Los Altos City Council
January 27, 2026

6 an aerial photo of the property, all associating the Van Epps family with the house. The family owned and occupied the house from 1929 to 1945, a total of sixteen years.

None of the consultants addressed the probable scenario that the tiny cottage on the rear of the property was the original home of the Van Epps family, occupied while they built their large house on the front of the property. After their new home was completed, the “cottage” may have been rented out, as noted in the 1930 census. It was apparently converted to a garage in 1933 and later remodeled once again to residential living. It is interesting however, that their presence, a family of four building a new house, was newsworthy enough to merit a newspaper notice when they made the transition.

While the consultant spent a great deal of effort researching the identities of the various homeowners over the last century, the Bibliography omits published histories of community development. Sadly, the consultants failed to understand the critical importance of the initial owners, the family who built the home. The consultant failed to investigate the heritage of the original family. Also, there are no standard references related to the development of Santa Clara County or the Southern Pacific Railroad. There are no histories of the development of the interurban rail lines, critical to understanding the establishment and creation of the economy of the City of Los Altos and the residential development of the Adams subdivision and the Pepper Drive neighborhood.

There are substantial errors. One of the most glaring mistakes confuses the San Francisco-San Jose Railroad (now known as CalTrain) with the “Southern Pacific”. The SF-SJ Railroad was initially a small local railroad, one of the most historic in America. Completed in 1864, it was acquired by the Central Pacific Railroad in 1870 and served the Peninsula. It was the SF-SJ Railroad that established the little depots such as Mayfield and many others, all part of Caltrain today, not the Southern Pacific. Later mergers changed the name of the railroad to Southern Pacific.

The consultant included a substantial discussion of a local Japanese family, the Furuichi family, who lived nearby on Hawthorne Avenue for approximately a century (1918-2018). The California Alien Land Law of 1913 is mentioned in the narrative, but the consultant does not tell us how the Furuichi family is related to the Van Epps family, or if the Furuichi family experienced discrimination. Were restrictive covenants in place in Los Altos because of the Furuichi family; the consultant is not clear on the connection between the Van Epps and the Furuichi family.

Notes in other California histories observe that many Japanese immigrants circumvented the restrictions and transferred legal ownership of their property to children who had been born in America and were therefore legal citizens rather than “aliens”. The specific reason for including a discussion of this one family in the historic report is not made clear.

Report Three (Page & Turnbull Peer Review, 2025)) – A Peer Review is a very specific critique of a Historic Resource Evaluation (HRE), one that is sometimes commissioned when

7 there are conflicting reports. A Peer Review is not a HRE although some elements are similar. It would have been helpful to the staff of the contracting agency and to the Historical Commissioners who read the Peer Review to explain the purpose and limitations of a Peer Review, what it covers and why it was necessary.

A Peer Review looks at the discrepancies of an HRE. For example, an adequate HRE looks at important community history on a local, state and national level. The Peer Review commented on the Evans & DeShazo report by noting, “ History of the property’s localized neighborhood is not discussed.” (Page 96)
The Peer Review correctly notes that the consultant has failed to discuss the subject property within the context of the Adams subdivision and the larger development of Los Altos in 1929. Although the Adams family chose to subdivide their property into small lots in 1911, it was eighteen years before any substantial development began taking place in the Los Altos area. This is a curious situation during what seems to be a prosperous time for the Santa Clara Valley community. The deed restrictions that were attached to the Adams subdivision may have been a limiting factor.

The creation of the Adams subdivision, perhaps the earliest such subdivision in Los Altos, marks the significant moment when the Los Altos area changed from small orchards to subdivisions of small parcels. Although the Adams subdivision is located within close proximity of the Los Altos depot and the growing commercial area, residential development was very slow. It is a situation that was not discussed, one questioning the desirability of Los Altos in the decades before the onset of the Great Depression. Context, both time and place, are critical elements in an HRE.

Like the previous consultant, Page & Turnbull also notes that the Bibliography meets Industry Standards. But both groups neglect to note the Industry Standard only covers format, not content. The format should conform to A Manual for Writers by Kate Turabian - Ninth Edition, now the standard guide for HREs. The references listed in the bibliographies do not include any local histories, other than one self-published book by Joe Salameda, a knowledgeable City of Los Altos employee. His book, Memories of Los Altos, was self-published in 1982 provides useful community information but overlooks the larger development issues.

Because Evans & De Shazo did not research the Van Epps family, any mention of their importance in the Los Altos community was not included in the comments by the subsequent consultant, Page & Turnbull. So Page & Turnbull could not come to accurate conclusions regarding the significance of the property. Comments on the original construction and biographical information of the original owner are completely missing from the Peer Review and it is therefore likewise an incomplete document.

8 The Importance of the Architecture and its Context
The Van Epps House appears on the Los Altos HRI because of its architectural style. All three reports agree on the name of the style of the house the Van Epps chose to build. They all agree it is called Colonial Revival, a building style that came back into fashion again after World War I. It is a popular style that originated in Eastern America in the late 17th century and has been revived by builders several times in America over the centuries. It is not a revival style that is generally popular in California and the Southwest. All three reports agree on the general stylistic features of Colonial Revival.

This is a very unusual house for its time and place. This is probably the reason the first consultant flagged it for the Historic Inventory and noted its importance for further research.

Because this house has retained its integrity and is unusual within in its community, it was singled out by the Circa architectural historian in 2011 as worthy of notice. The house is a pristine example of this important American building style; it has not been modified or “reinterpreted” to suit personal whim. The consultant report provides photographic examples of the style from a nationally recognized expert.

Having identified the house as a Colonial Revival-style structure, as described in Virginia McAlester’s reference A Field Guide to American Houses, 2014 Edition, the Page & Turnbull report identifies two other structures in Los Altos listed on the HRI as having similar characteristics. The houses are located at 1570 Kensington Circle and 1448 Fowler Lane.

Looking only at those photographs which were provided, both houses have some of the general characteristics of the general style but neither one appears to be a good overall example of the Colonial Revival style and neither one is a Cape Cod substyle. Both appear to have been originally built with some Colonial style features added by subsequent contractors. Both houses also appear to have been later modified by adding wings, porches, oversized dormers and replacing window panes. Both houses are substantially larger than the Pepper Drive house which retains its original footprint. The Colonial Revival style is notable in Los Altos because there are so few Colonial Revival houses anywhere in California.

There is some confusion about the relative importance of the Van Epps house and the comment was made that it does not appear to “embody the work of a craftsman”. This is not an appropriate assessment for several reasons. First, two of the reports refuse to research the builder, his heritage and his occupation. Second, it is frequently difficult to look at a Colonial Revival house and tell what decade or even what century it belongs to. For decades it has been a “nostalgia” style – a house that appeals to someone who wants a traditional “American” house. It is not a style that was ever widely popular in Santa Clara County or appeared in the early days of the rural Fremont Township. This is a housing style that was sometimes marketed and built as a “kit home”, particularly across the Midwest. Sears, Roebuck Company and others sold small Colonial Revival-style homes by mail.

9 This 1929 house is a modest “starter home”, which the builder may have hoped would appeal to the Los Altos resident of the future. It is an American style, one that is easily recognized and is nationally popular. It is a house that offers predictable comfort to its residents; it once featured a very traditional floor plan suitable for family living. The Van Epps house is remarkable as subsequent 1950’s-1960’s tract homes of midcentury style are ubiquitous in Los Altos. 81 Pepper captures our attention because of its very traditional, American-colonial style.

The house at 81 Pepper Drive is not an “orchard” house, although the community was marketed in brochures and newspaper ads as an area of extraordinary agricultural productivity.

It is located in a subdivision with relatively small lots, a subdivision that was opened in 1911 with severe deed restrictions and no mention of irrigation. It is located within what seems to be the first subdivision of its type, and it was not a popular location despite its proximity to the Los Altos Depot and other amenities. It would be decades before other homeowners became interested in building in the area.

Growth in the Los Altos area was slow when compared to the neighboring orchard communities of Campbell (1952), Cupertino (1955) and Saratoga (1956). Those adjacent communities generally have housing styles and a development pattern similar to Los Altos; frame farmhouses followed by orchard cottages and finally suburban tract homes. Urban development in California during the 1920s usually feature structures that take advantage of the weather, a highly desirable feature of California life. So it is very unusual to find a house built in a traditional American style when many neighboring Californians are choosing to build bungalows or stucco-clad adobe homes. The Van Epps houses are currently listed on the Los Altos HRI and should continue to be listed.

April Halberstadt, M.A.

Historian
January 2026

10 END NOTES FOR FURTHER BACKGROUND
Date of Construction
There is some inconsistency within the reports regarding the date of construction. One report (Evans) commented that the construction date had not been documented despite presenting evidence to the contrary! The earliest report, presented by Circa (2011) as part of the updated HRI, references the date as 1933. Many real estate companies (and researchers) use a date found on the records of Santa Clara County Assessor’s Office as the Year Built. The SCC Assessor frequently notes they are not responsible for the accuracy of building permit data; they are only responsible for tax data. The 1933 date appears to be an Assessor date.

Since there is only one field on the Assessor’s Records for any date, the year shown reflects the most recent year of any construction activity that will affect the property tax assessment. If a property owner builds a new garage or barn, that construction activity is forwarded from the local city to the Tax Assessor who updates their record accordingly. Year Built data from the SCC Assessor records is not always a reliable date of original construction.

The build date of 1933 for the garage is an obvious error; documentation in the Peninsula Times provided by Evans dated 1929 note the family living on the property during construction of the main house. The date is verified by both a newspaper clipping and a 1930 aerial photo on Page 30 of the Evans report. Those resources show both the “cottage” and the larger house on the site by 1930.

Given the documentary evidence it is very surprising that the Evans report then states in the Evaluation on page 43,
“A thorough literature search and review of the Property owners…did not reveal any person…that is important to our past.”
The Evans report failed to identify Van Epps as the builder, despite providing documentary evidence to the contrary. The researcher has the responsibility of not only identifying residents of state or national significance, but also identifying local residents who had a significant local impact on their community. Local history is also important history.

Records in the Office of the Santa Clara County Recorder show Harry and Grace Van Epps bought the lot for their home in December of 1928
5 from J. K. and Sofia Durst, who are
also listed at an address on Pepper Drive in 1930. The price of the lot was $1,050.

The Van Epps family built their home in 1929, a Colonial Revival-style “starter home” that is a very different from the (1905) J. Gilbert Smith house and other orchard house 5 Book 440 of Deeds, Pages 152-153.

11 properties nearby. The Gilbert house, a rustic cottage clad in redwood shingles, is more typical of early Los Altos orchard homes located on five-to-ten-acre orchard lots.

The lots of the Adams subdivision (1911) were restricted, specifying that residences built should cost not less than $5,000 and that no businesses were allowed. In addition, there could be no wood yards, barns, or stores and no livestock or chickens. Language in the deeds also restricts properties to owners of the Caucasian race. In 2023 a California law redacted all racially discriminatory language from legal documents.

None of the consultants addressed the probable scenario that the tiny cottage on the rear of the property was the original home of the Van Epps family, occupied while they built their large house on the front of the property. After their new home was completed, the “cottage” may have been rented out, as noted in the 1930 census. It was apparently converted to a garage in 1933 and later remodeled once again to residential living. It is interesting however, that their presence, a family of four building a new house, was newsworthy enough to merit a newspaper notice when they made the transition.

None of the three reports have commented directly on the importance of the build date. In this case, context (and timing) is everything. This house was completed just a few months before the stock market crash in 1929, the date usually noted as marking the beginning of the Great Depression. Within a few months, all construction nationwide, and in California, ground to a halt as banks failed and businesses closed. This house could not have been built a few months later; building materials and financing had become very scarce.

During the Great Depression, Santa Clara Valley was relatively better off than many other parts of America. At least the weather was not as severe and food was plentiful. But a review of local building permits and construction activity in the County shows almost no construction activity until after WWII when construction materials once again became available. None of the reports mention the significance of the date, an important part of the documentation. Given the documentary evidence, the date of construction for both structures should be 1929.

The Importance of Harry and Grace Van Epps
There is a special place in the development of communities for those people who are the pioneers, the first people to build houses and to create neighborhoods. Harry and Grace Van Epps are among the pioneers of Los Altos. The purpose of the Circa report was to identify notable houses that had some significance in the landscape. While Harry and Grace are listed as the first occupants of a house on Pepper Drive, none of the consultant reports credit this family with not only building the house but also helping to build the Los Altos community.

There is also a special place in the history of a house for the first owner, especially when the structure is a custom-built home. Most home-owners buy a home that reflects their social attitudes, taste and pocketbook. It is useful to analyze and discuss the style of a home to

12 determine something about the personality of the original owner, especially when the owner has designed and built the house. It would have been extremely important for the consultants to take a deeper dive into the history of Harry and his family. It should have been an obvious path to follow since they were the first owners.

Harry Van Epps and his family apparently had a long relationship with the Fremont Township area, as noted in his obituary. (His obituary was not acquired by the consultants).

Harry’s parents, George and Elizabeth Van Epps, were pioneers, first in Montana Territory (1882) and then in Palo Alto (1902). Harry moved to Palo Alto with his parents in 1902, but notes in the local paper, the Town Crier, reveals the family retained substantial ties to their Montana community. Harry grew up and attended school in the Mountain View area (Fremont Township) before returning to work in Montana when in his late teens.

Harry married Grace Lane when he was 33 years old; she was 26. His wife’s parents, George and Nettie Lane lived in very rural eastern Montana. The younger couple lived with the Lane family briefly in Montana, as recorded in the 1920 census. However it is important to note that the census shows Harry and Grace’s first daughter, Gwendolyn, was born in California. The young Van Epps family returned to Fremont Township during the 1920s, living first on Hawthorne, a block from Pepper Drive.

It is very likely that as a young teen, Harry returned to Montana to help with the family farm and met Grace. After they married, it is likely the little family decided to move to the Fremont Township area permanently for better schools and better opportunities in homebuilding.

An article in the Peninsula Times in July, 1929,
“Mr. and Mrs. Harry Van Epps of Los Altos will move at the end of this week into their new home which they have just completed on Pepper Drive. Since selling their former residence on Hawthorne Street, they have been occupying temporary quarters on the new property.”
From obituaries and census information we know that both grandfathers were also carpenter/ builders. So it is not surprising to read that the Van Epps family, a carpenter and the daughter of a carpenter, built their own home. We know that Hawthorne Avenue is directly behind Pepper Drive. We know from later census information and City Directories that the family moved to other properties nearby. The family lived on Lyell Street for eight years before the death of Grace Van Epps.

After their second daughter was born, the Van Epps family may have had the services of household help. When the Van Epps moved into their new home, Gwendolyn was eleven and Alice Virginia was six. The 1930 census shows a 15-year-old “boarder” in the household, who might have been a mother’s helper for the family. Grace died in 1958 at the age of 67, her obituary noting she was living in a local nursing home. Her obituary also noted she was a

13 member of the Los Altos Woman’s Club and the Union Church of Los Altos, two organizations with highly active memberships and profiles in the community. So presumably she participated in their activities for many years. Harry remarried after Grace’s death and left the area. He was about 72 years old at that time.

Building Permits in County Areas
Early construction in the rural areas was under the jurisdiction of Santa Clara County.

Los Altos was not incorporated as a City until 1952. Nearly all areas in Santa Clara County allow the construction of small buildings, generally 10x20 feet, without a permit. Nearby Mountain View was incorporated in 1902 and it was the commercial and business center that served Fremont Township, which included Los Altos and Los Altos Hills.

Since Mountain View and Palo Alto are both located on major transportation arteries, the San Francisco-San Jose Railroad (now Caltrain) and the El Camino Real, settlement of the remaining rural Los Altos community was comparatively slow. It has been possible to document some early Los Altos homes through the Daily Pacific Builder (DPB) an industry newspaper published weekly in San Francisco. Only a few hundred residences were built in the Fremont Township area before 1952. There was almost no local industry except a major fruit and vegetable processing business in Palo Alto and Stanford University.

The Importance of Fremont Township – Context
Historic reports should look at important community history on a local, state and national level. Los Altos and Los Altos Hills are rural communities within Fremont Township, established in 1852, shortly after California statehood. Fremont Township was the early governmental entity that supervised the establishment and locations of roads, bridges, post offices and schools within the northern area of Santa Clara County. Fremont Township included the communities of Mayfield and Mountain View, both located on the major transportation corridors. The major transport corridors were El Camino Real, which was established during the Spanish colonial era after 1777, and the San Francisco-San Jose Railroad, completed in 1864. It must be noted that the communities along these arteries were connected in 1852 by telegraph lines which ran between San Francisco and San Jose.

The earliest and most significant development in Fremont Township was the Town of Mountain View, established on the road between San Jose and San Francisco. When the railroad was established in 1864, the original town of Mountain View was bypassed so locals created a second town site nearby, resulting in Old Mountain View and (new) Mountain View.

These communities were Fremont Township’s gateways to goods and services, shipping agricultural commodities to market and providing community services such as a blacksmith, post offices, and many other essential businesses. Farms in what is now known as Los Altos and Los Altos Hills used San Antonio Road as their major route into the area. The Embarcadero at

14 Rengstorff Landing and Clark’s Landing were major shipping points for bulk commodities going to San Francisco and beyond.

Researching Rural Santa Clara County: Local History of Los Altos and Los Altos Hills The development of the communities of Los Altos and Los Altos Hills, now over a century old, has been poorly documented and poorly represented in local histories. They are not alone in failing to document their growth and development. Consultants shudder at trying to determine the histories of various structures because the rural areas of California frequently keep such poor records. Building permits in unincorporated areas are nearly nonexistent before 1950. The recent appearance of various digital media, such as digitized local newspapers beginning around the year 2000, has made access to rural information easier.

Over the early years of California’s urban centers, some of the more significant homes were noted in the Daily Pacific Builder, Building & Engineering News and the Building and Industrial Record. These publications were printed in San Francisco for the construction industry and list the approximate locations of construction projects throughout the Bay Area. In recent years these publications have been made available on line, but they are extremely timeconsuming to search. However they have provided some of the best (and only) information of construction activity in early Los Altos and Los Altos Hills. The other resources are the local newspapers, now available on line by subscription, thanks to the Internet.

Another reliable source of information about Los Altos development has also recently been made available, and that is their local newspaper. Los Altos has been very fortunate to have a newspaper that keeps an eye on its community. The Joe Salameda book has an excellent community timeline; Los Altos is a community that grew very slowly. There were only 230 patrons of the Los Altos Water Company in 1924 and although a volunteer fire department was organized in 1922, they did not purchase a truck until 1929.

15

16

M. SANDOVAL ARCHITECTS, INC.

Page:

Page: 1
145 Corte Madera Town Center #404
Corte Madera, California 94925
Peninsula and South Bay Region
Phone: 650.941.8048
San Francisco, Marin and
North Bay Region
Phone: 415.924.7059
Napa and Sonoma
Phone: 707.637.4363
[email protected]
www.msandovalarchitects.com
Architecture - Historic Preservation - Design
January 21, 2026
Members of the Los Altos City Council
1 North San Antonia Road
Los Altos, CA 94022
RE: The removal of 81 Pepper Drive from the City of Los Altos Historic Resource Inventory
Dear Members of the City of Los Altos City Council,
As a practicing Architect meeting the professional qualification requirements for both Architect and Historic Architect used by the National Park Service (Code of Federal Regulations, 36 CFR Part 61), and having over 25 years of experience preserving and repurposing historic buildings and landmark structures both in Los Altos and other Bay Area cities, and a past member of the Los Altos Historical Commission (1988-1989 & 1991-2003), upon my examination of the two historic resource evaluations prepared for this property there are two major concerns which I want to bring to your attention. They are follows:

ISSUE OF CONCERN 1: There is significant evidence to support the notion that the home located at 81 Pepper Drive could be only surviving example of a do-it-yourself (DIY) Kit Home that was widely sold through the Sears, Roebuck & Company catalogs between 1908 and 1942 left in the city of Los Altos. The absence of any evidence of this possibility from the discussions of the home’s historic significance and value, unfairly restricts this property from meeting the minimum threshold requirement in the California Register under Criterion 1: (NRHP Criterion A) that would be otherwise normally available to any other property locally listed on the city’s HRI.

ISSUE OF CONCERN 2: The two existing Los Altos historic properties used as comparable examples neither aligned with the two referenced within their own historic resource evaluation of the property, nor did they represent an accurate depiction of the variant and subtype of the Colonial Revival style, which is commonly referred to as Cape Cod Revival or Cape Cod Cottage to formulate the architectural context of this property. As a result, this has unfairly diminished the historic significance of the property to meet the minimum threshold required to be listed individually in the California Register under Criterion 3: (NRHP Criterion C).

M. SANDOVAL ARCHITECTS, INC.

Page:

Page: 2
145 Corte Madera Town Center #404
Corte Madera, California 94925
Peninsula and South Bay Region
Phone: 650.941.8048
San Francisco, Marin and
North Bay Region
Phone: 415.924.7059
Napa and Sonoma
Phone: 707.637.4363
[email protected]
www.msandovalarchitects.com
Architecture - Historic Preservation - Design
In the following attachment, I have tried to compile additional information for your consideration, supporting the two concerning issues raised.

It is my hope, upon reviewing this material, you too will share my concerns and direct staff to secure the services of another qualified third-part architectural firm to perform another historic resource evaluation of the property and to authenticate if the home at 81 Pepper Drive is actually a Sears Modern Home, in light of these two issues raised, before making any decision to remove this important historic resource from the city’s HRI.

Thank you for your time and consideration regarding this important matter.

Sincerely,
Mark Sandoval, AIA
President
M. SANDOVAL ARCHITECTS, Inc.

Attachment:

BACKGROUND
As has been pointed out in both historic resource evaluations, in order both authors to be found eligible for listing on the California Register of Historic Resources (CRHR) properties must have significance under one of the four following criteria and must retain enough of their historic character or appearance to be recognizable as historical resources and convey the reasons for their significance (i.e., retain integrity). The California Register utilizes the same seven aspects of integrity as the National Register. Properties that are eligible for the National Register are automatically eligible for the California Register. Properties that do not meet the threshold for the National Register may meet the California Register criteria.

Criterion 1: (NRHP Criterion A) Associated with events that have made a significant contribution to broad patterns of local or regional history, or the cultural heritage of California or the United States;
Criterion 2: (NRHP Criterion B) Associated with the lives of persons important to local, California, or national history;
Criterion 3: (NRHP Criterion C) 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
Criterion 4: (NRHP Criterion D) Yields important information about the prehistory or history of the local area, California, or the nation.

CRHR criteria are similar to the National Register of Historic Places criteria and are tied to CEQA, as any resource that meets the above criteria and retains a sufficient level of historic integrity is considered a historical resource under CEQA. Integrity is the authenticity of a historical resource’s physical identity, evidenced by the survival of characteristics that existed during the resource’s period of significance.

INTEGRITY
When evaluating a potential historic resource, one must determine and clearly state the significance of that resource to American history, architecture, archaeology, engineering, or culture. A resource may be considered individually eligible for listing in the California Register if it meets one or more of the above-listed criteria for significance and it possesses historic integrity. Historic properties must retain sufficient historic integrity to convey their significance.

The National Register of Historic Places recognizes seven aspects or qualities that define historic integrity. These are also used in evaluations of integrity for the CRHR and are as follows:

Location: The place where the historic property was constructed or the place where the historic event occurred.

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.

Association: The direct link between an important historic event or person and a historic property.

Historical resources eligible for listing in the California Register (CRHR) must meet one of the criteria of significance and retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. To retain historic integrity, a resource should possess several of the above-mentioned aspects. The retention of specific aspects of integrity is essential for a resource to convey its significance.

Resources that are significant, meet the age guidelines, and possess integrity will generally be considered eligible for listing in the CRHR.

There is no question that 81 Pepper Drive meets the minimum age threshold of 50 years since records show the home was constructed in 1929, or Criterion 4: (NRHP Criterion D) Yields important information about the prehistory or history of the local area, California, or the nation.

There is however sufficient evidence to support Criterion 1: (NRHP Criterion A) Associated with events that have made a significant contribution to broad patterns of local or regional history, or the cultural heritage of California or the United States and Criterion 3: (NRHP Criterion C) Embodies the distinctive characteristics of a design-type, period, region, or method of construction if authenticity clearly establishes the home at 81 Pepper Drive is actually a Sear’s, Roebuck & Company Kit Home.

To qualify under Criterion 1: (NRHP Criterion A) a property must be significant; that is, it must represent a significant part of the history, architecture, archeology, engineering, or culture of an area, and it must have the characteristics that make it a good representative of properties associated with that aspect of the past. It also must have an important association with the event or historic trends, and it must retain historic integrity.

In Page and Turnbull’s evaluation they state the following:

ʺThe current house and garage/cottage at 81 Pepper Drive was constructed during the time when most properties in Los Alto’s residential context, as per the Los Altos Historic Resource Inventory, were constructed, that is, in the 1920s and 1930s, which was reflective of the growth of the area after its earlier (1907) establishment. By this time, the central business district had been established, roadways were more complete and families, including the working class, could afford to relocate to the town. The extant property at 81 Pepper Drive, was constructed at the end of the 1920s, later than other Colonial Revival-style residential buildings in the general vicinity. Although associated with the general trend of growth in the 1920s, the property is not specifically important and thus does not convey significance for its association with that particular growth period (Event). Furthermore, research did not identify that the property contributed to any other significant events or other patterns of local, state, or national cultural heritage."
ISSUE OF CONCERN 1
There is significant evidence to support the notion that the home located at 81 Pepper Drive could be the only surviving example of a do-it-yourself (DIY) Kit Home that was widely sold through the Sears, Roebuck & Company catalogs between 1908 and 1942 in the City of Los Altos. The absence of any evidence of this possibility from the discussions of the home’s historic significance and value, unfairly restricts this property to meet the minimum threshold requirement under Criterion 1: (NRHP Criterion A).

It is important to note the remarkable similarity between this home and the “Gordon Modern House” featured by the Sears, Roebuck & Company (Figure 4). If this important information had been disclosed in either of the two historic resource evaluations then it would have left open the question that perhaps the home at 81 Pepper Drive could meet the eligibility requirements for being listed in the CRHR Criterion 1 (NRHP Criterion A) because of its association with early mail-order commerce and the early innovations in prefabrication of housing.

Since this information was not considered or presented for discussion in either historic evaluation below is a short history of the Sears, Roebuck & Company Kit House and how it offered an affordable option of the “American Dream" of homeownership to the Nations’ middle-class at the time.

SEARS, ROEBUCK, & COMPANY MODERN HOMES 1908 TO 1942
These small structures were usually modest and were designed to be affordable and not complicated to construct. Sears, in their advertisements at the time promised that the homeowner working even without a carpenter and only having rudimentary skills could build themselves a beautiful house for a reasonable price.

The Sears catalog homes were called “modern” because they included the latest in-home conveniences- central heating, indoor plumbing and electricity. Some also came with built-in

China cabinets, mirrored closets, dining room nooks, kitchen cupboards, built-in ironing board, telephone niches and medicine cabinets
The first catalog, titled, Book of Modern Homes and Buildings, appeared in 1908 and featured plans for twenty-two different houses ranging in price from $650 to $2,500. By the time the last catalog was published, 447 different home styles had been offered through the Modern Homes program. There were three lines of homes, at different price points eventually offered: Honor Bilt, featured cypress siding, cedar, and clear -grade flooring, Standard Built was advertised as the best for warmer climates, and the Simplex Sectional, were simpler designs that included summer cottages, outhouses, garages, and farm buildings.

Sears opened Modern Home sales offices so that customers would be able to meet with a Sears representative to select and order a home in 1930 there were forty-eight offices located throughout the country. By 1939, only nineteen sales offices were in operation.

Figure 1. Sears, Roebuck & Company catalogue advertisement for The Book of Modern Homes.

Figure 2. Sears, Roebuck & Company catalogue advertisement for the Gordon five or seven room and bath Cape Cod Revival home.

Figure 3. Photograph of the front primary exterior of the home located at 81 Pepper Drive home showing the enormous similarity between it and the Sears Gordon Kit House in the above Figure.

The railroad was fundamental to Sears, Roebuck and Company. Richard Sears initially saw the potential of using the railroad for transporting merchandise around the country when he was employed as a station agent and started his initial business venture selling surplus watches then later as the primary transportation for his massive mail-order empire. With the railroad-serving the factory warehouses established in Chicago and other cities, this enabled Sears to ship everything including their kit homes across the entire United States.

Figure 4. Bird’s eye view of the Sears sash and door manufacturing plant located at Norwood, Ohio.

Materials needed to build each home typically would arrive by railroad and then trucked to the building site. Sears could provide everything needed to construct the home, right down to the nails lumber, windows, door, flashings, roof material exterior siding, hardware, plumbing fixtures and the paint (Refer to Figure 5).

Figure 5. Illustration showing how the Sears Kit homes were shipped from the factory by railroad.

Since the Southern Pacific train service to Los Altos was established in 1908 it is easy to speculate the home arrived by boxcar probably to the main depot at Main Street then trucked a short distance to its building site to be constructed.

It is also quite plausible that the home was actually constructed by the original property owners. According to the archival information contained in both reports, George and Elizabeth Van Epps had moved from Montana to Palo Alto in 1902 with young Harry. Harry spent his late teens back in Hardin, Montana as a farmer. By the 1930 Federal Census, Harry was working in the Fremont Township (Los Altos) as a carpenter building houses, while his wife tutored students from their home; this which certainly aligns with the notion that the home had indeed been constructed by the original owners of the property.

The records also indicate that Harry and Grace Van Epps upon purchased the Pepper Drive property in 1928 began the construction of their family home in July 1929 and moved into the house in December of that same year. If this information is correct, having only six months to fully construct their home, could offer additional evidence that the home at 81 Pepper Drive indeed is a Sears Gordon Kit Home.

As a past member of the Los Altos Historical Commission, I recall there was a general consensus from the other members that historic importance of this property was not only that hit had been constructed just prior to the turbulent time of the Great Depression (1929 – 1939). The house also tells a very important story about the City's early development along with our Nation's history at a time of great economic and social upheaval. But the house also through its architecture, embodies the distinctive features and characteristics of a well-recognized architectural style commonly referred to as a Cape Cod Revival cottage—a variant and subtype of the Colonial Revival style, which was extremely popular between 1929 and 1940. There was also suspicion by the commission at the time of this listing, that this small home might be a doit- yourself kit home, but like most civic advisory boards and commissions there was no money available to hire the necessary outside consultants to confirm that speculation.

ISSUE OF CONCERN 2
The two existing Los Altos historic properties (1570 Covington and 1448 Fowler) used as comparable examples in the consultant reports neither aligned with the two referenced within their own historic resource evaluation of the property not do they represent an accurate depiction of the variant and subtype of the Colonial Revival style commonly referred to as Cape Cod Revival or Cape Cod Cottage to properly establish the architectural context of this property.

As a result, the historic significance has been unfairly diminished with respect to meeting the minimum threshold required to be listed individually in the California Register under Criterion 3: (NRHP Criterion A).

Page & Turnbull point out in their historic resource evaluation the following:
ʺA Field Guide to American Houses defines the one-story subtype of Colonial Revival or Cape Cod cottage as follows: One-Story Subtype – ...”one-story Colonial Revival houses are also common. These are generally Cape Cod

cottages, loosely patterned after early wooden Cape Cod folk houses of eastern Massachusetts, usually with the addition of Georgian or Federal inspired doorways. These were built throughout the Colonial Revival era but were particularly common in the 1940sʺ

This architectural stylistic distinction is extremely important in order to correctly apply the criteria necessary for the purposes of determining a historic resource’s eligibility for the California Register. Page & Turnbull also discuss the need for a comparative analysis by comparing works of the relevant and similar architectural style and same historic context. This comparison establishes the significance the resource, and provides a clear rationale to support findings, and is of great importance that the architectural period style is correctly identified before performing any analysis.

In addition, Page & Turnbull provided images of properties that exemplify excellent examples of the One-Story or Cape Cod cottage subtype, as shown in A Field Guide to American Houses, to visually explain the property’s architectural context missing from the DeShazo report.

Figure 5. Photograph taken from McAlester’s A Field Guide to American Houses to be provide a visual explanation of the Cape Cod cottage subtype.

After stating this importance, they reference two properties at (1448 Fowler Lane, and 1570 Kensington Circle) that are not comparable to the subject property. Although they do share similar architectural features and stylistic characteristics with the home at 81 Pepper Drive, because they are not homes constructed in the Cape Cod Revival or Cape Cod cottage tradition.

In short, the comparison is like is like apples with oranges. Yes, they are both fruit, but they come from two different types of trees.

To grasp a greater understanding of the importance between Colonial Revival and Cape Cod Revival or Cape Cod cottage, I have added a brief history of this once very popular architectural style below.

CAPE COD REVIVAL 1925 - 1955

The Cape Cod Revival style was one of the last house types of the American colonial era to be revived as a building form. Utilized exclusively for dwellings, the model for the style came from dwellings in Massachusetts and New York fishing villages. Built from 1700 to about 1850, many of the original Cape Cod dwellings were devoid of any architectural embellishments while others were often embellished with classical details. It is widely believed that the Cape Cod Revival-style house or sometimes referred to as Cape Cod cottage, were introduced during the Post Depression years and championed by Boston architect Royal Barry Wills (August 21, 1895 – January 10, 1962). Royal Barry Wills, was one of America’s most popular architects and considered the master of the Cape Cod-style house. From the 1920’s to the 1960’s. Wills designed 2,500 single-family residences, authored eight books about architecture, hosted a radio program, lectured widely, received awards, and supplied “Home Building Plans” for a number of newspapers and was a subject of a feature article in Life Magazine, The Saturday Evening Post, and Good Housekeeping.

Figure 6. Royal Barry Wills (August 21, 1895 – January 10, 1962) is considered the master of the Cape Cod Revival style home.

Evidence suggests the Cape Cod Reveal style began in the later 1920’s, and begun to appear in a variety of magazines and home builder catalogues. By the late 1930’s it was among the most popular of colonial revival styles. The design was featured in advertisements for a variety of home products and was often constructed as a model home for new housing developments.

The Portland Oregon based Western Pine Association’s model home at the 1939 San Francisco Golden Gate International Exposition. In the Pacific West most examples remaining date to the 1930’s. While the design was still published after WWII, by the mid 1950’s its use had nearly disappeared being replaced by the Ranch and other more modern house forms.

Figure 7. Front elevation drawing of one of the many Royal Barry Wills Cape Cod Revival designed homes.

Figure 8. Cover of American Builder 1936 featuring a Cape Cod Revival home.

THE TYPICAL COLONIAL CAPE COD FEATURES
• Simple symmetric design with some asymmetrical variations dated much later in the late 30’s and 40’s
• Small homes, usually 1,000–2,000 square feet in size often one-story or one-and-a half-story subtype
• Low, broad, single-story frame
• Moderately steep pitched gabled roof to minimized snow load • Local materials: i.e. cedar shingles and pine framing & flooring • Clapboard or shingle exterior, often unpainted to weather grey over time

• A typical early house had no dormers and little or no exterior ornamentation but later homes would include attic dormers along with second-story floors • Loosely patterned after early Cape Cod folk houses, often with simple Georgian and Federal-inspired doorways
• Central front door flanked by multi-paned windows
• Shutters on the windows to hold back heavy winds.
• Large central chimney that could often accommodate back-to-back fireplaces • Low ceilinged rooms to conserve heat
• The main bedroom was on the first floor,
• Often unfinished loft on the second floor with or without windows on the gable ends Figure 9. Cover of Houses for Homemakers on of the many house plan books authored by Royal Barry Wills.

If greater effort were made by both authors of the two historic evaluations to correctly identify the architectural style of the home, and if they included the only other comparable example of a Cape Cod Revival home remaining in Los Altos, their findings and their conclusions regarding 81 Pepper would be quite different. They missed the property located at 892 Carmel Street in Los Altos, commonly referred to as the Cyrus Berry House was constructed in 1930’s and is described "as Resembling a Cape Cod styleʺ (Figure 10).

Figure 10. The Cyrus Berry House located at 892 Carmel Avenue constructed in 1930’s and is described "as Resembling a Cape Cod”.

While the Carmel house resembles a Cape Cod, 81 Pepper Drive exemplifies one. Since little has changed to the exterior of the home located at 81 Pepper Drive over the 97 years to significantly diminish its overall historic integrity—which is a necessary criterion to convey the property’s historical significance, the only exception is construction work done without the necessary building permits by the current homeowner who also wishes to remove the home from the city’s HRI. Because the 1929 house embodies the distinctive characteristics of the Cape Cod Revival or Cape Cod cottage architectural style with no significant alterations to the building’s exterior or its setting, it has retained its historic integrity. Thus, making it eligible for listing on the CRHR under Criterion 3: (NRHP Criterion C), because the home embodies the distinctive characteristics of a design-type notably a Cape Cod Revival, or Cape Cod cottage.

1 Melissa Thurman
From: Bruce Beck <[email protected]>
Sent: Monday, January 26, 2026 8:36 AM
To: Public Comment
Subject: For City Council January 27, 2026 Item #9--Proposed delisting of 81 Pepper Street by Historical Commission
As the owner of a historical house in Los Altos, I was present in the audience at the Historical Commission meeting on October 27, 2025.

Delisting a historical house so that an owner can tear it down to suit their needs is a serious act. I was struck by the facts presented at the meeting by the owner that the house was a physical hardship on them, a health hazard, and there were difficulties they had discovered by living there. They presented another outside opinion that stated the house does not fulfill the requirements of being historic. A third "Peer Review" opinion was obtained by the City.

I was concerned by the following:
(1)There was no preparation of the Commission members with the original historic designation rationale and how to compare it with the recent alternative opinions, although there was excellent rebuttal given by members of the audience as to why this house was special architecturally. (2) One Commission member had excused herself earlier so the vote was initially split 2-2. No allowances were made.
(3 ) Staff did not provide the Commissioners with guidance as to what constitutes a proper way of analyzing whether a house should be delisted, and whether there were objective criteria for voting yea or nay. In shortt there was no educational prep for the Commissioners. (4) The Commissioners seemed to serve the opinion that they felt the City Council wanted to delist the house and did not want to offend said Council.

Living in and restoring/maintaining a historical house requires special fortitude and an appreciation of history of the area. The Historical Commission should serve as a resource opinion to the City Council, not vice versa. Maybe there is not a good match between house and owner here, but does the house need to get the short straw? We should be able to make better decisions.

Respectfully,
Bruce Beck

1 Melissa Thurman
From: History Los Altos <[email protected]>
Sent: Monday, January 26, 2026 3:08 PM
To: Public Comment
Subject: Public Comment: City Council Jan 27 Agenda Item #9 Removal of 81 Pepper Dr from HRO
Attachments: bressack letter.pdf; Response to 01 27 26 Staff Report.pdf; VanLaan_Historic_Architecture2.pdf; RGW Los Altos CC Letter.pdf; Van Epps News.pdf; sandoval response re architecture.pdf
Dear City Council,
The following additional information and six attached documents provide further documentation in support our appeal of the October 27, 2025 decision by the Los Altos Historical Commission to remove 81 Pepper Drive from the Los Altos Historic Resource Inventory (HRI).

These additional documents also respond to recent comments by Page & Turnbull in their response to the original appeal letter (Attachment #7).

Again, the matter before us: Unless the preponderance of evidence demonstrates that a property has lost integrity and/or historic significance, it is significant.

Some supporting excerpts that counter Page & Turnbull comments are below:

1. Richard Guy Wilson, Professor Emeritus Architectural History, University of Virginia, Author “The Colonial Revival Style”
“The Los Altos house which dates to 1929 shows how an East Coast style migrates across the country from the shores of the Atlantic Ocean in Massachusetts to the suburban area of San Francisco. It is an excellent example of the Cape Cod with its small size at one- and one-half stories, the steep pitched roof, the clapboard siding, dormers, and simple entrance features. The house has been very well preserved and has been duly recognized for its special and unique character.”

2. Mark Sandoval, Historic Architect, Los Altos Historical Commissioner 13 years:
“81 Pepper is considered a subtype and variant of the Colonial Revival style and should be treated as such. The comparable homes to establish the architectural context should therefore be similar to this subtype. Since McAlester defines these period homes as “Eclectic Houses 1880-1940”, and as a Cape Cod cottage as a subtype of the Colonial Revival style,

3. Krista Van Laan, Architectural Historian, CHRIS:
“Is the building representative of a type? (That is, does it have a preponderance of the characteristics of an identifiable architectural type?) The building should be a good representative example of the type and the period that is representative of the type…. A building has to be representative or have high artistic values.”

2 4. Phoebe Bressack, AIA Architect, former Los Altos Planning Commissioner:
“I believe the Los Altos Historical Commission analysis stopped short of digging into the complexity of the McAlester category ʺEclectic Houses 1880-1940. As a Cape Cod cottage subtype of the Colonial Revival style, it is architecturally inappropriate to compare it to the cited local examples (Fowler Lane and Kensington Circle) which are not Cape Cod cottage. In addition, as a west coast example of a style that migrated from the east, it is specious to expect a brick façade constructed by local craftsmen in our earthquake prone area.” We appreciate the additional work Page & Turnbull provided in their Peer Review of the original Evans & De Shazo HRE report. However, despite their assertions to the contrary, the firm did not provide sufficient information on the history of the local area. This deficiency of the DeShazo report, in fact, was identified by Page & Turnbull, but local historic context was not then developed by Page & Turnbull. The Halberstadt report provides local area history and subsequent conclusions as to its relevance to the importance of the house.

Further, Page & Turnbull, while disputing the importance of the Van Epps family, appears not to have done any additional biographical research on the Van Epps family to confirm or deny their conclusion.

Nor did they connect the dots to recognize that a family which included a master builder in Palo Alto and a carpenter/builder (per census) in Los Altos would have built the house at 81 Pepper Drive themselves.

Halberstadt provides detailed information about the Van Epps who built and first owned 81 Pepper Drive and their contributions to early Los Altos. In addition to being architecturally significant, the house is associated with a family important to local history (Criteria 2).

Additional biographical research on the Van Epps family uncovered key information including the following:
 Harry’s father George Van Epps was a builder in Palo Alto; he constructed two homes that are on the Palo Alto Historic Buildings Inventory.
 Harry was a contractor for over 50 years per his obituary; given the totality of facts, it is reasonable to conclude Harry Van Epps built the Pepper Drive house perhaps with the help of his father.  Numerous newspaper articles announced the start and the completion of the new Van Epps home on Pepper Drive. As there were no local building records at the time, it is typical to document who the builder was in unincorporated areas by newspaper report.  Harry and his wife sold their home on Hawthorne in September 1928 prior to their new home being built, and lived on the Pepper Drive property during construction.  Numerous newspaper articles about the Van Epps highlight their civic involvement in early Los Altos and association with noted early town “builders” including the Shoups and J Gilbert Smiths, their growing family and their travels. The Van Epps were a well-known, pioneering family in Los Altos.

We look forward to reviewing this material with you at the hearing scheduled for January 27th.

Thank you for your consideration.

3 Thomas Chapman, Jon Baer, and Maria Bautista

B R E S S A C K a n d W A S S E R M A N

A R C H I T E C T S

T W E N T Y O N E O S A G E A V E N U E
L O S A L T O S , C A L I F O R N I A 9 4 0 2 2
4 1 5 - 3 0 9 - 9 3 3 2 6 5 0 - 3 2 1 - 1 9 8 7
January 25, 2026
To: Los Altos City Council
Re: 81 Pepper Drive
I’m writing to support the appeal against the 2025 decision of the Los Altos Historical Commission to remove 81 Pepper Drive from the Los Altos Historic Resource Inventory (HRI).

Ours is a relatively young post-war town, with relatively few historic houses. That is why I feel strongly that any building’s proposed removal from the protected inventory must be reviewed with both great scrutiny and reticence.

When I look for historic guidance in my work as a residential architect for more than 40 years, I refer to the definitive published work: A Field Guide to American Houses by Virginia Savage McAlester
I believe the Los Altos Historical Commission analysis stopped short of digging into the complexity of the McAlester category ʺEclectic Houses 1880-1940. As a Cape Cod cottage subtype of the Colonial Revival style, it is architecturally inappropriate to compare it to the cited local examples (Fowler Lane and Kensington Circle) which are not Cape Cod cottage. In addition, as a west coast example of a style that migrated from the east, it is specious to expect a brick façade constructed by local craftsmen in our earthquake prone area.

This small, elegant structure has both the charm and integrity of Cape character. It is a house of historic significance in the early development of Los Altos, and as such would be a loss to the community if its removal from the HRI left it defenseless against future demolition.

As a longtime resident in Los Altos, I have seen with dismay several historic houses I thought to have been protected being demolished in recent years. I hope that this Council

will make the strong statement that we value our historic houses by supporting this appeal.

Respectfully yours,
Phoebe Goodman Bressack

Comments to the City Council Staff Report, Meeting January 27, 2026.

Environmental Impact
The Evans& DeShazo report states: “The proposed project consists of rehabilitating or demolishing the 1929 house and demolishing the ca.1933 detached garage allowing for the construction of a two-story addition or a new house.”
During the October 27, 2025, Historical Commission meeting the owner of 81 Pepper Drive James Parivsh alluded to new house plans saying he had already discussed plans with City Staff.

Hence, the project is not a ‘single action” under CEQA, and a foreseeable substantial adverse change to the environment is evident. A CEQA review is required.

Background
The National Park Service standards are for the purpose of the National Register of Historic Places. The Los Altos HRI and LAMC spell out the standards for local designation.

Analysis
The house at 55 Pepper Drive (1906) pre-dates the 1911 Adams Subdivision. The house at 236 Eleanor Drive (estimated 1914) is undergoing alteration. The historic house at 96 Hawthorne has been demolished. 81 Pepper is extant and intact.

The conclusion “In this case, Page & Turnbull finds 81 Pepper Drive does not represent an important example of architectural practices or trends in Los Altos, nor does it reflect a meaningful variation or evolution in construction type” is not the standard by which architectural historical significance is determined.

The 2008DPR523 Primary Record was not in the agenda packet. Attachment #2 was the 2011DPR523 Primary Record which served as an update to the original 2008 record.

Topanga doesn’t prevent an agency from stating findings in the language of an ordinance. The City had made findings of fact in order to designate the resource as historically significant which informs parties of the analytical path.

The house is a designated historic resource. Suggesting an evaluation of the “full criteria” is retroactively required for local listing simply is not true.

The OHP guidelines recommend inventories be updated over time, and that it is an established best practice to update or add information about historic resources on a periodic basis.

Citing the more recently adopted Historical Preservation Ordinance is not relevant to the matter at hand and only serves to confuse. LAMC 12.44 prevails here.

The eligibility for listing in the HRI is not at issue. 81 Pepper Drive is a designated historic resource. The issue is whether or not a preponderance of evidence demonstrates that 81 Pepper Drive has lost integrity and/or historical significance.

January 24, 2026
Hello, Maria,
You asked me about the criteria I use for determining the architectural significance of a building. I am listed with the California Historical Resources Information System (CHRIS) as an Architectural Historian, meeting the Secretary of the Interior’s Standards in architectural history. I have been working in the field since 2012.

Here are a few highlights about the process.

We often start by referring to A Field Guide to American Houses by Virginia Savage McAlester.

This book is used to determine a building’s style. It does not provide an assessment of what is a “better” or “worse” example of a particular building style.

If reviewing a building for significance, I apply the relevant city, state, or national criteria, all of which are based on the National Register criteria for evaluation: A) Event, B) Person, C) Design/Construction, D) Information Potential.

In many cases, I am assessing a building for only (C) architectural significance, so when doing so, I’m going to look for these things first:
• Is the building representative of a type? (That is, does it have a preponderance of the characteristics of an identifiable architectural type?) The building should be a good representative example of the type and the period that is representative of the type. • Does it possess integrity? That is, the exterior is little altered from its period of significance. If it is altered, are those alterations reversible or were they done more than fifty years ago and are themselves examples of an architectural era or period or do not distract from the primary characteristics of the style? In some cases, such as if the building is part of a historical district, it can be enough if the building retains the majority of the features that illustrate its style in terms of the massing, spatial relationships, proportion, pattern of windows and doors, texture of materials, and ornamentation.

If I am also evaluating a building for “high artistic values,” I’ll look further:
• Is it designed in such a way that it is especially pleasing architecturally? • Does it combine architectural elements and stylistic elements in an unusual or distinctive way?
Note that not all buildings need to have the high artistic values to be significant. A building has to be representative or have high artistic values. If a building is representative of a type but also has exceptional details, or a particularly unusual or distinctive feature, or is a particularly fine Krista Van Laan
Architectural Historian
494 Cypress Avenue
San Jose, CA 95117-1531
Tel. 408.476.2060
[email protected]

design of all of its elements, that qualifies it as both a representative example and of high artistic value.

I hope this helps.

Krista Van Laan

P. O. Box 400122
Charlottesville Virginia 22904-4122
January 25, 2026
Los Altos City Council
The house located at 81 Pepper Drive in Los Altos, California is an excellent example of the “Cape Cod Colonial Revival” that became popular in the 1910s and spread nationwide. The “Colonial Revival” was a broad scoped attempt to create an American architectural identity and has many styles/expressions under its umbrella. The Colonial Revival began in the midnineteenth century in New England an initially was employed in houses and buildings of the wealthy class. The various World’s Fairs held in the United States such as Philadelphia, 1876, and Chicago 1893 made it very, very popular. Over the years the scope of the Colonial Revival broadened and was used on houses and commercial buildings, and houses of all levels of wealth and social standing. As noted, the Colonial Revival has many different styles and expressions that can range from imitation Mount Vernons to buildings with large columns on the front, to smaller structures that recall more humble dwellings of the seventeenth and eighteenth centuries.

Los Altos contains a number of houses that come under the title “Colonial Revival” but are vastly different in appearance such as a Dutch-styled gambrel roofed on Fowler Lane, and then a side-gable roofed, two-story Colonial on Kensington Circle. These houses are Colonial Revival as is the Pepper Drive house. They show the broadness of the term: Colonial Revival, but each is a unique subtype of the style. The “Cape Code Style” was introduced in the 1910s and became very popular in the 1920s onwards with many books and articles.

As such, it is best practice to compare one Cape Cod to another Cape Cod when evaluating architectural merit.

The Los Altos house which dates to 1929 shows how an East Coast style migrates across the country from the shores of the Atlantic Ocean in Massachusetts to the suburban area of San Francisco. It is an excellent example of the Cape Cod with its small size at one- and one-half stories, the steep pitched roof, the clapboard siding, dormers, and simple entrance features. The house has been very well preserved and has been duly recognized for its special and unique character.

I have authored many articles, a book, and curated museum shows that have treated the Colonial Revival in America and where it fits into the broader

UNIVERSITY OF VIRGINIA
Architectural History Department

picture of architecture and American identity. I also might note that I am a native Californian, though of the Los Angles area, and also have done a lot of work on “modern” California architecture. The point, California contains many architectural expressions that range from East Coast inspired styles to the local Mission. The Cape Cod revival is a unique one that demonstrates the broad scope of California’s architectural expression. This house at 81 Pepper Drive must be preserved. It is very, very important.

Richard Guy Wilson
Commonwealth Professor Emeritus in Architectural History University of Virginia

Announcing September 1928 sale of their Hawthorne home

July 1929: VanEpps new
house to be built ”larger
scale and in colonial
style”
December 1929: move in
after “occupying
temporary quarters on the
property”

ABOUT MRS. HARRY VAN EPPS
Girl Scouts’ Captain
with Mrs J Gilbert Smith

Deaconess at Union Church
along with Mrs. Guy Shoup

Red Cross Captain in program set up by Guy Shoup

1 [email protected]
From: Mark Sandoval, AIA <[email protected]> Sent: Friday, January 23, 2026 10:56 AM
To: jonathan baer
Cc: Maria Bautista; [email protected]
Subject: Re: update
Attachments: cape cod house plan.docx
Hi Johnathan,
As I had explained the home is considered a subtype and variant of the Colonial Revival style and should be treated as such. The comparable homes to establish the architectural context should therefore be similar to this subtype. Since McAlister defines these period homes as ʺEclectic Houses 1880-1940", and as a Cape Cod cottage as a subtype of the Colonial Revival style, this is a strong argument. It also must be pointed out, these homes were often constructed by local carpenters hired by the property owner because they were simple to construct and affordable, as a result expensive decorative features such as elaborate entrance pediments were often not in the construction budget.

However, I did find this house plan (The Newcastle) that should address this argument (see attached).

Mark Sandoval, AIA
On 2026-01-23 09:44, jonathan baer wrote:

Mark-thanks again for your heroic effort in getting us your report in time for us to forward it, and the Halberstadt reports to city council. Your knowledge and expertise is recognized and much appreciated.

The city council packet came out and it include a section from page and turnbull as they were asked to comment on some of the points raised in our original appeal filing. As you may know, we had 15 days to file that appeal, so it was based on just guesses as to where the holes would be. And of course it lacked the research and expertise you brought to bear on the issue.

One point that they brought up that I think will be a sticking point with council. They claim that since the house is colonial revival it must be compared to any colonial revival home in los altos, even though as you know colonial revival is a category, which according to the mc Alester field guide covers a period from 1880 to 1955. They are also claiming that the lack of pediments, columns or pilasters which are part of the colonial revival style. The claim further is 81 pepper lacks the Georgian or federal inspired doorways typical of the cape cod subtype. And further they state the house has a non-original door set within a flat surround with sidelights only and a contemporary arbor trellis.

2 Is there anything you can provide us in terms of commentary on this point. Ideally it would be something we could forward on to council, but I don’t want to ask you for more than you are comfortable in providing. Please lmk as the hearing, as you may know, is Tuesday nite.

Many thx-j

(p&t; PAGE&TURNBULL

MEMORANDUM
DATE January 27, 2026 PROJECT
NUMBER
25162.01
Brittany Whitehill, AlCP, Senior
Planner
81 Pepper Drive, Los Altos TO PROJECT
City of Los Altos Jen Hembree, Cultural Resource
Planner, Page & Turnbull
Email

OF FROM
Christina Dikas Brobst, AlCP,
Principal
CC VIA
REGARDING Additional Documentation - Response Memorandum Page & Turnbull prepared this memorandum at the request of the City of Los Altos (City) in response to two professional opinion letters submitted by persons opposed to the delisting of the property at 81 Pepper Drive (APN 170-41-007) and its removal from the Los Altos Historic Resources Inventory (HRI).

The letters, prepared by MSA, Inc., dated January 21,2026 and Ms. April Halberstadt, undated, were provided to Page & Turnbull by City of Los Altos Planning staff two business days prior to the January 27, 2026 City Council Meeting, and therefore our response is brief.

The letters of opinion focus on different aspects of the property's history. The MSA, Inc. letter presents the possibility that the property at 81 Pepper Drive may be the only remaining Sears, Roebuck & Company Modern Home in Los Altos, that is, a ready-to-assemble (kit) house and specifically, a 'Gordon' model.’ The question of whether it is a mail-order house is a valid one to ask, but an explanation as to why this would make it individually historically significant is not fully explained. The letter states that mail-order homes made by Sears were available from 1908 until 1942, and although Sears is perhaps the most weil-known manufacturer, other companies such as Aiaddin, Lewis, Sterling, and Montgomery Ward, aiso sold mail-order homes during the early 20'*’ century, resulting in hundreds of thousands of such homes sold and easily assembled across the nation. The mere fact that a building may have been a mail-order home does not automatically ’ MSA, Inc, Letter to Members of Los Altos City Council, datedjanuary 21,2026, p. 7.

We imagine change in historic and contemporai7 environments to cultivate thriving, sustainable, and resilient communities. 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

Additional Documents Response Memorandum [25162.01]

equate to the building being an important example of the mail-order home pattern or trend that was prevalent across the nation for some 40 years.

It is true that the Sears' Gordon kit home model, an image of which is provided in the MSA, Inc. letter, depicts a Cape Cod Revival design and that it has some similarities to the property at 81 Pepper Drive. However, the chimney location differs, as do some of the secondary facade window opening locations, in addition to the fact that the property at 81 Pepper Drive lacks the more elaborate front entry; decorative pilasters are depicted on either side of the front door of the Gordon model.^ Although no citation is included, the MSA Inc. letter indicates that Cape Cod Revival cottages were "loosely patterned after early Cape Cod folk houses, often with simple Georgian and Federal-inspired doorways [emphasis added]."^ As Page & Turnbull has stated previously, the property at 81 Pepper Drive lacks a decorative front entry typical of Colonial Revival and Cape Cod Revival styles.

The Halberstadt letter, in contrast, focuses mainly on the biographical information of the original owners, the Van Eppses, as well as the early historical development of Los Altos. Page & Turnbull would clarify that in our Peer Review we did suggest that the existing detached garage/cottage was the structure serving as the Van Epps' temporary residence during construction of the primary house. We also stated in the Peer Review that given his trade as a carpenter, there is the possibility that Van Epps constructed the house in 1929 and/or the garage/cottage in ca. 1929 at 81 Pepper Drive; yet, no documentary evidence, such as architectural drawings, permit record, or other archival documentation was found to confirm that Van Epps performed this construction work himself. The 1929 news article referenced indicates that "Mr. and Mrs. Henry Van Epps...completed" their home. Page & Turnbull finds it is best practice to not make assumptions without archival/documentary backup. National Register guidance states that a property cannot be eligible if associations are speculative. No additional examples of houses built by Van Epps are described in the Halberstadt letter to support an assertion that Van Epps was indeed an important builder of homes in the community or that he built (rather than assembled) his own home.

The Halberstadt letter indicates, "There is also a special place in the history of a house for the first owner, especially when the structure is a custom-built home, an assembled kit home, as suggested in the MSA, Inc., letter. The additional information about the Van Epps family ancestry and any deed restrictions they may have been operating under when they purchased the property adds to their biographical record. However, owners who potentially custom- "A A custom-built home is in contrast to
^ hupsy/www.flickr.com/photos/daily bun£alow/1527279Z69.7 ^ MSA, Inc, Letter to Members of Los Altos City Council, dated January 21, 2026, p. 13.

April A. Halberstadt Letter to Maria Bautista, Thomas Chapman, John Baer, undated, p. 11.

PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

Additional Documents Response Memorandum [25162.01]

built their residence or potentially assembled a kit home for personal use, or who were living in a community during a particular period of development and participated in social and/or religious groups, are not automatically considered important persons within that community.

As Halberstadt states, the "modest 'starter home' at 81 Pepper Drive "captures our attention because of its very traditional, American-colonial style" which was "very unusual" for the area yet "nationally popular."^ Modesty of a property in and of itself does not preclude that a particular property might be significant. However, for potential resources that are modest, common, or vernacular, such as the home at 81 Pepper Drive, the question must be answered regarding what makes one such home significant. Although 81 Pepper Drive is an example of Cape Cod Revival cottage architectural style that is uncommon in Los Altos, as noted in Halberstadt's letter, rarity in and of itself is not a determining factor for significance. Generally, rarity would be a factor in instances where a significant property type was once common historically across a particular area but is now scarce. That scenario does not appear to be the case in this instance.

Furthermore, neither letter specifically addresses the criteria of the Los Altos Historic Resources Inventory. Both letters discuss California Register criteria, when the issue at hand is removal of the property from the local register.

Page & Turnbull, as a qualified historic preservation architecture and planning firm, provides peer reviews and historic assessments using consistent means and methods to be as objective as possible while taking into consideration local historic context and local historic inventory criteria.

The aesthetics of a property or potential future projects are not considered.

We provided a Peer Review Memorandum at the request of the City to address the technical adequacy of the 2025 Historic Resource Evaluation Report by Evans & de Shazo, Inc. and included additional information as needed for the City to make a determination regarding the property's significance and eligibility. The City has subsequently received additional memorandums from Page & Turnbull as well as letters of opinion by others. Professional opinions may differ, and therefore it is ultimately the jurisdictional authorities who must make the final determination. ^ April A. Halberstadt Letter to Maria Bautista, Thomas Chapman, John Baer, undated, p. 9.

PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

PAGE&TURNBULL P&T

MEMORANDUM
PROJECT 25162.01
NUMBER
PROJECT 81 Pepper Drive, Los Altos
DATE December 24, 2025
Brittany Whitehill, AlCP, Senior
Planner
TO
Stacy Kozakavich, Project Manager,
Page & Turnbull; and
Jen Hembree, Cultural Resource
Planner, Page & Turnbull
Email
City of Los Altos OF FROM
Christina Dikas Brobst, AlCP,
Principal
CC VIA
REGARDING Appeal Response Memorandum
Introduction

to an appeal of the Los Altos Historical Commission's October 27,2025 decision to remove the property at 81 Pepper Drive (APN 170-41-007) from the Los Altos Historic Resources Inventory (HRI).

Historic Resource Evaluation prepared in 2025 by Evans & DeShazo, Inc. (2025 HRE), which found that the property was ineligible for listing at the state or local level, and recommended its removal from the HRI. Our Peer Review Memorandum, dated June 16, 2025, concurred with this overall finding. The City has requested our comment on portions of the Appeal, filed on November 7, 2025 ("Appeal"), which are related to the eligibility of the property for listing at the local level. At the request of the City, we have also provided a written response to an email sent to Page & Turnbull by one of the appellants on November 18, 2025.

Response to Appeal
The following paragraphs provide Page & Turnbull's response to relevant statements made in the November 27, 2025 Appeal, grouped by theme or topic.

We imagine change in historic and contemporary environments to cultivate thriving, sustainable, and resilient communities. 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

Appeal Response Memorandum [25162.01]

Scope of Services
The Appeal states that City "Staff defined the Page & Turnbull report as both a peer review and a Historic Resource Evaluation (HRE) or designation assessment. The report, however, is oniy a peer review." The Appeal goes on to state that, "Without a complete HRE and a separate action by the Historical Commission to determine whether a property is eligible for listing," Page & Turnbull cannot make conclusions about the eligibility of the property.

Page & Turnbull acknowledges that the scope of services performed for the City is defined as a Peer Review Memorandum. A Peer Review Memorandum, in this instance, is intended to address the technical adequacy of an eligibility evaluation and, if necessary, to provide additional information needed by the City in making a determination regarding a property's significance. The scope of services agreed upon with the City specified that Page & Turnbull include independent analysis regarding the property's eligibility. The executed agreement between the City and Page & Turnbull established that the scope of services to be performed would consist of, "Peer review of previous reports and independent analysis [emphasis added] to determine whether the property located at 81 Pepper Drive meets the criteria for local listing on the HRI (Los Altos Municipal Code Chapter 12.44). [And] Services will include, but not be limited to, the items noted in the scope of work attached hereto and incorporated herein as Exhibit A."’ The referenced Exhibit A reiterates that Page & Turnbull would prepare a Peer Review Memorandum which would include our "professional opinion regarding eligibility."^ As such, to complete the Peer Review Memorandum as outlined in our scope of services, Page & Turnbull performed additional archival research to fill gaps in the historic context presented by previous documentation and provided our professional opinion regarding the property's eligibility for listing in the Los Altos Register of Historic Resources. As noted in the Peer Review Memorandum, "[w]ith the combined contents of previous evaluations and Page & Turnbull's additional research and field survey," the City had been provided with sufficient information and analysis to make a determination regarding the propert/s eligibility for continued listing on the HRI.

Eligibility Evaluations
The Appeal states that, "The standard for removal of an HRI listing is 'loss of integrity and/or historic significance,' not a reassessment of prior recognized importance that determined the HRI listing. The presumption is that the property has been and is historically significant, being treated officially as such since 2008."
Page & Turnbull acknowledges that according to Los Altos Municipal Code 12.44.090 - Termination of designation, 'The only legitimate reason for terminating the designation of a historic resource or ' Professional Services Agreement between City of Los Altos and Page & Turnbull, executed on May 13, 2025. ^ Exhibit A, Professional Services Agreement between City of Los Altos and Page & Turnbull, executed on May 13, 2025.

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historic landmark is when clear evidence is presented that shows the resource no longer meets the criteria of Section 12.44 .040 due to loss of integrity and/or historic significance." However, historic preservation inventories are always works in progress.

Per the California Office Historic Preservation's Instructions for Recording Historic Resources.

As a planning tool, it is important that information about historical resources is regularly updated to ensure its accuracy. Updates may amplify or correct information about a resource, or simply confirm that the existing record remains accurate at the time of a subsequent field examination. The documentation for a historical resource should be updated under the following conditions: When it is reevaluated; When changes occur to the resource or its setting; When erroneous information needs correcting; and/or When additional information is necessary for planning decisions.^
The California Office of Historic Preservation Technical Bulletin 8 in its discussion of California Historic Resource Status Codes, which are typically included on DPR 523 forms, furthers that users of the California Historic Resource Status Codes,
should keep in mind that the status codes are broad indicators which, in most cases, serve as a starting place for further consideration and evaluations. Because the assigned status code reflects an opinion or action taken at a specific point in time, the assigned status code may not accurately reflect the resource's eligibility for the National Register, California Register, or local listing or designation at some later time.'*
Page & Turnbull cannot comment on City' specific policies for updating or adding information to documentation of existing Los Altos historic resources or historic landmarks. However, it is an established best practice to update or add information about historic resources on a periodic basis.

While in some cases a property previously found ineligible for designation may later be found eligible by evaluators, in other cases a property which is found eligible may later, with further consideration of its context and merits, be found ineligible for designation. This reconsideration may find that in the period between evaluations a property has been altered to the degree that it can no ^ Office of Historic Preservation, "Instructions for Recording Historic Resources," March, 1995, p. 23 electronic resource at:
https://ohp.p.arks,ca.gov/pages/i,Q54/fiiei/!‘nanual95.pdf. ** Office of Historic Preservation, 'Technical Assistance Bulletin 8 - User’s Guide to the California Historical Resource Status Codes & Historic Resources Inventory Directory," November, 2004, p. 5 electronic resource at:
.■ca.gQv/pages/1069/files/tab8.pdf.

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longer convey its significance. This situation would meet the Los Altos Municipal Code condition that designation may be terminated in response to a “loss of integrity." The Municipal Code also provides the possibility of termination of designation due to loss of "historic significance." Significance is an inherent characteristic; a property has significance or it does not, and an original architectural design or an established association with a historic event cannot be "lost." This phrase in Los Altos' Municipal Code must therefore be interpreted to mean that, due to research and evaluation subsequent to the initial finding of significance, the preponderance of evidence demonstrates that a resource is not historically significant or eligible for listing.

Local Significance Evaluation
The Appeal states that the 2025 HRE and the Page & Turnbull Peer Review Memorandum analyses lack discussion of the property in relation to the Los Altos Historic Resource Inventory Section II titled, "Los Altos: The Influence of Transportation on Growth and Development and in the National Register Bulletin (National Park Service, Department of Interior)," and states that the property reflects early ’"railroad suburban' development in the inter-war/Great Depression period when a growing middle class sought homes that symbolized stability, simplicity and tradition." The Los Altos Historic Resource Inventory Section II titled, "Los Altos: The Influence of Transportation on Growth and Development ("Section U") describes the establishment and growth of the area now incorporated as the city of Los Altos and indicates that both the establishment of a railroad and subsequent mass production of the automobile contributed to the town's growth. In particular, Section II states that the Los Altos Train Station is a "symbol of the town's very existence."^ Section II illustrates that, as occurred in many other towns and cities in the United States during the late 19'^ and early centuries, a transportation official privately purchased large tracts of undeveloped land and then subdivided the land after the development of a transit line. In Los Altos, Southern Pacific railroad president, Paul Shoup (and his brother) bought a right-of-way from Palo Alto through Los Altos to run a connecting line through Los Gatos and points south. In 1907, his Altos Land Company as well as the University Land Company were incorporated. Both companies had as their objective the layout and subsequent sale of lots In what would be named the town of Los Altos. The train depot was initiallya boxcar along the tracks, until 1913, when the Architectural Bureau of Southern Pacific completed a permanent depot at 288 1 Street. Once regular passenger rail service to the town was initiated in 1908, the land companies were able to attract more residents for purposes of establishing homes.^
^ The City of Los Altos and Circa: Historic Property Development. The City of Los Altos Historic Resources Inventory (Los Altos, October 2012), Section II - pp. 11 -11.
^ The City of Los Altos Historic Resources Inventory, Section II - pp. li-14 - 11-15- PAGE &TURNBULL 170MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA94108 TEL 415-362-5154

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Page & Turnbull observes that the residence at 81 Pepper Drive was constructed in relative geographic proximity to the Los Altos rail station (approximately 0.3 miles as determined by Google Maps). However, its construction occurred in the year 1929, over two decades or 22 years after the establishment of a rail station in Los Altos. The construction of the residence therefore does not appear to be directly associated with the establishment of a rail line, passenger rail service or general rail transportation in Los Altos. In fact, its construction date occurred as passenger rail service was falling out of both national and local favor. According to Section II, less than a decade after the residence's construction, in 1935, the interurban Peninsular Railway disincorporated.^ The Peninsular Railway was the electrified rail passenger service or suburban streetcar service formally incorporated in 1909 and available between San Jose and Palo Alto including a stop at the Los Altos rail station. Earlier in 1930, in fact the Peninsular Railway had already eliminated through-service to Palo Alto north of Mayfield (present-day California Street area in Palo Alto); in 1933, the company made plans to substitute buses for the streetcars on all interurban routes and in 1934 it ceased the Mayfield line entirely.® The house constructed at 81 Pepper Drive in Los Altos in 1929 thus does not appear to be associated with streetcar suburban development in Los Altos.

The residence at 81 Pepper Drive therefore does not appear to reflect "early 'railroad suburban' development in the inter-war/Great Depression period." In Page & Turnbull's understanding of the history of Los Altos outlined in Los Altos Historic Resource Inventory Section II, the early railroad suburban era in Los Altos is more appropriately described as the initial years following the establishment of the rail service and depot in the town, that is 1907/08 until about 1920. According to the Section II, "The 1920s saw the growth of the automobile suburb."^ The subject property's association with the growth of automobile use in Los Altos is discussed below.

Page & Turnbull notes that Section II indicates that, per Eastman's "History of Los Altos" (in author, Joe Salameda's 1981 publication, "Memories of Los Altos"), Los Altos had -by July of 1911-"boasted some fifty houses..." These earlier houses, those built in the first decade of the 20'*^ century, would therefore be more likely associated with the early railroad development of the town and likely better representatives of that era. Examples include:
● J. Gilbert Smith House (now the Los Altos History Museum) at 51 S San Antonio Road, half a mile from the rail station. This Craftsman-style farmhouse was constructed between 1901 - 1905 and is a Los Altos Landmark.
' The City of Los Altos Historic Resources Inventory, Section II - pp. 11-17. ^Charles S. McCaleb. Tracks, Tires, and Wires. (Glendale, California; Interurban Press, 1981), pp. 95-97. ’ The City of Los Altos Historic Resources Inventory, Section II - pp. 11-17.

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Appeal Response Memorandum [25162.01]

● The residence at 42 Los Altos Avenue, 0.4 miles north of the rail station, was constructed in 1910. 10
The Appeal states that "81 Pepper Drive is the first house built in the first near-town subdivision of Los Altos."
As outlined in the 2025 HRE, the property addressed at 81 Pepper Drive is located within what was initially M.O. Wight's 20-acre property within what was initially the LS. Clark Subdivision. The land was subsequently subdivided further and became part of the Adams Subdivision. A 1926 map of the Adams Subdivision indicates It spanned approximately between San Antonio Road at the west to Eleanor Avenue at the east and between the south side of Hawthorne Avenue at the north southward through the south side of Marvin Avenue. Several residences predate the property at 81 Pepper Drive and were constructed within these bounds prior to 1929. Examples Include (but are not limited to):
■ The residence located at 55 Pepper Drive was constructed in 1906, a few parcels west of today's 81 Pepper Drive. Known as the Adam House, it is designated Los Altos Landmark. ● The residence located at 236 Eleanor Drive was constructed in 1919, northeast of today's 81 Pepper Drive. Known as the Morris House, it is listed in the Los Altos Historic Resource Inventory.
● The residence at 96 Hawthorne Avenue located directly north of today's 81 Pepper Drive was constructed in 1920.
11 Other properties located outside of the bounds of the Adams Subdivision, but in proximity to 81 Pepper Drive and constructed prior to 1929 include:

The residence at 41 Hawthorne Avenue, constructed in 1925 and in the Los Altos Historic Resource Inventory.

The residence at 109 Hawthorne Avenue, constructed in 1920 and in the Los Altos Historic Resource Inventory.

The residence at 151 Hawthorne Avenue, constructed in 1920 and in the Los Altos Historic Resource Inventory.

State of California Office of Historic Preservation Built Environment Resources Directory for Santa Clara County, September 23, 2022, electronic resource at; https://ohp.parks,ca.gov/pages /1068/files/Santa%20Gara,csv ” Circa: Historic Property Development. DPR 523 Primary Record for 236 Eleanor Avenue, 2011, electronic resource at:
hctps://mccmeeungspubJic.blob,core.usgovcloudapi.net/lo5allosca: mee.t:56429aeOef5a49612f7761b53clc3.4e06ZlTEJVl.- Attachment-001-06bf557386ae4cafbb962e02efaccc7b.pdf. Note that online market listings indicate the property was 10 constructed slightly earlier in 1914.

PAGE&TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

Appeal Response Memorandum [25162.01]

● The residence at 165 Hawthorne Avenue, constructed in 1925^^ The residence at 81 Pepper Drive therefore does not appear to have been the first house built in the first near-town subdivision of Los Altos. Early examples dating from five to twenty years prior to the construction of 81 Pepper Drive exist not only within the Adams Subdivision, but also within the general vicinity, some of which are locally designated landmarks or on the historic resource inventory.

The Appeal states that 81 Pepper Drive's "small, rectangular lot and the burgeoning automobile era favored a 1 1/2 story structure with a side-yard detached garage; 81 Pepper Drive is the only era-specific Colonial Revival with an original detached garage in Los Altos. With most original details intact, the house perfectly represents the small-town ideal of 1920-40, especially with respect to transportation trends."
Page & Turnbull acknowledges that the primary residence is a Colonial Revival "Cape Cod cottage" subtype. Page & Turnbull also acknowledges that National Register Bulletin 46: Historic Residential Suburbs, which is referred to by the appellants in the Appeal and November 18 email, recognizes the impact of automobile travel on suburban development and pays particular attention to the introduction and proliferation of garages.’^ As further noted in the Bulletin 46. "[s]helter for the automobile became an increasingly important consideration after 1900.' 14 The presence of a detached garage, although generally associated with the national historic trend of providing detached garages as part of residential construction, does not appear to be an important or sole determinant of a propert/s historic significance, regardless of the architectural style of the associated dwelling itself. The garage became important beginning as early as the year 1900 per the National Register Bulletin 46. Locally, detached garages appear within the 1926 Sanborn Fire Insurance Maps for Los Altos (the earliest date Sanborn maps are available). Indicated by the letter 'A' (for automobile) on these Sanborn Maps, a review of the 1926 Los Altos Sheet No. 2 shows that at least four dwellings on Third Street between Main and Edith streets featured detached garages set back towards the rear of their properties. At least eleven dwellings along Orange and University avenues also featured detached garages at their rears as evidenced by the 1926 Los Altos Sheet No.

4. Dates of construction provided in California Office of Historic Preservation Built Environment Resource Directory for Santa Clara County.

Best Practices Review: Oarages and Outbuildings, dated January 2023 electronic resource at:
htiA5:ZMwja.nps.gDyZsubis.cts/natiODalregisteryupioad/BPR_garage s.-.and-Q.utbuildii:igS:2Q2201-06,pdf.

Notional Register Bulletin 46: Historic Residential Suburbs, p. 56 electronic resource at; j_Suburbs_part1_508.p,df.

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Further, the Peer Review Memorandum clarified that the existing detached garage dates to ca. 1929 and the house dates definitively to 1929. This clarification is based on a 1929 newspaper article that describes the original owners/occupants (the Van Epps) as “occupying temporary quarters on the property," while their new home was under construction.’^ Initially, therefore, the ancillary building on the property appears to have functioned as a cottage and was likely subsequently converted for use as a garage.

Regardless of Its Initial intended function, as stated in National Register Bulletin 15, "mere association with historic events or trends is not enough, in itself to qualify under [National Register] Criterion A:
the property's specific association must be considered important as well [to the trend]."’^ The evolution of the automobile which necessitated the construction and prevalence of detached garages was already well-established and not uncommon in Los Altos prior to the construction of 81 Pepper Drive in 1929. The presence of a garage at 81 Pepper Drive is not a specific and important association with the nationwide trend of increasing automobile use in Los Altos, California, or the United States.

The Appeal states that, "At the time, the 'Homebuilder' becomes a profession with the likes of original homeowner Harry VanEpps."
According to the 1930 federal census. Van Epps was a carpenter in the “house building" industry. No documentary evidence was found to verify whether Van Epps constructed the primary residence at 81 Pepper Drive. Moreover, the profession of a property owner, such as Harry VanEpps' profession of carpenter does not immediately elevate a property to a level of significance necessary for listing in a local, state or federal register. National Register Criterion B: Person (equivalent to State Criterion 2) indicates a property may be eligible if it is associated with the lives of persons significant in our past.

However, according to the National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. "A property is not eligible if its only justification for significance is that it was owned or used by a person who is a member of an identifiable profession, class, or ethnic group. It must be shown that the person gained importance within his or her profession or group."’^ Research did not identify that Van Epps gained importance within his carpentry / house-building profession in Los Altos or elsewhere. Research did not identify that any family member having an association with the The Peninsula Times Tribune, 'To Occupy New Home,"July 15,1929.

National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 12. electronic resource at https://www.nps.gQv/iu.bjea5/nationalregister/upload/NRB-15_web5 08.pdf. '' National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 15. electronic resource at https://www.i 15_web5Q8.pdf.

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occupancy or ownership of 81 Pepper Drive was significant to the history of Los Altos, the state, or nation.

The Appeal states that, ‘With a symmetrical facade, detached garage and proximity to town and the train station, 81 Pepper Drive is tied to national patterns of residential architecture and provides a prime and unique example of the Los Altos' transition from agricultural lands to middle class suburban neighborhoods."
As noted above, per National Register Bulletin 15, "mere association with historic events or trends is not enough, in and of itself, to qualify under Criterion A: the property's specific association must be considered important as well [to the event or trend]."’® A property's importance to (not just representation of) the trend or pattern therefore must be clearly evident. For example, although the property at 81 Pepper Drives appears to have been generally associated with the national trend of providing detached garages at dwellings during the rise of the automobile as the preferred transportation method in the early 20''" century, the associated detached garage at 81 Pepper Drive appears to have initially functioned as a cottage, and furthermore, was constructed in 1929, near the end of the 1920s decade of growth of the automobile suburb as per Section II. Similarly, the transition from agricultural land to residential neighborhoods was a nationwide trend during the early decades of the twentieth century during which 81 Pepper Drive was constructed. However, the property is one of many examples of residential properties built in the Bay Area, California, and Nationwide during this time. Research has not provided evidence that the property was individually important to the initiation and spread of this trend in Los Altos. Other residences within what became the Adams Subdivision predate the property. Other residences outside of the bounds of the Adams Subdivision, but in proximity to 81 Pepper Drive predate the property. Other dwellings within the vicinity of downtown included detached garages prior to or by 1926 as per Sanborn maps. The property therefore does not appear to be a prime, unique, or influential example of the Los Altos transition from agricultural lands to middle class suburban neighborhoods.

The Appeal states that the primary residence, a “high integrity Colonial Revival ‘Cape Cod' subtype aka ‘Colonial Bungalow' of 1920s Los Altos" was designed in a style that “parallels popular Tudor, Dutch and Spanish Colonials, but speaks to a desire for a more American vernacular free from Victorian ornamentation," and that “Modest architectural structures are never automatically insignificant because of their modesty; both professional reports rely on deficiencies in grandeur.

In fact, 81 Pepper Drive is significant because of its modesty." National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 12, electronic resource at :tps://www.nps.gov/subjGcts/noiiona!register/upload/NRB-15 web508.pdf.

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When evaluating a property for eligibility for national, state or local designation under criteria related to type, period, or method of construction -- that is, architecture, it is best practice to utilize an objective methodology. First, a particular type or style must be demonstrably important within its historic context. Simply stated, as much as grandeur is not a requirement for a residential property to be found historically significant, so too integrity alone as an example of a common style or type is not sufficient for a property to rise to the level of significance required for designation. That style or type must itself be significant within the context of a property's location and period of construction.

Then, the essential physical features - the character-defining features - that enable the property to convey Its historic identity related to type, period, or method of construction must be evident. These distinctive character-defining features are the physical traits that commonly recur in property types and/or architectural styles. To be considered an excellent example and eligible under the criteria related to Architecture, a property must clearly contain enough of these characteristics to be considered a true representative of a particular type, period, or method of construction, and these features must also retain a sufficient degree of integrity. Evidencing the essential or character defining features ensures that properties are evaluated objectively for their architecture.

Architectural historian's Virginia McAlester's A Field Guide to American Houses, most recently updated in 2023, is considered the definitive guide to residential architecture in America. A Field Guide to American Houses presents a list of character-defining physical features that must be present for a building to be a true representative of and significant as a particular architectural style. As outlined in McAlester's guide and in the 2025 HRE, the character-defining features of the Colonial Revival architectural style are:

1. "Symmetry In facade - although 10% of Colonial Revival were asymmetrical.

2. Hipped or gabled roofs with boxed eaves.

3. Fanlights and/or sidelights around main door.

4. Double-hung sash windows, often set in pairs.

5. Clapboard and brick exterior cladding.

6. Classical detailing (sometimes exaggerated), including pediments, columns or pilasters leading to elaborate entries.'
As further stated in A Field Guide to American Houses, the One-Story Subtype or 'Cape Cod cottage,' which the property at 81 Pepper Drive most closely resembles, "are loosely patterned after early wooden Cape Cod folk houses of eastern Massachusetts, usually with the addition of Georgian or Federal-inspired doorways [emphasis added]. These were built throughout the Colonial Revival era 19 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023).

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20 but were particularly common in the 1940s...' [and] "The Cape Cod is the most common form of one-story Colonial Revival house. As a form, it originated in the early 18th century and continued ■21 with few changes through the 1950s.'
The property at 81 Pepper Drive lacks the pediments, columns or pilasters leading to elaborate entries of the overarching Colonial Revival style and thus, also lacks the usually added Georgian or Federal-inspired doorways typical of the Cape Cod cottage subtype. The extant residence instead has a non-original door set within a flat surround with sidelights only and a contemporary arbor trellis.

Further, as instructed by the California Office of Historic Preservation when recording historical resources, it is also important to "compare the resource with others that belong to the same property type and relate to the same historic context" because "it will help establish the significance of the resource," or will help provide a clear rationale to support an ineligible finding.The Los Altos Landmark properties at 1448 Fowler Lane and 1570 Kensington Circle both predate the property at 81 Pepper Drive and both fully express the Colonial Revival style, inclusive of elaborate entries. The property at 81 Pepper Drive is not the best extant early-20'^ century example of the Colonial Revival style in Los Altos. Other, better examples are extant and designated landmarks.

Modesty of a property in and of itself does not preclude that a particular property might be significant as an example of a style or type. Nonetheless, for potential resources that are common or vernacular, such as the Cape Cod cottage subtype and the property at 81 Pepper Drive, the question of what makes one Cape Cod Cottage, or the property at 81 Pepper Drive among many examples of Cape Cod cottages, significant, must be answered.^^ National Register guidance indicates that for a common or vernacular property to be eligible as a specimen of its type or period of construction, "it must be an important example (within its context) of building practices of a particular time in history." The property at 81 Pepper Drive does not appear to be an important example of a modest or vernacular Cape Cod cottage during the early 20'^ century or 1920s in Los Altos.

National Register guidance also states that, that "for properties that represent the variation, evolution, or transition of construction types, it must be demonstrated that the variation, etc., was an important phase of the architectural development of the area or community in that it had an Virginia Savage McAlester, A f/eW Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 412.

Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 427. https://ohp.parks.ca.gOv/pages/1054/files/iTianual95.pdf.

National Register of Historic Places, "Best Practices Review: Evaluating Common Resources," dated July 2023, electronic ,QZ-27:REV.pdf.
20 22
resource at: https://www.nps.gov/subjects/natiQnalregi5ter/uploa d/BPR_CQinrn.on-j PAGE&TURNBULL 170 MAIDEN LANE. 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

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impact as evidenced by later buildings.''^'^ The property at 81 Pepper Drive does not appear to represent a variation or evolution or transition of construction types in Los Altos that resulted in a new phase of architectural development in the area.

Response to Email, dated November 18, 2025
On November 17, 2025, one of the signatories to the Appeal spoke with Page & Turnbull staff regarding the Peer Review Memorandum. The phone call was followed by an email from the signatory to Page & Turnbull Principal, Christina Dikas Brobst and dated November 18, 2025. Page & Turnbull provides the following clarifications in response to the email.

The email states that the previous conversation communicated "an assumption!...] that a Peer Review has a lesser standard of thoroughness than a full HRE." In Page & Turnbull's practice, a peer review does not have a lesser standard of thoroughness than a full Historic Resource Evaluation. As stated above, while preparing the Peer Review Memorandum, Page & Turnbull performed additional archival research, as necessary, to fill gaps in the historic context presented by previous documentation and, for example, was able to clarify certain dates of construction. However, a peer review need not be redundant, or repeat accurate information or relevant context already provided for the same property in a previous document. With the combined contents of previous evaluations and Page & Turnbull's additional research and field survey. Page & Turnbull recommended that the 2025 Historic Resource Evaluation need not be revised.

The email states that Page & Turnbull's "method of evaluation was only "in the context of the state of California" and not within the context of local history.

This appears to be a misunderstanding of the word "context" in that particular statement. To our recollection, the context referred to in this part of the conversation was the breadth of comparative experience from which Page & Turnbull's architectural historians approach an evaluation, whether for significance at the national, state, or local level. Page & Turnbull was established in 1973 as Charles Hall Page & Associates to provide architectural and conservation services for historic buildings, resources, and civic areas within cites and towns across the state. The company was one of the first architecture firms in California to dedicate its practice to historic preservation and is among the longest practicing such firms in the country. Offices are located in San Francisco, San Jose, Los Angeles, and Sacramento, and staff includes planners, architectural historians, licensed National Register of Historic Places, "Best Practices Review: Evaluating Common Resources," dated July 2023, electronic i4tionalregisier/upload/BPRj:Qmmon-re5Ources--2Q23-07-27:REV.|idf. 24 resource at: hUpsiZ/yvww.nps,,
PAGE&TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO. CALIFORNIA 94108 TEL 415-362-5154

Appeal Response Memorandum [25162.01]

architects, designers, and conservators. All of Page & Turnbull's professional staff members meet or exceed the Secretary of the Interior's Professional Qualifications Standards as published in the Code of Federal Regulations, 36 CFR Part 61. The number of evaluations of age-eligible buildings within the firm's body of knowledge is extensive and serves as a valuable resource to staff, as do leadership and fellow staff, allowing Page & Turnbull to evaluate properties as objectively as possible and within their appropriate historic contexts.

The email states that Page & Turnbull's peer review memorandum "is absent recognition of Los Altos HR! Historic Contexts and of regional, state and national trends in architecture that are clearly spelled out in National Register data on Historic Residential Suburbs. The report also does not provide context for 81 Pepper Drive's relevance to the entirety of the Los Altos HRI." With respect to evaluation at the local level and according to local contexts, as defined by the California Office of Historic Preservation,
Historic context statements are intended to provide an analytical framework for identifying and evaluating resources by providing, focusing on and concisely explaining what aspects of geography, history and culture significantly shaped the physical development of a community or region's land use patterns and built environment over time, what important property types were associated with those developments, why they are important, and what characteristics they need to have to be considered an important representation of their type and context. 25 Where locally specific and/or geographically relevant historic context has been developed, such as the context discussion in the Los Altos Historic Resource Inventory, evaluators should prioritize these in providing a framework within which to understand a property's significance. In communities and locales where context statements have not been prepared, broad, nationwide contexts such as National Register Bulletin 46: Historic Residential Suburbs can be useful. However, in these cases, it is important for evaluations to demonstrate the local significance and expression of the themes discussed in works which may have been compiled with a broader geographic view.

In any individual evaluation, a historic preservation professional will select the appropriate and relevant themes within which to assess a property's significance. Evaluations need not address and demonstrate significance (or lack thereof) against all themes in the entirety of a city's historic context statement. Los Altos Historic Resource Inventory Section II outlines four specific Los Altos contexts:

Context 1: Prehistory; Context 2: Agriculture 1850 to 1940; Context 3; Residential Architecture 1907 25 httOSj^ohp.parks.cci.^ov/poges/.1054/files/Wrinn§tii5.toricContc x:s.pilf PAGE&TURNBULL 170 MAIDEN LANE. 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

Appeal Response Memorandum [25162.01]

to 1940; and Context 4: Institutional Development 1907 to 1940. Additional discussion is provided in two subsequent sections, "Los Altos; The Influence of Transportation on Growth and Development" and "Profile of Los Altos: 1907 to 1930."
Context 3 outlines the important property types associated with the residential architecture of Los Altos, including architectural styles. It is within this context that the property at 81 Pepper Drive is most appropriately considered. As all buildings are a product of their time and the trends of that period, when evaluating properties for significance it is necessary to determine whether a property is associated with the period or the trend in any important Page & Turnbull's evaluation of 81 Pepper Drive within the outlined Context 3 found that, although the property is associated with the general trend of Los Altos' growth in the 1920s, the property is not specifically important to the initiation and development of this trend and thus does not convey significance for its association with that particular growth period.

Taken together, the 2025 HRE, prior documentation, and additional research performed by Page & Turnbull do not suggest that 81 Pepper Drive is associated in any important way to events, persons, architecture, or archaeology at the local, state, or national level.

National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 12, electronic resource at 26 .15_web5.QS.pdf.

PAGE&TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154

B
li^El 6^
January 21, 2026
Jolie Houston
Partner-Berliner Cohen LLP
10 Almaden Boulevard, 11th Floor
San Jose, CA 95113
RE: Pepper Drive Appeal
Dear Jolie Houston:

Regarding the appeal of the delisting of the house at 81 Pepper Drive from the City of Los Altos Historic Resources Inventory (HRI), we provide the following expert opinion regarding the petitioner's comments on the California Environmental Quality Act (CEQA) process. Specifically, comments noted on page 5 of the appeal.

Comment 1: Finding the project is exempt from environmental review pursuant to Section 15061(b)(3) of CEQA is not permissible when the owner of the historic resource presents plans for demolition and replacement of the house and garage at 81 Pepper Drive during proceedings to terminate designation as was done on Monday, October 27, 2025.

Response 1: CEQA Guidelines Section 15061(b)(3) states that a project is exempt from CEQA if the activity is covered by the common sense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity In question may have a significant effect on the environment, the activity is not subject to CEQA.

A lead agency's implementation of CEQA follows a multi-step decision making process. First, the agency must determine whether the proposed activity (i.e., "project") is subject to CEQA. Second, assuming CEQA is found to apply, the agency must decide whether the activity qualifies for one of the many exemptions that excuse otherwise covered activities from CEQA's environmental review. Finally, assuming no applicable exemption, the agency must undertake environmental review of the activity.

CEQA defines a "project" as an activity that (1) is a discretionary action by a governmental agency and (2) will either have a direct or reasonably foreseeable indirect impact on the environment. (Pub. Res. Code, § 21065.)
1871 The Alameda, Suite 200 ● San Jose, CA 95126 ♦ Tel; (408) 248-3500 ● www.davidjpowers.com

The project that was formally submitted to the City was a proposal to delist the subject property from the City's HRI. The action of delisting a resource would not, in and of itself, result in a direct or indirect physical effect on the environment. As such, the use of a common sense exemption for the delisting proposal was correctly applied. No further consideration of CEQA would be required for the project.

Comment 2: Per the OHP Technical Assistance Series #6, removing or delisting a resource should be based solely on factual loss of integrity, not development intent.

Response 2: It should be noted that the referenced technical document from OHP does not provide guidance or direction on the removal or delisting of a resource from a historic inventory. It provides a comparison of the determination of eligibility for listing between the California Register of Historic Resources (CRHR) and the National Register of Historic Places (NRHP).

It should be noted that the California Code of Regulations, Title 14, Section 4856 - Criteria and Procedures for Removal of an Historical Resource from the California Register of Historical Resources states that a request for formal delisting may be approved if new information or analysis shows that the historic resource was not eligible at the time of its listing.

The Department of Parks and Recreation (DPR) form completed in June 2008 by Circa: Historic Property Development^ was used as substantial evidence to list the structure at 81 Pepper Drive on the City's HRI. The DPR form indicates that the survey type was intensive but also notes that the findings are based solely on architectural merit alone and do not include analysis of association with historically significant events and/or people. The period of significant is identified as 1933-1961 without justification and does not help to provide insight into the structure's association with an important historic context. The analysis itself is incomplete and does not meet the standards by which eligibility for listing would be determined under CEQA.

The Los Altos historic evaluation process has been developed using the criteria outlined in the State and National evaluation practices and is intended to coordinate the areas of integrity, significance, and association between the CRHR and the City of Los Altos, In order to avoid conflicting information or interpretations. Per the City of Los Altos criteria for listing of a historic resource:
"if a resource meets the age requirements and retains physical integrity, the next step is to determine if the resource has historic significance (i.e. has it been relocated, is it associated with a person or event of importance, is it associated with an event, person/people, architecture/design, and/or yields important information based on national, state or local definition). Significance is based on a property's relationship or association with an importanthistoric context.This context could be an association with a person, event or ^ The preparation and recording date on page 1 of the DPR form notes June 2008, but a completion date of April 2011 is listed on pages 2 and 3. The reason for the discrepancy is unclear. The document is reference here by the recording date noted on page 1 of the DPR form.
2

pattern of events significant in local, state or national history or themes within these associative values. It could be an association with a notable architect or an important architectural style or method of construction. A building, structure or object could also be important for its ability to provide information about prehistory. If a property is found to have a clear association with an important historic context, then it Is determined to have significance as a historic resource on a national, state or local level." The DPR Form is explicit that the analysis required for listing on the City's HRI was not done. As such, it is questionable if the structure should have been listed. Consistent with the process forthe CRHR, more detailed assessment of the structure was completed as part of the proposed delisting process. These assessments, which cover all the required state and local criteria, provide new information which supports delisting of the structure.

Comment 3: The petition to remove 81 Pepper Drive from the HRI cannot be considered exempt from CEQA because it is accompanied by a stated intention to demolish. CEQA prohibits segmenting {"piecemealing") related to actions; both delisting and demolition must be analyzed in a single environmental review before taking final action on either request.

Response 3: The action of delisting a resource would not, in and of itself, result in a direct or indirect physical effect on the environment. Demolition or modification could result in an impact under CEQA if a structure is determined to be eligible for listing on the NRHP, CRHR, or a local register.

Per the requirements of the City of Los Altos, and consistent with OHP guidance, if the property owner chooses to submit an application for demolition of the structure at a later date, a development application would also be required. The development application would require development review, which is a discretionary action. Regardless of the historic status of the structure on-site at the time an application for demolition/deve lopment is filed, demolition and construction of a new structure would constitute a project under CEQA and would require environmental review.

Pursuant to CEQA Guidelines Section 15064.5, a resource need not be listed on the CRHR or a local register to be considered historic under CEQA. The resource need only be shown to be eligible for listing based on substantial evidence, if a future demolition/development proposal is filed with the City, a reevaluation of the historic significance of the structure would be required. Unless new substantive evidence is provided the City may, however, rely on the existing historic assessments.

In conclusion, it does not appear, based on our review of the available documentation, that the decision to remove the subject property from the HRI was erroneous or that the City failed to consider the whole of the project. Due to the City's requirements for demolition applications, any future changes to the project site would require environmental review under CEQA at which time the historic significance of the structure would once again need to be confirmed. The delisting, by 3

itself, would not result in a direct or indirect physical impact on the environment and would not preclude future consideration of the structure under CEQA.

Sincerely,
Shannon George
Vice President/Principal
David J. Powers & Associates
Direct: (408) 454-3402
Emaii: [email protected]
4

1/26/26,3:25 PM JP Engineering and Construction Mail - Fwd: Additional Historic Reports from Appellants/ Orientation Summary - Recent Gmai James Parivash <[email protected]>
Fwd: Additional Historic Reports from Appellants/ Orientation Summary - Recent Mon, Jan 26,2026 at 12:44 PM Stacey De <[email protected]> To: James Parivash <[email protected]>
Hi James,
Thanks for sending this over. Hope you and your family are doing well. Although I will not be able to attend, as I have a project with the National Park Service for the Golden Gate National Recreation Area in Marin County that I am completing tomorrow, and I have a project site visit tomorrow afternoon that will likely go longer than expected, I can offer the following response.

As a qualified-architectural historian with a Master's in Historic Preservation, with the required architectural and regulatory coursework and master's thesis in the historic built environment, the SOI qualifications are very important to understand. I would suggest that although a SOI-quallfied historian write about history and a historic architect can document historic buildings, they may not be qualified to evaluate the significance of built environment resources in accordance with CEQA or Section 106 of NEPA, or local listing.

Key Qualifications by Discipline (as defined by the Secretary) History: A graduate degree In history, American studies, or a closely related field, or a bachelor's degree in one of these fields with at least two years of full-time experience in research, writing, teaching, or interpretation.

Archaeology: A graduate degree in archaeology, anthropology, or a related field, plus one year of full-time professional experience in archaeological research, including at least six months of field experience and technical report preparation.

Architectural History: A graduate degree in architectural history, art history, historic preservation, or a closely related field, or a bachelor's degree in one of these fields with at least two years of full-time experience in research, writing, or teaching American architectural history.

Architecture: A professional degree In architecture or a state license to practice architecture, plus at least two years of full-time professional experience in architecture.

Historic Architecture: A professional degree in architecture or a state license to practice architecture, plus at least one year of graduate study in architectural preservation or one year of full-time professional experience on historic preservation projects.

Documentation of Expertise: Professionals must demonstrate their skills through completed projects, such as reports, surveys, and site investigations that align with the Secretary's Standards for Archaeology and Historic Preservation.

The CHRZS Consultants List: This list consists of individuals who, based on the information they have provided, meet the minimum qualifications of a professional in the disciplines of Archaeology, Architectural History, Architecture, Historical Architecture, or History, as defined in the Secretary of Interior's Standards (36 CFR 61), and who have requested to be included in the list. It is not a listing of all individuals who qualify as professionals In these disciplines under the Secretary of Interior's Standards and does not constitute an endorsement of any listed individual or consulting firm by the Office of Historic Preservation or CHRIS Information Centers.
can
Both EDS and Page & Turnbull are listed on CHRIS; however, though required, neither Halberstadt nor Sandoval appears to be listed -https://chrisinfo.org/.
https://mail.google,com/mail/u/1/?lk=9b740f0019&view=pt&8earch=all&p8rmmsgld=m8g-f:1855413566472078333&slmpl=msg-f:1855413566472078333 1/2

JP Engineering and Construction Mail - Fwd: Additional Historic Reports from Appeilants/ Orientation Summary - Recent Finaily, the California State Office of Historic Preservation (OHP) provides dear guidelines as to the amount of research needed to support the significance findings and the necessity of integrity to support the findings. Noting recommendations to understand how much context is needed is the "so what" test "Information included in historic contexts needs to pass the "so what" test. IVhen researching or writing, it helps to ask, "So what information does this sentence, paragraph, or section provide to help explain how land use patterns developed or why the built environment looks the way it does today?" V^ars, fires, expositions, arrivals of the rail roads and street car lines, visits by presidents, and other such events generally serve as historical markers or frame time periods. But unless a connection is made between that information about what happened in the past and how it shaped today's built environment, then "so what" For example, a description of what native peoples ate, wore or made their houses from hundreds of years ago will not pass the "So what" test unless it is connected with where they collected or processed their resources and how their land use patterns shaped those of later inhabitants." (OHP link - https://ohp.parks. ca.gov/?page_id=23317)
1/26/26, 3:S'6 PM
Additional details:
● There Is no evidence to support the finding that this is a kit house. As such, the possibility does not comply with the NPS or OHP guidelines for evaluating historical resources/historic properties.

My apologies for not being able to attend.

All the best,
Stacey
Stacey De Shazo, M.A., Owner/Principal Architectural Historian Evans& De Shazo, Inc.

Archaeology & Historic Preservation
Celebrating 11 years in Business
Main Office: 1141 HWY116 South | Sebastopol | CA | 95472 | Office: 707-823-7400 | Cell: 971- 344-2826
Offices in Sacramento, California and Keizer, Oregon
Ty Evans ft De Shazo, INC ^//\*C'HAi:OLOCY KfSIOkn' I'Kfir^VATION- {Quoted text hidden]
https://mail,google.com/mail/u/1/?ik=9b740f0019&view=pt&search=a ll&permmsgld=msg-f;1855413566472078333&simpl=msg-f:1856413566472078333 2/2

CITY OF LOS ALTOS

CITY COUNCIL MEETING MINUTES
TUESDAY, JANUARY 13, 2026
7:00 p.m.
1 N. San Antonio Rd. ~ Los Altos, CA
Pete Dailey, Mayor
Neysa Fligor, Vice Mayor
Larry Lang, Councilmember
Sally Meadows, Councilmember
Jonathan D. Weinberg, Councilmember
CALL MEETING TO ORDER – Pete Dailey, Mayor, called the meeting to order at 7:00 p.m.

ESTABLISH QUORUM – All Councilmembers were present.

PLEDGE OF ALLEGIANCE – Pete Dailey, Mayor, led the Pledge of Allegiance.

REPORT ON CLOSED SESSION
There was no Closed Session meeting.

CHANGES TO THE ORDER OF THE AGENDA
Motion by Lang and Second by Weinberg to move the Discussion Item after the Consent Calendar. Motion carried unanimously by roll call vote.

PUBLIC COMMENTS ON ITEMS NOT ON THE AGENDA
The following members of the public spoke during Public Comment:

SPECIAL ITEM
Issue Proclamation Recognizing the Service and Retirement of Los Altos Town Crier Editor Bruce Barton
Pete Dailey, Mayor, presented a proclamation to Bruce Barton, Former Editor of the Los Altos Town Crier.

CONSENT CALENDAR
Jonathan D. Weinberg, Councilmember, recused himself from Items 4 and 5 of the Consent Calendar due to a potential conflict of interest.

Motion by Lang and Second by Fligor to approve the Consent Calendar. Motion carried unanimously by roll call vote for Items 2 and 3, and motion carried 4-0-1 by roll call vote with Councilmember Weinberg recused for Items 4 and 5.

2. Approval of Meeting Minutes
Approve the Draft Regular Meeting Minutes for the Meeting of December 9, 2025

3. Adoption of Resolution - Approve Senior Commission Recommendation for Sourcewise Advisory Council Representative
Adopt a resolution to appoint Senior Commissioner Dolores Gallagher Thompson as

City of Los Altos
City Council Regular Meeting Minutes
January 13, 2026

the city representative to the Sourcewise Advisory Council for a three-year term with the possibility of one additional term

4. Adoption of Resolution - Woodland Library Patio Expansion Project Contract Award
Adopt a resolution to authorize the City Manager to enter into an agreement with JPB Designs Inc to complete the Woodland Library Patio Expansion in an amount not to exceed $365,200

5. Adoption of Resolution - Woodland Library Patio Expansion Project Adopt a resolution that:
• Approves the acceptance of the Los Altos Library Endowment funds for the Woodland Library Patio Expansion Project; and
• Authorizes the City Manager to enter Memorandum of Understanding with Los Altos Library Endowment; and
• Amends the FY25/26 budget by increasing Woodland Library Patio Project (CD-00001) to $365,200; and
• Recognizes $335,500 revenue from Los Altos Library Endowment; and • Appropriates $335,500 revenue to the Woodland Library Patio Expansion Project

DISCUSSION ITEM

1. 2026 City Council Reorganization Ceremony - Election of Mayor and Vice Mayor; Administration of Oaths of Office; Remarks from the City Council Neysa Fligor, Vice Mayor, announced her resignation from the City Council due to her recent election to the seat of Santa Clara County Assessor.

Pete Dailey, Mayor, presented a proclamation to Neysa Fligor, Santa Clara County Assessor-Elect, in recognition of her service to the City of Los Altos.

The following members of the public and local dignitaries spoke during the City Council reorganization:
• Margaret Abe-Koga, Santa Clara County District Five Supervisor Supervisor Abe-Koga presented Pete Dailey, Mayor, with a commendation in recognition of his service to the City of Los Altos
• Raania Mohsen, District Director for Congressman Liccardo Raania Mohsen presented Pete Dailey, Mayor, with a Congressional Certificate of Recognition for his service to the City of Los Altos on Congressman Liccardo’s behalf
• Sergio Lopez, Councilmember for the City of Campbell

City of Los Altos
City Council Regular Meeting Minutes
January 13, 2026

• Kevin Fong, District Director for Assemblymember Berman • Joan Dentler, Representative for Senator Josh Becker
• Tina Walia, Vice Mayor of Saratoga
• Rajiv Bhateja, Mayor of the Town of Los Altos Hills
Pete Dailey, Mayor, nominated Sally Meadows, Councilmember, as Mayor for 2026. Motion carried unanimously by roll call vote.

Pete Dailey, Councilmember, nominated Larry Lang, Councilmember, as Vice Mayor for 2026. Motion carried unanimously by roll call vote.

Sally Meadows, Mayor, made remarks after accepting her nomination as Mayor.

Larry Lang, Vice Mayor, made remarks after accepting his nomination as Vice Mayor.

Neysa Fligor, Santa Clara County Assessor-Elect, administered the Oath of Office to Sally Meadows, Mayor.

Melissa Thurman, City Clerk, administered the Oath of Office to Larry Lang, Vice Mayor.

INFORMATIONAL ITEMS / COUNCIL Q&A
There will be no discussion or action on Informational Items. The Council Q&A will be included in the packet the day of the meeting.

6. Tentative Council Calendar and Housing Element Update Implementation Calendar

COUNCIL/STAFF REPORTS AND DIRECTIONS ON FUTURE AGENDA ITEMS ADJOURNMENT – The regular meeting adjourned at 8:12 p.m.

The meeting minutes were prepared by Melissa Thurman, City Clerk, for approval at the regular meeting on January 27, 2026.
_________________________________ __________________________________ Sally Meadows Melissa Thurman, MMC
Mayor City Clerk
The January 13, 2026, City Council meeting recording may be viewed via the following external website: https://www.youtube.com/@CityofLosAltosCA
The City of Los Altos does not own or operate YouTube. The video referenced in these minutes was live at the time the minutes were published.

City Council Staff Report
Meeting Date: January 27, 2026
Prepared By: Melissa Thurman
Approved By: Gabe Engeland
Subject: Affirmation of 2026 City Council Regional Assignments

COUNCIL PRIORITY AREA
General Government

RECOMMENDATION
Affirm 2026 City Council Mayoral Appointments to Local, Regional Boards and City Committees and Commissions Pursuant to the City Council Norms and Procedures

ENVIRONMENTAL IMPACT
None

FISCAL IMPACT
None

PREVIOUS COUNCIL CONSIDERATION
Annual

BACKGROUND
At the beginning of each term, the Mayor of Los Altos annually appoints Councilmembers to serve on local and regional boards, committees and commissions. The City Council is provided with a list of all local and regional boards/committees/commissions, and they indicate their preference for serving. Upon completion, they return their preference list to the City Clerk, who forwards it to the Mayor for final review and approval.

ANALYSIS

DISCUSSION

ATTACHMENTS

1. Attachment 1 - 2026 Mayoral Assignments

2026 City Council Mayoral Assignments
Council Standing Committees DONE Primary Alternate Last Year Assignment City/LASD Schools Issues 2 0 Meadows,
Lang
Dailey
Meadows
City/MVLA High School Issues 2 0 Dailey,
Lang
Dailey
Lang
City/CUSD/FUSD Schools Issues 2 0 Dailey,
Weinberg
Dailey
Weinberg
Youth Commission Interviews 2 0 Weinberg,
Lang
Weinberg
Lang
County and Regional Organizations Primary Alternate Last Year Assignment Association of Bay Area Governments 0 0 Fligor
Dailey (Alt.)
Assigned by
Cities Assoc.

Selection
Committee
County Housing & Community Development
Advisory Committee (HCDAC)
1 0 Meadows Dailey
Santa Clara County Cities Association – Board
(Mayor is primary)
1 1 Fligor
Dailey (Alt.)
Meadows
Lang (Alt.)
Santa Clara County Cities Association –
Legislative Action Committee
1 1 Dailey
No Alt
Assigned
Lang
Dailey (Alt.)
Santa Clara County Cities Association –
Selection Committee
1 1 Dailey
Fligor (Alt.)
Meadows
Lang (Alt.)
Santa Clara County Expressway Policy Advisory
Board
1 0 Lang Weinberg
Santa Clara Valley Water Commission
(2-year term)
1 1 Dailey,
Lang (Alt.)
Dailey
Lang (Alt.)
Santa Clara County Library District JPA 1 1 Meadows
Lang (Alt.)
Meadows
Lang (Alt.)
North County Library Authority
(2-year term)
2 Dailey
Lang
Dailey
Lang
Valley Transportation Authority – Policy Advisory
Committee
1 1 Weinberg
Fligor (Alt.)
Lang
Dailey (Alt.)
Silicon Valley Regional Interoperability Authority
(SVRIA)
(3-year term)
1 0 Weinberg Weinberg
Silicon Valley Clean Energy Authority Board 1 1 Meadows Dailey (Alt.)
Meadows
Weinberg (Alt.)
Valley Transportation Authority – State Route 85
Corridor Policy Advisory Body
1 1 Lang
No Alt
Assigned
Weinberg
No Alt
Assigned

2026 City Council Mayoral Assignments
City Commissions/Committee Primary Alternate Last Year Assignment Complete Streets 1 0 Lang Lang
Environmental 1 0 Fligor Dailey
Financial 1 0 Meadows Meadows
Historical 1 0 Dailey Lang
Library 1 0 Lang Lang
Parks, Arts, Recreation & Cultural 1 0 Dailey Weinberg
Planning 1 0 Weinberg Dailey
Senior 1 0 Meadows Meadows
Youth 1 0 Weinberg Weinberg
JVAC (Committee) 1 0 Lang Weinberg

City Council Staff Report
Meeting Date: January 27, 2026
Prepared By: Stephanie Williams
Approved By: Gabe Engeland
Subject: Adoption of Resolution - Weed Abatement Annual Property Identification

COUNCIL PRIORITY AREA
General Government
Public Safety

RECOMMENDATION
Adopt a Resolution Declaring Weeds, Brush and/or Rubbish on Certain Described Properties to be a Public Nuisance and find that this action is exempt from environmental review pursuant to Section 15301(h) of the California Environmental Quality Act (CEQA) Guidelines

ENVIRONMENTAL IMPACT
Adoption of this resolution is exempt from environmental review pursuant to Section 15301(h) of the California Environmental Quality Act as this action involves maintenance of existing landscaping and native growth.

FISCAL IMPACT
No direct fiscal impact to the City of Los Altos is associated with participation in the Weed Abatement Program as the cost to perform the work is covered by a Property Tax Assessment to the parcel of land where the violation occurs.

PREVIOUS COUNCIL CONSIDERATION
In June 2024 the City Council authorized the City of Los Altos’ participation in the County of Santa Clara Weed Abatement Program.

In November 2024 the City Council adopted a Resolution declaring described properties a public nuisance and in January 2025 held a public hearing for appeals.

BACKGROUND
Los Altos Municipal Code Chapter 11.06 requires property owners to remove excessive vegetative growth and combustible debris to reduce fire hazards. To support enforcement of this requirement, the City Council authorized the City’s participation in the Santa Clara County Weed Abatement Program on June 25, 2024.

The Weed Abatement Program is administered by the Santa Clara County Consumer and Environmental Protection Agency in partnership with cities throughout Santa Clara County. The program’s primary purpose is to prevent fire hazards caused by excessive vegetation and the

accumulation of combustible materials, with an emphasis on achieving voluntary compliance.

Property owners are required to maintain vegetation in accordance with minimum fire safety standards.

As part of the City’s participation in the program, the City Council must annually adopt a resolution confirming the properties identified by the County for abatement of known violations.

Adoption of this resolution is required in order for the County to enforce the program on the City’s behalf.

Properties may be added to the program through several means. Most commonly, an inspector identifies a hazard during a site visit. Properties may also be referred through community complaints, service requests, or referrals from other public agencies, such as the fire department.

Once a potential hazard is identified, an inspector verifies the condition, photographs the site, and documents the parcel location. Properties enrolled in the program remain subject to monitoring for up to three years. If no abatement action is required during that period, the property is removed from the program.

The program is funded through fees assessed to identified properties. Fees cover the cost of inspections, and if abatement is performed by a County contractor, the property owner is responsible for all associated abatement costs.

ANALYSIS
The attached draft resolution will declare the listed properties as being a potential fire hazard due to weeds and/or combustible materials (Attachment 1). As part of the adoption of the draft resolution, the City Council is establishing February 24, 2026, at 7:00 PM as the date for any appeals. At that time, owners of parcels identified by the County of Santa Clara as requiring weed abatement will have the opportunity to present justification for removing their property from the abatement list (Attachment 2).

After the conclusion of this appeal hearing, the County will be authorized to perform an inspection of the properties in the report to determine if properties have met the program requirements. Property owners will have until April 30, 2026 to abate their property.

DISCUSSION
The weed abatement process consists of the following steps:

1. County prepares a report on all properties that have been non-compliant in removing weeds in the last three years and provides that report to the City.

2. City adopts a resolution declaring weeds a public nuisance and the City sets an appeal hearing date.

3. County sends notice to the property owners in the report notifying them of the hearing date and that they must remove or destroy weeds by the abatement deadline of April 30th, or it will be done for them with the cost of the abatement plus administrative costs

assessed for their property.

4. City Council holds the hearing to consider objections by property owners and adopts a resolution ordering abatement.

5. County sends a courtesy letter to property owners listed in the report, notifying them again of the abatement deadline, and noting that they will work with the property owner to be sure the weeds are removed.

6. After April 30th, the properties are inspected by the County to verify that weeds were removed and proceed with abatement if the property fails the inspection. The County creates a report on all costs associated with the abatement. The County also provides a report of costs associated with the initial inspection fee for compliant properties and a report that includes properties that failed the inspection and associated costs proposed to be assessed.

7. City notifies the property owners listed on the assessment report, notifying them of the hearing date.

8. City Council holds a hearing, considers any disputes, and adopts a resolution placing a lien assessment on the properties to allow the County to recover the cost of weed abatement.

ATTACHMENTS

1. Attachment 1 - Resolution

2. Attachment 2 - 2026 Commencement Report

RESOLUTION NO. 2026-XX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS

DECLARING WEEDS, BRUSH AND/OR RUBBISH ON CERTAIN DESCRIBED

PROPERTIES TO BE A PUBLIC NUISANCE
WHEREAS, weeds and brush are growing in the City of Los Altos upon certain streets, sidewalks, highways, roads, and private property; and WHEREAS, the weeds, brush and rubbish create a fire hazard and/or health hazard and threaten the public health, safety, and welfare; and WHEREAS, on June 25, 2024, the City Council of the City of Los Altos authorized the participation in the County of Santa Clara Weed Abatement Program; and WHEREAS, on April 8, 2025, the City Council of the City of Los Altos adopted an Ordinance adding Chapter 11.06 - Weed Abatement regulations to the Los Altos Municipal Code; and
WHEREAS, the County of Santa Clara Weed Abatement Program is to prevent fire hazards posed by vegetative growth and the accumulation of combustible materials; and
WHEREAS, as a part of the City of Los Altos’ participation in the County of Santa Clara Weed Abatement Program the City shall declare any properties subject to the annual weed abatement program; and
NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos hereby declares that:

1. Weeds, brush and/or rubbish that create a fire hazard and/or health hazard are a public nuisance.

2. The nuisance exists or recurs upon all the streets, sidewalks, highways, roads and private property, more particularly described by common name or by reference to the parcel number on the report prepared by the Director of the County of Santa Clara Consumer and Environmental Protection Agency and attached hereto and incorporated as Exhibit A.

3. The property owners of the described parcels must abate the nuisance(s) throughout the year by removing the weeds, brush and/or rubbish, otherwise the County of Santa Clara, Consumer and Environmental Protection Agency will abate the nuisance(s) and the cost of abatement to the County will constitute a lien upon the property until paid.

4. Unless the nuisance is abated prior to the inspection of the property by the County, the cost of the failed inspection will constitute a lien upon the responsible

property until paid.

5. It is ordered that on Tuesday the 24th day of February 2026, at the hour of 7:00 PM, in the Community Chambers, located at 1 North San Antonio Road, Los Altos, CA, 94022, is the time and place when the City Council of the City of Los Altos will hear any objections at a public hearing to the proposed destruction or removal of the weeds, brush and/or rubbish by the County.

6. The Director of the County of Santa Clara Consumer and Environmental Protection Agency is hereby designated as the person to cause notice of the adoption of this resolution to be given in the manner and form provided in the Health and Safety Code Section 14980 and as the person to hereafter cause abatement of such seasonal and recurring nuisance.

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 27th day of January 2026 by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Sally Meadows, MAYOR
Attest:

Melissa Thurman, MMC, CITY CLERK

EXHIBIT A

Situs APN CITY/STATE
2026 WEED ABATEMENT PROGRAM

CITY OF LOS ALTOS
COMMENCEMENT REPORT Exhibit A
1 1183 LAURELES DR 167-10-026 TOBAGI FOUAD A 1183 LAURELES DRIVE LOS ALTOS CA 940222 410 TRAVERSO AVE 167-14-056 ZHENG JINGWEI AND CHAI YU 410 TRAVERSO AVE LOS ALTOS CA 940223 900 SANTA RITA AVE 167-14-061 FIROOZ MOHAMMAD HAMED AND 900 SANTA RITA AVE LOS ALTOS CA 940224 107 DEL MONTE AVE 167-17-026 GOUD SUNEEL AND ALIMCHANDANI 107 DEL MONTE AVE LOS ALTOS CA 940225 465 W. PORTOLA AVE 167-19-027 LAI TRACY ALYCE MARK TRUSTEE & 465 W. PORTOLA AVE LOS ALTOS CA 940226 638 TOMI LEA ST 167-23-013 HAGNERE GINETTE TRUSTEE 2801 NORMANDIE CT ESCONDIDO CA 920257 17 ALMA CT 167-28-027 JIA HONGZHONG AND CHEN WEI 580 ROSITA AVE LOS ALTOS CA 940248 394 N. SAN ANTONIO RD 167-29-062 SCHIATTARELLA ENRICO AND 61 CHESTER CIR LOS ATLOS CA 940229 110 LOS ALTOS AVE 167-35-043 DUCROHET XAVIER AND VICTORIA 110 LOS ALTOS AVE LOS ALTOS CA 9402210 987 ACACIA AV 170-01-043 GQ FIRST INC 97 BOSTON AVE SAN JOSE CA 9512811 4848 EL CAMINO 170-02-055 TS 4846 ECR LLC 12230 SARATOGA SARATOGA CA 9507012 4898 EL CAMINO 170-03-085 ADL 15 LLC 329 S SAN ANTONIO RD, UNTI LOS ALTOS CA 9402213 706 CASITA WY 170-04-020 HERLINGER, DAVID 706 CASITA WAY LOS ALTOS CA 9402214 84 ALVARADO AVE 170-15-005 COLE HENRY A JR AND ARLENE C 84 ALVARADO AVE LOS ALTOS CA 9402215 226 SOLANA DR 170-21-025 ANGULO ROBERT TRUSTEE & ET AL 411 PACO DR LOS ALTOS CA 9402416 241 SUNKIST LN 170-22-020 MEHTA SAGAR TRUSTEE & ET ALL 1595 MORTON AVE LOS ALTOS CA 9402417 200 ALMOND Av 170-24-008 VINNAKOTA SRICHARAN TRUSTEE & 200 ALMOND AVE LOS ALTOS CA 94022-220518 215 ANGELA DR 170-24-041 ANGELA GROUP LLC 10229 SCENIC BLVD CUPERTINO CA 9501419 245 HAWTHORNE AVE 170-26-076 245 HAWTHORNE LLC 873 SANTA CRUZ AVE UNIT MENLO PARK CA 9402520 140 LYELL ST 170-39-043 LYELL LLC 840 MORENO AVE PALO ALTO CA 9430321 136 PEPPER DR 170-40-054 HAMILTON KRISTINE K AND GARY G 136 PEPPER DR LOS ALTOS CA 9402222 175 BEVERLY LN 170-43-009 175 BEVERLY LLC 257 CASTRO STREET, STE # MOUNTAIN VIEW CA 9404123 562 PALM AVE 175-16-008 562 PALM LLC 562 PALM AVE LOS ALTOS CA 94022-353024 655 WASHINGTON ST 175-17-035 ELEANOR VALLEY LLC 221 YERBA BUENA AVE LOS ALTOS CA 94022 24 records of 57 Santa Clara County Weed Abatement Program Page 1

Situs APN CITY/STATE
2026 WEED ABATEMENT PROGRAM

CITY OF LOS ALTOS
COMMENCEMENT REPORT Exhibit A
25 782 UNIVERSITY AVE 175-18-031 WONG ERIC TRUSTEE 782 UNIVERSITY AVE LOS ALTOS CA 9402226 604 MILVERTON RD 175-19-042 GIOVANNOTTO ROBERTO M P.O. BOX 210 PALO ALTO CA 9430227 1169 GOLDEN WA 189-10-027 SU KEVIN P AND CHEN JENNIFER A 1169 GOLDEN WAY LOS ALTOS CA 94024-505828 968 LINDA VISTA WA 189-12-018 FENG YUAN AND HU LIUYI TRUSTEE 968 LINDA VISTA WAY LOS ALTOS CA 9402429 980 BERRY Av 189-12-028 DEATHERAGE DAVID G AND HSI 980 BERRY AV Los Altos CA 9402430 1540 MIRAMONTE AVE 189-15-085 POS GROUP MIRAMONTE LLC 137 ELM STREET SAN CARLOS CA 9407031 718 RONALD CT 189-19-003 718 RONALD LIMITED PARTNERSHIP 22330 SANTA PAULA AVE CUPERTINO CA 9501432 16 OTIS WA 189-35-038 ZHOU HUAPENG AND QI NITING 16 OTIS WAY LOS ALTOS CA 9402233 675 PACO DR 189-37-036 WONG NORMAN D AND EUGENIA L 1600 TROUSDALE DR BURLINGAME CA 9401034 645 PACO DR 189-37-039 OKADA RALPH T P.O. BOX 2396 SUNNYVALE CA 9408735 629 BENVENUE AVE 189-38-079 TUNG CHIEN-CHIH TRUSTEE & ET A 629 BENVENUE AV LOS ALTOS CA 9502436 674 TERESI LN 189-40-039 HINDMAN STEVEN MICHAEL AND 674 TERESI LN LOS ALTOS CA 9402437 847 RIVERSIDE DR 189-43-020 RIVERSIDE DR LLC 13717 FORTUNA CT SARATOGA CA 95070-524238 1065 ECHO DR 189-46-019 GUO FONG-CHIH AND LIOU HUOY-YU1065 ECHO DR LOS ALTOS CA 9402439 960 ECHO DR 189-46-028 RUGTIV STEWART, SUSAN & SCOTT 960 ECHO DR LOS ALTOS CA 94024-481740 571 EL MONTE AVE 189-51-056 WANG JOHN B AND WONG LYDIA A 571 S. EL MONTE AVE LOS ALTOS CA 9402241 562 BENVENUE AVE 189-52-064 SADAKIAN AVEDIS A AND ARO 562 BENVENUE AVE LOS ALTOS CA 9402442 705 VISTA GRANDE AV 189-58-070 TAWARI SANDESH AND SHIKHA 705 VISTA GRANDE AVE. LOS ALTOS CA 9402443 924 O'DELL WY 193-27-012 ROH YOUSIK AND CHUNG KRISTY 924 O'DELL WAY LOS ALTOS CA 9402444 1225 CARMEL TER 193-43-014 ROSS ELIZABETH TRUSTEE 1225 CARMEL TER LOS ALTOS CA 9402445 1375 RANCHITA DR 197-18-012 LION, ANNA R 1375 RANCHITA DRIVE LOS ALTOS CA 9402446 1347 RICHARDSON AVE 318-07-008 FIRST SOUTHERN BAPTIST CHURCH 1347 RICHARDSON AVE LOS ALTOS CA 94024-613547 1925 CHURTON AVE 318-15-033 MCGHEE GLENN E AND BONNIE J 1925 CHURTON AVE LOS ALTOS CA 9402448 1948 CHURTON AV 318-15-070 KELLOGG LEOLA J TRUSTEE 1948 CHURTON AVE LOS ALTOS CA 94024 48 records of 57 Santa Clara County Weed Abatement Program Page 2

Situs APN CITY/STATE
2026 WEED ABATEMENT PROGRAM

CITY OF LOS ALTOS
COMMENCEMENT REPORT Exhibit A
49 1561 LANDELL CT 318-17-018 AGRAWAL MOHIT AND BHUTANI 1796 JUAREZ AVE LOS ALTOS CA 94024-681350 1705 CHRISTINA Dr 318-21-015 CHRISTINA STERLING HOMES LLC 1072 HARLAN DR San Jose CA 9512951 2011 CRIST DR 318-23-033 FARMER KAREN Q 2011 CRIST DRIVE LOS ALTOS CA 9402452 2005 CRIST DR 318-23-035 CHIOTTI GREGORY L TRUSTEE 2005 CRIST DR LOS ALTOS CA 9402453 849 STARLITE LN 336-02-053 TURAIDS IVONNA A TRUSTEE & ET 849 STARLITE LANE LOS ALTOS CA 9402454 1590 VINEYARD DR 342-02-046 SHEAR HERBERT AND MAT TRUSTEE 1590 VINEYARD DRIVE LOS ALTOS CA 9402455 510 SEQUOIA DR 342-03-049 LEE SANG JUN & JEONG HEE YOUNG 510 SEQUOIA DRIVE LOS ALTOS CA 9402456 1816 GRANGER AVE 342-07-063 DEGIULI ANGELO AND FRANCHINI 1816 GRANGER AVE LOS ALTOS CA 9402457 1964 DEODARA DR 342-25-010 WU ROBERT S AND LI-CHUN C 1964 DEODARA DRIVE LOS ALTOS CA 94024 57 records of 57 Santa Clara County Weed Abatement Program Page 3

City Council Staff Report
Meeting Date: January 27, 2026
Prepared By: Yongdan Chunyu
Approved By: Gabe Engeland
Subject: Adoption of Resolution - Playground Renovations at Grant Park and Shoup Park

COUNCIL PRIORITY AREA
General Government

RECOMMENDATION
Adopt a resolution to authorize the City Manager to enter into an agreement with PlayCore Wisconsin Inc. dba GameTime of Fort Payne, Alabama, to design, purchase, and install new playground equipment and safety surfacing at Grant Park in an amount not-to-exceed $444,098.99 and at Shoup Park in an amount not-to-exceed $536,845.04, with a contingency of up to 15% for each project (not-to-exceed $66,615 for Grant Park and $80,527 for Shoup Park), for a total combined project cost not-to-exceed $1,128,086.03, to complete the playground renovations at Grant Park and Shoup Park

ENVIRONMENTAL IMPACT
Categorically Exempt pursuant to California Environmental Quality Act (CEQA) Section 15303 – New Construction or Conversion of Small Structures consisting of the construction and installation of small equipment and structures involving negligible or no expansion of existing or former use.

FISCAL IMPACT
The project budget was approved as part of the FY 2025–26 Capital Improvement and Major Maintenance Program (CIMMP). Funding for both projects is provided through Park-In-Lieu funds, with $620,000 allocated for Grant Park and $620,000 allocated for Shoup Park pursuant to City Council Resolution No. 2025-56.

PREVIOUS COUNCIL CONSIDERATION
None.

BACKGROUND
Grant Park and Shoup Park are well-used neighborhood parks that serve children and families throughout the City of Los Altos. Each park includes a playground that provides important recreational opportunities for nearby residents and visitors. This project aims to replace the existing play structures and safety surfacing at both sites to create safe, accessible, imaginative, and engaging playground spaces for the Los Altos community.

ANALYSIS

The existing playground at Shoup Park was installed in 2003, and the playground at Grant Park was installed in 2008. While the current equipment has remained functional over time and has been well maintained, it reflects an earlier generation of playground design and offers fewer play elements compared to newer playground installations.

The playground renovation projects at Grant Park and Shoup Park are included in the City’s Capital Improvement Program and are limited to replacement of existing play equipment and safety surfacing within the current playground footprints, with no expansion of the play areas.

DISCUSSION
In the process of implementing the playground renovation projects at Grant Park and Shoup Park, staff solicited proposals through a formal Request for Proposals (RFP). Seven proposals were received through the City’s required procurement platform, PlanetBids, prior to the RFP submission deadline of 4:00 PM on October 23, 2025. Proposals were reviewed by staff and a volunteer non-staff community member with knowledge and interest in the playground renovation projects.

Through this process, PlayCore Wisconsin Inc. dba GameTime was selected as the proposal that best met the City’s project goals and requirements. GameTime’s proposal included playground equipment layouts and components that evaluators felt satisfied current usage while incorporating modern play elements. The proposed playground designs at Grant Park and Shoup Park increase overall play value by expanding opportunities for music and sound play, dramatic play, climbing, and interactive activity panels, while maintaining a comparable number of core play elements such as slides and swings. Both designs also enhance accessibility and inclusivity through the addition of poured-in-place safety surfacing and a broader range of ADA-accessible and adaptive/universal play elements.

Staff is requesting City Council adopt a resolution to authorize the City Manager to enter into an agreement with PlayCore Wisconsin Inc. dba GameTime to design, purchase, and install new playground equipment and safety surfacing at Grant Park and Shoup Park in accordance with the proposed not-to-exceed contract amounts. Once approved, staff will coordinate with the selected vendor to refine design details and finalize renderings for equipment purchase and installation.

ATTACHMENTS

1. Attachment 1 - Resolution

Resolution No. 2025-__ Page 1
RESOLUTION NO. 2025-__

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS

AUTHORIZING THE CITY MANAGER TO ENTER INTO AN AGREEMENT WITH PLAYCORE WISCONSIN INC. DBA GAMETIME FOR THE DESIGN,

PURCHASE, AND INSTALLATION OF PLAYGROUND EQUIPMENT AND

SAFETY SURFACING AT GRANT PARK AND SHOUP PARK IN THE
AMOUNT NOT TO EXCEED $444,098.99 (GRANT PARK CONTRACT) + $66,615 (GRANT PARK CONTINGENCY) AND $536,845.04 (SHOUP PARK CONTRACT) + $80,527 (SHOUP PARK CONTINGENCY), FOR A TOTAL COMBINED AMOUNT NOT TO EXCEED $1,128,085.63
WHEREAS, the existing playground equipment and safety surfacing at Grant Park and Shoup Park reflect an earlier generation of playground design and are overdue for recommended replacement; and
WHEREAS, as part of the annual budget process, City Council approved the FY 2025–26 Capital Improvement and Major Maintenance Program, which includes the playground renovation projects at Grant Park and Shoup Park; and
WHEREAS, funding for these projects is provided through Park-In-Lieu funds as approved by City Council pursuant to Resolution No. 2025-56; and WHEREAS, staff solicited proposals through a formal Request for Proposals process and received seven proposals via the City’s required procurement platform, PlanetBids, prior to the established deadline; and
WHEREAS, PlayCore Wisconsin Inc. dba GameTime was selected as the proposal that best met the City’s project goals and requirements.

NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos hereby:

Authorize the City Manager to enter into an agreement with PlayCore Wisconsin Inc. dba GameTime to design, purchase, and install new playground equipment and safety surfacing at Grant Park in an amount not to exceed $444,098.99, plus a contingency of $66,615, and at Shoup Park in an amount not to exceed $536,845.04, plus a contingency of $80,527, for a total combined project cost not to exceed $1,128,085.63.

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 27th day of January 2026 by the following vote:

AYES: Councilmembers
NOES: None
ABSENT: None

Resolution No. 2025-__ Page 2
ABSTAIN: None
___________________________
, MAYOR
Attest:
__________________________________
Melissa Thurman, MMC
City Clerk

City Council Staff Report
Meeting Date: January 27, 2026
Prepared By: Yongdan Chunyu
Approved By: Gabe Engeland
Subject: Adoption of Resolution - Grant Park Project Acceptance

COUNCIL PRIORITY AREA
Public Safety
Environmental Sustainability
General Government

RECOMMENDATION
Adopt a resolution accepting completion of the Grant Park Building Mechanical and Electrical Renovations Project (CF-01034); authorize the Park & Recreation Director to record a Notice of Completion as required by law; and find the project categorically exempt under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15301

ENVIRONMENTAL IMPACT
Acceptance of the completed work is categorically exempt from CEQA under CEQA Guidelines Section 15301 (Existing Facilities), which includes minor alterations to existing public structures involving mechanical and electrical upgrades. None of the exceptions listed in CEQA Guidelines Section 15300.2 apply.

FISCAL IMPACT
On January 14, 2025, the City Council awarded a construction contract to Aria Electric Construction in an amount not-to-exceed $830,000, with a 15% contingency not-to-exceed $124,500, for a total authorization of $954,500. Funding for the project was provided by the InLieu Park Fund, including an additional allocation of $570,000 approved at award to fully fund construction and PG&E-required electrical service upgrades. All work has been completed within the approved budget. Project savings will be returned to the In-Lieu Park Fund.

Grant Park Building Mechanical and Electrical Renovations Project Funding Source
Project Funding Source Project Budget Final Cost
Design $ 122,000.00 $ 15,570.00
Construction $ 939,000.00
$ 1,096,423.21

Project Total Cost $ 1,178,000.00
$ 1,111,993.21
Total Project Savings $ 66,006.79

PREVIOUS COUNCIL CONSIDERATION
On January 14, 2025, Council adopted Resolution No. 2025-02 authorizing award of the construction contract to Aria Electric Construction for the Grant Park Building Mechanical and Electrical Renovations and approving additional funding from the In-Lieu Park Fund.

BACKGROUND
The Grant Park Community Center is composed of two single-story buildings constructed in the early 1970s and renovated in 1989. The mechanical and electrical systems had exceeded their service life, resulting in operational inefficiencies and increased maintenance needs. Upgrades were required to support current and future recreational programming and to ensure the facility meets safety and code requirements.

The project scope included:
• Replacement of electrical service equipment and distribution panels • Installation of a new PG&E electrical service
• Upgrades to HVAC systems
• Replacement of interior and exterior lighting and controls • Associated safety and code compliance improvements
Plans were prepared by Kurious Design Solutions, Inc. and were permitted in fall 2024.

ANALYSIS
Aria Electric Construction successfully completed all project work in accordance with the plans and specifications. The work included:
• Installation of a new PG&E electrical service and associated infrastructure • Full replacement of electrical panels, conduits, and wiring systems supplying the buildings
• HVAC system upgrades to improve efficiency, reliability and full climate control • Lighting improvements including new fixtures and code-compliant controls • Modifications to meet current electrical and mechanical safety standards

DISCUSSION
City staff conducted final inspections and determined that all contract requirements were satisfactorily completed. The project is now complete and ready for Council acceptance.

ATTACHMENTS

1. Attachment 1 - Resolution

RESOLUTION NO. 2025-__

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS

ACCEPTING COMPLETION OF AND DIRECTING THE PARK & RECREATION

DIRECTOR TO FILE A NOTICE OF COMPLETION FOR THE GRANT PARK BUILDING MECHANICAL AND ELECTRICAL RENOVATIONS (CF-01034) WHEREAS, the City of Los Altos and Aria Electric Construction entered into a construction contract on January 14, 2025, for the Grant Park Building Mechanical and Electrical Renovations (CF-01034); and
WHEREAS, the work performed by Aria Electric Construction has been completed to the satisfaction of the City Council and in accordance with the contract, plans, and specifications.

NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos does hereby finds and authorizes the following:

1. Accept completion of the Grant Park Building Mechanical and Electrical Renovations (CF-01034).

2. Direct the Park & Recreation Director to execute and file for record with the County Recorder of the County of Santa Clara a Notice of Completion, as required by law.

3. Confirm that acceptance of the work is exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15301, and that none of the circumstances listed in CEQA Guidelines Section 15300.2 apply 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 27th day of January 2026 year, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:
__________________________

PETE DAILEY
Mayor
ATTEST:
_________________________

MELISSA THURMAN, MMC
City Clerk

City Council Staff Report
Meeting Date: January 27, 2026
Prepared By: Sean Gallegos
Approved By: Gabe Engeland
Subject: Adoption of Resolution - Vesting Tentative Map at 996 Loraine Avenue

COUNCIL PRIORITY AREA
General Government
Housing

RECOMMENDATION
Adopt a Resolution approving a Vesting Tentative Map (Application No. TM22-0005) for the creation of thirteen (13) condominium lots and one (1) common lot at 996 Loraine Avenue per the recommended findings and conditions of approval; and find the project is statutorily exempt from environmental review pursuant to Public Resources Code (PRC) Section 21080.66

ENVIRONMENTAL IMPACT
The project is statutorily exempt under Public Resources Code Section 21080.66. The 0.2 acre infill site is previously developed, within the urban services area, and surrounded by urban uses; the project conforms to the General Plan and Commercial Neighborhood zoning as modified through State Density Bonus Law, the site contains no sensitive habitat or historic resources, is not in an area identified in Section 21080.66(a)(6), and utilities and public services are available.

Tribal consultation is complete, environmental site assessments are prepared, and any required remediation will be completed before construction. The project therefore meets the statutory exemption and is not subject to further environmental review.

FISCAL IMPACT
None.

PREVIOUS COUNCIL CONSIDERATION
The City Council previously considered the Vesting Tentative Map application for 996 Loraine Avenue at a public hearing on November 18, 2025, at which time the Council unanimously approved the application. The application has been rescheduled for consideration by Council at a public hearing that has been noticed in accordance with all applicable local and state requirements.

BACKGROUND
Property Description
The approximately 0.2-acre project site is located on the southwest corner of Loraine Avenue and Miramonte Avenue. The project site is currently developed with an approximately 2,240 square-foot, single-story commercial building, landscaping, and eleven (11) surface parking

spaces. Surrounding land uses include residences to the north and west, a day care use to the south, and along the east property line Miramonte Avenue, with a single-family residence and commercial uses (including a U.S. Post Office) located across the street.

Project Overview
The project includes a Vesting Tentative Map for condominium purposes for twelve (12) residential condominium units, one (1) commercial condominium unit, and a common lot (see Attachment 2).

The proposed map is in relation to a development project to construct a three-story, approximately 17,674 square foot mixed-use building with 962 square feet of ground-floor commercial space and twelve (12) multiple-family residential units on the upper floors.

Planning Commission Review
On November 6, 2025, the Planning Commission held a public hearing to review the Design Review, Conditional Use Permit and Vesting Tentative Map applications. The Planning Commission unanimously approved the Design Review and Conditional Use Permit applications and recommended approval of the Vesting Tentative Map application to the City Council. The Planning Commission report is included as Attachment 3.

ANALYSIS
General Plan Consistency
The project is consistent with the General Plan’s Neighborhood Commercial (NC) Land Use Designation, which supports neighborhood-serving retail, service, commercial, and office uses.

The designation also encourages higher-density residential uses in appropriate locations to promote walkability and support local businesses. By providing ground-floor commercial space with residential units above, including affordable units, the project aligns with these objectives and contributes to a vibrant, pedestrian-oriented environment. The project will contribute towards the City’s Regional Housing Needs Assessment (RHNA) and is aligned with the City’s recently adopted 6th Cycle Housing Element by adding twelve (12) units to the City’s housing stock, two (2) of which will be low-income units.

The project complies with the following General Plan polices:
• LU Policy 1.1:

Maintain flexibility of standards and procedures to
accommodate changing trends in retail, housing, and office uses.
• LU Policy 2.3:

Continue to conduct design review of residential and nonresidential development applications to ensure compatibility with surrounding property and neighborhoods.
• LU Policy 3.1
Encourage residential development above the ground floor that includes affordable housing units.

• LU Policy 4.2
Encourage mixed-use projects with retail, housing, and/or lodging in addition to retail and office uses.
• LU Policy 4.4
Encourage the development of affordable housing.
• Housing Policy

1.1:

The City will encourage a diverse range of both market-rate and affordable housing sizes and residential densities to accommodate the varied housing needs of families, couples, and individuals.
• Housing Policy

1.2:

The City will encourage mixed-use development in
designated zoning districts.
• Housing Policy 2.1
The City will facilitate the development of new affordable housing units.

Subdivision Consistency
The project includes a Vesting Tentative Map for condominium purposes. The subdivision will divide the site into twelve (12) individual residential condominium units, one (1) commercial condominium unit, and a common lot. The subdivision conforms to the General Plan, Subdivision Ordinance, and provisions of the Subdivision Map Act as substantiated in the Draft Resolution for approval of the Vesting Tentative Map (Attachment 1).

Housing Accountability Act (HAA)
The Housing Accountability Act (HAA) (Government Code Section 65589.5), establishes the state’s overarching policy that a local government may not deny, reduce the density of, or make infeasible housing development projects (projects resulting in more than two (2) housing units or resulting parcels) which includes subdivision of land that are consistent with objective local development standards. Before doing any of those things, local governments must make specified written findings based upon a preponderance of the evidence that a specific, adverse health or safety impact exists. Legislative intent language indicates that the conditions that would give rise to such a specific, adverse impact upon the public health and safety would occur infrequently.

The proposed project is protected under the Housing Accountability Act (HAA) as it creates additional housing stock within the City of Los Altos and meets all applicable objective design standards.

DISCUSSION
See Analysis Section.

PUBLIC NOTIFICATION
A public meeting notice was mailed to property owners within (300) feet of the project site and published in the newspaper. The applicant also posted the site with a public notice sign in conformance with the Planning Division posting requirements.

PUBLIC NOTIFICATION
A public meeting notice was mailed to property owners within (300) feet of the project site and published in the newspaper. The applicant also posted the site with a public notice sign in conformance with the Planning Division posting requirements.

ATTACHMENTS

1. Attachment 1 - Resolution

2. Attachment 2 - Vesting Tentative Map

3. Attachment 3 - Planning Commission Staff Report

RESOLUTION NO. 2026-___

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS APPROVING A VESTING TENTATIVE MAP (APPLICATION NO. TM22-0005) FOR THE CREATION OF 12 RESIDENTIAL CONDOMINIUM LOTS, ONE COMMERCIAL CONDOMINIUM LOT, AND ONE COMMON LOT AT 996 LORAINE AVENUE WHEREAS, the applicant, 996 Loraine LLC, submitted an application for a Vesting Tentative Map (Application No. TM22-0005) to subdivide an 8,898 square-foot (0.20-acre) parcel at 996 Loraine Avenue (APN 189-15-0186) into twelve (12) residential condominium lots, one (1) commercial condominium lot, and one (1) common lot; and WHEREAS, approval of the project is statutorily exempt from environmental review under Public Resources Code Section 21080.66 as a qualifying mixed-use housing project on an infill site consistent with the General Plan Neighborhood Commercial (NC) designation and the Commercial Neighborhood (CN) zoning district, as modified by the State Density Bonus Law.

The site is developed, served by utilities, surrounded by urban uses, and not located in any environmentally sensitive area identified in Section 21080.66(a)(6). The property is not a historic resource, tribal consultation has been completed, environmental site assessments prepared with remediation to occur before occupancy, and the site is more than 500 feet from the nearest freeway.

The project therefore meets all criteria for the statutory exemption.

WHEREAS, the Project was processed in accordance with the applicable provisions of the California Government Code and Los Altos Municipal Code; and WHEREAS, on November 6, 2025, the Planning Commission conducted a duly noticed public hearing at which members of the public were afforded an opportunity to comment on the project, and at the conclusion of the meeting, the Planning Commission recommended the City Council approve the Vesting Tentative Map; and
WHEREAS, the City Council previously considered and unanimously approved the Vesting Tentative Map on November 18, 2025, and the matter has been rescheduled for consideration at a public hearing that has been noticed in accordance with applicable legal requirements; and
WHEREAS, on January 27, 2026, the City Council held a duly noticed public hearing as prescribed by law and considered public testimony and evidence and recommendations presented by staff in connection with the Project; and
WHEREAS, the finding and conclusions made by the City Council in the Resolution are based upon the oral and written evidence presented as well as the entirety of the administrative record for the proposed Project, which is incorporated herein by this reference. The findings are not based on the information provided in this Resolution; and WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

Resolution No. 2026-XX Page 2
NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos hereby approves the Vesting Tentative Map for the creation of twelve (12) residential condominium lots, one (1) commercial condominium lot, and one (1) common lot, subject to the findings (Exhibit A) and Conditions of Approval (Exhibit B) attached hereto and incorporated by this reference.

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 January 27, 2026 by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
___________________________
Sally Meadows, MAYOR
Attest:
_________________________________
Melissa Thurman, MMC, CITY CLERK

Resolution No. 2026-XX Page 3

EXHIBIT A

FINDINGS
With regard to the Vesting Tentative Map (Application No. TM22-0005), the City Council finds the following in accordance with Chapter 4, Article 1, Section 66474 of the Subdivision Map Act of the State of California:

1. The proposed subdivision is not consistent with applicable general and specific plans as specified in 65451.

This Finding cannot be made. The subdivision is consistent with the Los Altos General Plan, including the Neighborhood Commercial (NC) designation, which supports neighborhoodserving commercial uses with higher-density residential above the ground floor, and with the Loyola Corners Specific Plan. Relevant policies include Land Use Element Policies 1.1 and

2.2; Housing Element Policies 1.1 and 1.2; and Infrastructure and Waste Disposal Element Policies 1.3, 2.2, and 3.1.

2. That the design or improvement of the proposed subdivision is not consistent with applicable general and specific plans.

This Finding cannot be made. The design and improvements are consistent with the General Plan and the Commercial Neighborhood (CN) zoning district, as modified by the State Density Bonus Law. The project provides ground-floor commercial space and upper-floor housing, consistent with permitted uses, and allows for the creation of twelve (12) residential condominium lots, one (1) commercial condominium lot, and one (1) common lot.

3. That the site is not physically suitable for the type of development.

This Finding cannot be made. The site is physically suitable because it is consistent with the Neighborhood Commercial (NC) designation and Commercial Neighborhood (CN) zoning district (as modified by the State Density Bonus Law), and adequately accommodates vehicle, pedestrian, and bicycle circulation while meeting life-safety and service requirements.

4. That the site is not physically suitable for the proposed density of development.

This Finding cannot be made. The site is physically suitable for the proposed density because the General Plan Neighborhood Commercial (NC) designation supports higher-density residential uses and the project complies with Commercial Neighborhood (CN) zoning district, except as modified by the State Density Bonus Law, and is located in an urbanized area surrounded by similar uses.

5. That the design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.

Resolution No. 2026-XX Page 4
This Finding cannot be made. The subdivision will not cause substantial environmental damage or injury to wildlife or habitat. The project qualifies for a statutory exemption under Public Resources Code Section 21080.66 (AB 130). The site is substantially surrounded by urban uses, has no sensitive habitat, would not result in significant impacts related to traffic, noise, or air quality, and will be served by existing utilities and public services.

6. That the design of the subdivision or type of improvements is likely to cause serious public health problems.

This Finding cannot be made. The subdivision will not cause serious public health problems because the site is in an urbanized area served by existing infrastructure, including sewer, water, and electricity. Police and fire protection will continue to be provided by the Los Altos Police Department and Santa Clara County Fire Department.

7. That the design of the subdivision or the type of improvements will conflict with easements acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements, for access or for use, will be provided, and that these will be substantially equivalent to ones previously acquired by the public. This subsection shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or use of property within the proposed subdivision.

This Finding cannot be made. The design of the subdivision will not conflict with access easements because there are no known existing access easements encumbering this property.

8. That the project is not exempt from environmental review.

This Finding cannot be made. The project is statutorily exempt under Public Resources Code Section 21080.66 (AB 130) as a qualifying infill mixed-use housing development. The 0.20- acre site is within city limits, previously developed, consistent with the General Plan Neighborhood Commercial designation and Commercial Neighborhood (CN) zoning (as modified by the State Density Bonus Law), and served by utilities. The site is not located in an environmentally sensitive area, it is not a historic resource, and is more than 500 feet from a freeway. Tribal consultation has been completed, and environmental site assessments with required remediation will be completed prior to occupancy.

Resolution No. 2026-XX Page 5

EXHIBIT B

CONDITIONS OF APPROVAL

PLANNING DIVISION

1. Approved Plans: The project shall be developed in substantial compliance with the approved project plans, except as modified by these conditions as specified below.

2. Expiration: This Permit is valid for a period of two years and will expire on January 27, 2028, unless prior to the date of expiration, a building permit is issued, or an extension is granted pursuant to the procedures and timeline for extensions.

3. Revisions to the Approved Project: Minor revisions to the approved plans which are found to be in substantial compliance with the overall approvals may be approved by the Development Services Director.

4. Notice of Right to Protest: The conditions of project approval set forth herein include certain fees, dedication requirements, reservation requirements, and other exactions. Pursuant to Government Code Section 66020(d)(1), these conditions constitute written notice of a statement of the amount of such fees, and a description of the dedications, reservations, and other exactions. You are hereby further notified that the 90-day period in which you may protest these fees, dedications, reservations, and other exactions pursuant to Government Code Section 66020(a) began on the date of approval of this project. If you fail to file a protest within this 90-day period complying with all of the requirements of Section 66020, you will be legally barred from later challenging such exactions.

5. Indemnity and Hold Harmless: The applicant/owner agrees to indemnify, defend, protect, and hold the City harmless from all costs and expenses, including attorney’s fees, incurred by the City or held to be the liability of the City in connection with the City’s defense of its actions in any proceedings brought in any State or Federal Court, challenging any of the City’s action with respect to the applicant’s project. The City may withhold final maps and/or permits, including temporary or final occupancy permits, for failure to pay all costs and expenses, including attorney's fees, incurred by the City in connection with the City's defense of its actions.

6. Affordable Housing Agreements: All applicable affordable housing agreements for the project shall be executed and recorded on a form provided by the City to the satisfaction of the Development Services Director and City Attorney prior to the issuance of the final map

ENGINEERING DIVISION

7. Payment of Impact and Development Fees: The applicant shall pay all applicable fees, including but not limited to sanitary sewer connection and impact fees, parkland dedication in

Resolution No. 2026-XX Page 6
lieu fees, traffic impact fees, public art impact fee, and map check fee as required by the City of Los Altos Municipal Code prior to issuance of a building permit.

8. Encroachment Permit: An encroachment permit shall be obtained from the Engineering Division prior to doing any work within the public right-of-way including the street shoulder.

All work within the public street right-of-way shall be in compliance with the City’s Shoulder Paving Policy.

9. Americans with Disabilities Act: All improvements shall comply with Americans with Disabilities Act (ADA). The latest edition of Caltrans ADA requirements shall apply to all improvements in the public right-of-way. Compliance with all ADA requirements shall be shown on all building permit plans.

10. Public Utility Dedication: Prior to final map recordation the applicant shall dedicate public utility easements as required by the utility companies to serve the site.

11. Subdivision Agreement: The applicant shall sign and return Subdivision Improvement Agreement to the City for records and recordation prior to the recordation of the final map.

12. Final Map Recordation: The applicant shall record the final map. Building Permits shall not be issued until the final map is recorded. Plats and legal descriptions of the final map shall be submitted for review by the City Land Surveyor. Applicant shall provide a sufficient fee retainer to cover the cost of the map review by the City.

13. Condominium Map: The applicant shall record the condominium map as required by the City Engineer prior to final occupancy.

14. SWMP Certification: The applicant shall have a final inspection and certification done and submitted by the Engineer who designed the SWMP to ensure that the treatments were installed per design. The applicant shall submit a maintenance agreement to City for review and approval of the stormwater treatment methods installed in accordance with the SWMP. Once approved, City shall record the agreement.

15. Storm Water Management Plan: The Applicant shall submit a Storm Water Management Plan (SWMP) in compliance with the City of Los Altos Municipal Regional Stormwater (MRP)NPDES Permit. The SWMP shall be reviewed and approved by a City approved third party consultant at the Applicant’s expense. The recommendations from the Storm Water Management Plan (SWMP) shall be shown on the building permit plans.

16. Storm Water Filtration Systems: The applicant shall insure the design of all storm water filtration systems and devices are without standing water to avoid mosquito/insect infestation.

17. Sewer Lateral: Any proposed sewer lateral connection shall be approved by the City Engineer. Only one sewer lateral per lot shall be installed. All existing unused sewer laterals shall be abandoned according to the City Standards, cut and cap 12” away from the main.

Resolution No. 2026-XX Page 7

18. Public Improvements: Install or reconstruct standard public improvements along the project frontages of Miramonte Avenue and Loraine Avenue, as directed by the City Engineer.

Required improvements include curb, gutter, and a five-foot-wide sidewalk constructed to comply with City standards for concrete sidewalks. A landscaped strip or rain garden shall be provided along both frontages. The applicant shall design street improvements up to one half the width of Miramonte Avenue and Loraine Avenue, as directed by the City Engineer or designee.

19. New ADA Ramps and Crosswalks: The applicant shall provide two new ADA ramps and crosswalk striping per the City standards at the intersection with Miramonte Avenue and Loriane Avenue. The applicant shall also install new ADA ramps at each side of the driveway approach on Loriane Avenue.

PLANNING COMMISSION

STAFF REPORT
Meeting Date November 6, 2025
Subject 996 Loraine Avenue – Mixed-Use Development
Prepared by: Sean Gallegos, Senior Planner
Initiated by: 996 Loraine LLC, Applicant
Attachments:

1. Draft Resolution – Design Review and Conditional Use Permit

2. Draft Resolution – Vesting Tentative Map

3. Project Plans

4. Density Bonus Report

5. Public Comment Letters
Recommendation

1. Adopt a Resolution approving Design Review (Application No. D22-0013) and Conditional Use Permit (Application No. CUP22-0003) for the construction of a three (3) story, mixed-use development with twelve (12) residential units and 962 square feet of ground floor commercial space utilizing State Density Bonus with a concession and waivers at 996 Loraine Avenue, per the recommended findings and conditions of approval; and find the project is statutorily exempt from environmental review pursuant to Public Resources Code (PRC) Section 21080.66 - Attachment 1.

2. Recommend the City Council adopt a Resolution approving a Vesting Tentative Map (Application No. TM22-0003) to create thirteen (13) condominium lots and one (1) common lot at 996 Loraine Avenue, per the recommended findings and conditions of approval; and find the project is statutorily exempt from environmental review pursuant to Public Resources Code (PRC) Section 21080.66 - Attachment 2.

Background
Property Description
The approximately 0.2-acre project site is located on the southwest corner of Loraine Avenue and Miramonte Avenue. The project site is currently developed with an approximately 2,240 squarefoot, single-story commercial building, landscaping, andsurface parking spaces.

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Mixed-Use Development at 996 Loraine Avenue Page 2
Surrounding land uses include residences
to the north and west, a day care use to the
south, and along the east property line
Miramonte Avenue, with a single-family
residence and commercial uses (including
a U.S. Post Office) located across the
street.

Preliminary Application
A preliminary application under Housing
Crisis Act (SB 330) allows a developer to
“freeze” applicable fees and development
standards as of the submission date,
provided that a formal project application
is filed within 180 days and the project
scope remains substantially consistent. A
Preliminary application was filed on
December 22, 2021 and discussed by the
Planning Commission at a study session on
March 17, 2022. No formal application was filed within 180 days of the preliminary filing; therefore, the preliminary application is deemed expired under the SB 330. A new preliminary application pursuant to SB 330 was submitted by the developer on November 2, 2022.

Formal Application
On November 8, 2022, a formal application was submitted, within the required 180-day period of the preliminary application. Accordingly, the project is eligible to “freeze” the fees and standards in effect as of November 2, 2022. The project has been reviewed under the zoning regulations in effect at the time of project submittal and is subject to Design Review under former Chapter 14.78 of the Los Altos Zoning Code, as well as a Use Permit for mixed use development, and a Tentative Map under Chapter 14.44.

At its meeting of September 4, 2025, the Planning Commission continued this item after staff confirmed that the required public notice sign was not posted at the project site. The applicant has since posted the sign, meeting Planning Division site posting requirements.

Project Overview
The project proposes to demolish the existing one-story commercial building and construct a threestory, approximately 17,674 square foot mixed-use building. The new development provides 962 square feet of ground floor commercial space and twelve (12) multiple-family residential units on the two upper floors. The residential mix includes four (4) one-bedroom units and eight (8) twobedroom units, of which two (2) units will be affordable for low-income households. On site parking is provided at grade with sixteen (16) spaces, including twelve (12) for residents and four (4) for the commercial use (Attachment 3 – Project Plans).

Figure 1: Location Map

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Mixed-Use Development at 996 Loraine Avenue Page 3
Adjacent to the commercial space, the first floor contains 924 square feet of residential support facilities and a partially enclosed parking garage with sixteen (16) vehicle spaces. Long-term bicycle parking for five bicycles will be provided in a secure indoor storage room, and two shortterm bicycle spaces will be located outside the building.

The proposed building will have a contemporary mixed-use design that integrates high-quality, durable materials to provide visual interest, reduce the perception of mass, and reinforce its architectural character. At the ground level, the commercial space is designed with large dark bronze anodized aluminum storefront glazing framed by smooth troweled plaster in Dover White and Portico, accented with stone veneer to create an inviting and transparent commercial frontage along the street. Metal canopies and recessed entries establish a comfortable pedestrian scale and provide weather protection.

Figure 21: Perspective from Miramonte Avenue
The second and third floors will feature smooth plaster in Dover White, Portico, and Hammered Silver combined with horizontal stained wood siding, introducing warmth and texture to the upper levels. The building will be articulated through vertical and horizontal modulation, alternating materials, and changes in color tone to break up the building mass. Projecting balconies with metal railings will add depth and shadow, while varied window placement and balcony recesses will further enhance visual interest.

The roofline will be defined by sloped standing seam metal roofing and vertical metal siding in a muted gray finish, which will frame and partially screen mechanical areas. A level rooftop terrace will offer 1,824 square feet of landscaped resident amenity space.

The site design provides vehicle and pedestrian access while maintaining an active public frontage.

Pedestrian entries to the commercial space and residential lobby are from existing sidewalks along Miramonte Avenue. Streetscape improvements include new sidewalks, accessible curb ramps with truncated domes, and landscaped planters to enhance the transition from the public right of way to

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Mixed-Use Development at 996 Loraine Avenue Page 4
building entrances. Vehicular access is provided by a single full-access driveway on Loraine Avenue leading to the parking garage.

The project will remove three (3) existing trees on site, none of which meet the definition of a protected tree under Chapter 11.08.050 of the Municipal Code, while preserving four (4) trees on adjacent properties. Ground-level landscaping will feature ornamental shrubs, grasses, and flowering plants along the Loraine Avenue and Miramonte Avenue frontages, with raised planters at the building base and a six-foot-tall wood fence along the southern and western boundaries. In total, nine new trees will be planted at the ground level, contributing to shade, greenery, and visual interest along the public edges of the site.

The rooftop terrace will provide 1,824 square feet of landscaped resident amenity space, including planters with five (5) small ornamental trees, drought-tolerant shrubs, and flowering plants.

Seating areas, open gathering spaces, and integrated shade elements will create a comfortable and functional outdoor environment. Plantings are arranged to frame outward views, add privacy between seating areas, and soften the upper profile of the building when viewed from surrounding properties.

Mechanical equipment is located on the rooftop and screened from public view by mansard roof forms integrated into the building’s design. Trash and utility areas are enclosed within the building near the parking area, with an internal trash room on the lower floor.

Analysis
General Plan Consistency
The project is consistent with the General Plan’s Neighborhood Commercial (NC) Land Use Designation, which supports neighborhood-serving retail, service, commercial, and office uses.

The designation also encourages higher-density residential uses in appropriate locations to promote walkability and support local businesses. By providing ground-floor commercial space with residential units above, including affordable units, the project aligns with these objectives and contributes to a vibrant, pedestrian-oriented environment. The project will contribute towards the City’s Regional Housing Needs Assessment (RHNA) and is aligned with the City’s recently adopted 6th Cycle Housing Element by adding twelve (12) units to the City’s housing stock, two (2) of which will be low-income units.

The project complies with the following General Plan polices:
• LU Policy 1.1: Maintain flexibility of standards and procedures to accommodate changing trends in retail, housing, and office uses.
• LU Policy 2.3: Continue to conduct design review of residential and non­residential development applications to ensure compatibility with surrounding property and neighborhoods.
• LU Policy 3.1 Encourage residential development above the ground floor that includes affordable housing units.

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Mixed-Use Development at 996 Loraine Avenue Page 5
• LU Policy 4.2 Encourage mixed-use projects with retail, housing, and/or lodging in addition to retail and office uses.
• LU Policy 4.4 Encourage the development of affordable housing. • Housing Policy 1.1: The City will encourage a diverse range of both market-rate and affordable housing sizes and residential densities to accommodate the varied housing needs of families, couples, and individuals. • Housing Policy 1.2: The City will encourage mixed-use development in designated zoning districts.
• Housing Policy 2.1 The City will facilitate the development of new affordable housing units.

Zoning Consistency
The project complies with the Zoning Standards of the CN Zoning District, except as modified by State Density Bonus Law. An analysis of the project’s compliance with CN Standards is provided in the table below:

CN Zoning District Zoning Standards
Requirement Proposal Project Compliance
Density N/A 12 units (60du/ac) Project Complies
Front Setback 40’ at R Zones 0’ SDBL Waiver; additional information provided
under “Density Bonus
Request” section
Interior and
Exterior Side
Setback
40’ at R Zones 0’ SDBL Waiver; additional
information provided
under “Density Bonus
Request” section
Rear Setback 20’ 20’ Project Complies
Height 30’ 41’1” SDBL Concession;
additional information
provided under “Density
Bonus Request” section
Off-Street Parking Zoning Standards
Residential Use 16 spaces 12 spaces SDBL Waiver; additional information provided
under “Density Bonus
Request” section

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Mixed-Use Development at 996 Loraine Avenue Page 6
CN Zoning District Zoning Standards
Commercial Use 4 spaces 4 spaces Project Complies
Parking Space
Size, vertical
clearance and
back up space
Space size: At least 9’
by 18’
Aisle Width: for
perpendicular parking
with 26’ back up space
Space size of 9 feet
by 18 feet
Aisle Width: 26
feet
Project Complies
Bicycle Parking
Residential Use 1 Short-term (Class-II)
bicycle parking space.
4 Long-term (Class-I)
bicycle parking spaces
1 short-term (ClassII) bicycle space
4 long-term (ClassI) bicycle g spaces
Project Complies
Commercial Use 1 Short-term (Class-II)
bicycle parking space.
1 Long-term (Class-I)
bicycle parking space.
1 short-term (ClassII) bicycle space.
1 long-term (ClassI) bicycle space.

Project Complies
Under Senate Bill 330, the City’s review is limited to applying adopted objective standards.

Concerns regarding neighborhood character, precedent, aesthetic preferences, economic viability, and requests for optional studies are not enforceable absent measurable standards. Transportation, parking, rooftop operations, construction management, and public notice are addressed through existing objective thresholds, policies, and permit stage requirements, except as modified by State Density Bonus Law, which the project meets or will be required to meet as conditions of approval.

Objective Design Control Standards for CN Zoning District The project must comply with the City's Objective Design Control Standards, as outlined in Los Altos Municipal (LAMC) Sections 14.40.150 for the CN Zoning District and 14.66.280 for all multiple-family and mixed-use projects. Except for the Density Bonus waivers requested by the applicant to deviate from some of the objective standards, the project is found consistent with all objective design control standards. The waivers requested for the objective design control standards are provided under the “Density Bonus Request” section.

Density Bonus Request
The subject site has a gross lot area of 0.20 acres (8,898 square feet). The Neighborhood Commercial (NC) General Plan designation and zoning district do not specify a maximum dwelling unit density. Consistent with California’s Density Bonus Law (Government Code Section

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Mixed-Use Development at 996 Loraine Avenue Page 7
65915 et seq.), the base density is therefore determined in accordance with LAMC Section

14.28.050.2, which calculates density based on a hypothetical code-compliant development using an average unit size consistent with the proposed project.

The project’s base density was calculated assuming a development consistent with all applicable standards, resulting in a base density of 39 dwelling units per acre, or eight (8) units for the site.

Under California’s Density Bonus Law (Government Code Section 65915), the applicant proposes two low-income units, which qualifies the project for a 50 percent density bonus. This allows four (4) additional units, for a total of twelve units on the site. A Density Bonus Report (Attachment 4) has been submitted documenting compliance with state and local requirements, including the requested concession and waivers.

Concession
The applicant requests a single density bonus concession under LAMC §14.44.120 to increase the maximum building height in the Neighborhood Commercial (CN) district from 30 feet to 41 feet, as shown in the project plans. The additional height is needed to accommodate two residential stories above the ground floor, achieve the project’s density objectives, and include affordable units consistent with State Density Bonus Law. The request qualifies as an “on-menu” concession under the LAMC.

Waivers
Under the Density Bonus Law, eligible projects may request unlimited waivers of development standards. The requested waivers are necessary to avoid physical preclusion of the project as proposed, including the density bonus and required affordable units. All other applicable objective standards are met. The applicant requests seven such waivers, described below.

1. Front Setback: LAMC §14.40.080 requires a minimum front yard setback of 40 feet when a site is located across from a residential district. The project proposes a zero-foot front setback, as shown on plans. The required setback would reduce the developable area by approximately 6,942 square feet (2,314 square feet per floor), substantially limiting the building envelope and preventing the project from achieving the permitted density.

2. Side Yard Setback: LAMC §14.40.090 requires a minimum side yard setback of 40 feet for sites across from a residential district. The project proposes a zero-foot side yard setback, as shown on plans. Compliance would reduce the developable area by approximately 8,142 square feet (2,714 square feet per floor), significantly decreasing the building envelope and precluding the proposed density.

3. Third Story Step-back: LAMC §14.40.150.B.1.a requires a minimum 10-foot step-back from the ground floor façade for upper stories exceeding 30 feet in height along front and street sides. The project proposes a step-back less than 10 feet, as shown on plans. Compliance would reduce the developable area by approximately 1,087 square feet, limiting residential unit layout and density.

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4. Third Story Step-back: LAMC §14.40.150.B.2.a requires a minimum 10-foot step-back for the third story when adjacent to an R-1 district. The project proposes a step-back less than 10 feet, as shown on plans. Compliance would reduce the developable area by approximately 1,300 square feet, constraining building design and unit count.

5. Building Recesses: LAMC §14.40.150.B.5.a.ii requires building recesses at least 10 feet wide by 15 feet deep for exterior façades longer than 48 feet abutting an R-1 district. The project proposes to omit or reduce recess dimensions, as shown on plans. Compliance would reduce the developable area by approximately 1,350 square feet (450 square feet per floor), decreasing usable floor space and residential density.

6. Orientation of Principal Windows and Balconies: LAMC §14.40.150.B.6.a/b requires that principal windows and balconies of living spaces along a side setback be oriented toward the front or rear of the building. The project proposes to orient certain living spaces and balconies toward the side yard to maintain functional layouts. Due to site constraints and interior layout needs, compliance would require eliminating balconies and reducing private open space by 238 square feet (119 square feet per residential floor), making it infeasible without reducing unit count.

7. Parking and Loading Space Requirements: LAMC §14.74 requires the provision of parking and loading spaces consistent with zoning standards. The project proposes providing parking at ratios shown on plans, which are below standard requirements. Compliance would require 21 parking spaces and providing these spaces while meeting setback standards would limit the project to 8 units, thereby eliminating 4 units and undermining the affordable housing objective.

Subdivision
The project includes a Vesting Tentative Map for condominium purposes. The subdivision will divide the site into twelve (12) individual residential condominium units, one (1) commercial condominium unit, and a common lot. The subdivision conforms to the General Plan, Subdivision Ordinance, and provisions of the Subdivision Map Act as substantiated in the Draft Resolution recommending approval of the Vesting Tentative Map (Attachment 2).

Bankers Hill 150 v. City of San Diego
Bankers Hill 150, the developer (Greystar), applied to construct a 20-story mixed-use project, at a building height of 223 feet, that would include 204 dwelling units, office space, a large courtyard, and underground parking. The proposed project qualified as a Density Bonus project because it set aside 18 dwelling units as affordable for very low-income residents. Accordingly, the City of San Diego granted Greystar a density bonus to exceed the zone’s maximum density of 147 units, as well as incentives to exceed the City’s 65-foot building height limit, eliminate requirements for a 15-foot setback and on-site truck loading and reduce private storage areas.

Two community groups, Bankers Hill 150 and Bankers Hill/Park West Community Association, filed a petition for writ of mandate challenging the City’s approval of the project application, alleging that the project is inconsistent with the City’s development standards for that

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Mixed-Use Development at 996 Loraine Avenue Page 9
neighborhood. The trial court denied the Association’s writ petition because it fatally failed to address the application of the Density Bonus Law.

The Court of Appeal affirmed the trial court’s denial of the writ petition. The court emphasized that, under the Density Bonus Law, absent very limited exceptions, the project is entitled to the waiver of any development standards that would have precluded the project’s construction as designed, including those with which the Association alleged the project is inconsistent.

Furthermore, the waiver or reduction in development standards is in addition to the incentives and concessions mandated by the Density Bonus Law.

The Association argued that the project could be redesigned to yield a shorter and less bulky building by eliminating a courtyard. Reaffirming the holding in Wollmer v. City of Berkeley (2011) 193 Cal.App.4th 1329, the court rejected the Association’s argument. According to the court, the City could not demand that Greystar redesign its building to better meet City development standards even if a design existed that would allow fewer deviations from the City’s requirements.

Housing Accountability Act (HAA)
The Housing Accountability Act (HAA) (Government Code Section 65589.5), establishes the state’s overarching policy that a local government may not deny, reduce the density of, or make infeasible housing development projects (projects resulting in more than two (2) housing units or resulting parcels) which includes subdivision of land that are consistent with objective local development standards. Before doing any of those things, local governments must make specified written findings based upon a preponderance of the evidence that a specific, adverse health or safety impact exists. Legislative intent language indicates that the conditions that would give rise to such a specific, adverse impact upon the public health and safety would occur infrequently.

The proposed project is protected under the Housing Accountability Act (HAA) as it creates additional housing stock within the City of Los Altos. Additionally, the proposed project meets all applicable objective design standards, except as modified by State Density Bonus Law.

Environmental Review
On June 30, 2025, Governor Newsom signed Assembly Bill 130 (AB 130), which included a new statutory exemption for qualifying housing projects. AB 130 became effective on June 30, 2025, and is codified in the Public Resources Code (PRC) Section 21080.66.

The proposed mixed-use project meets the requirements for this exemption. The 0.2-acre site is infill, surrounded by urban uses, previously developed, and contains no sensitive habitat or historic resources. The project is consistent with the General Plan and Commercial Neighborhood (CN) zoning as modified through the State Density Bonus Law (SDBL) and is not located in any environmentally sensitive area identified in PRC Section 21080.66(a)(6). Tribal consultation has

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been completed, environmental site assessments are prepared, and any required remediation will be completed.

Under Senate Bill 743, transportation effects under CEQA are evaluated using vehicle miles traveled (VMT). A screening memo prepared by Hexagon Transportation Consultants confirms that the project is screened out under the City’s VMT Policy; therefore, transportation impacts are presumed less than significant and a detailed VMT analysis is not required.

The City retains the existing level of service policy in the General Plan and continues to require development projects to conduct non-CEQA transportation analyses to evaluate and manage a project’s adverse effects on local roadways by imposing conditions related to operational improvements during the project review and permitting phases. Under the adopted City policy, a Local Transportation Analysis (LTA) is required for projects adding 50 or more net new daily trips. A trip generation memo was prepared by Hexagon Transportation Consultants and found the project results in an estimated net decrease of approximately five daily trips from the existing on site commercial use, so an LTA is not required and no site-specific operational intersection analysis is required. The project includes no roadway capacity expansions or other features that would induce additional trips and construction traffic will be managed through a construction management plan and any required encroachment permits.

Public Notification
A public meeting notice was mailed to property owners and commercial business tenants within (300) feet of the project site and published in the newspaper. The applicant also posted the site with a public notice sign in conformance with the Planning Division posting requirements.

At the time of preparation of this report, the Planning Division received four written public comment letters for the September 4, 2025 hearing that was continued: three individual letters and one collective objection letter signed by eight nearby residents and are included as Attachment #5.

Next Steps
The Planning Commissions decision on the Design Review and Conditional Use Permit applications are final. The Planning Commission’s consideration and recommendation on the Vesting Tentative Map application will be forwarded to Council for consideration at a future meeting and will be noticed separately.

City Council Staff Report
Meeting Date: January 27, 2026
Prepared By: Sean Gallegos
Approved By: Gabe Engeland
Subject: Appeal of Development Project at 4898 El Camino Real

COUNCIL PRIORITY AREA
Housing
General Government

RECOMMENDATION
Adopt a Resolution denying Appeal No. APPL25-0006 and upholding the Planning Commission’s approval of a Design Review and Conditional Use Permit with a State Density Bonus for an eight-story, 85-unit multifamily housing development at 4898 El Camino Real; and find the project is categorically exempt pursuant to Section 15332 of the California Environmental Quality Act (CEQA) Guidelines, and that none of the exceptions outlined in Section 15300.2 apply

ENVIRONMENTAL IMPACT
The project is categorically exempt pursuant to Section 15332 (Class 32) of the California Environmental Quality Act (CEQA) Guidelines because (1) the project is consistent with the General Plan and Zoning Ordinance; (2) occurs within city limits on a project site of no more than 5 acres substantially surrounded by urban uses; (3) is located on a site that does not have value as habitat for endangered, rare, or threatened species; (4) would not result in any significant impacts relating to traffic, noise, air quality, or water quality; and (5) is adequately served by all required utilities and services. Additionally, none of the exceptions listed in CEQA Guidelines Section 15300.2 apply to the project. A detailed analysis and supporting documentation for the CEQA exemption is provided in Attachment 2.

FISCAL IMPACT
None.

PREVIOUS COUNCIL CONSIDERATION
On October 1, 2019, the City Council adopted Resolution No. 2019-42 approving a Design Review Permit, Conditional Use Permit, and Tentative Map for a five-story multifamily residential development consisting of twenty-eight (28) units under the State Density Bonus Law. The project approval expired on October 1, 2022.

On November 18, 2025, the City Council approved a Vesting Tentative Map (TM25-0001) at 4898 El Camino Real. That action is not the subject of the current appeal.

BACKGROUND
Planning Commission Review
The Planning Commission considered the project at a public hearing on November 6, 2025.

Following staff presentation, public testimony, and deliberation, the Commission unanimously approved the Design Review Permit and Conditional Use Permit, found the project categorically exempt pursuant to CEQA Guidelines Section 15332, and adopted the required findings and conditions of approval.

In a separate unanimous action, the Planning Commission recommended that the City Council approve a Vesting Tentative Map (Application No. TM25-0001) creating 85 condominium lots and one common lot at 4898 El Camino Real and find the map categorically exempt under CEQA Guidelines Section 15332.

Public testimony raised concerns related to project height and scale, traffic conditions, Jordan Avenue access, loading operations, and the Transportation Impact Analysis, while other speakers expressed support based on the need for additional housing.

The Planning Commission’s November 6, 2025 actions and findings are documented in the staff report and Resolution No. PC25-04, included as Attachments 3 and 4.

Appeal of the Planning Commission’s Action
Pursuant to Los Altos Municipal Code Section 14.01.100, a decision rendered under regulations contained within Title 14 (Zoning) of the Los Altos Municipal Code by the Planning Commission may be appealed by the applicant, the City Council, any property owner or resident of property within a three-hundred (300) foot radius of the subject property. Appeals of decisions by the Planning Commission shall be heard by the City Council; the decision of appeal by the City Council is final.

Additionally, pursuant to Los Altos Municipal Code Section 14.77.120, the basis for any appeal of a housing development shall only be allowed and based on objective standards consistent with state law. A housing development as defined by law shall constitute any development which includes two or more residential units within a proposed project. This project is a housing development as defined by state law.

The City received a timely appeal of the project from a resident living within 300 feet of the project site on November 17, 2025. Supplemental appeal documents were submitted by the appellant on January 16, 2026. All appeal documents are included as Attachment 5.

The applicant submitted a written response addressing the appeal and is included as Attachment

6. ANALYSIS

Design Review and Conditional Use Permit
The project includes a Design Review Permit (D25-0004) for architectural approval and a Conditional Use Permit (CUP25-0001) for a new eight-story, 85-unit multifamily residential development with associated on-site and off-site improvements (Attachment 7 – Project Plans).

The site design provides pedestrian-oriented access and circulation while maintaining an active frontage along El Camino Real and Jordan Avenue. Pedestrian entries to the residential lobby are located along El Camino Real, with additional access from Jordan Avenue and the rear of the building. Streetscape improvements include new sidewalks, street trees, landscaped planters, and accessible curb ramps, enhancing the transition between the public right-of-way and building entrances. Vehicular access is provided from Jordan Avenue to the underground automated parking garage.

The ground floor includes the residential lobby and support areas, the primary building entry, and an entrance for a fully underground automated parking garage providing ninety-five (95) vehicle spaces. Bicycle parking is provided with long-term storage for ninety-eight (98) bicycles in a secure room, twenty (20) Class I bicycle spaces within the automated parking system, and five (5) Class II outdoor bicycle spaces located near the building entry.

The proposed building has a contemporary architectural design that incorporates smooth plaster in light and dark tones, fiber cement panels, and stone veneer accents to provide visual interest and reduce the perception of mass. At the ground level, aluminum storefront glazing framed by plaster columns and stone bases creates a transparent and active frontage along El Camino Real.

Recessed and projecting balconies, vertical bays, and metal canopies further articulate the façades, reinforce a pedestrian scale, and highlight building entries. The upper residential levels are finished with a combination of smooth stucco, composite fiber panels in wood and neutral tones, and cultured stone veneer, complemented by black-framed aluminum windows and metal railings. The roofline is defined by a parapet with cornice detailing that frames the building and screens rooftop elements. Behind the parapet, a landscaped rooftop deck provides resident amenity space.

The project site is currently vacant and contains no protected trees. New ground-level landscaping will feature a mix of ornamental shrubs, grasses, and flowering plants along the El Camino Real and Jordan Avenue frontages, with planters at the building base. A total of seven (7) new street trees will be planted at the ground level, consisting of three (3) Chinese Pistache trees along El Camino Real and four (4) Maidenhair (Ginkgo biloba) trees along Jordan Avenue, contributing to shade and visual interest along the streetscape.

Density Bonus
State Density Bonus Law allows housing developments with qualifying affordable units to receive additional density, waivers of development standards that would otherwise physically preclude construction at the permitted density, and incentives to reduce the cost of providing affordable housing.

The applicant proposes to restrict ten very low-income units, representing 20 percent of the 50- unit base density. Under Government Code section 65915(f)(2) and Los Altos Municipal Code (LAMC) Chapter 14.28, Table B, this qualifies the project for a 50 percent density bonus, adding 25 units for a total of 75 units. Because the project also exceeds the five percent very low-income threshold under Government Code section 65915(v), it qualifies for an additional 20 percent bonus, resulting in a maximum of 85 units.

The project’s approved density and associated density bonus calculations are documented in the Density Bonus Report submitted by the applicant (Attachment 8), which also identifies the waivers to accommodate the project at the permitted density while including the required affordable units.

Under the Density Bonus Law, eligible projects may request unlimited waivers of development standards. Waivers modify zoning or site development requirements that would otherwise physically preclude construction of the project, including the affordable and density bonus units.

The applicant requests sixteen waivers, including front yard setback; interior and exterior side yard setbacks; rear yard setback; building height; upper-story step backs; vertical façade articulation; façade entrance requirements; privacy and line-of-sight; parapet segment length; pedestrian-scaled entrances; interior side yard landscaping; rear yard landscaping; driveway landscaping; transformer fence adjacent to the driveway; and loading space location.

State Density Bonus Law provides limited discretion to deny requested waivers only where the required statutory findings cannot be made. The Planning Commission reviewed the applicant’s waiver requests and adopted findings for the waivers consistent with those requirements. With the approved waivers and density bonus, the proposed project is consistent with applicable development standards as modified by State law.

Appellants Reason for Appeal
The appellant’s reason for appeal filed with the City of Los Altos is attached as Attachment 5 to this report. For organizational clarity, staff structured the analysis to address the issues raised in the appeal under five topic areas. Several appeal arguments overlap or rely on the same statutory standards; therefore, related claims are addressed together rather than on a point-by-point basis.

1. State Housing Law, Density Bonus Law, and Required Findings for Denial The appeal asserts that the City retained discretion under State housing law to deny or substantially modify the project. State housing law, including the Housing Accountability Act and related statutes, establishes a presumption in favor of qualifying housing development projects and strictly limits the circumstances under which a city may deny a project or reduce approved density. Senate Bill 330 further restricts local discretion by prohibiting the application of development standards adopted after a housing development application is deemed complete.

Based on these statutory constraints, the City may only deny the project or reduce the approved density if the required written findings can be made.

The appeal further contends that the City failed to apply the required findings standards when

approving the project. Under State law, denial of a housing development project or reduction of approved density is permitted only where the City adopts written findings, supported by a preponderance of the evidence, demonstrating that one or more of the following conditions exist:
• The city has met or exceeded its regional housing needs allocation for the applicable income category and additional housing is not needed.
• The project would result in a specific, adverse impact on public health or safety, and there is no feasible method to satisfactorily mitigate or avoid that impact other than denial or a reduction in density.
• The project would violate specific State or federal law, and there is no feasible method to comply without rendering the project infeasible.
• The project is proposed on land zoned for agriculture or resource preservation, or the site lacks adequate water or wastewater service.
• The project is inconsistent with both the General Plan and zoning regulations in effect at the time the application was deemed complete, and the site was not identified for housing in the Housing Element.

These findings must be based on objective, written standards in effect at the time the application was deemed complete and may not rely on subjective concerns, speculation, or disagreement with State housing policy. Staff evaluated the appeal against each required finding and determined that none can be supported by the evidence presented.

The appeal relies primarily on assertions that the project would result in public health and safety impacts sufficient to justify denial and that the City failed to adequately evaluate such impacts prior to approval. State law defines a “specific, adverse impact on public health or safety” narrowly as an impact that is significant, quantifiable, direct, unavoidable, and based on objective, identified written public health or safety standards in effect at the time the application was deemed complete. Generalized concerns, design preferences, or disagreement with the scale or intensity of development do not satisfy this standard.

Applying this standard, the project was reviewed by City departments and external agencies with jurisdiction over public health, safety, and infrastructure, each of which evaluated the project for compliance with applicable objective standards and identified conditions of approval where appropriate. Based on this review, staff determined that no reviewing agency identified a significant, quantifiable, direct, and unavoidable public health or safety impact that would support denial of the project or reduction of approved density.

Based on the applicable State housing law framework and the evidence before the City, the required findings to deny the project or reduce the approved density cannot be made.

Accordingly, the appeal does not identify a lawful basis under State housing law to deny the project or condition approval in a manner that would reduce the approved density.

2. Base Density Determination and Density Bonus Waivers

The appeal contends the base density of 50 units is arbitrary and unsupported and that the requested density bonus waivers are based on design preference rather than physical necessity.

The appeal further asserts the project could be redesigned to comply with development standards without the requested waivers.

The Thoroughfare Commercial General Plan land use designation and Commercial Thoroughfare (CT) zoning district do not establish a numeric residential density limit. Where no fixed density applies, State Density Bonus Law and the Los Altos Municipal Code require the City to determine a base density using a hypothetical development scenario that reflects realistic development capacity and compliance with applicable objective standards. Applying the base density methodology required by State Density Bonus Law and the Los Altos Municipal Code, the applicant established a base density of 50 dwelling units. The provision of ten very lowincome units qualifies the project for density bonus incentives, resulting in 85 total units. The appeal does not provide technical or site-specific evidence demonstrating that the base density determination is legally unsupported.

The project proposes waivers from sixteen development standards that, if strictly applied, would physically preclude construction at the permitted density. The appeal contends that the waivers reflect design preference or economic considerations and that the project could be redesigned to comply. However, the applicable legal standard is whether strict application of the development standards would physically preclude construction at the permitted density, not whether an alternative design could theoretically be conceived. As reflected in the Density Bonus Report and the Planning Commission’s adopted findings, the requested waivers are supported by analyses demonstrating unit loss or physical infeasibility, and the appeal does not provide sitespecific architectural or engineering evidence rebutting those findings.

In Bankers Hill 150 v. City of San Diego, the court held that density bonus waivers must be granted where application of a development standard would physically preclude construction of the project at the permitted density, even if the project could theoretically be redesigned to comply with the standard. Similarly, in Schreiber v. City of Los Angeles, the court confirmed that local agencies may not deny waivers or impose additional evidentiary burdens based on alternative design preferences.

These court cases confirm that a city may only refuse a waiver or reduction of development standards for the limited statutory reasons (specific adverse impacts on health/safety/environment, impacts on historic resources, or conflict with state/federal law) and not based on optional design considerations or the idea that the project could be redesigned without waivers. In other words, the City cannot deny a waiver simply because another design might avoid it, as that would impose an extra evidentiary/design burden not authorized under the State Density Bonus Law.

Consistent with this legal framework, the Planning Commission appropriately granted the requested waivers and adopted findings demonstrating that strict application of the development standards would physically preclude construction of the project at the permitted density. The base density and resulting density bonus were established in accordance with State Density Bonus Law and the Los Altos Municipal Code. The appeal does not provide a lawful basis to

deny or condition approval in a manner that would reduce the approved density.

3. Transportation, Circulation, and Public Safety
The appeal asserts the Transportation Impact Analysis (TIA) (Attachment 9) is inadequate and invalid due to alleged deficiencies in professional qualifications, data timeliness, study scope and methodology, including school-related peak conditions, intersection coverage, trip generation, neighborhood cut-through traffic, pedestrian and bicycle safety, and analysis of site access, automated parking, and loading operations.

The TIA was prepared by Stephen Abrams, a California-licensed Traffic Engineer, in accordance with City standards and accepted professional practice. Traffic counts were collected in April 2024 while local schools were in session and reflect weekday AM and PM peak-hour conditions consistent with the City’s Local Transportation Analysis requirements. City standards do not require a separate school-peak analysis for residential projects without school or daycare use, and no site-specific conditions were identified that would warrant such analysis.

Accordingly, the traffic data and study methodology comply with adopted City requirements.

Study intersections were selected in coordination with City staff and are consistent with City guidelines. The analysis evaluated traffic conditions at key intersections along El Camino Real, North San Antonio Road, Jordan Avenue, and the project driveway, which represent the primary access routes serving the site. City staff determined that the selected intersections adequately capture potential project-related traffic impacts.

Traffic operations were analyzed under existing, existing-plus-project, cumulative (2040), and cumulative-plus-project (2045) conditions using the Highway Capacity Manual (6th Edition) Level of Service methodology with Synchro software. Except for the Jordan Avenue and North San Antonio Road intersection which operates at LOS F under existing conditions, the study intersections are projected to operate at acceptable levels of service with project traffic.

Consistent with accepted practice, the project also does not cause or measurably worsen existing failing conditions.

Trip generation was calculated using the ITE Trip Generation Manual (11th Edition) in accordance with City standards. The applied rates and calculations are appropriate and correctly distinguish between project trips used for analysis and net new trips from a previous use provided for informational purposes. The TIA evaluated neighborhood traffic conditions and found that project-related increases on Jordan Avenue would be minimal and below levels typically associated with cut-through traffic.

Pedestrian, bicycle, and transit conditions were evaluated, including sidewalks, crosswalks, signals, and driveway locations. The City’s Land Use (Engineering) Division reviewed the proposed frontage improvements and found them compliant with applicable standards, subject to building permit verification. The analysis concluded that the project would not create safety hazards or degrade pedestrian or bicycle conditions. The addition of a new sidewalk along Jordan Avenue will further improve pedestrian connectivity and safety.

Concerns related to site access, automated parking, and loading operations were also evaluated.

The TIA determined that the project driveway would operate acceptably, with adequate sight distance and on-site queuing. Parking operations and loading activity are addressed through Conditions of Approval requiring City-reviewed Parking Management and Loading and Delivery Management Plans prior to building permit issuance.

Based on the TIA, none of the issues raised in the appeal meets the statutory standard to deny the project. Further review at the building permit stage of detailed construction and engineering documents based on approved preliminary plans constitutes routine, ministerial enforcement of adopted codes and does not represent deferred discretionary review. Accordingly, the appeal does not provide a lawful basis to deny or condition approval in a manner that would reduce the approved density.

4. Parking, Loading, Accessibility, and Life-Safety Considerations The appeal challenges the application of Assembly Bill 2097 (AB 2097), the adequacy of the parking supply, the Conditional Use Permit findings for the automated parking system, the loading configuration, and compliance with accessibility and fire safety requirements.

AB 2097 prohibits local agencies from imposing minimum automobile parking requirements on qualifying housing developments located within one-half mile of a major transit stop. The project site is located within one-half mile of a major transit stop at El Camino and Showers Drive and therefore meets the statutory criteria for parking preemption; accordingly, the City may not require a minimum number of parking spaces. Notwithstanding this limitation, the project proposes 95 on-site parking spaces provided through an automated mechanical parking system, which was evaluated for adequacy and operational safety through the TIA and Conditional Use Permit review.

Loading operations, parking management, and site circulation were evaluated through the project review and are governed by conditions of approval, while the automated parking system was evaluated through the Conditional Use Permit review. The appeal’s concerns regarding potential system failures during outages or peak demand are speculative and are not supported by evidence demonstrating a public health or safety impact. The TIA evaluated site access and parking-related queuing and found no traffic or safety impacts. Condition No. 24 requires a Loading and Delivery Management Plan, and Condition No. 23 requires a Parking Management Plan governing parking operation.

The appeal also asserts that the project would create a noncompliant sidewalk and driveway conditions under the Americans with Disabilities Act (ADA) and California Building Code (CBC). The City’s Land Use (Engineering) Development Division reviewed the preliminary plans and identified no ADA or CBC violations, with ADA compliance further ensured through Condition No. 44. Construction drawings submitted as part of the building permit submittal will be reviewed for all ADA and CBC compliance including, but not limited to, passing spaces, turning areas, obstructions, and driveway transitions.

The appeal further asserts that the sidewalk along Jordan Avenue would function as a

noncompliant shared-use path. The installation of a new sidewalk on Jordan Avenue connecting to existing sidewalks to the north and south will increase pedestrian safety and comply with all accessibility requirements. Under the Los Altos Complete Streets Master Plan, Jordan Avenue is identified as a Class III bicycle route, which accommodates bicyclists within the vehicular travel way. The project provides a sidewalk along Jordan Avenue in compliance with applicable accessibility standards and does not create a noncompliant shared-use condition.

The project was reviewed by the Santa Clara County Fire Department and the City of Los Altos Planning, Building, Transportation Services, and Land Use (Engineering) Development divisions. Each department confirmed compliance with applicable objective life-safety and accessibility standards or imposed conditions of approval for modifications to the plans to ensure compliance prior to occupancy. Fire Department review of the project’s height, density, and emergency access did not identify any deficiency that would preclude emergency response.

Compliance with the CBC California Fire Code, and ADA is mandatory and enforced through the City’s plan check and inspection process. These requirements are not waived by project approval. A review of detailed system design at the building permit stage constitutes enforcement of adopted codes and does not represent deferral of discretionary review or abdication of responsibility. The appeal does not provide a lawful basis to deny or condition approval in a manner that would reduce the approved density.

5. CEQA – Class 32 Infill Development Exemption
The appeal asserts the project does not qualify for a Class 32 infill exemption due to traffic impacts, zoning inconsistencies created by density bonus waivers, and alleged unusual circumstances related to project height, scale, and proximity to schools.

The appeal’s assertions that CEQA Categorical Exemption Section 15332 was improperly applied are incorrect and lack evidentiary support. As supported in the detailed analysis and supporting documentation for the CEQA exemption provided in Attachment 2, the project is categorically exempt pursuant to Section 15332 of the CEQA Guidelines because the project (1) is consistent with the General Plan and Zoning Ordinance; (2) occurs within city limits on a project site of no more than 5 acres substantially surrounded by urban uses; (3) is located on a site that does not have value as habitat for endangered, rare, or threatened species; (4) would not result in any significant impacts relating to traffic, noise, air quality, or water quality; and (5) is adequately served by all required utilities and services. Additionally, none of the exceptions listed in CEQA Guidelines Section 15300.2 apply to the project.

DISCUSSION
See the Analysis Section above.

ATTACHMENTS

1. Attachment 1 - Resolution

2. Attachment 2 - CEQA Exemption Memorandum

3. Attachment 3 - November 6, 2025 Planning Commission Staff Report

4. Attachment 4 - Planning Commission Resolution PC25-04

5. Attachment 5 - Appeal Documents

6. Attachment 6 - Applicant Response to Appeal Letter

7. Attachment 7 - Project Plans

8. Attachment 8 - Density Bonus Report

9. Attachment 9 - Transportation Impact Analysis

10. Attachment 10 - Public Comments

RESOLUTION NO. ____

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS DENYING APPEAL NO. APPL25-0006 AND UPHOLDING THE PLANNING COMMISSION’S

APPROVAL OF A DESIGN REVIEW AND CONDITIONAL USE PERMIT WITH A STATE DENSITY BONUS FOR AN EIGHT-STORY, 85-UNIT MULTIFAMILY HOUSING DEVELOPMENT AT 4898 EL CAMINO REAL
WHEREAS, the City of Los Altos received an application for a housing development project at 4898 El Camino Real proposing an eight-story multifamily residential building consisting of 85 dwelling units, including ten very low-income below market rate units, with associated site improvements, parking, and loading facilities (the “Project”); and WHEREAS, the Project is located within the Commercial Thoroughfare zoning district and Thoroughfare Commercial General Plan land use designation and is subject to review under applicable provisions of the Los Altos Municipal Code, State Density Bonus Law, Senate Bill 330, and the Housing Accountability Act; and
WHEREAS, the Project qualifies as a housing development under State Density Bonus Law and includes very low-income units, making it eligible for density bonuses, waivers, incentives, and parking reductions as provided by State law; and WHEREAS, the City Council further finds that the Project is subject to, and has been reviewed for compliance with, the Housing Accountability Act (Government Code section 65589.5), State Density Bonus Law (Government Code section 65915), and Senate Bill 330 (Government Code section 66300 et seq.). These statutes limit the City’s discretion to deny, condition, or reduce the density of qualifying housing developments that comply with applicable objective standards in effect at the time the application was deemed complete; and WHEREAS, consistent with State Density Bonus Law, the Project’s use of approved density bonuses, waivers, incentives, and parking reductions does not render the Project noncompliant with objective zoning or development standards. Where waivers are granted pursuant to Government Code Section 65915, the Project is considered compliant with applicable objective standards as modified by State law; and WHEREAS, on November 6, 2025, following a duly noticed public hearing, the Planning Commission adopted Resolution No. 2025-04 approving a Design Review Permit and Use Permit with a State Density Bonus for the Project, subject to conditions of approval; and WHEREAS, a timely appeal of the Planning Commission’s approval was filed pursuant to Los Altos Municipal Code Chapter 14.01; and
WHEREAS, the City Council conducted a duly noticed public hearing on the appeal, reviewed the complete administrative record, and heard testimony from all interested parties; and

WHEREAS, the project is categorically exempt pursuant to Section 15332 (Class 32) of the California Environmental Quality Act (CEQA) Guidelines because (1) the project is consistent with the General Plan and Zoning Ordinance; (2) occurs within city limits on a project site of no more than 5 acres substantially surrounded by urban uses; (3) is located on a site that does not have value as habitat for endangered, rare, or threatened species; (4) would not result in any significant impacts relating to traffic, noise, air quality, or water quality; and (5) is adequately served by all required utilities and services. Additionally, none of the exceptions listed in CEQA Guidelines Section 15300.2 apply to the project; and WHEREAS, the finding and conclusions made by the City Council in the Resolution are based upon the oral and written evidence presented as well as the entirety of the administrative record for the proposed Project, which is incorporated herein by this reference; and WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos does hereby adopt a Resolution of the City Council of the City of Los Altos denying Appeal No. APPL25-0006 and upholding the Planning Commission’s approval of a Design Review and Conditional Use Permit with a State Density Bonus for an eight-story, 85-unit multifamily housing development at 4898 El Camino Real; and find the project is categorically exempt pursuant to Section 15332 the California Environmental Quality Act (CEQA) Guidelines, and that none of the exceptions outlined in Section 15300.2 apply, subject to the findings (Exhibit A) and conditions of approval (Exhibit B) attached hereto and incorporated by this reference.

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 twenty-seventh day of January 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

_______________________
Sally Meadows, MAYOR
Attest:
_________________________________
Melissa Thurman, MMC, CITY CLERK

EXHIBIT A

FINDINGS
Design Review
With regard to the design review for the Project, the City finds the following pursuant to Section

14.77.070 of Los Altos Municipal Code (LAMC):

A. The proposal meets the goals, policies, and objectives of the General Plan and any objective design guidelines or standards and ordinances adopted for the specific district or area because the project implements the Thoroughfare Commercial (TC) land use designation by providing a high-density residential development along El Camino Real that promotes walkability, supports nearby businesses, and provides housing near transit and services. The project meets all applicable zoning and design standards, except where deviations are granted through waivers under State Density Bonus Law to accommodate affordable housing consistent with Government Code Section 65915.

B. The proposed structure has been designed to follow the natural contours of the site with minimal grading, minimal impervious cover, and maximum erosion protection because the 0.43-acre infill site is flat and previously developed. The project utilizes podium construction, landscaped planters, and stormwater treatment areas to reduce impervious surface coverage while maintaining compliance with stormwater management and drainage requirements.

C. Building mass has articulated architectural elements or features that relate to the human scale, both horizontally and vertically. Building elevations have variation and depth and avoid large blank wall surfaces. Residential or mixed-use residential projects incorporate elements that signal habitation, such as identifiable entrances, stairs, porches, bays and balconies because the project features recessed and projecting balconies, defined bays, and varied window groupings that create depth and break up the massing. Alternating materials, parapet detailing, and clearly identifiable residential entries further emphasize human scale and visual interest consistent with Objective Design Standards for the TC District.

D. Exterior materials and finishes convey high quality, integrity, permanence and durability, and materials are used effectively to define building elements such as base, body, parapets, bays, arcades and structural elements. Materials, finishes, and colors have been used in a manner that serves to reduce the perceived appearance of height, bulk and mass. The project features a base clad in smooth stucco and stone veneer, a middle section composed of horizontal fiber cement panels with a warm wood appearance, and an upper portion with light-toned stucco and metal accent elements. Together, these materials establish visual hierarchy and depth, reinforce horizontal and vertical articulation, and maintain a cohesive architectural character throughout the façade.

E. The design and layout of the proposed project will result in well-designed vehicle and pedestrian access, circulation, and parking because pedestrian entries are located along El Camino Real and Jordan Avenue, and vehicular access is provided from Jordan Avenue to an automated underground mechanical parking facility. The parking system and overall circulation have been evaluated for adequacy, accessibility, and safety in the Transportation Impact Analysis (Abrams Associates, 2025), which found that the project would generate vehicle trips below the City’s screening thresholds, would not result in significant Vehicle Miles Traveled (VMT) impacts, and would maintain acceptable Level of Service (LOS) conditions at nearby intersections. The project design ensures safe pedestrian circulation, efficient parking operations, and ADA-compliant access consistent with the City’s transportation and design standards.

F. The general landscape design ensures visual relief, complements structures, provides an attractive environment, and is consistent with the adopted landscape program because the landscape plan integrates ground-level planting areas along El Camino Real and Jordan Avenue, including ornamental grasses, flowering shrubs, and seven new street trees, creating a balanced landscape composition that complements the building architecture.

G. Signage, when proposed or required, is designed to complement the building architecture in terms of style, materials, colors, and proportions and serves as identification of the building or businesses only because no signage is proposed at this time; any future signage will be reviewed under LAMC Chapter 14.68 to ensure it maintains consistency with the building architecture.

H. Mechanical equipment is fully screened from public view, and the screening is designed to be consistent with the building architecture in form, material, and detailing, and in full compliance with Chapter 11.14 of the Los Altos Municipal Code because all rooftop equipment is concealed behind parapets with cornice detailing that matches the building’s color and material palette, ensuring a cohesive and architecturally integrated design.

I. Service and trash areas are fully screened from public view or enclosed in structures that are consistent with the building architecture in materials and detailing because trash and utility enclosures are fully integrated into the building design at the ground level and screened with materials consistent with the building façade.

J. Street improvements which are identified in Chapter 11.20 of the Los Altos Municipal Code are provided because the project includes new sidewalks, curbs, and gutters along El Camino Real and Jordan Avenue, consistent with City standards for accessibility and pedestrian safety.

K. Off-site improvements associated with the subdivision of land allowed by Title 13 of the Los Altos Municipal Code and/or the Subdivision Map Act are not applicable because the project includes a Vesting Tentative Map for condominium purposes. The subdivision and related off-site improvements, including utility connections and frontage upgrades, have been designed in accordance with City standards and the Subdivision Map Act to ensure adequate public services, infrastructure capacity, and consistency with applicable regulations.

L. The Project is categorically exempt from environmental review under Section 15332 (In-Fill Development Projects) of the California Environmental Quality Act (CEQA) Guidelines because the

0.43 acre project site is considered an in-fill site that is substantially surrounded by urban uses and does not contain significant natural habitat for endangered, rare or threatened species; the proposed development is consistent with the General Plan and the CT Zoning District zoning standards except as modified by Density Bonus Law, and will not result in any significant impacts relating to traffic, noise, air quality, or water quality; the site can be served by all required utilities and public services; and none of the circumstances described in CEQA Guidelines Section 15300.2 apply.

Use Permit
With regard to the conditional use permit for the Project, the City finds the following pursuant to Section

14.80.060 of Los Altos Municipal Code (LAMC):

A. That the proposed location of the conditional use is desirable or essential to the public health, safety, comfort, convenience, prosperity, or welfare because the Project introduces an advanced automated parking system that improves safety, circulation, and efficiency. The mechanical parking system eliminates the need for interior drive aisles, reduces vehicular conflicts with pedestrians, and enhances site safety by operating in a secure, enclosed environment. By reducing emissions and

vehicle idling, the system contributes to improved air quality and energy efficiency while ensuring convenient, monitored access for residents.

B. That the proposed location of the conditional use is in accordance with the objectives of the zoning plan as stated in Chapter 14.02 of this title because the Commercial Thoroughfare (CT) zoning district promotes higher-density residential and mixed-use development along major corridors such as El Camino Real. The automated parking use supports this objective by efficiently providing required parking within a compact footprint, allowing more space for housing and streetscape improvements.

The Project advances City goals for sustainable infill development and efficient land use consistent with the zoning plan.

C. That the proposed location of the conditional use, under the circumstances of the particular case, will not be detrimental to the health, safety, comfort, convenience, prosperity, or welfare of persons residing or working in the vicinity or injurious to property or improvements in the vicinity because the automated parking system is fully enclosed, monitored, and designed to meet mechanical and fire safety standards. The Transportation Impact Analysis (Abrams Associates, 2025) found no significant Vehicle Miles Traveled (VMT) or Level of Service (LOS) impacts, confirming that the system will operate safely without adversely affecting nearby intersections or neighborhoods. The Project maintains appropriate setbacks, provides accessible pedestrian connections, and enhances overall site safety and functionality.

D. That the proposed conditional use will comply with the regulations prescribed for the district in which the site is located and the general provisions of Chapter 14.02 because the Project complies with applicable CT district standards except for deviations permitted under the State Density Bonus Law.

The automated parking facility is authorized under LAMC §14.74.070 as an alternative parking system and has been designed to meet City requirements for safety, access, and functionality. The Project is consistent with the intent of the zoning plan and advances the City’s housing, mobility, and design objectives.

E. When a conditional use permit is required, the Planning Commission shall make a specific finding that there is adequate on-site parking to support the facility, including staff, patients, visitors and other ancillary support services. This determination shall be based on a parking demand analysis prepared by a qualified professional and presented to the Planning Commission at a public hearing because the Transportation Impact Analysis (Abrams Associates, 2025) determined that ninety-five (95) automated parking spaces are sufficient to serve the eighty-five (85) residential units. The Project qualifies for parking reductions under AB 2097 due to its proximity to major transit and demonstrates adequate parking capacity, operational efficiency, and ADA accessibility to support the use and residents’ needs.

EXHIBIT B

CONDITIONS OF APPROVAL

PLANNING DIVISION

1. Approved Plans: The project shall be developed in substantial compliance with the design plans, support materials, and technical reports approved as part of the project, except as modified by these conditions as specified below.

2. Expiration: This Permit is valid for a period of two years and will expire twenty-four months from project approval, unless prior to the date of expiration, a building permit is issued, or an extension is granted pursuant to the procedures and timeline for extensions in the Zoning Code.

3. Revisions to the Approved Project: Minor revisions to the approved plans which are found to be in substantial compliance with the approved plans may be approved by the Development Services Director.

4. Notice of Right to Protest: The conditions of project approval set forth herein include certain fees, dedication requirements, reservation requirements, and other exactions.

Pursuant to Government Code Section 66020(d)(1), these conditions constitute written notice of a statement of the amount of such fees, and a description of the dedications, reservations, and other exactions. You are hereby further notified that the 90-day period in which you may protest these fees, dedications, reservations, and other exactions pursuant to Government Code Section 66020(a) began on the date of approval of this project. If you fail to file a protest within this 90-day period complying with all the requirements of Section 66020, you will be legally barred from later challenging such exactions.

5. Indemnity and Hold Harmless: The applicant/owner agrees to indemnify, defend, protect, and hold the City harmless from all costs and expenses, including attorney’s fees, incurred by the City or held to be the liability of the City in connection with the City’s defense of its actions in any proceedings brought in any State or Federal Court, challenging any of the City’s action with respect to the applicant’s project. The City may withhold final maps and/or permits, including temporary or final occupancy permits, for failure to pay all costs and expenses, including attorney's fees, incurred by the City in connection with the City's defense of its actions.

6. Certification Of Building Permit Plans: In a letter, the project architect shall certify the architectural design shown in the building permit plans match the approved plans. Any changes or modifications must be clearly noted in writing and shown on redlined plan sheets. The project architect shall also certify the structural plans are consistent with the architectural plans. In the event of a discrepancy between the structural plans and the architectural plans, the architectural plans shall take precedence, and revised structural drawings shall be submitted to the Building Division.

7. Affordable Housing Agreements: All applicable affordable housing agreements for the project shall be executed and recorded on a form provided by the City to the satisfaction of the Development Services Director and City Attorney prior to the issuance of the final map.

8. Single-Phase Development: Construction of the project shall be done in a single phase and shall not be considered a multi-phased development.

9. Roof Deck Operations: The approved hours of operation for the rooftop common area shall be limited to 7:00 a.m. to 9:00 p.m. and shall not allow amplified music.

10. Exterior Materials: High-quality materials and finishes shall be used throughout the project and shall remain in compliance with the materials identified in the approved plans, except as modified by the conditions of approval herein. Details regarding all color and architectural details shall be provided in the building permit plan submittal and shall be subject to review and approval by the Development Services Director or their designee prior to the issuance of building permits.

11. Special Paving Materials: The color, material, design, and product specifications for the special paving materials used on-site shall be submitted with the building permit drawings.

Final paving design details shall be subject to review and approval by the Development Services Director or their designee prior to the issuance of building permits.

12. Windows: Manufacturer type, design, material, and installation details for all windows within the project shall be specified for each unit in the building permit drawings for review and approval by the Development Services Director or their designee prior to the issuance of building permits.

13. Paint Color-Coding: Color-coded elevations of each side of the building(s) detailing the location of all paint and stain colors, manufacturer, and color names shall be included in the building permit plans.

14. Materials Mock-Up: The applicant shall set up a large material and color mock-up on-site, prior to building permit issuance and purchase of the finished materials, for final selection and approval by the Development Services Director or their designee. At a minimum, the mock-up shall include Trespa Meteon French Walnut siding, Trespa Meteon Brooklyn Classic siding, 3-coat stucco, cultured stone Cast-Fit Carbon veneer, window and door trim, metal coping, and paint samples. Proposed primary and secondary (accent) paint colors should be painted next to each other on the mock-up for purposes of inspection. The color(s) shall not be considered approved until after inspection and approval by the Development Services Director or their designee.

15. Rooftop Equipment Screen: All rooftop equipment must be concealed behind opaque (solid) screening designed to complement the building design such that rooftop equipment is not visible from any elevation. Details of the rooftop equipment and roof screens shall be included in the building permit drawings and shall be equal to, or taller than the equipment it is intended to screen.

16. Fences and Walls: All fencing and walls are to be shown on building plan drawings, including details on height, location, and material finish. No fence or wall shall exceed six

feet in height, measured from adjacent grade to the top of the fence or wall. The design and location must be approved by the Development Services Director or their designee and comply with all setback and traffic visibility area requirements prior to building permit issuance.

17. Lighting Plan: A detailed lighting plan shall be included in building permit drawings demonstrating compliance with Chapter 14.91 (Lighting Performance Standards) of the Los Altos Municipal Code. This plan should include photometric contours, manufacturer’s specifications on the fixtures, and mounting heights. The design and location of outdoor lighting fixtures shall ensure there will be no light spillover to surrounding properties, which is demonstrated with photometric contours extending beyond the project property lines. The lighting plan submitted with building permit drawings must be approved by the Development Services Director or their designee prior to building permit issuance.

18. Rooftop Deck Lighting: Proposed lighting fixtures on the rooftop deck shall not be visible from ground level on adjacent public streets. All string lighting shall be designed to include shades to avoid light spillover and be screened so they are not visible from off-site.

19. Landscaping: Detailed landscape plans encompassing on- and off-site plantable areas out to the street curb must be included in building permit drawings. Minimum plant sizes are flats or one-gallon containers for ground cover, five-gallon for shrubs, and 24” box for trees. The drawings must be approved by the Development Services Director or their designee prior to building permit issuance and implemented prior to occupancy. All plans should be prepared by a licensed Landscape Architect and shall comply with the City’s Water Efficient Landscape Ordinance (WELO) pursuant to Chapter 12.36 of the Municipal Code. Additional landscaping materials or modifications may be required by the Planning Division at final inspection to ensure adequate planting coverage and/or screening.

20. Landscape Screening: All utility meters, lines, transformers, backflow preventers, etc., on-site or off-site, must be shown on all site plan drawings and landscape plan drawings.

All such facilities shall be located to not interfere with landscape material growth and shall be screened in a manner which respects the building design and setback requirements.

Additional landscaping materials or modifications may be required by the Planning Division at final inspection to ensure adequate plant screening.

21. Signage: No signs are approved as part of this application. Any new signage will require separate planning and/or building permits and shall be designed in compliance with Chapter 14.68 of the Los Altos Municipal Code. Prior to the issuance of the building permit for the project, the applicant shall apply for and get approval of a Sign Permit from the Planning Division.

22. Parking Management Plan: Prior to building permit issuance, the applicant shall develop a parking management plan describing parking allocation for residents and guests, subject to administrative approval by the Development Services Director or their designee.

23. Loading/Delivery Plan: Prior to building permit issuance, the applicant shall develop a plan specifying measures to manage on-site deliveries and loading, which may include measures to tailor delivery hours and/or days to limit conflicts with peak traffic times or adjacent land uses.

24. Solid Waste and Recyclables Disposal Plan: The applicant shall submit a solid waste and recyclables disposal plan indicating the type, size and number of containers proposed, and the frequency of pick-up service subject to the approval of the Engineering Division. The applicant shall also submit evidence that Mission Trail Waste Systems has reviewed and approved the size and location of the proposed trash enclosure. The enclosure shall be designed to prevent rainwater from mixing with the enclosure's contents and shall be drained into the City’s sanitary sewer system. The enclosure's pad shall be designed to not drain outward, and the grade surrounding the enclosure designed to not drain into the enclosure. In addition, applicant shall show on plans the proposed location of how the solid waste will be collected by the refusal company. Include the relevant garage clearance dimension and/or staging location with appropriate dimensioning on to plans.

25. Construction Noise Reduction: The following noise reduction measures shall be incorporated into construction plans and contractor specifications to reduce the impact of temporary construction-related noise on nearby properties: (a) comply with manufacturer’s muffler requirements on all construction equipment engines; (b) turn off construction equipment when not in use, where applicable; (c) locate stationary equipment as far as practical from receiving properties; (d) use temporary sound barriers or sound curtains around loud stationary equipment if the other noise reduction methods are not effective or possible; and (e) shroud or shield impact tools and use electric-powered rather than dieselpowered construction equipment.

26. Mechanical Equipment: Prior to issuance of a building permit, the applicant shall show the location of any mechanical equipment which complies with the requirements of Chapter 11.14 (Mechanical Equipment) and Chapter 6.16 (Noise Control) of the Los Altos City Code.

27. Acoustical Report for Mechanical Equipment: Prior to issuance of a building permit, the applicant shall submit a report from an acoustical engineer/consultant ensuring that the rooftop mechanical equipment meets the City’s Noise Control Ordinance (Chapter 6.16).

28. Air Quality: The applicant is required to secure a permit from the Bay Area Air Quality Management District or provide written assurance that no permit is required prior to issuance of a building permit.

29. Basic Air Quality Construction Measures: The applicant shall require all construction contractors to implement the basic construction mitigation measures recommended by the Bay Area Air Quality Management District (BAAQMD) to reduce fugitive dust emissions.

Emission reduction measures will include, at a minimum, the following measures: (a) all exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) will be watered two times per day; (b) all haul trucks transporting soil, sand, or other loose material off-site will be covered; (c) all visible mud or dirt track-out onto adjacent public roads will be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited; (d) all vehicle speeds on unpaved roads will be limited to 15 mph; (e) all roadways, driveways, and sidewalks to be paved will be completed as soon as possible. Building pads will be laid as soon as possible after grading unless seeding or soil binders are used; (f) 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 measures Title 13, Section 2485, of the California Code of Regulations). Clear signage shall be provided for construction workers at all access points; and (g) all construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.

30. Discovery of Contaminated Soils: If contaminated soils are discovered, the applicant will ensure the contractor employs engineering controls and Best Management Practices (BMPs) to minimize human exposure to potential contaminants. Engineering controls and construction BMPs will include, but not be limited to, the following: (a) contractor employees working on-site will be certified in OSHA’s 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER) training; (b) the contractor will stockpile soil during redevelopment activities to allow for proper characterization and evaluation of disposal options; (c) the contractor will monitor area around construction site for fugitive vapor emissions with appropriate field screening instrumentation; (d) the contractor will water/mist soil as it is being excavated and loaded onto transportation trucks; (e) the contractor will place any stockpiled soil in areas shielded from prevailing winds; and (f) the contractor will cover the bottom of excavated areas with sheeting when work is not being performed.

31. Discovery of Archaeological Resources: If prehistoric or historic-period cultural materials are unearthed during ground-disturbing activities, it is recommended that all work within 100’ of the find be halted until a qualified archaeologist and Native American representative can assess the significance of the find. Prehistoric materials might include obsidian and chert-flaked stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks and artifacts; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered-stone tools, such as hammerstones and pitted stones. Historic-period materials might include stone, concrete, or adobe footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. If the find is determined to be potentially significant, the archaeologist, in consultation with the Native American representative, will develop a treatment plan that could include site avoidance, capping, or data recovery.

32. Discovery of Human Remains: In the event of the discovery of human remains during construction or demolition, there shall be no further excavation or disturbance of the site within a 50’ radius of the location of such discovery, or any nearby area reasonably suspected to overlie adjacent remains. The Santa Clara County Coroner shall be notified and shall make a determination as to whether the remains are Native American. If the Coroner determines that the remains are not subject to their authority, the Coroner shall notify the Native American Heritage Commission, which shall attempt to identify descendants of the deceased Native American. If no satisfactory agreement can be reached as to the disposition of the remains, then the landowner shall reinter the human remains and items associated with Native American burials on the property in a location not subject to further subsurface disturbance. A final report shall be submitted to the City’s Development Services Director prior to release of a Certificate of Occupancy. This report shall contain a description of the mitigation programs and its results, including a description of the monitoring and testing resources analysis methodology and conclusions, and a description

of the disposition/curation of the resources. The report shall verify completion of the mitigation program to the satisfaction of the City’s Development Services Director.

33. Discovery of Paleontological Resources: In the event that a fossil is discovered during construction of the project, excavations within 50’ of the find shall be temporarily halted or delayed until the discovery is examined by a qualified paleontologist, in accordance with Society of Vertebrate Paleontology standards. The City shall include a standard inadvertent discovery clause in every construction contract to inform contractors of this requirement. If the find is determined to be significant and if avoidance is not feasible, the paleontologist shall design and carry out a data recovery plan consistent with the Society of Vertebrate Paleontology standards.

34. Indoor Formaldehyde Reductions: If the project utilizes composite wood materials (e.g., hardwood plywood, medium density fiberboard, particleboard) for interior finishes, then only composite wood materials that are made with CARB approved, no-added formaldehyde (NAF) resins, or ultra-low emitting formaldehyde (ULEF) resins shall be utilized (CARB, Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products, 17 CCR Section 93120, et seq., 2009-2013).

BUILDING DIVISION

35. Building Permit: A building permit is required for the project and building design plans shall comply with the latest applicable adopted standards. The applicant shall submit supplemental application materials as required by the Building Division to demonstrate compliance.

36. Conditions of Approval: Incorporate the conditions of approval into the Building Permit submittal plans and provide a letter which explains how each condition of approval has been satisfied and/or which sheet of the plans the information can be found.

37. Green Building Verification: The applicant shall submit verification that the structure was built in compliance with the California Green Building Standards pursuant to Section 12.26 of the Municipal Code.

38. School Fee Payment: In accordance with Section 65995 of the California Government Code, and as authorized under Section 17620 of the Education Code, the property owner shall pay the established school fee for each school district the property is located in and provide receipts to the Building Division. Payments shall be made directly to the school districts.

39. Payment of Impact and Development Fees: The applicant shall pay all applicable development and impact fees in accordance with State Law and the City of Los Altos current adopted fee schedule. All impact fees not paid prior to building permit issuance shall be required to provide a bond equal to the required amount prior to issuance of the building permit.

40. Work Hours/Construction Site Signage: No work shall commence on the job site prior to 7:00 a.m. nor continue later than 5:30 p.m., Monday through Friday, from 9 a.m. to 3 p.m.

Saturday, and no work is permitted on Sunday or any City observed holiday. The general

contractor, applicant, developer, or property owner shall erect a sign at all construction site entrances/exits to advise subcontractors and material suppliers of the working hours and contact information, including an after-hours contact.

41. Disturbance Coordinator: The applicant shall designate a “disturbance coordinator” who will be responsible for responding to any local complaints regarding construction noise.

The coordinator (who may be an employee of the general contractor) will determine the cause of the complaint and will require that reasonable measures warranted to correct the problem be implemented. A telephone number of the noise disturbance coordinator shall be conspicuously posted at the construction site fence and on the notification sent to neighbors adjacent to the site. The sign must also list an emergency after-hours contact number for emergency personnel.

42. Change of Address: A “Request for Address Assignment or Change” form must be submitted to the Building Division to correlate with the addition of any new units or tenant spaces on the property.

43. California Water Service Upgrades: You are responsible for contacting and coordinating with the California Water Service Company any water service improvements including but not limited to relocation of water meters, increasing water meter sizing or the installation of fire hydrants. The City recommends consulting with California Water Service Company as early as possible to avoid construction or inspection delays.

44. Americans with Disabilities Act: All improvements shall comply with Americans with Disabilities Act (ADA). The latest edition of Caltrans ADA requirements shall apply to all improvements in the public right-of-way. Compliance with all ADA requirements shall be shown on all building permit plans.

45. Green Building Verification: The applicant shall submit verification that the structure was built in compliance with the California Green Building Standards pursuant to Section 12.26 of the Municipal Code.

46. Public Utilities: The applicant shall contact electric, gas, communication, and water utility companies regarding the installation of new utility services to the site.

47. Geotechnical Report: The applicant shall have a design-level geotechnical investigation prepared which includes recommendations to address and mitigate geologic hazards in accordance with the specifications of California Geological Survey (CGS) Special Publication 117, Guidelines for Evaluating and Mitigating Seismic Hazards, and the requirements of the Seismic Hazards Mapping Act. The report will be submitted to the City during building plan check, and the recommendations made in the geotechnical report will be implemented as part of the project and included in building permit drawings and civil drawings as needed. Recommendations may include considerations for design of permanent below-grade walls to resist static lateral earth pressures, lateral pressures caused by seismic activity, and traffic loads; method for back draining walls to prevent the buildup of hydrostatic pressure; considerations for design of excavation shoring system; excavation monitoring; and seismic design.