 5.
RFE.CALCTM Calculation Methodology
Assessment by Calculation of Compliance with FCC Exposure Guidelines Calculation Methodology
Figure 2 ©2023
180
θBW
×
0.1× Pnet
π ×D × h
0.1 x 16 x n x P
x h2
0.1×16 ×η × Pnet
π × h2
net
BW
180 0.1 x Pnet x
180
θBW
×
0.1× Pnet
π ×x DD x ×hh
2.56 x 1.64 x 100 x RFF2
x ERP
4 x x D2
180
θBW
×
0.1× Pnet
π ×D × h S =
q BW
Hammett & Edison has incorporated the FCC Office of Engineering and Technology Bulletin No. 65 (“OET-65”) formulas (see Figure 1) in a computer program that calculates, at millions of locations on a grid, the total expected power density from any number of individual radio frequency sources. The program uses the specific antenna patterns from the manufacturers and allows for the inclusion of uneven terrain in the vicinity, as well as any number of nearby buildings of varying heights, to obtain accurate projections of RF exposure levels. The program can account for spatial-averaging when antenna patterns are sufficiently narrow, and timeaveraging is typically considered when operation is in single-frequency bands, which require time-sharing between the base station and the subscriber devices.
OET-65 provides this formula for calculating power density in the far-field from an individual RF source:
power density in mW/cm2
where ERP = total Effective Radiated Power (all polarizations), in kilowatts, RFF = three-dimensional relative field factor toward point of calculation, and D = distance from antenna effective height to point of calculation, in meters.
The factor of 2.56 accounts for the increase in power density due to reflections, assuming a reflection coefficient of 1.6 (1.6 x 1.6 = 2.56). This factor is typically used for all sources unless specific information from FCC filings by the manufacturer indicate that a different reflection coefficient would apply. The factor of 1.64 is the gain of a half-wave dipole relative to an isotropic radiator. The factor of 100 in the numerator converts to the desired units of power density.
Because antennas are not true “point sources,” their signal patterns may not be fully formed at close distances and so exposure levels may be lower than otherwise calculated by the formula above. OET-65 recommends the cylindrical model formula below to account for this “near-field effect”:
power density in mW/cm2 S =
where Pnet = net power input to antenna, in watts,
= half-power beamwidth of antenna, in degrees,
D = distance from antenna effective height to point of calculation, in meters, and h = aperture height of antenna, in meters.
The factor of 0.1 in the numerator converts to the desired units of power density.
OET-65 confirms that the “crossover” point between the near- and far-field regions is best determined by finding where the calculations coincide from the two different formulas, and the program uses both formulas to calculate power density.
180
θBW
×
0.1× Pnet
π ×D × h
0.1 x 16 x n x P
x h2
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π × h2
net
BW
180 0.1 x Pnet x
θ
180
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180
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180
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4 x x D2
180
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π ×D × h S =
231
Agenda Item # 5.
From: Jennifer Yeh
To: [email protected]; Brittany Whitehill; Planning Services Subject: Tower proposal
Date: Monday, November 18, 2024 10:25:34 AM
Dear Planning Coordinators,
I would like to voice my strong objection to the building of a cell tower in the McKinsey Park area in Los Altos (please see attached announcement). In the past year, the city has converted this area to a dog park AND a pickle ball court. Because I live directly across the street from both of these new developments, I can hear dogs barking as early as 6 am, people playing pickle ball until 10 pm and sometimes 11 pm, and see a constant light shining into my home. This has been a continual nuisance to my property. Adding a cell tower is not only insightful, but research has shown that it can be harmful to young children (I have 3 children living in the home). I will send you research articles regarding the harmful effects of cell towers near young children.
Please consider relocating this cell tower to a different location.
Thank you
Jen Yeh
415-244-7986
1320 Country Club Drive
Los Altos, CA 94024
232
Agenda Item # 5.
City Council Agenda Report
Meeting Date: February 11, 2024
Prepared By: Anthony Carnesecca
Approved By: Gabe Engeland
Subject: Authorize Park Impact Fee Expenditure for Downtown Park with Parking
COUNCIL PRIORITY AREA
☒Business Communities
☒Circulation Safety and Efficiency
☒Environmental Sustainability
☒Housing
☐Neighborhood Safety Infrastructure
☐General Government
RECOMMENDATION
City staff recommends that the City Council:
Adopt resolution to use Park Impact Fee funds for community engagement and design services for downtown park with parking
Adopt resolution to award contract to Watry Design, Inc. for Community Engagement and Design Services for Downtown Park with Parking in the amount of $2,288,500 and authorize the City Manager to execute a change order not to exceed 10% ($228,850) of the total contract amount on behalf of the City
FISCAL IMPACT
The total contract will cost $2,288,500 over roughly 18 months that will be spent from Park Impact Fee funds. City staff has budgeted $500,000 for FY24-25 budget under CIP #CD-01030 and will budget the rest in future years moving forward for the work to be completed. The current Park Impact Fee Fund Balance is $18,908,912.
ENVIRONMENTAL REVIEW
The City Council action authorizing the review of the proposed project is exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3). Subsequent action taken during the review of the proposed project will be analyzed separately under CEQA.
PREVIOUS COUNCIL CONSIDERATION
January 9, 2024 & April 9, 2024
BACKGROUND
233
Agenda Item # 6.
As part of their Annual Retreat, the City Council directed City staff to explore the possibility of a downtown park with parking in the City-owned parking plazas. City staff initiated the exploratory research process to identify which parking plazas have the desirable characteristics and initial feasibility for the necessary project components.
There would be a number of benefits provided by a beautiful new park space with parking as compared to the existing at-grade parking in Parking Plazas #1 and #2. This project would further the City Council Strategic Goals #1 through #4:
Business Communities – Provide a benefit to the downtown business community through a new community space that will allow new visitors to spend their time and money in our main commercial district. It will provide high quality park space and parking spaces along with protected, secure parking for employee vehicles.
Circulation Safety and Efficiency – Improve circulation safety of the downtown by calming this portion of the downtown parking plazas from solely vehicular traffic in at-grade parking. Parking plaza efficiency will significantly increase with a new flow of traffic that is oriented to maximum benefit.
Environmental Sustainability – Enhance from the existing asphalt parking to green space with state-of-the-art sustainable amenities in addition to the new trash enclosures that will ensure trash is well-maintained and not entering the public right-of-way. Housing – Utilize portions of the Housing Element which identify integration of public park facilities with or nearby multi-family housing.
As presented previously, City staff completed an initial site analysis and identified Plaza #1 and Plaza #2 as the preferred location. City Council directed staff to move the project forward at Plazas #1 and #2 with community engagement and conceptual design as part of their strategic priorities for the 2024 calendar year and allocated funds in the FY24-29 Capital Improvement and Major Maintenance Budget focused on community engagement and design services for the project.
ANALYSIS
Since that time, City staff has continually been presenting this concept to community groups and developed a full scope of work for the Requests for Proposal.
This scope of work included robust community engagement on potential design amenities, investigate existing conditions, and garner consensus on the project before returning to City Council with a budget, program, and style for the project moving forward.
The consultant will then refine aspects of the project into three feasible conceptual design alternatives, cost estimates and funding sources for the alternatives, garner consensus on preferred alternatives, and provide a final update to City Council. At that time, City Council will move forward with the preferred design and allocate the appropriated budget to design full bid-ready construction documents.
The City issued the RFP – Community Engagement and Design Services for Downtown Park with Parking on our Bids and Requests for Proposals website on October 31, 2024. The RFP closed on December 3, 2024 at 3 pm.
234
Agenda Item # 6.
The City received five proposals for the project. The evaluation committee reviewed all the proposals and invited the highest-ranking proposers to a final interview.
The review committee conducted interviews with the finalists and selected Watry Design, Inc. as the consultant to complete the work specified in the RFP.
The City Council needs to hold a public hearing to allocate funds from the Park Impact Fee for this project, which it will do tonight, before authorizing the City Manager to execute a contract with the preferred consultant.
The City acknowledges that the Downtown Park with Parking Project is subject to compliance with all legal requirements, including and but not limited to compliance with the California Environmental Quality Act (CEQA). No financial commitment shall be construed to compel the City to approve or make any particular findings with respect to any environmental documentation that is prepared, pursuant to CEQA, for any portion of the Project. The City retains full discretion to approve any CEQA documents prepared or to analyze environmental impacts or the Project.
ATTACHMENTS
1. Resolution
2. Resolution
235
Agenda Item # 6.
Resolution No. 2025-XX Page 1
RESOLUTION NO. 2025-XX
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS
AUTHORIZING THE CITY MANAGER TO EXECUTE AN AGREEMENT ON BEHALF OF THE CITY OF LOS ALTOS WITH WATRY DESIGN, INC. FOR
COMMUNITY ENGAGEMENT AND DESIGN SERVICES FOR DOWNTOWN
PARK WITH PARKING (CD-01030)
WHEREAS, the City has selected Watry Design, Inc. to provide community engagement and design services for the Downtown Park with Parking; and WHEREAS, the City Council has already budgeted the FY24-25 portion of the project into the Capital Improvement and Major Maintenance Program #CD-0130; and WHEREAS, the City Council action authorizing the review of the proposed project is exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3). Subsequent action taken during the review of the proposed project will be analyzed separately under CEQA.
NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos adopt a resolution to:
1. Authorize the City Manager to execute the Agreement with Watry Design, Inc. in an amount of $2,288,500 and authorize the City Manager to execute a change order not to exceed 10% ($228,850) of the total contract amount on behalf of the City for the Downtown Park with Parking, and
2. Authorize the City Manager to take such further actions as may be necessary to implement the foregoing agreement.
I HEREBY CERTIFY that the foregoing is a true and correct copy of a Resolution passed and adopted by the City Council of the City of Los Altos at a meeting thereof on the 11 th
day of February 2025 by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
Pete Dailey, MAYOR
Attest:
_____________________________
236
Agenda Item # 6.
Resolution No. 2025-XX Page 2
Melissa Thurman, MMC
CITY CLERK
237
Agenda Item # 6.
Resolution No. 2025-XX Page 1
RESOLUTION NO. 2025-XX
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS
AUTHORIZING THE ALLOCATION OF PARK IMPACT FEE FUNDS TO
HIRE WATRY DESIGN FOR PROFESSIONAL CONSULTANT SERVICES
ON A DOWNTOWN PARK WITH PARKING, NOT TO EXCEED $2,517,350 WHEREAS, the City currently has $18,908,912 in the Park Impact Fee to cover the cost of park improvements in Los Altos; and
WHEREAS, City Council has directed staff to conduct community engagement and design for a park with parking in downtown; and
WHEREAS, the City has determined that Parking Plazas #1 and #2 are the best options for a permanent park within Downtown Los Altos; and
WHEREAS, the City Council action authorizing the review of the proposed project is exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3). Subsequent action taken during the review of the proposed project will be analyzed separately under CEQA; and WHEREAS, The City Council of the City of Los Altos hereby authorizes the allocation of funding not to exceed $2,517,350 from the City’s Park Impact Fee for professional services for community engagement and design of the downtown park with parking, and WHEREAS, Watry Design is the preferred design consultant to coordinate community engagement and design of the downtown park with parking.
NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos adopt a resolution to:
1. The City Council finds that Park Impact Fee may be used for the purpose of developing new or rehabilitating existing park or recreational facilities such as the design of a new downtown park with parking within the City because: (1) this park will be located within the neighborhood that may fees have been collected; (2) is reasonably foreseeable that City residents will use the proposed park and recreational facilities where the fees are being used; (3) the use of the fees is consistent with the City's adopted general plan; and (4) the fees are used in compliance with Los Altos Municipal Code Section 3.60.015.
2. The City Council of the City of Los Altos hereby authorizes the allocation of not to exceed $2,517,350 from the City’s Park Impact Fee to contract a professional consultant, Watry Design, for professional services for community engagement and design of the downtown park with parking
238
Agenda Item # 6.
Resolution No. 2025-XX Page 2
I HEREBY CERTIFY that the foregoing is a true and correct copy of a Resolution passed and adopted by the City Council of the City of Los Altos at a meeting thereof on the 11 th
day of February 2025 by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
Pete Dailey, MAYOR
Attest:
_____________________________
Melissa Thurman, MMC
CITY CLERK
239
Agenda Item # 6.
City Council Agenda Report
Meeting Date: February 11, 2025
Prepared By: Melissa Thurman
Approved By: Gabriel Engeland
Subject: Discuss the attendance of Parks, Arts, Recreation & Cultural Commissioner Yong Yeh
COUNCIL PRIORITY AREA
☐Business Communities
☐Circulation Safety and Efficiency
☐Environmental Sustainability
☐Housing
☐Neighborhood Safety Infrastructure
☒General Government
RECOMMENDATION
Discuss and take possible action on the attendance record and appointment of Parks, Arts, Recreation & Cultural Commissioner Yong Yeh
FISCAL IMPACT
Not Applicable.
ENVIRONMENTAL REVIEW
Not Applicable.
PREVIOUS COUNCIL CONSIDERATION
Not Applicable.
BACKGROUND
At the regular meeting of January 28, 2025, Mayor Pete Dailey requested a future agenda item to discuss the attendance record of Parks, Arts, Recreation & Cultural (PARC) Commissioner Yong Yeh. This request was supported by the full Council to be presented at a future City Council meeting as a Discussion Item.
Pursuant to the Commissioner Handbook, Commissioners are expected to attend no less than 75% of the regularly scheduled meetings held annually during their term in office. If a Commissioner fails to attend the required minimum number of meetings, they risk removal from the Commission on which they were appointed.
240
Agenda Item # 7.
Commissioner Yeh was absent for 3 out of 4 regular meetings in 2023 (25% attendance rate) and absent for 5 out of 10 regular meetings in 2024 (50% attendance rate).
In April 2024 a PARC Commissioner was asked to resign due to attendance issues. The Commission is a seven-member body and currently has one vacancy.
ATTACHMENTS
1. Commissioner Handbook
241
Agenda Item # 7.
City Council Agenda Report
Meeting Date: February 11, 2025
Prepared By: Jon Maginot
Approved By: Gabe Engeland
Subject: City Council Accountability Policy
COUNCIL PRIORITY AREA
☐Business Communities
☐Circulation Safety and Efficiency
☐Environmental Sustainability
☐Housing
☐Neighborhood Safety Infrastructure
☒General Government
RECOMMENDATION
Review the City Council Accountability Policy and provide direction on modifications as needed
FISCAL IMPACT
None
ENVIRONMENTAL REVIEW
Not Applicable
PREVIOUS COUNCIL CONSIDERATION
Last adopted by City Council on October 12, 2021
BACKGROUND
The City Council adopted the Accountability Policy of the Los Altos City Council on October 12, 2021. It has not been revised since its original adoption.
DISCUSSION
At the January 14, 2025 Council meeting, Council requested a future agenda item to discuss the Accountability Policy. It is recommended that Council review the Policy and provide direction on modifications as needed.
ATTACHMENTS
1. Accountability Policy of the Los Altos City Council
242
Agenda Item # 8.
4831-0084-6333v2
JH\27697001
ACCOUNTABILITY POLICY OF THE LOS ALTOS CITY COUNCIL
Adopted October 12, 2021
PURPOSE
The Los Altos City Council adopts this policy for members of the City Council to assure public confidence in the integrity of local governance, to hold itself accountable to each other and the public, and to foster trust from the public.
This policy applies only to the City of Los Altos Mayor, Vice Mayor, and City Councilmembers serving on the Los Altos City Council (“Council”) for improper conduct that could result in admonition or censure.
This policy shall be effective on the date of adoption by the Council (“Effective Date”) and shall not be applied retroactively to any conduct occurring before the Effective Date.
Any disciplinary action taken by the Council under this policy shall be a final action and is not subject to an appeal or reconsideration.
POLICY
It is the policy of the Council that all its members shall abide by federal and state law, City ordinances, and City policies, including the Council Norms and Procedures (hereinafter referred to as Law or Policy). Violations of such Law or Policy tend to undermine the effectiveness of the Council as a whole and foster distrust from the public.
Depending on the circumstances of alleged violations of Law or Policy, the Council may initiate an investigation of the allegations prior to the filing of a request for any of the actions described in this policy. An investigation is not required, but any Councilmember may request and be granted an investigation of the alleged violation.
Nothing in this policy shall preclude individual Councilmembers from making public statements regarding such alleged conduct. While the Council has broad discretion in deciding certain actions it may choose to take in response to violations of Law or Policy, which would not require the Council to adopt policy, including but not limited to voting to remove a Councilmember from a Committee or Board, or a vote of no confidence in a particular Councilmember, this policy provides definitions and procedures related to two types of actions: admonition and censure.
The Council shall only admonish or censure a Councilmember pursuant to this policy if a Councilmember has violated the same Law or Policy more than two times and the 243
Agenda Item # 8.
4831-0084-6333v2
JH\27697001
Councilmember has been publicly warned about such violations by another Councilmember or Councilmembers(s) and the Councilmember that received the warning continues to violate the Law or Policy.
Admonition
An admonition may be informal or formal and is typically directed to a member or members of the Council. An admonition may be issued in response to a particular alleged action or actions in violation of a Law or Policy. An informal admonition may be issued by the Council prior to any findings of fact regarding allegations, and because it is a warning or reminder, it would not require an investigation or separate hearings to determine whether the allegation is true. A formal admonition would follow a public hearing, as further described below. The Council recognizes the right to criticize is protected by the First Amendment, and may be done by an individual Councilmember, or by a Council motion and vote. A Mayor may from time to time remind Councilmembers to comply with any Law or Policy in order to conduct an orderly meeting.
Such reminders by the Mayor are not an admonition.
Censure
Censure is an official reprimand or condemnation made by Council in response to specified conduct by one of its own members. Censure is disciplinary in nature and requires the formal adoption of a resolution setting forth the Councilmember’s alleged violations of Law or Policy.
Although not required, censure could involve an investigation and it must protect the due process rights of the Councilmember being investigated. Censure carries no fine or suspension of the rights of the Councilmember as an elected official, but a censure is a punitive action for a Councilmember’s violations of Law or Policy.
PROCEDURE
Informal Admonition
An individual Councilmember can make an informal admonition at any Council meeting during the Public Presentations or Reports of Councilmembers portion of the meeting. The Councilmember making the informal admonition must first ask the Mayor to make the informal admonition and state on the record the basis for the informal admonition, including the previous two or more times that the Councilmember, who would be subject to the informal admonition, had been warned. After doing so, the Mayor must allow the Councilmember to make the informal admonition. If the Mayor would like to make an informal admonition, the Mayor is also required to state on the record the basis for the informal admonition.
Formal Admonition or Censure Public Hearing
At a public City Council Meeting, three (3) Councilmembers may request a discussion of a formal censure and/or formal admonition action be placed on a future regular meeting Council agenda. At the future meeting that the discussion is heard, a vote by three (3) or more Councilmembers is required to agendize a formal public hearing. The City Clerk shall provide a formal notice of the hearing to the Councilmember who is the subject of the action. The notice 244
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shall contain the specific allegations and/or charges on which the proposed action is based and the date and time that the matter will be heard. At the hearing, the Councilmembers who requested the hearing shall have a cumulative total time of no more than 10 minutes to state the reason(s) they are requesting the formal admonition or censure, and the Councilmember who is the subject of the action shall have up to 10 minutes to respond. Upon hearing the testimony, the Council may take action setting forth its findings and stating the terms of the disciplinary action.
Disciplinary Action.
If, at the close of the hearing, a majority of the entire membership of the Council finds that the subject member’s conduct violates any Law or Policy, the Council may take one or more of the following measures:
(1) Formal Admonition. A Formal Admonition can be in the form of a motion and vote, or an adopted Resolution, and can take any or all of the following forms:
(a) The admonition is directed to one or all members of the Council, reminding them that a particular type of behavior is in violation of law or City policy; and/or (b) Direction is given to the subject Councilmember to correct the result of the particular behavior that violated Law or Policy; and/or
(c) A reprimand is directed to the subject member of the Council based on a particular action (or set of actions) that is determined to be in violation of Law or Policy but is considered by the Council to be not sufficiently serious to require formal censure. (2) Resolution of Censure. The Council may adopt a resolution of censure that clearly sets forth the facts supporting the allegations of misconduct giving rise to the censure. A resolution of censure requires a majority vote of the entire membership of the Council. A resolution of censure may include the imposition of certain actions against the Councilmember such as removal from a committee or Board.
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Agenda Item # 8.
City Council Agenda Report
Meeting Date: February 11, 2025
Prepared By: Nick Zornes
Approved By: Gabe Engeland
Subject: City Council Term Limit Considerations
COUNCIL PRIORITY AREA
☐Business Communities
☐Circulation Safety and Efficiency
☐Environmental Sustainability
☐Housing
☐Neighborhood Safety Infrastructure
☒General Government
RECOMMENDATION
Provide direction on City Council Term Limits.
FISCAL IMPACT
No fiscal impact has been incurred in the preparation of this agenda item. If a ballot initiative were to be placed on a ballot during a future election additional cost will be incurred by the City.
ENVIRONMENTAL REVIEW
This action is not a project under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines section 15378 and 15061(b)(3) as it pertains to organizational structure change that will not result in any direct or indirect physical change in the environment.
PREVIOUS COUNCIL CONSIDERATION
On October 22, 2024, the City Council requested future agenda items for discussion regarding City Council term limits, and consideration of becoming a Charter City. On January 14, 2024, the City Council discussed consideration of a Charter City and Term Limits of the City Council. Consideration of Term Limits was directed to come back for further discussion.
BACKGROUND
The Los Altos Municipal Code (LAMC) of the City of Los Altos (“City”) limits Councilmembers from serving more than two consecutive terms. However, the LAMC does not prohibit a City Councilmember from taking a “break in service” and then being elected to the Council if he or she desires. This is supported by Measure G, adopted by the voters on November 2, 1999, as well as prior City ordinances.
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Voter Approved 1999 – Measure G. On November 2, 1999, Measure G was adopted by the voters and approved Ordinance No. 99-370 (Attachment #2). Ordinance No. 99-370 was adopted on June 8, 1999. It was to apply to persons elected to the City Council or appointed thereto on November 2, 1999, and thereafter, “provided that a majority of the voters voting in said election pass and adopt the proposition approving the above ordinance.” Measure G complied with state law that allowed the City Council to enact an ordinance restricting the number of terms a person may serve on the City Council.
Existing Los Altos Municipal Code
2.04.020 - Limitation of terms for councilmembers.
No person shall serve more than two consecutive terms on the Los Altos city council, plus the completion of any unexpired term to which such person was elected or appointed. [Emphasis added] *Prior code § 2-2.02, renumbered as § 2.04.020.
Additional information regarding the existing provisions of term limits is discussed in the September 25, 2012, Agenda Item – City Council Term Limits (Attachment #1).
ANALYSIS
The City of Los Altos does currently have limitation of terms for councilmembers pursuant to section 2.04.020 of the Los Altos Municipal Code, as approved Voter Approved 1999 – Measure G. The existing provisions regarding term limits however only limit a maximum of two consecutive terms, not a cumulative maximum of two terms (Attachment #1).
The City Council may consider changing the terms for Council members. However, if an initiative is adopted by the Council, or adopted by the voters, it can be repealed or amended only by the voters, unless the ballot language provides otherwise. Govt. Code § 9217; Mobilepark W.
Homeowners Ass’n v. Escondido Mobilepark W. (1995) 35Cal.App.4th 32.
DISCUSSION
If the Council wishes to proceed with a ballot measure changing the Council Term Limits, it will apply prospectively. Govt. Code § 36502. The Council may wish to explore the following options:
Adopt a ballot measure repealing Term Council Limits (Repeal Measure G) Adopt a ballot measure repealing Term Limits (Measure G) and prohibiting any person from serving on the Los Altos City Council:
o For no more than two terms, or no more than eight consecutive years total. o For no more than two terms and any time serving as unexpired term. o Or some combination of the above examples or other limitation not listed here.
A ballot measure to repeal or modify the existing term limit provisions could be considered at the 2025 or 2026 election.
ATTACHMENTS
1. September 25, 2012, Agenda Item – City Council Term Limits Ordinance No. 99-37
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ORDINANCE NO. 99-370
AN ORDINANCE'OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS
ESTABLISHING A TERM LIMIT FOR COUNCILMEMBERS
AT TWO CONSECUTIVE TERMS PLUS COMPLETION
OF AN UNEXPIRED TERM
The City Council of the City of Los Altos does hereby ordain as follows:
Sectioa 1.: Section 2-2.02 is hereby added to the Los Altos Municipal Code to read as follows:
"Section 2-2.02. Limitation of Terms for Councilmembers.
No person shall serve more than two consecutive
terms on the Los Altos City Council, plus the completion of any unexpired term to which such person was elected
or appointed. "
Section 2.: Publication. This ordinance shall be published as provided in Government Code section 36933.
Section 3.: Effective Date. This ordinance shall apply to persons elected to the City Council or appointed thereto on ru'o-iember 2, 1999, and thereafter, provided that a majority of the vsku voting in said election pass and adopt the proposition approving the above ordinance.
The above and foregoing ordinance was 'duly and properly introduced at a regular meeting of the Los Altos City Council held on May 25, 1999, and was thereafter, at a regular meeting of the Los Altos City Council held on June 8, 1999, duly passed and adopted by the following roll call vote: ..
AYES: Mayor Becker, Councilmembers Casto, La Poll, Lear and Moss NOES: ;<one
ABSENT: None
ATTEST:
..I
City Clerk
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City Council Agenda Report
Meeting Date: February 11, 2025
Prepared By: Jaime Chew
Approved By: Gabriel Engeland
Subject: Direct staff to adopt and implement a childcare subsidy program
COUNCIL PRIORITY AREA
☐Business Communities
☐Circulation Safety and Efficiency
☐Environmental Sustainability
☐Housing
☐Neighborhood Safety Infrastructure
☒General Government
RECOMMENDATION
Direct staff to adopt and implement a childcare subsidy program in support of the Santa Clara County initiative for affordable childcare.
FISCAL IMPACT
The ad hoc subcommittee and staff recommend allocating $30,000 from the general fund to support the creation of the childcare subsidy program.
$30,000 will be budgeted in the Parks & Recreation FY 25/26 operating budget. $25,000 in revenue is expected from the first full year of the agreement with Children’s Corner to offset 83% of the program cost.
ENVIRONMENTAL REVIEW
Not Applicable.
PREVIOUS COUNCIL CONSIDERATION
None
BACKGROUND
At the June 25, 2024, regular City Council meeting, City Council authorized the creation of a Subcommittee of Councilmember Fligor and Mayor Weinberg to research the topic further, and for staff to bring the item back to a future meeting date.
ANALYSIS
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Staff surveyed seven Santa Clara County cities (Campbell, Gilroy, Milpitas, Mountain View, Palo Alto, Santa Clara, Sunnyvale) that currently offer subsidy programs. After evaluating all program parameters, staff noted the following:
All surveyed cities utilized Housing and Urban Development (HUD) income limits to set program eligibility.
All surveyed cities set residency as a program requirement for eligibility. However, the city of Campbell is in the process of changing this requirement to include non-residents (those who work in the city) to increase program usage. The subsidy program in three of the seven cities (Gilroy, Mountain View, Sunnyvale) are specific to youth. The other four cities (Palo Alto, Milpitas, Santa Clara, Campbell) service all ages.
All surveyed cities set a maximum level of subsidy through:
o Flat subsidy amount per child and/or per family.
Example - $200 per child and $400 per family.
o Percentage subsidy of the program fee.
Example – 50% of the program fee.
The subsidy program in six of the seven cities are managed internally by staff. In the city of Mountain View, the Community Services Agency (CSA) manages the application and verification process.
DISCUSSION
It is anticipated that the city will net approximately $25,000 in annual revenue from Children’s Corner, the vendor selected to offer the preschool-age enrichment program on behalf of the city of Los Altos, for use of the Acorn Room at the Los Altos Community Center.
Based upon evaluation of survey information and Subcommittee discussion, the creation and implementation of a childcare subsidy program is being recommended with the following parameters:
HUD income limits to set program eligibility.
Open to residents and all city of Los Altos employees. Subsidy of 50% of the program fee up to $10,000 per family. Preschool-age focus, 2 years to 5 years.
Considerations for program eligibility expansion include:
Contracted public safety (Firefighters)
Contracted city staff
Los Altos business employees
School district staff
Staff recommends City Council direct staff to adopt and implement the proposed childcare subsidy program in support of the Santa Clara County initiative for affordable childcare. 272
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Resolution 2025- Page 1 of 2
RESOLUTION NO. 2025-___
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS
TO DIRECT STAFF TO ADOPT AND IMPLEMENT A
CHILDCARE SUBSIDY PROGRAM
WHEREAS, on February 28, 2023, the Board of Supervisors for the County of Santa Clara approved funding for childcare initiatives to address childcare disruptions and enrollment gaps by reopening or increasing the total number of affordable infant and toddler childcare spaces available to families; and
WHEREAS, at the regular meeting of April 9, 2024, City Council authorized execution of an agreement with Children’s Corner to offer preschool-age services on behalf of the city of Los Altos at the Los Altos Community Center; and
WHEREAS, at the regular meeting of June 25, 2024, City Council authorized the creation of an Ad Hoc Subcommittee of Councilmember Fligor and Mayor Weinberg to research the topic further; and
WHEREAS, seven Santa Clara County cities currently offer subsidy programs; and WHEREAS, the Ad Hoc Subcommittee and staff recommend including $30,000 in the Parks & Recreation operating budget starting fiscal year 2025/26 to support the creation of the childcare subsidy program; and
NOW, THEREFORE, BE IT RESOLVED, that the City Council of the city of Los Altos hereby directs staff to adopt and implement a childcare subsidy program in support of the Santa Clara County initiative for affordable childcare.
I HEREBY CERTIFY that the foregoing is a true and correct copy of a Resolution passed and adopted by the City Council of the city of Los Altos at a meeting thereof on the 11th day of February 2025 by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
Pete Dailey, MAYOR
Attest:
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Resolution 2025- Page 2 of 2
_____________________________
Melissa Thurman, MMC
CITY CLERK
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Agenda Item # 10.
City of Los Altos 2025 Tentative Council Agenda Calendar All items and dates are tentative and subject to change unless a specific date has been noticed for a legally required Public Hearing.
Items may be added or removed from the shown date at any time and for any reason prior to the publication of the agenda.
FEBRUARY 25, 2025
CLOSED SESSION (5:00 p.m.)
STUDY SESSION (6:00 p.m.):
Joint Commission Meetings:
o Complete Streets Commission
o Financial Commission
o Senior Commission
o Planning Commission
REGULAR MEETING (7:00 p.m.):
CONSENT:
Amendment No. 2 to Environmental Engineering & Contracting, Inc. Agreement Dog Park
DISCUSSION:
Parking Restrictions around Los Altos High School
Council Goals and Priorities
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Agenda Item # 11.
City of Los Altos 2025 Tentative Council Agenda Calendar All items and dates are tentative and subject to change unless a specific date has been noticed for a legally required Public Hearing.
Items may be added or removed from the shown date at any time and for any reason prior to the publication of the agenda.
MARCH 11, 2025
REGULAR MEETING (7:00 p.m.):
CONSENT:
Appoint Commissioners for Vacant Seats
Contract Award for Hetch Hetchy ADA Improvements Project Independent Intake Official Report
DISCUSSION:
Introduce Ordinance Amending Council Meeting Definitions AB481 – Military Equipment
Parking Enforcement Contract Award and Code Change
Remaining 2025 City Council agenda calendar items are pending and will be published at a later date. 276
Agenda Item # 11.
PROGRAM SUB PROJECT INITIATION DATE HEU COMPLETION DATE STATUS Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
Budget & Hire Planning
Technician December 31, 2022 COMPLETED
Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
Amend ADU Ordinance
based upon HCD's letter 6 months or less COMPLETED
Program 6.G: Housing mobility
Allow more than one
JADU (at least two per
site)
with ADU Ordinance
Update COMPLETED
Program 3.H: Amend design review process and
requirements.
Eliminate 3rd Party
Architectural Review February 28, 2023 COMPLETED
Program 3.H: Amend design review process and
requirements.
Dismiss Design Review
Commission February 28, 2023 COMPLETED
Program 3.L: Eliminate the requirement of story poles. March 31, 2023 COMPLETED Program 2.E: Conduct annual ADU rental income surveys.
Budget & Hire Housing
Manager March 31, 2023 COMPLETED
Program 4.J: Facilitate alternate modes of transportation for Adopt VMT Policy & June 30, 2023 COMPLETED Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
RFP-Permit Ready ADU
Plans July 31, 2023 COMPLETED
Program 1.H: Facilitate housing on City-owned sites. Financial Analysis July 1, 2023 December 31, 2023 COMPLETED Program 3.D: Evaluate and adjust impact fees. August 1, 2023 December 31, 2024 COMPLETED Program 1.H: Facilitate housing on City-owned sites. Release RFP December 31, 2023 COMPLETED Program 6.C: Target housing development in highest
resource areas. Initial Outreach September 31, 2023 IN-PROGRESS Program 6.D: Promote Housing Choice (Section 8) rental
assistance program. September 31, 2023 IN-PROGRESS
Program 2.A: Continue to implement and enhance
inclusionary housing requirements. December 31, 2023 ONGOING Program 2.B: Establish an affordable housing in-lieu fee and commercial linkage fee. Housing in-lieu fee. December 31, 2023 COMPLETED Program 2.F: Water and Sewer Service Providers. December 31, 2023 COMPLETED Program 3.B: Modify building height in mixed-use zoning districts. Downtown Districts December 31, 2023 COMPLETED 277
Agenda Item # 11.
Program 3.E: Ensure that the density bonus ordinance
remains consistent with State law. December 31, 2023 ONGOING Program 3.H: Amend design review process and
requirements. Code Amendments December 31, 2023 COMPLETED Program 3.K: Standardize multimodal transportation
requirements.
Bicycle Storage and
Charging Regulations December 31, 2023 COMPLETED
Program 3.K: Standardize multimodal transportation
requirements.
Remove CSC Review of
Housing Developments December 31, 2023 COMPLETED
Program 4.C: Allow Low Barrier Navigation Centers
consistent with AB 101. December 31, 2023 COMPLETED
Program 4.D: Allow transitional and supportive housing
consistent with State law. December 31, 2023 COMPLETED
Program 4.E: Allow employee/farmworker housing
consistent with State law. December 31, 2023 COMPLETED
Program 4.F: Reasonably accommodate disabled persons’
housing needs. December 31, 2023 COMPLETED
Program 6.B: Maintain and expand an inventory of
affordable housing funding sources. Prepare Inventory. December 31, 2023 IN-PROGRESS Program 6.E: Prepare and distribute anti-displacement
information. December 31, 2023 IN-PROGRESS
Program 1.A: Rezone for RHNA shortfall. January 31, 2024 COMPLETED Program 1.G: Rezone housing sites from previous Housing Elements. January 31, 2024 COMPLETED
Program 3.G: Amend Conditional Use Permits findings
applicable to housing developments. March 31, 2024 COMPLETED Program 3.I: Allow residential care facilities consistent with State law. January 31, 2024 COMPLETED
Program 3.J: Explicitly allow manufactured homes consistent with State law. January 31, 2024 COMPLETED
Program 3.F: Reduce Conditional Use Permit requirement for residential mixed-use and
multi-family. September 31, 2024 COMPLETED
Program 1.B: Facilitate higher density housing in the
Commercial Thoroughfare (CT) District. January 31, 2024 COMPLETED 278
Agenda Item # 11.
Program 1.C: Allow housing in the Office Administrative (OA) District. January 31, 2024 COMPLETED
Program 1.E: Update the Loyola Corners Specific Plan. January 31, 2024 COMPLETED Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
Adopt-Permit Ready ADU
Plans December 31, 2024 IN-PROGRESS
Program 3.A: Prepare a Downtown parking plan and update citywide parking requirements. Downtown Parking Plan December 31, 2024 COMPLETED Program 3.A: Prepare a Downtown parking plan and update citywide parking requirements.
Comprehensive Parking
Ordinance Update December 31, 2024 COMPLETED
Program 3.B: Modify building height in mixed-use zoning districts.
Commercial
Neighborhood (CN)
District December 31, 2024 COMPLETED
Program 3.C: Remove floor-to-area ratio (FAR) restriction at Rancho Shopping Center and
Woodland Plaza. December 31, 2024 COMPLETED
Program 3.M: Modify parking requirements for emergency
shelters consistent with State
law. December 31, 2024 COMPLETED
Program 2.B: Establish an affordable housing in-lieu fee and commercial linkage fee. Commercial linkage fee. December 31, 2025 COMPLETED Program 1.D: Allow housing on certain Public and
Community Facilities District sites and
facilitate housing on religious institution properties. December 31, 2025 Program 6.G: Housing mobility
Allow housing on all
religious sites within the
City December 31, 2025
Program 1.F: Rezone Village Court parcel. January 31, 2024 COMPLETED Program 4.H: Provide additional density bonuses and
incentives for housing that accommodates special needs
groups. December 31, 2025
Program 4.I: Allow senior housing with extended care
facilities in multi-family and mixed-use zoning districts. December 31, 2025 Program 1.I: Incentivize Downtown lot consolidation. July 31, 2026 279
Agenda Item # 11.
Program 4.G: Assist seniors to maintain and rehabilitate their homes. July 31, 2026
Program 6.C: Target housing development in highest
resource areas. Follow-up Outreach September 31, 2026
Program 1.H: Facilitate housing on City-owned sites. Entitlement Review December 31, 2026 Program 3.N: Modify standards in the R3 zoning districts. December 31, 2026 COMPLETED Program 4.J: Facilitate alternate modes of transportation for residents.
Capital Improvement
Project for above head
pedestrian crossing
signals on San Antonio
Road near Downtown Los
Altos December 31, 2027
Program 5.F: Incentivize the creation of play areas for multifamily housing projects. December 31, 2027 Program 1.K: Participate in regional housing needs planning efforts. Ongoing
Program 1.L: General Plan amendments. Ongoing
Program 1.M: SB 9 implementation. Ongoing
Program 1.N: Facilitate and monitor pipeline housing
projects. Ongoing
Program 2.C: Assist in securing funding for affordable
housing projects. Ongoing
Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs). Ongoing
Program 2.E: Conduct annual ADU rental income surveys. Annual Survey Annually ONGOING Program 4.A: Support efforts to fund homeless services. Ongoing Program 4.B: Continue to participate in local and regional forums for homelessness,
supportive, and transitional housing. Ongoing
Program 5.A: Monitor condominium conversions. Ongoing
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Agenda Item # 11.
Program 5.B: Continue to administer the City’s affordable housing programs. Ongoing
Program 5.C: Restrict commercial uses from displacing
residential neighborhoods. Ongoing
Program 5.D: Implement voluntary code inspection program. Ongoing Program 5.E: Help secure funding for housing rehabilitation and assistance programs. Ongoing
Program 6.A: Assist residents with housing discrimination and landlord-tenant
complaints. Ongoing
Program 6.B: Maintain and expand an inventory of
affordable housing funding sources.
Inform, Evaluate
Apply/Submit Ongoing
Program 6.F: Affirmatively market physically accessible units. Ongoing Program 7.A: Promote energy and water conservation and
greenhouse gas reduction
through education and awareness campaigns. Ongoing
Program 7.B: Monitor and implement thresholds and
statutory requirements of climate change legislation. Ongoing 281
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