48. Off-Haul Excavated Soil: The grading plan shall show specific grading cut and/or fill quantities. Cross section details showing the existing and proposed grading through at least two perpendicular portions of the site or more shall be provided to fully characterize the site. A note on the grading plans should state that all excess dirt shall be off hauled from the site and shall not be used as fill material unless approved by the Building and Planning Divisions.
ENGINEERING DIVISION
49. Public Infrastructure Repairs: The applicant shall repair any damaged right-of-way infrastructures and otherwise displaced curb, gutter and/or sidewalks and City’s storm drain inlet shall be removed and replaced as directed by the City Engineer or their designee. The applicant is responsible to resurface (grind and overlay) half of the street along the project frontages, if determined to be damaged during construction as directed by the City Engineer or their designee.
50. Construction Management Plan: The applicant shall submit a construction management plan for review and approval by the Development Services Director and the City Engineer.
The construction management plan shall address any construction activities affecting the public right-of-way, including but not limited to excavation, traffic control, truck routing, pedestrian protection, material storage, earth retention and construction vehicle parking.
The plan shall provide specific details with regards to how construction vehicle parking will be managed to minimize impacts on nearby single-family neighborhoods. Sidewalks, parking and travel lanes along El Camino Real and Jordan Ave shall not be closed for the full duration of the project. Closures will be reviewed and approved with Encroachment Permit submittals on Jordan Ave. Closures on El Camino Real shall be approved by Cal Trans. The applicant shall be required to have a pre-construction meeting with all abutting property owners to discuss the project schedule and to prominently display a sign with the single point of contact the community should interface with for any construction related impacts from the project.
51. Maintenance Bond: A one-year, ten-percent maintenance bond shall be submitted upon acceptance of improvements in the public right-of-way.
52. 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.
53. Label Catch Basin Inlets: The applicant shall label all new or existing public and private catch basin inlets which are on or directly adjacent to the site with the “NO DUMPING - FLOWS TO ADOBE CREEK” logo as required by the City.
54. 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.
55. Public Improvements: Install or reconstruct standard public improvements required for the project along the project frontages of El Camino Real and Jordan Ave. These improvements include, new sidewalk, curb and gutter including extending the sidewalk along the frontage on Jordan Ave to the corner of El Camino Real and Jordan Ave.
Additionally the applicant shall grind and overlay half of Jordan Ave as directed by the City Engineer.
a. Provide a 5-foot-wide sidewalk along Jordan Ave; the 6-inch curb shall not be included in the sidewalk width.
b. The existing street centerline on Jordan Ave shall be repainted and extended to a total length of 150 feet.
c. Provide checker non-slip lids for the electric vault and all other utility lids located within the right-of-way.
56. Traffic Control Plans: Upon submitting the initial building permit and improvement plans, the applicant shall submit traffic control plans for any off-site and on-site improvements or any work that requires temporary lane closure, shoulder closure, bike lane closure, and/or sidewalk closure for review and approval. Sidewalk closures are not allowed unless reconstruction of sidewalk necessitates temporary sidewalk closure. In these instances, sidewalk detour should be shown on the Traffic Control plans. Traffic control plans shall be prepared in accordance with the latest edition of the California Manual of Uniform Traffic Control Devices (CA MUTCD).
57. 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.
58. Storm Water Management Plan: The applicant shall submit a Storm Water Management Plan (SWMP) in compliance with the San Francisco Bay Region Municipal Regional Stormwater (MRP) National Pollutant Discharge Elimination System (NPDES) Permit No.
CA S612008, Order R2-2022-0018, Provision C.3 dated May 11, 2022. All projects that create and/or replace 5,000 sq. ft. or more of impervious surface on the project site and affected portions of the public right-of-way that are developed or redeveloped as part of the project must also complete a C.3. Data Form available on the City’s Building Division website. The SWMP shall be reviewed and approved by a City approved third party consultant at the Applicant’s expense. The recommendations from the SWMP shall be shown on the building permit plans.
59. Pollution Prevention: The improvement plans shall include the “Blueprint for a Clean Bay” plan sheet in all plan submittals.
60. 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.
61. 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.
62. Transportation Permit: A Transportation Permit, per the requirements specified in California Vehicle Code Division 15, is required before any large equipment, materials or soil is transported or hauled to or from the construction site. Applicant shall pay the applicable fees before the transportation permit can be issued by the City Engineer.
63. Encroachment Permit: An encroachment permit and/or an excavation permit shall be obtained prior to any work done within the public right-of-way and it shall be in accordance with plans to be approved by the City Engineer. Any work within El Camino Real will require the applicant to obtain an encroachment permit with Caltrans prior to commencement of work.
64. Grading and Drainage Plan: The applicant shall submit on-site grading and drainage plans that include (i.e. drain swale, drain inlets, rough pad elevations, building envelopes, drip lines of major trees, elevations at property lines, all trees and screening to be saved) for approval by City Engineer. No grading or building pads are allowed within two-thirds of the drip line of trees unless authorized by a certified arborist and the Planning Division.
65. Cost Estimate and Performance Bonds: The applicant shall submit a cost estimate for the improvements in the public right-of-way and shall submit a 100 percent performance bond or cash deposit (to be held until acceptance of improvements) and a 50 percent labor and material bond (to be held 6 months after acceptance of improvements) for the work in the public right-of-way.
66. Condominium Map: The applicant shall record the condominium map as required by the City Engineer prior to final occupancy.
67. Public Access Easement: The applicant shall dedicate public access easements for the purpose of providing pedestrian access prior to the recordation of the final map.
68. Public Utility Dedication: The applicant shall dedicate public utility easements as required by the utility companies to serve the site.
69. 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.
70. New ADA Ramps and Crosswalks: The applicant shall provide new ADA ramps and crosswalk striping per the City standards at the corner of El Camino Real and Jordan Ave crossing over Jordan Ave. Additionally, ADA ramps shall be installed in either side of the proposed driveway on Jordan Ave and an ADA ramp shall be installed at the corner or El Camino Real and Jordan Ave crossing El Camino Real.
a. New ADA Ramps shall follow the latest Caltrans Standard Detail A88A. b. Truncated domes on ADA ramps shall be cast iron and baked-on-oil finish. c. The crosswalk on Jordan shall be repainted.
71. Parking Stall and Red Curb Striping: The applicant shall install parking stall striping and red curb as directed by the City Engineer or his designee.
a. Provide a minimum 20 feet of red curb on each side of the driveway entrance. b. Provide red curb starting at the end of curb on El Camino Real and extending 30 feet into Jordan.
72. Sewage Capacity Study: The applicant shall show sewer connection to the City sewer main and submit calculations showing that the City’s existing 8-inch sewer main will not exceed two-thirds full due to the additional sewage capacity from the proposed project. For any segment that is calculated to exceed two-thirds full for average daily flow or for any segment that the flow is surcharged in the main due to peak flow, the applicant shall upgrade the sewer line or pay a fair share contribution for the sewer upgrade to be approved by the City Engineer.
73. Solid Waste Ordinance Compliance: The applicant shall be in compliance with the City’s adopted Solid Waste Collection, Remove, Disposal, Processing & Recycling Ordinance (LAMC Chapter 6.12) which includes a mandatory requirement that all multi-family dwellings provide for recycling and organics collection programs.
74. Solid Waste and Recyclables Disposal Plan: The applicant shall contact Mission Trail Waste Systems and 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.
FIRE DEPARTMENT
75. Formal Plan Review: Review of this Developmental proposal is limited to acceptability of site access and water supply and may include specific additional requirements as they pertain to fire department operations and shall not be construed as a substitute for formal plan review to determine compliance with adopted model codes. Prior to performing any work, the applicant shall make application to and receive from the Building Division all applicable construction permits.
76. Fire Sprinklers Required: Approved automatic sprinkler systems in new and existing buildings and structures shall be provided in the locations described in this section or in Sections 903.2.1 through 903.2.18, whichever is more restrictive. For the purposes of this section, firewalls used to separate building areas shall be constructed in accordance with the California Building Code and shall be without openings or penetrations. The owner(s), occupant(s), and any contractor(s) or subcontractor(s) are responsible for consulting with the water purveyor of record to determine if any modification or upgrade of the existing water service is required. A State of California licensed (C-16) Fire Protection Contractor shall submit plans, calculations, a completed permit application, and appropriate fees to this department for review and approval prior to beginning work. CFC Sec. 903.2
77. Fire Alarm Requirements: Refer to CFC Sec. 907 and the currently adopted edition of NFPA 72. Submit shop drawings (three sets) and a permit application to the Santa Clara County Fire Department (SCCFD) for approval before installing or altering any system.
78. Public Fire Hydrant Required: Provide a public fire hydrant at a final location to be determined jointly by the Fire Department and California Water Company. The maximum distance shall be 250 feet from the building frontage, 500 feet between hydrants, and a maximum of 100 feet from the Fire Department Connection (FDC), with a minimum hydrant flow of 1,500 GPM at 20 psi residual. Fire hydrants shall be provided along required fire apparatus access roads and adjacent public streets. CFC Sec. 507, Appendix B, and Appendix C.
79. Fire Hydrant Systems Required: Where a portion of a facility or building is more than 400 feet from a hydrant on a fire apparatus access road, measured by an approved route around the exterior, onsite fire hydrants and mains shall be provided as required by the fire code official. Exception: For Group R-3 and Group U occupancies equipped throughout with an approved automatic sprinkler system, the distance requirement shall be not more than 600 feet. [CFC Sec. 507.5.1]
80. High-Rise Requirements: Every building with floors used for human occupancy located more than 75 feet above the lowest floor level with building access, except hospitals, shall meet high-rise structure requirements per CFC 202 Definition. Include a note on plans indicating this project requires high-rise structure compliance.
81. Buildings and Facilities Access: Approved fire apparatus access roads shall be provided for every facility or building. The access road shall comply with the requirements of this section and extend to within 150 feet of all portions of the facility and exterior walls of the first story, measured by an approved route around the exterior. [CFC Sec. 503.1.1]
82. Required Aerial Access: Where the vertical distance between the grade plane and the highest roof surface exceeds 30 feet, approved aerial fire apparatus access roads shall be provided. At least one required access route shall be located within 15 to 30 feet of the building and parallel to one entire side. Exception: Where approved by the fire official, Type IA, IB, or IIA buildings fully sprinklered under Section 903.3.1.1 and having firefighter access through an enclosed stairway with a Class I standpipe from the lowest vehicle access level to all roof surfaces. Overhead power lines shall not be located within the aerial access roadway. [CFC Ch. 5 and SCCFD SD&S A-1]
83. Knox Key Boxes/Locks Where Required for Access: Where access to or within a structure or area is restricted because of secured openings or where immediate access is necessary for lifesaving or firefighting purposes, a key box shall be installed in an approved location. The Knox Key Box shall contain keys for required access. Gates or barriers shall be equipped with Knox Locks. Operators must notify the fire code official and update keys when locks are changed. [CFC Sec. 506]
84. Fire Department Connection: The FDC shall be installed on the street-address side of the building, within 100 feet of a public fire hydrant and within ten feet of the main Post Indicator Valve (PIV), unless otherwise approved. FDCs shall have at least two 2½-inch
national standard threaded inlet couplings, be painted safety yellow, and oriented for unobstructed hose access. [SCCFD SP-2 Standard]
85. Two-Way Communication System: Two-way communication systems shall be designed and installed per NFPA 72 (2022), the California Electrical Code (2022), the California Fire Code (2022), and the California Building Code (2022). Revise plans to show this as a deferred submittal item.
86. Emergency Responder Radio Coverage in New Buildings: All new buildings shall provide approved radio coverage for emergency responders within the building based on existing coverage levels at the exterior. This section shall not require improvement of public safety communication systems. [CFC Sec. 510.1]
87. Standpipes Required: Standpipe systems shall be provided where the floor-level of the highest story is more than 30 feet above the lowest level of fire department vehicle access.
Systems shall be manual wet type and installed in accordance with NFPA 14. [CFC Sec. 905]
88. Required Fire Flow: The minimum required fire flow for this project is 1,500 GPM at 20 psi residual pressure, assuming installation of automatic sprinklers per CFC Sec. 903.3.3.1.
89. Fire Lanes Required: The minimum clear width of fire department access roads shall be 20 feet. Fire lanes shall be designated and marked as required by California Vehicle Code Section 22500.1. Plans shall show proposed red curbs, fire lane markings, and access sign locations.
90. Water Supply Requirements: Potable water supplies shall be protected from contamination caused by fire protection water supplies. The applicant and contractors shall coordinate with the water purveyor to meet all requirements. Final system approval requires written confirmation from the purveyor that all standards have been met. [CFC Sec. 903.3.5 and Health and Safety Code 13114.7]
91. Address Identification: New and existing buildings shall have approved address numbers visible from the street or road fronting the property. Numbers shall contrast with the background, be a minimum of six inches high, and have a minimum stroke width of 0.5 inch. For buildings not visible from the public way, provide a monument or sign. [CFC Sec. 505.1]
92. Construction Site Fire Safety: All construction sites must comply with applicable provisions of CFC Chapter 33 and SCCFD Standard Detail and Specification S1-7. Include appropriate notations on subsequent plan submittals.
93. Building Construction Type Compliance: The construction type of the building shall be verified to be compliant with the allowable height, area, and number of stories permitted under the California Building Code (CBC).
94. Standby and Emergency Power: Standby and emergency power shall be provided in accordance with CBC Section 403.4.8. If a generator is proposed, its location shall be shown on the plans.
95. Smoke-Proof Enclosures for Stairways: Smoke-proof enclosures shall be provided for all interior exit stairways in compliance with CBC Section 403.5.4.
96. Fire Command Center: A fire command center shall be provided in the main lobby area per CBC Section 403.4.6. The command center size and configuration shall comply with CFC Section 508.1.3.
97. Smoke Control System Space Requirements: Sufficient space and designated area shall be provided for the smoke control system as required by CBC Section 403.4.7.
98. Fire Pump Room Access: Where a fire pump is required, fire pump rooms not directly accessible from the exterior shall be accessible through a fire-resistance-rated corridor from an enclosed stairway or exterior exit, consistent with NFPA 20 Section 4.14.2.1.1.
99. Fire Pump Power Source Reliability: Where an electric fire pump is proposed, the power source shall meet the reliability requirements of NFPA 20 Section 9.3.2, including:
a. The source power plant has not experienced shutdowns exceeding ten continuous hours in the past three years.
b. Power outages are not routinely experienced in the service area. c. The normal source of power is not supplied by overhead conductors outside the protected facility.
d. Only disconnect switches and overcurrent protection devices permitted by NFPA 20 Section 9.2.3 are installed in the normal source of power. 100. Secondary Water Supply: A secondary water supply shall be provided for the sprinkler system in accordance with CBC Section 403.3.3, and its location and capacity shall be clearly identified in the plans.
101. Smoke Control System Basis of Design Report: Prior to building permit review, a basis of design report for the smoke control system shall be provided. The report, while conceptual in nature, shall include all elements required in the final Smoke Control Report other than calculations, supporting data, and diagrams.
City of Los
Altos
1 North San Antonio Road
Los Altos, California 94022-3087
SECTION 15332 - CLASS 32 - INFILL DEVELOPMENT PROJECTS
CEQA EXEMPTION DOCUMENTATION
4898 EL CAMINO REAL, LOS ALTOS
Prepared by the City of Los Altos
Summary
As discussed in this memorandum, the project would be exempt from detailed CEQA review under State CEQA Guidelines Section 15332 – Class 32. Under Section 15332, a project characterized as infill development qualifies for a Class 32 Exemption if 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. The project satisfies all of these conditions. Additionally, State CEQA Guidelines Section 15300.2 lists six exceptions to a categorical exemption related to location, cumulative impact, significant effect, scenic highways, hazardous waste sites, and historical resources.
None of these exceptions apply to the project.
Project Description
The project proposes to construct an eight (8) story (approximately 109 ft 9 in in height), multi-family development utilizing State Density Bonus law. The development includes 85 dwelling units, consisting of nine studios, 47 one-bedroom units, and 29 two-bedroom units.
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 ninetyfive (95) vehicle spaces. Bicycle parking is provided with long-term storage for ninetyeight (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 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.
1 North San Antonio Road
Los Altos, California 94022-3087
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.
CEQA Class 32 Exemption
To qualify under Class 32, the project must meet five criteria: (1) consistency with the General Plan and zoning, (2) location within City limits on a site less than five acres and surrounded by urban uses, (3) absence of habitat for endangered species, (4) no significant effects related to traffic, noise, air quality, or water quality, and (5) availability of adequate utilities and public services. The project must also avoid the exceptions to categorical exemptions listed in Section 15300.2.
1. Consistency with the General Plan and Zoning
The site is designated Thoroughfare Commercial (TC) in the Los Altos General Plan and zoned Commercial Thoroughfare (CT), allowing residential development. The project is consistent with the General Plan’s Thoroughfare Commercial Land Use Designation, which supports retail, service, office, and higher-density residential uses along El Camino Real, except as modified by State Density Bonus Law. The designation is intended to promote walkability, support local businesses, and provide opportunities for housing near services and transit. By providing a highdensity residential development with ground-floor residential support area, including affordable units utilizing State Density Bonus law, the project aligns with these objectives and contributes to a vibrant, pedestrian-oriented corridor. The project will contribute towards the City’s Regional Housing Needs Assessment (RHNA) obligation and is aligned with the City’s recently adopted 6th Cycle Housing Element by adding eighty-five (85) units to the City’s housing stock, including ten affordable units.
The project complies with the Thoroughfare Commercial (TC) land use designation and Zoning Standards of the Commercial Thoroughfare (CT) Zoning District, except as modified by State Density Bonus law. The project must also comply with the City’s Objective Design Control Standards, as outlined in Los Altos Municipal Code (LAMC) Section 14.50.170 for the CT Zoning District and Section 14.66.280 for all multiple-family and mixed-use projects. Except for the requested waivers under Density Bonus, the project is consistent with the applicable Objective Design Control Standards.
1 North San Antonio Road
Los Altos, California 94022-3087
No amendments to an adopted planning document or General Plan or Zoning designation would be required for implementation of the proposed project. Additionally, pursuant to case law (Wollmer v. City of Berkeley (2011)), the City of Los Altos can still determine the project is consistent with the General Plan for the purpose of deeming the project exempt per Section 15332 of the CEQA Guidelines even with the adoption of density bonus concessions or waivers.
2. Location within City limits on a site less than five acres and surrounded by urban uses The approximately 0.43-acre project site is within City limits and fully surrounded by commercial and residential uses. The project site is located on the southeast corner of Jordan Avenue and El Camino Real. Surrounding land uses include a fast-food restaurant and residential uses across Jordan Avenue to the west, office and residential uses across El Camino Real to the north, office uses to the west, and the parking lot serving 4906 El Camino Real to the south.
3. Absence of habitat for endangered species
The property was previously developed in 1956 with a commercial building that has since been demolished; the site is now paved vacant land with no trees.
The project site was previously developed and surrounded by other urban developments and paved roadways; therefore, no special-status species are expected to occur on the project site under existing conditions because of the lack of suitable habitat. Similarly, the proposed project would not substantially reduce locally common wildlife populations, because no suitable habitat exists on site. The proposed project would not significantly affect sensitive biological resources given the amount of previous development that has taken place on the project site and in the vicinity.
Project construction and operation would have no impacts either directly or through habitat modification to any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the United States Fish and Wildlife Service. Therefore, the project site does not have value as habitat for endangered, rare, or threatened species.
4. No significant effects related to traffic, noise, air quality, or water quality Traffic
Based on the City’s adopted vehicle miles traveled (VMT) policy and CEQA Guidelines section 15064.3, transportation effects under CEQA are evaluated using vehicle miles traveled (VMT). A transportation analysis was prepared by Abrams Associates Traffic Engineering, Inc. including a VMT screening analysis, which confirms the project is screened out under the City’s VMT Policy
1 North San Antonio Road
Los Altos, California 94022-3087
based on the map screening and Transit Proximity Screening criteria; therefore, transportation impacts are presumed less than significant.
The project would not result in degradation of the level of service (or a significant increase in delay) on any intersections or roadway segments currently being utilized by bus transit in the area and would not increase ridership beyond existing capacity. As such, no significant impacts to bus transit will occur. In addition, the proposed project would not significantly impact or change the design of any existing pedestrian facilities and would not create any new safety problems for pedestrians in the area. The project will add some bicyclists in the area, but the volumes added would not be expected to significantly impact any existing bicycle facilities. 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 and does not require sidewalk widening or conversion to a shared-use path. In relation to the existing conditions, the proposed project would not cause substantial changes to the pedestrian or bicycle traffic in the area and would not significantly impact or require changes to the design of any existing bicycle or pedestrian facilities.
The intersection of Jordan Avenue with North San Antonio Road is forecast to continue operating at LOS F and is forecast to exceed the LOS standards regardless of whether or not the proposed project is implemented. In addition, this intersection is not forecast to meet Caltrans’ warrants for installation of a traffic signal. Therefore, impacts related to project conflicts with adopted policies, plans, or programs related to alternative transportation would be considered less-than-significant.
The proposed project would have three points of access (two building doorways and one two-way driveway). The proposed stop-controlled exit for the project driveway would be forecast to have acceptable operations. The analysis found that the project driveway on Jordan Avenue would operate within acceptable performance standards, with adequate sight distance and on-site queuing that would not affect the public right-of-way. Operational parking controls are required through the Parking Management Plan condition of approval, subject to City review and approval prior to building permit issuance, and loading activity is managed through conditions of approval, a Loading and Delivery Management Plan. New public sidewalks would be installed along Jordan Avenue connecting to existing sidewalk segments along Jordan Avenue and El Camino Real where none currently exist. Additionally existing sidewalks and curb ramps on El Camino Real would be replaced or modified to continue to provide adequate pedestrian access within all applicable requirements including the Americans with Disabilities Act (ADA), California Building Code (CBC), and Caltrans requirements. Therefore, impacts related to access and circulation for the proposed project would be considered less-than-significant.
Noise
The City of Los Altos Noise Ordinance establishes interior and exterior noise standards by zoning district for daytime and nighttime hours, and identifies prohibited acts relative to noise, including
1 North San Antonio Road
Los Altos, California 94022-3087
maximum noise levels at affected properties and hours during which construction is permitted.
The noise ordinance allows for increases in noise related to construction activities during permitted construction hours. Compliance with the noise ordinance will ensure construction noise impacts are less than significant. Noise impacts from a residential project would occur only if projectrelated activities resulted in noise levels that exceed the City’s applicable standards at sensitive receptors. For the proposed residential project, the primary source of noise would be operational traffic. The project site is located along El Camino Real (California State Highway 82), which already experiences substantial ambient traffic noise from vehicles, buses, and trucks. The addition of project-related vehicle trips, distributed throughout the day, along with a fully enclosed parking garage, is not expected to increase noise levels beyond existing ambient conditions or exceed City noise standards. Therefore, noise impacts associated with the proposed project would be considered less than significant.
Air Quality
According to the Bay Area Air Quality Management District 2022 CEQA Guidelines the operational criteria pollutant screening size for general condominiums/townhouses is 637 dwelling units, and the construction related screening size is 416 dwelling units. At 85 dwelling units the proposed project is below all screening thresholds. No demolition will take place on site as the site is currently vacant and all best management practices recommended by BAAQMD have been incorporated as conditions of approval. Therefore, impacts related to air quality for the proposed project would be considered less-than-significant.
Water Quality
The proposed project will be required to comply with all City of Los Altos ordinances, policies, and processes regarding the construction and post‐construction treatment of storm water runoff.
As required by the project conditions of approval, all projects that create and/or replace 5,000 square feet or more of impervious surface on the project site and affected portions of the public right-of-way that are developed or redeveloped as part of the project must also complete a C.3.
Data Form available on the City’s Building Division website and shall submit a Storm Water Management Plan (SWMP) in compliance with the San Francisco Bay Region Municipal Regional Stormwater (MRP) National Pollutant Discharge Elimination System (NPDES) Permit No. CA S612008, Order R2-2022-0018, Provision C.3 dated May 11, 2022. The SWMP will be reviewed and approved by the City and recommendations from the SWMP shall be shown on the building permit plans. Therefore, impacts related to water quality for the proposed project would be considered less-than-significant.
1 North San Antonio Road
Los Altos, California 94022-3087
5. Availability of adequate utilities and public services The project site is currently served and would continue to be served by all necessary utilities and public services under proposed conditions. These services include water supply, wastewater collection, electricity and natural gas, solid waste and recycling services, fir protection, police services, and elementary, middle, and high schools. Therefore, impacts related to adequate utilities and public services for the proposed project would be considered less-than-significant.
Exceptions
State CEQA Guidelines Section 15300.2. – Exceptions - lists instances where an exemption would be inapplicable to a project. These include:
(a) Location. Classes 3, 4, 5, 6, and 11 are qualified by consideration of where the project is to be located – a project that is ordinarily insignificant in its impact on the environment may in a particularly sensitive environment be significant. Therefore, these classes are considered to apply all instances, except where the project may impact on an environmental resource of hazardous or critical concern where designated, precisely mapped, and officially adopted pursuant to law by federal, state, or local agencies.
(b) Cumulative Impact. All exemptions for these classes are inapplicable when the cumulative impact of successive projects of the same type in the same place, over time is significant. (c) Significant Effect. A categorical exemption shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances.
(d) Scenic Highways. A categorical exemption shall not be used for a project which may result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway. This does not apply to improvements which are required as mitigation by an adopted negative declaration or certified EIR.
(e) Hazardous Waste Sites. A categorical exemption shall not be used for a project located on a site which is included on any list compiled pursuant to Section 65962.5 of the Government Code.
(f) Historical Resources. A categorical exemption shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource.
1 North San Antonio Road
Los Altos, California 94022-3087
Location
The location exception only applies to exemption Classes 3, 4, 5, 6, and 11. The project qualifies for a Class 32 exemption and therefore, the location exception does not apply to the project.
Cumulative Impact
The proposed project is an infill development project in an urban area. According to the Governor’s Office of Planning and Research, the term “infill development” refers to building within unused and underutilized lands within existing development patterns, typically, but not exclusively, in urban areas. The project site and surrounding areas allow urban uses as defined by PRC Section 21072. The proposed project does not include planning successive projects of the same type in the same place. There are several residential redevelopment projects proposed in the general area; however, these are consistent with the general plan and consistent with the infill development project definition expected in an urban area.
Significant Effect
Examples of unusual circumstances under this exception include, but are not limited to, locations within sensitive environmental areas; sites containing historical or cultural resources; projects proposed in areas where such development is uncommon; or sites located within landslide zones, wildfire hazard areas, or areas containing hazardous materials. The proposed residential project does not meet any of these unusual circumstances. Specifically, the site is not located within a sensitive environmental area, does not contain historical or cultural resources, is not situated within a landslide or wildfire hazard area, and the site does not contain hazardous materials. The proposed residential development is consistent with surrounding land uses and is similar in character to existing development in the area. Given the urban context of the project site and the compatibility of the proposed project with surrounding uses, there is no evidence that the project would result in a significant environmental effect due to unusual circumstances.
Scenic Highways
According to the California Department of Transportation California Scenic Highway Mapping System, the sole state‐designated scenic highway in Santa Clara County is State Route (SR) 9 from the Santa Cruz County line to the Los Gatos city limit. The proposed project is not located near this state scenic highway and would, therefore, not result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway.
1 North San Antonio Road
Los Altos, California 94022-3087
Hazardous Waste Sites
The Phase I Environmental Site Assessment prepared for the site identified no recognized environmental conditions or contamination. The proposed project is not located on a site that is included on any list compiled pursuant to Section 65962.5 of the Government Code. The site is not located on the California Environmental Protection Agency’s Cortese List (Health and Safety Code Section 25187.5). The State Water Resources Control Board’s GeoTracker (Health and Safety Code Section 25295 and Water Code Sections 13273 and 13301) does not indicate any hazardous conditions within the project site. The project site is also not listed on the California Environmental Protection Agency’s list of solid waste sites identified by the Water Board with waste constituents above hazardous waste levels outside the waste management unit (Health and Safety Code Section 116395).
Historical Resources
The City has an adopted Historical Preservation Ordinance and local register of historic resources.
The project site currently does not contain any structures and is not identified in the City’s Historic Resources Inventory. The project site is within a highly developed and urbanized area and is not within a historic district or adjacent to historically significant buildings. The project would not cause a substantial adverse change in the significance of a historical resource.
PLANNING COMMISSION
STAFF REPORT
Meeting Date November 6, 2025
Subject 4898 El Camino Real – New Multi-Family Residential Project Prepared by: Sean Gallegos, Senior Planner
Initiated by: Subhendu Datta on behalf of ADL 15 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. Transportation Analysis
Recommendation
1. Adopt a Resolution approving Design Review (Application No. D25-0004) and Conditional Use Permit (Application No. CUP25-0001) for the construction of an eight (8) story, multiplefamily development with eighty-five (85) residential units utilizing State Density Bonus with waivers at 4898 El Camino Real, per the recommended findings and conditions of approval; and find the project is categorically exempt from environmental review pursuant to Section 15332 (In-Fill Development Projects) of the California Environmental Quality Act (CEQA) - Attachment 1.
2. Recommend the City Council adopt a Resolution approving a Vesting Tentative Map (Application No. TM25-0001) to create eighty-five (85) condominium lots and one (1) common lot at 4898 El Camino Real, per the recommended findings and conditions of approval; and find the project is categorically exempt from environmental review pursuant to Section 15332 (In-Fill Development Projects) of the California Environmental Quality Act (CEQA) - Attachment 2.
November 6, 2025
Multi-Family Residential Development at 4898 El Camino Real Page 2 Background
Property Description
The approximeatly 0.43-acre vacant project site is located on the southeast corner of Jordan Avenue and El Camino Real. Surrounding land uses include a fast-food restaurant and residential uses across Jordan Avenue to the west, office and residential uses across El Camino Real to the north, office uses to the west, and the parking lot serving 4906 El Camino Real to the south.
Project Overview
The project proposes to construct an eight (8) story, multi-family development utilizing State Density Bonus law. The development includes 85 dwelling units, consisting of nine studios, 47 one-bedroom units, and 29 two-bedroom units (Attachment 3 – 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, of which twelve (12) are EV-ready and six (6) are equipped with active EV charging stations. 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.
Mechanical equipment will be located on the rooftop and screened from view by the parapet and cornice elements integrated into the building’s design. Trash and utility areas are located within the building envelope, with an internal trash room provided on the lower floor adjacent to the garage.
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.
November 6, 2025
Multi-Family Residential Development at 4898 El Camino Real Page 3 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 while adding
architectural interest and
softening the overall building
mass as viewed from the
street.
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.
The rooftop deck will provide approximately 2,720 square feet of landscaped resident amenity space, including six (6) Golden Spirit Smoke trees in planters, drought-tolerant shrubs, and flowering species. Seating areas, open gathering spaces, and integrated shade elements will create a functional and comfortable outdoor environment. Plantings are arranged to frame outward views, provide privacy between seating areas, and soften the building’s upper profile when viewed from surrounding streets.
Previous Site Approvals
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 approved unit mix included four (4) one-bedroom units, eleven (11) two-bedroom units, and thirteen (13) three-bedroom units. Of these, four (4) units were designated as affordable. The project approval expired on October 1, 2022.
Figure 1: View from El Camino Real
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Multi-Family Residential Development at 4898 El Camino Real Page 4 Analysis
General Plan Consistency
The project is consistent with the General Plan’s Thoroughfare Commercial Land Use Designation, which supports retail, service, office, and higher-density residential uses along El Camino Real, except as modified by State Density Bonus Law. The designation is intended to promote walkability, support local businesses, and provide opportunities for housing near services and transit. By providing a high-density residential development with ground-floor residential support uses, including affordable units utilizing State Density Bonus law, the project aligns with these objectives and contributes to a vibrant, pedestrian-oriented corridor. The project will contribute towards the City’s Regional Housing Needs Assessment (RHNA) obligation and is aligned with the City’s recently adopted 6th Cycle Housing Element by adding eighty-five (85) units to the City’s housing stock, including ten (10) very 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.
Zoning Consistency
The project complies with the Zoning Standards of the Commercial Thoroughfare (CT) Zoning District, except as modified by State Density Bonus law. An analysis of the project’s compliance with CT Standards is provided in the table below:
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Multi-Family Residential Development at 4898 El Camino Real Page 5 CT Zoning District Zoning Standards
Requirement Proposal Project Compliance
Front setback Minimum 20 ft 17 ft 2.5 in Waiver requested under State Density Bonus
Front setback
landscaping
Minimum 50% of
setback area landscaped
795 square feet
(50%)
Complies
Interior side
setback
Minimum 10 ft 9 ft 6 in Waiver requested under
State Density Bonus
Interior side
setback
landscaping
Minimum 50% of
setback area landscaped
41.5% Waiver requested under
State Density Bonus
Exterior side
setback
Minimum 15 ft 8 ft Waiver requested under
State Density Bonus
Exterior side
setback
landscaping
Minimum 50% of
setback area landscaped
50.8% Complies
Rear setback Minimum 25 ft 20 ft 8 in Waiver requested under State Density Bonus
Rear setback
landscaping
Minimum 50% of
setback area landscaped
14% Waiver requested under
State Density Bonus
Building height 55 ft (5 stories) 109 ft 9 in (8
stories)
Waiver requested under
State Density Bonus
Private Open
Space
An average of 50 square
feet
An average of 50.8
square feet
Project Complies
Common Open
Space
Minimum of 2,400
square feet
3,280 square feet Project Complies
Off-Street
Vehicle Parking
0 Spaces. AB 2097
eliminates minimum
parking requirements for
projects within one-half
mile of a major transit
stop; the site is located
95 automated
parking spaces
Project Complies
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Multi-Family Residential Development at 4898 El Camino Real Page 6 CT Zoning District Zoning Standards
within this distance and
therefore qualifies for
the exemption.
Bicycle Parking 5 short -term (Class-II)
bicycle parking spaces.
128 long-term (Class-I)
bicycle parking spaces.
5 short-term (ClassII) bicycle parking
spaces
128 long-term
(Class-I) bicycle
parking spaces
Project Complies
The project must also comply with the City’s Objective Design Control Standards, as outlined in Los Altos Municipal Code (LAMC) Section 14.50.170 for the CT Zoning District and Section
14.66.280 for all multiple-family and mixed-use projects. Except for the requested waivers under Density Bonus, the project is consistent with the applicable Objective Design Control Standards.
The requested waivers to the objective design control standards are described in the “Density Bonus Request” section of this report.
Density Bonus Request
Under California’s Density Bonus Law (Government Code Section 65915 et seq.), the Thoroughfare Commercial (TC) General Plan designation and the Commercial Thoroughfare (CT) Zoning District do not establish a fixed maximum dwelling unit density. In such cases, the City calculates base density using a hypothetical development consistent with all applicable standards and average unit sizes. Based on this methodology, the site supports a base density of 116 dwelling units per acre, or 50 units.
The applicant proposes to restrict ten (10) units as very low-income, which represents twenty (20) percent of the base 50 units. Under Government Code Section 65915(f)(2) and Los Altos Municipal Code Chapter 14.28, Table B, projects providing at least fifteen (15) percent of the base units as very low-income are entitled to a fifty (50) percent density bonus. Applying the 50 percent bonus to the 50-unit base allows an additional 25 units, for a subtotal of 75 units. In addition, because the project provides more than five (5) percent very low-income units, it also qualifies for an additional 20 percent bonus under Government Code Section 65915(v). This additional bonus increases the total by ten (10) units, resulting in a maximum of eighty-five (85) units on site.
Accordingly, the project is entitled to 85 total units, including ten (10) very low-income units, as documented in the Density Bonus Report submitted by the applicant (Attachment 4). The report also identifies the requested waivers, which are necessary to accommodate the project at the proposed density while including the required affordable units.
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Multi-Family Residential Development at 4898 El Camino Real Page 7 Waivers
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 such waivers, described below.
1. Front Setback: LAMC §14.50.090 requires a minimum front setback of 20 feet. The project proposes 17 feet 2-1/4 inches. Compliance would reduce the building footprint by about 99 square feet per floor (792 square feet total over eight floors), which would constrain residential layouts and reduce unit yield, directly conflicting with the affordable housing requirement.
2. Interior Side Setback: LAMC §14.50.100(A) requires a minimum 10-foot interior side setback.
The project proposes a 9-foot 6-inch setback. Compliance would reduce the buildable width by approximately 82 square feet per floor (660 square feet total across eight levels), constraining residential layout and preventing the project from achieving the proposed density and affordable housing objectives.
3. Exterior Side Setback: LAMC §14.50.100(B) requires a minimum 15-foot exterior side setback. The project proposes an 8-foot setback. Compliance would remove approximately 1,155 square feet per floor (9,235 square feet total), substantially shrinking the building envelope and eliminating multiple units, thereby undermining project feasibility.
4. Rear Setback: LAMC §14.50.110 requires a minimum rear setback of 25 feet. The project proposes a 20-foot, 8-inch setback. Compliance would displace about 360 square feet per floor (2,880 square feet total), compressing unit depth and circulation and resulting in inefficient layouts and fewer units.
5. Building Height: LAMC §14.50.140(A) limits building height in the CT District to 55 feet, with an additional 12 feet permitted for rooftop equipment and appurtenances under §14.66.240(E), for a combined maximum height of 67 feet. The project proposes a roof deck at 92 feet, 2¼ inches and an elevator overrun at 109 feet, 7¼ inches, exceeding the 67-foot limit by 42 feet, 7¼ inches. A waiver is therefore requested to allow the roof deck to exceed the base height limit by 37 feet, 2¼ inches and the elevator overrun to exceed the combined maximum height by 42 feet, 7¼ inches. Strict adherence to the height limitation would require removal of approximately three stories and 35 units, thereby preventing the project from achieving the density permitted under State Density Bonus Law (Gov. Code §65915).
6. Upper-Story Step Backs: LAMC §14.50.170(B)(1)(a–b) requires a minimum 10-foot step back along the front and street-facing façades for stories above 45 feet. The project proposes no upper-story step backs. Compliance would reduce the building area by approximately 2,051 square feet per floor (8,204 square feet total over four floors), resulting in the loss of roughly ten residential units and making it infeasible to achieve the density allowed under State Density Bonus Law.
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Multi-Family Residential Development at 4898 El Camino Real Page 8
7. Vertical Façade Articulation: LAMC §14.50.170(B)(2)(a)–(b) requires that building façades exceeding 100 feet in length along a right-of-way be divided into primary façade bays no greater than 50 feet in width and secondary façade bays defined by recesses at least three feet deep and 10 feet wide. The project proposes primary bays that exceed 50 feet in some locations and utilizes vertically stacked balconies approximately five feet by 10 feet to provide visual articulation. Full compliance would eliminate about 316 square feet per floor, totaling approximately 2,528 square feet or three residential units, thereby reducing the building’s efficiency and precluding the intended density.
8. Façade Entrances: LAMC §14.50.170(B)(2)(c) requires at least one pedestrian entrance per 150 linear feet along El Camino Real and per primary façade bay along other street frontages.
The project proposes fewer entrances than required to maintain functional interior layouts and avoid the loss of ground-floor residential and commercial space. Full compliance would displace approximately two units, which adversely affects project feasibility and site design objectives.
9. Privacy and Line of Sight: LAMC §14.50.170(B)(5)(a) requires that when primary living spaces and balconies are along a side setback, principal windows and balconies be oriented toward the front or rear of the building. The project orients some primary living space windows and balconies toward the front, rear, and sides to preserve functional layouts and private open space. Enforcing this standard would reduce the building area by approximately 2,099 square feet per level (16,792 square feet total over eight levels) and eliminate about 21 units, substantially constraining unit design and preventing achievement of the intended density under State Density Bonus Law.
10. Parapet Length/Screening: LAMC §14.50.170(B)(6)(a)(v)(b) limits parapet segments above the third floor to twenty-five feet. The project proposes a maximum parapet length of thirtynine feet, five inches. Meeting the standard would reduce approximately 488 square feet of floor area and about one half of a unit, and would require irregular parapet breaks that disrupt façade rhythm and design cohesion. A waiver is requested to preserve architectural consistency, maintain efficient unit layouts, and achieve the permitted density under State Density Bonus Law.
11. Pedestrian-Scaled Entrance: LAMC §14.50.170(C)(3)(a) requires buildings over seventy feet in length along a right-of-way to include at least one forecourt frontage. The project instead provides a recessed main entrance at the corner of Jordan Avenue and El Camino Real.
Compliance would remove about 412 square feet per level (3,296 square feet total), eliminating roughly four units and reducing overall housing capacity.
12. Interior Side Yard Landscaping: LAMC §14.50.100 requires at least 50 percent of the interior side yard to be landscaped. The project provides 41.5 percent. Full compliance would remove approximately 736 square feet, reducing usable site area and eliminating one unit, which would constrain density and overall project feasibility.
13. Rear Yard Landscaping: LAMC §14.50.100 requires at least 50 percent of the required rear yard to be landscaped. The project provides 14 percent. Compliance would displace
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Multi-Family Residential Development at 4898 El Camino Real Page 9 approximately 5,416 square feet, resulting in the loss of about seven units and directly reducing housing capacity.
14. Driveway Landscaping: LAMC §14.50.170(G) requires landscaping on each side of a driveway at grade or in raised planters. Compliance would eliminate approximately 5,416 square feet of developable area, equivalent to seven units, reducing project density.
15. Transformer Fence Height: LAMC §14.72 limits fences within 15 feet of a driveway to a maximum height of 4 feet to preserve visibility. The project proposes a 6-foot-5-inch fence to screen transformers adjacent to the driveway. Compliance would require reducing the fence height, exposing equipment to public view, or redesigning the layout, displacing approximately 5,578 square feet (seven units). To maintain driveway safety, the project will include warning lights and/or signage consistent with the recommendations of the Transportation Impact Analysis prepared by Abrams Associates (2025).
16. Loading Space Location: LAMC §14.74.090 requires at least one on-site loading space of specific dimensions that allows safe vehicle maneuvering without blocking traffic or parking.
Due to site constraints, the project’s loading facility requires vehicles to back onto Jordan Avenue. Relocating the space elsewhere on-site would displace about 5,081 square feet (seven units), undermining the project’s housing capacity and design efficiency.
Conditional Use Permit
The project requires a Conditional Use Permit pursuant to Los Altos Municipal Code Section
14.74.070, which governs the use of automated parking systems as an alternative to conventional off-street parking. The applicant proposes a mechanical parking system providing ninety-five (95) parking spaces in a fully enclosed underground garage. In compliance with code requirements, the system is located within a permanent structure, is supported by a Parking Management Plan, incorporates backup power for emergency operation, and has been reviewed for overall compliance with City requirements. Based on this review, staff finds the project consistent with the requirements of LAMC §14.74.070 and recommends approval of the Conditional Use Permit as outlined in the Draft Resolution (Attachment 1).
Subdivision
The project includes a Vesting Tentative Map for condominium purposes. The subdivision will divide the site into eighty-five (85) individual residential condominium units 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).
Transportation Analysis
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
November 6, 2025
Multi-Family Residential Development at 4898 El Camino Real Page 10 Local Transportation Analysis (LTA) is required for projects adding 50 or more net new daily trips. A transportation analysis was prepared by Abrams Associates Traffic Engineering, Inc. and evaluated the project in accordance with the City’s LTA requirements. Based on the project’s design and a detailed analysis conducted according to the City’s LTA requirements, there would be no significant impacts to traffic operations according to established traffic engineering standards and no off-site transportation improvements would be required (Attachment 5).
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 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
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Multi-Family Residential Development at 4898 El Camino Real Page 11 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 Density Bonus law.
Environmental Review
The 0.43-acre project site is an infill location along El Camino Real surrounded by urban development and contains no natural habitat for endangered species. The proposed development is consistent with the General Plan and CT District standards, as modified by State Density Bonus law, and will not result in significant impacts related to traffic, noise, air quality, or water quality.
The site can be served by all required utilities and public services, and none of the exceptions in CEQA Guidelines Section 15300.2 apply.
Based on the City’s adopted vehicle miles traveled (VMT) policy and CEQA Guidelines section 15064.3, transportation effects under CEQA are evaluated using vehicle miles traveled (VMT). A screening memo prepared by Abrams Associates Traffic Engineering, Inc. confirms that the project is screened out under the City’s VMT Policy based on the map screening and Transit Proximity Screening criteria; therefore, transportation impacts are presumed less than significant.
Therefore, the project qualifies for an exemption under Section 15332 (Infill Development Projects) of the CEQA Guidelines.
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.
At the time of preparation of this report, the Planning Division has not received comments on the proposed project.
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.
RESOLUTION NO. 2025-04
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF LOS ALTOS
APPROVING DESIGN REVIEW AND A CONDITIONAL USE PERMIT FOR AN EIGHT-STORY, 85-UNIT MULTIPLE-FAMILY RESIDENTIAL DEVELOPMENT WITH A STATE DENSITY BONUS WITH WAIVERS AT 4898 EL CAMINO REAL WHEREAS, an application has been submitted for a Design Review Permit (Application No. D25-0001) and Conditional Use Permit (Application No. CUP25-0001) to construct an eightstory, multiple-family residential building at 4898 El Camino Real, consisting of eighty-five (85) residential units, including ten (10) very low-income units, and an automated underground parking system; and
WHEREAS, the approximately 0.43-acre site is currently vacant and is located within the Thoroughfare Commercial (TC) General Plan Land Use Designation and Commercial Thoroughfare (CT) Zoning District; and
WHEREAS, the TC General Plan designation supports retail, service, office, and highdensity residential uses along major corridors such as El Camino Real and encourages mixed-use development that enhances walkability, supports nearby businesses, and provides opportunities for housing near services and transit; and
WHEREAS, the TC General Plan designation and CT zoning district do not establish a fixed maximum dwelling unit density, and pursuant to Los Altos Municipal Code §14.28.050.2, the base density was determined using a hypothetical development consistent with all applicable standards and average unit sizes comparable to the proposed project, resulting in a base density of 50 dwelling units (116 units per acre). The applicant’s inclusion of ten (10) very low-income units qualifies the project for a density bonus consistent with Government Code Section 65915 and supports the City’s adopted Housing Element and overall housing production goals; and WHEREAS, the applicant proposes to restrict ten (10) units as very low-income, representing twenty (20) percent of the base 50 units, which qualifies the project for a 50 percent density bonus under Government Code §65915(f)(2) and LAMC Chapter 14.28, Table B, allowing an additional twenty-five (25) units for a subtotal of seventy-five (75) units. The project also provides more than five (5) percent very low-income units; therefore; qualifies for an additional 20 percent density bonus under Government Code §65915(v), yielding ten (10) additional units for a total of eighty-five (85) units; and
WHEREAS, the applicant has requested waivers of development standards pursuant to Government Code §65915(e) and LAMC §14.28.050 to allow deviations necessary to physically accommodate the proposed project, including modifications to front, interior side, exterior side, and rear setbacks; building height; upper-story step backs; vertical façade articulation; facade entrances; privacy and line-of-sight standards; parapet length; pedestrian-scaled entrance requirements; interior side landscaping, rear yard landscaping, driveway landscaping standards; transformer fence height; and loading space location, consistent with State Density Bonus Law; and
WHEREAS, said Project has been processed in accordance with the applicable provisions of the California Government Code and the Los Altos Municipal Code; and
Resolution No. PC 2025-XX Page 2
WHEREAS, the Planning Commission held a duly noticed public hearing to consider the Project on November 6, 2025 and considered the written record and all public comment; and WHEREAS, all the requirements of the Public Resources Code (PRC), the State California Environmental Quality Act (CEQA) Guidelines, and the regulations and policies of the City of Los Altos have been satisfied or complied with by the City in connection with the Project; and WHEREAS, the findings and conclusions made by the Planning Commission in this 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 solely on the information provided in this Resolution; and WHEREAS, approval of the Project would be 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’s 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.
NOW, THEREFORE, BE IT RESOLVED, that the Planning Commission of the City of Los Altos hereby approves Design Review Permit (Application No. D25-0001) and Conditional Use Permit (Application No. CUP25-0001) for a mixed-use development based on the findings attached hereto as “Exhibit A” and conditions of approval attached hereto as “Exhibit B” and incorporated by this reference.
Resolution No. PC 2025-XX Page 3
EXHIBIT A
Findings
Design Review
With regard to the design review for the Project, the Planning Commission 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, September 17, 2025), which found that the project would
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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. The 2,720-square-foot rooftop terrace includes six trees and drought-tolerant species to provide shade and visual interest, 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 offsite 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
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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 Planning Commission 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
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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.
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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 on November 6, 2027, 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. Applicability of This Permit: This Permit shall apply to any business/owner entity whose use and operational characteristics match those of the approved use. Intensification of the approved use shall require an amendment to this Permit. This Permit shall continue to be valid upon a change of ownership/operator of the site, business, service, use(s), or structure that was the subject of this approval provided the new owner/operator agrees in writing to all applicable conditions and operating standards prior to reopening or maintaining the use or structure(s) under the new ownership. Any new owner/operator must submit a wet (original) signed letter to the Planning Division noting agreement with the enclosed conditions which includes notation of this permit number and the new business/operator name. This letter may be requested by the City at any time.
6. 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.
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7. 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.
8. 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.
9. Single-Phase Development: Construction of the project shall be done in a single phase and shall not be considered a multi-phased development.
10. 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.
11. 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.
12. 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.
13. 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.
14. 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.
15. 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.
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16. 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.
17. 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.
18. 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.
19. 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.
20. 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.
21. Landscape Screening: All utility meters, lines, transformers, backflow preventers, etc., onsite or off-site, must be shown on all site plan drawings and landscape plan drawings. All such facilities shall be located so as 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.
22. 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.
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23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
28. 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).
29. 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.
30. 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,
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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.
31. 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.
32. 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 tool-making 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.
33. 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
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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.
34. 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.
35. 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
36. 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.
37. 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.
38. 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.
39. 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.
40. 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.
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41. 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.
42. 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.
43. 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.
44. 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.
45. 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.
46. 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.
47. Public Utilities: The applicant shall contact electric, gas, communication, and water utility companies regarding the installation of new utility services to the site.
48. 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 build-up of
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hydrostatic pressure; considerations for design of excavation shoring system; excavation monitoring; and seismic design.
49. Off-Haul Excavated Soil: The grading plan shall show specific grading cut and/or fill quantities. Cross section details showing the existing and proposed grading through at least two perpendicular portions of the site or more shall be provided to fully characterize the site.
A note on the grading plans should state that all excess dirt shall be off hauled from the site and shall not be used as fill material unless approved by the Building and Planning Divisions.
ENGINEERING DIVISION
50. Public Infrastructure Repairs: The applicant shall repair any damaged right-of-way infrastructures and otherwise displaced curb, gutter and/or sidewalks and City’s storm drain inlet shall be removed and replaced as directed by the City Engineer or his designee. The applicant is responsible to resurface (grind and overlay) half of the street along the frontage of First Street if determined to be damaged during construction, as directed by the City Engineer or his designee.
51. Construction Management Plan: The applicant shall submit a construction management plan for review and approval by the Development Services Director and the City Engineer.
The construction management plan shall address any construction activities affecting the public right-of-way, including but not limited to excavation, traffic control, truck routing, pedestrian protection, material storage, earth retention and construction vehicle parking. The plan shall provide specific details with regards to how construction vehicle parking will be managed to minimize impacts on nearby single-family neighborhoods. Sidewalks, parking and travel lanes along El Camino Real and Jordan Ave shall not be closed for the full duration of the project. Closures will be reviewed and approved with Encroachment Permit submittals on Jordan Ave. Closures on El Camino Real shall be approved by Cal Trans. The applicant shall be required to have a pre-construction meeting with all abutting property owners to discuss the project schedule and to prominently display a sign with the single point of contact the community should interface with for any construction related impacts from the project.
52. Maintenance Bond: A one-year, ten-percent maintenance bond shall be submitted upon acceptance of improvements in the public right-of-way.
53. 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 for the stormwater treatment methods installed in accordance with the SWMP.
Once approved, City shall record the agreement.
54. Label Catch Basin Inlets: The applicant shall label all new or existing public and private catch basin inlets which are on or directly adjacent to the site with the “NO DUMPING - FLOWS TO ADOBE CREEK” logo as required by the City.
55. 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 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.
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56. Public Improvements: Install or reconstruct standard public improvements required for the project along the project frontages of El Camino Real and Jordan Ave. These improvements include, new sidewalk, curb and gutter including extending the sidewalk along the frontage on Jordan Ave to the corner of El Camino Real and Jordan Ave. Additionally the applicant shall grind and overlay half of Jordan Ave as directed by the City Engineer. a. Provide a 5-foot wide sidewalk along Jordan Ave; the 6-inch curb shall not be included in the sidewalk width.
b. The existing street centerline on Jordan Ave shall be repainted and extended to a total length of 150 feet.
c. Provide checker non-slip lids for the electric vault and all other utility lids located within the right-of-way.
57. Traffic Control Plans: Upon submitting the initial building permit and improvement plans, the applicant shall submit traffic control plans for any off-site and on-site improvements or any work that requires temporary lane closure, shoulder closure, bike lane closure, and/or sidewalk closure for review and approval. Sidewalk closures are not allowed unless reconstruction of sidewalk necessitates temporary sidewalk closure. In these instances, sidewalk detour should be shown on the Traffic Control plans. Traffic control plans shall be prepared in accordance with the latest edition of the California Manual of Uniform Traffic Control Devices (CA MUTCD).
58. 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.
59. Storm Water Management Plan: The applicant shall submit a Storm Water Management Plan (SWMP) in compliance with the San Francisco Bay Region Municipal Regional Stormwater (MRP) National Pollutant Discharge Elimination System (NPDES) Permit No.
CA S612008, Order R2-2022-0018, Provision C.3 dated May 11, 2022. All projects that create and/or replace 5,000 sq. ft. or more of impervious surface on the project site and affected portions of the public right-of-way that are developed or redeveloped as part of the project must also complete a C.3. Data Form available on the City’s Building Division website. The SWMP shall be reviewed and approved by a City approved third party consultant at the Applicant’s expense. The recommendations from the SWMP shall be shown on the building permit plans.
60. Pollution Prevention: The improvement plans shall include the “Blueprint for a Clean Bay” plan sheet in all plan submittals.
61. 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.
62. 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. PC 2025-XX Page 16
63. Transportation Permit: A Transportation Permit, per the requirements specified in California Vehicle Code Division 15, is required before any large equipment, materials or soil is transported or hauled to or from the construction site. Applicant shall pay the applicable fees before the transportation permit can be issued by the City Engineer.
64. Encroachment Permit: An encroachment permit and/or an excavation permit shall be obtained prior to any work done within the public right-of-way and it shall be in accordance with plans to be approved by the City Engineer. Any work within El Camino Real will require the applicant to obtain an encroachment permit with Caltrans prior to commencement of work.
65. Grading and Drainage Plan: The applicant shall submit on-site grading and drainage plans that include (i.e. drain swale, drain inlets, rough pad elevations, building envelopes, drip lines of major trees, elevations at property lines, all trees and screening to be saved) for approval by City Engineer. No grading or building pads are allowed within two-thirds of the drip line of trees unless authorized by a certified arborist and the Planning Division.
66. Cost Estimate and Performance Bonds: The applicant shall submit a cost estimate for the improvements in the public right-of-way and shall submit a 100 percent performance bond or cash deposit (to be held until acceptance of improvements) and a 50 percent labor and material bond (to be held 6 months after acceptance of improvements) for the work in the public right-of-way.
67. Condominium Map: The applicant shall record the condominium map as required by the City Engineer prior to final occupancy.
68. Public Access Easement: The applicant shall dedicate public access easements for the purpose of providing pedestrian access prior to the recordation of the final map.
69. Public Utility Dedication: The applicant shall dedicate public utility easements as required by the utility companies to serve the site.
70. 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.
71. New ADA Ramps and Crosswalks: The applicant shall provide new ADA ramps and crosswalk striping per the City standards at the corner of El Camino Real and Jordan Ave crossing over Jordan Ave. Additionally, ADA ramps shall be installed in either side of the proposed driveway on Jordan Ave and an ADA ramp shall be installed at the corner or El Camino Real and Jordan Ave crossing El Camino Real.
a. New ADA Ramps shall follow the latest Caltrans Standard Detail A88A. b. Truncated domes on ADA ramps shall be cast iron and baked-on-oil finish. c. The crosswalk on Jordan shall be repainted.
72. Parking Stall and Red Curb Striping: The applicant shall install parking stall striping and red curb as directed by the City Engineer or his designee. a. Provide a minimum 20 feet of red curb on each side of the driveway entrance. b. Provide red curb starting at the end of curb on El Camino Real and extending 30 feet into Jordan.
Resolution No. PC 2025-XX Page 17
73. Sewage Capacity Study: The applicant shall show sewer connection to the City sewer main and submit calculations showing that the City’s existing 8-inch sewer main will not exceed two-thirds full due to the additional sewage capacity from the proposed project. For any segment that is calculated to exceed two-thirds full for average daily flow or for any segment that the flow is surcharged in the main due to peak flow, the applicant shall upgrade the sewer line or pay a fair share contribution for the sewer upgrade to be approved by the City Engineer.
74. Solid Waste Ordinance Compliance: The applicant shall be in compliance with the City’s adopted Solid Waste Collection, Remove, Disposal, Processing & Recycling Ordinance (LAMC Chapter 6.12) which includes a mandatory requirement that all multi-family dwellings provide for recycling and organics collection programs.
75. Solid Waste and Recyclables Disposal Plan: The applicant shall contact Mission Trail Waste Systems and 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.
FIRE DEPARTMENT
76. Formal Plan Review: Review of this Developmental proposal is limited to acceptability of site access and water supply and may include specific additional requirements as they pertain to fire department operations and shall not be construed as a substitute for formal plan review to determine compliance with adopted model codes. Prior to performing any work, the applicant shall make application to, and receive from the Building Division all applicable construction permits.
77. Fire Sprinklers Required: Approved automatic sprinkler systems in new and existing buildings and structures shall be provided in the locations described in this section or in Sections 903.2.1 through 903.2.18, whichever is more restrictive. For the purposes of this section, firewalls used to separate building areas shall be constructed in accordance with the California Building Code and shall be without openings or penetrations. The owner(s), occupant(s), and any contractor(s) or subcontractor(s) are responsible for consulting with the water purveyor of record to determine if any modification or upgrade of the existing water service is required. A State of California licensed (C-16) Fire Protection Contractor shall submit plans, calculations, a completed permit application, and appropriate fees to this department for review and approval prior to beginning work. CFC Sec. 903.2
78. Fire Alarm Requirements: Refer to CFC Sec. 907 and the currently adopted edition of NFPA 72. Submit shop drawings (three sets) and a permit application to the Santa Clara
Resolution No. PC 2025-XX Page 18
County Fire Department (SCCFD) for approval before installing or altering any system.
79. Public Fire Hydrant Required: Provide a public fire hydrant at a final location to be determined jointly by the Fire Department and California Water Company. The maximum distance shall be 250 feet from the building frontage, 500 feet between hydrants, and a maximum of 100 feet from the Fire Department Connection (FDC), with a minimum hydrant flow of 1,500 GPM at 20 psi residual. Fire hydrants shall be provided along required fire apparatus access roads and adjacent public streets. CFC Sec. 507, Appendix B, and Appendix C.
80. Fire Hydrant Systems Required: Where a portion of a facility or building is more than 400 feet from a hydrant on a fire apparatus access road, measured by an approved route around the exterior, onsite fire hydrants and mains shall be provided as required by the fire code official. Exception: For Group R-3 and Group U occupancies equipped throughout with an approved automatic sprinkler system, the distance requirement shall be not more than 600 feet. [CFC Sec. 507.5.1]
81. High-Rise Requirements: Every building with floors used for human occupancy located more than 75 feet above the lowest floor level with building access, except hospitals, shall meet high-rise structure requirements per CFC 202 Definition. Include a note on plans indicating this project requires high-rise structure compliance.
82. Buildings and Facilities Access: Approved fire apparatus access roads shall be provided for every facility or building. The access road shall comply with the requirements of this section and extend to within 150 feet of all portions of the facility and exterior walls of the first story, measured by an approved route around the exterior. [CFC Sec. 503.1.1]
83. Required Aerial Access: Where the vertical distance between the grade plane and the highest roof surface exceeds 30 feet, approved aerial fire apparatus access roads shall be provided. At least one required access route shall be located within 15 to 30 feet of the building and parallel to one entire side. Exception: Where approved by the fire code official, Type IA, IB, or IIA buildings fully sprinklered under Section 903.3.1.1 and having firefighter access through an enclosed stairway with a Class I standpipe from the lowest vehicle access level to all roof surfaces. Overhead power lines shall not be located within the aerial access roadway. [CFC Ch. 5 and SCCFD SD&S A-1]
84. Knox Key Boxes/Locks Where Required for Access: Where access to or within a structure or area is restricted because of secured openings or where immediate access is necessary for lifesaving or firefighting purposes, a key box shall be installed in an approved location. The Knox Key Box shall contain keys for required access. Gates or barriers shall be equipped with Knox Locks. Operators must notify the fire code official and update keys when locks are changed. [CFC Sec. 506]
85. Fire Department Connection: The FDC shall be installed on the street-address side of the building, within 100 feet of a public fire hydrant and within ten feet of the main Post Indicator Valve (PIV), unless otherwise approved. FDCs shall have at least two 2½-inch national standard threaded inlet couplings, be painted safety yellow, and oriented for unobstructed hose access. [SCCFD SP-2 Standard]
Resolution No. PC 2025-XX Page 19
86. Two-Way Communication System: Two-way communication systems shall be designed and installed per NFPA 72 (2022), the California Electrical Code (2022), the California Fire Code (2022), and the California Building Code (2022). Revise plans to show this as a deferred submittal item.
87. Emergency Responder Radio Coverage in New Buildings: All new buildings shall provide approved radio coverage for emergency responders within the building based on existing coverage levels at the exterior. This section shall not require improvement of public safety communication systems. [CFC Sec. 510.1]
88. Standpipes Required: Standpipe systems shall be provided where the floor-level of the highest story is more than 30 feet above the lowest level of fire department vehicle access.
Systems shall be manual wet type and installed in accordance with NFPA 14. [CFC Sec. 905]
89. Required Fire Flow: The minimum required fire flow for this project is 1,500 GPM at 20 psi residual pressure, assuming installation of automatic sprinklers per CFC Sec. 903.3.3.1.
90. Fire Lanes Required: The minimum clear width of fire department access roads shall be 20 feet. Fire lanes shall be designated and marked as required by California Vehicle Code Section 22500.1. Plans shall show proposed red curbs, fire lane markings, and access sign locations.
91. Water Supply Requirements: Potable water supplies shall be protected from contamination caused by fire protection water supplies. The applicant and contractors shall coordinate with the water purveyor to meet all requirements. Final system approval requires written confirmation from the purveyor that all standards have been met. [CFC Sec. 903.3.5 and Health and Safety Code 13114.7]
92. Address Identification: New and existing buildings shall have approved address numbers visible from the street or road fronting the property. Numbers shall contrast with the background, be a minimum of six inches high, and have a minimum stroke width of 0.5 inch.
For buildings not visible from the public way, provide a monument or sign. [CFC Sec. 505.1]
93. Construction Site Fire Safety: All construction sites must comply with applicable provisions of CFC Chapter 33 and SCCFD Standard Detail and Specification S1-7. Include appropriate notations on subsequent plan submittals.
94. Building Construction Type Compliance: The construction type of the building shall be verified to be compliant with the allowable height, area, and number of stories permitted under the California Building Code (CBC).
95. Standby and Emergency Power: Standby and emergency power shall be provided in accordance with CBC Section 403.4.8. If a generator is proposed, its location shall be shown on the plans.
96. Smoke-Proof Enclosures for Stairways: Smoke-proof enclosures shall be provided for all interior exit stairways in compliance with CBC Section 403.5.4.
Resolution No. PC 2025-XX Page 20
97. Fire Command Center: A fire command center shall be provided in the main lobby area per CBC Section 403.4.6. The command center size and configuration shall comply with CFC Section 508.1.3.
98. Smoke Control System Space Requirements: Sufficient space and designated area shall be provided for the smoke control system as required by CBC Section 403.4.7.
99. Fire Pump Room Access: Where a fire pump is required, fire pump rooms not directly accessible from the exterior shall be accessible through a fire-resistance-rated corridor from an enclosed stairway or exterior exit, consistent with NFPA 20 Section 4.14.2.1.1. 100. Fire Pump Power Source Reliability: Where an electric fire pump is proposed, the power source shall meet the reliability requirements of NFPA 20 Section 9.3.2, including:
a. The source power plant has not experienced shutdowns exceeding ten continuous hours in the past three years.
b. Power outages are not routinely experienced in the service area. c. The normal source of power is not supplied by overhead conductors outside the protected facility.
d. Only disconnect switches and overcurrent protection devices permitted by NFPA 20 Section 9.2.3 are installed in the normal source of power. 101. Secondary Water Supply: A secondary water supply shall be provided for the sprinkler system in accordance with CBC Section 403.3.3, and its location and capacity shall be clearly identified in the plans.
102. Smoke Control System Basis of Design Report: Prior to building permit review, a basis of design report for the smoke control system shall be provided. The report, while conceptual in nature, shall include all elements required in the final Smoke Control Report other than calculations, supporting data, and diagrams.
From: Guiting Ye
Sent: Friday, January 16, 2026 1:13 PM
To: Stephanie Williams <[email protected]>
Cc: Melissa Thurman <[email protected]>
Subject: 4898 El Camino Real Appeal - Materials
Hi Stephanie,
I am writing to submit materials for inclusion in the agenda packet for the 4898 El Camino Real Appeal hearing scheduled for January 27, 2026. Please include the following documents in the public record and agenda packet as part of the appeal materials:
1. Elite Transportation Group (ETG) letter dated December 21, 2025, regarding traffic safety concerns for the project
2. Summary on traffic counts for the intersection of Jordan Avenue and El Camino Real (December 10–11, 2025)
3. Worksheets for the traffic study
4. Raw traffic count data from December 10 and December 11, 2025 (Excel file) These materials are being submitted because I believe 4898 El Camino Real, as approved, presents significant unresolved public safety risks related to traffic operations, roadway design, and conflicts with pedestrians, bicyclists, and students.
In particular, the materials document and highlight the following safety issues:
• Dangerous congestion and queueing on Jordan Avenue during the morning peak:
Observed backups of 17–22 vehicles are common, often requiring multiple signal cycles to clear. These conditions create a high-stress environment that increases the likelihood of aggressive driving, risky maneuvers, and collisions—particularly in a corridor heavily used by school commuters.
• Unsafe roadway conditions due to insufficient street width and parked cars:
Jordan Avenue cannot safely accommodate two turn lanes toward El Camino Real, one lane from El Camino Real, and parked cars on both sides of the street. This routinely forces pedestrians and bicyclists into the roadway to maneuver around stationary vehicles, creating clear conflict points and safety hazards. • Frequent disruption from routine activities that immediately create safety risks:
Even brief events—such as a double-parked car, a delivery truck stopping, or a large
vehicle turning—have been observed to cause immediate traffic backups. This demonstrates how fragile and unsafe the current conditions are for all road users. • High-risk conflicts at the project driveway for vulnerable users:
As detailed in the ETG letter, the design of the project driveway creates a direct conflict between right-turning vehicles exiting the site and pedestrians, bicyclists, and scooter users. This risk is exacerbated by a solid transformer fence that blocks visibility, reducing drivers’ ability to see approaching sidewalk users—many of whom are middle school students traveling to nearby schools. • Compounding safety risks during the morning peak:
Overlapping peak-hour activities—including school commutes, trash collection, and traffic from recently approved nearby development—combine to create a particularly hazardous environment with constrained roadway space and heightened conflict potential.
• Existing failing intersection conditions that will be made worse:
The Jordan Avenue / North San Antonio Road intersection already operates at Level of Service (LOS) F. Adding additional project-generated traffic without meaningful mitigation will further degrade conditions, increase driver frustration, and elevate safety risks for pedestrians, bicyclists, and motorists alike.
Given these unresolved safety concerns, I respectfully request that these materials be included in the agenda packet and considered fully as part of the appeal.
Please confirm receipt of these documents and their inclusion in the public record. I am happy to provide any additional information if needed.
Thank you for your time and attention.
Sincerely,
Guiting
Elite Transportation Group (ETG) | Integrity ∞ Quality ∞ Reliability Modeling • Planning • Engineering • ITS Page 1 of 2
December 21, 2025
SUBJECT: 4898 El Camino Real – New Multi-Family Residential Project: Traffic Safey Issues To Whom It May Concern:
I, Lin Zhang, Ph.D., PE, TE, PTOE, have reviewed both the site plan and the traffic impact analysis report for the 4898 El Camino Real Residential Project. I have over 20 years of experience in Transportation Engineering and Planning, with progressively responsible roles across both public agencies and private consulting. My areas of expertise include traffic engineering, traffic safety, corridor studies, traffic simulation and modeling, traffic signal systems, and Intelligent Transportation Systems (ITS). I am a licensed Professional Engineer (PE) and Traffic Engineer (TE) in the State of California. Based on my review, there are major safety concerns that have not been addressed, as listed below. • Driveway Right-Turn Conflict with Bicyclists, Scooters, and Pedestrians: Our primary concern is safety at the development driveway, particularly for vehicles exiting the driveway and turning right. This movement creates a direct conflict with pedestrians, scooters, and bicyclists using the sidewalk/walkway on the development side. This risk is amplified by the approximately 6½ -foot-high solid transformer fence, which visually obscures approaching sidewalk users and reduces the driver’s ability to detect a pedestrian, scooter, or bicyclist in time.
As a result, a vehicle turning right out of the driveway could strike a pedestrian, scooter, or bicyclist traveling along the project-side sidewalk. Most bike, sooter, and pedestrian users on this segment appear to be Grade 5–8 students traveling to and from two nearby schools. Based on a recent field observation, about 60 bicyclists/scooters/pedestrians used this segment in the morning peak hour during which many students travel from El Camino Real toward Portola Avenue, and they are very likely to use the sidewalk on the development side because it is more direct and typically requires fewer street crossings.
• “All-At-Once” Morning Peak Conflicts and Compounding Operational Complexity: My second concern is the increased safety risk when multiple peak-hour elements occur at the same time:
o Trash collection during the Friday morning peak: When the loading zone is occupied during trash pickup (noting that collection occurs around 8:00–8:30 AM, which overlaps with the morning peak and student commute), it can create added conflicts and unexpected maneuvers. This introduces additional safety risks for drivers, pedestrians, and bicyclists when everyone is rushing and roadway space is constrained. o Cumulative growth from already-approved development across the street: The site across the street (currently Jack-in-the-Box) received approval in 2024 for a redevelopment adding 33 units. With this proposed project (approximately 85 units), the
Elite Transportation Group (ETG) | Integrity ∞ Quality ∞ Reliability Modeling • Planning • Engineering • ITS Page 2 of 2
corridor will experience a combined addition of 118 units (33 + 85). The combined effect will further elevate peak-hour operational strain and safety risk at Jordan Avenue/driveway crossing locations.
• Jordan Avenue / North San Antonio Road Intersection Operational and Safety Concerns:
The Traffic Analysis Report acknowledges that the Jordan Avenue / North San Antonio Road intersection currently operates at Level of Service (LOS) F under existing conditions. Despite this baseline deficiency, the traffic analysis concludes that traffic generated by the proposed 85- unit development does not require mitigation. I strongly disagree with this conclusion. Any additional traffic introduced at an intersection already operating at LOS F will further degrade operations, increase delay and queueing, and exacerbate driver frustration and aggressive maneuvers. These conditions directly elevate safety risks—particularly for pedestrians, scooters, and bicyclists—at an intersection that already experiences congestion during peak periods. Given the existing LOS F conditions, the project’s traffic should not be dismissed as inconsequential. At a minimum, the City should require a focused safety and operational analysis and identify appropriate mitigation measures to address the added risk introduced by the project, especially during peak hours when vehicle, bicycle, scooter, and pedestrian volumes overlap.
If you have any questions, please do not hesitate to contact me at (510) 673-9656 or [email protected].
Sincerely,
Elite Transportation Group, Inc. (ETG)
Lin Zhang, PhD, PE, TE, PTOE
Vice President
Summary on traffic counts for the intersec2on of Jordan and El Camino.
Jim and I counted traffic both going into the intersec2on from Jordan and coming out of the intersec2on of El Camino Real onto Jordan Avenue. We did the counts on Dec. 10, a Wednesday, and Dec. 11, 2025, a Thursday. We counted in 10-minute increments. Unfortunately, we started the increments at different 2mes (One day at 8:10, 8:10, etc. and one day at 8:05, 8:15 etc.) but this should not affect the conclusions or observa2ons.
Note that:
Wednesday was a late start day for Egan. School did not start un2l 9:15pm Thursday was wheels or walk to school for Egan.
Both days were quite cold and overcast
As shown in the included summary, the peak period was from 8:10 to 8:40 on Wednesday and 8:05 to 8:45 on Thursday. The Thursday traffic load was spread out over a longer period (un2l 9am), probably due to the late start at Egan.
Some other observa2ons:
• The intersec2on of Marich and Jordan seems to have as much if not more traffic than the ECR/Portola intersec2on. Cars coming off ECR onto Portola may go straight at the Marich or they may turn leZ. Addi2onally, there appears to be a lot of traffic that bypasses the light at ECR onto Jordan by turning off ECR onto Distel, then onto Marich then turning leZ onto Portola. There are also more bikes and pedestrians at this intersec2on.
• Because of the lack of sidewalks or marked crosswalks in the area on Jordan around the Jack-in-the-Box, there were at least 5 incidences where bikes or pedestrians had to move around sta2onary cars. Jordan is not wide enough to handle 3 lanes of traffic (2 turning onto ECR and 1 turning from ECR onto Jordan) plus the parked cars on both sides of Jordan by the intersec2on. (There were at least 4 cars parked on each side of Jordan) • The traffic would be higher at the intersec2on if people could not use the parking lots behind the proposed building as a cut-through from Jordan to ECR. • At one 2me there were 22 cars backed up on Jordan wai2ng for the turn signal onto ECR.
It took 2 turns of the light for cars to get through. 17-20 cars backed up was the norm in the 8:20-8:40 2meframe.
• At one point, a car double parked on Jordan near the apartment building past the JackIn-The Box to pick up a passenger and traffic immediately backed up. There was also a large truck on Jordan heading toward ECR that stopped temporarily to make a leZ turn and traffic again backed up. That en2re area is sensi2ve to any ac2vity that does not just go straight.
Let us know if you have any ques2ons.
Rose Rambo and Jim Clark
778 Jordan Ave
Traffic Count for Jordan/ECR intersection on Dec 10 and Dec 11 2025 10-Dec
Cars bikes/scooters pedestrians Cars bikes/scooters pedestrians Cars bikes/scooters pedestrians 7:50-8:00am 11 0 0 26 4 3 37 4 3
8:00-8:10 11 9 1 23 1 3 34 10 4
8:10-8:20 72 3 2 28 2 3 100 5 5
8:20-8:30 54 3 0 60 1 3 114 4 3
8:30-8:40 17 2 2 32 2 1 49 4 3
8:40-8:50 14 3 5 19 2 2 33 5 7
8:50-9:00 17 2 1 28 0 1 45 2 2
9:00-9:10 10 0 1 9 0 2 19 0 3
11-Dec
Cars bikes/scooters pedestrians Cars bikes/scooters pedestrians Cars bikes/scooters pedestrians 7:35-7:45am 13 2 0 20 0 0 33 2 0
7:45-7:55 16 7 4 15 1 1 31 8 5
7:55-8:05 12 5 5 20 1 2 32 6 7
8:05-8:15 45 8 13 20 1 4 65 9 17
8:15-8:25 90 0 0 45 1 1 135 1 1
8:25-8:35 26 0 2 40 1 5 66 1 7
8:35-8:45 17 0 0 40 3 1 57 3 1
to Portola from ECR to ECR from Portola Totals
to Portola from ECR to ECR from Portola Totals
PATTERSON & O’NEILL, PC
235 Montgomery Street, Suite 950
San Francisco, CA 94104
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
January 15, 2026
VIA E-MAIL AND U.S. MAIL
Los Altos City Council
Council Chambers
1 N San Antonio Road
Los Altos, CA 94022
Re: Agenda Item XXX
4898 El Camino Real (File Nos. D25-0004, CUP25-0001)
Housing Development Project Appeal
Dear Mayor Dailey and Councilmembers:
Our office represents ADL 15 LLC, the applicant for an eighty-five-unit multi-family housing development project, with ten of the units dedicated as affordable to very low-income households, located at 4898 El Camino Real (the “Project”). The Project will provide much needed housing on a vacant project site that is located just steps away from a major transit stop.
The Project consists solely of residential uses and is thus protected by the provisions of the Housing Accountability Act (“HAA”), which significantly limits the ability of local governments to disapprove, lower the density, or conditionally approve housing development projects. (Gov.
Code § 65589.5.) In addition, because the Project restricts 25% of the base units as affordable to very low-income households, the Project is eligible for the regulatory benefits of the state Density Bonus Law (“DBL”). (Gov. Code § 65915.) As explained further below, the Project is consistent with all applicable laws and therefore must be approved as proposed. The appellants’ have not raised any legitimate issues, and the Planning Commission’s approval must be upheld.
I. PROJECT APPROVAL AND APPEAL BACKGROUND
A. The Project Approvals
On November 6, 2025, the Planning Commission approved a Design Review Application (“DRA”) and Conditional Use Permit (“CUP”) for the Project. In addition, the Planning Commission adopted a resolution to recommend that the Council approve a Vesting Tentative Map (“VTM”) for the condominium map. As required by Gov. Code § 66452.2 and Los Altos Municipal Code (“LAMC”) § 13.12.050, the Council took action to approve the VTM at its next regular meeting on November 17, 2025 after receiving the Planning Commission’s recommendation.
Mayor Dailey and Councilmembers
January 15, 2026
B. The Neighbors’ Appeal
On November 16, 2025, neighbors of the Project submitted an appeal of the Commission’s DRA and CUP approval. The appeal forms did not state that the neighbors appeal was related to the Commission’s VTM recommendation.
The stated bases for the appeal are without merit, and demonstrate fundamental misunderstandings of both state housing law and the California Environmental Quality Act (“CEQA”). The neighbors’ actions are motivated entirely by self-interest, and they have not raised any genuine legal or environmental concern. Rather, neighbors are attempting to abuse the appeal and legal process to cause delay in the hopes of squeezing concessions from the developer and the City. As one of the appellants admitted in his subsequent legal filing, the true concern is not about any purported imagined environmental impacts, but the “future prospects for the value and development of his property.” The Council should see this appeal for what it is – a baseless effort to cause delay and prevent new housing. As such, the Council must deny the appeal and uphold the Planning Commission’s approval.
The appeal contentions can be broken down into four categories. First, appellants make various erroneous claims about the DBL, raising arguments that directly contradict state law and legal precedent. Second, the appellants argue that the Project is inconsistent with objective, health and safety standards without ever identifying any of the objective standards that the Project purportedly fails to meet. Third, the appellants argue the Project is not exempt from CEQA based on issues that are not relevant to CEQA and without providing any evidence of any actual environmental impacts at all. Finally, the appellants argue that they were somehow denied their constitutional rights to due process even though the appellants have had multiple opportunities to heard. Each of these frivolous contentions are addressed in detail below.
II. LEGAL BACKGROUND
A. Density Bonus Law
The DBL is intended to create “incentives for the construction of more housing across all areas of the state” and to “cover at least some of the financing gap of affordable housing with regulatory incentives, rather than additional public subsidy.” (Gov. Code § 65915(u).) To accomplish this, an applicant may seek a “density bonus,” which means a “density increase over the otherwise maximum allowable gross residential density.” (Id. subd. (f).) Courts have explained that the DBL “imposes a clear and unambiguous mandatory duty on municipalities to award a density bonus when a developer agrees to dedicate a certain percentage of the overall units in a development to affordable housing.” (Friends of Lagoon Valley v. City of Vacaville (2007) 154 Cal.App.4th 807, 823.)
The amount of density bonus is based on the “maximum allowable gross residential density” or “base density,” which the law defines as “the maximum number of units allowed under the zoning ordinance, specific plan, or land use element of the general plan.” (Id. subd. (o)(6).)
Mayor Dailey and Councilmembers
January 15, 2026
Where existing standards do not establish density based on a dwelling unit per acre standard, an agency must calculate the base density by “[e]stimating the realistic development capacity of the site based on the objective development standards applicable to the project.” (Id.) The law states that a “developer may provide a base density study and the local agency shall accept it.” (Id.) The density bonus determination must occur at the early stage of the application process. The DBL states that to “provide for the expeditious processing of a density bonus application,” after an application is accepted as complete, an agency must provide the applicant with determinations regarding the amount of density bonus and parking ratios for which the project is eligible. (Id. subd. (a)(3)(D).) An agency may only adjust the density bonus and parking ratio determinations “based on any changes to the project during the course of development.” (Id.) The DBL also prohibits a local government from subjecting a project to “any development standard that will have the effect of physically precluding the construction of a development” at the densities permitted. A developer may propose to have any such standards waived or reduced, and the City may only refuse a proposed waiver for three specifically enumerated reasons: 1) the waiver would have a specific, adverse impact upon public health or safety; 2) the waiver would have an adverse impact on a property listed in the California Register of Historical Resources; or 3) the waiver is contrary to state or federal law. (Gov. Code, § 65915(e)(1).) There is no limit on the number of waivers a project can request.
Because the DBL strictly limits the reasons a waiver can be denied, a project that qualifies for a density bonus “provides a developer with broad discretion to design projects with additional amenities even if doing so would conflict with local development standards.” (Bankers Hill 150 v. City of San Diego (2022) 74 Cal.App 5th 755, 774-75.) Moreover, the DBL does not authorize the City to deny waivers “based on the theory that another project, with a similar number of units, might conceivably be designed differently and accommodated without waivers.” (Wollmer v. City of Berkeley (2011) 193 Cal.App.4th 1329, 1346–1347.) In short, the City may not deny a waiver unless the City makes one of the three required findings explained above.
B. Housing Accountability Act
In enacting the HAA, the Legislature found and declared that California “has a housing supply and affordability crisis of historic proportions.” To address this crisis, the HAA greatly limits a local government’s ability to disapprove, lower the density, or conditionally approve projects that comply with applicable objective standards and generally prohibits local governments from applying subjective standards. (Gov. Code § 65589.5(j)(1); see also Cal. Renters Legal Advocacy & Educ. Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 844.) The term “objective” is defined as meaning “involving no personal or subjective judgment by a public official and being uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official.” (Id. subd. (h)(8).)
Mayor Dailey and Councilmembers
January 15, 2026
For a code-consistent project, a local government must make written findings supported by a preponderance of the evidence in the record that the project would have an unmitigable, specific, adverse impact upon the public health. (Id. subd. (j)(1).) The HAA further defines “specific, adverse impact” to mean “a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.” (Id.) For extra measure, the Legislature also declared that “the conditions that would have a specific, adverse impact upon the public health and safety . . . arise infrequently.” (Id. subd. (a)(3).) The HAA sets strict timelines for local agencies to determine whether a proposed housing development project is inconsistent with any applicable standard. An agency must provide written documentation identifying and explaining any inconsistencies “[w]ithin 30 days of the date that the application for the housing development project is determined to be complete” for projects with 150 or fewer housing units. (Gov. Code § 65589.5(j)(2).) If an agency fails to timely provide the required inconsistency documentation, “the housing development project shall be deemed consistent.” (Id.) The HAA makes clear that “the receipt of a density bonus, incentive, concession, waiver, or reduction of development standards pursuant to [the DBL] shall not constitute a valid basis on which to find a proposed housing development project is inconsistent.” (Id. subd. (j)(2).) The consistency determination is governed by a “reasonable person” standard, where a project is deemed consistent if there is substantial evidence that would allow a reasonable person to conclude the project is consistent. (Id. subd. (f)(4).) III. APPEAL RESPONSE
A. Response to the Appellant’s Density Bonus Law Contentions
Base Density
The appellants claim, without evidence, that the base density study completed for this project is inaccurate. The base density study was included in the Planning Commission report, yet the appellants still have not identified any flaws in the study. This is unsurprising, as the base density study is accurate and legally valid. Rather than identify any insufficiencies with the existing study, the appellants argue for a “rigorous massing study” to cause unnecessary delay. This is entirely inconsistent with the requirements of the DBL.
First, as explained above, a local agency is required to accept an applicant’s base density study and make a determination on the amount of density bonus at the start of the application process after an application is deemed complete. Even if the City wanted to change the density bonus determination, any change to the density bonus determination can only be “based on any changes to the project during the course of development.” (Gov. Code § 65915(a)(3).) No changes in the project have occurred, and therefore the City cannot alter its prior density bonus determination.
Second, the California Department of Housing and Community Development (“HCD”), the state agency charged with enforcing state housing law, has explained that the base density study must be applied in a permissive manner to roughly estimate the base density and is not intended to
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impose a strict, labor-intensive process.1 HCD has stated that a local agency should “apply only those objective standards necessary to reasonably calculate a base density” and should eliminate any standard that “does not serve to roughly estimate the total floor area of the hypothetical base project.” The purpose of the study is not to shrink the building, but to “apply development standards in a generous, permissive way to produce the maximum number of total housing units.” The appellants argue the exact opposite of what the law requires. The base density study is accurate and valid, and must be accepted.
Requested Waivers
The appellants urge the Council to violate the DBL by refusing to grant development standard waivers to which the Project is entitled. The appeal asserts the incorrect legal standard, stating that the applicant must show that there is no possible way to achieve the permitted density without the requested waivers. This argument, which the appellant dubs the “physical preclusion” test, has been repeatedly rejected by courts.
First, the appellants argue that some of the waivers can be avoided by redesigning the project or removing amenities such as the proposed bike parking and balconies. Courts have explained that the use of waivers is not limited solely to accommodating the units themselves, as nothing in the DBL “requires the applicant to strip the project of amenities.” (Bankers Hill, supra, 74 Cal.App.5th at 775.) Rather, standards must be waived “that physically preclude construction of a housing development meeting the requirements for a density bonus, period.” (Id. (emph. added).) Further, the DBL does not authorize the City to deny waivers “based on the theory that another project, with a similar number of units, might conceivably be designed differently and accommodated without waivers.” (Wollmer, supra, 193 Cal.App.4th at 1346–1347.) The appellants also state that it is the appellant’s burden to meet its erroneous “physical preclusion” test. That is not what the law says. The DBL merely states that an applicant “may submit . . . a proposal for the waiver or reduction of development standards” and that the local agency shall be in violation of the DBL if it refuses to grant a waiver in violation of the law. (Gov. Code § 65915(e).) An agency may only deny a requested waiver based on findings that one of the three enumerated bases exist. There is no valid basis to deny any of the requested waivers, and the applicant is not required to redesign the project to the neighbors’ satisfaction to eliminate the need for such waivers.
Second, the appellants also argue that the economic impact of a waiver can never be considered.
This is also wrong. Courts have explained that economic feasibility must be considered, because if “the project were not built, it goes without saying that housing units for lower-income households would not be built and the purpose of the density bonus law to encourage such development would not be achieved.” (Id.) While the appellants are factually incorrect that the 1 HCD, Base Density Calculation under AB 2334 (State Density Bonus Law), June 14, 2023, available at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/sanfrancisco-ta-06142023.pdf.
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applicant has relied on economic factors to support the requested waivers, such considerations are not prohibited.
Specific Waiver Objections
The appellants make additional objections to some of the specific waivers, which the appellants claims can be denied based on unexplained “health and safety” impacts and purported noncompliance with ADA and building code requirements.
First, the appellants object to the requested waiver of LAMC 14.72.020 of the four-foot fence height limitation within 15-feet of driveways. The project proposes a fence 18 inches larger than this requirement in order to screen transformers from public view, and will include warning lights or signage for traffic safety consistent with the recommendations of the Transportation Impact Analysis prepared by Abrams Associates (2025).
The appellant vaguely claims that the additional 18 inches of fencing will create a collision hazard, which fails to raise a specific, adverse impact upon health or safety that would justify denial of the requested waiver. (Gov. Code § 65915(e).) Moreover, the DBL states that denial of a waiver is only justified if “there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact.” Even if there were a specific, adverse impact to public health and safety from the additional 18 inches of fence height (which there is not), the traffic analysis conducted for the Project concluded that warning lights or signage will mitigate any potential traffic safety issues.
The appellants also raise various American Disabilities Act (“ADA”) and California Building Code (“CBC”) issues, claiming that the applicant must demonstrate compliance with these federal and state requirements now in order to justify the requested waivers. As the Council is aware, compliance with the ADA (which is mandated by the CBC) and CBC is not determined at the entitlement phase. Rather, “the City complies with the ADA through building permit review and issuance.” (See Los Altos 6th Cycle Housing Element, p. F-4.) While the applicant (and the City’s building department) disagree with the appellants’ assertions of ADA and CBC noncompliance, these issues are simply premature and not relevant to the Council’s decision on the Project entitlement. The Project will undergo a thorough building permit review where the City will ensure that all ADA and CBC requirements are met.
Parking Reductions
AB 2097 eliminates all minimum parking requirements for projects within one-half mile of a major transit stop unless the local government makes certain findings. (Gov. Code § 65863.2.) In addition, the DBL prohibits a local agency from imposing more than a maximum of 0.5 spaces per unit for projects within one-half mile of a major transit stop under any circumstances. (Gov.
Code § 65915(p)(2).) The project exceeds these requirements and provides 95 parking spaces for the proposed 85 units.
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The definition of a “major transit stop” includes the “intersection of two or more major bus routes with a frequency of service interval of 20 minutes or less during the morning and afternoon peak commute periods.” (Pub. Res. Code § 21064.3(c).)2 As confirmed by the Metropolitan Transportation Commission map (see Exhibit B), the VTA El Camino and Showers bus stop that is served by the 22 and Rapid 522 meets the definition of a major transit stop and is located just a few hundred feet from the Project.
The appellants admit the Project meets this definition, confirming that the “VTA Route 22 operates at 15-20 minute headways during peak hours.” The appellants erroneously state that 15- minute intervals are required, a standard that was amended in 2024 by AB 2553. The Project is located within a half-mile of a major transit stop, and the 95 parking spaces provided well exceeds the amount of parking that the City can legally require, which is zero.
The appellants make additional claims that the proposed parking spaces are insufficient and does not meet the findings necessary for a conditional use permit. These claims are completely irrelevant, as the City is prohibited from imposing any parking at all. Yet the appellants simultaneously claim that the Project provides too much parking, and that the City should deny requested waivers and demand that the applicant remove what they describe as the “highamenity parking design” to shrink the size of the building. This incongruity is telling. This appeal does not contain any genuine concerns, but is simply the appellants throwing mud against the wall to see what sticks.
B. Response to the Appellant’s Health and Safety Impact Allegations If the City believed that the Project was inconsistent with any applicable City standard, the City would have been required to identify any such inconsistency 30 days after the application was deemed complete. (Gov. Code § 65589.5(j)(1).) Thus, while the Project is consistent with all applicable standards in fact, the Project has been deemed consistent with any standard for which an inconsistency has not already been identified. (Id. subd. (j)(2).) As a result, the codeconsistent Project may only be disapproved based on a finding that the Project will cause a specific, adverse unmitigable impact on public health and safety. (Id. subd. (j)(1).) The appellant vaguely argues that the Project can be disapproved based on unsubstantiated claims that the Project will cause a specific, adverse public health or safety impact related to fire and traffic. As explained above, the HAA creates a high bar to disapprove a project based on public health and safety impacts. Any such impact findings must be based on “a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.” (Gov. Code § 65589.5(j)(1).) Such objective standards must involve no personal or 2 AB 2097 and the DBL both refer to the definition of major transit stop in Pub. Res. Code § 21155, which cross-reference the definition contained in Pub. Res. Code § 21064.3 but also include planned transit stops.
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subjective judgment by a public official. (Id. subd. (h)(8).) The appeal does not come anywhere close to meeting this standard.
With regards to fire, the appeal claims that any building above 100-feet is a de-facto public health and safety risk because fire truck ladders are typically only 100 feet. This argument is farcical. The Project is a high-rise building (defined as greater than 75-feet above the lowest level of fire vehicle access) and is therefore designed to meet all of the objective fire protection requirements for high-rise buildings contained in CBC §§ 403.2-403.7 to ensure fire safety. The appeal argues that the project has only one accessway to a public street – yet points to no objective standard requiring multiple street access points. This is because no such standard exists. The Project has been reviewed by fire personnel, who have confirmed that the Project meets all fire safety requirements.
Regarding traffic safety, the appeal also makes vague arguments that the Project will increase risks for collision. Predictably, nowhere does the appeal identify any objective traffic safety standards that the Project fails to meet. Instead, the appellants’ traffic engineer states that the Project could increase traffic delays, which could “exacerbate driver frustration and aggressive maneuvers.” In other words, the appellants’ argument is that the Project could cause people to break traffic laws and that these future traffic violations could create a safety risk. This exceptionally tenuous and subjective assertion is without evidence.
While the appeal does not raise any significant impacts based on objective public health or safety standards that could legally justify disapproval of the Project, the applicant’s traffic engineering consultant has nonetheless provided a comprehensive response to the appellant’s claims. (Attached as Exhibit A.)
Still, it is worth noting that many of the appellants vague allegations of traffic safety are premised on the erroneous conclusion that the Project will intensify traffic, which the traffic study for the Project refutes. The Project is only forecast to add six trips per hour, which equates to less than a 0.05% increase to existing PM peak hour traffic volumes. Further, as explained in more detail below, the appellants’ reliance on a claimed traffic level of service (“LOS”) rating of F is misleading and generally considered an outdated method for reviewing project impacts.
C. Response to the Appellant’s CEQA Claims
Where a project is categorically exempt, the project is not subject to CEQA requirements and “may be implemented without any CEQA compliance whatsoever.” (Working Fams. of Monterey Cnty. v. King City Plan. Comm’n (2024) 106 Cal. App. 5th 833.) Thus, if a project fits within an exemption, a local agency is required to find that the project is exempt because such projects “have already determined do not, in fact, ‘have a significant effect on the environment.’” (Berkeley Hillside Pres. v. City of Berkeley (2015) 60 Cal. 4th 1086, 1108.) Exemption must be issued to carry out the Legislature’s intent that CEQA not be interpreted “in a manner which imposes procedural or substantive requirements beyond those explicitly stated.” (Pub. Res. Code § 21083.1.)
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One such CEQA exemption is for “in-fill development,” also known as the Class 32 Exemption. (Cal. Code Regs. Tit. 14, § 15332.) The Class 32 Exemption may be used for infill housing on sites of less than 5 acres within city limits surrounded by urban uses. (Id.) Exempt projects must also be consistent with the applicable standards, on sites with no value as habitat for endangered, rare or threatened species that can be adequately served by utilities and public services, and would not result in any significant effects relating to traffic, noise, air quality, or water quality. (Id.)
The appellants main contention is that the Project does not qualify for a Class 32 Exemption because the Project is not “consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations” as required due to the DBL waivers. This claim is flatly wrong under the plain language of the law and court precedent.
First, as noted above, the HAA clearly states that a DBL waiver “shall not constitute a valid basis on which to find a proposed housing development project is inconsistent” with applicable standards. (Gov. Code § 65589.5(j)(3).) Second, courts have further rejected this exact claim, explaining that because standards that are waived under the DBL are “not ‘applicable’ to the project within the meaning of [the Class 32 Exemption] because the above statute renders these standards inapplicable.” (Wollmer, supra, 193 Cal. App. 4th at 1348.) The Project is eligible for the requested waivers under the DBL, and therefore cannot be considered “inconsistent” with any waived standards.
Second, the appellants argue that the Project will have traffic impacts. The appellants main evidence for this assertion is related to existing LOS conditions – a metric that the Legislature removed for purposes determining CEQA traffic impacts nearly six years ago with the enactment of SB 743. The appellant does not even attempt to argue that the Project will have adverse traffic impacts based on the current metric of Vehicle Miles Traveled (“VMT”). This is because the Project will undoubtedly not cause significant impacts based on established VMT criteria and formulas as explained in the traffic analysis.
Traffic impacts are no longer evaluated utilizing an LOS analysis, which qualitatively measures existing levels of traffic congestion. This is because when there are existing traffic congestion issues, any addition of more vehicles would be identified as a traffic impact – effectively prohibiting all in-fill development and encouraging urban sprawl to less developed areas. LOS increases reliance on cars, increases carbon emissions, and is likely to result in more traffic accidents as people must travel farther from where they work and shop.
VMT, on the other hand, generally quantitatively measures the amount and length of vehicle trips that a project would produce compared citywide averages. This better reflects the actual impacts that would be created by the proposed project rather than punish in-fill development for pre-existing conditions – a much-used tactic by those who do not want new housing in their back yard. Even though the traffic analysis demonstrates the Project would not have any significant
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impacts on existing congestion conditions, existing LOS metrics are simply not a relevant basis in any CEQA analysis. The appellants fail to raise any legally cognizable CEQA traffic impacts that would eliminate the Project from the Class 32 Exemption.
Moreover, this further demonstrates that the vague claims of traffic impacts based on LOS – a metric the state abandoned because it creates more impacts than it prevents – is without merit.
While the City still maintains a General Plan policy that requires a non-CEQA traffic analysis to be conducted based on LOS, there is no objective LOS or traffic policy that Project fails to meet.
As a final desperate attempt, the appellants argue the Project cannot claim any CEQA exemptions due to the “unusual circumstances” exemption – without identifying any environmental impacts that would be cause by such purported circumstances.
The California Supreme Court has explained that the existence of an unusual circumstance alone is insufficient to require more in-depth CEQA review. (Berkeley Hillside Pres. v. City of Berkeley (2015) 60 Cal.4th 1086, 1097.) Rather than merely raise a “fair argument” of a potential environmental impact, a project opponent must demonstrate 1) a “reasonable possibility” that a project will have a significant effect on the environment, and 2) that the significant effect is “caused by the unusual circumstance that distinguishes the Project from others in the exempt class.” (Id. at 1105.)
The appellants fail to establish either criterion of the unusual circumstances exception. The only “unusual” circumstance the appellants claim is that the proposed building will be tall, which is hardly a distinguishing feature of Class 32 in-fill projects. Further, appellants fail to demonstrate that the Project’s height raises a reasonable possibility – or any possibility at all – of a significant effect on the environment. The appellants argument that a tall building cannot be exempt from CEQA under the Class 32 exemption is without merit.
D. Response to the Appellant’s Due Process Claims
The appellants argue that the staff report for the planning commission was released “a few days” before the hearing, and that this somehow violated their rights to due process. This procedure is entirely consistent with state law, which generally requires agenda materials to be made available 72 hours before the meeting. (Gov. Code § 54954.2) In other words, appellants are claiming that the Brown Act – the state law governing public meetings that has been in effect since 1953 – violates their rights to due process. This argument is without merit.
The general due process requirement is that interested parties be given the opportunity to be heard “at a meaningful time and in a meaningful manner.” (People v. Allen (2008) 44 Cal.4th 843, 869.) The Planning Commission hearing provided the appellants with that meaningful opportunity, and no due process violation occurred.
Subsequent to the appeal submittal, the appellants have made additional due process claims due to a basic misunderstanding of permit process. The appellants argue that the DRA and CUP
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appeal process is somehow a sham because the Council acted on the VTM application before their appeal of the Planning Commission’s approvals were heard.
Pursuant to the LAMC, the Planning Commission is not authorized to take a final action on a VTM and the Council is require to act on a VTM at the first regular meeting following a Commission recommendation. (LAMC § 13.12.050.) This is because if the Council fails to act within 30 days of receipt of the Commission’s recommendation, the VTM is deemed approved by operation of law. (Gov. Code § 64452.4)
In other words, the Council was legally required to hold the public hearing on the VTM and it was not a due process violation for the Council to hold a hearing it was legally required to hold.
The Council was not provided with DRA and CUP appeal documents at the VTM meeting because the DRA and CUP were not under consideration. The City is holding a separate appeal hearing on the DRA and CUP appeal, giving the appellants’ yet another opportunity to be heard, which is the legally correct procedure.
The appellants further claim that the public notice for the Council meeting on the VTM was inadequate, yet admit that they knew of the public hearing, attended the meeting, and had an opportunity to address the Council at that meeting. Even if the public notice was defective, state law confirms that an action shall not be invalidated due to any procedural error unless 1) the error was prejudicial; 2) the complainant suffered substantial injury from that error; and 3) a different result would have been probable if the error had not occurred. (Gov. Code § 65010(b); see also Roberson v. City of Rialto 226 Cal.App.4th 1499 [rejecting claim of defective hearing notice without evidence of substantial injury].) The appellants have raised no evidence that failing to receive notice to a hearing they attended caused them substantial injury. Regardless, the City has decided to hold another hearing on the VTM, and any claim of a procedural defect is moot.
The appellants have had multiple meaningful opportunities to raise their meritless arguments, and thus no due process violations have occurred.
IV. CONCLUSION
The appellants are attempting to bully the Council by filing frivolous litigation prematurely and making threats that the City will be responsible for all their legal fees. To the contrary, recent court precedent in Coal. of Pacificans for an Updated Plan v. City Council of City of Pacifica (2025) __ Cal.App.1st __, an appeal litigated by our firm, has significantly limited the availability of fee awards in cases that involve challenges to housing project approvals. In fact, the petitioner may be required to post a $500,000 bond to compensate the applicant for damages caused by the delays of litigation against a housing project that lacks merit. (CCP § 529.2; see also Save Livermore Downtown v. City of Livermore (2022) 87 Cal.App.5th 1116.) The Council should not be intimidated by these threats. The appeal raises no valid factual or legal issues and is entirely without merit. The Project is protected by the HAA and the DBL, and
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there is no legally valid basis to disapprove, lower the density, or conditionally approve the Project. As such, the applicant respectfully requests that appeal by denied and this desperately needed housing project be allowed to move forward.
Very truly yours,
PATTERSON & O’NEILL, PC
__________________________
Brian O’Neill
_____________________ ___________
B i O’N ill
Exhibit $
Abrams Associates
TRAFFIC ENGINEERING, INC.
1 Olympic Boulevard, Suite 210 Walnut Creek, CA 94596 925.945.0201 Fax: 925.945.7966 November 24, 2025
Sean Gallegos
City of Los Altos
1 North San Antonio Road
Los Altos, CA
Re: Response to Appeal Comments on Transportation for the 4898 El Camino Real Residential Project
Dear Mr. Gallegos,
This letter was prepared to summarize our response to the comments on transportation on the 4898 El Camino Real Residential Project. These comments were contained in an appeal letter dated November 17, 2025 that was filed in response to the Planning Commission approval of the project on November 6, 2025. Below are our responses to the comments.
Comments contained in the Planning Commission Appeal Letter dated November 17, 2025
Comment #1: The record shows multiple unmitigated safety impacts including: A loading design requiring trucks to back across the public sidewalk and into Jordan Avenue, blocking the only travel lane.
Response to Comment #1 – Having trucks back out of a driveway onto the roadway is not an unusual or prohibited maneuver. This is not a City liability issue or a safety impact as the driver would be fully responsible and liable for safely maneuvering his truck in and out of the driveway. In some situations, this could require flagmen to safely accommodate larger trucks.
Comment #2 - The record shows multiple unmitigated safety impacts including:
Removal of driveway sight distance protections along a school route shared by pedestrians, cyclists, and on-street parking.
Response to Comment #2 – It is not accurate to say that sight distance protections have been removed at the driveway. It is assumed this comment is referencing the proposed transformer enclosure next to the project driveway. Only a portion of the fence in this area would encroach next to the driveway and it would only be on one side.
There would be no sight distance restriction for bicycles and vehicles approaching from the left. It is not uncommon for driveways to have partially restricted sight distance and there are ways to ensure they still operate safely. For example, the City could
Abrams Associates Response to Appeal Comments Dated November 17, 2025 TRAFFIC ENGINEERING, INC.
theoretically require auditory and visual alerts and/or require that a portion of the fence not be opaque if this is a concern.
Comment #3 - The record shows multiple unmitigated safety impacts including:
Complete reliance on an automated parking system with no analysis of failures, outages, queuing, or emergency access implications.
Response to Comment #3 – The first automated parking system was created over 60 years ago and currently the largest automated system in operation has parking for over 2,300 vehicles.1 With respect to queuing, the reality is that the current parking/retrieval times for a modern automated parking garage average about one minute per car.2 However, for the purposes of sample queuing calculations for the project it is assumed that each parking bay could allow a resident to either drop off or pick up a car in an average of about three minutes. Therefore, with two automated parking bays the system should be able to accommodate at least 40 cars per hour (total in and out).
The City requires the project trip generation forecasts to be based on the Institute of Transportation Engineers (ITE) Trip Generation Manual, and the resulting forecast is for a maximum of 37 trips per hour (total in and out) during the PM peak commute hour.
This is the forecast total of all trips to and from the project, including guests and deliveries. Based on the maximum forecast inbound volume (23 vehicles per hour) the average inbound queue at the automated garage entrance would be approximately two vehicles. The driveway adjacent to the automated garage bays has available queuing for three inbound vehicles and therefore the queues would not be forecast to extend back out onto Jordan Avenue. The parking system operator will provide information on maintenance, the potential for outages, and emergency access.
Comment #4 - The record shows multiple unmitigated safety impacts including:
Intensified traffic at an already LOS F intersection heavily used by school children.
Response to Comment #4 – The project is not actually forecast to intensify traffic at the referenced intersection at Jordan Avenue and N San Antonio Road. The proposed project is forecast to add only about six trips per hour (about one vehicle every 10 minutes) which equates to less than a 0.05% increase to the existing PM peak hour traffic volumes at the intersection. This intersection has overall intersection operations of LOS A and would continue to operate at LOS A with the addition of project traffic.
However, as required, the traffic study reported that the side street traffic operates at LOS F.
This LOS F condition is only on the stop-controlled side street approach, the overall intersection has LOS A operations with no noticeable delays for through traffic on N. San 1 The Largest Robotic Parking Systems in the World: Is the United States Ready for This? Kathy Price Robinson, Architectural Record Magazine, New York, NY, April, 2021. 2 Interesting Facts About Automated Parking, Marcus Radonic, Automated Parking Corporation, Fort Lauderdale, FL February 8, 2023.
Abrams Associates Response to Appeal Comments Dated November 17, 2025 TRAFFIC ENGINEERING, INC.
Antonio Road. This intersection does not meet any of Caltrans’ warrants for installation of a traffic signal and has only had one reported accident in the past five years. There is no crosswalk across N. San Antonio Road at this intersection and there were no pedestrian or bicycle accidents identified at the intersection during the review of the California Highway Patrol accident records.
Comment #5 - The record shows multiple unmitigated safety impacts including: A single emergency access point serving a 109-foot building.
Response to Comment #5 – Sufficient emergency access is determined by factors such as number of access points, roadway widths, and proximity to fire stations. While the land use plan for the proposed project would include one access driveway, this does not mean this is the only emergency access point for the project. The proposed project is directly adjacent to Jordan Avenue and El Camino Real, which are streets that are wide enough to provide full emergency access. In addition, the project driveway adjacent to the automated parking bays meets the minimum width needed to accommodate emergency vehicles. The addition of traffic from the project would not be forecast to result in any significant changes to emergency vehicle response times in the area. The Los Altos Fire Station on Almond Avenue is 1.2 miles from the project site, approximately a 3-minute drive. Therefore, subject to City and fire department verification, the development of the proposed project is expected to have less-thansignificant impacts regarding emergency vehicle access.
Comment #6 – Missing School-Peak Traffic Analysis. Although traffic counts were collected in April, 2024, the TIA evaluated only commuter PM peaks (4-6 PM) and entirely ignored the school dismissal peak (approximately 2:45-3:45 PM).
Response to Comment #6 (3.1) – The comment fails to acknowledge the traffic study analyzed the most critical school period, the AM peak hour. This is the time period when the commute traffic in the area overlaps with school traffic and the analysis found no significant impacts during this period. The afternoon peak school dismissal period has lower background volumes and the project itself would also generate less traffic during this period, which is why the analysis was not required. During this time period the project would only generate about one car every two minutes, which would not be enough traffic to significantly change the traffic or safety conditions in the area.
Comment #7 (3.2) – Existing LOS F at Jordan / N. San Antonio Ignored – The TIA acknowledges that the Jordan Avenue / North San Antonio Road intersection already operates at Level of Service (LOS) F, the worst congestion rating.
Response to Comment #7 – This LOS F on the side street at this intersection is an existing condition and the proposed project is not forecast to result in any significant impacts there. The proposed project is forecast to add about six trips per hour (about one vehicle every 10 minutes) which equates to less than a 0.05% increase to the existing PM peak hour traffic volumes. This intersection has overall intersection
Abrams Associates Response to Appeal Comments Dated November 17, 2025 TRAFFIC ENGINEERING, INC.
operations of LOS A and would continue to operate at LOS A with the addition of project traffic. However, as required, the traffic study reported that the side street traffic operates at LOS F.
This LOS F condition is only on the stop-controlled side street approach, the overall intersection has LOS A operations with no noticeable delays for through traffic on N. San Antonio Road. This intersection does not meet any of Caltrans’ warrants for installation of a traffic signal and has only had one accident reported in the past five years.
Comment #8 (3.3) – No Analysis of Cut-Through Traffic on Jordan Avenue – Jordan Avenue is already used as a cut-through route by drivers seeking to bypass congestion on San Antonio Road.
Response to Comment #8 – Rather than encouraging cut-through traffic the project would be likely to discourage cut-through traffic by slightly increasing the activity on Jordan Avenue, which would make it a less desirable cut through route. The City did require a neighborhood traffic intrusion analysis to be included in the traffic study. The analysis noted the proposed project would only slightly increase the volumes on Jordan Avenue in the neighborhood to the south of the project site. This would include about 4 trips added during the morning peak commute hour and about 6 trips added during the afternoon peak commute hour. This equates to an addition of a maximum of about one car every 10 minutes. Typically, a project would need to increase traffic on a neighborhood street by at least 10 cars per hour (one car every six minutes) to potentially warrant additional analysis or evaluation of potential new traffic control elements. In the case of this project the increase in traffic on any local neighborhood streets would be well under 10 trips per hour and the project is not forecast to significantly increase cut-through traffic.
Comment #9 (3.4) – Incomplete Intersection Coverage – Two critical intersections – Jordan & Marich and Jordan & East Portola – were not evaluated, despite being heavily used diversion and turning points for school and neighborhood traffic. These intersections often operate near capacity during school hours and should have been included in the TIA.
Response to Comment #9 – Analysis of these two intersections was not required based on the City’s traffic study requirements and also because the amount of project traffic added to these intersections would be negligible from a traffic analysis standpoint.
The City’s Local Transportation Analysis (LTA) Requirements specify which intersections are to be included in the study and the City has the final authority on what study intersections are included.3 The LTA requirements specify the following: “Analyze only intersections between an arterial or collector and another road. Do not analyze intersections of local roads.” As per the circulation element of the City of Los Altos 3 City of Los Altos Local Transportation Analysis Requirements, Los Altos Development Services Department, Los Altos, CA, 2023.
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General Plan, both of the intersections referred to in this comment are intersections of local roads. In addition, the project was forecast to add no more than about three trips per hour to both East Portola Avenue and Marich Way, equating to an average of about one additional car every twenty minutes. Typically, this amount of additional traffic would not warrant analysis of additional intersections in a traffic study.
Comment #10 (3.5) – No Pedestrian Safety Analysis Despite Substandard Sidewalk Network – Jordan Avenue has discontinuous, narrow, or missing sidewalks, forcing pedestrians – including school children – into the travel lane.
Response to Comment #10 – The City regularly reviews the need for pedestrian improvements as part of its Safe Routes to School Program and its Complete Streets Master Plan Program. In February of 2021 the City conducted a School Safety Assessment for Egan Middle School and Bullis Charter School. The resulting Safe Routes to Schools Improvement Plan recommended that both Jordan Avenue and Portola Avenue should be Class III Bicycle Boulevards. No other pedestrian improvements or sidewalk changes on Jordan Avenue were recommended.
The Los Altos Complete Streets Master Plan (2022) provides a strategy to develop a comprehensive bicycling and walking network and identifies a plan for improvements with prioritization and phasing to ensure implementation is manageable and fundable for the City. No other bicycle or pedestrian improvements have been identified on Jordan Avenue in the Complete Streets Master Plan. In addition, a review of five years of California Highway Patrol accident data did not reveal an unusual number of accidents or any identifiable accident patterns on Jordan Avenue.
Comment #11 (3.6) – No Analysis of Automated Parking System Operations or Failures – The project depends entirely on an automated mechanical parking system for 95 spaces. The TIA does not analyze: retrieval and storage time during peak hours; queuing or congestion during high-demand periods; mechanical outages or maintenance downtime; queue spillback onto Jordan Avenue; emergency scenarios where vehicles cannot exit.
Response to Comment #11 – As noted in Response to Comment #3, the current parking/retrieval average of a modern automated parking garage is about one minute per car.4 However, for the purposes of the sample queuing calculations it is assumed that each bay could allow a resident to either drop off or pick up a car in an average of about three minutes. Therefore, with two automated parking bays the system should be able to accommodate at least 40 cars per hour (total in and out).
The City requires the project trip generation forecasts to be based on the Institute of Transportation Engineers (ITE) Trip Generation Manual, and the resulting forecast is for 4 Interesting Facts About Automated Parking, Marcus Radonic, Automated Parking Corporation, Fort Lauderdale, FL February 8, 2023.
Abrams Associates Response to Appeal Comments Dated November 17, 2025 TRAFFIC ENGINEERING, INC.
a maximum of 37 trips per hour (total in and out) during the PM peak commute hour.
This is the forecast total of all trips to and from the project, and includes deliveries and guests. Based on the maximum forecast inbound volume (23 vehicles per hour) the average inbound queue at the automated garage bays would be approximately two vehicles. The driveway adjacent to the automated garage bays has available queuing for three inbound vehicles and therefore the queues would not be forecast to extend back out onto Jordan Avenue. The parking system operator will provide information on maintenance, the potential for outages, and emergency access.
Comment #12 (3.7) – The TIA is Not Certified by a Licensed Professional Engineer (P.E.). – California public agencies generally require TIA’s to be prepared, stamped, and signed by a licensed Professional Engineer (P.E.) to ensure technical accuracy and accountability. The submitted TIA lacks a P.E. stamp, making it procedurally deficient and unreliable as substantial evidence for City decision-making.
Response to Comment #12 – It is true that California public agencies generally require TIA’s to be prepared by a licensed professional engineer, which was the case with this project’s traffic study. However, as is the case in many Cities, the City did not request or otherwise require that the traffic study cover have a P.E. stamp, or it would been have provided. This is typically because Cities do have the ability to readily verify the current status of an engineer’s professional license online.
Comment #13 (3.8 a.) – Outdated traffic data (18 months old) – The TIA relies on traffic counts from April, 2024, nearly 18 months before project review. Counts collected in April may also coincide with Spring Break, making them unrepresentative. Missing time Response to Comment #13 – The year referred to is a typo as the traffic counts were conducted on April 29, 2025 when local schools were in session. The counts were less than three months old when the City began its review of the traffic study. The City has possession of the raw traffic counts showing the date of the counts as they are included in the technical appendix to the traffic study.
Comment #14 (3.8 b.) – Missing timestamps and context – The TIA does not clearly document: precise data collection dates, exact times of day; or school calendar context (session vs. break).
Response to Comment #14 – As noted above, the traffic counts were conducted on April 29, 2025 when local schools were in session. The City has possession of the raw traffic counts showing the date of the counts and the times they were conducted as they are included in the technical appendix to the traffic study. It is a standard traffic study requirement that the traffic counts be conducted when local schools are in session.
Comment #15 (3.9 a.) Trip-rate labeling errors – In Table 4, the ITE trip rates for “Multifamily Housing (Mid-Rise)” are incorrectly labeled as “trips per ksf.” In reality, the applied rates (5.44, 0.36, 0.44) are per dwelling unit. Although the arithmetic is correct,
Abrams Associates Response to Appeal Comments Dated November 17, 2025 TRAFFIC ENGINEERING, INC.
this fundamental unit error undermines confidence in the technical review.
Response to Comment #15 – This comment is correct as there is a typo in Table 4 that refers to the rates as being “per ksf”. The rates should have been identified as being “per unit” which are the correct rates and were what was used in the calculations.
Comment #16 (3.9 b.) Contradictory trip-generation calculations – Section 5.1 states “No trip generation credit was given because the site was vacant.” Yet Section 5.2 adds trip credits for prior land uses, claiming the net increase is only 19 AM / 10 PM trips.
This contradiction suggests selective adjustments intended to minimize reported impacts.
Response to Comment #16 – It can be readily verified that the traffic analysis was based on the trip generation rates for the project with no credit given for removal of traffic from the prior uses. Section 5.2 clearly states that it is simply presenting a comparison to the prior land uses. While the traffic analysis does not utilize these numbers, this is an important comparison for the decision makers to consider when evaluating a new land use. The existing buildings were not occupied at the time of the traffic counts and therefore credit cannot be given in the traffic analysis for the traffic previously generated by them. However, Section 5.2 was included to provide a comparison showing the forecast net increase in traffic when compared to the prior uses for informational purposes only. For this project the net increase in traffic compared to the prior land uses is forecast to be about 19 additional trips during the AM peak hour and about 10 additional trips during the PM peak hour.
Comment #17 (3.9 c.) Misapplied parking demand data – The TIA cites parking demand data applicable to buildings with no two-bedroom units. However, the proposed project includes 29 two-bedroom units, making the cited rates inapplicable and the parking analysis unreliable.
Response to Comment #17 – Two thirds of the proposed project would be studios and one-bedroom units and the average square footage of the units is about 800 square feet.
The rates used also do not account for the availability of transit adjacent to the project.
As a result, since the project has smaller sized units it was concluded that the onebedroom category was more applicable than the rates for buildings with 2+ bedrooms.
However, it is important to point out that even if the mid-rise parking generation rate for buildings with 2+ bedrooms are used the project would still be found to have sufficient parking. The Institute of Transportation Engineers (ITE) Parking Generation Manual specifies a peak parking demand rate of 1.1 vehicles per unit for an 85-unit Multifamily Mid-Rise Housing project with 2+ bedrooms (ITE Land Use Code 221).5 For the proposed project this equates to a forecast peak parking demand of 95 vehicles. As Parking Generation Manual, 6th Edition,QVWLWXWHRI7UDQVSRUWDWLRQ(QJLQHHUV:DVKLQJWRQ'& 2FWREHU
Abrams Associates Response to Appeal Comments Dated November 17, 2025 TRAFFIC ENGINEERING, INC.
noted in the traffic study, this peak demand forecast includes guests and deliveries, indicating the 95-space automated parking garage should be sufficient to accommodate the peak demand from the project.
Amendments to the State CEQA Guidelines (which became effective March 18, 2010) removed parking from the State’s Environmental Checklist as an environmental factor to be considered under CEQA. The City of Los Altos, in its review of the proposed project, considers parking demand to ensure that the project’s provision of parking spaces would result in minimal adverse effects, and that any secondary effects (such as on air quality due to drivers searching for parking spaces) would be minimized. As such, although not required by CEQA, parking conditions are evaluated in the traffic study as a non-CEQA topic for informational purposes.
Comment #18 (4.) Improper Use of CEQA Class 32 (Infill) Exemption – The City relied on CEQA Guidelines 15332 (Class 32 Infill). This exemption is only available if the project would not result in any significant effects related to traffic, noise, air quality, or water quality. In this case the TIA documents an already failing intersection (LOS F) at Jordan / N. San Antonio; adding traffic is a significant cumulative impact. The project introduces new traffic and complex access patterns with no mitigation.
Response to Comment #18 – The traffic study clearly specifies that the addition of a minimal amount of project traffic to the intersection of Jordan Avenue and N. San Antonio Road is not considered a significant impact according to City standards. This intersection has overall intersection operations of LOS A and would continue to operate at LOS A with the addition of project traffic. The proposed project would only add about 6 trips per hour to the intersection. As required, the traffic study reported that the side street traffic operates at LOS F. However, this LOS F condition is only on the stopcontrolled side street approach, the overall intersection has LOS A operations with no noticeable delays for through traffic on N. San Antonio Road. This intersection does not meet any of Caltrans’ warrants for installation of a traffic signal and has only had one reported accident in the past five years.
Comment #19 (5.) Challenge to AB 2097 Parking Exemption (Major Transit Stop Definition) – The project effectively claims a parking exemption under AB 2097 based on proximity to a “major transit stop.” However, the Applicant’s own traffic report states that VTA Route 22 operates at a 15-10 minute headways during peak hours. Under Public Resources Code 21155, a “major transit stop” requires service intervals of 15 minutes or less during peak commute hours. Because headways reach 20 minutes, the site does not meet the statutory definition.
Response to Comment #19 – Assembly Bill No. 2553 was passed on 8/22/2024 and revised the definition of “major transit stop” to increase the required frequency of service interval from 15 minutes to 20 minutes. However, Route 22 actually does operate with service intervals of 15 minutes oU less during the peak hours. It is our understanding that 20-minute service intervals only occur during off-peak periods. It is important to note
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that State law does not specify whether a minimum bus service interval is required in both directions during both the AM and PM peak periods. In most jurisdictions meeting the minimum service intervals in just one direction during each peak period is sufficient to satisfy the minimum bus service requirements.
Comment #20 (6.) Incomplete and Unsupported Parking Analysis – The applicants assertion that 95 spaces “is sufficient” is not supported by objective analysis: No guest parking demand analysis (typical standards often require ~0.25 spaces per unit); No combined analysis of loading need and parking operations; No clear demonstration of ADA compliance with the mechanical system; No credible failure-scenario modeling; No evaluation of driveway blockage if cars queue back onto Jordan.
Response to Comment #20 – The Institute of Transportation Engineers (ITE) Parking Generation Manual specifies a peak parking demand rate of 1.1 vehicles per unit for Multifamily Mid-Rise Housing with 2+ bedrooms. ThLV rateLVbased on surveys of parking demand at 44 similar apartment complexes and the parking surveys included all guests and deliveries. Guest parking is already accounted for in the peak parking demand rates and the guest parking requirements referred to are instead related to municipal code requirements for guest parking that some cities have. The ITE parking demand analysis indicated the 95-space automated parking garage would be sufficient to accommodate the peak demand from the project, including guests.
As noted previously, based on the maximum forecast inbound volume (23 vehicles per hour) the average inbound queue at the automated garage bays would be approximately two vehicles. The driveway adjacent to the automated garage bays has available queuing for three inbound vehicles and therefore the queues would not be forecast to extend back out onto Jordan Avenue.
Comment #21 (9.) - Loading Waiver Creates a Documented Public Safety Hazard – Under the current design: Every trash truck, delivery truck, and moving vehicle must back onto Jordan Avenue or reverse across the public sidewalk to reach the trash and mail rooms. With a building of this scale, routine deliveries, trash collection, and moving activities will inevitably block traffic, just feet from the El Camino Real intersection.
Response to Comment #21 – Having trucks back out of a driveway onto the roadway is not an unusual or prohibited maneuver. This is not a City liability issue or a safety impact as the driver would be fully responsible and liable for safely maneuvering his truck in and out of the driveway. In some situations, this could require flagmen to safely accommodate larger trucks. The comment describes the driveway as being just feet from the El Camino Real intersection. The driveway is approximately 175 feet from the El Camino Real intersection with Jordan Avenue.
Comment #22 (12.) – Transformer Fence Waiver Creates a Safety Hazard and Fails Physical-Preclusion Test – The proposed 6’5” opaque transformer fence eliminates required sight distance. The applicant proposes a 6’5” fence directly adjacent to the
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driveway and 4.5-foot sidewalk, eliminating the sight triangle needed for safe turning movements. This creates a foreseeable collision hazard for vehicles exiting the garage and for cyclists and pedestrians on this school route.
Response to Comment #22 – Only a portion of the fence in this area would encroach next to the driveway and it would only be on one side. There would be no sight distance restriction for bicycles and vehicles approaching from the left. It is not uncommon for driveways to have partially restricted sight distance and there are ways to ensure they still operate safely. For example, the City could theoretically require auditory and visual alerts and/or require that a portion of the fence not be opaque if this is a concern.
Comment #23 (13.) – Fire Safety and Emergency Access Hazards – The project presents serious life-safety concerns. Single access: There is only one vehicular access point on Jordan Avenue. In a congested LOS F environment, this single access could be blocked by queues or parked vehicles, delaying or preventing fire and ambulance access.
Response to Comment #23 – While the land use plan for the proposed project would include one access driveway, this does not mean this is the only emergency access point for the project. The proposed project is directly adjacent to Jordan Avenue and El Camino Real, which are streets that are wide enough to provide full emergency access.
In addition, the project driveway adjacent to the automated parking bays meets the minimum width needed to accommodate emergency vehicles. The addition of traffic from the project would not be forecast to create new impacts to traffic operations in the area and would not result in any significant changes to emergency vehicle response times. Therefore, subject to City and fire department verification, the development of the proposed project is expected to have less-than-significant impacts regarding emergency vehicle access.
The LOS F condition the comment is referring to was only reported on the stopcontrolled side street approach at Jordan Avenue and W San Antonio Road, which is located about six blocks from the project site. There were no LOS F conditions identified in the immediate vicinity of the proposed project, the project driveway intersection and the adjacent intersection of Jordan Avenue with El Camino Real are both forecast to operate at LOS B or better under all study scenarios.
Please don’t hesitate to contact me if you have any questions about this information.
Sincerely,
Stephen C. Abrams
President
Abrams Associates
T.E. License No. 1852
Exhibit %
Abrams Associates
TRAFFIC ENGINEERING, INC.
1875 Olympic Boulevard, Suite 210 Walnut Creek, CA 94596 925.945.0201 Fax: 925.945.7966 January 15, 2026
Sean Gallegos
City of Los Altos
1 North San Antonio Road
Los Altos, CA
Re: Response to Appeal Comments on Transportation for the 4898 El Camino Real Residential Project
Dear Mr. Gallegos,
This letter was prepared to summarize our response to the comments on transportation on the 4898 El Camino Real Residential Project. These comments were contained in an appeal letter dated November 17, 2025 and also in a letter from Lin Zhang of Elite Transportation Group dated December 21, 2025. These letters were both filed in response to the Planning Commission approval of the project on November 6, 2025.
Below are our responses to the comments.
Comments contained in the Planning Commission Appeal Letter dated November 17, 2025
Comment #1 - The record shows multiple unmitigated safety impacts including: A loading design requiring trucks to back across the public sidewalk and into Jordan Avenue, blocking the only travel lane.
Response to Comment #1 - The project site plan has now been revised to include a truck loading area on the Jordan Avenue frontage. However, it should be noted that having trucks back out of a driveway onto the roadway is not an unusual or prohibited maneuver. This is not a City liability issue or a safety impact as the driver would be fully responsible and liable for safely maneuvering his truck in and out of the driveway. In some situations, this could require flagmen to safely accommodate larger trucks.
Comment #2 - The record shows multiple unmitigated safety impacts including:
Removal of driveway sight distance protections along a school route shared by pedestrians, cyclists, and on-street parking.
Response to Comment #2 - It is not accurate to say that sight distance protections have been removed at the driveway. It is assumed this comment is referencing the proposed transformer enclosure next to the project driveway. The enclosure has now been relocated so that it no longer will obstruct motorist’s view of pedestrians exiting the driveway. The proposed driveway would be no different than many other driveways
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along Jordan Avenue and the improved sidewalk along the project frontage would be expected to improve safety for pedestrians in the area.
Comment #3 - The record shows multiple unmitigated safety impacts including:
Complete reliance on an automated parking system with no analysis of failures, outages, queuing, or emergency access implications.
Response to Comment #3 - The first automated parking system was created over 60 years ago and currently the largest automated system in operation has parking for over 2,300 vehicles.1 With respect to queuing, the reality is that the current parking/retrieval times for a modern automated parking garage average about one minute per car.2 However, for the purposes of the sample queuing calculations for the project it is assumed that each parking bay could allow a resident to either drop off or pick up a car in an average of about three minutes. Therefore, with two automated parking bays the system should be able to accommodate a minimum of about 40 cars per hour (total in and out).
The City requires the project trip generation forecasts to be based on the Institute of Transportation Engineers (ITE) Trip Generation Manual, and the resulting forecast is for a maximum of 37 trips per hour (total in and out) during the PM peak commute hour.
This is the forecast total of all trips to and from the project, including guests and deliveries. Based on the maximum forecast inbound volume (23 vehicles per hour) the average inbound queue at the automated garage entrance would be approximately two vehicles. The driveway adjacent to the automated garage bays has available queuing for three inbound vehicles and therefore the queues would not be forecast to extend back out onto Jordan Avenue. The parking system operator will provide information on maintenance, the potential for outages, and emergency access.
Comment #4 - The record shows multiple unmitigated safety impacts including:
Intensified traffic at an already LOS F intersection heavily used by school children.
Response to Comment #4 - The project is not actually forecast to intensify traffic at the referenced intersection at Jordan Avenue and N San Antonio Road. The proposed project is forecast to add only about six trips per hour (about one vehicle every 10 minutes) which equates to less than a 0.05% increase to the existing PM peak hour traffic volumes at the intersection. This intersection has overall intersection operations of LOS A and would continue to operate at LOS A with the addition of project traffic.
However, as required, the traffic study reported that the side street traffic operates at LOS F.
1 The Largest Robotic Parking Systems in the World: Is the United States Ready for This? Kathy Price Robinson, Architectural Record Magazine, New York, NY, April, 2021. 2 Interesting Facts About Automated Parking, Marcus Radonic, Automated Parking Corporation, Fort Lauderdale, FL February 8, 2023.
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This LOS F condition is only on the stop-controlled side street approach, the overall intersection has LOS A operations with no noticeable delays for through traffic on N. San Antonio Road. This intersection does not meet any of Caltrans’ warrants for installation of a traffic signal and has only had one reported accident in the past five years. There is also no crosswalk across N. San Antonio Road at this intersection and there were no pedestrian or bicycle accidents identified at the intersection during the review of the California Highway Patrol accident records. Motorists in the area also have the option of using the E. Portola Avenue intersection with San Antonio Road, which is just over 500 feet to the north of the Jordan Avenue intersection. This intersection has a traffic signal where left turns can be made with less delay during the peak hours.
Comment #5 - The record shows multiple unmitigated safety impacts including: A single emergency access point serving a 109-foot building.
Response to Comment #5 - Sufficient emergency access is determined by factors such as number of access points, roadway widths, and proximity to fire stations. While the land use plan for the proposed project would include one access driveway, this does not mean this is the only emergency access point for the project. The proposed project is directly adjacent to Jordan Avenue and El Camino Real, which are streets that are wide enough to provide full emergency access.
In addition, the project driveway adjacent to the automated parking bays meets the minimum width needed to accommodate emergency vehicles. The addition of traffic from the project would not be forecast to result in any significant impacts to emergency vehicle response times in the area. The Los Altos Fire Station on Almond Avenue is 1.2 miles from the project site, approximately a 3-minute drive. Therefore, subject to City and fire department verification, the development of the proposed project is expected to have less-than-significant impacts regarding emergency vehicle access.
Comment #6 - Missing School-Peak Traffic Analysis. Although traffic counts were collected in April, 2024, the TIA evaluated only commuter PM peaks (4-6 PM) and entirely ignored the school dismissal peak (approximately 2:45-3:45 PM).
Response to Comment #6 (3.1) - The comment fails to acknowledge the traffic study analyzed the most critical school period, the AM peak hour. This is the time period when the commute traffic in the area overlaps with school traffic and the analysis found no significant impacts during this period. The afternoon peak school dismissal period has lower background volumes at the project study intersections and the project itself would also generate less traffic during this period, which is why the analysis was not required.
During this time period the project would only generate about one car every two minutes, which would not be enough traffic to significantly change the traffic or safety conditions in the area.
In response to this comment additional school traffic counts were conducted to provide evidence supporting the preceding statements. The traffic counts were conducted at the
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intersections of Jordan Avenue at Marich Way and also at Portola Avenue on Wednesday, January 7, 2026 from 2:00 PM to 4:00 PM when local schools were in session. The traffic counts are attached to this letter and indicated that during the peak hour of school traffic (2:45 to 3:45 PM) the volumes on Jordan Avenue were less than the AM and PM peak hour volumes studied in the transportation impact analysis for the project. A figure presenting the school peak hour traffic volumes from the latest counts is also attached to this letter.
In addition, an intersection level of service (LOS) analysis was conducted at both of the intersections for the school peak hour, consistent with City guidelines. The analysis indicated both intersections operate at LOS B or better during the school peak hour and there were no significant queuing problems or delays observed during the traffic surveys.
An analysis of cumulative conditions, consistent with the traffic study prepared for the project, indicated the intersections would also be forecast to have acceptable operations (LOS B or better) in the future with the addition of traffic from the proposed project and other approved projects in the area. A table summarizing the analysis results along with the detailed LOS calculations are attached to this letter.
Comment #7 (3.2) - Existing LOS F at Jordan / N. San Antonio Ignored – The TIA acknowledges that the Jordan Avenue / North San Antonio Road intersection already operates at Level of Service (LOS) F, the worst congestion rating.
Response to Comment #7 - This LOS F on the side street at this intersection is an existing condition and the proposed project is not forecast to result in any significant impacts there. The proposed project is forecast to add about six trips per hour (about one vehicle every 10 minutes) which equates to less than a 0.05% increase to the existing PM peak hour traffic volumes. This intersection has overall intersection operations of LOS A and would continue to operate at LOS A with the addition of project traffic. However, as required, the traffic study reported that the side street traffic operates at LOS F.
This LOS F condition is only on the stop-controlled side street approach; the overall intersection has LOS A operations with no noticeable delays for through traffic on N. San Antonio Road. This intersection does not meet any of Caltrans’ warrants for installation of a traffic signal and has only had one accident reported in the past five years.
Motorists in the area also have the option of using the E. Portola Avenue intersection with San Antonio Road, which is just over 500 feet to the north of the Jordan Avenue intersection. This intersection has a traffic signal where left turns can be made with less delay during the peak hours.
Comment #8 (3.3) - No Analysis of Cut-Through Traffic on Jordan Avenue – Jordan Avenue is already used as a cut-through route by drivers seeking to bypass congestion on San Antonio Road.
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Response to Comment #8 - Rather than encouraging cut-through traffic the project would be likely to discourage cut-through traffic by slightly increasing the activity on Jordan Avenue, which would make it a less desirable cut through route. The City did require a neighborhood traffic intrusion analysis to be included in the traffic study. The analysis noted the proposed project would only slightly increase the volumes on Jordan Avenue in the neighborhood to the south of the project site. This would include about 4 trips added during the morning peak commute hour and about 6 trips added during the afternoon peak commute hour. This equates to an addition of a maximum of about one car every 10 minutes. Typically, a project would need to increase traffic on a neighborhood street by at least 10 cars per hour (one car every six minutes) to potentially warrant additional analysis or evaluation of potential new traffic control elements. In the case of this project the increase in traffic on any local neighborhood streets would be well under 10 trips per hour and the project is not forecast to significantly increase cut-through traffic.
Comment #9 (3.4) - Incomplete Intersection Coverage – Two critical intersections – Jordan & Marich and Jordan & East Portola – were not evaluated, despite being heavily used diversion and turning points for school and neighborhood traffic. These intersections often operate near capacity during school hours and should have been included in the TIA.
Response to Comment #9 - Analysis of these two intersections was not required based on the City’s traffic study requirements and also because the amount of project traffic added to these intersections would be negligible from a traffic analysis standpoint. The City’s Local Transportation Analysis (LTA) Requirements specify which intersections are to be included in the study and the City has the final authority on what study intersections are included.3 The LTA requirements specify the following: “Analyze only intersections between an arterial or collector and another road. Do not analyze intersections of local roads.” As per the circulation element of the City of Los Altos General Plan, both of the intersections referred to in this comment are intersections of local roads. In addition, the project was forecast to add no more than about three trips per hour to both East Portola Avenue and Marich Way, equating to an average of about one additional car every twenty minutes. Typically, this amount of additional traffic would not warrant analysis of additional intersections in a traffic study.
In response to this comment traffic counts were conducted to provide a LOS analysis of these two intersections. The traffic counts were conducted at the intersections of Jordan Avenue at Marich Way and also at Portola Avenue on Wednesday, January 7, 2026 from 2:00 PM to 4:00 PM when local schools were in session. The traffic counts are attached to this letter. A figure presenting the school peak hour traffic volumes from the latest counts is also attached to this letter.
3 City of Los Altos Local Transportation Analysis Requirements, Los Altos Development Services Department, Los Altos, CA, 2023.
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An intersection level of service (LOS) analysis was conducted at both of the intersections for the school peak hour, consistent with City guidelines. The analysis indicated both intersections operate at LOS B or better during the school peak hour and there were no significant queuing problems or delays observed during the traffic surveys.
An analysis of cumulative conditions, consistent with the traffic study prepared for the project, indicated the intersections would also be forecast to have acceptable operations (LOS B or better) in the future with the addition of traffic from the proposed project and other approved projects in the area. A table summarizing the analysis results along with the detailed LOS calculations are attached to this letter.
Comment #10 (3.5) - No Pedestrian Safety Analysis Despite Substandard Sidewalk Network – Jordan Avenue has discontinuous, narrow, or missing sidewalks, forcing pedestrians – including school children – into the travel lane.
Response to Comment #10 - The City regularly reviews the need for pedestrian improvements as part of its Safe Routes to School Program and its Complete Streets Master Plan Program. In February of 2021 the City conducted a School Safety Assessment for Egan Middle School and Bullis Charter School. The resulting Safe Routes to Schools Improvement Plan recommended that both Jordan Avenue and Portola Avenue should be Class III Bicycle Boulevards. No other pedestrian improvements or sidewalk changes on Jordan Avenue were recommended.
The Los Altos Complete Streets Master Plan (2022) provides a strategy to develop a comprehensive bicycling and walking network and identifies a plan for improvements with prioritization and phasing to ensure implementation is manageable and fundable for the City. No other bicycle or pedestrian improvements have been identified on Jordan Avenue in the Complete Streets Master Plan. In addition, a review of five years of California Highway Patrol accident data did not reveal an unusual number of accidents or any identifiable accident patterns on Jordan Avenue.
Comment #11 (3.6) - No Analysis of Automated Parking System Operations or Failures – The project depends entirely on an automated mechanical parking system for 95 spaces. The TIA does not analyze: retrieval and storage time during peak hours; queuing or congestion during high-demand periods; mechanical outages or maintenance downtime; queue spillback onto Jordan Avenue; emergency scenarios where vehicles cannot exit.
Response to Comment #11 - As noted in Response to Comment #3, the current parking/retrieval average of a modern automated parking garage is about one minute per car.4 However, for the purposes of the sample queuing calculations it is assumed that each bay could allow a resident to either drop off or pick up a car in an average of 4 Interesting Facts About Automated Parking, Marcus Radonic, Automated Parking Corporation, Fort Lauderdale, FL February 8, 2023.
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
about three minutes. Therefore, with two automated parking bays the system should be able to accommodate at least 40 cars per hour (total in and out).
The City requires the project trip generation forecasts to be based on the Institute of Transportation Engineers (ITE) Trip Generation Manual, and the resulting forecast is for a maximum of 37 trips per hour (total in and out) during the PM peak commute hour.
This is the forecast total of all trips to and from the project, and includes deliveries and guests. Based on the maximum forecast inbound volume (23 vehicles per hour) the average inbound queue at the automated garage bays would be approximately two vehicles. The driveway adjacent to the automated garage bays has available queuing for three inbound vehicles and therefore the queues would not be forecast to extend back out onto Jordan Avenue. The parking system operator will provide information on maintenance, the potential for outages, and emergency access.
Comment #12 (3.7) - The TIA is Not Certified by a Licensed Professional Engineer (P.E.). – California public agencies generally require TIA’s to be prepared, stamped, and signed by a licensed Professional Engineer (P.E.) to ensure technical accuracy and accountability. The submitted TIA lacks a P.E. stamp, making it procedurally deficient and unreliable as substantial evidence for City decision-making.
Response to Comment #12 - It is true that California public agencies generally require TIA’s to be prepared by a licensed professional engineer, which was the case with this project’s traffic study. However, as is the case in many Cities, the City did not request or otherwise require that the traffic study cover have a P.E. stamp, or it would been have provided. This is typically because Cities do have the ability to readily verify the current status of an engineer’s professional license online.
Comment #13 (3.8 a.) - Outdated traffic data (18 months old) – The TIA relies on traffic counts from April, 2024, nearly 18 months before project review. Counts collected in April may also coincide with Spring Break, making them unrepresentative. Missing time Response to Comment #13 - The year referred to is a typo as the traffic counts were conducted on April 29, 2025 when local schools were in session. The counts were less than three months old when the City began its review of the traffic study. The City has possession of the raw traffic counts showing the date of the counts as they are included in the technical appendix to the traffic study.
Comment #14 (3.8 b.) - Missing timestamps and context – The TIA does not clearly document: precise data collection dates, exact times of day; or school calendar context (session vs. break).
Response to Comment #14 - As noted above, the traffic counts were conducted on April 29, 2025 when local schools were in session. The City has possession of the raw traffic counts showing the date of the counts and the times they were conducted as they
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
are included in the technical appendix to the traffic study. It is a standard traffic study requirement that the traffic counts be conducted when local schools are in session.
Comment #15 (3.9 a.) Trip-rate labeling errors - In Table 4, the ITE trip rates for “Multifamily Housing (Mid-Rise)” are incorrectly labeled as “trips per ksf.” In reality, the applied rates (5.44, 0.36, 0.44) are per dwelling unit. Although the arithmetic is correct, this fundamental unit error undermines confidence in the technical review.
Response to Comment #15 - This comment is correct as there is a typo in Table 4 that refers to the rates as being “per ksf”. The rates should have been identified as being “per unit” which are the correct rates and were what was used in the calculations.
Comment #16 (3.9 b.) - Contradictory trip-generation calculations – Section 5.1 states “No trip generation credit was given because the site was vacant.” Yet Section 5.2 adds trip credits for prior land uses, claiming the net increase is only 19 AM / 10 PM trips.
This contradiction suggests selective adjustments intended to minimize reported impacts.
Response to Comment #16 - It can be readily verified that the traffic analysis was based on the trip generation rates for the project with no credit given for removal of traffic from the prior uses. Section 5.2 clearly states that it is simply presenting a comparison to the prior land uses. While the traffic analysis does not utilize these numbers, this is an important comparison for the decision makers to consider when evaluating a new land use. The existing buildings were not occupied at the time of the traffic counts and therefore credit cannot be given in the traffic analysis for the traffic previously generated by them. However, Section 5.2 was included to provide a comparison showing the forecast net increase in traffic when compared to the prior uses for informational purposes only. For this project the net increase in traffic compared to the prior land uses is forecast to be about 19 additional trips during the AM peak hour and about 10 additional trips during the PM peak hour.
Comment #17 (3.9 c.) - Misapplied parking demand data – The TIA cites parking demand data applicable to buildings with no two-bedroom units. However, the proposed project includes 29 two-bedroom units, making the cited rates inapplicable and the parking analysis unreliable.
Response to Comment #17 - Two thirds of the proposed project would be studios and one-bedroom units and the average square footage of the units is about 800 square feet.
The rates used also do not account for the availability of transit adjacent to the project.
As a result, since the project has smaller sized units it was concluded that the onebedroom category was more applicable than the rates for buildings with 2+ bedrooms.
However, it is important to point out that even if the mid-rise parking generation rate for buildings with 2+ bedrooms are used the project would still be found to have sufficient parking. The Institute of Transportation Engineers (ITE) Parking Generation Manual
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
specifies a peak parking demand rate of 1.1 vehicles per unit for an 85-unit Multifamily Mid-Rise Housing project with 2+ bedrooms (ITE Land Use Code 221).5 For the proposed project this equates to a forecast peak parking demand of 95 vehicles. As noted in the traffic study, this peak demand forecast includes guests and deliveries, indicating the 95-space automated parking garage should be sufficient to accommodate the peak demand from the project.
Amendments to the State CEQA Guidelines (which became effective March 18, 2010) removed parking from the State’s Environmental Checklist as an environmental factor to be considered under CEQA. The City of Los Altos, in its review of the proposed project, considers parking demand to ensure that the project’s provision of parking spaces would result in minimal adverse effects, and that any secondary effects (such as to air quality due to drivers searching for parking spaces) would be minimized. As such, although not required by CEQA, parking conditions are evaluated in the traffic study as a non-CEQA topic for informational purposes.
Comment #18 (4.) - Improper Use of CEQA Class 32 (Infill) Exemption – The City relied on CEQA Guidelines 15332 (Class 32 Infill). This exemption is only available if the project would not result in any significant effects related to traffic, noise, air quality, or water quality. In this case the TIA documents an already failing intersection (LOS F) at Jordan / N. San Antonio; adding traffic is a significant cumulative impact. The project introduces new traffic and complex access patterns with no mitigation.
Response to Comment #18 - The traffic study clearly specifies that the addition of a minimal amount of project traffic to the intersection of Jordan Avenue and N. San Antonio Road is not considered a significant impact according to City standards. This intersection has overall intersection operations of LOS A and would continue to operate at LOS A with the addition of project traffic. The proposed project would only add about 6 trips per hour to the intersection. As required, the traffic study reported that the side street traffic operates at LOS F. However, this LOS F condition is only on the stopcontrolled side street approach, the overall intersection has LOS A operations with no noticeable delays for through traffic on N. San Antonio Road. This intersection does not meet any of Caltrans’ warrants for installation of a traffic signal and has only had one reported accident in the past five years.
Comment #19 (5.) - Challenge to AB 2097 Parking Exemption (Major Transit Stop Definition) – The project effectively claims a parking exemption under AB 2097 based on proximity to a “major transit stop.” However, the Applicant’s own traffic report states that VTA Route 22 operates at a 15-10 minute headways during peak hours. Under Public Resources Code 21155, a “major transit stop” requires service intervals of 15 minutes or less during peak commute hours. Because headways reach 20 minutes, the site does not meet the statutory definition.
5 Parking Generation Manual, 6th Edition, Institute of Transportation Engineers, Washington D.C., October, 2023.
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
Response to Comment #19 - Assembly Bill No. 2553 was passed on 8/22/2024 and revised the definition of “major transit stop” to increase the required frequency of service interval from 15 minutes to 20 minutes. However, Route 22 actually does operate with service intervals of 15 minutes or less during the peak hours. It is our understanding that 20-minute service intervals only occur during off-peak periods. It is important to note that State law does not specify whether a minimum bus service interval is required in both directions during both the AM and PM peak periods. In most jurisdictions meeting the minimum service intervals in just one direction during each peak period is sufficient to satisfy the minimum bus service requirements.
Comment #20 (6.) - Incomplete and Unsupported Parking Analysis – The applicants assertion that 95 spaces “is sufficient” is not supported by objective analysis: No guest parking demand analysis (typical standards often require ~0.25 spaces per unit); No combined analysis of loading need and parking operations; No clear demonstration of ADA compliance with the mechanical system; No credible failure-scenario modeling; No evaluation of driveway blockage if cars queue back onto Jordan.
Response to Comment #20 - The Institute of Transportation Engineers (ITE) Parking Generation Manual specifies a peak parking demand rate of 1.1 vehicles per unit for Multifamily Mid-Rise Housing with 2+ bedrooms. This rate is based on surveys of parking demand at 44 similar apartment complexes and the parking surveys included all guests and deliveries. Guest parking is already accounted for in the peak parking demand rates and the guest parking requirements referred to are instead related to municipal code requirements for guest parking that some cities have. The ITE parking demand analysis indicated the 95-space automated parking garage would be sufficient to accommodate the peak demand from the project, including guests.
As noted previously, based on the maximum forecast inbound volume (23 vehicles per hour) the average inbound queue at the automated garage bays would be approximately two vehicles. The driveway adjacent to the automated garage bays has available queuing for three inbound vehicles and therefore the queues would not be forecast to extend back out onto Jordan Avenue.
Comment #21 (9.) - Loading Waiver Creates a Documented Public Safety Hazard – Under the current design: Every trash truck, delivery truck, and moving vehicle must back onto Jordan Avenue or reverse across the public sidewalk to reach the trash and mail rooms. With a building of this scale, routine deliveries, trash collection, and moving activities will inevitably block traffic, just feet from the El Camino Real intersection.
Response to Comment #21 - The project site plan has now been revised to include a truck loading area on the Jordan Avenue frontage. However, having trucks back out of a driveway onto the roadway is not an unusual or prohibited maneuver. This is not a City liability issue or a safety impact as the driver would be fully responsible and liable for safely maneuvering his truck in and out of the driveway. In some situations, this could
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
require flagmen to safely accommodate larger trucks. The comment describes the driveway as being just feet from the El Camino Real intersection. The driveway is approximately 175 feet from the El Camino Real intersection with Jordan Avenue.
Comment #22 (12.) - Transformer Fence Waiver Creates a Safety Hazard and Fails Physical-Preclusion Test – The proposed 6’5” opaque transformer fence eliminates required sight distance. The applicant proposes a 6’5” fence directly adjacent to the driveway and 4.5-foot sidewalk, eliminating the sight triangle needed for safe turning movements. This creates a foreseeable collision hazard for vehicles exiting the garage and for cyclists and pedestrians on this school route.
Response to Comment #22 - The enclosure has now been relocated so that it no longer will obstruct motorist’s view of pedestrians exiting the driveway. The proposed driveway would be no different than many other driveways along Jordan Avenue and the improved sidewalk along the project frontage would be expected to improve safety for pedestrians in the area.
Comment #23 (13.) - Fire Safety and Emergency Access Hazards – The project presents serious life-safety concerns. Single access: There is only one vehicular access point on Jordan Avenue. In a congested LOS F environment, this single access could be blocked by queues or parked vehicles, delaying or preventing fire and ambulance access.
Response to Comment #23 - While the land use plan for the proposed project would include one access driveway, this does not mean this is the only emergency access point for the project. The proposed project is directly adjacent to Jordan Avenue and El Camino Real, which are streets that are wide enough to provide full emergency access.
In addition, the project driveway adjacent to the automated parking bays meets the minimum width needed to accommodate emergency vehicles. The addition of traffic from the project would not be forecast to create new impacts to traffic operations in the area and would not result in any significant changes to emergency vehicle response times. Therefore, subject to City and fire department verification, the development of the proposed project is expected to have less-than-significant impacts regarding emergency vehicle access.
The LOS F condition the comment is referring to was only reported on the stopcontrolled side street approach at Jordan Avenue and W San Antonio Road, which is located about six blocks from the project site. There were no LOS F conditions identified in the immediate vicinity of the proposed project, the project driveway intersection and the adjacent intersection of Jordan Avenue with El Camino Real are both forecast to operate at LOS B or better under all study scenarios.
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
Comments contained in a letter from Lin Zhang of Elite Transportation Group dated December 21, 2025
Comment #1 - Driveway Right-Turn Conflict with Bicyclists, Scooters, and Pedestrians – Our primary concern is safety at the development driveway, particularly for vehicles exiting the driveway and turning right. This movement creates a direct conflict with pedestrians, scooters, and bicyclists using the sidewalk/walkway on the development side. This risk is amplified by the approximately 6½ -foot-high solid transformer fence, which visually obscures approaching sidewalk users and reduces the driver’s ability to detect a pedestrian, scooter, or bicyclist in time. As a result, a vehicle turning right out of the driveway could strike a pedestrian, scooter, or bicyclist traveling along the projectside sidewalk. Most bike, sooter, and pedestrian users on this segment appear to be Grade 5–8 students traveling to and from two nearby schools. Based on a recent field observation, about 60 bicyclists/scooters/pedestrians used this segment in the morning peak hour during which many students travel from El Camino Real toward Portola Avenue, and they are very likely to use the sidewalk on the development side because it is more direct and typically requires fewer street crossings.
Response to Comment #1 - The enclosure has now been relocated so that it no longer will obstruct motorist’s view of pedestrians exiting the driveway. The proposed driveway would be no different than many other driveways along Jordan Avenue and the improved sidewalk along the project frontage would be expected to improve safety for pedestrians in the area.
Comment #2 - “All-At-Once” Morning Peak Conflicts and Compounding Operational Complexity: My second concern is the increased safety risk when multiple peak-hour elements occur at the same time:
Trash collection during the Friday morning peak: When the loading zone is occupied during trash pickup (noting that collection occurs around 8:00–8:30 AM, which overlaps with the morning peak and student commute), it can create added conflicts and unexpected maneuvers. This introduces additional safety risks for drivers, pedestrians, and bicyclists when everyone is rushing and roadway space is constrained.
Cumulative growth from already-approved development across the street: The site across the street (currently Jack-in-the-Box) received approval in 2024 for a redevelopment adding 33 units. With this proposed project (approximately 85 units), the corridor will experience a combined addition of 118 units (33 + 85). The combined effect will further elevate peak-hour operational strain and safety risk at Jordan Avenue/driveway crossing locations.
Response to Comment #2 - The project site plan has now been revised to include a truck loading area on the Jordan Avenue frontage and there would be nothing unusual
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
about garbage truck activity overlapping with the morning peak and student commute in the area. In addition, having garbage trucks backing out of a driveway onto the roadway is not an unusual or prohibited maneuver. This is not a City liability issue or a safety impact as the driver would be fully responsible and liable for safely maneuvering his truck in and out of the driveway.
The additional traffic added from the approved 33-unit project across the street was accounted for and analyzed as part of the transportation impact analysis prepared for the project. There is no evidence indicating that driveways in the area would have poor operations or safety problems with the addition of traffic from proposed and approved projects in the area. The analysis indicated that no level of service or safety impacts would be forecast to occur with the addition of background traffic growth and all planned development in the area.
Comment #3 - Jordan Avenue / North San Antonio Road Intersection Operational and Safety Concerns: The Traffic Analysis Report acknowledges that the Jordan Avenue / North San Antonio Road intersection currently operates at Level of Service (LOS) F under existing conditions. Despite this baseline deficiency, the traffic analysis concludes that traffic generated by the proposed 85-unit development does not require mitigation. I strongly disagree with this conclusion. Any additional traffic introduced at an intersection already operating at LOS F will further degrade operations, increase delay and queueing, and exacerbate driver frustration and aggressive maneuvers. These conditions directly elevate safety risks—particularly for pedestrians, scooters, and bicyclists—at an intersection that already experiences congestion during peak periods.
Given the existing LOS F conditions, the project’s traffic should not be dismissed as inconsequential. At a minimum, the City should require a focused safety and operational analysis and identify appropriate mitigation measures to address the added risk introduced by the project, especially during peak hours when vehicle, bicycle, scooter, and pedestrian volumes overlap.
Response to Comment #3 - The project is forecast to add a very limited amount of traffic at the referenced intersection at Jordan Avenue and N San Antonio Road. The proposed project is forecast to add only about six trips per hour (about one vehicle every 10 minutes) which equates to less than a 0.05% increase to the existing PM peak hour traffic volumes at the intersection. The amount of traffic added at this intersection would not normally warrant that it even be included in traffic study. However, staff requested that it be included in the analysis to verify there would be no impacts there. The results of the analysis indicated this intersection has overall intersection operations of LOS A and would continue to operate at LOS A with the addition of project traffic. However, as required, the traffic study reported that the stop-controlled side street approach operates at LOS F.
This LOS F condition is only on the side street approach, the overall intersection has LOS A operations with no noticeable delays for through traffic on N. San Antonio Road.
This intersection does not meet any of Caltrans’ warrants for installation of a traffic signal
Abrams Associates Response to Appeal Comments on the 4898 El Camino Real Project TRAFFIC ENGINEERING, INC.
and has only had one reported accident in the past five years. There were no pedestrian or bicycle accidents identified at the intersection during the review of the California Highway Patrol accident records. Motorists in the area also have the option of using the E. Portola Avenue intersection with San Antonio Road, which is just over 500 feet to the north of the Jordan Avenue intersection. This intersection has a traffic signal where left turns can be made with less delay during the peak hours.
With or without the proposed project there are several reasons the City would probably not select this intersection for further study. The first reason is there is no crosswalk across N. San Antonio Road at this intersection. The second reason is a review of the accident data did not identify any safety problems. Another reason is that motorists and pedestrians in the area also have the option of using the nearby E. Portola Avenue intersection with San Antonio Road. This signalized intersection is just over 500 feet to the north of the Jordan Avenue intersection, which is less than the typically desired spacing for the installation of traffic signals.
Please don’t hesitate to contact me if you have any questions about this information.
Sincerely,
Stephen C. Abrams
President
Abrams Associates
T.E. License No. 1852
7 Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 7:00 AM
7:15 AM
7:30 AM
7:45 AM
8:00 AM
8:15 AM
8:30 AM
8:45 AM
Total 000000000000
Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 2:00 PM 7 2 3 13 1 0 26
2:15 PM 13 4 10 12 0 1 40
2:30 PM 12 4 7 16 4 2 45
2:45 PM 15 7 14 24 6 4 70
3:00 PM 18 11 11 14 9 9 72
3:15 PM 19 11 6 15 21 12 84
3:30 PM 13 13 4 16 12 4 62
3:45 PM 15 7 6 11 5 4 48
Total 0 112 59 61 121 0 0 0 0 58 0 36 447
Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 7:00 AM
7:15 AM
7:30 AM
7:45 AM
Total 0 0 0 0 0 0 0 0 0 0 0 0
Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 2:45 PM 15 7 14 24 6 4 70
3:00 PM 18 11 11 14 9 9 72
3:15 PM 19 11 6 15 21 12 84
3:30 PM 13 13 4 16 12 4 62
Total 0 65 42 35 69 0 0 0 0 48 0 29 288
0 (0) 0 (69) 0 (35) 0 (104) 0 (94)
0 (0) 0 (29)
0 (0) 0 (77)
0 (0) 0 (0)
0 (0) 0 (77)
0 (0) 0 (48)
0 (0) 0 (65) 0 (42) 0 (117) 0 (107)
South Segment: 0 (224)
WESTBOUND
North Segment: 0 (198)
East Segment
0 (154)
West Segment
0 (0)
PM PEAK HOUR VOLUMES
7 Jordan Avenue Jordan Avenue Marich Way Marich Way
NORTHBOUND SOUTHBOUND EASTBOUND PM
7 Jordan Avenue Jordan Avenue Marich Way Marich Way
NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND AM
AM PEAK HOUR VOLUMES
WESTBOUND
7 Jordan Avenue Jordan Avenue Marich Way Marich Way
NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND PM
JORDAN AVENUE AT MARICH WAY INTERSECTION TURNING MOVEMENT SUMMARY 7 Jordan Avenue Jordan Avenue Marich Way Marich Way
NORTHBOUND SOUTHBOUND EASTBOUND AM
Location: Jordan Avenue at Marich Way
AM Start Time
PM Start Time 2:00 PM
Date: Wednesday, January 7, 2026
Collected By: Jessica Fong
Intersection No:
8 Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 7:00 AM
7:15 AM
7:30 AM
7:45 AM
8:00 AM
8:15 AM
8:30 AM
8:45 AM
Total 000000000000
Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 2:00 PM 1 7 3 0 5 11 8 0 1 1 0 1 38
2:15 PM 0 8 1 1 6 6 7 1 0 0 1 0 31
2:30 PM 2 9 1 3 6 9 9 0 1 1 1 2 44
2:45 PM 2 9 2 1 11 16 11 0 2 1 0 1 56
3:00 PM 2 13 3 1 8 20 14 1 2 0 1 2 67
3:15 PM 1 18 0 0 13 26 21 0 0 1 0 1 81
3:30 PM 1 4 1 2 18 17 25 1 1 1 2 1 74
3:45 PM 1 11 1 1 5 6 14 0 1 0 0 1 41
Total 10 79 12 9 72 111 109 3 8 5 5 9 432
Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 7:00 AM
7:15 AM
7:30 AM
7:45 AM
Total 0 0 0 0 0 0 0 0 0 0 0 0
Time Left Thru Right Left Thru Right Left Thru Right Left Thru Right Total 2:45 PM 2 9 2 1 11 16 11 0 2 1 0 1 56
3:00 PM 2 13 3 1 8 20 14 1 2 0 1 2 67
3:15 PM 1 18 0 0 13 26 21 0 0 1 0 1 81
3:30 PM 1 4 1 2 18 17 25 1 1 1 2 1 74
Total 6 44 6 4 50 79 71 2 5 3 3 5 278
0 (79) 0 (50) 0 (4) 0 (133) 0 (120)
0 (71) 0 (5)
0 (88) 0 (11)
0 (2) 0 (3)
0 (78) 0 (12)
0 (5) 0 (3)
0 (6) 0 (44) 0 (6) 0 (58) 0 (56)
South Segment: 0 (114)
WESTBOUND
North Segment: 0 (253)
East Segment
0 (23)
West Segment
0 (166)
PM PEAK HOUR VOLUMES
8 Jordan Ave Jordan Ave E Portola / Portola Ct E Portola / Portola Ct
NORTHBOUND SOUTHBOUND EASTBOUND PM
8 Jordan Ave Jordan Ave E Portola / Portola Ct E Portola / Portola Ct
NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND AM
AM PEAK HOUR VOLUMES
WESTBOUND
8 Jordan Ave Jordan Ave E Portola / Portola Ct E Portola / Portola Ct
NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND PM
JORDAN AVE AT E PORTOLA / PORTOLA CT INTERSECTION TURNING MOVEMENT SUMMARY 8 Jordan Ave Jordan Ave E Portola / Portola Ct E Portola / Portola Ct
NORTHBOUND SOUTHBOUND EASTBOUND AM
Location: Jordan Ave at E Portola / Portola Ct
AM Start Time
PM Start Time 2:00 PM
Date: Wednesday, January 7, 2026
Collected By: Rick Folster
Intersection No:
Catalina Ct
a Wy in al Cat
University Ave
e uz Av r aC r eV
Belden Dr
PortolaCt
l C a kr
vA e
Pan hit c
Wa
y
LosNinos Wy
Del Monte
Ave
Dis et lDr
aF ri
a O sk
vA e
Stanford Ave
oC lege l
vA e
E
Portola Ave
a C sit Wa
y
Paso Robles
Ave
Marich Wy
Alvarado Ave
De pl hi Cir
Loucks Ave
r O et ag vA e
Latham
St
W
Portola Ave
Marich Wy
Latham
St
r O ega t
vA e
Showers Dr
R ne gs ot rffAve
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ord
a
n
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v
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O RD I NO NT A NAS N
W
EL
CAMINO
REAL
WEL CAMINO
REAL
Walmart
Safeway
24 Hour
Fitness
Target &
CVS
DMV
Egan
Junior High
School
PROJECT
LOCATION 1
2 N
Catalina Ct
a Wy in al Cat
University Ave
e uz Av r aC r eV
Belden Dr
PortolaCt
l C a kr
vA e
Pan hit c
Wa
y
LosNinos Wy
Del Monte
Ave
Dis et lDr
aF ri
a O sk
vA e
Stanford Ave
oC lege l
vA e
E
Portola Ave
a C sit Wa
y
Paso Robles
Ave
Marich Wy
Alvarado Ave
De pl hi Cir
Loucks Ave
r O et ag vA e
Latham
St
W
Portola Ave
Marich Wy
Latham
St
r O ega t
vA e
Showers Dr
R ne gs ot rffAve
J
ord
a
n
A
v
e
Jo dr an Ave
O RD I NO NT A NAS N
W
EL
CAMINO
REAL
WEL CAMINO
REAL
Walmart
Safeway
24 Hour
Fitness
Target &
CVS
DMV
Egan
Junior High
School
PROJECT
LOCATION 1
2 N
Catalina Ct
a Wy in al Cat
University Ave
e uz Av r aC r eV
Belden Dr
PortolaCt
l C a kr
vA e
Pan hit c
Wa
y
LosNinos Wy
Del Monte
Ave
Dis et lDr
aF ri
a O sk
vA e
Stanford Ave
oC lege l
vA e
E
Portola Ave
a C sit Wa
y
Paso Robles
Ave
Marich Wy
Alvarado Ave
De pl hi Cir
Loucks Ave
r O et ag vA e
Latham
St
W
Portola Ave
Marich Wy
Latham
St
r O ega t
vA e
Showers Dr
R ne gs ot rffAve
J
ord
a
n
A
v
e
Jo dr an Ave
O RD I NO NT A NAS N
W
EL
CAMINO
REAL
WEL CAMINO
REAL
Walmart
Safeway
24 Hour
Fitness
Target &
CVS
DMV
Egan
Junior High
School
y
PROJECT
LOCATION 1
2 N
JORDAN AVE
PORTOLA CT
E PORTOLA AVE
533 4
6 44
6 25
71 50
79 2
JORDAN AVE
2948
MARICH WY
35 42
65 69
1 N
FIGURE 1 EXISTING SCHOOL PERIOD TRAFFIC VOLUMES
TRANSPORTATION IMPACT ANALYSIS4898 El Camino Real Residential ProjectCity of Los Altos Abrams Associates
TRAFFIC ENGINEERING, INC.
Abrams Associates
TRAFFIC ENGINEERING, INC.
TABLE 1
EXISTING SCHOOL PEAK HOUR INTERSECTION LEVEL OF SERVICE CONDITIONS
INTERSECTION CONTROL
EXISTING
SCHOOL PEAK HOUR
EXISTING SCHOOL
PEAK PLUS PROJECT
Delay LOS Delay LOS
1 MARICH WAY & JORDAN AVENUE Side Street
Stop 10.7 B 10.8 B
2 PORTOLA AVENUE & JORDAN AVENUE Side Street
Stop 7.7 A 7.8 A
SOURCE: Abrams Associates, 2026
NOTES: Intersection LOS is based on delay which is presented in terms of seconds per vehicle.
TABLE 2
CUMULATIVE SCHOOL PEAK HOUR INTERSECTION LEVEL OF SERVICE CONDITIONS
INTERSECTION CONTROL
CUMULATIVE
SCHOOL PEAK HOUR
CUMULATIVE
SCHOOL PEAK PLUS
PROJECT
Delay LOS Delay LOS
1 MARICH WAY & JORDAN AVENUE Side Street
Stop 12.0 B 12.1 B
2 PORTOLA AVENUE & JORDAN AVENUE Side Street
Stop 8.3 A 8.4 A
SOURCE: Abrams Associates, 2026
NOTES: Intersection LOS is based on delay which is presented in terms of seconds per vehicle.
HCM 7th TWSC Existing PM
1: Jordan Avenue & Marich Way 01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 1
Intersection
Int Delay, s/veh 3.8
Movement WBL WBR NBT NBR SBL SBT
Lane Configurations
Traffic Vol, veh/h 48 29 65 42 35 69
Future Vol, veh/h 48 29 65 42 35 69
Conflicting Peds, #/hr 22 12 0 22 12 0
Sign Control Stop Stop Free Free Free Free
RT Channelized - None - None - None
Storage Length 0 -----
Veh in Median Storage, # 0 - 0 - - 0
Grade, % 0 - 0 - - 0
Peak Hour Factor 87 87 87 87 87 87
Heavy Vehicles, % 2 2 2 2 2 2
Mvmt Flow 55 33 75 48 40 79
Major/Minor Minor1 Major1 Major2
Conflicting Flow All 303 133 0 0 145 0
Stage 1 121 -----
Stage 2 182 -----
Critical Hdwy 6.42 6.22 - - 4.12 -
Critical Hdwy Stg 1 5.42 - - - - -
Critical Hdwy Stg 2 5.42 - - - - -
Follow-up Hdwy 3.518 3.318 - - 2.218 -
Pot Cap-1 Maneuver 689 916 - - 1437 -
Stage 1 904 -----
Stage 2 849 -----
Platoon blocked, % - - -
Mov Cap-1 Maneuver 641 887 - - 1407 -
Mov Cap-2 Maneuver 641 -----
Stage 1 885 -----
Stage 2 807 -----
Approach WB NB SB
HCM Ctrl Dly, s/v 10.74 0 2.57
HCM LOS B
Minor Lane/Major Mvmt NBT NBRWBLn1 SBL SBT
Capacity (veh/h) - - 716 606 -
HCM Lane V/C Ratio - - 0.124 0.029 -
HCM Ctrl Dly (s/v) - - 10.7 7.6 0
HCM Lane LOS - - B A A
HCM 95th %tile Q(veh) - - 0.4 0.1 -
HCM 7th AWSC Existing PM
2: Jordan Avenue & Portola Ave 01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 2
Intersection
Intersection Delay, s/veh 7.7
Intersection LOS A
Movement EBL EBT EBR WBL WBT WBR NBL NBT NBR SBL SBT SBR Lane Configurations
Traffic Vol, veh/h 71 2 5 3 3 5 6 44 6 4 50 79
Future Vol, veh/h 71 2 5 3 3 5 6 44 6 4 50 79
Peak Hour Factor 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 Heavy Vehicles, % 2 2 2 2 2 2 2 2 2 2 2 2
Mvmt Flow 82 2 6 3 3 6 7 51 7 5 57 91
Number of Lanes 010010010010
Approach EB WB NB SB
Opposing Approach WB EB SB NB
Opposing Lanes 1111
Conflicting Approach Left SB NB EB WB
Conflicting Lanes Left 1111
Conflicting Approach Right NB SB WB EB
Conflicting Lanes Right 1111
HCM Control Delay, s/veh 8.1 7.3 7.6 7.6
HCM LOSA A A A
Lane NBLn1 EBLn1 WBLn1 SBLn1
Vol Left, % 11% 91% 27% 3%
Vol Thru, % 79% 3% 27% 38%
Vol Right, % 11% 6% 45% 59%
Sign Control Stop Stop Stop Stop
Traffic Vol by Lane 56 78 11 133
LT Vol 6 71 3 4
Through Vol 44 2 3 50
RT Vol 6 5 5 79
Lane Flow Rate 64 90 13 153
Geometry Grp 1111
Degree of Util (X) 0.075 0.111 0.015 0.162
Departure Headway (Hd) 4.188 4.461 4.276 3.81
Convergence, Y/N Yes Yes Yes Yes
Cap 842 793 842 926
Service Time 2.281 2.549 2.276 1.895
HCM Lane V/C Ratio 0.076 0.113 0.015 0.165
HCM Control Delay, s/veh 7.6 8.1 7.3 7.6
HCM Lane LOS AAAA
HCM 95th-tile Q 0.2 0.4 0 0.6
HCM 7th TWSC Existing +Project PM
1: Jordan Avenue & Marich Way 01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 1
Intersection
Int Delay, s/veh 3.7
Movement WBL WBR NBT NBR SBL SBT
Lane Configurations
Traffic Vol, veh/h 48 29 70 42 35 72
Future Vol, veh/h 48 29 70 42 35 72
Conflicting Peds, #/hr 22 12 0 22 12 0
Sign Control Stop Stop Free Free Free Free
RT Channelized - None - None - None
Storage Length 0 -----
Veh in Median Storage, # 0 - 0 - - 0
Grade, % 0 - 0 - - 0
Peak Hour Factor 87 87 87 87 87 87
Heavy Vehicles, % 2 2 2 2 2 2
Mvmt Flow 55 33 80 48 40 83
Major/Minor Minor1 Major1 Major2
Conflicting Flow All 312 139 0 0 151 0
Stage 1 127 -----
Stage 2 185 -----
Critical Hdwy 6.42 6.22 - - 4.12 -
Critical Hdwy Stg 1 5.42 - - - - -
Critical Hdwy Stg 2 5.42 - - - - -
Follow-up Hdwy 3.518 3.318 - - 2.218 -
Pot Cap-1 Maneuver 681 910 - - 1430 -
Stage 1 899 -----
Stage 2 846 -----
Platoon blocked, % - - -
Mov Cap-1 Maneuver 633 880 - - 1400 -
Mov Cap-2 Maneuver 633 -----
Stage 1 880 -----
Stage 2 804 -----
Approach WB NB SB
HCM Ctrl Dly, s/v 10.81 0 2.5
HCM LOS B
Minor Lane/Major Mvmt NBT NBRWBLn1 SBL SBT
Capacity (veh/h) - - 708 589 -
HCM Lane V/C Ratio - - 0.125 0.029 -
HCM Ctrl Dly (s/v) - - 10.8 7.6 0
HCM Lane LOS - - B A A
HCM 95th %tile Q(veh) - - 0.4 0.1 -
HCM 7th AWSC Existing +Project PM
2: Jordan Avenue & Portola Ave 01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 2
Intersection
Intersection Delay, s/veh 7.8
Intersection LOS A
Movement EBL EBT EBR WBL WBT WBR NBL NBT NBR SBL SBT SBR Lane Configurations
Traffic Vol, veh/h 71 2 5 3 3 5 6 49 6 4 53 79
Future Vol, veh/h 71 2 5 3 3 5 6 49 6 4 53 79
Peak Hour Factor 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 Heavy Vehicles, % 2 2 2 2 2 2 2 2 2 2 2 2
Mvmt Flow 82 2 6 3 3 6 7 56 7 5 61 91
Number of Lanes 010010010010
Approach EB WB NB SB
Opposing Approach WB EB SB NB
Opposing Lanes 1111
Conflicting Approach Left SB NB EB WB
Conflicting Lanes Left 1111
Conflicting Approach Right NB SB WB EB
Conflicting Lanes Right 1111
HCM Control Delay, s/veh 8.1 7.4 7.7 7.7
HCM LOSA A A A
Lane NBLn1 EBLn1 WBLn1 SBLn1
Vol Left, % 10% 91% 27% 3%
Vol Thru, % 80% 3% 27% 39%
Vol Right, % 10% 6% 45% 58%
Sign Control Stop Stop Stop Stop
Traffic Vol by Lane 61 78 11 136
LT Vol 6 71 3 4
Through Vol 49 2 3 53
RT Vol 6 5 5 79
Lane Flow Rate 70 90 13 156
Geometry Grp 1111
Degree of Util (X) 0.082 0.111 0.015 0.166
Departure Headway (Hd) 4.194 4.476 4.297 3.823
Convergence, Y/N Yes Yes Yes Yes
Cap 841 789 838 924
Service Time 2.288 2.569 2.297 1.909
HCM Lane V/C Ratio 0.083 0.114 0.016 0.169
HCM Control Delay, s/veh 7.7 8.1 7.4 7.7
HCM Lane LOS AAAA
HCM 95th-tile Q 0.3 0.4 0 0.6
HCM 7th TWSC
1: Jordan Avenue & Marich Way
Cumulative (2045) PM
01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 1
Intersection
Int Delay, s/veh 4
Movement WBL WBR NBT NBR SBL SBT
Lane Configurations
Traffic Vol, veh/h 65 39 92 57 47 100
Future Vol, veh/h 65 39 92 57 47 100
Conflicting Peds, #/hr 22 12 0 22 12 0
Sign Control Stop Stop Free Free Free Free
RT Channelized - None - None - None
Storage Length 0 -----
Veh in Median Storage, # 0 - 0 - - 0
Grade, % 0 - 0 - - 0
Peak Hour Factor 87 87 87 87 87 87
Heavy Vehicles, % 2 2 2 2 2 2
Mvmt Flow 75 45 106 66 54 115
Major/Minor Minor1 Major1 Major2
Conflicting Flow All 405 173 0 0 193 0
Stage 1 161 -----
Stage 2 245 -----
Critical Hdwy 6.42 6.22 - - 4.12 -
Critical Hdwy Stg 1 5.42 - - - - -
Critical Hdwy Stg 2 5.42 - - - - -
Follow-up Hdwy 3.518 3.318 - - 2.218 -
Pot Cap-1 Maneuver 601 871 - - 1380 -
Stage 1 868 -----
Stage 2 796 -----
Platoon blocked, % - - -
Mov Cap-1 Maneuver 552 843 - - 1351 -
Mov Cap-2 Maneuver 552 -----
Stage 1 850 -----
Stage 2 746 -----
Approach WB NB SB
HCM Ctrl Dly, s/v 11.99 0 2.49
HCM LOS B
Minor Lane/Major Mvmt NBT NBRWBLn1 SBL SBT
Capacity (veh/h) - - 634 576 -
HCM Lane V/C Ratio - - 0.189 0.04 -
HCM Ctrl Dly (s/v) - - 12 7.8 0
HCM Lane LOS - - B A A
HCM 95th %tile Q(veh) - - 0.7 0.1 -
HCM 7th AWSC
2: Jordan Avenue & Portola Ave
Cumulative (2045) PM
01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 2
Intersection
Intersection Delay, s/veh 8.3
Intersection LOS A
Movement EBL EBT EBR WBL WBT WBR NBL NBT NBR SBL SBT SBR Lane Configurations
Traffic Vol, veh/h 96 3 7 4 4 7 8 63 8 5 74 106
Future Vol, veh/h 96 3 7 4 4 7 8 63 8 5 74 106
Peak Hour Factor 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 Heavy Vehicles, % 2 2 2 2 2 2 2 2 2 2 2 2
Mvmt Flow 110 3 8 5 5 8 9 72 9 6 85 122
Number of Lanes 010010010010
Approach EB WB NB SB
Opposing Approach WB EB SB NB
Opposing Lanes 1111
Conflicting Approach Left SB NB EB WB
Conflicting Lanes Left 1111
Conflicting Approach Right NB SB WB EB
Conflicting Lanes Right 1111
HCM Control Delay, s/veh 8.7 7.6 8 8.3
HCM LOSA A A A
Lane NBLn1 EBLn1 WBLn1 SBLn1
Vol Left, % 10% 91% 27% 3%
Vol Thru, % 80% 3% 27% 40%
Vol Right, % 10% 7% 47% 57%
Sign Control Stop Stop Stop Stop
Traffic Vol by Lane 79 106 15 185
LT Vol 8 96 4 5
Through Vol 63 3 4 74
RT Vol 8 7 7 106
Lane Flow Rate 91 122 17 213
Geometry Grp 1111
Degree of Util (X) 0.112 0.161 0.022 0.239
Departure Headway (Hd) 4.449 4.745 4.51 4.038
Convergence, Y/N Yes Yes Yes Yes
Cap 807 757 794 891
Service Time 2.469 2.768 2.538 2.053
HCM Lane V/C Ratio 0.113 0.161 0.021 0.239
HCM Control Delay, s/veh 8 8.7 7.6 8.3
HCM Lane LOS AAAA
HCM 95th-tile Q 0.4 0.6 0.1 0.9
HCM 7th TWSC Cumulative (2045) +Project PM
1: Jordan Avenue & Marich Way 01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 1
Intersection
Int Delay, s/veh 4
Movement WBL WBR NBT NBR SBL SBT
Lane Configurations
Traffic Vol, veh/h 65 39 97 57 47 103
Future Vol, veh/h 65 39 97 57 47 103
Conflicting Peds, #/hr 22 12 0 22 12 0
Sign Control Stop Stop Free Free Free Free
RT Channelized - None - None - None
Storage Length 0 -----
Veh in Median Storage, # 0 - 0 - - 0
Grade, % 0 - 0 - - 0
Peak Hour Factor 87 87 87 87 87 87
Heavy Vehicles, % 2 2 2 2 2 2
Mvmt Flow 75 45 111 66 54 118
Major/Minor Minor1 Major1 Major2
Conflicting Flow All 415 178 0 0 199 0
Stage 1 166 -----
Stage 2 248 -----
Critical Hdwy 6.42 6.22 - - 4.12 -
Critical Hdwy Stg 1 5.42 - - - - -
Critical Hdwy Stg 2 5.42 - - - - -
Follow-up Hdwy 3.518 3.318 - - 2.218 -
Pot Cap-1 Maneuver 594 865 - - 1373 -
Stage 1 863 -----
Stage 2 793 -----
Platoon blocked, % - - -
Mov Cap-1 Maneuver 545 837 - - 1345 -
Mov Cap-2 Maneuver 545 -----
Stage 1 845 -----
Stage 2 743 -----
Approach WB NB SB
HCM Ctrl Dly, s/v 12.09 0 2.44
HCM LOS B
Minor Lane/Major Mvmt NBT NBRWBLn1 SBL SBT
Capacity (veh/h) - - 627 564 -
HCM Lane V/C Ratio - - 0.191 0.04 -
HCM Ctrl Dly (s/v) - - 12.1 7.8 0
HCM Lane LOS - - B A A
HCM 95th %tile Q(veh) - - 0.7 0.1 -
HCM 7th AWSC Cumulative (2045) +Project PM
2: Jordan Avenue & Portola Ave 01/12/2026
4898 El Camino Real Residential Project Synchro 11 Report City of Los Altos Page 2
Intersection
Intersection Delay, s/veh 8.4
Intersection LOS A
Movement EBL EBT EBR WBL WBT WBR NBL NBT NBR SBL SBT SBR Lane Configurations
Traffic Vol, veh/h 96 3 7 4 4 7 8 68 8 5 77 106
Future Vol, veh/h 96 3 7 4 4 7 8 68 8 5 77 106
Peak Hour Factor 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 0.87 Heavy Vehicles, % 2 2 2 2 2 2 2 2 2 2 2 2
Mvmt Flow 110 3 8 5 5 8 9 78 9 6 89 122
Number of Lanes 010010010010
Approach EB WB NB SB
Opposing Approach WB EB SB NB
Opposing Lanes 1111
Conflicting Approach Left SB NB EB WB
Conflicting Lanes Left 1111
Conflicting Approach Right NB SB WB EB
Conflicting Lanes Right 1111
HCM Control Delay, s/veh 8.7 7.7 8.1 8.4
HCM LOSA A A A
Lane NBLn1 EBLn1 WBLn1 SBLn1
Vol Left, % 10% 91% 27% 3%
Vol Thru, % 81% 3% 27% 41%
Vol Right, % 10% 7% 47% 56%
Sign Control Stop Stop Stop Stop
Traffic Vol by Lane 84 106 15 188
LT Vol 8 96 4 5
Through Vol 68 3 4 77
RT Vol 8 7 7 106
Lane Flow Rate 97 122 17 216
Geometry Grp 1111
Degree of Util (X) 0.119 0.161 0.022 0.243
Departure Headway (Hd) 4.455 4.765 4.531 4.049
Convergence, Y/N Yes Yes Yes Yes
Cap 806 753 790 888
Service Time 2.475 2.789 2.559 2.065
HCM Lane V/C Ratio 0.12 0.162 0.022 0.243
HCM Control Delay, s/veh 8.1 8.7 7.7 8.4
HCM Lane LOS AAAA
HCM 95th-tile Q 0.4 0.6 0.1 1
architects
SDG Architects, Inc.
3361 Walnut Blvd. Suite 120
Brentwood, CA 94513
925.634.7000 | sdgarchitectsinc.com
A00
ARCHITECTURAL
A00 TITLE SHEET
A01 PROJECT DATA SHEET
A02 CONTEXT - LOS ALTOS MULTI-FAMILY
A03 CONTEXT - SITE PHOTOS
A04 CONTEXT - 4898 EL CAMINO REAL VICINITY
A05 COLORS AND MATERIALS
A06 PERSPECTIVE VIEW
A07 PERSPECTIVE VIEW
A08 PERSPECTIVE VIEW
A09 ARCHITECTURAL SITE PLAN
A10 BASEMENT FLOOR PLAN
A11 FIRST FLOOR PLAN
A12 SECOND FLOOR PLAN
A13 THIRD FLOOR PLAN
A14 FOURTH FLOOR PLAN
A15 FIFTH FLOOR PLAN
A16 SIXTH FLOOR PLAN
A17 SEVENTH FLOOR PLAN
A18 EIGHTH FLOOR PLAN
A19 ROOF PLAN
A20 FRONT ELEVATION
A21 RIGHT ELEVATION
A22 REAR ELEVATION
A23 LEFT ELEVATION
A24 AXONOMETRIC VIEWS
A25 AXONOMETRIC VIEWS
A26 BUILDING SECTION
A27 BUILDING SECTION
A28 SITE SECTION
A29 ELEVATOR SECTION
A30 ELEVATOR SPEC SHEET
A31 WALL SECTIONS
A32 WALL SECTIONS
A33 UNIT FLOOR PLANS
A34 UNIT FLOOR PLANS
A35 UNIT FLOOR PLANS
A36 SHADOW STUDY
A37 SHADOW STUDY
A38 BUILDING AREA SUMMARY
A39 BUILDING AREA SUMMARY
A40 DETAILS
A41 STREETSCAPE ELEVATION
VICINITY MAP
PROJECT TEAM
ARCHITECT
CONTACT: JEFF POTS
SDG ARCHITECTS, INC.
3361 WALNUT BLVD. SUITE 120
BRENTWOOD, CA 94513
PHONE: (925) 634-7000
EMAIL: [email protected]
LANDSCAPE ARCHITECT
CONTACT: BLAKE RHINEHART
EVERGREEN DESIGN GROUP
1340 ENVIRON WAY
CHAPEL HILL, NC 27515
PHONE: (800) 680-6630
EMAIL: [email protected]
ARON TERRACE - 4898 ECR
LOS ALTOS, CA | AUGUST 1, 2025
CIVIL ENGINEER
CONTACT: PETER CARLINO
LEA & BRAZE ENGINEERING, INC.
2495 INDUSTRIAL PARKWAY WEST
HAYWARD, CA 94545
PHONE: (510) 887-4086
EMAIL: [email protected]
JOINT TRENCH
CONTACT: ALFONSO REYES
TARRAR UTILITY CONSULTANTS
813 FIRST STREET
BRENTWOOD, CA 94513
PHONE: (925) 308-0650
EMAIL: [email protected]
PROJECT
SITE
OWNER
CONTACT: NAVNEET ARON
ADL 15 LLC, ARON DEVELOPERS
171 MAIN ST. #562
LOS ALTOS, CA 94022
PHONE: (650) 770-9812
EMAIL: [email protected]
CIVIL
TM-1.0 TITLE SHEET
TM-1.1 TENTATIVE MAP FOR CONDOMINIUM PURPOSES
TM-1.2 PRELIMINARY SITE PLAN
TM-2.0 PRELIMINARY GRADING & DRAINAGE PLAN
TM-3.0 PRELIMINARY UTILITY PLAN
TM-4.0 SPECIAL PROJECT EXHIBIT
TM-4.1 PRELIMINARY STORMWATER CONTROL PLAN
TM-4.2 PRELIMINARY STORMWATER CONTROL DETAILS
SU1 ALTA / NSPS LAND TITLE SURVEY
SU2 ALTA / NSPS LAND TITLE SURVEY
LANDSCAPE
L-0 PRELIM NOTES & IMAGES
L-1 PRELIM LANDSCAPE PLAN
L-2 PRELIM LANDSCAPE PLAN
JOINT TRENCH
JT1 JOINT TRENCH COMPOSITE TITLE SHEET
JT2 JOINT TRENCH GENERAL NOTES & DETAILS
JT3 JOINT TRENCH DETAILS
JT4 JOINT TRENCH SECTIONS & DETAILS
JT5 JOINT TRENCH COMPOSITE PLAN
PARKING SYSTEM
QG0.00 COVER SHEET
QA1.0B1 EQUIPMENT FLOOR PLAN - AUTOMATED
PARKING LEVEL B1
QA1.0B2 EQUIPMENT FLOOR PLAN - AUTOMATED
PARKING LEVEL B2
QA1.01 EQUIPMENT FLOOR PLAN - FIRST FLOOR (LOAD
BAY LEVEL)
SHEET INDEX
LOS ALTOS, CA | SEPTEMBER 23, 2025
TM-1.1 VESTING TENTATIVE MAP
TM-1.2 PRELIMINARY SITE PLAN
TM-2.0 PRELIMINARY GRADING & DRAINAGE PLAN
TM-3.0 PRELIMINARY UTILITY PLAN
TM-4.0 SPECIAL PROJECT EXHIBIT
TM-4.1 PRELIMINARY STORMWATER CONTROL PLAN
TM-4.2 PRELIMINARY STORMWATER CONTROL DETAILS
SU1 ALTA / NSPS LAND TITLE SURVEY
SU2 ALTA / NSPS LAND TITLE SURVEY
LANDSCAPE
L-0 PRELIM NOTES & IMAGES
L-1 PRELIM LANDSCAPE PLAN
L-2 PRELIM LANDSCAPE PLAN
JOINT TRENCH
JT1 JOINT TRENCH COMPOSITE TITLE SHEET
JT2 JOINT TRENCH GENERAL NOTES & DETAILS
JT3 JOINT TRENCH DETAILS
JT4 JOINT TRENCH SECTIONS & DETAILS
JT5 JOINT TRENCH COMPOSITE PLAN
PARKING SYSTEM
QG0.00 COVER SHEET
QA1.0B1 EQUIPMENT FLOOR PLAN - AUTOMATED
PARKING LEVEL B1
QA1.0B2 EQUIPMENT FLOOR PLAN - AUTOMATED
PARKING LEVEL B2
QA1.01 EQUIPMENT FLOOR PLAN - FIRST FLOOR (LOAD
BAY LEVEL)
TM-1.2 PRELIMINARY SITE PLAN
TM-2.0 PRELIMINARY GRADING & DRAINAGE PLAN
TM-3.0 PRELIMINARY UTILITY PLAN
TM-4.0 SPECIAL PROJECT EXHIBIT
TM-4.1 PRELIMINARY STORMWATER CONTROL PLAN
TM-4.2 PRELIMINARY STORMWATER CONTROL DETAILS
SU1 ALTA / NSPS LAND TITLE SURVEY
SU2 ALTA / NSPS LAND TITLE SURVEY
LANDSCAPE
L-0 PRELIM NOTES & IMAGES
L-1 PRELIM LANDSCAPE PLAN
L-2 PRELIM LANDSCAPE PLAN
JOINT TRENCH
JT1 JOINT TRENCH COMPOSITE TITLE SHEET
JT2 JOINT TRENCH GENERAL NOTES & DETAILS
JT3 JOINT TRENCH DETAILS
JT4 JOINT TRENCH SECTIONS & DETAILS
JT5 JOINT TRENCH COMPOSITE PLAN
PARKING SYSTEM
QG0.00 COVER SHEET
QA1.0B1 EQUIPMENT FLOOR PLAN - AUTOMATED
PARKING LEVEL B1
QA1.0B2 EQUIPMENT FLOOR PLAN - AUTOMATED
PARKING LEVEL B2
QA1.01 EQUIPMENT FLOOR PLAN - FIRST FLOOR (LOAD
BAY LEVEL)
FOR CONDOMINIUM PURPOSES Page 485 of 1184
September 23, 2025 A01
Los Altos, CA 94022
399.298Livio El Camino PROJECT DATA SHEET
PROJECT DESCRIPTION
A MULTIPLE-FAMILY RESIDENTIAL PROJECT AT 4898 EL CAMINO REAL. THE PROJECT CONSISTS OF 85 DWELLING UNITS WITHIN AN EIGHT-STORY BUILDING, AND ONE LEVEL OF UNDERGROUND PARKING. THE PROJECT REPLACES THE EXISTING FUTON SHOP BUILDING WHICH IS APPROXIMATELY 8,396 SF. THE UNDERGROUND PARKING LEVEL IS ACCESSED BY AN AUTOMATED LIFT SYSTEM FROM THE ALLEY AND INCLUDES, 104 PARKING STALLS. THE FIRST FLOOR INCLUDES THE MAIN LOBBY, A COMMUNITY ROOM, LOCKED BIKE STORAGE, 7 RESIDENTIAL UNITS, AND A MAIL ROOM. THE ROOF TOP INCLUDES A 3,250 SQUARE FOOT ROOFTOP DECK WITH OUTDOOR SEATING. IN ADDITION SOLAR PANELS WILL BE INSTALLED TO OFFSET ELECTRICITY USE. THE TABLE BELOW SUMMARIZES THE PROJECT. THE PROJECT IS DEFINED AS A HIGH RISE STRUCTURE PER THE 2022 CALIFORNIA BUILDING CODE.
PROJECT DATA TABLE
ADDRESS:
APN:
GENERAL PLAN:
ZONING:
GROSS SITE AREA:
NET SITE AREA:
PROPOSED DENSITY:
LOT COVERAGE:
IMPERVIOUS AREA:
OCCUPANCY:
CONSTRUCTION:
FIRE SPRINKLERS:
FEMA FLOOD ZONE:
FLOOR AREA RATIO (FAR):
4898 EL CAMINO REAL
LOS ALTOS, CA 94022
170-03-085
THOROUGHFARE COMMERCIAL (TC)
COMMERCIAL THOROUGHFARE (CT)
18,919 SF (0.43 acres)
16,919 SF (0.39 acres)
85 UNITS (219 du / net ac)
58.7%
18,919 SF
S2 / R2
TYPE IB
INCLUDED PER C.B.C. 903.2
DESIGNATED AS AN "OTHER AREAS OF
FLOOD HAZARD": 0.2% ANNUAL CHANCE
FLOOD HAZARD
TOTAL INTERIOR (91,520 SF) /
GROSS SITE AREA (18,919 SF) = 4.84 FAR
BUILDING AREA SUMMARY (GROSS S.F.)
BASEMENT FLOOR:
FIRST FLOOR:
SECOND FLOOR:
THIRD FLOOR:
FOURTH FLOOR:
FIFTH FLOOR:
SIXTH FLOOR:
SEVENTH FLOOR:
EIGHTH FLOOR:
TOTAL INTERIOR:
GARAGE:
13,688 S.F.
11,272 S.F.
11,464 S.F.
11,464 S.F.
11,464 S.F.
11,464 S.F.
11,464 S.F.
11,464 S.F.
11,464 S.F.
91,520 S.F.
13,494 S.F.
PARKING STANDARDS
PARKING STANDARDS (PER ASSEMBLY BILL 2097)
THE PROJECT IS LOCATED WITHIN 0.5 MILES OF AT LEAST TWO BUS ROUTES OR STOPS THAT PROVIDE SERVICE EVERY 15 MINUTES.
THEREFORE, UNDER AB 2097, THERE IS NO MINIMUM REQUIREMENT FOR AUTOMOBILE PARKING.
PARKING PROVIDED (LIFT-SYSTEM)
STANDARD SPACES
ADA SPACES
EV CHARGING SPACES (LEVEL 2)
TOTAL PROVIDED
NOTES:
PARKING IN BASEMENT IS A DOUBLE-STACKED AUTOMATED LIFT
SYSTEM. RESIDENTS EXIT THEIR VEHICLE ON THE FIRST FLOOR AND THEN THE VEHICLE IS BROUGHT TO THE BASEMENT.
ALL VEHICLES ON BASEMENT FLOOR ARE UNOCCUPIED. NO
RESIDENTS WILL HAVE ACCESS TO THE BASEMENT. BASEMENT
ACCESS IS STRICTLY FOR MAINTENANCE PURPOSES.
83 SPACES
2 SPACES
10 SPACES
95 SPACES
BICYCLE PARKING STANDARDS
REQUIRED SPACES (PER LAMC 14.75.040)
1.5 CLASS I SPACES PER 1 UNIT
1 CLASS II SPACES PER 20 UNITS
PROVIDED SPACES
CLASS I (BICYCLE STORAGE ROOM)
CLASS I (AUTOMATED PARKING SYSTEM)
CLASS II (OUTDOOR BICYCLE RACKS)
128 SPACES
5 SPACES
108 SPACES
20 SPACES
5 SPACES
EXISTING PROPOSED REQUIRED / ALLOWED
SETBACKS:
FRONT 50' 17' - 2 1/2" 20'
REAR 42' 20' - 8" 25'
EXTERIOR (RIGHT) SIDE 5' 8' - 0" 15'
INTERIOR (LEFT) SIDE 0' 9' - 6" 10'
HEIGHT: +/- 22' 109' - 9" (8 STORIES) 55' (OR 5 STORIES)
UNIT AREA SUMMARY
PROPOSED BMR UNITS
TYPE
UNIT SA
UNIT SB
UNIT 1A
UNIT 2A
UNIT 2B
AREA NUMBER OF UNITS
IN BUILDING
TOTAL SF OF
UNITS IN BUILDING
BEDROOMS BATHS
TOTALS
520 SF
600 SF
750 SF
1020 SF
870 SF
2 7
47 22
7 85
1040 SF
4,200 SF
35,250 SF
22,440 SF
6,090 SF
69,020 SF
0 0
1 2
2 1
1 1
2 1
LEVEL
(SHEET)
1 (A11)
2 (A12)
3 (A13)
4 (A14)
5 (A15)
STUDIO
(UNIT SB)
2-BED
(UNIT 2A)
2-BED
(UNIT 2B)
TOTALS 1
301
400
ALL BMR UNITS TO BE VERY LOW INCOME
6 (A16)
7 (A17)
8 (A18)
1 TOTAL
2 2
1 1
1 1
10 1
1 208
1-BED
(UNIT 1A)
104
204
504
604
704
804
6 300
2 PRIVATE
OPEN SPACE
0 SF
0 SF
65 SF - 70 SF
30 SF - 40 SF
50 SF
4320 SF
(See sheets A38 & A39)
AVERAGE PRIVATE OPEN SPACE PER DWELLING UNIT = 50.8 SF
August 1, 2025
Los Altos, CA
August 1, 2025
Los Altos, CA
August 1, 2025
14, 2025
Los Altos, CA
August 1, 2025
Los Altos, CA
September 23, 2025 14, 2025
August 1, 2025
Los Altos, CA
August 1, 2025
Los Altos, CA
August 1, 2025
14, 2025
Los Altos, CA
August 1, 2025
Los Altos, CA
September 23, 2025 14, 2025
August 1, 2025
Los Altos, CA
August 1, 2025
Los Altos, CA
August 1, 2025
14, 2025
Los Altos, CA
August 1, 2025
Los Altos, CA
September 23, 2025 14, 2025
September 23, 2025 A05
Los Altos, CA 94022
399.298Livio El Camino COLORS AND MATERIALS
DOORS AND WINDOWS: ALUMINUM WINDOWS
METAL RAIL
SIDING: TRESPA METEON - BROOKLYN CLASSIC 3-COAT STUCCO
SW 7006 Extra White
CULTURED STONE: CAST-FIT CARBON
SIDING: TRESPA METEON - FRENCH WALNUT COPING & FASCIA COLORS (A COMPOSITE WOOD-BASED FIBER PANELING SYSTEM) (A COMPOSITE WOOD-BASED FIBER PANELING SYSTEM) (A LARGE FORMAT STONE VENEER)
3-COAT STUCCO
WINDOW & DOOR TRIM COLOR
SW 0077 Classic French Gray
(TO MATCH CULTURED STONE: CAST-FIT CARBON)
SW 7006 Extra White
SW 6155 Rice Grain
(TO MATCH TRESPA - BROOKLYN CLASSIC)
SW 6095 Toasty
(TO MATCH TRESPA - FRENCH WALNUT)
(BLACK FRAME FINISH BY METAL WINDOW CORPORATION)
(BLACK FINISH)
(TO MATCH ADJACENT SURFACES)
SW 6155 Rice Grain
(TO MATCH TRESPA - BROOKLYN CLASSIC)
SW 0077 Classic French Gray
(TO MATCH CULTURED STONE:
CAST-FIT CARBON)
August 1, 2025 A06
Los Altos, CA 94022
399.298Livio El Camino PERSPECTIVE VIEW
September 23, 2025 14, 2025
August 1, 2025 A07
Los Altos, CA 94022
399.298Livio El Camino PERSPECTIVE VIEW
September 23, 2025 14, 2025
August 1, 2025 A08
Los Altos, CA 94022
399.298Livio El Camino PERSPECTIVE VIEW
September 23, 2025 Page 493 of 1184
DN
UP
UP
PAD MOUNTED
TRANSFORMERS
MAIL &
PARCEL
ROOM
ENTRANCE
LOBBY
PROPERTY LINE
A23
A21
PROPERTY LINE
LIFT SYSTEM
GARAGE ENTRANCE
LIFT SYSTEM
GARAGE ENTRANCE
BIKE STORAGE
ELEC. MAIN
ROOM
LINE OF
FLOOR
BELOW
24' - 0"
JORDAN AVE
EL CAMINO REAL
BICYCLE PARKING
PATIO METAL FENCE - STEEL
HORIZONTAL FENCE, 3'-6" TALL, TYP.
AT EVERY GROUND FLOOR UNIT PATIO
FIRE DEPARTMENT
CONNECTION (FDC)
(N) GAS SERVICE
& METER
GM
WM WM WM
(N) FIRE PREVENTION
(N) 3" DOMESTIC WATER
(N) 1" IRRIGATION
STEEL HORIZONTAL FENCE,
6'-0" TALL (SEE L-1)
STEEL HORIZONTAL
FENCE, 6'-0" TALL
(SEE L-1)
(FIRE DEPARTMENT ACCESS ROAD)
(FIRE DEPARTMENT ACCESS ROAD)
(N) TREE
(N) TREE,
TYP. OF (4)
(N) SEWER LATERAL
10' - 0"
15' - 0"
20' - 0"
25' - 0"
SETBACK
SETBACK
FRONT
SETBACK
REAR
SETBACK
8' - 9"
TRASH
DECORATIVE PAVING
- SEE LANDSCAPE PLANS
FIRE HOSE DISTANCE
150' - 0"
FIRE HOSE DISTANCE
97' - 6"
FIRE HOSE DISTANCE
52' - 6"
16' - 0"
19' - 0"
21' - 5"
9' - 6"
12' - 6"
12' - 6"
12' - 4"
150' - 6"
WALL MOUNTED
GREEN SCREENS, SEE
LANDSCAPE PLANS
10' - 0"
RECESSED
WINDOW
STAMPED
CONCRETE
8' - 0"
17' - 2 1/2"
17' - 2 3/8"
10' - 7"
10' - 4"
14' - 11"
A20
A21
A22
A23
20' - 8"
PARKING STANDARDS
ALL PARKING FOR THE BUILDING IS LOCATED IN THE
BASEMENT LEVEL. SEE SHEET A10 FOR PARKING
COUNTS AND CALCULATIONS
0' 2' 4' 6' 8' 16'
NORTH
September 23, 2025 A09
Los Altos, CA 94022
399.298Livio El Camino ARCHITECTURAL SITE PLAN
UP
A26
A26
A27 A27
CAR LIFT 01
CAR LIFT 02
164' - 11"
STAIR 1
LINE OF ELEVATOR
PIT ABOVE
83' - 0"
LINE OF CAR LIFT
ROOM 01 ABOVE
LINE OF CAR LIFT
ROOM 02 ABOVE
VEHICLE
STORAGE
01 02
ABV.
03 04
VAN ABV.
05 06
ABV.
07 08
ABV.
09 10
ABV.
11 13
14 ABV.
15 16
ABV.
17 18
ABV.
19 20
ABV.
21 23
24 25
ABV.
26 27
ABV.
28 29
ABV.
30 31
ABV.
32 34
35 ABV.
36 37
ABV.
38 39
ABV.
40 41
ABV.
42 43
ABV.
44 45
ABV.
46 47
ABV.
48 49
ABV.
50 51
ABV.
52 53
ABV.
54 55
ABV.
56 57
ABV.
58 59
ABV.
60 61
ABV.
62 63
ABV.
64 65
ABV.
66 67
ABV.
68 69
ABV.
70 71
ABV.
72 73
ABV.
74 75
ABV.
76 77
ABV.
78 79
ABV.
80 81
ABV.
82 83
ABV.
84 85
ABV.
86 87
ABV.
88 89
ABV.
90 91
ABV.
92 93
ABV.
94 95
ABV.
18'-6" x 8'-6"
CAR STORAGE
SPACE, TYP.
22 33
BATTERY BACKUP
SYSTEM ABV.
10 BIKES
ABV.
12 BELOW
BELOW
10 BIKES
ABV.
QUEUING
PALETTE
ABV.
FIRE PUMP
ROOM BELOW
PARKING STANDARDS
PROJECT UTILIZES AN AUTOMATED PARKING SYSTEM
PARKING STANDARDS (PER ASSEMBLY BILL 2097)
THE PROJECT IS LOCATED WITHIN 0.5 MILES OF AT LEAST
TWO BUS ROUTES OR STOPS THAT PROVIDE SERVICE
EVERY 15 MINUTES. THEREFORE, UNDER AB 2097, THERE IS
NO MINIMUM REQUIREMENT FOR AUTOMOBILE PARKING.
PARKING PROVIDED (LIFT-SYSTEM)
STANDARD SPACES
ADA SPACES
EV CHARGING SPACES (LEVEL 2)
TOTAL PROVIDED
BIKE PARKING PROVIDED (LIFT-SYSTEM)
NUMBER OF BIKES PER PALETTE
NUMBER OF BIKE DESIGNATED PALETTES
TOTAL PROVIDED
NOTES:
PARKING IN BASEMENT IS A DOUBLE-STACKED
AUTOMATED LIFT SYSTEM. RESIDENTS EXIT THEIR
VEHICLE ON THE FIRST FLOOR AND THEN THE
VEHICLE IS BROUGHT TO THE BASEMENT.
ALL VEHICLES ON BASEMENT FLOOR ARE
UNOCCUPIED. NO RESIDENTS WILL HAVE ACCESS TO
THE BASEMENT. BASEMENT ACCESS IS STRICTLY FOR
MAINTENANCE PURPOSES.
83 SPACES
2 SPACES
10 SPACES
95 SPACES
10 BIKES
2 PALETTES
20 BIKES
0' 2' 4' 6' 8' 16'
NORTH
September 23, 2025 A10
Los Altos, CA 94022
399.298Livio El Camino BASEMENT FLOOR PLAN