Los Altos City Council
June 23, 2026

City of Los Altos
Purchasing Policy
JUNE 2026
Attachment 2 - Final Purchasing Policy

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TABLE OF CONTENTS
Contents
ETHICAL GUIDELINES .....................................................................................................3 OVERVIEW & RESPONSIBILITIES..................................................................................3 A VARIETY OF WAYS TO MAKE PURCHASES.................................................................5 A more detailed discussion of these purchasing methods follows: ........................................................ 6 ENVIRONMENTAL PROCUREMENT PRACTICES..................................................................8 SECTION 1. PURPOSE ........................................................................................................................................ 8 SECTION 2. POLICY ....................................................................................................................................... 10 Requirements for City Departments or Procurement Practices.............................................................. 10 Requirements for Vendors............................................................................................................................ 11 Compost and SB 1383 Eligible Mulch procurement................................................................................. 11 SECTION 3. RECORDKEEPING ..................................................................................................................... 12 BIDDING & AUTHORIZATION LIMITS................................................................................ 13 BIDDING EXCEPTIONS .................................................................................................. 15 Sole Source Procurements.......................................................................................................................... 15 Emergency purchases.................................................................................................................................. 15 BUDGET AUTHORITY LEVELS..................................................................................... 17 SIGNATURE AUTHORITY & APPROVALS....................................................................19 LEVEL OF SIGNING AUTHORITY ..................................................................................... 20 Change Orders.............................................................................................................................................. 20 Information Technology Purchases.............................................................................................................. 20 Shared Cost Purchases & Payroll Payments ............................................................................................. 21 Warehouse Orders, Shared Building Supplies & Fuel............................................................................... 21 Equipment PurchasesIdentified in the Budget Process........................................................................... 21 Fixed Asset Identification & Tracking........................................................................................................ 21 Professional Services................................................................................................................................... 22 Legal Fees ...................................................................................................................................................... 24 ADDITIONAL GUIDANCE FISCAL YEAR-END CUT OFF......................................................25 SUPPLIER CONTACT AND DECORUM.............................................................................. 26 Prohibited Practices...................................................................................................................................... 29 PUBLIC WORKS PROJECTS............................................................................................. 29 GLOSSARY................................................................................................................... 30

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EXHIBIT A..................................................................................................................... 35 PURCHASING BID AND AUTHORIZATION CHART..................................................................................... 35 EXHIBIT B..................................................................................................................... 37 PURCHASING BID AND AUTHORIZATION CHART..................................................................................... 37 EXHIBIT C ..................................................................................................................... 38 EMERGENCY PURCHASE FORM – EXAMPLE .............................................................................................. 38 Describe Emergency: .................................................................................................................................. 38 EXHIBIT D.................................................................................................................... 39 MINIMUM INSURANCE REQUIREMENTS ....................................................................................................... 39 Minimum Scope of Insurance asrelated to the provision ofservice to the City ................................... 39 EXHIBIT E..................................................................................................................... 42 PURCHASE CARD POLICY OVERVIEW......................................................................................................... 42 RESPONSIBILITY........................................................................................................................................... 42 REQUESTING CALCARD ................................................................................................................................. 44 CALCARD BASICS ......................................................................................................................................... 44 SPENDING LIMITS .......................................................................................................................................... 46 PROHIBITED PURCHASES ................................................................................................................................ 46 PURCHASE DOCUMENTATION................................................................................................................... 46 REVOCATION OF PRIVILEGES........................................................................................................................ 48 EMERGENCY PURCHASES........................................................................................................................... 48 RECONCILING STATEMENTS ..................................................................................................................... 48 DISPUTED CHARGES .................................................................................................................................... 49 RETURNING ITEMS....................................................................................................................................... 49 LOST OR STOLEN CALCARD........................................................................................................................... 50 DECLINED PURCHASE ................................................................................................................................. 50 REVIEW & AUDITS .......................................................................................................................................... 50 INVOICES & RECEIPTS................................................................................................................................... 50 EXHIBIT F ..................................................................................................................... 51 PURCHASE CARD EMPLOYEE AGREEMENT .............................................................................................. 51

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ETHICAL GUIDELINES
• Compliance with legal prohibitions on conflicts of interest, including the Political Reform Act and Government Code §1090, is required.
• Purchasing from or contracting with a business entity wholly or partially owned or operated by a City employee, or employee’s spouse, is prohibited unless approved in advance by the City Manager. Any employee with such an ownership interest must have no official (City) role in the contracting process. • Purchasing from or contracting with a business entity wholly or partially owned or operated by a family member of a City employee must be approved in advance by a Department Head in writing. To avoid any purchasing conflicts and contract administration issues, any City employee with a familial relationship to a City contractor must disclose the relationship to the Department Head. Such employees must have no official (City) role in the contracting process. A familial relationship is defined as grandparent, grandchild, parent, child, son-in-law, daughter-in-law, parent- in-law, or sibling relationship.
• A City employee may not participate in the contracting processif they have a financial interest in any person(s), firm, or business entity involved with providing goods or services to the City.
• Departments must make every attempt to ensure open and competitive purchases. • Splitting purchases for the purpose of evading the procedures outlined in this document is strictly prohibited.
• The receipt of any monetary or non-monetary gifts, gratuities, promotional items, rebates, or kickbacks of any value from a prospective or actual contractor or vendor to a City employee is prohibited.

OVERVIEW & RESPONSIBILITIES
Implementing a formal policy and process of procuring goods and services, including a purchase order process, provides several key benefits. It supports clear purchase specifications, avoids disputes with vendors, builds an audit trail, allows level competition to set prices, controls spending limits, creates a system of checks and balances, and enhances public trust. The following principles were used in developing this document, and are as follows:
• This policy addresses the acquisition of equipment, materials, supplies, maintenance services, and professional services in accordance with the Los Altos Municipal Code.

It does not address the procurement of public work projects as defined by the California Public Contract Code.

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• The Finance Director is responsible for implementing this document. Administrative changes or interpretations to this document shall be approved by the City Manager to clarify instructions and address tactical operational needs. • The City Attorney or other Attorneys used do not have any financial authority but are responsible for providing legal review of items directed to them by a Department Director, Risk Manager or City Manager. The City Attorney’s role is limited to legal review and does not constitute financial approval authority. Legal review(s) could be contracts, Purchase Orders (PO), Blanket Purchase Orders (BPO), or other Service Agreements as defined in this document.
• Purchasing is decentralized, with each Department Director responsible for coordinating purchasing efforts in their operations. Purchases are initiated through a departmental Requisition (REQ), which is routed to Finance for review and approval.

Once the Requisition is approved, Finance will generate the corresponding Purchase Order (PO), Blanket Purchase Order (BPO), Purchase Contract Agreement (PCA), or Contract Purchase Order (CPO).
• No requisition or BPO, PO, PCA or CPO lacking sufficient appropriation levels as set in the adopted budget will be undertaken.
• Purchases shall not be split to avoid required bid levels or authorizing dollar limits. • Competitive bids shall be sought using the scope and dollar limits outlined herein whenever possible. A minimum of two (2) quotes are required with three (3) quotes preferred. Requests for Bids should consider the quality necessary to meet the City’s needs.
• Service and pricing negotiation is encouraged by the procurement of professional or maintenance services bound via the execution of a City-compliant contract approved by the Risk Manager.
• Contracts and Service Agreementsthat result in a Purchase Order must be reviewed and approved by the Risk Manager for insurance and liability compliance. • A City Business License shall be required of any vendor providing construction or maintenance services within the City of Los Altos. Professional Services such as specialized consultants who do not maintain offices within the City of Los Altos are not required to maintain a City Business License.
• Emergency purchases are allowed under the conditions set forth herein.

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A VARIETY OF WAYS TO MAKE PURCHASES
Purchasing methods vary with the dollar amount and nature of the purchase as follows:

Method of
Purchase
Purchase Type Subject to
Bidding
Supporting
Documents
Conditions Dollar Limits
Petty Cash Small dollar
items on a
reimbursement
basis
No Approved petty
cash slip -
original receipt -
invoice
Cannot
supplant
existing
Purchase
Orders or
Contracts
$100 or
Under
City Calcard Small dollar
items
No Purchase Card
Log/Statement/
receipts/invoice/
delivery packing
slip
Cannot
supplant
existing
Purchase
Orders or
Contracts
Dept set
transaction
limits and
monthly max
card limits
Direct Vendor
Purchases
Small dollar
items
No Approved
invoice/receipt
/check request
Cannot
supplant
existing
Purchase
Orders or
Contracts
Under
$10,000
Purchase
Order (PO)
Large dollar
purchases
requiring bids
Required Approved
requisition/PO/
invoices/receipts
Not to be
used for
professional
services
$10,000 and
over
Blanket
Purchase
Orders (BPO)
Routine
repetitive
purchases using
pre-established
vendor
Required BPOs ID - receipt
- invoice -
packing slip if
delivered
Not to be
used for
professional
services
Subject to
established
annual limits
and dept.
approval
authority

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arrangements.

City ID
required at point
of sale.

Contract
Purchase
Orders(CPO)
Contracted
services - either
maintenance or
professional
See PCA
or PSA
below
Negotiated and
executed
Contract
Contracted
annual limits
and dept.
approval
authority
City Council
approval at
$125,000 and
greater
Purchase
Contracts
Agreements
(PCA)
Routine
repetitive
purchases using
pre-established
vendor
arrangements
Required Negotiated and
executed
Contract and
CPO
Contracted
annual limits
and dept.
approval
authority
Council
approval at
$125,000 and
greater
Professional
Service
Contract
Professional
services based
on need - pricing
competition
encouraged
Recomme
nded
Negotiated and
executed
Contract and
CPO
Contracted
annual limits
and dept.
approval
authority
Council
approval at
$125,000 and
greater
A more detailed discussion of these purchasing methods follows:

Petty Cash is used for infrequent purchases under $100 requiring immediate funding. Petty cash draws must be supported by original receipts and an approved petty cash form denoting a clear business purpose and budget coding. Petty cash shall never be used for personal change requests and is only accessible to designated department custodians.

Department Director approval is always required. Replenishment requests to Finance require full reconciliation and approval.

Calcards accommodate small dollar purchases under $10,000 and are limited to preestablished monthly maximums. They are issued for use only with department director’s approval and the execution of a formal employee agreement. The requirements outlined in the Purchasing Card Policy must be strictly adhered to. Calcards are issued jointly in the City’s and employee’s name and shall only be used by the employee they are issued to.

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Cardholders are responsible for reconciling monthly statements and completing a fully documented and approved transaction log. The proper use of Calcards along with timely payment submittal and complete documentation will be strictly enforced with violations promptly resulting in the revocation of Calcard usage.

Direct Vendor Purchases for one-time purchases that fall under $10,000 and can be submitted for payment using original vendor receipts/invoices. This method should not be used to supplant existing BPO or PCA arrangements. Original vendor receipts/invoices must be marked with a City standard approval and budget coding, be submitted on a timely basis with proper approvals and include a clear/concise description of purpose. With increased volume trends, a BPO or PCA can be established for vendors to use repetitively given proper bidding procedures are followed. Departments should use a Purchase Order whenever purchases are planned, repetitive, or expected to exceed $10,000 cumulatively, to avoid vendor fragmentation.

Purchase Orders (POs) facilitate purchases of over $10,000. They follow the submission of a purchase requisition (REQ) to Finance, are subject to bidding either at the informal or formal level (as defined below) and require department director established authorizations.

Blanket Purchase Orders (BPOs) are based on pre-bid agreements with specific vendors.

They promote efficiency by simplifying access to routinely needed goods and services. • The establishment of a BPO requires competitive bidding. • A BPO has a pre-defined, as coordinated with the requesting department, annual maximum limit tracked by the Finance Department. Purchases shall be supported by identifying BPO ID #, department approvals, original receipts, and invoices prior to payment. Budget/account codes and a clear business purpose shall always be noted. • Requests to increase annual BPO limits must be approved by the department director and the Finance Director or their designee. BPO activity will be reviewed annually by the Finance Department as a basis for justifying the continuance of any one vendor.

It is the requested department’s responsibility to rebid periodically (no more than three to five years) to ensure the best possible pricing, service and availability. • Department directors may request additional BPO vendors by submitting an email to the Finance Department. Criteria for establishing a BPO includes frequency of ordering, the dollar amount of each order and the absence of an established contract. • Regardless of the annual dollar maximum limit, BPO purchases are subject to the signing authority approvals and transaction limits developed by departments and reviewed by the Finance Department.

Purchase Contract Agreements (PCAs) may be beneficial in establishing firm pricing and an ongoing source of goods and services. This entails entering a multi-year contract. Much

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like a BPO, these contracts allow departments to access repetitively needed goods and services with minimal procedural overhead.
• The establishment of a Purchase Contract requires competitive bidding based on signing authority thresholds and use of a City-compliant and approved contract. The approvals of the City Manager (for contracts greater than $50,000), Risk Manager, and Finance Director are required.
• The Risk Manager’s approval is required at the initiation of the PCA and annually thereafter if the cost of the initial agreement is modified by over 5% in total. • Departments may request the establishment of a contract for a particular product or service in coordination with the Finance Department with the submission of a Contract Purchase Order (CPO). Criteria for establishing contracts include frequency of ordering, the dollar amount of each order and barriers to contracting such as insurance requirements.
• A Contract Purchase Order (CPO) must follow the approval thresholds established in the Policy and be submitted to the Finance Department with the fully executed agreement attached.

Cooperative Purchasing Agreements, The City Manager, where advantageous to the City, may, by cooperative purchasing agreements or arrangements, purchase supplies, equipment, and materials through legal contracts of other governmental jurisdictions or public agencies without further competitive bidding by the City. The City may act as the cooperating purchasing agent for other public entities.

Professional Service Contracts are discussed in the following sections of this policy and can only be authorized via an executed City-compliant contract approved by the Risk Manager.

Competitive selection and pricing are required in accordance with applicable procurement thresholds and are encouraged for smaller purchases whenever practical. Departments may request the establishment of a professional service contract below the formal threshold, or must request one when required by policy, in coordination with the Finance Department through submission of a Contract Purchase Order (CPO). The CPO must follow the approval thresholds. Approvals may include the City Manager, Risk Manager, Finance Director, and the City Attorney if legal review is required based on the nature of the contract, as determined by the Risk Manager or Finance Director.

ENVIRONMENTAL PROCUREMENT PRACTICES
SECTION 1. PURPOSE
The City of Los Altos recognizes its responsibility to minimize negative environmental impacts of the City’s activities by ensuring the procurement of services and products that reduce toxicity; conserve natural resources, materials, and energy; and maximize

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recyclability and recycled content while supporting a diverse, equitable, and vibrant community and economy.

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The purpose of this policy is to support procurement decisions that align with the City’s sustainability standards and goals as identified in the adopted Climate Action and Adaptation Plan (CAAP). This policy is applicable to all departments and divisions, to incorporate environmental considerations including but not limited to recycled-content paper and recovered Organic Waste product use into purchasing practices and procurement.

This section will:
• Provide implementation guidance.
• Communicate the City’s commitment to sustainable purchasing to its employees, vendors, and the community.
• Protect and conserve natural resources, water, and energy. • Minimize the City’s contribution to climate change, pollution, and solid waste disposal.
• Empower employees to be innovative and demonstrate leadership by considering sustainability benefits when making purchasing decisions; and • Comply with State requirements as contained in 14 CCR Division 7, Chapter 12, Article 12 (SB 1383 procurement regulations) to procure a specified amount of Recovered Organic Waste Products to support Organic Waste disposal reduction targets and markets for products made from recycled and recovered Organic Waste materials, and to purchase Recycled-Content Paper Products and Recycled-Content Printing and Writing Paper.

SECTION 2. POLICY
Requirements for City Departments or Procurement Practices A. If fitness and quality of Recycled-Content Paper Products and Recycled-Content Printing and Writing Paper are equal to that of non-recycled items, all departments and divisions of the City shall purchase Recycled-Content Paper Products and Recycled-Content Printing and Writing Paper that consists of at least thirty percent (30%), by fiber weight, postconsumer fiber, whenever available at the same or a lesser total costthan non- recycled items, consistent with the requirements of the Public Contracts Code, Sections 22150 through 22154 and Sections 12200 and 12209, as amended.

1. All Paper Products and Printing and Writing Paper shall be eligible to be labeled with an unqualified recyclable label as defined in Title 16 Code of Federal Regulations Section 260.12 (2013).

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2. Provide records to the City of all Paper Products and Printing and Writing Paper purchases on a schedule to be determined by the City and not less than annually (both recycled content and non-recycled content, if any is purchased) made by a division or department or employee of the City.

Requirements for Vendors
A. All vendors that provide Paper Products (including janitorial Paper Products) and Printing and Writing Paper to the City shall:

1. Provide Recycled-Content Paper Products and Recycled-Content Printing and Writing Paper that consists of at least thirty percent (30%), by fiber weight, postconsumer fiber, if fitness and quality are equal to that of non-recycled item, and available at equal or lesser price.

B. All vendors providing printing services to the City via a printing contract or written agreement,shall use Printing and Writing Paper that consists of at least thirty percent (30%), fiber weight, postconsumer fiber, or as amended by Public Contract Code Section 12209.

Compost and SB 1383 Eligible Mulch procurement.

A. Divisions and departments responsible for landscaping maintenance shall:

1. Use SB 1383 Eligible Compost and SB 1383 Eligible Mulch produced from recovered Organic Waste, as defined in the Glossary section of this Policy, for landscaping maintenance as practicable, whenever available, and capable of meeting quality standards and criteria specified.

2. Keep records, including invoices or proof of Recovered Organic Waste Product procurement (either through purchase or acquisition), and submit records to the City, on a schedule to be determined by City.

Recordsshall include:
a. General procurement records, including:
i. General description of how and where the product was used and applied, if applicable.
ii. Source of product, including name, physical location, and contact information for each entity, operation, or facility from whom the Recovered Organic Waste Products were procured.
iii. Type of product.
iv. Quantity of each product; and,
v. Invoice or otherrecord demonstrating purchase or procurement. b. For Compost and SB 1383 Eligible Mulch provided to residents through giveaway events or other types of distribution methods, keep records of

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Compost and SB 1383 Eligible Mulch provided to residents. Records shall be maintained and submitted to the City in accordance with the requirements specified in Section 3.

3. When a Direct Service Provider for the City procures compost or mulch, enter into a written contract or agreement or execute a purchase order between the City and Direct Service Provider with enforceable provisions that include: (i) definitions and specifications for SB 1383 Eligible Mulch, Compost, Renewable Gas, and/or Electricity Procured from Biomass Conversion; and, (ii) an enforcement mechanism (e.g., termination, liquidated damages) in the event the Direct Service Provider is not compliant with the requirements.
a. Renewable Gas procurement (used for fuel for transportation, electricity, or heating applications). For Renewable Gas procurement, City shall:

1. Procure Renewable Gas made from recovered Organic Waste for transportation fuel, electricity, and heating applications to the degree that it is appropriate and available for the City.

2. Keep records in the same manner indicated in Section 3 for Renewable Gas procured and used by the City, including the general procurement of record information specified in Section 3, and submit records to the City on a schedule to be determined by the City and notlessthan annually. City shall additionally obtain the documentation and submit records specified in Section 3 below, if applicable.

SECTION 3. RECORDKEEPING

1. The City will do the following to track Procurement of Recovered Organic Waste Products, Recycled-Content Paper Products, and Recycled-Content Printing and Writing Paper:

1. Collect and collate copies of invoices or receipts (paper or electronic) or other proof of purchase that describe the procurement of Printing and Writing Paper and Paper Products, including the volume and type of all paper purchases; and, copies of certifications and other required verifications from all departments and/or divisions procuring Paper Products and Printing and Writing Paper (whether or not they contain recycled content) and/or from the vendors providing Printing and Writing Paper and Paper Products. These records must be kept as part of the City’s documentation of its compliance with 14 CCR Section 18993.3.

2. Collect and collate copies of invoices or receipts or documentation evidencing procurement from all departments and divisions procuring Recovered Organic

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Waste Products and invoices or similar records from vendors/contractors/others procuring Recovered Organic Waste Products on behalf of the City to develop evidence of the City meeting its Annual Recovered Organic Waste Product Procurement Target. These records must be kept as part of the City’s documentation of its compliance with 14 CCR Section 18993.1.

BIDDING & AUTHORIZATION LIMITS
Competitive bidding promotes fair pricing commensurate with the quality required. The City awards equipment, materials, supplies and maintenance service bids to the lowest priced responsible and suitable bidder. This means that the prevailing bidder is the one who best responds in price, quality, service, fitness or capacity to the requirements of the City. The selection process also considers the ability of the vendor to deliver the needed product, obtain availability of parts or service, prior experience and system compatibility.

Approval Codes: Approval Levels Approving Documents
DH Department Head

REQ, PO, CPO
DE Department Head designee*
FD Finance Department
ACM Assistant City Manager
CM City Manager
CC City Council
* See Signature Authority below
Dollar Limits Bidding Requirements Required Approvals
$10,000 through $50,000 Informal bids DH or DE & FD
Greater than $50,000 and
less than $125,000
Formal sealed bids DH & FD & CM
$125,000 and greater Formal published/ advertised
sealed bids

DH & FD & CM & CC
* Purchases under $10,000 do not require bids although approvals are required from a Department Head and/or Designee for all purchases

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• Purchases of $10,000 through $50,000 require informal bids by the requesting department with quotes obtained from at least two (2) vendors. Telephone quotes are acceptable although written quotations are preferred. Email quotes are allowed. All quotes must be documented and submitted, in comparative format, as part of the approved requisition (REQ) prior to PO, CPO issuance.
• Purchases greater than $50,000 and less than $125,000 require formal bids by the requesting department. This entails the preparation of written specifications, vendor solicitations and sealed bids. The requesting department shall contact as many vendors as necessary and obtain at least two (2) written quotes with three (3) quotes recommended. If the minimum number of quotations cannot be obtained, evidence of the attempt should be documented and kept on file. Professional Services are exceptions.
• Purchases of $125,000 and greater require formal bidding as discussed above but bear the additional requirement of having bid invitations formally published on the City’s electronic bid portal, and regional newspaper before sealed bid opening.

The communication of specifications helps ensure that required, ordered and received items meet the desired level of quality, performance or design. Clarity and completeness in writing specifications avoids a mismatch between vendor compliance and operational needs. It is imperative that staff clearly communicate these requirements in the bid process and inform suppliers, at the time of the bid, exactly what it is that the City needs.

The splitting of purchases to avoid bid and authorization limits is a clear violation of these instructions. Furthermore, purchase cost estimates should always include necessary postmanufacturer add-ons and be included in the Bid specifications.

Bid Cancellations - City Council may cancel an invitation for bids, a request for proposal or other solicitations and may reject some or all bids or proposals when it is determined that cancellation or rejection serves the best interest of the City.

Cooperative Purchasing - Where possible, Cooperative Purchasing may be a benefit to the City. With cooperative purchasing, public entities may mutually make purchases, achieving significant economies of scale. Although public entities together prepare specifications and receive bids, each public entity executes its own contract, administers the procurement function and finances the purchase independently.

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BIDDING EXCEPTIONS
Sole Source Procurements
Sole source procurementsinvolve goods and/orservicesthat can only be practically obtained from one source. Justification will be based on the following:
• The contractor orsupplier is the sole provider of the goods orservice. • The contractor or supplier is the only source permitted to provide the service or supply based on the manufacturer’s agreement acting as the sole representative in the geographical area.

The person requesting the purchase is to prepare written correspondence justifying and describing the reason for the sole source purchase and must have the approval of the department director. This documentation must be submitted to the Finance Director and Risk Manager, along with the Assistant City Manager for review. City Manager approval is required for sole source purchases greater than $50,000, and City Council approval is required for sole source purchases of $125,000 and greater. The requisition shall accompany this documentation when submitted for approval. Because sole source purchases often involve contracts or services with potential risk, the Risk Manager shall remain in the approval chain for all sole source procurements.

Emergency purchases
For the purposes of this section, an emergency shall be deemed to exist if:
• A public disaster occurs; or
• An emergency is declared by the City Council or City Manager • There is an immediate need to prepare for national or local defense; or • There is a breakdown in machinery or an essential service which requires the immediate procurement of supplies and equipment to protect the public health, welfare, or safety; or
• Public health, welfare, or safety would be greatly hampered, if there was an undue delay in the procurement of the needed item
Authority - The City is not required to engage in competitive bidding in an emergency. The City Manager or designee holds the authority to waive any procedures in these instructions that are not statutorily mandated when making emergency purchases of supplies, equipment, materials or services.

If the purchase equals or exceeds $125,000 for construction work, supplies, equipment, materials or services (including professional services), after-the-fact ratification is to be obtained by adoption of City Council Resolution at the soonest possible public meeting

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following the expenditure. For this purpose, the $125,000 threshold is measured against the total emergency purchase or contract amount, including any subsequent amendments or change orders.

If, at the time of the emergency, neither the City Manager nor designee are available, department directors may order the needed commodity from the nearest available source.

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As they become accessible, the City Manager, designee and Finance Director should be immediately notified of the purchase.

Initiating the Purchase - Emergency purchases can be made by designated staff responsible for the emergency response. Staff should attempt to determine the best price and quality of goods or services available and advise their department director at the earliest possible opportunity. The Department Director is to relay such information to the City Manager or designee promptly.

Finance Department Notification – Soon after placing the order, the Finance Department is to be notified of: (1) of the emergency purchase; (2) the nature of the purchase and emergency; (3) the Department Director or authorized designee approval; (4) the name and location of the vendor; and (5) the City Manager approval pursuant to the procedures outlined above. This information is to be provided via the Emergency Purchase Documentation form.

Emergency Credit Card Limits - In times of emergency, the City Manager and Department Directors may request a temporary increase in individual credit card transaction limits from the Finance Department up to a maximum of $100,000. This temporary increase is a processing tool to enable timely emergency payments and does not by itself constitute purchase or approval authority; the applicable approval and after-the-fact ratification requirements set forth in this section continue to apply.

Federal Emergency Management Agency (FEMA) - In all cases, the documentation requirements of both the local and federal FEMA agencies are to be complied with as the City’s emergency response team is activated. The tracking of work/OT hours by location, position(s) and incident, invoices/receipts and photographs will ensure cost recovery when claims are ultimately submitted.

City Council Discretion - In its discretion, the City Council may reject any and all bids only when an emergency requires that an order be placed with the nearest available source of supply, when the amount involved is less than an amount to be set by the City Council by resolution, or when the commodity can be obtained from only one (1) vendor.

BUDGET AUTHORITY LEVELS
Budget Responsibility - The annual budget is an essential element of the financial planning, control, and evaluation process of the City. It is reviewed each fiscal year by the City Council and is designed as a financial blueprintforthe City to follow.

Upon adoption, the various amounts approved in the budget are recorded in the City’s financial system. Monthly reports are provided to departments, programs or project managers in order to track expenditures activities and compliance with budget limits. It is

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the responsibility of each Department to maintain control of their budgets.

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Per Financial Policy, Department Directors have budget control at the total department appropriation level. The City Manager’s budget authority is at the Fund and Capital Improvement Project level. This means no Department Director can transfer to/from or utilize the budget of another department – they cannot cross departmental or capital project lines of appropriation. The City Manager may approve transfers between Departments/Programs and between Capital Improvement Projects, but cannotincrease the total adopted appropriation. Any increase in total appropriation levels, as well as any transfer between funds, must be authorized by the City Council. This authority relationship is as displayed graphically below.

It is critical that all expenditures be coded to the appropriate account classifications during the year without restriction to itemized line-item limits (excluding salary and benefit items and total capital project appropriations). The accurate reporting of expenditure types allows for the refinement of budget variances each year.

SIGNATURE AUTHORITY & APPROVALS
The Finance Department maintains an authorized signatory list, including individual approval dollar limits and areas of responsibility, of employees designated by Department Directors to approve and sign for purchases. Department Directors may delegate signing authority up to a maximum of $25,000 to a Division Manager but must submit such authorization in advance via the signed signatory list previously referenced herein. Overall functional signing limits are established as displayed in the following chart. Purchase requests received by the Finance Department lacking appropriate approval will be returned promptly to the requesting department before any purchase orderisissued and/or payments

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are processed. Any late charges arising from such processing delays will need to be charged against the department budget.

LEVEL OF SIGNING AUTHORITY
Change Orders
The submission of change orders to an existing PO, CPO or PCA can alter the level of approvals required up to, and including, the need for City Council action. The determination of authorization levels should include the total of the purchases including the accumulated value of related change orders.

Information Technology Purchases
All Information Technology (IT) purchases must be approved in advance by the IT Manager or designee to ensure compliance with City hardware and system standards. Similarly, IT is required to be consulted for any planned purchases of software and hardware arising during the budget process and in the development of system specifications. IT cannot make purchases on behalf of the operating department without documentation pre-authorized by the department director. This approval will be documented via the completion of the IT WorkOrder form.

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Shared Cost Purchases & Payroll Payments
Some shared costs, such as utilities (phone, water, gas, electric, insurance, Software annual maintenance or subscription payments, etc.), fuel, facilities and payroll/benefits deductions (taxes, health benefits, PERS, etc.), require broadly defined processing methods as they are operational in nature and addressed in the budget on a bulk basis. Such payments are held to categorical budget appropriation limits, are centrally processed by the Finance Department, fall outside individual authorizing dollar limits, and are handled in bulk form in the monthly accounting process. These items are reviewed by the Finance Department for completeness, budget compliance and accuracy as they are processed. The basis for these shared cost allocations should be developed by the Finance Director in coordination with the impacted departments and discussed in the annual and mid-year budget process.

Warehouse Orders, Shared Building Supplies & Fuel
Limited items are available for order through the Maintenance Services warehouse. These mostly include janitorial supplies, fuel, office paper, kitchen supplies and can simply be requested via email or phone. They will be charged to the ordering department at the monthend based upon inventory pricing. Supplies delivered to shared cost sites, such as City Hall, will be allocated among benefitting programs on a reasonable basis. Maintenance services shall document these purchases monthly as a basis for financial reporting.

Equipment PurchasesIdentified in the Budget Process
All new and replacement requests for equipment or vehicles are itemized and submitted to the Finance Department as part of the annual budget process or at the time of mid-year budget review. At budget adoption, these specifically identified items will be considered approved. In procuring these items, departments are to strictly follow the bid and approval procedures set forth herein but may finalize such purchases without returning to City Council. However, City Council approval must be obtained if additional appropriations are required above the original adopted budget or if the nature of the purchase is substantially altered.

Fixed Asset Identification & Tracking
Any tangible item with a useful life of at least one (1) year and a purchase cost, including sales tax and incidentals, of $10,000 or more is considered a fixed asset. These items are to be identified by a unique identifying number (ID) and tracked during their lifecycle. Items that do not fit within the dollar threshold for a fixed asset, but are considered valuable, such as cellular phones, cameras or computers should also be identified by a City ID. Departments are responsible for ensuring that unique identifying numbers (serial numbers/VIN #s) are evident in the supporting documentation provided to the Finance Department and for

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safeguarding City assets, regardless of the value. Departments should expect to account for the asset’s condition and location as part of a year-end inventory.

Physical movement of any fixed asset, even within a department, must be approved by Department Directors or designees and coordinated with the Finance Department to ensure that inventories are updated with the proper location. The physical disposal of any fixed asset must be approved by Department Directors and designees and coordinated with the Finance Department and Facilities Division to ensure that inventory listings are updated.

Periodically, the Finance Department or independent auditors may conduct periodic spot audits to verify asset inventory records and expenditures. Departments should be prepared to support these reviews as needed.

Professional Services
Professional services include those provided by industry specialists such as lawyers, accountants, actuaries, technology specialists, planning, building, and financial consultants. These services, beyond the realm of public works contracts, are exempt from bidding requirements as their selection is based on expertise, experience and proficiency rather than price. As a matter of practice, the City highly encourages competitive bidding for all service contracts and formal RFPs for contracts with values greater than $25,000. A formal RFP is required for contracts of $50,000 and greater; for contracts of $25,000 to less than $50,000, competitive proposals are encouraged but not required.

Agreements with vendors for services can be for a three (3) year period with up to a two (2) year extension of the agreement to a total of no more than five (5) years. At the conclusion of the five (5) years, it is recommended that the agreement be re-bid to test the price of like services in the marketplace and to provide other vendors with an opportunity to present a bid for services. Agreements posted on the Template drive contain the language needed to state the “term” (length of time) of the agreement. For existing agreements that are ongoing until terminated, consult with the Risk Manager to ensure agreements are revised to include a five (5) year term or proper amendment language.

Managers are to review with the Risk Manager each ongoing software or licensing agreement that exceeds the five (5) year term. These agreements are evaluated on a case-by-case basis for the length of term of the agreement and amendment language.

All contracts entered into by the City require approvals based on the applicable dollar thresholds. This typically includes the Department Director, Finance Director, and Risk Manager. Review by the City Attorney shall be obtained if required, depending on the nature and risk level of the contract. Contracts over the annual dollar limit listed below require City Council approval prior to the award. City Council approval is required only for contracts of

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$125,000 and greater; contracts below $125,000 may be approved administratively within the signing authority limits established in this Policy. This $125,000 threshold applies consistently throughout this Policy and is distinct from the City Manager’s individual signing authority below $125,000. RFPs are encouraged as a best practice to ensure competitive selection and transparency.

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Value of Non-Legal
Professional Services
Recommended Number of
Proposals
Required Approvals
$10,000 to less than $25,000 The department must conduct an evaluation of options but
does not have to obtain written
proposals.

Department Director, Finance
Director
$25,000 to less than $50,000 Formal RFP and two (2) written proposals recommended
Department Director, Finance
Director
$50,000 to less than
$125,000
Formal RFP required; two (2)
written proposals
recommended
Department Director, Finance
Director, Risk Manager, City
Manager, and City Attorney if
legal review is required
$125,000 and greater Formal RFP required; two (2)
written proposals
recommended
Department Director, Finance
Director, Risk Manager, City
Manager, City Council, and
City Attorney if legal review is
required
Value of Legal Services Recommended Number of
Proposals
Required Approvals
Up to Annual Budgeted
Appropriation for Legal Fees
City Attorney to evaluate
needs based on expertise
City Attorney, Finance
Director, City Manager
Above Fund Level Budgeted
Appropriation
City Attorney to evaluate
needs based on expertise
City Council
* Services under $10,000 do not require bids although approvals are required from a Department Director and/or designee for all purchases.

Legal Fees
Under the Los Altos Municipal Code, the City Attorney may retain or employ other attorneys, assistants, orspecial counsel as needed to take charge of, or assist with, any litigation or legal matters.

The City Attorney estimates these costs at the preparation of the budget on a gross basis.

Such payments are held to categorical budget appropriation limits, and are centrally processed by the Finance Department, and therefore fall outside individual authorizing

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dollar limits, and are approved by the City Manager. These items are reviewed by the Finance Directorfor completeness, budget compliance and accuracy asthey are processed.

Changes in the scope of existing contracts may trigger a higher level of required approvals.

Professional Services must be initiated and approved via the use of a CPO. Professional Services shall be entered into contractually using a City-compliant executed contract and require the approval of the Risk Manager.

Professional Service Travel Costs - Professional service firms often bill clients for their direct and indirect costs, such as travel, photocopying, proposal preparation, etc. It is advisable that potential providers are informed of, and make documentation available in support of, the City operating travel policies including the following:
• Airfare: The City will not reimburse first class, business class, boarding preferences or other premium types of transportation.
• Hotel: The City will reimburse reasonable hotel accommodation (i.e., single or double rooms, but no suites) and encourage obtaining a government rate in a local venue. • Meals: Reimbursement for meals is limited to the current IRS per diem rate for the destination city.
• Car Rental: Rental vehicles shall be mid-sized class or smaller with rates commensurate with those offered by major rental companies. Use of luxury cars, specialty vehicles, or other non-standard cars will not be reimbursed. Insurance will be provided under the driver's or company's own policy. Additional insurance coverage offered by the car rental company is not reimbursable by the City. • Entertainment/Personal Services: Under no circumstances are expenses related to entertainment (i.e., theater tickets, sporting events) or personal services (i.e., dry cleaning, haircuts) reimbursable.
• Deliveries/Transmittals: Deliveries for which the City is billed will be transmitted in the most economical manner reasonably, unless otherwise required by the City. • Proposal Costs: The City will not reimburse the vendor for any costs associated with the preparation of a proposal.

ADDITIONAL GUIDANCE

FISCAL YEAR-END CUT OFF
The City’s fiscal year runs from July 1 to June 30. To allow for adequate processing time certain types of purchases must be completed well before the end of the fiscal year. While exact calendar dates may vary, the cutoff for submitting purchasing paperwork is generally as follows:

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• Requisitions & Purchase Orders: 2nd week of June
• Blanket Purchase Orders: Orders to be placed by June 30

SUPPLIER CONTACT AND DECORUM
Staff are obliged to always act in a professional and ethical manner when in contact with suppliers who market their services to the City. To this end, we strive to:
• Give allsuppliers full, fair, prompt and courteous consideration • Maintain a level playing field and information transparency • Protect vendor confidentiality when dealing with market-sensitive data • Solicit suggestions in determining clear and adequate specifications and standards • Effectively coordinate with suppliers in an equitable and uniform manner • Observe truthfulness and highest ethics in all transactions and correspondence It isimportant to treat all vendors equally. Thisincludes providing all competing vendors with the same information needed to respond to a request. It is unfair and unethical to divulge one vendor’s bid price, terms or conditions to another during the competitive bidding stages and important to realize that this information is not publicly accessible until all bids have been received and evaluated. Information marked “Proprietary” or “Confidential” by the vendor is not considered public and must not be revealed to outside parties. The appearance of impropriety isjust as important as actual impropriety. Displays of favoritism to a particular vendor should be always avoided.

Gratuities- To maintain strict objectivity and the highest ethical standards, the City prohibits employees accepting vendor gifts or gratuities. Violation of this standard may result in employee disciplinary action up to, and including, termination.

Insurance - It is the City’s practice to transfer as much risk as possible from the City to the supplier or contractor. Therefore, insurance is required from any contractor performing work for the City. This is especially the case for services provided on City property. In these cases, the standards and insurance requirements set forth by the Risk Manager must be adhered to. The City’s minimum insurance standards to be complied with are included in this document.

Taxes - The City pays sales or use tax on most purchases as defined by Santa Clara County.

This amount is added to the taxable subtotal of your order (certain items such as labor or transportation may or may not be taxable). Use tax, which is equivalent to the sales tax rate, is collected on many out-of-state purchases where the state originating the sale does not collect California State sales tax on behalf of the State. It is important to identify the

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applicability of Use Tax in bidding to avoid unintentional budget overrun. The City is exempt from paying Federal Excise Tax.

Shipping and Installation Costs - In developing, accepting and evaluating goods and material bids, it is incumbent on City staff to ensure that costs include any related shipping and/or installation costs and request such information from the subject vendors. In all cases, developing the full costs of purchase is critical to the budget process.

Payments Terms & Frequency - While the City’s standard payment terms are Net 30 days from the invoice date, actual processing follows a weekly payment cycle. Vendor agreements should be established using this standard and clearly communicated to them. A vendor’s inability to adapt to the City’s payment terms may make them ineligible for use. Generally, the City will not pay late fees.

Conflict of Interest/Third Party Transactions - To maintain public trust and confidence in the integrity of purchasing transactions, no City employee who has a real or apparent conflict of interest should participate in the transaction.

Establishing New Vendors - One element of fiduciary responsibility is maintaining strict control over the open accounts established under the City’s name. Therefore, the City has instituted a practice whereby Finance has control over creation of all new vendor accounts and the submission and completion of credit applications for open accounts. W-9s are required for all new vendors without exception.

Grant Funding - Federal or other grant programs may require special conditions which are more stringent than City procedures. It is the responsibility of the department to accept the grant on behalf of the City to ensure that all grant provisions are complied with. All grants shall be awarded with City Council approval.

Surplus Property Management - the Facilities Division is responsible for the disposal of all City surplus property via auction. Information Technology should be contacted to disconnect or dispose of computers and related hardware.

The City maintains a small inventory of serviceable surplus property items that may be acceptable for use upon request by a department. City staff or family members are not eligible to purchase City surplus property. Staff may, however, attend any third-party public auction and bid as a member of the public.

Public Safety handles property room disposals directly through a safety-specific auction process and coordinates revenue collections associated with the Finance Department.

Independent Contractors - The Internal Revenue Service (IRS) and the California Employment Development Department (EDD) require independent contractors to provide a

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W-9 form to the City including the businesstype (sole proprietor, corporation or partnership)

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and documenting a taxpayer identification number (Social Security or federal identification number). Finance must receive the W-9 when a requisition or invoice is processed for a new vendor. Failure to provide this form will result in non-payment of an invoice or delaying processing of a requisition.

Other Jurisdiction BPO or Purchase Contract Agreements (PCA) - Staff may use BPOs or PCAs issued by other jurisdictions entered competitively if it is shown that the selection criteria are essentially the same as would be used by the City. Examples include Santa Clara County BPA for furnishings or awarded unit price schedules for slurry seal or sidewalk repairs.

Prohibited Practices
No City employee shall use or misrepresent the City’s purchasing process to obtain property or services for personal use, benefit or personal price discounts. Volume or incentive discounts made available in making City purchases can only be applied to the City’s benefit and never personal gain.

No City employee shall draft or cause to be drafted any specifications for bids in such a way asto intentionally limit the bidding directly or indirectly to any one bidder except for the sole source procurements.

PUBLIC WORKS PROJECTS
Public Projects are defined by the State of California Public Contract Code, Section 20161 as a project for the erection, improvement, painting, or repair of public buildings and works; work in or about streams, bays, waterfronts embankments, or other work for the protection against overflow;street orsewer work except maintenance or repair; supplies and materials for any such project, including maintenance or repair of streets or sewers. These purchases are controlled directly by the related Public Contract Code sections and fall outside the operational purchasing cycle addressed in this policy.

Pursuant to Chapter 3.16 of the Los Altos Municipal Code, the City of Los Altos has adopted Bidding Procedures Under the Uniform Public Construction Cost Accounting Act.

Requirements and allowances associated with this can be found in the Municipal Code.

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GLOSSARY
Bid: A proposal to provide goods and services submitted in accordance with the request for bid documents.

Bidder: A person or entity who submits a bid.

Blanket Purchase Order (BPO): A method by which departments may purchase materials from a specific vendor continuously throughout a specified time. Orders for materials not available from BPO vendors can be purchased by petty cash, credit card, purchase contract, or through the purchase requisition/purchase order process as described within this document.

Change Order: An amendment to an original purchase order authorizing a change in the scope of work; adjustment in the contract sum or contract time; or cancellation of parts or all of a purchase order.

Check Request: The form is used to request that Finance process payment to a vendor or contractor. The form accommodates several uses, including Direct Payments, Blanket Purchase Order payments as well as partial payments against existing purchase orders and contracts.

City: The City of Los Altos, the City Manager, or their designee.

Compost (SB 1383 Eligible): The product resulting from the controlled biological decomposition of organic solid wastes that are source separated from the municipal solid waste stream, or which are separated at a centralized facility or as otherwise defined in 14 CCR Section 17896.2(a)(4).

Contract: An agreement between two or more parties to do something which is set forth in writing and is enforceable by law.

Contract Purchase Order (CPO): The document used by departments to document the request professional services and supported by a formal executed city compliant contract approved by the Risk Manager. A CPO, on its own, does not support authorization to purchase. A CPO shall always be accompanied by an executed formal contract and must follow the approval thresholds established in this Policy.

Cooperative Purchasing Agreement (CPA): The purchase of goods, materials, or services which is entered into by one or more local government entities. The expected impact is to increase volume and/or competition which will result in greater savings.

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Purchase Contract Agreement (PCA): A purchase agreement is a legally binding contract between a buyer and seller. These agreements usually relate to the buying and selling of goods instead of services, and they can cover transactions for just about any type of product.

Direct Service Provider: A person, company, agency, district, or other entity that provides a service or services to the City pursuant to a contract or other written agreement or as otherwise defined in 14 CCR Section 18982(a)(17).

Electricity Procured from Biomass Conversion: Electricity generated from biomass facilities that convert recovered Organic Waste, such as wood from the municipal stream, into electricity.

Informal Bid: A proposal to provide materials, supplies, or maintenance services valued at $10,000 through $50,000. Informal bids typically require at least two (2) written quotes, though verbal quotes may be acceptable if documented. Used for non-complex purchases where sealed bidding is not warranted.

Formal Bid: A proposal for goods, services, or projects valued greater than $50,000. For purchases greater than $50,000 and less than $125,000, formal sealed bids must be solicited from vendors, with written proposals recommended. For purchases of $125,000 and greater, formal bids must follow the published/advertised sealed bid process, including public notice and competitive solicitation.

Organic Waste: Solid waste containing material originated from living organisms and their metabolic waste productsincluding, but not limited to, food, yard trimmings, organic textiles and carpets, lumber, wood, Paper Products, Printing and Writing Paper, manure, biosolids, digestate, and sludges, or as otherwise defined in 14 CCR Section 18982(a)(46). Biosolids and digestate are defined in 14 CCR Section 18982(a)(4) and 14 CCR Section 18982(a)(16.5), respectively.

Packing List: A list of supplies requested which includes stock number, item description, quantity requested, and number of items delivered.

Paper Products: Includes, but is not limited to, paper janitorial supplies, cartons, wrapping, packaging, file folders, hanging files, corrugated boxes, tissue, and toweling; or as otherwise defined in 14 CCR Section 18982(a)(51).

Petty Cash: Small dollar reimbursements ($100 or less) made from cash boxes held within departments.

Printing and Writing Papers: Includes, but is not limited to, copy, xerographic, watermark, cotton fiber, offset, forms, computer printout paper, white wove envelopes, manila envelopes, book paper, note pads, writing tablets, newsprint, and other uncoated writing

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papers, posters, index cards, calendars, brochures, reports, magazines, and publications; or as otherwise defined in 14 CCR Section 18982(a)(54).

Professional Service: A specialized type of service typically provided by those requiring extensive education, certification, and experience standards. Examples of professional services contracts include, but are not limited to, those of accountants, actuaries, appraisers, architects, attorneys, brokerage firms, business consultants, business development managers, copywriters, dentists, distributors, engineers, law firms, physicians, public relations professionals, recruiters, researchers, real estate brokers, translators, software engineers, value-added resellers and web designers. While not limited to those holding professional licenses, the services are considered "professional”, and the contract may run to partnerships, firms, or corporations as well as to individuals.

Purchase Contracts: Contracts for routine and repetitive maintenance services typically for the maintenance of landscaping, office machines, office supplies, janitorial services, building maintenance, and street sweeping.

Purchase Order (PO): The document that obligates the purchase of goods or maintenance services that are not available from a BPO; an existing purchase contract; and is above the limit for procurement as a direct vendor payment.

Purchase Requisition: The document used by departments to request goods or maintenance services that are: not available through a BPO; not available on an existing purchase contract; and is above the limit for procurement as direct vendor payment.

Quality: The extent to which the actual minimum needs of the end users are satisfied.

Recovered Organic Waste Products: Products made from California, landfill-diverted recovered Organic Waste, processed at a permitted or otherwise authorized operation or facility, or as otherwise defined in 14 CCR Section 18982(a)(60). Products that can be used to meet the Annual Recovered Organic Waste Product Procurement Target shall include Compost, SB 1383 Eligible Mulch, Renewable Gas from an in-vessel digestion facility, and Electricity Procured from Biomass Conversion as described herein and provided that such products meet requirements of 14 CCR, Division 7, Chapter 12, Article 12.

Recyclability: The Paper Products and Printing and Writing Paper offered or sold to the City are eligible to be labeled with an unqualified recyclable label as defined in 16 Code of Federal Regulations Section 260.12 (2013).

Recycled-Content Paper Products and Recycled-Content Printing and Writing Paper:

Products that consist of at least thirty percent (30%), by fiber weight, postconsumer fiber,

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consistent with the requirements of Sections 22150 to 22154 and Sections 12200 and 12209 of the Public Contract Code, and as amended.

Renewable Gas: Gas derived from Organic Waste that has been diverted from a landfill and processed at an in-vessel digestion facility that is permitted or otherwise authorized by 14 CCR to recover Organic Waste, or as otherwise defined in 14 CCR Section 18982(a)(62).

Request for Proposal (RFP): Used to request information and pricing from contractors or suppliers. Typically, RFPs are utilized for non-commodity type items where the expertise of the contractor is vital criteria in the selection process. While price/cost is an important component of the selection process, it is not the only factor in the selection process.

SB 1383: Senate Bill 1383 of 2016 approved by the Governor on September 19, 2016, which added Sections 39730.5, 39730.6, 39730.7, and 39730.8 to the Health and Safety Code, and added Chapter 13.1 (commencing with Section 42652) to Part 3 of Division 30 of the Public Resources Code, establishing methane emissions reduction targets in a statewide effort to reduce emissions of short-lived climate pollutants, as amended, supplemented, superseded, and replaced from time to time.

SB 1383 Regulations or SB 1383 Regulatory: Refers to, for the purposes of this policy, the Short- Lived Climate Pollutants (SLCP): Organic Waste Reductions regulations developed by CalRecycle and adopted in 2020 that created Chapter 12 of 14 CCR, Division 7 and amended portions of regulations of 14 CCR and 27 CCR.

SB 1383 Eligible Mulch: Mulch eligible to meet the Annual Recovered Organic Waste Product Procurement Target, pursuant to 14 CCR Chapter 12 of Division 7. This SB 1383 Eligible Mulch shall meet the following conditions for the duration of the applicable procurement compliance year, as specified by 14 CCR Section 18993.1(f)(4):

1. Produced at one of the following facilities:
i. A compostable material handling operation or facility as defined in 14 CCR Section 17852(a)(12), that is permitted or authorized under 14 CCR Division 7, other than a chipping and grinding operation or facility as defined in 14 CCR Section 17852(a)(10);
ii. A transfer/processing facility or transfer/processing operation as defined in 14 CCR Sections 17402(a)(30) and (31), respectively, that is permitted or authorized under 14 CCR Division 7; or,
iii. A solid waste landfill as defined in Public Resources Code Section 40195.1 that is permitted under 27 CCR Division 2.

Service Contract: A service contract means a contract that directly engages the time and effort of a contractor whose primary purpose isto perform an identifiable task ratherthan to

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furnish an end item of supply. A service contract may cover services performed by either professional or non-professional personnel whether on an individual or organizational basis.

Sole Source Purchase: One where there is only a single vendor capable of providing an item or service, and therefore it is not possible to obtain competitive bids.

Specifications: A complete and accurate statement or set of statements covering the physical, functional, or technical characteristics of goods or services needed, description of any requirements for inspecting or testing and performance standards for items sought. It may also include provisions which govern various aspects of parties to the contract and any special conditions or pre-conditions that exist relative to any goods or services being solicited.

State: The State of California.

Maintenance Services: Services typically dealing with operational maintenance, supplies, and equipmentsupport, rather than specialized professionalservices described above.

Vendor: A person or company who provides goods orservices. A vendor can also be referred to as a supplier or direct service provider.

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EXHIBIT A

PURCHASING BID AND AUTHORIZATION CHART

MATERIALS - GOODS - MAINTENANCE SERVICES

ORDER TYPE COST POINT FEATURES
Materials, Goods,
Maintenance Service
Less Than $10,000
(No Bids Required)
Prudent judgment should be used
along with obtaining comparative
pricing whenever practical. Orders
require department director or
designee approval.

These include supplies,
equipment, operating or
maintenance services and
projects.

Excludes “Public Works
Projects” and "Professional
Services"
$10,000 through $50,000
(Informal Bid)
At least two (2) quotes are required
but three (3) are recommended.

Written bids/quotes are preferred
but may be verbal with
documentation. Required
Approvals: Department Head or
Designee & Finance Director (DH or
DE & FD). Risk Manager approval
and CPO required for contracts. City
Attorney review is required only if
needed based on the nature of the
contract.

Greater than $50,000
and less than $125,000
(Formal Sealed Bid)
Formal sealed bids required. Public
advertisement required only for
purchases of $125,000 and greater.

Required Approvals: Department
Head, Finance Director, and City
Manager (DH, FD, CM). Risk
Manager approval and CPO
required for contracts. City Attorney
review is required only if needed
based on the nature of the contract.
$125,000 and greater
(Formal
Published/Advertised
Sealed Bid)
Formal bids must be publicly
advertised on the City’s electronic
bid portal and regional newspaper
prior to sealed bid opening.

Required Approvals: Department
Head, Finance Director, City
Manager, and City Council (DH, FD,
CM, CC). Risk Manager approval
required for contracts; City Attorney
review only if required based on the
nature of the contract.

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Materials, Goods and Maintenance Service contract costs of any dollar value must adhere to pre-defined signature
approval limits. All Information Technology (IT) purchases require the approval of the IT Manager for network
compliance. Any IT Purchase for a service department
must be authorized via an IT Work Order authorized by a department head or designee.

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EXHIBIT B

PURCHASING BID AND AUTHORIZATION CHART

PROFESSIONAL SERVICES

ORDER TYPE COST POINT FEATURES
Professional Services $0 to $25,000
(RFP Highly Recommended)
Prudent judgment should be
exercised and obtaining
comparative pricing if
practical. Orders require
department head or designee
approval. Price proposals are
not required but three are
recommended and must
include a Department Head
and Finance Director
approved CPO and service
contract, with Risk Manager
approval and City Attorney
review only if required based
on the nature of the contract.

These services include
those of a highly technical
nature requiring extended
training and certification.

Include legal, accountancy,
technology and specialty
consulting services.

These are general
guidelines. The evaluation
and selection of consultant
services may vary on a
case-by- case basis.

Greater than
$25,000
A formal RFP is required for
contracts of $50,000 and
greater; competitive
proposals are encouraged for
contracts of $25,000 to less
than $50,000. Three (3)
competitive proposals are
encouraged and the package
must include a Department
Head, Finance Director, Risk
Manager, and City Managerapproved CPO and service
contract. City Council
approval is required for
contracts of $125,000 and
greater. City Attorney review
only if required based on the
nature of the contract; See
the Non-Legal Professional
Services table in the
Professional Services section
of this Policy for the full fourtier approval breakdown.

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EXHIBIT C
EMERGENCY PURCHASE FORM – EXAMPLE
EmergencyDate
Cost
Department/Division
Vendor
Address
Telephone
Emergency Description
Describe Emergency:

Because emergency purchases do not normally provide the City an opportunity to obtain competitive quotes, these purchases shall be limited to those necessary to address an immediate operational, health, safety, or infrastructure need. The following procedures shall apply:
• Complete a requisition and obtain a purchase order within three days of the emergency.
• Notify City Manager and Finance of emergency costs greater than $5,000. • Notify City Council at the next regularly scheduled meeting of emergency costs greater than $125,000.
• If Emergency purchases cause line-item budget shortfalls, the department responsible shall obtain City Council approval for additional appropriation; or request that the City Manager transfer appropriations from other programs, within the same Fund, to cover the purchase.

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EXHIBIT D

MINIMUM INSURANCE REQUIREMENTS
Minimum Scope of Insurance as related to the provision ofservice to the City CONSULTANT shall provide his insurance broker(s)/agent(s) with a copy of these requirements and request that they provide Certificates of Insurance complete with copies of all required endorsements to: Project Manager, City of Los Altos, 1 N. San Antonio Rd., Los Altos, CA 94022
Minimum Scope of Insurance Coverage shall be at least as broad as:

1. Commercial General Liability (CGL): Insurance Services Office Form CG 0001 covering CGL on an “occurrence” basis, including products-completed operations, personal & advertising injury, with limits no less than $1,000,000 (or $2,000,000) per occurrence.

If a general aggregate limit applies, either the general aggregate limit shall apply separately to this project/location or the general aggregate limit shall be twice the required occurrence limit.

2. Automobile Liability: Insurance Services Office Form Number CA 0001 covering, Code 1 (any auto), or if Consultant has no owned autos, Code 8 (hired) and 9 (non- owned), with limit no lessthan $1,000,000 per accident for bodily injury and property damage.

3. Workers’ Compensation insurance as required by the State of California, with Statutory Limits, and Employer’s Liability Insurance with limit of no less than $1,000,000 per accident for bodily injury or disease.

4. Professional Liability (Errors and Omissions) Insurance appropriate to the Consultant’s profession, with limits of no less than $1,000,000 per occurrence or claim, $2,000,000 aggregate.

Other Insurance Provisions. The insurance policies are to contain, or be endorsed to contain, the following provisions:
• Additional Insured Status. The City, its officers, officials, employees, and volunteers are to be covered as additional insureds on the CGL policy, with endorsements under CG 20 26, with respect to liability arising out of work or operations performed by or on behalf of the Consultant including materials, parts or equipment furnished in connection with such work or operations.
• Primary Coverage. For any claims related to this contract, the Consultant’s insurance coverage shall be primary insurance as respects the City, its officers, officials, employees, and volunteers. Any insurance or self-insurance maintained by the City,

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its officers, officials, employees, or volunteers shall be an excess of the Consultant’s insurance and shall not contribute to it.
• Notice of Cancellation. Each insurance policy required above shall be endorsed to state that coverage shall not be canceled except after thirty (30) days’ prior written notice (10 daysfor non-payment) has been given to the City.
• Waiver of Subrogation. Consultant hereby grants to City a waiver of any subrogation which any insurer of said Consultant may acquire against the City by virtue of payment of any loss under such insurance. The consultant agrees to obtain any endorsement that may be necessary to effect this waiver of subrogation, but this provision applies regardless of whether the City has received a waiver of subrogation endorsement from the insurer.
• Deductibles and Self-Insured Retentions. Any deductibles or self-insured retentions must be declared to and approved by the City. The City may require the Consultant to provide proof of the ability to pay losses and related investigations, claim administration, and defense expenses within the retention. • Acceptability of Insurers. Insurance is to be placed with insurers with a current A.M.

Best’s rating of no less than A:VII, unless otherwise acceptable to the City.

Claims Made Policies. If any of the required policies provide claims-made coverage:

5. The Retroactive Date must be shown and must be before the date of the contract or the beginning of contract work.

6. Insurance must be maintained, and evidence of insurance must be provided for at least three (3) (or five (5)) years after completion of the contract work.

7. If coverage is canceled or non-renewed and not replaced with another claims-made policy form with a Retroactive Date prior to the contract effective date, the Consultant must purchase “extended reporting” coverage for a minimum of three (3) years after completion of contract work.

Verification of Coverage. Consultant shall furnish the City with original certificates and amendatory endorsements affecting coverage required by this clause. All certificates and endorsements are to be received and approved by the City before work commences.

However, failure to obtain the required documents prior to the work beginning shall not waive the Consultant’s obligation to provide them. The City reserves the right to require complete, certified copies of all required insurance policies, including endorsements required by these specifications, at any time.

Special Risks or Circumstances. City reserves the right to modify these requirements, including limits, based on the nature of the risk, prior experience, insurer, coverage, or other special circumstances.

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PLEASE NOTE: See the City Template General Service and Contract Agreements posted in the Templates Folder online. Check for periodic updates and other provision requirements.

Assistance is available from the Risk Manager.

Requesting departments are responsible for verifying insurance coverage requirements with Risk Management as these parameters may be modified periodically. It is equally important to reference the TEMPLATE General Service and Contract Agreements posted on the Templates folder online and supplied by Risk management while preparing RFPs and finalizing agreements. Departments must attain insurance documents from the vendor prior to execution of the agreements/contracts.

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EXHIBIT E

PURCHASE CARD POLICY OVERVIEW
The City has implemented Purchase Cards (CalCard) based on the State-wide “CalCard” program. The program is designed to establish a more efficient and cost-effective method of purchasing and paying for small dollar City purchases. This program should minimize the need for voluminous blanket/open purchase orders and petty cash requests.

This document puts forth the practices and procedures required of those using Calcard and those who manage their use. The topics addressed in this policy follow:
• Responsibility
• Requesting CalCard
• Calcard Basics
• Spending Limit
• Prohibited Purchases
• Purchase Documentation
• Revocation of Privileges
• Emergency Purchases
• Reconciling Statements
• Disputed Charges
• Returning Items
• Lost or Stolen CalCard
• Declined Purchase
• Review & Audits
• Invoices & Receipts
• Purchase Card Employee Agreement

RESPONSIBILITY

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Department Heads: Responsible for authorizing individuals within the Department to receive CalCard and designated approvers. Department heads must approve individual requests for CalCard and make any changes to them. Department heads are ultimately responsible for ensuring the cards’ proper use in conformance with City practices and procedures.

Designated approvers: Designated approvers are selected and authorized by Department heads, responsible for reviewing monthly statements and submitting them to Finance in complete form. These approvers are responsible for ensuring that cardholders track and report any disputed/unauthorized charges to "Calcard" and to Finance. Individual Department Head Calcard statements and transaction logs will be reviewed by the Finance Director and City Manager.
• Read and be fully aware of the requirements of this document and the City’s Purchasing Policy
• Read and execute an approved Purchase Card Employee Agreement. • Maintain secure possession of the CalCard and keep the account number confidential.
• Ensure that all purchases strictly comply with City instructions. • Obtain the best possible value for the City with CalCard purchases. • Never give a CalCard to anyone for use.
• Always retain and maintain original records of receipts. • Promptly reconcile monthly statements and provide a complete Purchase Card Log including supervisor/department head review and approval. This documentation must be submitted to Finance, along with all supporting original invoices/receipts and packing slips (if shipped), within ten business days after the statement is received. • Purchases made on behalf of another department, although uncommon, must be authorized by an authorized signer from the department being charged prior to submission to Finance.
• Promptly resolve disputed items since only authorized charges will be paid. Disputed items may be suspended pending resolution by the department responsible. Failure to pay charges on a timely basis will result in card suspension. Any late fees that result from such delays will be charged to the department budget. • Immediately call “CalCard” if a card is lost or stolen and notify Department supervisors and Finance.
• Resolve all incorrect charges and product returns as quickly as possible. • Return the CalCard to Finance upon the request of a supervisor, suspension of

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privileges, or termination of employment.

Finance: Responsible for administering the program, activating and terminating CalCard, and maintaining a record of individuals authorized to conduct purchase card transactions.

Finance is also responsible for processing monthly payments.

REQUESTING CALCARD
To apply for a CalCard, the Department head should send an email request to Finance and ultimately submit an approved Purchase Card Employee Agreement (Exhibit F) specifying an individual purchase limit as well as a total monthly limit. Total monthly limit shall not exceed $10,000.

CALCARD BASICS
CalCard are to be used exclusively for City business. They are Visa credit cards that work just like a personal credit card except that monthly charges are paid directly by the City.

Calcard purchases are held to individual transactional limits set by Department heads and to the small dollar purchase limit established by City purchasing policy. Department heads also set a total monthly dollar limit for each individual cardholder. Each time the card is used, an electronic process verifies that the purchase is within these limits. If the purchase violates these limits, the supplier will not accept the order.

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CalCard will be issued in an employee’s name, bear a “City of Los Altos” imprint and display a unique color scheme to distinguish them from personal credit cards. Cardholders are directly responsible for the proper use of their cards and department heads for the management and review of those they have authorized.

Monthly statements will be sent to cardholders for verification of charges against invoices/receipts, coding of appropriate budget accounts, and approval by an immediate supervisor and department head or designee. Finance will receive a full set of statements.

Monthly statements for cards held by Department heads are to be reviewed and approved by the City Manager and/or their designee.

The effectiveness of the Calcard program is dependent on the timely review, processing and submission of approved monthly transactions. Providing timely, accurate and complete purchase documentation is critical. Use of such cards is a privilege that provides a valuable alternative purchasing mechanism and requires strict adherence to established practices.

Non-compliance with the City Purchasing Policy will result in card revocation and/or disciplinary action.

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SPENDING LIMITS
CalCard purchases shall be subject to individual transaction limits approved by Department Heads and must comply with the City’s small-dollar purchasing threshold of less than $10,000. In addition, Department Heads shall establish a total monthly limit for each cardholder.
30-Day Monthly Transaction Limit
• Cardholder spending limits may be modified only on an as-needed basis and must receive prior approval from the Department Heads or their designee. • To request a change in a cardholder’s spending limit, the cardholder must submit a properly approved Purchase Card Employee Agreement to [email protected], along with a memorandum providing a brief justification for the requested change and specifying the proposed new limit.

PROHIBITED PURCHASES
Purchases made shall be strictly for City of Los Altos business. CalCard cannot be used for:
• Personal use and entertainment
• Cash advances or refunds
• Per diem and mileage advances
• Any transaction exceeding the Department Head’s established limit or the approved purchasing card limits—the level at which a purchase requisition and purchase order are required
• Professional services, except for industry-wide training services (such as seminars). • Purchases prohibited by the City’s Purchasing Policy
• Unauthorized travel-related expenses
• Fines
• Splitting purchases to circumvent the dollar limit

PURCHASE DOCUMENTATION
• Always get an original invoice/receipt from the supplier. • If paying for a conference orseminar, the original registration form and/or certification of completion must be provided.
• For non-conference business meals, the itemized restaurant receipt indicates purchased items should be provided.
• For subscriptions, keep a copy of the renewal notice or initial subscription request. • In the case of internet purchases, provide a copy of the E-commerce receipt.

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• In all cases, items being shipped or picked up at point-of-sale must be supported by a delivery packing slip with approval from Department Head.

If placing an order by phone, mail, or fax, or on the internet:
• Instruct the supplier to include your name, department, and address on the shipping label
• Instruct the supplier to include a receipt and delivery packing slip (charge slip, invoice, or cash register receipt) with the package.
• Verify the order is correct upon delivery, sign the packing slip and have another member of the receiving Department inspect and sign the packing slip as well. • Retain the original invoice/receipt/packing slipsforreconciliation and substantiation.

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REVOCATION OF PRIVILEGES
Failure to follow established City purchasing procedures or the improper use of CalCard will result in one or more of the following consequences:
• Suspension of card privileges
• Disciplinary action, up to and including termination of employment There may also be criminal and civil consequences related to misuse of public funds and potential action by the bonding company that provides the City’s blanket employee bond.

Your account can be canceled for:
• Failure to exercise reasonable care in safeguarding the CalCard from loss or unauthorized uses
• Failure to meet the monthly reconciliation submission deadline for two (2) consecutive months, which may result in the CalCard being locked or suspended • Making improper or unauthorized purchases
• Excessive lost receipts, defined as more than two lost receipts within a six-month period
• Failure to comply with the intent, requirements, and provision of the CalCard Policy • Splitting purchases to circumvent CalCard limits or authorization requirements • Determination by the Department head that there is no longer a business purpose Your account will be canceled immediately upon separation from the City, or if the card is intentionally used for personal purposes or shared with unauthorized users.

EMERGENCY PURCHASES
Finance management can approve a temporary increase in Calcard transactions and monthly limits in the event of an emergency as defined in the City’s purchasing instructions. Such increase requests can be directed to Finance by Department heads and/or the City Manager.

Emergency purchases will still require the retention of supporting invoices/receipts/packing slips as a basis for payment and grant assistance recovery.

RECONCILING STATEMENTS
CalCard statements are mailed directly to the departments and are also available for download through the U.S. Bank online system. Immediately upon receipt, the cardholder must verify the accuracy of the statement by comparing charges to supporting invoices/receipts. The review shall encompass the following items:

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1. The reconciled CalCard statement, verifies that statement charge amounts do not exceed or differ from receipt amounts.

2. Any items on the statement that were not purchased, received, or supported by a packing slip (if applicable).

3. Original invoices/receipts (in the order they appear on the statement) submitted to the designated approver for review and signature.

4. If a receipt has been lost, a memorandum (T drive) documenting the description and amount of the charge.

5. The Card Activity Report signed by the cardholder and the approver, including the appropriate budget/expense account codes.

6. Department Heads are responsible for ensuring that reconciled and approved statements for all cardholding employees, including invoices/receipts, are submitted to Finance within ten (10) business days of mail delivery.

DISPUTED CHARGES
If an item on the monthly statement is incorrect, the cardholder should call the supplier immediately to resolve the problem and inform his/her designated approver. Calcard should also be contacted to file the proper file dispute form if necessary. Additionally, Finance should be notified of these disputes as statements are submitted.

RETURNING ITEMS
For an over-the-counter purchase, return the item directly to the supplier and obtain a credit receipt. Requesting a cash refund is not allowed.

If the purchase was made by internet, phone, mail, or fax:
• Contact the supplier for return instructions.
• Get a return reference number from the supplier or credit number.

Be sure to check subsequentstatements to verify credit received for the returned items.

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LOST OR STOLEN CALCARD
• Reporting Lost or Stolen CalCard: 1-800-344-5696 (24 hours/7 days a week) • Inform your designated approver and Finance Department: [email protected].

DECLINED PURCHASE
If a supplier purchase is declined, contact CalCard, and your designated approver to inquire about the reason for the decline. This may be an indication of an exceeded transaction limit, monthly limit, unauthorized purchase category, or simply a processing error.

REVIEW & AUDITS
All accounts are to be reviewed at the Department level and audited regularly as part of the annual interim and year-end audit process. Finance will conduct unscheduled audits of credit card transactions and request specific identification of tangible goods purchased.

INVOICES & RECEIPTS
Supporting original invoices/receipts/packing slips are required without exception before payment can be made. If the supplier does not provide an invoice/receipt/packing slip at the time of transaction or delivery, you must contact the supplier and request replacement documentation. Failure to provide the required documentation may result in non-payment of the charge. Any resulting late fees or penalties shall be charged to the benefiting department.

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EXHIBIT F

PURCHASE CARD EMPLOYEE AGREEMENT
Section 1: Completion of this section is required when applying for a new Cal Card.

This section must be fully completed, signed by the applicant and the Department Head, and returned to Finance for processing.

You are entrusted with a City of Los Altos purchasing card, issued based on your official need to acquire supplies, equipment, and materials for the City. The City may revoke this card at any time, and its issuance does not confer any rights or entitlements based on your position.

Your signature below acknowledges that you have read this Agreement and agree to comply with its terms.

I understand that I will be making financial commitments on behalf of the City of Los Altos and will obtain the best value for The City.

I have read, understood, and agree to follow the policies and procedures described in the City’s Purchasing Instructions. I agree that under no circumstances will I use the purchasing card to make personal purchases, either for myself or for others.

I understand that the purchasing card will be issued in my name and “City of Los Altos.” Personal use of the card is strictly prohibited. Any unauthorized or personal charges must be reimbursed to the City, including related fees.

The purchasing card remains the property of the City and is subject to all applicable internal control and verification requirements, including production of the card upon request. I will immediately notify Cal Card and the Finance Department in the event the card is lost or stolen.

I am responsible for all charges, for reconciling monthly statements within ten days of the bank’s statement received, and for submitting approved statements with original receipts to Finance. If I fail to meet the monthly reconciliation submission deadline for two (2) consecutive months, the Cal Card will be locked or suspended.

I agree to surrender the purchasing card immediately upon request by the Program Administrator or upon termination of employment with the City of Los Altos, regardless of the reason.

I understand that failure to comply with the requirements of the Purchase Card Instructions may result in the revocation of card privileges and other disciplinary actions, including employment termination.

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______________
Print EmployeeName Employee Signature Date
______
Dept. Head Signature Print Name Date
Single Purchase Limit $ __ Total Monthly Limit $ __
Section 2: Completion of this section is required only if the Cal Card is ready to be picked up.

I certify that all purchases charged to Cal Card, unless annotated to the contrary, are true, correct and for official business only. Payment is authorized.

Cal Card Number Print Name Employee Signature Date Pick Up

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City Council Staff Report
Meeting Date: June 23, 2026
Prepared By: Tania Katbi
Approved By: Gabe Engeland
Subject: Authorize the City Manager to Execute an Agreement for the Urban Forest Assessment

COUNCIL PRIORITY AREA
Environmental Sustainability
General Government

RECOMMENDATION
Adopt a Resolution authorizing the City Manager to execute a professional services agreement with Dudek to conduct an updated public tree inventory, perform a land cover assessment, and develop both a city operational and maintenance guide and a residential guide in a total amount not to exceed $199,808

ENVIRONMENTAL IMPACT
Not Applicable.

FISCAL IMPACT
The Urban Forest Assessment project will cost a total not to exceed $199,808. The amount for the professional services contract is included in the FY 2025/26 Sustainability operating budget.

There will be no additional fiscal impact.

PREVIOUS COUNCIL CONSIDERATION
None.

BACKGROUND
Not Applicable.

ANALYSIS
Not Applicable.

DISCUSSION
The City’s Climate Action and Adaptation Plan (CAAP) identifies the urban forest as a key

asset for carbon sequestration, heat reduction, and climate resilience, specifically targeting an expanded tree canopy to help the City achieve complete carbon neutrality by 2035. To advance these targets, the Environmental Commission (EC) formally included the Urban Forest project as a top priority within its 2025 Work Plan, which received City Council approval at the Joint City Council and Commission meeting in early 2025.

Following this approval, a dedicated working group was formed to collaborate closely with City staff. To operationalize the Commission's goals and objectives, staff and the working group collaborated in an extended, iterative scoping process throughout 2025. This process required additional time to align the commission's vision with actionable deliverables that fit within municipal operational capabilities and the project's approved budget. The resulting Urban Forest Assessment project will evaluate public tree health and citywide land cover, providing the essential informational baseline and resources needed to manage the urban forest as a complete, resilient system alongside the City's existing tree protection policies.

The City issued a Request for Proposals (RFP) for the Urban Forest Assessment project on the City’s procurement webpage on April 14, 2026. The City received four proposals from the following firms: Davey Resource Group (DRG), Biotech Consulting, Dudek, and ArborPro.

The selection committee conducted a thorough evaluation of all submitted proposals based on a variety of considerations such as technical qualifications, pervious experience, methodology, and cost-effectiveness. Based on this evaluation process, Dudek was identified as the highestranked and most qualified firm to meet the project's comprehensive requirements.

The project scope encompasses a comprehensive urban forest assessment and the development of supporting educational and operational resources. These deliverables are designed to provide the City with the essential data and tools needed to support the long-term health and protection of the urban forest.

Staff recommends that the City Council approve the contract award and authorize the City Manager to execute the Professional Services Agreement with Dudek.

ATTACHMENTS

1. Attachment 1 - Resolution

Attachment 1 - Resolution
Resolution No. 2026-XX Page 1
RESOLUTION NO. 2026-XX

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

AUTHORIZING THE CITY MANAGER TO EXECUTE AN AGREEMENT ON

BEHALF OF THE CITY OF LOS ALTOS WITH DUDEK CONSULTING FIRM

FOR THE URBAN FOREST ASSESSMENT PROJECT
WHEREAS, the City has selected Dudek to provide professional services for the Urban Forest Assessment Project; and
WHEREAS, funding for the project has been provided through the City's budgeted sustainability funds; and
WHEREAS, this agreement requires City Council approval pursuant to the Los Altos Purchasing Policy.

NOW THEREFORE, BE IT RESOLVED, that the City Council of the City of Los Altos adopt a resolution to:

1. Authorize the City Manager to execute the Agreement with Dudek in a total amount not to exceed $199,808 on behalf of the City, and

2. Authorize the City Manager to take such further actions as may be necessary to implement the foregoing agreement.

I HEREBY CERTIFY that the foregoing is a true and correct copy of a Resolution passed and adopted by the City Council of the City of Los Altos at a meeting thereof on the 26th day of June 2026 by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
___________________________
Sally Meadows, MAYOR
Attest:
_____________________________
Melissa Thurman, MMC

CITY CLERK

City Council Staff Report
Meeting Date: June 23, 2026
Prepared By: Jon Maginot
Approved By: Gabe Engeland
Subject: Adoption of Ordinance - Sidewalk Maintenance and Repair

COUNCIL PRIORITY AREA
Circulation Safety and Efficiency
General Government

RECOMMENDATION
Adopt an ordinance adding a new Chapter 9.32 of the Municipal Code entitled "Maintenance and repair of sidewalks"

ENVIRONMENTAL IMPACT
This ordinance is exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3) (common sense exemption), as it does not have the potential to result in a significant environmental impact.

FISCAL IMPACT
It is unknown the direct cost for adoption of the ordinance. It is anticipated to be largely costneutral over time, as the City may recover costs associated with sidewalk repairs through assessments to property owners as authorized by the Streets and Highway Code. However, there is expected to be costs associated with the 50-50 program. The City has currently budgeted $50,000 in the FY 2026/27 budget for this program.

PREVIOUS COUNCIL CONSIDERATION
June 9, 2026

BACKGROUND
On June 9, 2026, the City Council introduced an ordinance amending the Los Altos Municipal Code to add a new Chapter 9.32 entitled "Maintenance and repair of sidewalks."

ANALYSIS
State law places responsibility for sidewalk maintenance on adjacent property owners. The introduced ordinance restates the State law and codifies current practices and policies of the City.

DISCUSSION
The ordinance assigns responsibility for sidewalk maintenance and repair to property owners whose parcels abut the sidewalk area, including parking strips, curbs and gutters. The ordinance

authorizes the City to perform sidewalk repairs if property owners fail to comply and to recover costs through assessments or liens.

Adoption of the ordinance allows the City to start a "cost share" program with property owners who are needing to repair sidewalks to partner with the City to make the needed repairs.

The ordinance will go into effect 31 days after adoption.

ATTACHMENTS

1. Attachment 1 - Sidewalk Ordinance

Ordinance No. 2026-

Attachment 1 - Ordinance
ORDINANCE NO. 2026-

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF LOS ALTOS ADDING A NEW CHAPTER 9.32 TO THE LOS ALTOS MUNICIPAL CODE ENTITLED “MAINTENANCE AND REPAIR OF SIDEWALKS”
WHEREAS, Article XI, Section 7 of the California Constitution grants cities the police power to make and enforce ordinances to protect the public health, safety, and welfare; and
WHEREAS, the public sidewalks, streets, and rights-of-way within the City are intended for safe and accessible pedestrian travel and are held in trust for use by the general public; and
WHEREAS, unobstructed sidewalks are essential to ensure compliance with state and federal accessibility requirements, including the Americans with Disabilities Act (ADA), and to protect the health, safety, and welfare of all residents and visitors, unobstructed sidewalks are essential to ensure compliance with state and federal accessibility requirements, including the Americans with Disabilities Act (ADA), and to protect the health, safety, and welfare of all residents and visitors; and WHEREAS, the City Council further finds that maintaining clear and accessible pedestrian pathways promotes public safety, supports economic vitality, and enhances the usability of the public realm; and
WHEREAS, the City has an interest in regulating the use of sidewalks and public rightsof-way to prevent obstructions while allowing reasonable and permitted uses consistent with the public interest; and
WHEREAS, the City Council recognizes that other jurisdictions within California and Santa Clara County have adopted similar regulations governing sidewalk use to ensure clarity, consistency, and enforceability; and
WHEREAS, the City desires to establish clear standards regarding prohibited obstructions, time, place, and manner restrictions, and enforcement mechanisms to ensure compliance while emphasizing voluntary compliance and education where appropriate; and
WHEREAS, the City Council finds that adoption of this ordinance is necessary to protect the public health, safety, and welfare and to ensure that sidewalks remain open, accessible, and safe for their intended use.

NOW THEREFORE, the City Council of the City of Los Altos does hereby ordain as follows:

SECTION 1. AMENDMENT OF CODE. Title 9 of the Municipal Code for the City (“Code”) shall be amended to add Chapter 9.32, entitled “Maintenance and Repair of Sidewalks” to read as follows:

Ordinance No. 2026-

Attachment 1 - Ordinance
Chapter 9.32 – Maintenance and Repair of Sidewalks

9.32.010 Maintenance and repair of sidewalks
A. Anything in this chapter to the contrary notwithstanding, the maintenance and repair of sidewalk areas and the making, confirming and collecting of assessments for the cost and expenses of said maintenance and repair may be done and the proceedings therefor may be had and taken in accordance with this part and the procedure therefor provided in Chapter 22 of Division 7, Part 3, of the Streets and Highways Code of the state as the same is now in effect or may hereafter be amended. In the event of any conflict between the provisions of said Chapter 22 of Division 7, Part 3, of the Streets and Highways Code of the state and this Part 17, the provisions of Part 17 shall control.

B. The owners of lots or portions of lots adjacent to or fronting on any portion of a sidewalk area between the property line of the lots and the street line, including parking strips, sidewalks, curbs and gutters, and persons in possession of such lots by virtue of any permit or right shall repair and maintain such sidewalk areas and pay the costs and expenses therefor, including a charge for the City of Los Altos’ costs of inspection and administration whenever the city awards a contract for such maintenance and repair and including the costs of collection of assessments for the costs of maintenance and repair under subsection A. of this section or handling of any lien placed on the property due to failure of the property owner to promptly pay such assessments.

C. For the purposes of this part, maintenance and repair of sidewalk area shall include, but not be limited to, maintenance and repair of surfaces including grinding, removal and replacement of sidewalks, repair and maintenance of curb and gutters, removal and filling or replacement of parking strips, removal of weeds and/or debris, tree root pruning and installing root barriers, trimming of shrubs and/or ground cover and trimming shrubs within the area between the property line of the adjacent property and the street pavement line, including parking strips and curbs, so that the sidewalk area will remain in a condition that is not dangerous to property or to persons using the sidewalk in a reasonable manner and will be in a condition which will not interfere with the public convenience in the use of said sidewalk area.

D. Notwithstanding the provisions of Section 5614 of the state Streets and Highways Code, the city manager or designee may in their discretion, and for sufficient cause, extend the period within which required maintenance and repair of sidewalk areas must commence by a period of not to exceed ninety days from the time the notice referred to in said Section 5614 is given.

9.32.020 Liability for injuries to public
The property owner required by Section 9.32.020 to maintain and repair the sidewalk area shall owe a duty to members of the public to keep and maintain the sidewalk area in a safe and nondangerous condition. If, as a result of the failure of any property owner to maintain the sidewalk area in a nondangerous condition as required by Section 9.32.020, any person suffers injury or damage to person or property, the property owner shall be liable to such person for the resulting damages or injury.

9.32.030 Work performance – city manager authority

Ordinance No. 2026-

Attachment 1 - Ordinance
In performing the work of repairing or constructing any sidewalk as provided in Chapter 22 of Division 7, Part 3 of the Streets and Highways Code of the state, the City Manager or designee may:

A. Procure services from an outside contractor per the City’s Purchasing Policy; or B. Order a city work crew to perform said work.

9.32.040 Notice of cost and hearing by council
Upon the completion of the repairs or construction, the City Manager or designee shall cause notice of the cost of the repairs or construction to be given in the manner specified in Chapter 22 (Repair) of Division 7, Part 3, of the Streets and Highways Code of the state of California, as the same is now in effect or may hereafter be amended, for the giving of notice to repair or construct. The notice shall specify the day, hour and place when the city council will hear and pass on the report of the costs of the repair, together with any written objections or protests which may be raised by any property owner liable to be assessed for the cost of such repair or construction and any other interested persons. The notice shall also describe the procedure to be followed for such written objections or protests. In no case shall the hearing provided for in this section be sooner than ten days after giving of notice.

9.32.050 Hearing by city council
The city council, on the day and hour fixed for hearing, shall hear and pass upon the report of the city manager or designee, together with any written protests or objections, which have not been withdrawn prior to the hearing, from property owners liable to be assessed for the work of making such repair in accord with the procedure provided in Chapter 22 of Division 7, Part 3 of the Streets and Highways Code.

SECTION 2. CONSTITUTIONALITY. If any section, subsection, sentence, clause or phrase of this code is for any reason held to be invalid or unconstitutional, such decision shall not affect the validity of the remaining portions of this code.

SECTION 3. PUBLICATION. This ordinance shall be published as provided in Government Code section 36933.

SECTION 4. CEQA - EXEMPTION. The City Council finds, pursuant to Title 14 of the California Code of Regulations, Section 15061(b)(3), that this ordinance is exempt from the requirements of the California Environmental Quality Act (CEQA) in that it is not a project which has the potential for causing a significant effect on the environment.

SECTION 5. EFFECTIVE DATE. This ordinance shall be effective upon the commencement of the thirty-first day following the adoption date.

The foregoing ordinance was duly and properly introduced at a regular meeting of the City Council of the City of Los Altos held on June 9, 2026, and was thereafter, at a regular meeting held on June 23, 2026, passed and adopted by the following vote:

Ordinance No. 2026-

Attachment 1 - Ordinance
AYES:

NOES:

ABSENT:

ABSTAIN:

Sally Meadows, Mayor
ATTEST:

Melissa Thurman, City Clerk

City Council Staff Report
Meeting Date: June 23, 2026
Prepared By: Melissa Thurman
Approved By: Gabe Engeland
Subject: Adoption of Resolution - SB707 Disruption Policy

COUNCIL PRIORITY AREA
General Government

RECOMMENDATION
Adopt a Resolution approving the Senate Bill 707 (SB707) Disruption Policy and Approve the use of Zoom Technologies for Remote Public Participation

ENVIRONMENTAL IMPACT
N/A

FISCAL IMPACT
While there is no immediate fiscal impact associated with receiving this report, future costs may be incurred to comply with the remote participation requirements in SB707, including potential upgrades or changes to technology, software, and equipment.

PREVIOUS COUNCIL CONSIDERATION
February 10, 2026

BACKGROUND
During the February 10, 2026 City Council meeting, staff presented an informational report regarding Senate Bill 707 (SB707) and its impact on remote public participation requirements under the Ralph M. Brown Act, including the July 1, 2026 implementation timeline. The report outlined anticipated operational considerations and the need to reinstate remote public comment for City meetings by July 1, 2026.

Following the release of that report, staff attended a discussion and training session hosted by the League of California Cities (CalCities) on April 13, 2026, during which additional implementation guidance and clarification were provided regarding the term “eligible legislative body,” including which bodies within a local agency are subject to the remote public participation requirements established under SB 707. A flyer for that training session is included with this report as Attachment 2.

ANALYSIS

SB707 requires local agencies to provide members of the public with the opportunity to participate remotely and to offer them the opportunity to provide comments remotely during meetings. This requirement, however, applies specifically to an "eligible legislative body." As amended by SB707, Government Code Section 54953 requires that an "eligible legislative body" provide a means for the public to remotely hear, visually observe, and address the body in real time.

Under Government Code Section 54953 and SB707, an "eligible legislative body" is defined as:
• The governing body of a local agency; and
• Certain legislative bodies with statewide jurisdiction (not applicable to the City of Los Altos)
During the April 13, 2026 CalCities training session, additional clarification was provided that, for purposes of SB707 implementation, the City Council is the eligible legislative body for the City of Los Altos. The guidance further clarified that the definition does not extend to subordinate advisory bodies, such as commissions, committees, or other advisory bodies established by the City Council, as was previously believed when the February informational report was drafted. Accordingly, while these bodies remain subject to the Brown Act, they are not required under SB707 to provide remote public comment.

DISCUSSION
Pursuant to SB707:
a) All open and public meetings shall include an opportunity for members of the public to attend via a two-way telephonic service or a two-way audiovisual platform, except if adequate telephonic or internet service is not operational at the meeting location. If adequate telephonic or internet service is operational at the meeting location during only a portion of the meeting, the legislative body shall include an opportunity for members of the public to attend via a twoway telephonic service or a two-way audiovisual platform during that portion of the meeting.

The City of Los Altos currently utilizes Zoom technology for remote meeting observation and internal meeting management. Although the City previously discontinued remote public comment via Zoom, the platform continues to allow members of the public to access meetings via the Zoom link published on meeting agendas for viewing and listening. Zoom also provides telephonic access, allowing members of the public to listen to meetings and provide public comment by phone.

Currently, city staff plans to meet the requirements of SB 707 by allowing public comment via Zoom. Allowing comments via Zoom is often easier than via telephone because of the built-in tools that help organize and manage comments more efficiently and reduce interruptions. In contrast, telephone calls can become confusing if multiple people try to speak at once. Staff conducted an informal review of other cities to determine whether they allow comments via telephone or an audio/visual platform. Only one agency responded that they receive comments by telephone, and they reported a number of issues, including feedback from speakers and difficulty hearing the speaker through broadcast channels. That agency will be switching to

Zoom for remote public comments by the July 1st SB707 deadline.

The City of Los Altos currently provides multiple methods by which members of the public may participate in City Council meetings and provide public comment. In addition to traditional inperson participation, members of the public may submit written comments prior to a meeting and, beginning July 1, 2026, may also participate remotely in accordance with the requirements of SB707. The methods for participation are listed below:

Written Public Comment (Email or Mail)
Members of the public may submit written comments by emailing [email protected] prior to the meeting or by mailing a letter to the City Clerk’s Office. Written comments received prior to the agenda publication deadline will be included with the corresponding agenda packet. Written comments received after agenda publication will be distributed to the City Council and made available to the public in accordance with the City’s established procedures.

In-Person Public Comment
Members of the public may provide verbal comments by attending a City Council meeting in person, completing a speaker card, and addressing the City Council when the agenda item they wish to speak on is called for public comment.

Remote Public Comment (Zoom)
Beginning July 1, 2026, members of the public may participate remotely through the City’s Zoom meeting platform. Individuals wishing to address the City Council remotely must join the meeting using the Zoom link provided on the agenda, and utilize the "Raise Hand" feature when the agenda item is called for public comment. Speakers will be recognized by the City Clerk or their designee and provided an opportunity to address the City Council in real time.

Telephonic Public Comment
Beginning July 1, 2026, members of the public may participate by telephone using the phone number listed on the meeting agenda. Individuals who call into the meeting and wish to speak on an agenda item may press *9 to raise their hand and request to speak when the item is called for public comment. The City Clerk or their designee will recognize telephone participants and provide an opportunity for them to address the City Council in real time.

To facilitate the orderly conduct of meetings, speakers will generally be called in the following order:

1. In-person speakers;

2. Remote speakers participating through Zoom; and

3. Telephonic speakers.

The Mayor retains the discretion to modify the order of speakers as necessary to ensure the efficient administration of the meeting.

As the use of outside software and technology poses a risk of potential outages and other issues

beyond staff control, SB707 also requires eligible legislative bodies to adopt a written policy regarding the disruption of telephonic or internet services during a public meeting. This policy must address the following requirements:
• Recessing the Meeting - In the event of a disruption to telephone or internet services/software, the body must recess the meeting for at least one hour in an attempt to restore service.
• Good Faith Effort - The policy must outline the steps staff or the legislative body will take to attempt to restore service.
• Reconvening - The policy must detail procedures for reconvening the meeting if a disruption is resolved, and for continuing or canceling the meeting if the disruption cannot be resolved after one hour has passed.

Attachment 1 of this report is the proposed Disruption Policy Resolution, which will satisfy the requirement of addressing the disruption of telephonic or internet services during a public meeting.

ATTACHMENTS

1. Attachment 1 - Resolution

2. Attachment 2 - CalCities SB707 Flyer

Resolution No. 2026-
RESOLUTION NO. 2026-

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

ADOPTING A POLICY ADDRESSING DISRUPTION OF TELEPHONIC OR

INTERNET SERVICE DURING PUBLIC MEETINGS, IN ACCORDANCE WITH SENATE BILL 707 (SB707)
WHEREAS, the Ralph M. Brown Act (Government Code § 54950 et seq.) establishes requirements for open and public meetings of local legislative bodies; and WHEREAS, Senate Bill 707 (2025) amended the Brown Act to update teleconferencing and accessibility requirements, including provisions related to remote participation in public meetings; and
WHEREAS, Government Code § 54953.4(b)(1)(A) requires eligible legislative bodies, on or before July 1, 2026, to adopt at a noticed public meeting in open session, and not on the consent calendar, a policy addressing disruption of telephonic or internet service during meetings conducted with remote participation; and
WHEREAS, the required policy must address procedures for recessing and reconvening a meeting in the event of a disruption and the efforts the legislative body will make to attempt to restore service; and
WHEREAS, Government Code § 54953.4 further requires that, in the event of a disruption preventing members of the public from observing or participating in the meeting through a twoway telephonic or audiovisual platform, the legislative body shall recess the open session for at least one hour and make a good faith effort to restore service, and may not reconvene open session until at least one hour has passed or service has been restored, whichever occurs first; and WHEREAS, if telephonic or internet service has not been restored upon reconvening, the legislative body must make findings by roll call vote that good faith efforts to restore service have been made and that the public interest in continuing the meeting outweighs the public interest in remote public access; and
WHEREAS, adoption of a technology disruption policy is required to ensure compliance with state law and to promote transparency and continuity of public meetings; and WHEREAS, the proposed policy addressing disruption of telephonic or internet service during meetings of the City of Los Altos has been prepared in accordance with Government Code § 54953.4 and is attached hereto as Exhibit 1; and
WHEREAS, the activity is not a “Project” as defined under Section 15378 of the California Environmental Quality Act (CEQA) State Guidelines; therefore, pursuant to State Guidelines Section 15060(c)(3), no environmental review is required.

Attachment 1 - Resolution

Resolution No. 2026-
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Los Altos as follows:

Section 1. Adoption of Policy. The City of Los Altos hereby adopts the policy entitled “Disruption of Telephonic or Internet Service During Public Meetings,” substantially in the form attached hereto as Exhibit 1.

Section 2. Implementation. The City Clerk and/or City Attorney is authorized and directed to implement the policy in coordination with agency staff, legal counsel, and technology support staff, as appropriate.

Section 3. Minor Modifications. The City Clerk and/or City Attorney may approve minor, nonsubstantive modifications to the policy as necessary to conform to applicable law, agency practices, or formatting requirements, provided such modifications do not materially alter the intent of the policy.

I HEREBY CERTIFY that the foregoing is a true and correct copy of a resolution passed and adopted by the City Council of the City of Los Altos at a meeting thereof on the 9th day of June, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:
__________________________
Sally Meadows
Mayor
ATTEST:
_________________________
Melissa Thurman, MMC
City Clerk

City of Los Altos
1 North San Antonio Road
Los Altos, California 94022-3087

DISRUPTION POLICY OF TELEPHONIC OR INTERNET SERVICE

DURING PUBLIC MEETINGS

1. BACKGROUND
Senate Bill 707 (SB707) (2025), amended the Brown Act to require eligible legislative bodies to adopt, on or before July 1, 2026, a policy addressing how the agency will respond to disruptions in telephonic or internet service that prevent members of the public from attending or observing a meeting remotely. This policy is adopted to comply with that requirement and to ensure continuity of public participation during technical disruptions.

2. PURPOSE
This policy establishes procedures for responding to a disruption in the telephonic or internet services that provide two-way remote public access to meetings of the City of Los Altos, as required by the Brown Act (Government Code §54953.4). The policy ensures transparency, public participation, and continuity of government during technology disruptions.

3. DEFINITIONS
For purposes of this policy:
• “Disruption” means any failure, outage, or other interruption that prevents members of the public from attending or observing the meeting via the available remote access services utilized by the City of Los Altos.
• “Remote access services” means the two-way telephonic service and/or two-way audiovisual platform used to provide real-time remote public attendance and observation of meetings.

4. APPLICABILITY
This policy applies to all open and public meetings of the City Council of the City of Los Altos, at which remote public participation is offered or required under the Brown Act.

5. PROCEDURES IN THE EVENT OF A DISRUPTION OF SERVICE

5.1 RESPONSE TO SERVICE DISRUPTION
If the City Clerk, or the party responsible for managing technology providing remote public participation, becomes aware of a disruption to the agency’s remote access services that prevents members of the public from attending or observing the meeting remotely:

1. The City Clerk shall make the Mayor aware of the disruption.

2. The Mayor shall announce the disruption in service to the public.

DISRUPTION OF TELEPHONIC OR INTERNET SERVICE

DURING PUBLIC MEETINGS
1 North San Antonio Road
Los Altos, California 94022-3087

3. The Mayor may then call for a recess of the open session, or convene the legislative body in closed session, consistent with the Brown Act.

4. Staff shall begin a diligent effort to diagnose and restore the disrupted service.

5. The meeting shall remain in recess for at least one hour or until service is restored, whichever is sooner. The recess period may be extended if restoration efforts are ongoing.

5.2 EFFORTS TO RESTORE SERVICE
The agency shall make good faith efforts to restore remote access services, which may include:
• Troubleshooting platform or teleconferencing software • Resetting or replacing audiovisual equipment, if applicable • Contacting necessary support staff, such as IT, or other service providers or vendors for additional help
The City Clerk shall document the restoration efforts undertaken, including the time of the recess, the attempts at reconnection, and the end time of the recess.

6. RECONVENING THE OPEN SESSION

6.1 TIMING
The open session may be reconvened after at least one hour has elapsed from the time of the initial disruption, or as soon as service is restored, whichever occurs earlier.

6.2 IF SERVICE IS RESTORED
If the remote access service is restored before or at the time the meeting reconvenes, the meeting shall continue as normal.

6.3 IF SERVICE IS NOT RESTORED
If service has not been restored after one hour of recess, the City Council may reconvene and:

1. Adjourn the meeting; or

2. Continue the meeting in open session by adopting, by roll call vote only, the following, or a substantially similar finding:
“Staff of the City of Los Altos has made good faith efforts to restore telephonic or internet service in accordance with its adopted policy, and the public interest in continuing the meeting outweighs the public interest in remote public access.”

DISRUPTION OF TELEPHONIC OR INTERNET SERVICE

DURING PUBLIC MEETINGS
1 North San Antonio Road
Los Altos, California 94022-3087
Upon adoption of the finding, the legislative body may continue the open session even if remote access has not been restored.

7. REVIEW AND UPDATES
The City Council of the City of Los Altos may amend this policy at a noticed public meeting, but may not adopt it as a routine item on the Consent Calendar.

Attachment 2 - CalCities Flyer

City Council Staff Report
Meeting Date: June 23, 2026
Prepared By: Stephanie Williams
Approved By: Gabe Engeland
Subject: Receive Report - Elections Code Section 9212

COUNCIL PRIORITY AREA
General Government

RECOMMENDATION
Staff recommends the City Council receive the Elections Code Section 9212 Report for the proposed Measure entitled “Los Altos Downtown Parking Plazas Ordinance.”

ENVIRONMENTAL IMPACT
Preparation of the report pursuant to Elections Code Section 9212 is not a project under the California Environmental Quality Act (CEQA) because it constitutes an administrative and informational activity that will not result in a direct or reasonably foreseeable indirect physical change in the environment pursuant to CEQA Guidelines Sections 15060(c)(2), 15378(b)(2), and 15378(b)(5). Therefore, no CEQA review is required.

FISCAL IMPACT
Preparation of the 9212 Report will result in one-time costs for staff time and specialized consultant support, with a consultant contract amount not to exceed $124,160. Potential longerterm fiscal impacts of the Measure are evaluated in the 9212 Report.

PREVIOUS COUNCIL CONSIDERATION
April 28, 2026 and June 9, 2026

BACKGROUND
On April 28, 2026, the City Council authorized the City Manager, or designee, to execute an agreement with a consultant to prepare an Elections Code Section 9212 report and directed staff to return with the completed report within the statutory timeframe before any further action under Elections Code Section 9215. Under Section 9212, the report must be presented within the timeframe prescribed by the legislative body, but no later than 30 days after the election’s official certifies the sufficiency of the petition.

On May 26, 2026 the City Clerk prepared the Certificate of Sufficiency of Initiative Petition. On June 9, 2026, the City Council accepted the City Clerk’s Certificate of Sufficiency of Initiative Petition and reaffirmed its direction that the 9212 Report be returned no later than June 25, 2026. The report is being presented within the required 30-day period. Following presentation of the report, the City Council may either: (1) adopt the Ordinance after presentation or within 10

days; or (2) order an election pursuant to Elections Code Section 1405. At this meeting, the City Council will have the opportunity to select one of these options.

ANALYSIS
The 9212 Report provides the City Council and the public with a structured, objective evaluation of the potential consequences of the proposed Measure before the City Council is required to determine whether to adopt the Ordinance or submit it to the voters. The report is included as Attachment 1. Consistent with Elections Code Section 9212, the report, to the extent feasible, analyzes the Measure’s impact on the following areas:

1. Fiscal Impacts: Its fiscal impact.

2. Planning Impacts: Its effect on the internal consistency of the City's general and specific plans, including the housing element, the consistency between planning and zoning, and the limitations on city actions under Section 65008 of the Government Code and Chapters 4.2 (commencing with Section 65913) of Division 1 of Title 7 of the Government Code.

3. Land Use and Housing Impacts: Its effect on the use of land, the impact on the availability and location of housing, and the ability of the city to meet its regional housing needs.

4. Infrastructure Impacts: Its impact on funding for infrastructure of all types, including, but not limited to, transportation, schools, parks, and open space. The report may also discuss whether the measure is likely to result in increased infrastructure costs or savings, including the costs of infrastructure maintenance, to current residents and businesses.

5. Business Impacts: Its impact on the community's ability to attract and retain business and employment.

6. Vacant Land Impacts: Its impact on the uses of vacant parcels of land.

7. Other Impacts: Its impact on agricultural lands, open space, traffic congestion, existing business districts, and developed areas designated for revitalization.

8. Urban Greenery Impacts: The report also evaluates other topics and questions as directed by the City. This includes impacts on urban greenery and urban heat islands.

The Elections Code Section 9212 Report was prepared by a consultant team consisting of Metropolitan Planning Group (M-Group) and Bay Area Economics (BAE). The consultant team was selected for its technical expertise, knowledge of Los Altos, and ability to prepare the report within the statutory deadline. The report before the City Council evaluates how the proposed Measure would impact the topic areas set forth above. The report is intended to present factual information and professional judgment to reach conclusions or hypotheses regarding the potential results of the Measure if adopted.

DISCUSSION
See Analysis section above.

ATTACHMENTS

1. Los Altos Elections Code Section 9212 Report

2026 Ballot Measure Impact Analysis – 9212 Report |Table of Contents, Page 1 Ballot Measure Impact Analysis
Pursuant to Election Code 9212
Proposed Ballot Measure Entitled:
“Los Altos Downtown Parking Plazas
Ordinance”
June 15, 2026
Prepared By:

City of Los Altos
Metropolitan Planning Group
Bay Area Economics (BAE)

2026 Ballot Measure Impact Analysis – 9212 Report |Table of Contents, Page 2 Table of Contents
Introduction ................................................................................................................................... 3 Executive Summary....................................................................................................................... 4 Purpose .......................................................................................................................................... 8 Background.................................................................................................................................... 8

1. Fiscal Impacts........................................................................................................................... 10

2. Planning Impacts ..................................................................................................................... 18

3. Housing Impacts...................................................................................................................... 37

4. Infrastructure Funding Impacts.............................................................................................. 55

5. Business Impacts..................................................................................................................... 60

6. Vacant Land Impacts ............................................................................................................... 68

7. Other Impacts .......................................................................................................................... 69

8. Urban Greenery Impacts ........................................................................................................ 77 List of Tables
Table 1: Parcels Affected by the Ballot Measure......................................................................... 9 Table 2: Land Use Designations ................................................................................................. 37 Table 3: 6th Cycle RHNA Allocation for Los Altos and Site Inventory Summary...................... 50 Table 4: 6th Cycle RHNA Allocation for Downtown Parking Plazas .......................................... 51 Table 5: 6th Cycle RHNA Progress for Los Altos through May 22, 2026................................... 52 List of Figures
Figure 1: Parking Plazas in City Context....................................................................................... 5 Figure 2: Existing Parking Plaza Opportunity Sites ................................................................... 25 Figure 3: Downtown Plaza Locations for Long-Term Vision..................................................... 26 Figure 4: Locations of Other Downtown Public Plazas............................................................. 27 Figure 5: Location of Future Parking Facilities .......................................................................... 28 Figure 6: Parking Plaza General Plan Land Use Designations ................................................. 31 Figure 7: Parking Plaza Zoning ................................................................................................... 33 Attachments
A. Proposed Ballot Measure Entitled “Los Altos Downtown Parking Plazas Ordinance” B. YIMBY Law Letter dated June 4, 2026
C. YIMBY Law Letter dated June 15, 2026

2026 Ballot Measure Impact Analysis – 9212 Report |Introduction, Page 3 References
The following referenced planning documents can be found on the City’s website.1 • Downtown Los Altos Parking Strategy
• Downtown Vision Plan
• Climate Action and Adaptation Plan
• Complete Streets Master Plan
Introduction
This report covers the topics included in the Election Code Section 9212. References in the text to “Ballot Measure” refer to the Ballot Measure titled “Los Altos Downtown Parking Plazas Ordinance" as authorized by the City of Los Altos (the “City”) City Council on April 28, 2026. The Ballot Measure is included as Attachment A.

The Ballot Measure would amend the Los Altos Municipal Code to prohibit the City from taking the following actions:

1. Sell, trade, lease, donate, dispose or otherwise convey any Parking Plaza, or any portion thereof, for any reason.

2. Designate or change the use of any Parking Plaza in any way which would affect the use of the Parking Plazas for parking, or which would diminish the availability, access or convenience of public parking.

3. Declare any Parking Plaza “surplus land” or “exempt surplus land” under the California Surplus Land Act (Government Code sections 54220 et seq.).

4. Modify, alter or construct any capital project or other physical alteration on any of the Parking Plazas which permanently diminishes the availability, access or convenience of public parking.

5. Modify or physically alter any Parking Plaza by adding additional levels or floors.

6. Modify or physically alter any Parking Plaza in a way which would negatively affect protected trees or the tree canopy.

The Ballot Measure includes exceptions for maintenance and repair of the Parking Plazas, hosting community activities, and developing Parking Plazas 7 and 8 for affordable housing.

This report describes how the Ballot Measure would impact the following topic areas as provided for in Section 9212 of the state election code:

1. Fiscal Impacts: Its fiscal impact.

2. Planning Impacts: Its effect on the internal consistency of the city's general and specific plans, including the housing element, the consistency between planning and zoning, and the limitations on city actions under Section 65008 of the Government 1 See, https://www.losaltosca.gov/218/Adopted-Plans

2026 Ballot Measure Impact Analysis – 9212 Report |Executive Summary, Page 4 Code and Chapters 4.2 (commencing with Section 65913) of Division 1 of Title 7 of the Government Code.

3. Land Use and Housing Impacts: Its effect on the use of land, the impact on the availability and location of housing, and the ability of the city to meet its regional housing needs.

4. Infrastructure Impacts: Its impact on funding for infrastructure of all types, including, but not limited to, transportation, schools, parks, and open space. The report may also discuss whether the measure would be likely to result in increased infrastructure costs or savings, including the costs of infrastructure maintenance, to current residents and businesses.

5. Business Impacts: Its impact on the community's ability to attract and retain business and employment.

6. Vacant Land Impacts: Its impact on the uses of vacant parcels of land.

7. Other Impacts: Its impact on agricultural lands, open space, traffic congestion, existing business districts, and developed areas designated for revitalization.

8. Urban Greenery Impacts: The report also evaluates other topics and questions as directed by the City. This includes impacts on urban greenery and urban heat islands.

Executive Summary
The report finds that the Ballot Measure would potentially limit new development by adding additional constraints to development on the City-owned Downtown Parking Plazas.

Although there is an exception for “affordable housing” on Plazas 7 and 8, it is not clear if mixed-income housing or other development programs that include affordable housing could be approved without a subsequent Ballot Measure. This would impact development of even affordable multifamily housing on all these lots, including Plazas 7 and 8, by potentially complicating development opportunities. This would impact Program 1.H (“Facilitation housing on City-owned sites”) and other Housing Element programs and policies. The parking plazas and their location in the City can be seen in Figure 1: Parking Plazas in City Context.

If the Ballot Measure were to pass and then subsequently be challenged in court, the City would be required to pay defense costs of the challenge and potentially indemnify the proponents. The City would also be required to defend the Ballot Measure and any implementation of the Ballot Measure, until ended by voters. These legal costs would be assumed by the City no matter what the margin of victory if the Ballot Measure were to pass. The Ballot Measure could potentially be challenged by the State of California, residents, and/or an advocacy group.

2026 Ballot Measure Impact Analysis – 9212 Report |Executive Summary, Page 5 Figure 1: Parking Plazas in City Context

2026 Ballot Measure Impact Analysis – 9212 Report |Executive Summary, Page 6 The Ballot Measure could complicate the City’s ability to meet its Regional Housing Needs Allocation (RHNA) obligations under State law, as well as its obligations under California’s Affirmatively Furthering Fair Housing (AFFH) requirements, enacted in 2018 through Assembly Bill 686.

Over time, and particularly in the upcoming 7th Cycle (2031-2039), the City would have reduced flexibility in planning for future housing or other land uses because the Ballot Measure could limit the City’s ability to plan for mixed-use development, housing, and/or new parking facilities on City-owned sites downtown as projected in the Downtown Vision Plan.

The state’s department of Housing and Community Development (HCD) advises jurisdictions that there are various consequences that may apply when a city does not have a housing element in compliance with Housing Element Law. This could be the case for housing elements in future cycle, and would include ineligibility or delay in receiving certain state funds, referral to the California Office of the Attorney General (AGO), court-imposed financial penalties, the loss of local land use authority to a court-appointed agent, and the application of the Builder’s Remedy provisions of the Housing Accountability Act. 2 The Ballot Measure could delay or prevent the City from developing additional parking within the Downtown parking plazas by constraining the City’s ability to evaluate alternative parking configurations, such as parking structures, that may increase the supply of Downtown parking or allow existing parking resources to be used more efficiently.

In addition, the City’s Downtown Vision Plan expressly contemplates redevelopment and other changes to the parking plazas. The Climate Action and Adaptation Plan, the Multimodal Plan, and other adopted City policy documents are coordinated to advance a unified long-term vision for Downtown, and each of these documents contemplate changes to the City-owned parking plazas. The proposed ballot measure would be inconsistent with, and potentially undermine implementation of, the City’s adopted policy framework.

Impacts of Undefined Terms
The lack of definition and the restrictions posed by the Ballot Measure introduce several areas of elevated legal and administrative risk. The Ballot Measure uses key terms that are undefined.

The application of terms such as “availability,” “access,” and “convenience” of parking creates inherent ambiguity in determining when voter approval is required, making consistent application difficult and increasing the likelihood of conflicting interpretations and legal disputes. Also, the Ballot Measure’s restrictions on physical alterations to Parking Plazas may significantly impair the City’s ability to issue encroachment or construction permits for private-party activities – including utility repairs, trenching, and construction staging – creating risk that property owners or service providers could be unable to access 2 Gov. Code Section 65585, subds. (j), (I), 65589.5, subd. (d)(5).

2026 Ballot Measure Impact Analysis – 9212 Report |Executive Summary, Page 7 or maintain infrastructure, which in turn could prompt challenges to permit denial or inaction.

In addition, by requiring voter approval for actions affecting sites identified for housing, the measure may operate as an additional constraint on housing development capacity and timing, creating potential exposure to state law compliance issues and challenges related to maintaining adequate housing opportunity sites. Finally, the limitation on declaring surplus land or modifying Parking Plazas introduces a structural constraint on the City’s ability to carry out state-required land disposition processes, potentially placing local procedural requirements in tension with state mandates.

Because the initiative shifts project-level decisions to a voter approval process, it introduces a high degree of uncertainty and susceptibility to competing stakeholder interests in individual project outcomes, increasing the likelihood of contested decisions, delays, and project-specific legal challenges.

Fiscal Impacts
Broadly, the passage of the Ballot Measure is likely to have a negative net fiscal impact on the City's General Fund. By limiting the range of development that can occur without voter approval and introducing additional entitlement risk, the measure would likely constrain developer interest in the Plaza sites and reduce the amount developers would be willing to pay for them, directly affecting the City's revenues from any future sale or ground lease.

Beyond disposition proceeds, the Ballot Measure is also likely to deter or delay development types that could generate net positive ongoing fiscal impacts, such as marketrate residential and nonresidential development, while not necessarily making 100-percent affordable housing more probable. Affordable housing, at any proportion or income level could generate indirect fiscal benefits by providing housing opportunities for the local workforce that sustains Downtown businesses and employers, which in turn supports the City's broader revenue base from sources such as property tax, sales tax, and transient occupancy tax.

Infrastructure Funding Impacts
Passage of the Ballot Measure would have implications for infrastructure funding. New development generates demand for infrastructure improvements and in some cases generates revenues through impact fees and other mechanisms to help fund those improvements.
• Transportation infrastructure would likely have offset effects: less development means less demand on the transportation network, and therefore less fee revenue to address that demand.
• Stormwater infrastructure would be negatively affected as the Ballot Measure's requirement to make uses such as a park, paseo, or landscaped open space not possible on the Plaza sites could have a modest negative effect on stormwater

2026 Ballot Measure Impact Analysis – 9212 Report |Purpose, Page 8 funding needs by decreasing opportunities to reduce runoff through redevelopment.
• Utility infrastructure would be affected by reducing the amount of new development, reducing sewer connection fees (as well as any incremental demands) as well as electricity demand.
• Parks and open space infrastructure could be affected because reduced development on the Parking Plaza sites would reduce park impact fee revenues that could otherwise help fund park improvements. However, any park or open space use would be complicated by requiring subsequent voter approval. • School facility impacts would likely be limited because reduced residential development on the Plaza sites would also reduce the number of new students generated by that development. However, less residential development would also reduce school impact fee revenues that would otherwise help fund school facility needs. These two effects would generally offset one another.

Business Impacts
A 2024 parking study found that the existing public parking supply substantially exceeds demand under current conditions. Trading parking supply for additional residents, who are likely to shop and spend money near their homes, would likely benefit the Downtown business environment. As the Ballot Measure would make it more difficult to develop residential uses, the passing of the Ballot Measure would have a negative impact on local businesses.

Racial and Economic Equity
Passage of the Ballot Measure would negatively affect racial and economic equity by making it harder, in the future, to develop affordable housing on the Downtown parking lot sites, which are in a “Highest Resource” area with strong access to opportunity. Delays or constraints to building affordable units in this location would limit progress toward addressing the City’s significant housing cost burdens, particularly among Black, Latino, and lower-income households, and would exacerbate longstanding patterns of unequal access to high-opportunity neighborhoods.

Purpose
Within the scope of the 9212-election code and as prescribed by the City Council, the purpose of this Report is to provide a professional, factual and objective analysis of the potential impacts of the Ballot Measure on the City of Los Altos.

Background
On September 6, 2023, the California Department of Housing and Community Development (HCD) certified the City’s 2022-2031 Housing Element. The Housing Element

2026 Ballot Measure Impact Analysis – 9212 Report |Background, Page 9 includes many programs designed to meet the City’s RHNA, in compliance with State law.

Program 1.H describes how the City will facilitate development of housing on City-owned sites through public-private partnerships during the planning period, including on Cityowned Downtown Parking Plazas 7 and 8.

The Los Altos Downtown Parking Plazas Ordinance (”Ballot Measure”), if adopted, would add a chapter to the City’s Municipal Code and, among other provisions, prohibit the City from selling, trading, leasing, donating, disposing or otherwise conveying all or a portion of City-owned Downtown parking plazas for any reason that would affect, or diminish the availability or convenience of parking, without voter approval, with exceptions for maintenance work and related capital improvement projects, temporary events, and developing Parking Plazas 7 and 8 for affordable housing.

The Ballot Measure defines “Parking Plazas” as the ten separate parking lots located in downtown Los Altos, described as “publicly-accessible” and “owned by the City.” Their APNs are provided in Table 1: Parcels Affected by the Ballot Measure, below:

Table 1: Parcels Affected by the Ballot Measure
Common Designation Assessor’s Parcel
Number (APN)
Plaza 1, South Plazas, First Street 167-40-039
Plaza 2, South Plazas, Second Street 167-40-072
Plaza 3, South Plazas, Third Street 167-38-002
Plaza 4, Central Plazas, First Street 167-39-057
Plaza 5, Central Plazas, Second Street 167-39-069
Plaza 6, Central Plazas, State Street 167-38-028
Plaza 7, North Plazas, First Street 167-39-032
Plaza 8, North Plazas, Second Street 167-39-007
Plaza 9, North Plazas, Fourth Street 167-38-049
Plaza 10, North Plazas, Fourth Street 167-38-029

Specifically, the Ballot Measure would prohibit the City from taking the following actions without approval by a majority vote of the City’s voters:

1. Sell, trade, lease, donate, dispose or otherwise convey any Parking Plaza, or any portion thereof, for any reason.

2. Designate or change the use of any Parking Plaza in any way which would affect the use of the Parking Plazas for parking or which would diminish the availability, access or convenience of public parking.

3. Declare any Parking Plaza “surplus land” or “exempt surplus land” under the California Surplus Land Act (Government Code sections 54220 et seq.).

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 10

4. Modify, alter or construct any capital project or other physical alteration on any of the Parking Plazas which permanently diminishes the availability, access or convenience of public parking.

5. Modify or physically alter any Parking Plaza by adding additional levels or floors.

6. Modify or physically alter any Parking Plaza in a way which would negatively affect protected trees or the tree canopy.

If the City wishes to take one of these actions, it must place that action on the next regularly scheduled election following final City approval of the action, at the earliest time allowable by law, and the action will only become effective if approved by a majority of the voters.

There are exceptions to the voter requirement. The City may take the following actions with respect to the Parking Plazas without a vote:

1. Maintain and repair the Parking Plazas, even if these activities temporarily affect parking availability, access, or convenience, if they are intended to preserve or improve the access or convenience of public parking.

2. Host community activities, such as the farmers market or similar events, which use the Parking Plazas on a short-term and temporary basis.

3. Develop Parking Plaza 7 (APN: 167-39-032) and Parking Plaza 8 (APN:167-39-007) for affordable housing.

The Ballot Measure would take effect upon approval by a majority of voters, but would become operative as of April 4, 2026, the date the notice of intention to circulate the initiative petition was published.

On May 5, 2026, the petition for the proposed Ballot Measure was filed with the County of Santa Clara within the required time following the publication date.

Signature verification is performed by the Santa Clara County Clerk-Recorder’s Office (“County”). At the time the petition was filed, Los Altos had 22,789 registered voters, which required 2,279 valid signatures to qualify the measure for the ballot. Pursuant to Elections Code section 9211, the County examined the signatures submitted in support of the initiative petition and, on May 21, 2026, determined that 2,676 signatures were valid exceeding the number required to qualify the Ballot Measure for the ballot.

Based on the validation of the petition format and content (Elections Code section 9239) along with the signature verification (Elections Code sections 9215 and 9240), the City Clerk certified the petition as sufficient to qualify as an initiative petition for the ballot on May 26, 2026. The City Council requested the preparation of a 9212 report which is due no later than June 25, 2026 - 30 days from the City Clerk's certification.

1. Fiscal Impacts
This chapter analyzes the potential impact that passage of the Ballot Measure could have on the City of Los Altos’ annual operating budget. The City of Los Altos funds key services

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 11 for residents and local businesses, including public safety, public works, and parks and recreation. These services are supported by revenue from property tax, sales tax, fees, transient occupancy (lodging) tax, and other sources. Passage of the ballot measure could affect the City’s operating revenues and service costs to the extent that it influences whether development occurs on any of the parking lot sites.

Overview of the Ballot Measure
Passage of the Ballot Measure would amend the Los Altos Municipal Code to prevent ten City-owned surface parking lots in the Downtown area from being sold, repurposed, or significantly altered unless voters first approve the change by majority vote.

The ordinance includes an exception for Parking Plazas 7 and 8 (APNs 167-39-032 and 167- 39-007), which are explicitly exempted from the voter approval requirement if developed for affordable housing. The term "affordable housing" is not defined in the measure; a carve-out in “Exceptions” Section 14.92.050(3) simply states the City may "develop Parking Plaza 7 and Parking Plaza 8 for affordable housing," with no reference to income thresholds, affordability levels (e.g., Area Median Income (AMI) percentages), or deed restriction requirements.3 The measure also does not specify whether a mixed-income project with only a portion of affordable units would satisfy the exception, or whether 100- percent affordable projects are required. The absence of a definition of affordable housing may lead to disputes over whether specific project proposals qualify for the exemption.

Possible Future Redevelopment Scenarios for Parking Plaza Sites This section summarizes potential future development projects on the Parking Plaza sites for the purpose of evaluating the possible impacts of the ballot measure.

The City is currently considering two redevelopment efforts on Parking Plaza sites. For Plazas 1, 2, and/or 3, the City is exploring the possibility of a new downtown park and parking improvements. For Plazas 7 and 8, the City is pursuing residential development which includes affordable housing. Plaza 8 was identified as an ideal site for affordable housing in the City's Downtown Vision Plan, adopted in 2018. The City's 6th Cycle Housing Element identifies all the plazas as housing opportunity sites. At its August 27, 2024, meeting, the City Council voted to formally declare Plazas 7 and 8 as surplus land under the California Surplus Land Act, opening the door to sell or lease the sites to a developer for residential development.

While the City is not currently pursuing redevelopment of the remaining five Parking Plazas (4, 5, 6, 9, and 10), those sites could potentially be used for residential development, along with a range of commercial and mixed-use activities appropriate for the Downtown. The same range of future uses could likewise apply to Plazas 1, 2, 3, 7, and 8 — either on 3 Section 62250(a) of the Government Code states: ““Affordable housing” means housing with an affordable housing cost, as defined in Section 50052.5 of the Health and Safety Code, or affordable rent, as defined in Section 50053 of the Health and Safety Code, for households whose gross income does not exceed 120 percent of the area median income.”

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 12 portions of those sites not ultimately developed under the uses currently under consideration, or if the currently contemplated projects do not move forward.

Impacts of the Ballot Measure on Possible Future Development Scenarios Passage of the Ballot Measure would make it meaningfully more difficult for the City to pursue development or improvements to the Parking Plaza sites. The voter approval requirement introduces additional time, cost, and uncertainty that could deter action at multiple stages: the City could elect not to move forward given the procedural burden; voters could reject a proposed project; or prospective developers could be deterred from pursuing projects or unable to secure adequate financing due to the uncertainty inherent in a ballot process. Even where development ultimately proceeds, the voter approval requirement could add years to the timeline.

While the Ballot Measure preserves a pathway for affordable housing development on Parking Plazas 7 and 8, in effect this outcome is unlikely even if the measure passes. The measure does not provide a clear exemption from the voter approval requirement for mixed-income housing development, leaving 100-percent affordable housing as the only option with a clear exemption. However, a 100-percent affordable development is unlikely on these sites due to a variety of potential factors, including developer concern at an extended development timeline to allow for a ballot measure and the feasibility of a 100- percent affordable housing model on the site. The overall effect would be to make any kind of development on the sites unlikely, as any development other than 100-percent affordable housing would require voter approval and 100-percent affordable housing is unlikely. If the Ballot Measure does not pass, a mixed-income residential development is likely to proceed on these sites, consistent with the City’s current efforts and the City’s Housing Element.

For the remaining Plaza sites, the most immediate impact would be that it would be more difficult to pursue a downtown park and parking improvements on Plazas 1, 2, and/or 3, which the City is currently evaluating. Over the longer term, passage of the measure could similarly constrain the City's ability to pursue other forms of development or improvements across all Plazas.

Impact on City Revenues
Development of the Parking Plaza sites would generate new revenues for the City of Los Altos General Fund from a variety of sources. The most direct source of revenue would be proceeds from the disposition of the sites themselves, whether through a fee-simple sale or a ground lease arrangement. In addition, new development would generate ongoing annual revenues for the General Fund, which could include property tax, sales tax, transient occupancy tax, and utility user tax. The type and magnitude of both one-time and ongoing revenues would depend on the type and intensity of development, as discussed in the following subsections.

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 13 Land Disposition Revenues
If the City ultimately sells or ground leases the Parking Plaza sites to developers, it will receive proceeds from those transactions either as a lump-sum payment in the case of a fee-simple sale or as ongoing ground lease payments over the term of a lease. These proceeds would represent a direct revenue benefit to the City, the magnitude of which would depend on the value of the sites, the terms negotiated with the developer, and the type of development proposed.

Passage of the Ballot Measure can be anticipated to have a negative impact on future City revenues from disposition of the Parking Plaza sites compared to a scenario in which the Ballot Measure does not pass. If the ballot measure passes, the voter approval requirement could deter developers from pursuing projects on these sites altogether or reduce their willingness to offer competitive terms due to the uncertainty and additional costs associated with a ballot process. Developers factor entitlement risk into their underwriting, and the requirement to obtain voter approval before a project can proceed represents a significant source of risk that would likely be reflected in lower offers or reduced interest from the development community.

Annual Property Tax Revenues
The City receives a share of the property tax generated by all taxable real property within City limits. The downtown Parking Plazas are in Tax Rate Area (TRA) 011-001, where property taxes flow to the City at a rate of $116.60 per year for every $100,000 in assessed value. Because the Parking Plazas are publicly owned, they are currently exempt from property tax and generate no property tax revenue for the City.

The property tax implications of any future development on the Parking Plaza sites would depend significantly on the type of use developed.4 As a general matter:
• Public agency-owned land is not subject to property tax. The Parking Plazas therefore generate no property tax revenue under current conditions. • 100-percent affordable housing is typically exempt from property tax, provided the development is owned and operated by a nonprofit entity and meets applicable requirements under State law.
• Market-rate housing and mixed-income development are generally subject to property tax. Affordable units in mixed-income projects are typically taxable unless separated from the market-rate units in the project and owned and operated by a non-profit entity.
4 If the City disposes of any Parking Plaza site through a ground lease rather than a fee-simple sale, the City will retain ownership of the land and the site would remain exempt from property tax. However, any development on a ground-leased site that would otherwise be subject to property tax if privately owned would instead be subject to possessory interest tax. For long-term ground leases, the City's possessory interest tax revenues would generally be approximately equivalent to the property tax revenues the City would receive from a comparable development on a privately-owned site.

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 14 • Nonresidential uses such as office, retail, hotel, and performing arts centers are generally subject to property tax. Publicly owned non-residential uses such as a cityowned park, paseo, or civic facility would remain exempt from property tax, as with other public agency-owned land.

If the Ballot Measure does not pass, there is a higher likelihood that the Parking Plaza sites will be developed with property-tax-generating projects such as mixed-income housing or commercial uses. Because the sites are currently exempt from property tax, such development would have a positive impact on City property tax revenues. If the Ballot Measure passes, the sites are more likely to remain exempt from property tax, as the Plazas are more likely to remain undeveloped due to the measure’s limitations on pathways to development and procedural hurdles associated with the voter approval requirement.

Annual Sales Tax Revenues
Taxable purchases in Los Altos generate sales tax revenue for the City at a rate of 1.0 percent of the taxable sale price. All California jurisdictions collect a statewide base sales tax rate of at least 7.25 percent, comprised of 6.0 percent that accrues to the State, 0.25 percent allocated to fund transportation projects in the county where the sale occurs, and the 1.0 percent "Bradley-Burns" local sales tax, which some incorporated jurisdictions share with the county in which they are located.

For sales occurring in Los Altos, the full Bradley-Burns 1.0 percent accrues to the City.

Taxable purchases in Santa Clara County are also subject to various local "district" sales taxes that fund regional services and projects, which cumulatively add 2.5 percent to the overall rate, resulting in a total Los Altos sales and use tax rate of 9.75 percent. None of the district sales and use taxes that apply to purchases in Los Altos accrue to the City.

Development of the Parking Plaza sites would be expected to generate positive sales tax impacts for the City. The Parking Plazas are situated in Downtown Los Altos, which serves as a significant retail hub within the City, and new development of virtually any kind would likely strengthen the commercial activity that drives sales tax generation.

New housing would bring residents directly into Downtown, adding spending power to support local businesses.5 New office development would similarly bring workers who patronize nearby shops and restaurants, and some office tenants generate sales and use tax through business-to-business transactions. New retail space would directly generate sales tax through purchases at new businesses. Even non-commercial uses such as a park, public event space, or arts and cultural venue would contribute indirectly by drawing people into Downtown and increasing foot traffic to surrounding businesses.

As discussed above, passage of the Ballot Measure is likely to reduce the overall amount and range of development that can occur on the Parking Plaza sites. To the extent the 5 For an example of incomes eligible for affordable housing units, see HCD’s 2025 State Income Limits, available at https://www.hcd.ca.gov/sites/default/files/docs/grants-and-funding/income-limits-2025.pdf. For a 4-person household, a moderate income can be up to $234,500.

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 15 Ballot Measure reduces development activity on these sites, it would correspondingly reduce the positive sales tax impacts that such development would otherwise generate.

Annual Transient Occupancy Tax Revenues
Los Altos levies a transient occupancy tax (TOT) on lodging revenues at a rate of 14 percent.

The development scenarios the City is currently evaluating for the Parking Plaza sites do not include hotel development, and therefore no direct change in TOT revenue is anticipated in the near term under either outcome of the Ballot Measure. However, if the City were to consider hotel development on one or more Plaza sites in the future, passage of the Ballot Measure would introduce additional time and uncertainty into that process and reduce the likelihood that such development would ultimately occur. To the extent the Ballot Measure diminishes the potential for future hotel development on the sites, it could correspondingly reduce the City's ability to capture TOT revenue from that development.

Beyond direct hotel development, new uses on the Parking Plaza sites could also affect TOT indirectly. Development that enhances the vitality and appeal of Downtown Los Altos could benefit existing hotels by supporting higher occupancy rates or room rates. Conversely, if passage of the Ballot Measure makes it more difficult for the City to activate the Parking Plaza sites in ways that improve the Downtown experience, any benefit to local hotel businesses and the associated TOT revenues could be diminished.

Annual Utility User Tax Revenues
The City levies a utility user tax (UUT) on the consumption of certain utility services within City limits. The UUT applies to electricity, gas, and water at a rate of 3.5 percent of charges, and to telephone and cable television services at a rate of 3.2 percent of charges. UUT revenues totaled approximately $4.1 million in the City's 2025/26 General Fund budget, representing roughly six percent of the City's $65.1 million General Fund.

Because the Parking Plazas are currently used for surface parking, they generate virtually no utility consumption and therefore contribute negligibly to UUT revenues under existing conditions. Development of the Parking Plaza sites would be expected to increase utility consumption on those sites and, correspondingly, generate new UUT revenues for the City.

The magnitude of that increase would depend on the type and intensity of development.

More intensive uses such as residential buildings, office space, or hotels would generate meaningfully more utility consumption than lighter uses such as a park or open space.

As discussed above, passage of the Ballot Measure is likely to reduce the overall amount and range of development that can occur on the Parking Plaza sites. To the extent the Ballot Measure deters or delays development on these sites, it would correspondingly reduce the incremental UUT revenues that such development would otherwise generate.

Net Impact on City Revenues and Expenditures
Development on the Parking Plaza sites would generate new revenues for the City, as discussed in the preceding section, but would also result in increased demand for municipal services such as police, public works, and parks and recreation. The costs of providing these services would need to be covered under the City’s General Fund annual

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 16 operating budget and are not covered by one-time development impact fees, which are used to cover the capital costs of infrastructure that is needed to serve new development.

Net Fiscal Impacts by Development Type
The net fiscal impact of the Ballot Measure on the City of Los Altos General Fund would depend on whether the Parking Plaza sites are ultimately developed and, if so, how they are developed. The City is currently pursuing residential development on Plazas 7 and 8 and evaluating potential park and parking improvements on Plazas 1, 2, and/or 3, though the ultimate development outcome for these sites remains uncertain even in the absence of the Ballot Measure. The City has not taken action to develop or significantly alter any of the remaining Plazas, though development of those sites could be pursued in the future.

The following sections provide a summary of net fiscal impacts associated with various potential uses that the City could pursue on the Parking Plaza sites.

Net Fiscal Impact of Residential Uses
The net fiscal impact of residential development depends on the valuation of the units and the extent to which the development includes units that are exempt from property tax.

Due to Los Alto’s high residential property values, many market-rate residential units have a positive fiscal impact on the City’s General Fund, generating enough revenue from property tax, sales tax from resident spending, and other sources to offset and, in some cases, exceed the City’s cost to provide municipal services to the associated residents.

Market-rate residential units are also generally profitable enough to support a substantial land acquisition cost, which would generate revenue for the City in the case of a sale or ground lease of any Plaza sites for market-rate residential development.

Because 100-percent affordable housing is typically exempt from property tax, a predominantly or exclusively affordable project generates relatively limited ongoing revenues while still requiring the full range of municipal services, often resulting in a net negative direct fiscal impact on an ongoing basis. In addition, a 100-percent affordable development may not be able to support a land acquisition cost, meaning that this type of development may not generate sale or ground lease revenue for the City if developed on Parking Plaza sites. However, affordable housing can provide indirect fiscal benefits by providing housing opportunities for the local workforce. Workforce housing can help to sustain Los Altos businesses and employers by supporting employee retention and, in turn, strengthening the City's broader revenue base from sources such as property tax, sales tax, and transient occupancy tax.

The overall net fiscal impact of mixed-income housing would depend on several factors, including the share of affordable and market-rate units, the value of the market-rate component of the project, and whether the affordable component is eligible for a property tax exemption. However, given the high value of market-rate residential units in Los Altos, many mixed-income development scenarios would have a positive net fiscal impact on the City’s General Fund.

2026 Ballot Measure Impact Analysis – 9212 Report |1. Fiscal Impacts, Page 17 Net Fiscal Impact of Nonresidential Uses
Nonresidential development often produces a net positive fiscal impact, as workers and visitors typically place lower demands on local services than residents, and uses such as retail, office, and hotel can generate substantial revenues through sales tax, property tax, and transient occupancy tax that more than offset the cost of providing services. Like market-rate residential uses, nonresidential uses developed on the Parking Plaza sites would also typically generate sale or ground lease revenue for the City though the disposition process.

Net Fiscal Impact of a Park or Civic Use
A park or similar civic use is likely to have a negative net fiscal impact on the City’s General Fund, as these uses would not generate property tax revenues and the City could incur ongoing operational and maintenance costs that may not be fully recovered through user fees or other charges. In addition, the City would not sell or lease any Parking Plazas used for these purposes, and therefore a park or civic use would not generate sale or ground lease revenues for the City. At the same time, such uses could generate indirect fiscal benefits by activating Downtown, drawing visitors, and supporting the commercial activity that drives sales tax revenues at nearby businesses. Whether the indirect benefits outweigh the direct costs would depend on the nature of the use, how it is programmed and managed, and the degree to which it succeeds in enhancing Downtown vitality.

Net Fiscal Impacts of the Ballot Measure
On balance, passage of the Ballot Measure is likely to have a negative net fiscal impact on the City's General Fund relative to a scenario in which the Ballot Measure does not pass. By limiting the range of development that can occur without voter approval and introducing additional entitlement risk, the measure would likely deter developers from pursuing projects on these sites or reduce their willingness to offer competitive terms. The uncertainty and additional costs associated with a ballot process would likely be reflected in lower disposition proceeds compared to a scenario in which the measure does not pass, or no proceeds if the City cannot attract a developer with the ability to support a land purchase or ground lease.

Beyond disposition proceeds, the Ballot Measure is also likely to deter or delay development types that could generate net positive ongoing fiscal impacts, such as marketrate residential and nonresidential development. The Ballot Measure's potential effect on the downtown park is somewhat more nuanced: a park would likely have a negative direct fiscal impact but could generate indirect fiscal benefits by drawing visitors to Downtown businesses and supporting the City's broader revenue base.

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 18

2. Planning Impacts
This section reviews the Ballot Measure’s effect on the internal consistency of the City's general and specific plans, the consistency between planning and zoning, and the limitations on city actions under the following California Government Code sections:
• Section 65008 of the Government Code (prohibits discrimination in housing and land use),
• Chapters 4.2, commencing with Section 65913 (addresses the shortage of affordable housing and encourages the development of new housing).

Internal Consistency of the City’s General Plan
California state law requires internal consistency of the General Plan, as well as consistency with zoning and specific plans.6 The Ballot Measure may affect the internal consistency of the City’s General Plan by potentially limiting the attainment of goals, policies, and programs in the Land Use Element, Circulation Element, Open Space, Conservation and Community Facilities Element, Economic Development Element, Natural Environment and Hazards Element, Community Design & Historic Resources Element and Housing Element.

The Ballot Measure would amend the Los Altos Municipal Code to prohibit the City of Los Altos from selling, trading, leasing, donating, disposing or otherwise conveying any parking plaza, or any portion thereof, for any reason without approval by a majority vote of the City’s voters, with certain exceptions.

This section focuses on the Ballot Measure’s relationship with the General Plan’s Land Use Element, Circulation Element, Open Space, Conservation and Community Facilities Element, Economic Development Element, Natural Environment and Hazards Element, and Community Design & Historic Resources Element. The relationship between the Ballot Measure and the Housing Element is discussed in section 3. Housing Impacts of this report.

The Ballot Measure itself passing would not immediately impact these topics and the related General Plan sections as the impact would be determined by a subsequent Ballot Measure for the approval, or not, of any development or any other potential land use intended to further General Plan goals, policies or programs.

The Ballot Measure would potentially limit new development by adding an additional constraint to development on the downtown Parking Plazas. The Ballot Measure would implement additional procedural requirements, which could result in an increase in cost and potential delays. These procedural requirements could complicate the ability to meet goals and policies under the City’s General Plan and implement associated programs. 6 Gov. Code Section 65300.5

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 19 Land Use Element
The existing General Plan includes several goals, policies and programs that support housing and a complementary mix of uses within the Downtown area. By requiring a vote to change land uses in parking plazas, the Ballot Measure may inhibit the Downtown from developing diverse land uses and a more vibrant commercial and residential area, where there is easy access to resources and grocery stores, and other needs. Additionally, the Ballot Measure could create constraints to the development of affordable housing, which is envisioned as part of the mixed-use development in the Land Use Element.

In the Land Use Element, the City has included the following goals, policies, and programs that intend to promote the intensification of land uses in the Downtown to create a more vibrant area with mixed uses, including affordable housing:7 Goal 2: Plan for a compatible and harmonious arrangement of land uses by providing a mix of uses consistent with projected future social and economic conditions in Los Altos.

Policy 2.1: Continue to apply land use designations, which recognize existing development patterns and expected future conditions.

Policy 2.2: Encourage a variety of residential housing opportunities by allowing residential uses with adequate parking in ap­propriate commercial areas, including sections of the Downtown area, Foothill Plaza and along El Camino Real.

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

Policy 3.1: Encourage residential development above the ground floor that includes affordable housing units.

Policy 3.2: Consider zoning code incentives to encourage mixed-use development.

Policy 3.4: Consider amending the zoning code to allow development of three-story buildings in the Downtown Core to encourage construction of be­low market rate housing units.

Program LU 2: Review and amend (as needed) the Zoning Ordinance to provide consistency with new state legislation and court decisions. Consider Zoning Ordinance amendments that implement the use and development of goals, policies, and plan objectives for the identified special planning areas (e.g., Downtown, El Camino Real Corridor, and Foothill Plaza).

Program LU 5: Study and periodically update information on parking needs in the Downtown Core and methods of financing. Implement the recommendations of parking studies and consider the financing opinions for parking plaza improvements.
7 City of Los Altos. (2002, November). Land Use Element. https://www.losaltosca.gov/DocumentCenter/View/538/Land-Use-Element-PDF?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 20 Program LU 6: Consider Zoning Ordinance amendments to increase the maximum density and intensity for residential development above the ground floor consistent with the goals, policies, and plan objectives for the Downtown Core. Ensure that new development and redevelopment is consistent with the Downtown Urban Design Plan.

Economic Development Element
Consistent with the Land Use Element, the Economic Development Element focuses efforts on the development, redevelopment, and intensification of the Downtown core. The Downtown is recognized as one of the seven primary commercial areas within the City of Los Altos. The majority of the primary commercial areas are developed; therefore, future development is focused on upgrading and redeveloping to ensure their continued vitality.

The Ballot Measure potentially impacts the Economic Development Element’s vision and plan to potentially revitalize the Downtown with mixed uses, including a mix of commercial uses. The Economic Development Element includes the following goals, policies, and programs intended to promote the Downtown revitalization with development of mixed uses and upgrades:8
Goal 2: Promote the economic and commercial success of all commercial districts in Los Altos.

Policy 2.1: Promote an optimum mix of commercial uses in existing commercial locations to meet both the shopping needs of residents and fiscal needs of the City.

Goal 3: Increase the attractiveness of Downtown area to shoppers and pedestrians to enhance the economic vibrancy of the area.

Policy 3.1: Improve and seek to eliminate current perceived and real difficulties in finding parking places.

Policy 3.5: Allow mixed-use development with multi-family residential and commercial uses to provide alternative housing opportunities within community.

Policy 3.6: Limit ground floor uses to retail and limited personal services in the Downtown Commercial Retail Sales District, with a special emphasis on retail uses on Main and State Streets.

Policy 3.9: Work to ensure that the Downtown is a clean, attractive and safe area.

Program ED 3: Facilitate economic development of the Downtown as follows: 1) Encourage land use intensification of the Downtown Core for mixed-use development with an emphasis on retail development on the ground floor (especially on Main and State Streets) consistent with the applicable General Plan policies and plan; 2) Work to improve both real and perceived parking issues relative to overall numbers and proximity to businesses; 3) Implement the Downtown Urban Design Plan and Downtown Commercial Retail Sales (CRS) Zoning 8 City of Los Altos. (2002, November). Economic Development Element. https://www.losaltosca.gov/DocumentCenter/View/534/Economic-Development-Element-PDF?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 21 District; and 4) Work with the Los Altos Village Association and Chamber of Commerce to publicize shopping opportunities Downtown.

All the City-owned Downtown parking plazas are within an area with pedestrian-oriented development and design. This area is a commercial core for City of Los Altos with retail and other services. The previously mentioned goals, policies, and programs within the Land Use Element and Economic Development Element encourage mixed-use development with residential units in the Downtown, while preserving the Downtown character and limiting negative parking and traffic impacts. These goals, policies, and programs support the vitality of the Downtown as changes occur throughout the years and support the City’s economic growth. Additionally, these goals, policies, and programs support the City’s vision of creating new housing opportunities, including affordable housing.

The Ballot Measure conflicts with the goals, policies, and programs within the Land Use Element and the Economic Development Element because the Ballot Measure potentially limits multi-family residences, mixed use, and parking structure development, which are developments that would support these goals, policies, and programs. Regulatory constraints can include land use controls, zoning and building codes, fees, exactions, and permit procedures. The Ballot Measure may limit development by adding a constraint to development of City-owned land within the Downtown.

Circulation Element
The Los Altos Circulation Element includes provisions to ensure adequate parking supply is available within the Downtown, to minimize intrusion into adjacent neighborhoods.9 The Circulation Element also highlights that the provision of adequate parking is important for all uses, as it helps with traffic flow. The Circulation Element includes goals, policies, and programs that intend to manage traffic within the City’s commercial areas, including the Downtown, by encouraging the provision of adequate parking:

Goal 5: Provide the appropriate amount of parking in residential neighborhoods and commercial areas to accommodate needs but not to encourage the use of automobile travel.

Policy 5.3: Reduce the amount of on street parking in single-family residential neighborhoods caused by adjacent non-residential and multi-family residential uses.

Policy 5.5: Establish methods for providing for existing and future parking demands in the Downtown and other commercial areas in an economically feasible and aesthetically pleasing manner.

Policy 5.6: Target parking that is close to destinations for short-term (customer) use and target outlying parking (edge of Downtown, but not in neighboring residential areas) for long-term (owner and employee) parking. 9 City of Los Altos. (2002, November). Circulation Element. https://www.losaltosca.gov/DocumentCenter/View/532/Circulation-Element-PDF?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 22 Program C 27: Establish special parking standards as follows: 1) Require on-site covered parking in review of alterations to existing residential structures; 2) Provide for an adequate supply of short-term parking in commercial retail zones; and 3) Regulate commercial parking lots to protect residential neighbors to include times and location of commercial deliveries and garbage collection, overnight parking, and other unauthorized use.

Program C 29: Undertake a study to assess the feasibility of underground/aboveground parking in the Downtown.

Program C 30: Consider establishing traffic impact fees to reduce the impact of new development or redevelopment. Consider parking fees in lieu of providing required parking in the Downtown area to encourage additional housing opportunities.

Program C 31: Consider establishing a parking assessment district to expand Downtown parking and provide parking for other commercial areas.

The goals, policies, and programs above promote increased parking in the Downtown, including underground and above-ground parking, to accommodate existing and future needs for residents and visitors. The Ballot Measure could delay or prevent the City from developing additional parking within the Downtown parking plazas by constraining the City’s ability to evaluate alternative parking configurations, such as parking structures, that may increase the supply of Downtown parking or allow existing parking resources to be used more efficiently.

Natural Environment & Hazards Element
The Natural Environment & Hazards Element is intended to identify and address characteristics in or near the City of Los Altos Planning Area that represents a potential hazard to the community.10 The goals, policies, and programs are intended to protect the quality of life from hazards relating to human activity. The following Natural Environment & Hazards Element goal and policies support air quality within the City of Los Altos:

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

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

Policy 8.2: Encourage transportation modes that minimize contaminant emissions from motor vehicle use.

The goal and policies above support reducing air pollutants to improve air quality within the City of Los Altos. The parking plazas have the potential to promote air quality initiatives through the development of more electric vehicle parking spaces, electric vehicle charging stations, and bicycle parking facilities. The Ballot Measure may limit the ability to develop these additional amenities as it may delay or deny their development. These facilities 10 City of Los Altos. (2002, November). Natural Environment & Hazards Element. https://www.losaltosca.gov/DocumentCenter/View/1767/Natural-Environment-and-Hazards-Element?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 23 would support residents and visitors to use electric vehicles and bicycles, which support the environment by reducing pollutants generated. As a result, the Ballot Measure may preclude the City from reaching its goal of maintaining or improving its air quality.

Open Space, Conservation & Community Facilities Element The Open Space, Conservation & Community Facilities Element is focused on addressing several open space categories including the preservation of natural resources, the managing of production of resources, and the maintenance of open space for public health and safety reasons.11 The Element outlines goals, policies, and programs that seek to protect and maintain natural resources and public services. The following goals, policies, and programs support the City’s initiatives to maintain and provide recreational facilities:

Goal 3: Expand recreation programs and facilities for all ages using City and nonCity sites.

Policy 3.3: Provide and expand continuing support for children and teen facilities and programs.

Policy 3.4: Promote and provide programs and recreation facilities for seniors.

Goal 9: Encourage the provision of cultural facilities and activities within the City.

Policy 9.2: Work with private developers to offer cultural activities within the community, such as a community theater and cinema.

Program OCC 8: Provide a full range of recreational opportunities to serve the community by: 1) Promoting a high level of public outreach by coordinating with community organizations, special interest groups and private businesses to provide recreation program opportunities, and disturbing newsletters or brochures to inform the community of available recreation programs and facilities; 2) Coordinating with other agencies/organizations such as the school districts, Parks, Art, and Recreation Commission, Youth Commission, and other appropriate agencies to achieve maximum utilization of recreation programs and facilities in the community; 3) Facilitating cooperative recreational programming with surrounding jurisdictions to expand opportunities and cost efficiencies; 4) Identifying and evaluating the provision of drop-in, team sports, and other afterschool recreation programs for youth; 5) Involving the Youth Commission in recreational programming for youth and teen center activities; 6) Continuing work with the Hillview Senior Center and Garden House to identify the available programs and facilities for seniors, and looking for ways to augment them where appropriate; 7) Exploring means to provide programs to those who cannot afford to pay by utilizing corporate sponsorships, volunteers and joint use of school facilities and services; and 8) Developing new recreation programs to reflect the changing needs and interests of Los Altos residents.
11 City of Los Altos. (2002, November). Open Space, Conservation & Community Facilities Element. https://www.losaltosca.gov/DocumentCenter/View/540/Open-Space-Conservation-and-Community-FacilitiesElement-PDF?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 24 The Downtown Vision Plan envisions some parking plazas becoming public plazas, where there are recreational activities and public amenities present. This vision is supported by the Open Space, Conservation and Community Facilities Element by promoting recreational activity within the City of Los Altos, including cultural activity. The Ballot Measure may preclude the growth of recreational activity within the City of Los Altos due to potential development delay or denial. Additionally, the Ballot Measure may result in additional procedural requirements, which may increase costs and make projects infeasible.

Community Design & Historic Resources Element
The Community Design & Historic Resources Element highlights that the Downtown will continue to thrive by attracting businesses and encouraging additional restaurants and entertainment venues.12 Additionally, it promotes mixed-use development, the increase in public parking, and the development of affordable housing within the Downtown. The following goals, policies, and programs from the Community Design & Historic Resources Element support an increase in parking, mixed-use development and affordable housing in the Downtown:

Goal 3: Increase the appeal of Downtown to pedestrians and shoppers.

Policy 3.6: Evaluate the public benefit of City-owned parking plazas and the best use thereof, while preserving or increasing public parking Downtown.

Policy 3.8: Encourage the development of affordable housing above the ground floor throughout the Downtown.

Program CDHR 4: Implement the Downtown Urban Design Plan to preserve the unique character and pedestrian appeal of the Downtown by ensuring that future development and redevelopment in the Downtown is consistent with the plan.

The Community Design & Historic Resources Element promotes the preservation of Downtown’s character as redevelopment and new development occurs throughout the years. The goals, policies, and programs within the Element encourage the growth of the Downtown to provide more residential units and additional uses that support a more vibrant area. To support the growth in housing and other uses within the Downtown, the Element promotes an increase in public parking. The Ballot Measure may preclude the increase in new housing, commercial uses, and public parking by potentially creating a constraint. By potentially delaying or denying new development in the Downtown parking plazas, the Ballot Measure would limit the City’s ability to reach its Community Design & Historic Resources Element goals, policies, and programs. 12 City of Los Altos. (2002, November). Community Design & Historic Resources Element. https://www.losaltosca.gov/DocumentCenter/View/533/Community-Design-and-Historic-Resources-ElementPDF?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 25 Internal Consistency of the Downtown Vision Plan
The Downtown Vision Plan provides guidance for growth and development within the Downtown and replaces the Downtown Design Plan.13 The Downtown Vision Plan elements include but are not limited to enhancing economic vitality, developing adequate parking facilities, utilizing the existing parking plazas in a manner that enhances the village character while also meeting other community desires, and expanding the variety of residential housing types.

The Downtown Vision Plan identifies the Downtown parking plazas envisioned as opportunity sites as shown in Figure 2 Existing Parking Plaza Opportunity Sites. The plan envisions Parking Plaza 8 as new affordable housing, Parking Plaza 2 as a new hotel use and live theater, and new office uses for Parking Plazas 1, 3, and 7. Parking consolidation in new parking facilities is envisioned on Parking Plazas 1, 2, and 3 as well as 7 and 8. Parking Plaza 9 is envisioned for new development in support of the Downtown Vision Plan.

Figure 2: Existing Parking Plaza Opportunity Sites14
The Downtown Vision Plan has a short-term vision of focusing initial plaza enhancement efforts on Parking Plaza 5, which is envisioned as a “community living room”. The 13 City of Los Altos. (2018, August 28). Downtown Vision Plan. https://www.losaltosca.gov/DocumentCenter/View/524/Downtown-Vision-PDF?bidId= 14 Ibid.

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 26 “community living room” would have outdoor dining, public seating, trees and landscaping, play structures, restrooms, trash and recycling, and event space. Additional parking opportunities would be needed to offset the loss of parking, which may be a parking structure on Parking Plaza 2 or 3. The long-term vision for the Downtown is to extend the “community living room” to include the existing Parking Plazas 4 and 6 as shown in Figure 3: Downtown Plaza Locations for Long-Term Vision.

Figure 3: Downtown Plaza Locations for Long-Term Vision15 The Downtown Vision Plan also envisions the addition of two public plazas within portions of Parking Plazas 2 and 3, with the construction of a live theater fronting onto 3rd Street, as shown on Figure 4: Locations of Other Downtown Public Plazas. These public plazas are envisioned to have a variety of public amenities including outdoor dining, seating, landscaping, activity nodes, interactive structures, public art, and others. 15 Ibid.

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 27 Figure 4: Locations of Other Downtown Public Plazas16
The Downtown Vision Plan envisions the parking plazas as a focal point for integrating new structured parking within Downtown, with some existing at-grade parking lots maintained.

The above-ground parking facilities should be designed with flexibility for adaptive reuse and with electric vehicle charging stations. The plan envisions these parking facilities to be designed with commercial or office space on the ground floor. As shown on Figure 5:

Location of Future Parking Facilities, the Downtown Vision Plan has located parking facilities to be accessed from San Antonio Road and First Street, which would minimize traffic through Downtown. The plan anticipates the need to construct 1,620 new aboveground and underground parking spaces to accommodate existing development and future growth as envisioned in the Downtown Vision Plan. 16 Ibid.

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 28 Figure 5: Location of Future Parking Facilities17
The Ballot Measure would conflict with the Downtown Vision Plan as it may inhibit new development as envisioned in the plan. The Ballot Measure may result in constraints that limit the ability to develop new housing, parking facilities, public facilities, and mixed-uses.

The Ballot Measure may inhibit the growth and development within the Downtown, which would not support the plan’s goal to support the economic vitality of the City. The Downtown Vision Plan envisions a vibrant Downtown that attracts more businesses, residents, and visitors, which could provide many benefits including more economic growth. To support these new developments, the plan envisions additional parking facilities to improve traffic flow and accommodate the anticipated growth. Such new parking facilities would support electric vehicles with charging stations and may potentially include bicycle parking facilities, supporting air quality initiatives. 17 Ibid.

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 29 Internal Consistency of the Downtown Los Altos Parking Strategy The Downtown Los Altos Parking Strategy is a plan that provides recommendations to proactively address existing and future parking challenges within the Downtown.18 By addressing the parking issues, the plan intends to support the continued success of the Downtown as a place to live and work. The parking management plan strategies within the plan were informed by the feedback received from community members, developers, and other stakeholders.

One of the strategies discussed involves bicycle parking improvements, including shortterm and long-term bicycle parking. By improving bicycle parking within the Downtown, it will make it more convenient to bike to and from the Downtown and reduce the dependency on vehicles, which improves the traffic flow, reduces air pollution, and supports outdoor activity. These bicycle improvements could be implemented in future development within the Downtown, including within parking plazas, which are envisioned to have improvements that could support bicycle parking.

The plan mentions that the Downtown Los Altos Vision Plan envisions increases in development and the conversion of parking plazas into structures. The plan discusses that as the Downtown evolves over time, the parking needs will change and thus the proposed parking strategies should be implemented to address these changes. The plan introduces the strategy of maintaining and upgrading existing parking facilities in the Downtown, including the parking plazas. The upgrades envisioned include underground or structured parking with the inclusion of electric vehicle charging stations with clear signage. By including electric vehicle charging stations in the future development of parking plazas, there will be more support for electric vehicle users, which supports the environment’s air quality.

The parking management strategies outlined in the Downtown Los Altos Parking Strategy were informed by key objectives. The objectives include but are not limited to making the most efficient use of all existing parking resources, ensuring parking facilities adequately accommodate the consistent peak period demand in the Downtown and nearby public parking lots, and support Downtown economic development. By supporting bicycle parking and electric vehicle charging station development in the Downtown, more people will be drawn to area for retail and other uses, which supports the economic development in the Downtown and the air quality. The plan, consistent with the Downtown Los Altos Vision Plan, envisions the conversion of the parking plazas into structures, which could potentially accommodate the growth anticipated from new developments in the Downtown and would support the objectives of increasing the efficiency of existing parking resources and ensuring there is adequate parking facilities for peak period demand.

The Ballot Measure may inhibit the implementation of the parking management strategies outlined in the Downtown Los Altos Parking Strategy, as it could result in the delay or 18 City of Los Altos. (2025, January 13). Downtown Los Altos Parking Strategy. https://www.losaltosca.gov/DocumentCenter/View/1762/Downtown-Los-Altos-Parking-Strategy?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 30 denial of new development on the parking plazas, including the development of electric vehicle charging stations and bicycle parking facilities. The Ballot Measure would conflict with objectives in the Downtown Los Altos Parking Strategy as it could potentially limit the development of any parking facilities on the parking plazas that could support Downtown economic development, make efficient use of the existing parking resources, and ensure that adequate parking facilities accommodate the peak period demand in the Downtown.

Internal Consistency of the Los Altos Complete Streets Master Plan: An Active Transportation Framework
The Los Altos Complete Streets Master Plan: An Active Transportation Framework (CSMP) is a long-term vision for the improvement of walking and bicycling in Los Altos.19 As discussed in the CSMP, the Downtown has many destinations that attract bicyclists, including coffee shops, ice cream shops, restaurants, and retail shopping. The CSMP details that the strategy to attract more bicyclists is to convert automobile parking spaces into Bicycle Corrals. By providing more bicycle parking, more bicyclists are encouraged to travel to Downtown, which supports retail activity and reduces the vehicle miles traveled in the City.

The CSMP recommends increasing bicycle parking, as it can enhance the Downtown activity and support the local economic development. The Ballot Measure may inhibit this initiative as it could delay or deny development of potential bicycle parking within the existing parking plazas or the conversion of automobile parking to bicycle parking, limiting potential Downtown visitors. As a result, the Ballot Measure may inhibit the City’s economic growth.

Internal Consistency of Planning and Zoning
As shown in Figure 6: Parking Plaza General Plan Land Use Designations, the City-owned parking plazas are either in the “Downtown Commercial” or “Public and Institutional” General Plan Land Use Designations. The Downtown Commercial land use designation provides for a wide range of general retail and services, commercial recreation, cultural, and office uses.

The Downtown Commercial land use designation is intended to support higher density residential uses, which supports the village character of the area. The General Plan Land Use Element acknowledges that within the Downtown there is on-street parking available and that most parking is contained within the City-owned and operated parking plazas.

The Public and Institutional land use designation provides governmental, institutional, academic, group residence, church, community service and other similar uses. The Public and Institutional land use designation also provides for City-owned parking facilities. 19 City of Los Altos. (2022). Los Altos Complete Streets Master Plan: An Active Transportation Framework. https://www.losaltosca.gov/DocumentCenter/View/528/Los-Altos-Complete-Streets-Master-Plan-PDF?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 31 Figure 6: Parking Plaza General Plan Land Use Designations20

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 32 These general plan land use designations support community recreational, cultural, and institutional activity. These uses support the General Plan’s vision for a vibrant and active Downtown area. The Ballot Measure may inhibit the development of uses consistent with the General Plan Land Use Designations as it could result in delays or denials of such proposed uses.

As shown in Figure 7: Parking Plaza Zoning, the parking plazas are either located in the “Commercial Retail Sales” (CRS) or “Commercial Downtown” (CD) zoning districts. The Commercial Downtown district permits parking spaces and loading areas.21 The Commercial Retail Sales district permits parking spaces and loading areas incidental to a permitted use.22
20 City of Los Altos. (n.d.). Public GIS Viewer.
https://losaltos.maps.arcgis.com/apps/webappviewer/index.html?id=cc2d724e72af46dda3a03174b51ccd05 21 City of Los Altos. (n.d.). Los Altos Municipal Code: Chapter 14.44 – CD Commercial Downtown District. https://library.municode.com/ca/los_altos/codes/code_of_ordinances?nodeId=TIT14ZO_CH14.44CDCODODI_14.

44.020SPPUCD
22 City of Los Altos. (n.d.). Los Altos Municipal Code: Chapter 14.48 – CRS Commercial Retail Sales District. https://library.municode.com/ca/los_altos/codes/code_of_ordinances?nodeId=TIT14ZO_CH14.48CRCORESADI_1

4.48.020VISTSPPUCR

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 33 Figure 7: Parking Plaza Zoning23

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 34 The CRS District’s primary characteristics include but are not limited to a mix of uses, a pedestrian-oriented shopping environment that encourages social interaction, and activities that enhance and extend commercial vitality. The CD District’s purpose includes but is not limited to retaining and enhancing the downtown Los Altos village atmosphere, providing pedestrian amenities, and providing retail, office and service uses.

The parking plaza zoning districts promote the enhancement and commercial vitality of the Downtown. They support a variety of uses including retail, office, and service uses, which supports the City’s economic development and encourages social activity. The Ballot Measure may inhibit the growth of the social activity and economic development that the zoning districts are promoting by creating a constraint on parking plaza development.

Effect on the Use of Land
The Ballot Measure may have impacts that could restrict land use allowances and the ability of the property owner (the City) to follow Surplus Land Act requirements.

Specifically, the Ballot Measure proposes a new section 14.92.030 Preservation of Parking Plazas that could have several impacts that would complicate the conveyance of the property:

1. Sell, trade, lease, donate, dispose or otherwise convey any Parking Plaza, or any portion thereof, for any reason.

This section provides that the selling, trading, leasing, donating, disposing, or conveyance of Parking Plazas, or any portion thereof, would require a subsequent ballot measure. This section could impact the City’s ability to implement the General Plan and other applicable plans.

2. Designate or change the use of any Parking Plaza in any way which would affect the use of the Parking Plazas for parking or which would diminish the availability, access or convenience of public parking.

This section provides that a subsequent ballot measure is required prior to the designation or change in use of the Parking Plazas from the existing parking use. This may impact the City’s ability to implement other uses as envisioned in the Downtown Vision Plan.

3. Declare any Parking Plaza “surplus land” or “exempt surplus land” under the California Surplus Land Act (Government Code sections 54220 et seq.).

This section would require a subsequent ballot measure following any City determination that the Parking Plazas are exempt surplus land or surplus land pursuant to the Surplus Land Act. This section may impact the ability to develop affordable housing on the Parking Plazas, except for Parking Plazas 7 and 8, which are allowed to develop affordable housing without a vote requirement.
23 City of Los Altos. (n.d.). Public GIS Viewer.
https://losaltos.maps.arcgis.com/apps/webappviewer/index.html?id=cc2d724e72af46dda3a03174b51ccd05

2026 Ballot Measure Impact Analysis – 9212 Report |2. Planning Impacts, Page 35

4. Modify, alter or construct any capital project or other physical alteration on any of the Parking Plazas which permanently diminishes the availability, access or convenience of public parking.

This section provides that a subsequent ballot measure is required prior to the modification, alteration or construction of any capital project or other physical alteration on any Parking Plaza which would permanently diminish the availability, access or convenience of public parking. This section would potentially limit the development and improvements of the Parking Plazas as envisioned in the General Plan and other applicable plans.

5. Modify or physically alter any Parking Plaza by adding additional levels or floors.

This section provides that a subsequent ballot measure is required prior to the modification or physical alteration of any Parking Plazas through the addition of levels or floors. This section would potentially impact the development of any structures on the Parking Plazas as envisioned in the General Plan and other applicable plans.

6. Modify or physically alter any Parking Plaza in a way which would negatively affect protected trees or the tree canopy.

This section provides that a subsequent ballot measure is required prior to the modification or alteration of any Parking Plaza which would negatively affect protected trees or the tree canopy. This section would potentially impact the City’s ability to develop on the Parking Plazas.

Internal Consistency of Climate Action & Adaptation Plan The Climate Action and Adaptation Plan (CAAP) assesses the impacts of Los Altos on the climate, how Los Altos can reduce its impact, and how it can adapt to climate change.24 Based on the current and forecasted greenhouse gas emissions, implementation of the previous 2013 Climate Action Plan, and guidance received, the CAAP is based on pursuing a goal of Carbon Neutrality by 2035. To help the City of Los Altos reach its carbon neutral goal, greenhouse gas mitigation strategies were developed. Mitigation strategies include reducing single-occupancy vehicle travel, electrifying transportation, and supporting a green community. These mitigation strategies could be achieved through the development of new bicycle parking, new electric vehicle parking spaces and charging stations, and increasing the urban tree canopy.

The Ballot Measure could inhibit several of the mitigation measures identified to support the goal of Carbon Neutrality by 2035. New bicycle parking, electric vehicle parking, and electric vehicle charging stations could be potentially developed in the City-owned parking plazas; however, the Ballot Measure may preclude this from occurring by delaying the process or denying it. The Downtown parking plazas are areas that could support the CAAP 24 City of Los Altos. (2022). Climate Action & Adaptation Plan. https://www.losaltosca.gov/DocumentCenter/View/527/Los-Altos-Climate-Action-and-Adaptation-PlanPDF?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |, Page 36 goals by implementing development that supports the City’s sustainability growth and reduces greenhouse gas emissions. The parking plazas are also areas where new landscaping and trees could be planted as part of new developments, which could help improve air quality. The addition of landscaping and trees could also be inhibited by the Ballot Measure as it would require more steps for approval and may result in denial. This constraint to more sustainable improvements may delay the City from reaching its CAAP goals.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 37

3. Housing Impacts
The Ballot Measure would impact the internal consistency of the City’s 6th Cycle Housing Element and may inhibit the City’s ability to meet its housing goals.

The City of Los Alto’s useable land area is 3,846 acres (approximately six square miles), as shown in Table 2: Land Use Designations. Parking Plazas 1, 2, and the southern half of Parking Plaza 3 are designated as Downtown Commercial, while Parking Plazas 4 through 10 along with the northern half of Parking Plaza 3 are designated as Public and Institutional land use. As shown in the table, the Ballot Measure addresses a subset of approximately 155 acres (4 percent) of the combined Downtown Commercial and Public and Institutional land area. The Downtown Parking Plazas account for about 8 acres (0.2 percent) in the City.

Table 2: Land Use Designations25
Land Use Designation Acres Percentage of
Land in City
Percentage of Land
Where Housing is
Allowed in City
Single-Family Large Lot 429 11% 12%
Single-Family Medium Lot 2,598 67% 71%
Single-Family Small Lot 83 2% 2%
Low Density Multi-Family 34 1% 1%
Medium Density Multi-Family 45 1% 1%
Neighborhood Commercial 37 1% 1%
Thoroughfare Commercial 59 1% 2%
Downtown Commercial 42 1% 1%
Public and Institutional, Utilities, Parking 113 3% 3%
Public and Private School Land 154 4% 4%
Open Space (Parks and Others) 220 6% N/A
Planned Community 93 2% 2%
TOTAL 3,846 ac. 100% 94%
(3,626 ac.)
While the Downtown Parking Plazas are 8 acres, a small subset of the 155 acres (Downtown Commercial and Public and Institutional, Utilities, Parking) noted in the table, the City has 25 City of Los Altos (November 2002). General Plan Land Use Element. Information adapted from Table LU-3, Page

14.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 38 identified them as significant sites for developing affordable housing in the Downtown Vision Plan26 and 6th Cycle of the Housing Element27 for a variety of reasons, including:
• The City owns these Downtown Parking Plazas, allowing the City to mitigate the cost of land to implement City housing goals. The City has identified the cost of land as a significant market-related constraint for developing more housing. • The parking lots are in Los Altos’ downtown, a highest resource area with commercial amenities and a VTA bus transit line along San Antonio Road. • Addition of new housing within these parking lots would infuse the Downtown with additional residents and enhance the vitality of both daytime and nighttime activity.

In addition, the City has noted in the Downtown Los Altos Parking Strategy28 that parking policies are linked to the financial feasibility of future housing development in Downtown Los Altos.

Since Los Altos does not have much available vacant land, nonvacant sites comprise a substantial portion of the sites inventory of the City’s 6th Cycle Housing Element. Nonvacant parcels were chosen based on a ratio of their improvement value to their land value and screened to ensure their existing use did not present an impediment to residential development as described in the Site Inventory and Methodology appendix in the 6th Cycle Housing Element.29 The sites inventory include all the Downtown Parking Plazas, which are identified as key opportunity sites to accommodate new market-rate and affordable housing. The Downtown Vision Plan,30 Downtown Los Altos Parking Strategy Plan,31 and Housing Element have all identified Parking Plazas 7 and 8 as opportunity sites for affordable housing developments.

Ballot Measures and Land Use
Future land use decisions involving the parking plazas will be constrained by the Ballot Measure because regulations implemented by ballot can only be changed with another ballot measure. Cities that have passed similar Ballot Measures experience very few, if any, attempted subsequent ballot measures to change land uses due to long time frames, 26 City of Los Altos. (August 28, 2018). Downtown Vision Plan. https://www.losaltosca.gov/DocumentCenter/View/524/Downtown-Vision-PDF 27 City of Los Altos. (Revised August 2023). 6th Cycle Housing Element 2023-2031. https://www.losaltosca.gov/DocumentCenter/View/286/6th-Cycle-Los-Altos-Housing-Element-2023-to-2031- PDF.
28 City of Los Altos. (January 13, 2025). Downtown Los Altos Parking Strategy. https://www.losaltosca.gov/DocumentCenter/View/1762/Downtown-Los-Altos-Parking-Strategy?bidId= 29 City of Los Altos. (Revised August 2023). “Appendix B: Sites Inventory & Methodology.” 6th Cycle Housing Element 2023-2031, pp. 122-169. https://www.losaltosca.gov/DocumentCenter/View/286/6th-Cycle-Los-AltosHousing-Element-2023-to-2031-PDF. 30 City of Los Altos. (August 28, 2018). Downtown Vision Plan. https://www.losaltosca.gov/DocumentCenter/View/524/Downtown-Vision-PDF 31 City of Los Altos. (January 13, 2025). Downtown Los Altos Parking Strategy. https://www.losaltosca.gov/DocumentCenter/View/1762/Downtown-Los-Altos-Parking-Strategy?bidId=

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 39 significant expense and uncertain outcomes. In a March 2024 research paper, the San Francisco Bay Area Planning and Urban Research Association (SPUR) noted that:32 [Ballot] measures curb urban sprawl and protect open space by limiting new developments to infill locations. But without concurrent incentives to promote infill development — that is, development of vacant or underutilized land in alreadydeveloped areas — many of the measures have the potential to limit the supply of housing overall.

Moreover, other growth management ballot measures that have passed within city boundaries, such as zoning restrictions, voter approval requirements, height and bulk limits, and infrastructure provisions or parking requirements, have had a direct negative impact on infill housing production.

San Francisco Bay Area Planning and Urban Research Association (SPUR) points out that “most voter approval requirements aim to enshrine zoning approval in the hands of the local citizenry and to lengthen the approval process to discourage growth.”33 The study specifically referenced Costa Mesa’s Measure Y (requiring voter approval for development projects exceeding 40 dwelling units) and Escondido’s Measure S (required voter approval of many types of changes to the General Plan).

In these cases, the cities mitigated the earlier ballot measures, either through putting a new measure on the ballot years later or by directly referencing overriding State law. In the City of Alameda, whose Measure A set a maximum density throughout the City, HCD eventually issued a letter stating that the voter initiative was in direct violation of state law.34
Recently in 2024, Eureka citizens put Measure F on its local ballot, which would both “Require the City to maintain current levels of public parking on specified downtown Cityowned off-street public parking lots” and rezone a school district site for additional affordable housing.35
In a letter to the City of Eureka,
36 HCD noted that any amendments to the housing element due to the local measure would require HCD review and could lead to a finding of 32 Emma Jordan. (2024). Planning by Ballot. SPUR. https://www.spur.org/sites/default/files/2024- 03/SPUR_Planning_by_Ballot_0.pdf. Page 3
33 Ibid., Page 10
34 Paul McDougall. (Nov. 29, 2021). “RE: City of Alameda Measure A Provisions and Housing Element Compliance.” California Dept. of Housing and Community Development. https://www.hcd.ca.gov/communitydevelopment/housing-element/docs/alaalamedacity-ta-112921.pdf 35 People of the City of Eureka. (July 21, 2023). City of Eureka Housing for All and Downtown Vitality Initiative. https://www.eurekaca.gov/DocumentCenter/View/5340/23-7-21-Eureka-HFA-DV-Initiative.

For additional context on the discussions behind the measure, see Ben Christopher. (July 25, 2024). “Ballot battles, lawsuits and a ticked off millionaire: What’s behind Eureka’s parking lot war?” Cal Matters. Available at https://calmatters.org/housing/2024/07/eureka-affordable-housing-parking/ 36 Melinda McCoy. (October 9, 2024). “RE: Adopted Housing Element Revision Process – Letter of Technical Assistance.” California Dept. of Housing and Community Development.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 40 noncompliance. Such a finding could lead to consequences such as ineligibility or delay in receiving certain state funds, losing local land use authority, application of “Builder’s Remedy” provisions of the Housing Accountability Act to certain qualifying housing development projects, and/or more. At the November 5, 2025, election, Eureka’s Measure F was defeated.37 It remains unclear whether Measure F would have led to the finding of noncompliance for the City.

While Los Altos’ Ballot Measure does not include any explicit amendments to the City’s 6th Cycle Housing Element, the Ballot Measure imposes additional development constraints on all ten Parking Plazas, which have been identified as housing sites in the Housing Element.

The Ballot Measure does not directly restrict the fulfillment of the schedule of programs within the Housing Element, because the Ballot Measure includes an exception in Section

14.92.050 that would have otherwise restricted implementation of Program 1.H of the Housing Element:

Notwithstanding section 14.92.030, the City may take the following actions with respect to the Parking Plazas without a vote of the People:
[…]

3. Develop Parking Plaza 7 (APN: 16739032) and Parking Plaza 8 (APN:16739007) for affordable housing.

However, the Ballot Measure would introduce additional procedural steps to developing housing on housing sites identified in the Housing Element, which could lead to the 6th Cycle Housing Element being inconsistent with State laws.

Consistency with State Laws
The Ballot Measure could be interpreted as leading the City to be in violation of state law, especially the Housing Crisis Act of 2019 (enacted via SB 330) and No Net Loss Law (Government Code Section 65863).38
SB 330
Senate Bill (SB) 330 established the Housing Crisis Act of 2019, which prohibits a local jurisdiction from imposing standards or regulations that would change the land use designation or zoning of identified housing sites to a less intensive use or reduce the intensive of land use within an existing zoning district than what was allowed under the General Plan or a specific plan. This law also applies to an electorate exercising its local initiative or referendum power, such as in the case of this Ballot Measure. https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/eureka-ta-he-compliance100924.pdf 37 Information on the results of the voting are available at Ballotpedia:
https://ballotpedia.org/Eureka,_California,_Measure_F,_General_Plan_Amendment_Initiative_(November_2024) 38 California Government Code Section 65863

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 41 The Ballot Measure provides an exception to allow for housing developments on Parking Plazas 7 and 8. However, the Ballot Measure would introduce an additional procedural step for developing housing on any of the ten Parking Plazas, imposing new constraints or reducing the effective development capacity of housing sites identified in the 6th Cycle of the Housing Element. This action could be evaluated under SB 330 as an action that limits housing development, leading to inconsistencies with State law.

YIMBY Law, a housing advocacy organization, wrote a letter to Los Altos City Council on June 4, 2026, advocating the City submit a SB 330 preliminary application for housing on the Parking Plazas (see Attachment B). An SB 330 preliminary application could serve to establish vesting rights in a development proposal before the Ballot Measure is put in front of voters. While the letter advocates for a preliminary application to promote compliance with the City’s Housing Element programs, it could serve to inflame a sensitive process.

The letter references Article 34 of the California Constitution, which allows legal challenges to governments developing affordable housing. However, Article 34 does not require voter approval for a specific project but rather allows a jurisdiction to authorize a maximum number of affordable units to be built or acquired (with this decision coming later).

No Net Loss
In addition, the Ballot Measure would impact the City’s ability to comply with No Net Loss law. Since all the Downtown Parking Plazas were identified as housing sites for moderate and above-moderate income housing developments, the Parking Plazas contributed to meeting City’s RHNA needs in the 6th Cycle Housing Element. The Ballot Measure would create additional constraints for housing developments on the Parking Plazas, reducing the likelihood of developing housing on the identified housing sites at the assumed densities, losing credited site capacity to achieve the City’s RHNA goals.

Responding to Any Identified Inconsistencies
Both SB 330 and No Net Loss law restrict the City’s ability to reduce housing capacity through zoning amendments or individual project approvals. The Ballot Measure could reduce housing capacity through either pathway, leading to a conflict between a local ordinance and State law.

If the Ballot Measure passes successfully, the City may need to make findings within 180 days to show that the additional constraint is consistent with the adopted General Plan and assess whether the remaining sites in the inventory are still adequate to accommodate the City’s full share of regional housing need at every income level. If the remaining inventory falls short in any income level, the City will need to identify and make available additional sites to cover the shortfall created by the Ballot Measure.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 42 Internal Consistency of 2023-2031 (6th Cycle) Housing Element The certified 6th Cycle Housing Element39 includes a policy framework to guide the City in successfully producing a variety of housing types, including affordable housing, during the period from 2023-2031. The City’s Regional Housing Need Allocation (RHNA) is 1,958 units, of which 789 are for lower income households. The Ballot Measure would be inconsistent with or impact the following Housing Element policies and programs:

Policy 1.2: Mixed-Use Development. The City will encourage mixed-use development in designated zoning districts.

Program 3.F: Reduce Conditional Use Permit requirement for residential mixed-use and multi-family. To facilitate housing, the City will amend the Zoning Code to allow the following as permitted uses (and no longer requiring a conditional use permit):
• Residential mixed-use in the CN, CD, CRS, CT, and CRS/OAD districts; and • Multi-family in appropriate areas of mixed-use districts (e.g., not on the ground floor, etc.).

The Ballot Measure would increase the timeframes for mixed-use developments on the Downtown Parking Plazas identified as opportunity sites in the Housing Element, impacting the ability for the City to encourage mixed-use developments to support downtown businesses. For more information on the business impacts, see Chapter 5 “Business Impacts.”
Program 1.A: Rezone for RHNA shortfall. To accommodate the remaining above moderate-income RHNA of 19 units, the City will identify and rezone sufficient vacant land or land with redevelopment potential to provide capacity for this shortfall. Appendix B (Sites Inventory and Methodology) identifies potential parcels for rezoning to address this shortfall and provide excess capacity throughout the planning period. Separate programs detail specifics of various rezoning actions that would provide additional capacity for all income levels.

The Downtown Parking Plazas are identified as opportunities parcels to accommodate moderate- and above moderate-income RHNA. The Ballot Measure would impact the City’s ability to use the Parking Plazas to address its RHNA, which could lead the City to review the site inventory and reevaluate the shortfall in the above moderate-income category to ensure that there are still adequate opportunity sites and potential sites for rezoning to meet RHNA goals.

Program 1.H: Facilitate housing on City-owned sites. The City will facilitate development of housing on City-owned sites through public-private partnerships during the planning period. City-owned Downtown Parking Plazas 7 and 8 were identified as opportunity sites that could accommodate new development, including affordable housing. The first RFP issued by the City for housing on either Parking 39 City of Los Altos (Revised August 2023). City of Los Altos 6th Cycle Housing Element. https://www.losaltosca.gov/DocumentCenter/View/286/6th-Cycle-Los-Altos-Housing-Element-2023-to-2031-PDF

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 43 Plaza 7 or 8 will be affordable housing and the City will commit to selecting the development proposal that maximizes public benefit in creating additional affordable housing in Downtown Los Altos. Prior to the RFP issuance, the City shall hire a third-party to analyze what the minimum financially feasible affordable housing production could be, based upon a minimum of 20 years of a zero-cost land lease and a commitment to provide a minimum 55-year lease. In the event the development is 100 percent affordable as defined by law, the City shall waive all applicable development impact fees per Program 2.C. The City will comply with all Surplus Land Act requirements. The City will provide a dedicated project planner to facilitate an expedited project review process.

The Ballot Measure would directly impact the City’s ability to fulfill this program. While the Ballot Measure grants an exception for the development of affordable housing on Downtown Parking Plazas 7 and 8, it can inhibit the City’s ability to provide incentives for affordable housing developers. The addition of governmental constraints could delay the timeline identified in this program, which is discussed in greater detail below.

Program 1.I: Incentivize Downtown lot consolidation. In certain portions of Downtown, particularly along Main Street and State Street, the presence of small lots, fragmented ownership pattern, and lack of ability to provide on-site parking may constrain future development. Considering other programs addressing governmental constraints (see programs under Goal 3), the City will evaluate and adopt (through the Zoning Code or by resolution, as appropriate) complementary incentives to further encourage lot consolidation in Downtown. This will include expedited application processing, reduction in application fees, reduction in permit fees, or other incentives. The City will promote the lot consolidation incentives on the City’s website, through regular updates at the Planning Commission and City Council public meetings, and at the developer’s roundtable (see Program 2.C).

Additionally, Policy 3.7 in the Community Design & Historic Resources Element of the General Plan will be modified for consistency with this Program.

The Ballot Measure would directly impact the City’s ability to modify or alter the Downtown Parking Plazas along with their ability to convey the sites for any purpose. While the City can continue to offer complementary incentives through the Zoning Codes or by resolution to encourage lot consolidation, the Ballot Measure sets governmental constraints on the process, which could impact the City’s ability to encourage lot consolidation. If passed, the Ballot Measure could delay the timeframe identified in this program.

Program 1.J: Produce annual housing status reports. Provide an annual status report to the City Council and California Department of Housing and Community Development (HCD) on the status of the General Plan housing programs and their implementation as required by State law. This status report will also address no net loss requirements as necessary throughout the planning period.

The Ballot Measure would serve as a new governmental constraint that could restrict of delay housing development and the implementation of Housing Element programs,

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 44 specifically Housing Element Program 1.H. If the Ballot Measure passes, this program would direct City staff to evaluate the additional constraints and potentially make recommendations for revisions to the Housing Opportunity Sites in the annual housing status report. City staff would also need to determine whether the additional constraints impact the City’s ability to meet the no net loss requirements.

Policy 2.1: New Affordable Housing Units. The City will facilitate the development of new affordable housing units.

The City has identified the City-owned Downtown Parking Plazas as Housing Opportunity Sites for developing affordable housing, especially in relation to Housing Element Program

1.H. The Ballot Measure would present a constraint for developing affordable housing units downtown, which could impact the City’s ability to meet its RHNA goals.

Program 2.C: Assist in securing funding for affordable housing projects. To promote the development of affordable housing projects, and when requested by the project sponsor, the City will continue to assist in securing funding for low- and moderate-income housing developments through the following actions (all of the incentives below are currently in place except for providing funding for multijurisdictional housing finance programs and partnering with nonprofit housing developers):
• Apply for State and federal funding on behalf of a nonprofit, under a specific program to construct affordable housing including persons with physical disabilities or developmental disabilities.
• Provide financial incentive waiving City fees for 100 percent affordable housing projects.
• Provide a dedicated project planner for 100 percent affordable housing projects.
• Transfer the City’s annual CDBG allocation to the County for projects that serve the Los Altos community.
• Allocate a portion of CDBG funds toward affordable housing development. • Provide funding to participate in a multi-jurisdictional housing finance program (such as a Mortgage Revenue Bond or Mortgage Credit Certification Program). The City will continue to coordinate with Santa Clara County and other agencies on multi-jurisdictional housing finance programs. • Partner with nonprofit housing developers to facilitate the development of affordable housing.
• Impact fees associated with the development of Below Market Rate Units shall be set at a proportional rate in line with the level of affordability of each unit. This will result in a reduction in impact fees collected in association with the development of Below Market Rate Units.

The City will also promote incentives through outreach to developers, specifically by hosting a developers roundtable annually to inform developers of available incentives and encourage affordable housing development.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 45 The Ballot Measure would impact the City’s ability to encourage and facilitate the development of below-market-rate housing units because it presents an additional governmental constraint to developing affordable housing on Housing Opportunity Sites that the City had initially identified in the site inventory. Despite the various incentives for facilitating affordable housing, the Ballot Measure could impact the development of affordable housing in the short term. The Program sets a timeframe to develop at least 80 below-market-rate units by January 2031, with a mid-cycle checkpoint in January 2027 to determine if the City is on track to meet the objective. If the Ballot Measure passes and inhibits the development of below-market-rate housing before the mid-cycle checkpoint, the City may need to evaluate and establish additional incentives for developers.

Program 3.A: Prepare a Downtown parking plan and update citywide parking requirements. To address all parking constraints, the City will analyze and update parking requirements citywide and implement a Downtown parking plan. This effort will include the following:
• Assess parking demand, requirements, and strategies in the Downtown and citywide.
• Identify approaches to address short and long-term parking needs considering innovative parking design and strategies that support efficient use of land.
• Reflect that the City will support consolidation of City-owned parking plazas. • Prepare a Downtown parking plan and modify parking requirements to reflect this plan and reflect ensuring that overflow parking does not spill over into adjacent residential only districts.
• Consistent with AB 2097, the City will update its parking regulations to remove minimum parking requirements on any residential, commercial, or other development projects within one half mile of public transit (as defined in AB 2097) unless required findings are made as specified in State law. The City will map eligible properties consistent with AB 2097 and will apply current State law even before local amendments are adopted (AB 2097 is effective January 1, 2023).
• Amend the City’s parking requirements citywide based on the assessment’s findings. This will include reducing parking ratios (as noted above), eliminate guest parking requirements for multi-family housing; offering further reduced ratios for properties participating in a public parking district; establishing further reduced parking ratios for single-room occupancy units, senior housing, housing for persons with disabilities, deed-restricted affordable housing, etc. (e.g., 0.5 spaces per unit); providing more flexibility related to the underground parking requirement by allowing covered parking instead of requiring undergrounding; offering other alternatives to comply with parking requirements; and modifying the required parking design dimensions (e.g., parking stall and lane dimensions) so that less land area is

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 46 required to be dedicated to parking while providing safe vehicle movement as approved by the City’s Engineering Division.

The City has already prepared a Downtown Los Altos Parking Strategy which was adopted on January 13, 2025, which includes parking strategies and regulatory changes to support more efficient usage of the Downtown Parking Plazas. The Ballot Measure would directly impact the City’s ability to implement the strategies developed in the Downtown Los Altos Parking Strategy. Since the Ballot Measure would limit the City’s ability to modify, physically alter, or convey the parking lots for any use, the City would need to evaluate the strategies that were prepared in the Parking Strategy and determine their feasibility. The Ballot Measure would also impact the City’s time frame for implementing the Downtown Los Altos Parking Strategy, which could impact the businesses in the downtown.

Policy 6.1: Promote Equal Opportunity. Promote governmental efforts to provide equal opportunity housing for existing and projected demands in Los Altos, including the creation and management of waitlists for below-market-rate ownership and rental units.

The Ballot Measure could impact the City’s ability to provide equal opportunity housing throughout the City. As the Ballot Measure creates additional governmental constraints for developing housing in the Downtown Parking Plazas, developers may choose to develop in other parts of the City which may not be highest resource or be near public transit and major transportation corridors. Affordable housing developments may be allocated to other parts of the City that are less suited but present fewer constraints, inhibiting equal opportunity housing.

Policy 6.3: Promote Community Involvement in Housing Efforts. Promote representative citizen participation in the implementation of housing programs.

The Ballot Measure would provide a direct method for citizens to participate in the implementation of housing programs on the Downtown Parking Plazas via voting on ballot measures during Citywide elections.

Program 6.C: Target housing development in highest resource areas. The City will outreach to property owners of housing sites in the highest resource areas including areas of the city with higher TCAC Education and Environment scores. In this outreach, the City will provide written material to property owners of identified sites describing potential residential capacity for the site, available incentives, including density bonuses and available funding. The City will disseminate this information on its website.

The Ballot Measure could impact the City’s ability to encourage housing developments within a highest resource area. The downtown area is a highest resource opportunity area according to the California Tax Credit Allocation Committee (TCAC), due to the amenities and adjacency by a VTA bus line that runs on San Antonio Street. The Ballot Measure would create a governmental constraint for developing housing units downtown. Since Los Altos

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 47 is generally built out, developers would have fewer potential sites to develop affordable housing, which could impact the City’s ability to meet its RHNA goals.

Program 6.G: Housing Mobility. Housing mobility strategies consist of removing barriers to housing in areas of opportunity and strategically enhancing access (Los Altos is entirely highest resource in terms of access to opportunity and a concentrated area of affluence). To improve housing mobility and promote more housing choices and affordability throughout Los Altos, including in lower-density neighborhoods, the City will employ a suite of actions to expand housing opportunities affordable to extremely low, very low-, low-, and moderate-income households. Actions and strategies include:
• Rezoning – Modify zoning to allow residential or increased residential intensity and/or density of residential throughout Los Altos. This includes zoning amendments along higher intensity corridors (e.g., El Camino Real, San Antonio Road, and Foothill Expressway) and for sites within lowerdensity neighborhoods (e.g., Loyola Corners Specific Plan, OA zoned sites on Altos Oaks Drive, and church sites on Magdalena Avenue). See Programs 1.B,

1.C, 1. D, 1.E, and 1.F.
• Housing on City Sites – Enter into a public-private partnership to develop housing, targeting low-income households, on City-owned Downtown Parking Plazas. See Program 1.H.

The Ballot Measure creates an additional constraint to developing housing on the Downtown Parking Plazas. In addition, the Ballot Measure could impact the City’s ability to facilitate housing on City-owned parking lots, which could impact the City’s objective of providing 150 housing opportunities affordable to lower income households by January 2031. If the City is not on track to meet this objective by 2027, the City may consider alternative land use strategies and zoning code amendments to improve housing mobility.

Housing Element Program 1.H Facilitate Housing on City-Owned Sites As previously stated, while the Ballot Measure grants an exception for the implementation of Housing Element Program 1.H, Facilitate Housing on City-Owned Sites, the Ballot Measure could still impact the financial feasibility of developing affordable housing on Parking Plazas 7 and 8.

The Downtown Los Altos Parking Strategy includes an Economic and Financial Feasibility Assessment40 to assess the relationship between parking requirements and housing developments in Downtown Los Altos. The assessment focused on the financial feasibility of parking policies introduced within the strategy
Developers build on-site parking in response to resident demand, but as parking typically generates less revenue compared to housing units, developers can be understood to be 40 City of Los Altos. (January 13, 2025). “Economic and Financial Feasibility Assessment Memorandum.” Downtown Los Altos Parking Strategy, pages 59-64.
https://www.losaltosca.gov/DocumentCenter/View/1762/Downtown-Los-Altos-Parking-Strategy?bidId=.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 48 incentivized to provide as little parking as possible, or to investigate parking alternatives such as parking-in-lieu fees. There are strong demand and expectation for on-site parking due to the high costs of housing that is typically built in Los Altos, leading to developers being unlikely to reduce on-site parking ratios, regardless of whether minimum parking requirements exist to meet market demand. However, housing developers are willing to explore alternative parking arrangements or use a parking-in-lieu fee based on the fee amount to net project revenue.

There are other unique considerations for affordable housing projects because parking demands are driven less by market demand and more by tenants who need to access their jobs. The City of Los Altos has determined that affordable housing developers will likely require significant local funding contributions to pursue projects in Downtown Los Altos.41 In addition, they may be receptive to alternative options to on-site parking such as designating parking spaces in nearby parking garages or other measures funded with a parking-in-lieu fee.

While the Ballot Measure provides an exception for the development of affordable housing on Parking Plazas 7 and 8, it may constrain the City’s ability to explore the parking strategies proposed within the Downtown Los Altos Parking Strategy. The Ballot Measure prevents the City from designating any other portion of the Parking Plazas for affordable housing as it would diminish the availability, access, or convenience of public parking. The Ballot Measure also restricts the modification or physical alteration of any Parking Plazas to add additional levels or floors, inhibiting the construction of parking garages on any of the existing surface lots. Since the Ballot Measure restricts the City’s options in providing costeffective alternatives to on-site parking for affordable housing developments, developers may feel reluctant to pursue affordable housing projects on Parking Plazas 7 and 8.

The requirement to secure voter approval would not necessarily make development on Downtown Parking Plazas impossible to achieve, but it would create a significant constraint to affordable development as identified in Program 1.H. While the City has a surplus of parcels to develop housing citywide, the Downtown Parking Plazas are counted for a significant portion of units for reaching the City’s RHNA goals.

If the Ballot Measure creates a substantial constraint on housing development in the Downtown, HCD may require the City to evaluate whether the measure introduces new governmental constraints that affect implementation of the City’s certified 6th Cycle Housing Element. If, after review, HCD determines that the Housing Element is no longer in compliance with State law, it may require the City to amend the Housing Element or take other corrective actions to restore compliance. A finding of noncompliance could result in consequences such as reduced access to state funding, loss of local land use authority, and exposure to qualifying “Builder’s Remedy” projects.

According to Government Code section 65400, the City must provide an annual progress report to monitor and report on the results of their implementation of Housing Element 41 Ibid., pages 63-64

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 49 programs. In addition, Government Code section 65595, subdivision (i) grants HCD authority to review any action or failure to act by a local government that it determines is inconsistent with an adopted housing element or housing element law. This includes failure to implement program actions included in the City’s Housing Element. HCD may revoke the housing element compliance if the local government’s actions do not comply with state law.

YIMBY Law submitted a second letter to the Los Altos City Council on June 15, 2026, stating that the Ballot Measure could create several grounds for challenging the validity of the City’s Housing Element and could expose the City to Builder’s Remedy projects. The letter further advises that YIMBY Law is prepared to sue the City immediately if the measure is adopted, creating significant, immediate, and ongoing legal implications for the City. Such litigation could involve claims related to Housing Element Law, the Housing Accountability Act, the Permit Streamlining Act, and, where remedies require environmental review, potentially CEQA (see Attachment C).

Effect on Regional Housing Need Allocation (RHNA)
The 6th Cycle Housing Element must demonstrate adequate capacity for 1,958 new housing units for the 2023-2031 time period. Cities that cannot demonstrate meeting or exceeding their housing requirements during the eight-year planning period may risk not having their housing element certified by HCD. As shown in Table 3: 6th Cycle RHNA Allocation for Los Altos and Site Inventory Summary, Los Altos’ 6th Cycle Housing Element planned for 1,958 units along with a surplus of 640 units accounting for potential sites for rezoning.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 50 Table 3: 6th Cycle RHNA Allocation for Los Altos and Site Inventory Summary42 Income
Category: Very Low Low Moderate Above Moderate Total
0-50% AMI 51-80% AMI 81-120% AMI >120% AMI
6th Cycle
RHNA 501 288 326 843 1,958
Percent 25% 15% 17% 43% 100%
LowerIncome
Units
789
Approved/
Entitled
Projects*
101 34 39 451 625
ADUs 16 97 161 48 322
Remaining
RHNA 384 157 126 344 1,011
Total Sites
Inventory 557 169 325 1,051
Surplus 16 43 -19 40
Rezone Sites 408 128 64 600
Surplus with
Rezone Sites 424 171 45 640
* The “Approved/Entitled Projects” row is current as of Housing Element certification in 2023. For an update, see Table 4: 6th Cycle RHNA Progress for Los Altos through May 22, 2026.

Between currently approved or entitled projects, accessory dwelling units (ADU) assumptions, sites in Los Altos’ Housing Opportunity Sites Inventory, and potential sites for rezoning, the 6th Cycle Housing Element planned for a surplus of 424 units combined in the Very Low and Low income categories beyond the RHNA designation of 789 units (501 Very Low income plus 288 Low income units).

The Ballot Measure imposes procedural constraints on developing housing on the Downtown Parking Plazas which have all been identified as housing sites for moderate and above-moderate income housing. The Parking Plazas were included within the City’s calculations to satisfy its RHNA goals as shown in Table 4: 6th Cycle RHNA Allocation for 42 City of Los Altos (Revised August 2023). City of Los Altos 6th Cycle Housing Element. https://www.losaltosca.gov/DocumentCenter/View/286/6th-Cycle-Los-Altos-Housing-Element-2023-to-2031-PDF Information adapted from Table III-1: Residential Development Potential and RHNA, Page 16.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 51 Downtown Parking Plazas, which means the additional constraints imposed by the Ballot Measure could be understood to lead to a reduction in the City’s capacity to meet its RHNA.

Table 4: 6th Cycle RHNA Allocation for Downtown Parking Plazas43 Parking Plaza APN Income Category Units (Realistic, Net) Plaza 1, South Plazas 167-40-039 Above Moderate 15
Plaza 2, South Plazas 167-40-072 Above Moderate 15
Plaza 3, South Plazas 167-38-002 Above Moderate 28
Plaza 4, Central Plazas 167-39-057 Moderate 8
Plaza 5, Central Plazas 167-39-069 Moderate 8
Plaza 6, Central Plazas 167-38-028 Moderate 8
Plaza 7, North Plazas 167-39-032 Moderate 15
Plaza 8, North Plazas 167-39-007 Moderate 16
Plaza 9, North Plazas 167-38-049 Above Moderate 3
Plaza 10, North Plazas 167-38-029 Moderate 8
The Downtown Parking Plazas count towards 124 units: 63 moderate-income units and 61 above moderate-income units. Not counting Parking Plazas 7 and 8, which are addressed as an undefined exception in the Ballot Measure, the rest of the Parking Plazas still account for 32 units in the moderate-income category and 61 units in the above moderate-income category.

A potential loss of the Parking Plazas as housing sites would create a RHNA shortfall in the moderate and above moderate-income categories, leading to the City having a smaller surplus of 139 moderate units and a shortfall of 16 above-moderate units. Since the above moderate category would have a shortfall, the City would be unable to meet its RHNA without additional amendments to its certified 6yh Cycle Housing Element. This could lead HCD to make a finding of noncompliance for the City’s 6th Cycle Housing Element unless the City can identify and make available additional housing sites to address the above moderate shortfall within a 180-day time frame.

Since the Housing Element was certified in 2023, there has been progress in how the City is meeting its RHNA, as seen in Table 6: 6th Cycle RHNA Progress for Los Altos through May 22, 2026.
43 Ibid., Information adapted from Table B-10: Housing Sites (Under Existing Zoning), Pages 163-167.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 52 Table 5: 6th Cycle RHNA Progress for Los Altos through May 22, 202644 Income Category: Very Low Low Moderate Above
Moderate Total
Units Counted Towards RHNA 52 142 117 248 559
Remaining RHNA 449 146 209 595 1,399
The City is three years into the 8-year planning period for the 6th Cycle Housing Element and is making progress on its RHNA required housing production. However, it’s uncertain whether the City will be able to continue the same trajectory to meeting their RHNA goals if the Ballot Measure passes.

Effect on Affirmatively Furthering Fair Housing (AFFH)
Assembly Bill 686 (2018) Housing Discrimination: Affirmatively Further Fair Housing (AFFH) is a bill which amended the Government Code relating to housing, so that it is in compliance with the Federal Fair Housing Act.

AB 686 creates new requirements for all State and local agencies (including, but not limited to, all cities, counties, and housing authorities) to ensure that their laws, programs and activities affirmatively further fair housing, and that they take no action inconsistent with this obligation.

When housing choice and access are limited because of someone’s race, sexual orientation, or disability status, there are far-reaching impacts on access to job opportunities, access to quality education, and on mental and physical health. As indicated by the California Department of Housing and Community Development (HCD):

Past and present discriminatory policies and practices, including long-term disinvestment, have resulted in neighborhoods with concentrated poverty and poor housing stock, limited access to opportunity, unsafe environmental conditions, underfunded schools, dilapidated infrastructure, and other disproportionately experienced problems. In addition, governmental policies have subsidized the development of segregated, high-resourced suburbs in metropolitan areas by constructing new highway systems—often through lower income communities of color— to ensure access to job opportunities in urban centers.15 AFFH policy seeks to combat housing discrimination, eliminate racial bias, undo historic patterns of segregation, and lift constraints that restrict access to foster inclusive communities and achieve racial equity, fair housing choice, and opportunity for all Californians.
44 RHNA Progress is updated weekly and can be accessed at https://www.hcd.ca.gov/planning-and-communitydevelopment/housing-open-data-tools/regional-housing-needs-allocation-progress.

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 53 The demographic characteristics and other conditions are mostly similar across the City of Los Altos, with the majority of the City receiving a high or highest resource composite score according to TCAC. As such, the Ballot Measure is unlikely to affect the City’s ability to comply with state laws regarding Affirmatively Furthering Fair Housing.

Effect on HCD Prohousing Designation
The Prohousing Designation Program was established in the 2019-2020 Budget Act to provide additional funding and support for local jurisdictions that “go above and beyond state housing law to help accelerate housing production.”45 Jurisdictions that receive a Prohousing Designation may receive priority processing for various statewide funding programs and allow them to apply for the Prohousing Incentive Program (PIP) which rewards jurisdictions with additional funding to accelerate affordable housing production and preservation.

In April 2024, the City leveraged its Housing Element and promoted some of their Housing Element programs in its application to HCD to receive a Prohousing Designation. If the Ballot Measure passes and impacts the 6th Cycle Housing Element, HCD may revoke the City’s Prohousing Designation, significantly impacting the amount of funding the City can receive from the state.

There is precedent in which a city has had their Prohousing Designation revoked due to the city’s failure to implement key housing policies within a specified timeframe. On May 22, 2025, the City of Fresno received a letter from the Department of Housing and Community Development revoking their Prohousing Designation status. HCD “acknowledges the City’s request for an extension to implement proposed Prohousing Policies to May 30, 2025, and recognizes the challenges and complexities in enacting Prohousing Policies. However, timely enactment of proposed Prohousing Policies is clearly required by regulations and paramount to the goals of the Program to accelerate housing outcomes.”46 Fresno had failed to implement key housing policies by the November 30, 2024 timeframe that they had established when renewing their Prohousing Designation status constituting a basis for HCD to review and subsequently revoke their Prohousing Designation. The City of Fresno was allowed to reapply for the Prohousing Designation once they had remedied the areas identified by the HCD to be in violation of the status. In September 2025, the City of Fresno reapplied to the program and was subsequently re-awarded in October.47 In addition, the City would no longer be eligible for the PIP program, which could impact their ability to develop and preserve affordable housing, directly impacting Housing Element Program 2.C, Assist in Securing Funding for Affordable Housing Projects; Program 45 HCD. Prohousing Designation Program. https://www.hcd.ca.gov/planning-and-research/prohousing 46 HCD. (May 22, 2025). RE: City of Fresno – Revocation of Prohousing Designation, available at https://drive.google.com/file/d/1psk0_-p2nnDYXhtXEgU8efnbm-mM-7M8/view 47 City of Fresno. (Updated September 30, 2025). City of Fresno 2025 Prohousing Application. https://www.fresno.gov/wp-content/uploads/2025/10/City-of-Fresno-2025-Prohousing-Application-Response-toComments-09302025.pdf

2026 Ballot Measure Impact Analysis – 9212 Report |3. Housing Impacts, Page 54

5.B, Continue to Administer the City’s Affordable Housing Programs; and Program 6.B, Maintain and Expand an Inventory of Affordable Housing Funding Sources.

Possible Effects on Future Housing Element Planning Efforts Looking further into the future over the next few decades, the Ballot Measure could slow development and improvements in the Downtown Area as identified in the Downtown Vision Plan, Downtown Los Altos Parking Strategy, and 6th Cycle Housing Element. This could force development in other areas around the City.

There are no major transit stops that are eligible for SB 79, which prioritizes housing density and infill development around transit, in Los Altos. The city is also not currently included in the Metropolitan Transportation Commission’s (MTC) Transit Oriented Communities policy. However, if the City receives a major transit stop in the future, the Ballot Measure may come into conflict with state and regional objectives, which could potentially complicate future planning efforts.

2026 Ballot Measure Impact Analysis – 9212 Report |4. Infrastructure Funding Impacts, Page 55

4. Infrastructure Funding Impacts
In addition to impacts to the City’s General Fund operating budget, discussed in the Fiscal Impacts section of this report, development on the Parking Plaza sites would have implications for infrastructure funding. New development generates demand for infrastructure improvements and in some cases generates revenues through impact fees and other mechanisms to help fund those improvements. This section assesses how the ballot measure could affect infrastructure needs and the availability of funding to meet those needs across the major infrastructure categories relevant to the Parking Plaza sites.

The Ballot Measure creates different conditions for different sites. For Parking Plazas 7 and 8, the Ballot Measure preserves a path to affordable housing development without voter approval, while making other types of development on those sites more difficult and uncertain. For the remaining eight Parking Plazas, the measure subjects all forms of development and significant physical alteration to a voter approval requirement, adding time, cost, and uncertainty to any future development project. As discussed in the fiscal impact analysis section of this report, the likely effect of the Ballot Measure, if passed, will be to reduce the likelihood of development across all Parking Plaza sites, including Plazas 7 and 8.

Transportation Infrastructure
New development on the Parking Plaza sites could generate demand for transportation infrastructure improvements by bringing additional residents, workers, or visitors to Downtown Los Altos and increasing use of the local transportation network. The City collects a transportation impact fee from new residential, office, and retail and commercial projects to finance improvements needed to address the impacts of new development.

This fee is waived for affordable housing units and is not assessed on parks or open space, which limits the revenue available to address transportation impacts under those development scenarios. Other potential funding sources for transportation infrastructure include State funds, special gas tax revenues, countywide sales tax revenues, grants, and the City's General Fund. Developers may also be required to directly construct or fund improvements needed to address the transportation impacts of their specific projects.

The Ballot Measure reduces the likelihood of development on the Parking Plaza sites. To the extent that development is deterred or delayed, the City would avoid the infrastructure demands associated with new development and would also lose the impact fee revenues that would otherwise help fund transportation improvements. These two effects broadly offset one another; less development means less demand on the transportation network, and therefore less fee revenue to address that demand.

Stormwater Infrastructure
In their current condition, the Parking Plaza sites are largely impervious surface parking lots that contribute to stormwater runoff. Redevelopment could reduce or increase impervious coverage depending on project design: projects that incorporate landscaping, courtyards, or stormwater retention features could reduce runoff relative to existing

2026 Ballot Measure Impact Analysis – 9212 Report |4. Infrastructure Funding Impacts, Page 56 conditions, while projects with significant building footprints could maintain or increase impervious areas.

The stormwater infrastructure funding implications of the Ballot Measure are relatively modest compared to other infrastructure categories and depend in part on whether the City's existing stormwater system has adequate capacity to handle current and future runoff from the Plaza sites. If the existing system is functioning adequately, maintaining the current impervious surface conditions on the Plaza sites would not create additional funding needs, and the stormwater funding implications of the ballot measure would be limited regardless of outcome. If, on the other hand, the existing system needs upgrades or has limited capacity, development that reduces impervious coverage could improve stormwater conditions and potentially reduce the City's long-term infrastructure costs. In that case, the Ballot Measure's tendency to make uses such as a park, paseo, or landscaped open space less likely on the Plaza sites could have a modest negative effect on stormwater funding needs by decreasing opportunities to reduce runoff through redevelopment.

Utility Infrastructure
This section addresses the potential impacts of the Ballot Measure on sewer and electrical utility infrastructure, both as they relate to site-specific conditions on the Parking Plaza sites and to broader infrastructure funding considerations.

Sewer
Several of the Downtown Parking Plaza sites are encumbered by existing sewer infrastructure that would affect future development. Sewer lines run through the middle of Plazas 7 and 8 as well as at least some of the remaining Plazas. Any development on affected sites would need to either relocate these lines, adding a potentially significant cost, or design around them, constraining the buildable area and configuration of any development project. Sewer relocation costs would generally be borne by the developer, adding to overall project costs and potentially affecting the financial feasibility of development. To the extent that the Ballot Measure makes development less likely or narrows the range of viable development types, it could affect whether and when these sewer relocations occur, though this is primarily a development feasibility consideration rather than a City funding obligation, it impacts new development More broadly, new developments on the Parking Plaza sites would increase demand on the City's sewer system. The City does not collect a sewer impact fee; instead, new development pays connection fees at the time of permitting, which help offset the cost of connecting to the existing system. Whether additional capacity investments in the broader sewer system would be needed to serve new development on the Plaza sites would depend on available capacity in the existing infrastructure. To the extent the Ballot Measure reduces the number of developments that occurs on the Plaza sites, it would correspondingly reduce new sewer connections and the associated connection fee revenues, as well as any incremental demands on sewer system capacity.

2026 Ballot Measure Impact Analysis – 9212 Report |4. Infrastructure Funding Impacts, Page 57 Electricity
Several of the Plaza sites have overhead utility lines. Undergrounding these lines is a meaningful infrastructure improvement that enhances the streetscape and reduces the risk of outages, but it is expensive and difficult to accomplish outside of a development context. While PG&E's Rule 20 program provides funding for some utility undergrounding projects, these funds are generally reserved for projects that provide a broad public benefit, such as eliminating overhead lines in areas of heavy concentration, along major corridors, in areas of cultural or historic interest, or in locations with heavy pedestrian or vehicular traffic. As a result, development activity on the Plaza sites represents one of the more practical opportunities to accomplish utility undergrounding in this area.

To the extent that the Ballot Measure reduces the likelihood or financial feasibility of development on the Plaza sites, it could delay or prevent the utility undergrounding that would otherwise be associated with development on these sites. If development does not proceed, these improvements would need to be funded through other means or deferred indefinitely.

More broadly, new development on the Parking Plaza sites would increase electrical demand in the Downtown area. Electrical infrastructure upgrades needed to serve new development are typically funded through PG&E's capital program and recovered through utility rates, rather than through City fees or the General Fund, so the fiscal implications for the City are limited. However, to the extent that the Ballot Measure affects the amount and type of development that occurs, it would have a corresponding impact on electrical demand in the Downtown area.

Parks and Open Space Infrastructure
To the extent that the Ballot Measure affects development on the Parking Plaza sites, it could impact both the demand for parks and open space in Los Altos and the City's resources available to address that demand.

New development generally increases demand for parks and open space. This is particularly true of residential development, where new residents place direct and ongoing demand on parks and recreational facilities. However, nonresidential and civic uses that bring workers and visitors to Downtown, such as office, retail, arts, or cultural facilities, can also increase use of nearby parks and open space. To the extent that the Ballot Measure prevents development of any kind from occurring on the Plaza sites, the associated increase in demand may also be avoided.

The City's primary resources for creating and improving parks and open space include developer contributions, use of City-owned land, and funding from the Park Development Fund, General Fund, and applicable grants. The City assesses a Park and Recreation Impact Fee on new residential development, with an exemption for affordable units; the fee does not apply to nonresidential development. The City can apply these revenues to fund construction of new parks or improvements to existing facilities. In addition, the City can use City-owned land to expand its park inventory, as it is currently evaluating with the

2026 Ballot Measure Impact Analysis – 9212 Report |4. Infrastructure Funding Impacts, Page 58 potential Downtown park on Plazas 1, 2, and/or 3. More broadly, because the Parking Plazas are City-owned, the City has greater leverage to negotiate the provision of publicly accessible open space as a component of any development project on these sites than it would typically have with development on privately owned land. This could result in open space benefits beyond what standard fee requirements alone would support, whether as part of a residential project on Plazas 7 and 8 or as a component of any future development on any of the remaining Plazas.

The Ballot Measure could affect these resources in several ways. Preventing or reducing residential development on the Plaza sites would reduce the park impact fee revenues the City would otherwise collect but could also reduce the corresponding increase in park demand that new development would generate, resulting in a broadly neutral net impact on park resources. For non-residential development on the remaining Plazas, there is no park impact fee, so preventing such development could avoid an increase in unmitigated demand — a modestly positive outcome from a parks funding perspective, though one that comes at the cost of forgoing the broader economic and community benefits those uses could generate. Beyond fee revenues, where development does not proceed or where the voter approval requirement makes projects less attractive and increases developer risk, the City's leverage to negotiate open space commitments above and beyond standard requirements would also be diminished, potentially requiring additional City funds to provide a comparable level of parks improvements elsewhere.

Perhaps most significantly, if the Ballot Measure passes, any park or open space use on a Plaza site would itself require voter approval, since converting a parking lot to a park would constitute a change in use under the Ballot Measure. This means the Ballot Measure creates a procedural constraint not only to private development but also to City-initiated public amenities. If the potential downtown park on Plazas 1, 2, and/or 3 does not move forward due to this procedural burden, the City would lose a significant opportunity to expand its Downtown parks and open space inventory on land it already owns, which could lead the City to expend additional funds to acquire a site elsewhere to construct a new park. It is worth noting that the City is still in the early stages of evaluating the potential park, and the project may ultimately not move forward regardless of the Ballot Measure outcome. Nevertheless, the Ballot Measure would add cost, time, and uncertainty to any future effort to develop a park on these sites.

On balance, the Ballot Measure's impacts on parks and open space resources are more likely to be negative than positive. The most significant risks are the potential loss of the downtown park opportunity and a diminished ability to negotiate developer-provided open space as part of future projects.

The one scenario in which the Ballot Measure could have a insignificantly positive effect — by preventing non-residential development that would increase park demand without generating fee revenue — is a narrow one and would come at the cost of forgoing the broader benefits those uses would provide to Downtown Los Altos.

2026 Ballot Measure Impact Analysis – 9212 Report |4. Infrastructure Funding Impacts, Page 59 Public School Facilities
New residential development on the Parking Plaza sites would generate new students in the local school districts and corresponding school impact fee revenues. The Plaza sites are served by the Los Altos School District (LASD) for kindergarten through 8th grade and the Mountain View–Los Altos Union High School District (MVLA) for high school.

Both LASD and MVLA levy school impact fees on new development; under State law, maximum combined fees for all school districts that serve a project are $5.38 per square foot for residential development and $0.87 per square foot for nonresidential development.

The magnitude of enrollment impacts and fee revenues would depend on the scale and mix of development, with multi-family residential development — the most likely form on the Plaza sites — tending to generate fewer school-age children per unit than single-family development.

School impact fees help offset the capital costs of serving new enrollment but do not always fully cover the cost of new or expanded facilities. If existing capacity in the affected schools is insufficient to accommodate growth associated with new development, the districts could face funding needs that exceed what school impact fees alone would provide, potentially requiring additional voter-approved bonds or other funding sources to make up the difference.

To the extent the Ballot Measure reduces the amount of residential development on the Plaza sites, it could correspondingly reduce both enrollment impacts and school impact fee revenues, with the two effects possibly broadly offsetting one another. It is worth noting that non-residential development on the Plaza sites would also generate school impact fees without directly increasing student enrollment, which would modestly offset the enrollment-driven costs associated with residential development.

To the extent the Ballot Measure reduces the likelihood of future nonresidential development on these sites, it would forgo this enrollment driven opportunity, though the effect would be modest.

2026 Ballot Measure Impact Analysis – 9212 Report |5. Business Impacts, Page 60

5. Business Impacts
This section evaluates how the proposed Ballot Measure could affect business and employment attraction and retention in downtown Los Altos. It examines current conditions in the Downtown retail market, recent taxable sales trends, and the potential effects of the Ballot Measure on parking supply, accessibility, and future development opportunities. The section also assesses how the Ballot Measure could influence Downtown visitation, local spending, and the availability of housing that supports the local workforce.

Downtown Retail Market Overview
Downtown Los Altos is a retail and dining hub within the City, organized around a six-block “downtown triangle” bounded by Foothill Expressway, San Antonio Road, and Edith Avenue.

The area is home to more than 150 retail, dining, service, and professional businesses.48 The mix includes fast-casual and full-service restaurants, coffee shops, convenience retail, destination retail, and personal services. Retailers include grocery stores (Draeger’s, Safeway), a drug store (Walgreens), hardware stores (Los Altos Hardware), and specialty stores in apparel, footwear, and home goods. The area is also home to a cluster of personal-service businesses, including hair and nail salons, banks, and dry cleaners, as well as a multi-vendor food hall (State Street Market) on State and Third Streets.

Downtown land area is divided between active commercial frontage, roadways, a few parks, and ten City-owned surface Parking Plazas. The Plazas occupy a substantial share of the Downtown’s developable land and produce no rent, no sales tax, and no residential population. A 2024 Parking Occupancy Study commissioned by the City—conducted during the December 2023 holiday shopping season, the highest-demand period of the year— found that peak occupancy of the approximately 1,700 public spaces in the Downtown ranged between 54 and 60 percent, reaching a high of 71 percent, with most vehicles parked for less than two hours.49 An occupancy ceiling of 60 to 71 percent during the peak demand period indicates that the Downtown’s public parking supply substantially exceeds demand under existing conditions.

Downtown Los Altos Taxable Sales Trends
Sales tax data published by the City indicate that Los Altos has lagged regional taxable sales performance in recent quarters. In the third quarter of 2025 (July through September), the City’s local one-cent sales tax receipts totaled approximately $708,150, a decrease of 7.7 percent compared to the third quarter of 2024 after adjusting for reporting modifications 48Los Altos Village Association, "Downtown Los Altos," available at https://downtownlosaltos.org/. 49W-Trans, Downtown Los Altos Parking Occupancy and Turnover Study (presented to Los Altos City Council, November 12, 2024).