Cities Index.
Agenda packet, special meeting

Los Altos Hills City Council
June 18, 2025

Document
Agenda packet, special meeting
Meeting
June 18, 2025
Body
Los Altos Hills City Council
Pages
1,435
Original file
586.5 MB
Text extracted from the city's file for reading and search. Open the original on losaltoshillsca.api.civicclerk.com. That file is the official record.

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CO VAN

LOADING
1 2 EV 3,4 5,6 7,8
26 25 24
EV 9,10 11,12 13,14 EV

EV EV EV
15 16 EV 18 19 20,21
EV
23 17
3Y 3Y 3Y 3Y
SPARE
3Y
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SPARE P C T
27 22 Mora Dr.
& CONSTRUCTION OPERATION PLAN
10'0' 20' 40' SCALE:
1"=20' NORTH
A
A

SEDIMENT ROLL DETAIL
NTS 1 SILT FENCE DETAILNTS 2

CONCRETE WASHOUT PIT DETAIL
NTS 4
biowattles
tree protection
straw bale barrier
silt fence
concrete washout

TREE PROTECTION FENCE DETAIL
NTS 3

LEGEND VARIES
10'-0"

EROSION CONTROL MEASURES SHALL CONFORM TO ABAG STANDARDS, SCC COUNTY STANDARDS AND

APPROVAL OF THE ENGINEERING DEPARTMENT

1. ALL MATERIALS NECESSARY FOR THE APPROVED EROSION CONTROL MEASURES SHALL BE ON SITE BY OCTOBER 15TH AND IN PLACE BY NOVEMBER 1ST.

2. 3. EROSION CONTROL SYSTEMS SHALL BE INSTALLED AND MAINTAINED THROUGHOUT THE RAINY SEASON.

THE CONTRACTOR SHALL BE RESPONSIBLE FOR CHECKING AND REPAIRING EROSION CONTROL SYSTEMS AFTER EACH STORM.

4. PROJECTS MUST HAVE ALL CUT AND FILL SLOPES PROTECTED BY SEEDING AND PUNCHING THE SLOPES WITH STRAW OR HYDROSEEDING.

5. ANY AREAS OF DISTURBED SOIL SHALL BE SEEDED OR REPLANTED TO THE SATISFACTION OF THE COUNTY ENGINEER PRIOR TO NOVEMBER 1ST, OR FINAL INSPECTION, WHICHEVER IS SOONER.

6. ADDITIONAL EROSION CONTROL MEASURES MAY BE REQUIRED AS DETERMINED BY COUNTY ENGINEERING DEPARTMENT OR BUILDING OFFICIALS.

7. PROJECT SHALL PREVENT ANY ACCUMULATION OR DEPOSIT OF DIRT, MUD, SAND, ROCKS, GRAVEL OR

DEBRIS ON THE SURFACE OF ANY STREET , ALLEY OR PUBLIC PLACE OR IN ANY PUBLIC STORM DRAIN SYSTEM.

8. THE CONTRACTOR SHALL COMPLY WITH THE REQUIREMENTS OF STORM WATER POLLUTION PREVENTION DURING ALL PHASES OF CONSTRUCTION.

9. WORK AREAS THAT HAVE NOT BEEN STABILIZED PRIOR TO ONSET OF WET SEASON SHALL BE GRADED TOWARD TEMPORARY SETTLEMENT BASINS WITHIN SITE. STORM RUNOFF WATER FROM UN-STABILIZED AREAS SHALL BE DIRECTED THROUGH BIOWATTLES PRIOR TO RELEASE FROM THE SITE.

10. INSTALL SEDIMENT
ROLL, SEE DETAIL 1

INSTALL SILT FENCE,
SEE DETAIL 2

INSTALL TREE

PROTECTION,
SEE DETAIL 3

INSTALL TREE

PROTECTION,
SEE DETAIL 3

CONSTRUCTION ENTRANCE,
INSTALL 2" TO 3" CRUSHED
ROCK 4" THICK 12'-0"
4'-0"

CONSTRUCTION FENCING

CONCRETE WASHOUT,
SEE DETAIL 4

SOIL EROSION AND SEDIMENT CONTROL PLAN DUMPSTER STORAGE CONTAINER NOTE: TEMPORARY CRANE INSTALLATION TO BE ERECTED AND OPERATIONAL FOR DURATION CONSTRUCTION. 4.

LOCATION OF TEMPORARY STORAGE CONTAINERS TO ENCROACH ON TO RIGHT-OF-WAY AT MORA DR. NOT ALL LOCATIONS NOT SHOWN FOR CLARITY. 2

LOCATION OF TEMPORARY DEBRIS BOX / DUMPSTER TO BE PRESENT FOR DURATION OF CONSTRUCTION. 3
1 INSTALL TEMPORARY FENCING TO BE PRESENT FOR DURATION OF CONSTRUCTION. 3 SOIL EROSION & SEDIMENT CONTROL NOTES CONSTRUCTION OPERATION NOTES 2 1
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8
C6

SOIL EROSION AND SEDIMENT CONTROL PLAN
& CONSTRUCTION OPERATION PLAN

HYDROLOGY AND WATER QUALITY
CONSTRUCTION BMPs:

1. GRADING SHALL BE PERFORMED IN ACCORDANCE WITH THE CITY GRADING ORDINANCE, CHAPTER 9 OF THE CITY CODE. SOIL OR OTHER

CONSTRUCTION MATERIALS SHALL NOT BE STOCKPILED IN THE PUBLIC

RIGHT-OF-WAY UNLESS AN ENCROACHMENT PERMIT IS OBTAINED
FROM THE DEPARTMENT OF PUBLIC WORKS. GRADING SHALL NEITHER BE INITIATED NOR CONTINUED BETWEEN NOVEMBER 15 AND APRIL 15. GRADING SHALL BE DONE BETWEEN THE HOURS OF 8:00 A.M. AND 5:00 P.M., MONDAY THROUGH FRIDAY UNLESS OTHERWISE SPECIFICALLY AUTHORIZED BY THE DIRECTOR OF PUBLIC WORKS. THE STORMWATER

POLLUTION PREVENTION PROGRAM BEST MANAGEMENT PRACTICES
(BMPS) FOR CONSTRUCTION SHALL BE IMPLEMENTED TO PROTECT WATER QUALITY. 2.THE OWNER/APPLICANT SHALL ENSURE THAT ALL CONSTRUCTION

PERSONNEL FOLLOW STANDARD BMPS FOR STORMWATER QUALITY
PROTECTION DURING CONSTRUCTION OF PROJECT. THESE INCLUDES, BUT ARE NOT LIMITED TO, THE FOLLOWING:
a) STORE, HANDLE, AND DISPOSE OF CONSTRUCTION MATERIALS AND

WASTES PROPERLY, SO AS TO PREVENT THEIR CONTACT WITH
STORMWATER. b) CONTROL AND PREVENT THE DISCHARGE OF ALL POTENTIAL

POLLUTANTS, INCLUDING SOLID WASTES, PAINTS, CONCRETE,

PETROLEUM PRODUCTS, CHEMICALS, WASH WATER OR SEDIMENT,

AND NON- STORMWATER DISCHARGES TO STORM DRAINS AND
WATERCOURSES. c) USE SEDIMENT CONTROLS, FILTRATION, OR SETTLING TO REMOVE SEDIMENT FROM DEWATERING EFFLUENT. d) DO NOT CLEAN, FUEL, OR MAINTAIN VEHICLES ON-SITE, EXCEPT IN

A DESIGNATED AREA IN WHICH RUNOFF IS CONTAINED AND
TREATED. e) DELINEATE CLEARING LIMITS, EASEMENTS, SETBACKS, SENSITIVE

OR CRITICAL AREAS, BUFFER ZONES, TREES, AND DRAINAGE
COURSES WITH FIELD MARKERS OR FENCING. f) PROTECT ADJACENT PROPERTIES AND UNDISTURBED AREAS FROM

CONSTRUCTION IMPACTS USING VEGETATIVE BUFFER STRIPS, SEDIMENT BARRIERS OR FILTERS, DIKES, MULCHING, OR OTHER MEASURES AS APPROPRIATE. g) PERFORM CLEARING AND EARTH MOVING ACTIVITIES ONLY DURING DRY WEATHER (APRIL 15 THROUGH NOVEMBER 14).
h) LIMIT AND TIME APPLICATIONS OF PESTICIDES AND FERTILIZERS TO PREVENT POLLUTED RUNOFF.
i) LIMIT CONSTRUCTION ACCESS ROUTES AND STABILIZE DESIGNATED ACCESS POINTS.
j) DO NOT TRACK DIRT OR OTHER MATERIALS OFF-SITE; CLEAN OFFSITE PAVED AREAS AND SIDEWALKS USING DRY SWEEPING METHODS. IF CONSTRUCTION IS NOT COMPLETE BY THE START OF THE WET SEASON (NOVEMBER 15 THROUGH APRIL 15), PRIOR TO NOVEMBER 15 THE DEVELOPER SHALL IMPLEMENT A WINTERIZATION PROGRAM TO MINIMIZE THE POTENTIAL FOR EROSION AND SEDIMENTATION. AS

APPROPRIATE TO THE SITE AND STATUS OF CONSTRUCTION, DISTURBED SOILS THROUGH TEMPORARY OR PERMANENT SEEDING,

MULCHING, MATTING, TARPING OR OTHER WINTERIZATION

REQUIREMENTS SHALL INCLUDE

INSPECTING/MAINTAINING/CLEANING ALL SOIL EROSION AND

SEDIMENTATION CONTROLS PRIOR TO, DURING, AND IMMEDIATELY AFTER EACH STORM EVENT; STABILIZING PHYSICAL MEANS;

ROCKING UNPAVED VEHICLE ACCESS TO LIMIT DISPERSION OF MUD ONTO PUBLIC RIGHT-OF- WAY; COVERING/TARPING STORED
CONSTRUCTION MATERIALS, FUELS, AND OTHER CHEMICALS. PLANS

TO INCLUDE PROPOSED MEASURES TO PREVENT EROSION AND
POLLUTED RUNOFF FROM ALL SITE CONDITIONS. AS SITE

CONDITIONS WARRANT, THE DEPARTMENT OF PUBLIC WORKS MAY

DIRECT THE DEVELOPER TO IMPLEMENT ADDITIONAL
WINTERIZATION REQUIREMENTS.

GENERAL NOTES
DUST CONTROL: TO REDUCE DUST LEVELS, EXPOSED EARTH
SURFACES SHALL BE WATERED AS NECESSARY. THE APPLICATION

OF WATER MUST BE MONITORED TO PREVENT RUNOFF INTO THE
STORM DRAIN SYSTEM. SPILLAGE RESULTING FROM HAULING

OPERATIONS ALONG OR ACROSS ANY PUBLIC OR PRIVATE
PROPERTY SHALL BE REMOVED IMMEDIATELY.
a) ALL EXPOSED SURFACE (e.g.PARKING AREAS, STAGING AREAS,

SOIL PILES, GRADED AREAS, AND UNPAVED ACCESS ROADS) SHALL BE WATERED TWO TIMES PER DAY.
b) ALL HAUL TRUCKS TRANSPORTING SOIL, SAND, OR OTHER LOOSE MATERIAL OFF-SITE SHALL BE COVERED.
c) ALL VISIBLE MUD OR DIRT TRACKOUT ONTO ADJACENT PUBLIC

ROADS SHALL BE REMOVED USING WET POWER VACUUM STREET
SWEEPERS AT LEAST ONCE PER DAY. THE USE OF DRY POWER
SWEEPING IS PROHIBITED.
d) ALL VEHICLE SPEEDS ON UNPAVED ROADS SHALL BE LIMITED TO 15 mph.
e) ALL ROADWAYS, DRIVEWAYS, AND SIDEWALKS TO BE PAVED
SHALL BE COMPLETED AS SOON AS POSSIBLE. BUILDING PADS

SHALL BE LAID AS SOON AS POSSIBLE AFTER GRADING UNLESS
SEEDING OR SOIL BINDERS ARE USED.
f) ALL EXCAVATION, GRADING, AND/OR DEMOLITION ACTIVITIES SHALL BE SUSPENDED WHEN AVERAGE WIND SPEEDS EXCEED 20 mph.
g) ALL TRUCKS AND EQUIPMENT, INCLUDING THEIR TIRES, SHALL BE WASHED OFF PRIOR TO LEAVING THE SITE.
h) UNPAVED ROADS PROVIDING ACCESS TO SITES LOCATED 100 FEET OR FURTHER FROM A PAVED ROAD SHALL BE TREATED WITH A 6-TO 12-INCH LAYER OF COMPACTED LAYER OF WOOD CHIPS, MULCH,
OR GRAVEL.
i) PUBLICLY VISIBLE SIGNS SHALL BE POSTED WITH THE TELEPHONE

NUMBER AND NAME OF THE PERSON TO CONTACT ON-SITE
DISTURBANCE COORDINATOR REGADING DUST COMPLAINS.

GREENHOUSE GASES: A MINIMUM OF 50% OF THE CONSTRUCTION

WASTE GENERATED BY THIS PROJECT TO BE RECYCLED OR SALVAGED FOR USE. DOCUMENTATION TO BE PROVIDED BEFORE THE FINAL
BUILDING PERMIT INSPECTION. SAMPLE FORMS LOCATED AT
WWW.HCD.CA.GOV/CALGREEN.HTML MAY BE USED TO ASSIST IN
DOCUMENTING COMPLIANCE.

TREE PROTECTION: THE APPLICANT SHALL IMPLEMENT THE TREE

PROTECTION GUIDELINES IDENTIFIED ON THE PROJECT LANDSCAPE PLANS (DEMOLITION NOTES SHEET L-0.1).

CLEARING & GRUBBING: CLEAR AND GRUB TWO THE LIMITS OF WORK

PER SPECIFICATIONS TAKING CARE TO NOT DISTURB THE ROOT SYSTEM OF EXISTING TREES TO REMAIN.

EXISTING TREES TO REMAIN: EXISTING TREES TO REMAIN SHALL BE

PRUNED UNDER THE DIRECTION OF A CERTIFIED ARBORIST IN

ACCORDANCE WITH INTERNATIONAL SOCIETY OF ARBORICULTURAL (ISA) GUIDELINES PRIOR TO BEGINNING OF CONSTRUCTION. DURING CONSTRUCTION, FENCING SHALL BE INSTALLED.

AIR QUALITY
CONSTRUCTION AND OPERATIONAL EMISSION: 1.OFF- ROAD
EQUIPMENT GREATER THAN 50 HORSEPOWER(HP) AND OPERATING
FOR MORE THAN 20 TOTAL HOURS PER WEEK SHALL OPERATE ON AN EPA-APPROVED TIER 4 OR NEWER ENGINE.

2.TO REDUCE CONSTRUCTION-RELATED FUGITIVE DUST BY

IMPLEMENTING BAAQMD'S BASIC CONTROL MEASURES AT ALL
CONSTRUCTION AND STAGING AREAS. THE FOLLOWING MEASURES ARE BASED ON BAAQMD'S CURRENT [2017] CEQA GUIDELINES.
a) ALL HAUL TRUCKS TRANSPORTING SOIL, SAND, OR OTHER LOOSE MATERIAL OFFSITE WILL BE COVERED. b) ALL VISIBLE MUD OR DIRT TRACK-OUT ONTO ADJACENT PUBLIC

ROADS WILL BE REMOVED USING WET POWER VACUUM STREET
SWEEPERS. THE USE OF DRY POWER SWEEPING IS PROHIBITED.
c) ALL VEHICLE SPEEDS ON UNPAVED ROADS, DRIVEWAYS, OR DRIVING SURFACES SHALL BE LIMITED TO 15 MPH.
d) ALL ROADWAYS, DRIVEWAYS, AND SIDEWALKS TO BE PAVED WILL BE COMPLETED AS SOON AS POSSIBLE. BUILDING PADS WILL BE LAID AS

SOON AS POSSIBLE AFTER GRADING UNLESS SEEDING OR SOIL
BINDERS ARE USED. e) POST A PUBLICLY VISIBLE SIGN WITH THE TELEPHONE NUMBER AND

THE NAME OF THE PERSON TO CONTACT AT THE ON-SITE
DISTURBANCE COORDINATOR REGARDING DUST COMPLAINTS. THIS PERSON WILL RESPOND AND TAKE CORRECTIVE ACTION WITHIN 48 HOURS. THE PHONE NUMBER OF THE DISTRICT WILL ALSO BE VISIBLE TO ENSURE COMPLIANCE.
f) IDLING TIMES TO BE MINIMIZED EITHER BY SHUTTING EQUIPMENT

OFF WHEN NOT IN USE OR REDUCING THE MAXIMUM IDLING TIME

TO FIVE MINUTES (AS REQUIRED BY THE CALIFORNIA AIRBORNE TOXICS CONTROL MEASURE TITLE 13, SECTION 2485 OF
CALIFORNIA CODE OF REGULATIONS). CLEAR SIGNAGE MUST BE
PROVIDED FOR CONSTRUCTION WORKERS AT ALL ACCESS POINTS. g) ALL CONSTRUCTION EQUIPMENT TO BE MAINTAINED AND

PROPERLY TUNED IN ACCORDANCE WITH THE MANUFACTURER'S
SPECIFICATIONS.

ITEM 2A ATTACHMENT 8A

Page 566 of 1435 ends

VAN

LOADING
1 2 EV
30 29 28
EV EV

EV EV EV
EV EV
31 571.85' 571.0' 20.0% 2.0% 8.0%
577.5'
571.85'
586.85' F.F. ABOVE
579.1' 579.7'
564.0' 5.1%
566.0'
564.2' 6.0% 8' RAMP 8%
586.8'
586
UP DN
564.3'
27 3,4,5 6,7,8 9,10,11 12,13,14 15,16,17 18,19,20 21 22 24 25 26
23 SWITCH BOARD

SWITCH BOARD
553.1' DN
UP
557.1'
541.9' UP
575.6'
12 9 6 3 18 21 24 27 30 33 36
45 48
586.8'
15 586.8'
39 42
598.0'
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8
SCALE:
1"=20' NORTH

PODIUM /GARAGE

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1

TRASH ROOM

DRIVEWAY
ELEC
MPOE

ACCESSIBLE PATH OF TRAVEL
MECH
FAN
ROOM
18'-5" 10'-4"
11'-7" 9'-0" 20'-2" OVHD GATE
GARAGE 1'-6"
28'-2 1/4" 9" 1'-0"

BASEMENT

SUB BASEMENT

ELEVATOR
#2
EXIT
STAIR #2 23'-8" 22'-11"
2 1/4" 1'-8"
8'-7"

CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT

PLANTERS

BICYCLE PARKING ROLL-UP DOOR

BUILDING PLAN

BUILDING PLAN
BUILDING PLAN 50'-3"
44" CORRIDOR 49'-3" 17'-2" 52'-6"
34'-10" 99'-6" 30'-6 3/4"
214'-4"
103'-2"
10'-0" 213'-5"
20' 40' 60'
44" CORRIDOR

MEZZANINE

BUILDING PLAN
LEVEL 1

BUILDING PLAN
47'-10" 43'-4 1/4" 1'-6" 9" 1'-0"
47'-7 3/4" 14'-1" 29'-8"1'-8"
2 1/4"
2 1/4" 2 1/4"
102'-10"
102'-5 1/4"

FLOOR PLAN BR

FLOOR PLAN H

FLOOR PLAN AL

ELEVATOR
#2
EXIT
STAIR #2

FLOOR PLAN D
IDF 44" CORRIDOR
IDF

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH

DRIVEWAY BELOW
LOBBY

PACKAGE ROOM

MAIL ROOM

FAN CHASE

TO ROOF
21'-9" 29'-4" 11'-8" 11'-6"
14'-7 3/4" 1'-6"
18'-7" 13'-4 1/2" 9" 1'-0"
3'-8"
2 1/4" 44'-10 7/8" 2 1/4" 62'-5 3/8" 47'-7 3/4" 14'-1" 1'-8" 8'-7" 29'-5 1/2"
2 1/4"
31'-1 3/4"
2 1/4" 2 1/4" 2 1/4"
2'-0"
2 1/4" 2 1/4" 52'-6"
214'-4"
213'-5"
POWDER
ROOM
5'-0"

FLOOR PLAN F

FLOOR PLAN C
2 1/4"
IDF

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH
21'-9"
22'-11 1/4" 18'-0 3/4" 11'-6"
14'-7 3/4" 1'-6"
60'-8 1/4" 30'-6" 9" 1'-0"
3'-8"
2 1/4" 44'-10 7/8" 2 1/4" 62'-5 3/8" 47'-7 3/4" 14'-1" 29'-8"1'-8" 8'-7"
2 1/4" 2 1/4" 2 1/4" 2 1/4"
2'-0"
2 1/4" 2 1/4"
214'-4"
213'-5"

FLOOR PLAN G

FLOOR PLAN E

FLOOR PLAN D

FLOOR PLAN F

FLOOR PLAN C
2 1/4"
44" CORRIDOR
44" CORRIDOR 52'-6"
LEVEL 2

BUILDING PLAN

DECK DECK DECK DECK
DECK

DECK DECK

JULIET BALCONY

DECK DECK DECK

DECK DECK
DECK
DECK
UP
UP
UP
29'-5 1/2"
W
D
LAUNDRY 23'-8"
31'-10 3/4"
29'-8"
29'-8"

FITNESS

ROOM FLOOR PLAN H FLOOR PLAN J MEDIA

UTILITY ROOM
D
DW
W
UP
48'-10 1/2"
29'-11 3/4"
14'-5" 14'-0" 16'-10 3/4" 13'-1"
10'-10 1/2" 2 1/4"
10'-10 1/2" 2 1/4" SHELVES SHELVES
44" CORRIDOR
31'-5 1/4" 29'-3"

FLOOR PLAN BP

FLOOR PLAN BB

FLOOR PLAN H

FLOOR PLAN HR

JULIET BALCONY

JULIET BALCONY

NURSING STATION
SUPPLY
ROOM

SCOPE OF WORK, PERMITS & AUTHORIZATIONS

IN ORDER TO MANAGE AND RUN THIS SENIOR RESIDENTIAL LIVING FACILITY, CERTAIN INCIDENTAL

SERVICES AND OFFERINGS ARE NECESSARY FOR ITS OPERATION AND TO SERVE ITS RESIDENTS DUE TO THE

LIMITED MOBILITY AND SPECIAL NEEDS OF SENIOR RESIDENTS, INCLUDING LOW-INCOME SENIOR RESIDENTS. THESE SERVICES AND OFFERINGS AND MUST REMAIN INCIDENTAL AND SUPPLEMENTAL TO THE PRIMARY RESIDENTIAL USAGE. THESE SERVICES AND OFFERINGS SHALL BE AVAILABLE TO RESIDENTS AND THE FACILITIES GUESTS, BUT SHALL NOT BE MADE AVAILABLE TO THE GENERAL PUBLIC. THESE SERVICES

AND OFFERINGS SHALL BE LICENSED AND PERMITTED IN PERPETUITY FOR THE LIFE OF THE FACILITY AND NOT BE SUBJECT TO CURRENT OR FUTURE LOCAL ORDINANCES AND REQUIREMENTS. NOTWITHSTANDING, ALL SUCH SERVICES AND OFFERINGS SHALL MEET ALL STATE AND FEDERAL REQUIREMENTS.

THESE SERVICES AND OFFERINGS INCLUDE:

1. NAIL & HAIR SALON, MASSAGE, CHIROPRACTIC, TRANSPORTATION, AND SIMILAR NON-MEDICAL SERVICES.

2. MEDICAL TREATMENT TO ITS RESIDENTS AND GUEST THROUGH THIRD PARTY CONTRACTORS FOR TREATMENT ON PREMISES.

3. EVENTS OF UP TO 250 PEOPLE BETWEEN THE HOURS OF 9:00AM AND 10:00PM WITH A MAXIMUM NOISE LEVEL OF 80 DECIBELS MEASURED AT GROUND LEVEL ON THE PROPERTY LINE.

4. USE STREET PARKING, REGARDLESS OF SIGNAGE, ALONG THE MORA DRIVE RIGHT-OF-WAY BUT OUTSIDE THE ROADWAY PATH OF TRAVEL, EXCEPT WHERE PARKING IS OBJECTIVELY UNSAFE:

5. SERVING AND SALE OF HOT AND COLD FOOD, BEER, WINE AND LIQUOR.

6. SELECT AND MANAGE ITS TENANTS, INCLUDING LOW-INCOME TENANTS.

7. SALE GIFTS, INCIDENTALS, AND FOOD ITEMS.

8. MANAGEMENT OF ALL INTERIOR AND EXTERIOR LIGHTING, INCLUDING WATTAGE, ORIENTATION,

HOWEVER LIGHTING SHALL BE ORIENTED TO REDUCE IMPACT ON NEIGHBORING STRUCTURES WHERE FEASIBLE.

9. NON MEDICAL CARE OF RESIDENTS, INCLUDING PHYSICAL THERAPY, RECOVERY FROM MEDICAL USES, AND IN MONITORING, BATHING OR OTHER LIFE ACTIVITIES.

THIS PLAN IS INTENDED TO CONTAIN ALL REQUIRED USE, SITE OFF-SITE AND STREET IMPROVEMENTS PERMITS REQUIRED FOR THIS PROJECT. SOME OF THESE IMPROVEMENTS MAY REQUIRE FURTHER DETAILING TO MEET HEALTH AND SAFETY STANDARDS.

ALLOWABLE AREA NOTES:

FROM THE 2022 CALIFORNIA BUILDING CODE

BUILDING AREA

GENERAL NOTES

FIRE WALLS
706.5 HORIZONTAL CONTINUITY. FIRE WALLS SHALL BE CONTINUOUS FROM EXTERIOR WALL TO EXTERIOR WALL AND SHALL EXTEND AT LEAST 18" BEYOND THE EXTERIOR SURFACE OF EXTERIOR WALLS.

EXCEPTIONS

1. [NOT USED.]

2. [NOT USED]

3. FIRE WALLS SHALL BE PERMITTED TO TERMINATE AT THE INTERIOR SURFACE OF ON

COMBUSTIBLE EXTERIOR SHEATHING WHERE THE BUILDING ON EACH SIDE OF THE FIRE WALL IS

PROTECTED BY AN
AUTOMATIC SPRINKLER SYSTEM INSTALLED IN ACCORDANCE WITH SECTION 903.3.1.1 OR 903.3.1.2. 706.5.1 EXTERIOR WALLS. WHERE THE FIRE WALL INTERSECTS EXTERIOR WALLS, THE FIRE-RESISTANCE

RATING AND OPENING PROTECTION OF THE EXTERIOR WALLS SHALL COMPLY WITH ONE OF THE FOLLOWING:

1. [NOT USED]

2. BUILDINGS OR SPACES ON BOTH SIDES OF THE INTERSECTING FIRE WALL SHALL ASSUME TO

HAVE AN IMAGINARY LOT LINE AT THE FIRE WALL AND EXTENDING BEYOND THE EXTERIOR OF THE FIRE WALL.

THE LOCATION OF THE ASSUMED LINE IN RELATION TO THE EXTERIOR WALLS AND THE FIRE WALL SHALL

BE SUCH THAT THE EXTERIOR WALL AND OPENING PROTECTION MEET THE REQUIREMENTS SET FORTH IN SECTIONS 705.5 AND 705.8. SUCH PROTECTION IS NOT REQUIRED FOR EXTERIOR WALLS TERMINATING AT FIRE WALLS THAT FORM AN ANGLE EQUAL TO OR GREATER THAN 180 DEGREES. 706.5.2 HORIZONTAL PROJECTING ELEMENTS. FIRE WALLS SHALL

EXTEND TO THE OUTER EDGE OF HORIZONTAL PROJECTING ELEMENTS SUCH AS BALCONIES, ROOF OVERHANGS, CANOPIES, MARQUEES AND SIMILAR PROJECTIONS THAT ARE WITHIN 4 FEET OF THE FIRE WALL.

EXCEPTIONS:

1. HORIZONTAL PROJECTING ELEMENTS WITHOUT CONCEALED SPACES, PROVIDED THAT THE EXTERIOR WALL BEHIND AND BELOW THE PROJECTING ELEMENT HAS NOT LESS THAN 1-HOUR

FIRE-RESISTANCE-RATE CONSTRUCTION FOR A DISTANCE NOT LESS THAN THE DEPTH OF THE PROJECTING ELEMENT ON BOTH SIDES OF THE FIRE WALL. OPENINGS WITHIN SUCH EXTERIOR WALLS

SHALL BE PROTECTED BY OPENING PROTECTIVES HAVING A FIRE PROTECTION RATING OF NOT LESS THAN 3/4 HOUR.

2. NONCOMBUSTIBLE HORIZONTAL PROJECTING ELEMENTS WITH
CONCEALED SPACES, PROVIDED THAT A MINIMUM 1-HOUR FIRERESISTANCE- RATED WALL EXTENDS

THROUGH THE CONCEALED THE PROJECTING ELEMENT SHALL BE SEPARATED FROM THE BUILDING BY NOT LESS THAN 1-HOUR FIRE-RESISTANCE-RATED CONSTRUCTION FOR A DISTANCE ON EACH SIDE OF

THE FIRE WALL
EQUAL TO THE DEPTH OF THE PROJECTING ELEMENT. THE WALL IS NOT REQUIRED TO EXTEND UNDER THE PROJECTING ELEMENT WHERE THE BUILDING EXTERIOR WALL IS NOT LESS THAN 1-HOUR

FIRE-RESISTANCE RATED FOR A DISTANCE ON EACH SIDE OF THE FIRE WALL EQUAL TO THE DEPTH OF THE PROJECTING ELEMENT.

OPENINGS WITHIN SUCH EXTERIOR WALLS SHALL BE PROTECTED BY OPENING PROTECTIVES HAVING A FIRE PROTECTION RATING OF NOT LESS THAN 3/4 HOUR.

3. FOR COMBUSTIBLE HORIZONTAL PROJECTING ELEMENTS WITH CONCEALED SPACES, THE FIRE WALL

NEED ONLY EXTEND THROUGH THE CONCEALED SPACE TO THE OUTER EDGES OF THE PROJECTING ELEMENTS. THE EXTERIOR WALL BEHIND AND BELOW THE PROJECTING ELEMENT SHALL BE OF NOT LESS THAN 1-HOUR FIRE-RESISTANCE RATED CONSTRUCTION FOR A DISTANCE NOT LESS THAN THE DEPTH OF THE PROJECTING ELEMENTS ON BOTH SIDES OF THE FIRE WALL. OPENINGS WITHIN SUCH EXTERIOR

WALLS SHALL BE PROTECTED BY OPENING PROTECTIVES HAVING A FIRE PROTECTION RATING OF NOT LESS THAN 3/4 HOUR.
706.6 VERTICAL CONTINUITY. FIRE WALLS SHALL EXTEND FROM THE FOUNDATION TO A TERMINATION POINT AT LEAST 30" ABOVE BOTH ADJACENT ROOFS.

EXCEPTIONS:

1. STEPPED BUILDINGS IN ACCORDANCE WITH SECTION 706.6.1.

2. TWO-HOUR FIRE-RESISTANCE-RATED WALLS SHALL BE PERMITTED TO TERMINATE AT THE UNDERSIDE OF THE ROOF SHEATHING, DECK OR SLAB, PROVIDED THAT:

2.1. THE LOWER ROOF ASSEMBLY WITHIN 4 FEET OF THE WALL HAS NOT LESS THAN A 1-HOUR FIRE

RESISTANCE RATING AND THE ENTIRE LENGTH AND SPAN OF SUPPORTING ELEMENTS FOR THE RATED ROOF ASSEMBLY HAS A FIRE-RESISTANCE RATING OF NOT LESS THAN 1 HOUR.

2.2. OPENINGS IN THE ROOF SHALL NOT BE LOCATED WITHIN 4 FEET OF THE FIRE WALL.

2.3. EACH BUILDING SHALL BE PROVIDED WITH NOT LESS THAN A CLASS B ROOF COVERING.

3. WALLS SHALL BE PERMITTED TO TERMINATE AT THE UNDERSIDE OF NONCOMBUSTIBLE ROOF

SHEATHING, DECK OR SLABS WHERE BOTH BUILDINGS ARE PROVIDED WITH NOT LESS THAN A CLASS B ROOF COVERING. OPENINGS IN THE ROOF SHALL NOT BE LOCATED WITHIN 4 FEET OF THE FIRE WALL.

4. IN BUILDINGS OF TYPE III, IV AND V CONSTRUCTION, WALLS SHALL BE PERMITTED TO TERMINATE

AT THE UNDERSIDE OF COMBUSTIBLE ROOF SHEATHING OR DECKS, PROVIDED THAT ALL OF THE FOLLOWING REQUIREMENTS ARE MET.

4.1 ROOF OPENINGS ARENOT LESS THAN 4 FEET FROM THE FIRE WALL,

4.2 THE ROOF IS COVERED WITH A MINIMUM CLASS B ROOF COVERING.

4.3 THE ROOF SHEATHING OR DECK IS CONSTRUCTED OF FIRERETARDANT- TREATED WOOD FOR A DISTANCE OF 4 FEET ON BOTH SIDES OF THE WALL OR THE ROOF IS PROTECTED WITH 5/8" TYPE X

GYPSUM BOARD DIRECTLY BENEATH THE UNDERSIDE OF THE ROOF SHEATHING OR DECK, SUPPORTED BY NOT LESS THAN 2-INCH NOMINAL LEDGERS ATTACHED TO THE SIDES OF THE ROOF FRAMING MEMBERS FOR A DISTANCE OF NOT LESS THAN 4 FEET ON BOTH SIDES OF THE FIRE WALL.

5. IN BUILDINGS DESIGNED IN ACCORDANCE WITH SECTION 510.2, FIRE WALLS LOCATED ABOVE THE 3-HOUR HORIZONTAL ASSEMBLY REQUIRED BY SECTION 510.2, ITEM 1 SHALL BE PERMITTED TO EXTEND FROM THE TOP OF THIS HORIZONTAL ASSEMBLY.

BUILDINGS WITH SLOPED ROOFS IN ACCORDANCE WITH SECTION 706.6.2. 706.6.1 STEPPED BUILDINGS. WHERE A FIRE WALL SERVES AS AN EXTERIOR WALL FOR A BUILDING AND

SEPARATES BUILDINGS HAVING DIFFERENT ROOF LEVELS, SUCH WALL SHALL TERMINATE AT A POINT NOT LESS THAN 30 INCHES (762 MM) ABOVE THE LOWER ROOF LEVEL, PROVIDED THE EXTERIOR WALL FOR A HEIGHT OF 15 FEET (4572 MM) ABOVE THE LOWER ROOF IS NOT LESS THAN 1-HOUR

FIRE-RESISTANCERATED CONSTRUCTION FROM BOTH SIDES WITH OPENINGS PROTECTED BY FIRE ASSEMBLIES HAVING A FIRE PROTECTION RATING OF NOT LESS THAN 3/4 HOUR.

EXCEPTION: WHERE THE FIRE WALL TERMINATES AT THE UNDERSIDE OF THE ROOF SHEATHING, DECK OR SLAB OF THE LOWER ROOF, PROVIDED THAT:

1. THE LOWER ROOF ASSEMBLY WITHIN 10 FEET (3048MM) OF THE WALL HAS NOT LESS THAN A 1-HOUR FIRE RESISTANCE RATING AND THE ENTIRE LENGTH AND SPAN OF SUPPORTING ELEMENTS FOR THE RATED ROOF ASSEMBLY HAS A FIRE-RESISTANCE RATING OF NOT LESS THAN 1 HOUR.

2. OPENINGS IN THE LOWER ROOF SHALL NOT BE LOCATED WITHIN 10 FEET (3048 MM) OF THE FIRE WALL.
706.8 OPENINGS. EACH OPENING THROUGH A FIRE WALL SHALL BE PROTECTED IN ACCORDANCE WITH SECTION 716.5 AND SHALL NOT EXCEED 156 SQUARE FEET (15 m2). THE AGGREGATE WIDTH OF OPENINGS AT ANY FLOOR LEVEL SHALL NOT EXCEED 25 PERCENT OF THE LENGTH OF THE WALL.

EXCEPTIONS:

1. OPENINGS ARE NOT PERMITTED IN PARTY WALLS CONSTRUCTED IN ACCORDANCE WITH SECTION 706.1.1.

2. OPENINGS SHALL NOT BE LIMITED TO 156 SQUARE FEET (15 m2) WHERE BOTH BUILDINGS ARE

EQUIPPED THROUGHOUT WITH AN AUTOMATIC SPRINKLER SYSTEM INSTALLED IN ACCORDANCE WITH SECTION 903.3.1.1.
706.9 PENETRATIONS. PENETRATIONS OF FIRE WALLS SHALL COMPLY WITH SECTION 714. 706.10 JOINTS. JOINTS MADE IN OR BETWEEN FIRE WALLS SHALL COMPLY WITH SECTION 715. 706.11 DUCTS AND AIR TRANSFER OPENINGS. DUCTS AND AIR TRANSFER OPENINGS SHALL NOT PENETRATE FIRE WALLS.

EXCEPTION: PENETRATIONS BY DUCTS AND AIR TRANSFER OPENINGS OF FIRE WALLS THAT ARE NOT ON

A LOT LINE SHALL BE ALLOWED PROVIDED THE PENETRATIONS COMPLY WITH SECTION THE SIZE AND AGGREGATE WIDTH OF ALL OPENINGS SHALL NOT EXCEED THE LIMITATIONS OF SECTION 706.8.

FLOOR PLAN H

FLOOR PLAN I FLOOR PLAN J

FLOOR PLAN L

FLOOR PLAN K

FLOOR PLAN N

FLOOR PLAN M

FLOOR PLAN P

FLOOR PLAN O

FLOOR PLAN Q

DENOTES PROPOSED LOCATION OF
BMR UNIT. SUBJECT TO CHANGE.

NOTE:
"BMR"
IDF
DINING
29'-8"
151 CERVANTES ROAD
PORTOLA VALLEY, CA 94041 8'-0"
29'-11 1/4" 49'-3" 49'-3" 23'-2" 26'-1"
11"
17'-4 1/4" 29'-11 3/4"
47'-4" 1'-0"
18'-10 3/4"
2 1/4"

STORAGE
POWDER
ROOM 49'-3" 23'-8" 25'-7" 49'-3" 23'-8" 25'-7" 49'-3" 23'-8" 25'-7" 49'-3" 23'-8" 25'-7" A1.1

BUILDING FLOOR PLANS

FLOOR PLAN HRB

LANDING
19'-9"
49'-7 1/4"
11"
11"
11"
11"
DECK
DECK 1'-8" 1'-8" 1'-8"
DECK 1'-8"
LANDING 4'-0" 4'-0" 4'-0" 22'-5 3/4" 16'-4 3/4" 24'-4 3/4" 11"

JANITOR
TYPE I-A NON BEARING EXTERIOR WALLS:
1-HOUR FIRE-RATED PARTITION WALLS
OPENNINGS: 75% MAX.

TYP. AT REAR OF BUILDING BELOW PODIUM
TYPE I-A NON BEARING EXTERIOR WALLS:

REQUIRED: 1-HOUR FIRE-RATED WALLS
PROVIDED: 2-HOUR FIRE-RATED WALLS
OPENNINGS: 25% MAX.

TYP. AT SIDES OF BUILDING BELOW PODIUM
TYPE I-A NON BEARING EXTERIOR WALLS:

REQUIRED: 1-HOUR FIRE-RATED WALLS
PROVIDED: 2-HOUR FIRE-RATED WALLS
OPENNINGS: 25% MAX.

TYP. AT SIDES OF BUILDING BELOW PODIUM
TYPE I-A NON BEARING EXTERIOR WALLS:

REQUIRED: 1-HOUR FIRE-RATED WALLS
PROVIDED: 2-HOUR FIRE-RATED WALLS
OPENNINGS: 25% MAX.

TYP. AT SIDES OF BUILDING BELOW PODIUM
TYPE I-A NON BEARING EXTERIOR WALLS:

REQUIRED: 1-HOUR FIRE-RATED WALLS
PROVIDED: 2-HOUR FIRE-RATED WALLS
OPENNINGS: 25% MAX.

TYP. AT SIDES OF BUILDING BELOW PODIUM
29'-4 1/4"

JULIET BALCONY

DECK DECK

JULIET BALCONY
2 1/4"

FLOOR PLAN I

GIFT SHOP

AESTHETICS
LIGHTING NOTES: ALL EXTERIOR LIGHTING SHALL EMPLOY THE USE OF CUT-OFF FIXTURES TO RESTRICT THE DIRECTION OF THE LIGHT SO AS NOT TO BE DIRECTLY VISIBLE FROM OFF-SITE.

RECREATION COURTS: NO ARTIFICIAL LIGHTING SHALL BE PERMITTED FOR TENNIS AND OTHER RECREATION COURTS.

SWIMMING POOL AND SPAS: ARTIFICIAL LIGHTING OF SWIMMING POOLS AND SPAS SHALL BE PLACED BENEATH THE SURFACE OF THE WATER IN THE POOL OR SPA TO ILLUMINATE THE WATER.

OTHER EXTERIOR LIGHTS USED TO ILLUMINATE THE SURROUNDING AREA USE THE MINIMUM NUMBER AND WATTAGE OF LIGHT WHICH WILL SAFELY ILLUMINATE THE AREA.

HIGH INTENSITY LIGHTING PROHIBITED: HIGH INTENSITY DISCHARGE LIGHTING, SUCH AS MERCURY VAPOR, HIGH- AND LOW-PRESSURE SODIUM, AND METAL HALIDE LIGHTING IS PROHIBITED.

OUTDOOR LIGHTING: OUTDOOR LIGHTING SHOULD USE THE MINIMUM NUMBER AND WATTAGE LIGHTS WHICH WILL SAFELY ILLUMINATE THE AREA. OUTDOOR LIGHT SOURCES SHALL BE SHIELDED SO AS NOT TO BE DIRECTLY VISIBLE FROM OFF-SITE.

BIOLOGICAL RESOURCES

NESTING MIGRATORY BIRDS ARE PROTECTED UNDER THE MIGRATORY BIRD TREATY ACT, AND SECTION 3503 OF THE CALIFORNIA FISH AND GAME CODE. SEVERAL SPECIES OF BATS THAT INHABIT THE BAY AREA ARE LISTED AS A CALIFORNIA SPECIES OF SPECIAL CONCERN (CSSC). TREE REMOVAL HAS THE POTENTIAL TO DISTURB NESTING MIGRATORY BIRDS AND BATS. THUS, ALL APPLICATIONS THAT INCLUDE TREE REMOVAL ARE REQUIRED TO IMPLEMENT THE FOLLOWING MEASURES AS STANDARD CONDITIONS OF PROJECT APPROVAL:

NESTING BIRDS:

1.TO MINIMIZE POTENTIAL IMPACTS ON NESTING BIRDS, THE APPLICANT SHALL AVOID CONSTRUCTION ACTIVITIES (I.E., TREE PRUNING, TREE REMOVAL, TREE PROTECTION WORK, DEMOLITION, GRADING, AND CONSTRUCTION) DURING THE ACTIVE NESTING SEASON (BETWEEN FEBRUARY 1, AND AUGUST 31). IF IT IS NOT POSSIBLE TO SCHEDULE CONSTRUCTION ACTIVITIES BETWEEN SEPTEMBER 1 AND JANUARY 31, THEN

PRE-CONSTRUCTION SURVEYS FOR NESTING BIRDS SHOULD BE CONDUCTED BY A QUALIFIED

BIOLOGIST TO ENSURE THAT NO NESTS WILL BE DISTURBED DURING PROJECT IMPLEMENTATION. THESE SURVEYS SHALL BE CONDUCTED NO MORE THAN 7 DAYS PRIOR TO THE INITIATION OF CONSTRUCTION ACTIVITIES. DURING THIS SURVEY, A QUALIFIED BIOLOGIST WILL INSPECT ALL TREES AND OTHER POTENTIAL NESTING HABITATS (E.G., TREES, SHRUBS, AND STRUCTURES) IN AND IMMEDIATELY ADJACENT TO THE IMPACT AREAS FOR NESTS. IF AN

ACTIVE NEST IS FOUND SUFFICIENTLY CLOSE TO WORK AREAS TO BE DISTURBED BY THESE

ACTIVITIES, THE BIOLOGIST WILL DETERMINE THE EXTENT OF A CONSTRUCTION-FREE BUFFER ZONE TO BE ESTABLISHED AROUND THE NEST (TYPICALLY 300 FT FOR RAPTORS AND 100 FT

FOR OTHER SPECIES, TYPICALLY RECOMMENDED BY THE CALIFORNIA DEPARTMENT OF FISH

AND WILDLIFE), TO ENSURE THAT NO NESTS OF SPECIES PROTECTED BY THE MIGRATORY BIRD

TREATY ACT AND CALIFORNIA FISH AND GAME CODE WILL BE DISTURBED DURING PROJECT IMPLEMENTATION. 2. IF CONSTRUCTION ACTIVITIES WILL NOT BE INITIATED UNTIL AFTER THE START OF THE NESTING SEASON, ALL POTENTIAL NESTING SUBSTRATES (E.G., BUSHES, TREES, GRASSES, AND OTHER

VEGETATION) THAT ARE SCHEDULED TO BE REMOVED BY THE PROJECT SHOULD BE REMOVED PRIOR TO THE START OF THE NESTING SEASON (E.G., PRIOR TO FEBRUARY 1). THIS WILL

REDUCE THE INITIATION OF NESTS IN

THE VEGETATION AND REDUCE POTENTIAL DELAYS OF THE PROJECT DUE TO THE PRESENCE OF ACTIVE NESTS WITHIN THESE SUBSTRATES. BATS:

1.A QUALIFIED BIOLOGIST SHALL VISUALLY INSPECT TREES TO BE REMOVED FOR BAT ROOSTS WITHIN 7 DAYS PRIOR TO THEIR REMOVAL. THE BIOLOGIST WILL LOOK FOR SIGNS OF BATS

INCLUDING SIGHTINGS OF LIVE OR DEAD BATS, BAT CALLS OR SQUEAKING, THE SMELL OF BATS, BAT DROPPINGS, GREASE STAINS, OR URINE STAINS AROUND OPENINGS IN TREES OR STRUCTURES, OR FLIES AROUND SUCH OPENINGS. TREES WITH MULTIPLE HOLLOWS, CREVICES, FORKED BRANCHES, WOODPECKER HOLES OR LOOSE AND FLAKING BARK HAVE THE HIGHEST CHANCE OF OCCUPATION AND SHALL BE INSPECTED THE MOST CAREFULLY. 2. IF SIGNS OF BATS ARE DETECTED, CDFW SHOULD BE CONTACTED ABOUT HOW TO PROCEED.

ECHO-LOCATION SURVEYS MAY BE NEEDED TO VERIFY THE PRESENCE OF BATS, OR AN

EXCLUSION ZONE AROUND THE OCCUPIED TREE MAY BE RECOMMENDED UNTIL BATS LEAVE THE ROOST. DUE TO RESTRICTIONS OF THE CALIFORNIA HEALTH DEPARTMENT, DIRECT CONTACT BY WORKERS WITH ANY BAT IS NOT ALLOWED. THE QUALIFIED BAT BIOLOGIST

SHALL BE CONTACTED IMMEDIATELY IF A BAT ROOST IS DISCOVERED DURING PROJECT CONSTRUCTION.

CULTURAL RESOURCES
HUMAN REMAINS: IF ANY HUMAN REMAINS ARE DISCOVERED OR RECOGNIZED IN ANY

LOCATION ON A PROJECT SITE, THERE SHALL BE NO FURTHER EXCAVATION OR

DISTURBANCE OF THE SITE OR ANY NEARBY AREA REASONABLY SUSPECTED TO OVERLIE ADJACENT HUMAN REMAINS UNTIL:

THE SAN MATEO COUNTY CORONER/SHERIFF HAS BEEN INFORMED AND HAS DETERMINED THAT NO INVESTIGATION OF THE CAUSE OF DEATH IS REQUIRED; AND IF THE REMAINS ARE OF NATIVE AMERICAN ORIGIN:
a) THE DESCENDANTS OF THE DECEASED NATIVE AMERICANS HAVE MADE A

RECOMMENDATION TO THE LANDOWNER OR THE PERSON RESPONSIBLE FOR THE

EXCAVATION WORK, FOR MEANS OF TREATING OR DISPOSING OF, WITH APPROPRIATE

DIGNITY, THE HUMAN REMAINS AND ANY ASSOCIATED GRAVE GOODS AS PROVIDED IN PUBLIC RESOURCES CODE SECTION 5097.98; OR
b) THE NATIVE AMERICAN HERITAGE COMMISSION WAS UNABLE TO IDENTIFY A DESCENDANT OR THE DESCENDANT FAILED TO MAKE A RECOMMENDATION WITHIN 24 HOURS AFTER BEING NOTIFIED BY THE COMMISSION. DEFENSIBLE SPACE NOTES CFC Sec. 4291: THIS PROJECT SHALL BE CONSTRUCTED AND MAINTAINED TO:
(1)(A) MAINTAIN DEFENSIBLE SPACE OF 100 FEET FROM EACH SIDE AND FROM THE FRONT AND

REAR OF THE STRUCTURE, BUT NOT BEYOND THE PROPERTY LINE, EXCEPT AS PROVIDED IN SUBPARAGRAPH (B). THE AMOUNT OF FUEL MODIFICATION NECESSARY SHALL CONSIDER THE

FLAMMABILITY OF THE STRUCTURE AS AFFECTED BY BUILDING MATERIAL, BUILDING STANDARDS, LOCATION, AND TYPE OF VEGETATION. FUELS SHALL BE MAINTAINED AND SPACED IN A CONDITION

SO THAT A WILDFIRE BURNING UNDER AVERAGE WEATHER CONDITIONS WOULD BE UNLIKELY TO IGNITE THE STRUCTURE. THIS SUBPARAGRAPH DOES NOT APPLY TO SINGLE SPECIMENS OF TREES

OR OTHER VEGETATION THAT ARE WELL-PRUNED AND MAINTAINED SO AS TO EFFECTIVELY

MANAGE FUELS AND NOT FORM A MEANS OF RAPIDLY TRANSMITTING FIRE FROM OTHER NEARBY VEGETATION OR TO INTERRUPT THE ADVANCE OF EMBERS TOWARD A STRUCTURE. THE INTENSITY OF FUELS MANAGEMENT MAY VARY WITHIN THE 100-FOOT PERIMETER OF THE STRUCTURE, WITH MORE INTENSE FUEL REDUCTIONS BEING UTILIZED BETWEEN 5 AND 30 FEET AROUND THE STRUCTURE, AND AN EMBER-RESISTANT ZONE BEING REQUIRED WITHIN 5 FEET OF STRUCTURE,

BASED ON REGULATIONS PROMULGATED BY THE BOARD, IN CONSULTATION WITH THE

DEPARTMENT, TO CONSIDER THE ELIMINATION OF MATERIALS IN THE EMBER-RESISTANT ZONE THAT WOULD LIKELY BE IGNITED BY EMBERS. CONSISTENT WITH FUELS MANAGEMENT

OBJECTIVES, STEPS SHOULD BE TAKEN TO MINIMIZE EROSION, SOIL DISTURBANCE, AND THE SPREAD OF FLAMMABLE NONNATIVE GRASSES AND WEEDS. FOR PURPOSES OF THIS SUBPARAGRAPH, "FUEL" MEANS ANY COMBUSTIBLE MATERIAL, INCLUDING PETROLEUM-BASED PRODUCTS, CULTIVATED LANDSCAPE PLANTS, GRASSES, WEEDS, AND WILDLAND VEGETATION. (2) REMOVE THAT PORTION OF A TREE THAT EXTENDS WITHIN 10 FEET OF THE OUTLET OF A CHIMNEY OR STOVEPIPE.
(3) MAINTAIN A TREE, SHRUB, OR OTHER PLANT ADJACENT TO OR OVERHANGING A BUILDING FREE OF DEAD OR DYING WOOD.
(4) MAINTAIN THE ROOF OF A STRUCTURE FREE OF LEAVES, NEEDLES, OR OTHER VEGETATIVE MATERIALS.
(5) BUILDING SHALL COMPLY WITH ALL STATE BUILDING STANDARDS, INCLUDING THOSE DESCRIBED IN SUBDIVISION (b) OF SECTION 51189 OF THE GOVERNMENT CODE. UPON COMPLETION

OF THE CONSTRUCTION OR REBUILDING, THE OWNER SHALL OBTAIN FROM THE LOCAL BUILDING

OFFICIAL, A COPY OF THE FINAL INSPECTION REPORT THAT DEMONSTRATES THAT THE DWELLING

OR STRUCTURE WAS CONSTRUCTED IN COMPLIANCE WITH ALL APPLICABLE STATE AND LOCAL BUILDING STANDARDS, INCLUDING THOSE DESCRIBED IN SUBDIVISION (b) OF SECTION 51189 OF

THE GOVERNMENT CODE, AND SHALL PROVIDE A COPY THAT INSURES THE DWELLING OR STRUCTURE.

1. THIS CONSTRUCTION DOCUMENT SET IS INCLUSIVE OF THE DRAWING SHEETS LISTED IN THE SHEET INDEX(A0.0) AND THE PROJECT MANUAL.

2. THE CONTRACTOR SHALL CHECK AND VERIFY ALL DIMENSIONS AND CONDITIONS FOR BUILDING AND SITE PRIOR TO PROCEEDING WITH THE WORK.

3. WRITTEN DIMENSIONS TAKE PRECEDENCE OVER SCALED DIMENSIONS. DO NOT SCALE THE DRAWINGS.

4. ALL DIMENSIONS, WHEN SHOWN IN THE ARCHITECTURAL PLANS, ARE TO FACE OF STUD, MASONRY, OR CONCRETE, OR CENTERLINE OF COMMON WALL UNLESS OTHERWISE NOTED.

5. ALL CHANGES IN FLOOR MATERIAL OCCUR AT THE CENTERLINE OF DOOR OR FRAMED OPENING UNLESS OTHERWISE INDICATED ON THE DRAWINGS.

6. GLASS SUBJECTED TO HUMAN IMPACT SHALL BE OF SAFETY GLAZING MATERIAL ( LAMINATED, UNLESS OTHERWISE WHERE REQUIRED AND SHALL MEET LOCAL, STATE, AND FEDERAL REQUIREMENTS.

7. ANY SURVEY MONUMENTS WITH IN THE AREA OF CONSTRUCTION SHALL BE PRESERVED OR RESET BY A REGISTERED CIVIL ENGINEER OR A LICENSED LAND SURVEYOR.

8. PRIOR TO BIDDING, THE GENERAL CONTRACTOR AND ALL SUB-CONTRACTORS SHALL VISIT THE SITE AND

BECOME ACQUAINTED WITH ALL CONDITIONS RELATING TO THE CONSTRUCTION AND COMPLETION OF THE PROJECT AND THE EMPLOYMENT OF LABOR THEREON. BIDDERS AND THEIR SUB-CONTRACTORS SHALL REPORT ANY DISCREPANCIES TO THE ARCHITECT.

9. HAZARDOUS MATERIALS: IN THE EVENT THAT HAZARDOUS MATERIALS ARE ENCOUNTERED IN THE

PREMISES DURING THE EXECUTION OF THE WORK, NOTIFY THE OWNER IMMEDIATELY AND DO NOT PROCEED UNTIL DIRECTED. FOLLOW ALL CAL OSHA REQUIREMENTS.

10. NOTES ARE AN AID TO THE CONTRACTOR IN UNDERSTANDING THE WORK AND SHOULD NOT BE CONSTRUCTED AS BEING COMPLETE IN EVERY DETAIL. IT IS THE RESPONSIBILITY OF THE CONTRACTOR TO

BECOME THOROUGHLY FAMILIAR WITH THE WORK, AND REPORT ALL DISCREPANCIES BETWEEN THE DRAWINGS AND THE ACTUAL CONDITIONS TO THE ARCHITECT.

11. THE DRAWINGS INDICATE LOCATION, DIMENSIONS, REFERENCE, AND TYPICAL DETAILS OF CONSTRUCTION. THE DRAWINGS DO NOT ILLUSTRATE EVERY CONDITION. WORK NOT PARTICULARLY DETAILED SHALL BE OF CONSTRUCTION SIMILAR TO PARTS THAT ARE DETAILED.

12. DO NOT SUBSTITUTE, REVISE, OR CHANGE THE WORK WITHOUT THE WRITTEN CONSENT OF THE ARCHITECT.

13. INSTALL ALL WORK PLUMB, LEVEL SQUARE,TRUE, AND IN PROPER ALIGNMENT.

14. COORDINATE ALL WORK AS REQUIRED BY THE CONTRACT DOCUMENTS WITH THE OWNER, INCLUDING TEMPORARY STORAGE, LOADING, KEYING SYSTEMS, ETC., AND PROVIDE NECESSARY BARRICADES, SIGNS, BARRIERS, AND PROTECTION.

15. CONTRACTOR SHALL PAY SPECIFIC ATTENTION TO THE DIMENSIONS OR IMPLIED PLAN AND SECTIONAL SPATIAL RELATIONSHIPS, AND VERIFY ALL AXES AND IMPLIED SYMMETRIES BEFORE BEGINNING WORK.

16. PROVIDE AND COORDINATE LOCATION AND TYPE OF BLOCKING/ BACKING IN PARTITIONS BEHIND ALL WALL MOUNTED ITEMS. REVIEW ALL BLOCKING W/ ARCHITECT IN FIELD PRIOR TO COVERING W/ OTHER MATERIAL.

17. DETAILED AND LARGER SCALE DRAWINGS TAKE PRECEDENCE OVER SMALLER SCALE DRAWINGS.

BMR BMR
BMR

WOODRATS
A QUALIFIED BIOLOGIST SHALL VISUAL INSPECT THE SITE 30 DAYS PRIOR TO COMMENCEMENT

TO IDENTIFY ANY SAN FRANCISCO DUSKY-FOOTED WOODRATS (SFDW) HOUSES AND DETERMINE WHETHER THE NESTS ARE ACTIVE OR INACTIVE. IF AN ACTIVE SFDW HOUSE IS FOUND OUTSIDE

OF THE GRADING FOOTPRINT, THE ACTIVE HOUSE SITE WILL BE DESIGNATED AS "ECOLOGICALLY SENSITIVE AREAS" (ESA) AND PROTECTED DURING PROJECT CONSTRUCTION WITH ESTABLISHMENT OF FLAGGING OR A FENCE BARRIER SURROUNDING THE NEST SITE.

IF SFDW HOUSES ARE FOUND WITHIN THE GRADING FOORPRINT AND IMPACTS CANNOT BE AVOIDED, A BIOLOGIST WILL PREPARE AN SFDW HOUSE RELOCATION PLAN. THE PLAN WILL

IDENTIFY THE LOCATION OF THE ACTIVE HOUSES, THE NEED FOR RELOCATION, THE NEW LOCATION, AND THE METHODS FOR RELOCATION. THE METHODS MAY INCLUDE CREATING A

NEW NEST BOX, CAPTURING THE RAT(S) OVER UP TO TWO NIGHTS OF TRAPPING WITH EVENING

SET AND EARLY MORNING CHECK, RELOCATING THE NEST CUP AND LARDER TO THE NEW NEST

BOX, REBUILDING THE STICK HOUSE OVER THE NEST BOX, RELEASING THE RAT(S) INTO IT AND ADDING STICKS TO PREVENT THE RATS FROM BOLTING IMMEDIATELY. THE METHODS WILL BE

DETERMINED BY THE BIOLOGIST ACCORDING TO THE LATEST SCIENTIFIC INFORMATION AVAILABLE.

ITEM 2A ATTACHMENT 8A

Page 567 of 1435 ends

609.2'
620.4'
620.4'
631.6' 10
8 8
7 7 10 OFF 10
8 8
7 7 10 OFF
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8
A1.2
SCALE:
1"=20'

BUILDING PLANS & ROOF PLAN NORTH
20' 40' 60'
IDF

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH
21'-9"
22'-11 1/4" 18'-0 3/4" 11'-6"
14'-7 3/4"
30'-6" 25'-7" 1'-6"
60'-8 1/4" 9" 1'-0"
3'-8" 23'-8"
2 1/4" 44'-10 7/8" 2 1/4" 62'-5 3/8" 47'-7 3/4" 14'-1" 29'-8"1'-8" 8'-7"
2 1/4"
47'-10"
2 1/4" 2 1/4" 2 1/4"
2 1/4" 2 1/4"
214'-4"
213'-5" 49'-3"

FLOOR PLAN G

FLOOR PLAN E

FLOOR PLAN D

FLOOR PLAN B

FLOOR PLAN F

FLOOR PLAN C
2 1/4"
44" CORRIDOR 52'-6"
LEVEL 3

BUILDING PLAN

DECK DECK

DECK DECK DECK DECK
IDF

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH
21'-9"
22'-11 1/4" 18'-6 3/4" 11'-0"
14'-7 3/4" 25'-7"
60'-8 1/4" 1'-6"9" 1'-0"
3'-8" 23'-8"
2 1/4" 44'-10 7/8" 2 1/4" 62'-5 3/8" 47'-7 3/4" 14'-1"
8'-7" 42'-3 3/4"
2 1/4"
47'-10"
2 1/4" 2 1/4" 2 1/4"
3'-0"
2 1/4" 2 1/4"
214'-4"
213'-5" 49'-3"

FLOOR PLAN E

FLOOR PLAN D

FLOOR PLAN B

FLOOR PLAN A

FLOOR PLAN F

FLOOR PLAN C
2 1/4"
44" CORRIDOR 52'-6"
LEVEL 4

BUILDING PLAN

DECK DECK DECK

DECK DECK DECK

MUSIC ROOM
POWDER
ROOM
DECK
14'-5 1/8"
2'-0"

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1
12'-3"
14'-4"
18'-1" 25'-8"
28'-6 1/2" 3'-2" 9" 1'-0" 23'-7"
15'-5" 29'-8 1/8" 33'-2 3/4" 33'-0 1/4" 14'-1" 14'-7 3/8" 8'-7" 15'-1 1/4" 90'-5"
214'-4"
213'-5" 49'-3" 52'-6"
LEVEL 5/ ROOF TERRACE

BUILDING PLAN

DECK BELOW
29'-11 3/4"
14'-9 5/8" 29'-11" 15'-2 7/8" 1'-8"

FAN DUCTS TO GARAGE
18" HT. GLASS RAIL 1'-8"
18" HT. GLASS RAIL
48" HT. GLASS RAIL 48" HT. GLASS RAIL
UP
UP
UP
DN
YOGA
ROOM

DOG RUN
POOL
BATTERY BACKUP, TYP.

POWDER
ROOM
102'-10 1/2" 22'-2" 23'-11 3/4"
42'-3 3/4" 31'-8"
POOL EQUIPMENT, TYP.
48"HT.PARAPET WALL
48" HT.PARAPET WALL 48" HT. PARAPET WALL
MECH.ROOM
A.C UNITS, TYP.

EQUIPMENT ROOF

BUILDING PLAN
109'-4 1/2" 40'-0"
118'-8 1/4" 48'-10"
36" HT.PARAPETWALL 36" HT.PARAPETWALL
36" HT.PARAPETWALL 36" HT.PARAPETWALL
FLOOR PLAN A 6" 4'-4"
POWDER
ROOM

ROOF GARDEN

REF ROOM

KITCHEN
PANTRY

FLOOR PLAN GR
30'-6"
DECK

ELEVATOR
#2
EXIT
STAIR #2
VENT
SHAFT
UP
DN
DECK
11" 1'-8"
DECK 11"
11"
15'-2 7/8" 18" HT. GLASS RAIL
18" HT. GLASS RAIL 36" HT. GLASS RAIL
POWDER
ROOM

CANOPY WITH APPROVED COVERING HAVING A
FLAME SPREAD INDEX OF NOT GREATER THAN 25
9'-6"
POWDER
ROOM 11'-6"
TRASH 6'-2"
BAR
DINING

MULTI PURPOSE ROOM

FIRE PIT

OUTDOOR

SEATING

OUTDOOR

SEATING

SHUFFLE BOARD
4'-4" 4'-4"
4'-4"
18" HT. GLASS RAIL 11'-6"
14'-7 3/4"

KITCHEN STORAGE
10" 10"

PREP ROOM
VENT STACK, TYP.

VENT STACK, TYP.
15'-9" 11'-8" 13'-4"
22'-8" 7'-5" 17'-7"
1'-11"
5'-0"
DECK

JULIET BALCONY

JULIET BALCONY

CRAFT ROOM

ART ROOM
2'-0"
ITEM 2A ATTACHMENT 8A

Page 568 of 1435 ends

South
558.0'
560.0'
562.0'
564.0'
566.0'
568.0'
570.0'
572.0'
574.0'
576.0'
578.0'
580.0' 580.0' EDGE OF

PAVEMENT
556.0'
554.0'
582.0'
584.0'
586.0'
588.0'
590.0'
592.0'
645.8' T.O. PARAPET
594.0'
596.0'
598.0'
600.0'
585.5' B.O. PODIUM
586.8' T.O. PODIUM
602.0'
604.0'
606.0'
608.0'
612.0'
614.0'
616.0'
618.0'
620.0'
622.0'
624.0'
626.0'
628.0'
630.0'
632.0'
634.0'
610.0'
608.0' B.O. JOISTS
609.2' T.O. SHEATHING
596.8' B.O. JOISTS
598.0' T.O. SHEATHING
619.2' B.O. JOISTS
620.4' T.O. SHEATHING
630.4' B.O. JOISTS
631.6' T.O. SHEATHING
574.3' B.O. PODIUM
575.6' T.O. PODIUM
563.1' B.O. JOISTS
564.3' T.O. SHEATHING
552.0'
550.0'
548.0'
546.0'
544.0'
542.0'
540.0'
538.0'
536.0'
534.0'
532.0'
551.9' B.O. JOISTS
553.1' T.O. SHEATHING
540.7' B.O. SLAB
541.9' T.O. SLAB
641.6' B.O. JOISTS
642.8' T.O. SHEATHING
636.0'
638.0'
640.0'
642.0'
644.0'
646.0'
581.8'
573.9'
570.6'
568.3'
565.5'
561.6'
557.5'
554.6'
553.0'
547.2'
559.3'
584.8'

8.0% SLOPE

8.0% SLOPE

8.0% SLOPE

8.0% SLOPE

8.0% SLOPE
570.8' GRADE PLANE

LANDING
557.1'

ELEVATOR SHAFT EXIT STAIRS

VENT STACKVENT STACK
570.0'
572.0'
574.0'
576.0'
578.0'
580.0' 580.0' EDGE OF

PAVEMENT
582.0'
584.0'
586.0'
588.0'
590.0'
592.0'
594.0'
596.0'
598.0'
600.0'
585.5' B.O. PODIUM
586.8' T.O. PODIUM
602.0'
604.0'
606.0'
608.0'
612.0'
614.0'
616.0'
618.0'
620.0'
622.0'
624.0'
626.0'
628.0'
630.0'
632.0'
634.0'
610.0'
608.0' B.O. JOISTS
609.2' T.O. SHEATHING
596.8' B.O. JOISTS
598.0' T.O. SHEATHING
619.2' B.O. JOISTS
620.4' T.O. SHEATHING
630.4' B.O. JOISTS
631.6' T.O. SHEATHING
574.3' B.O. PODIUM
575.6' T.O. PODIUM
579.7'
586.8'
577.5'

PLANTERS

DRIVEWAY
645.8' T.O. PARAPET
641.6' B.O. JOISTS
642.8' T.O. SHEATHING
636.0'
638.0'
640.0'
642.0'
644.0'
646.0'
586.0'
OPEN

TO BEYOND
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8
SCALE: 5'0' 10' 20'
1"=10' 73'-2" TOTAL BUILDING HEIGHT TO FINISH GRADE 78'-6" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-4" 11'-2 3/8" 11'-2 3/8" 62'-4" TOTAL BUILDING HEIGHT TO FINISH GRADE FINISH LEVEL 66'-2" TOTAL BUILDING HEIGHT TO FINISH GRADE 66'-7" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8"

SOUTH ELEVATION
1 5'0' 10' 20' SCALE:
1"=10'

WEST ELEVATION
2 COLOR SAMPLES
SW 7666

FLEUR DE SEL
C
F
SW 7020

BLACK FOX
A
SW 6198

SENSIBLE HUE
D

CEMENTITIOUS HORIZONTAL SIDING

ARTISAN V-RUSTIC
G
HTYP

ELEVATORS AND STAIRWELLS ARE EXEMPT FROM
HEIGHT REQUIREMENTS PER CBC 504.3.

ALL LIGHT SOURCES AT EXTERIOR SHALL BE FULL
CUT-OFF DARK SKY COMPLIANT. FOR SURFACE
MOUNTED LIGHT FIXTURE, SEE SHEET 3/A4.1. FOR
RECESSED SOFFIT LIGHT FIXTURE, SEE SHEET 4/A4.1
Work Notes
1 2
SW 6431

LEAPFROG
LEVEL 1
+ 0'-0"

PODIUM / GARAGE
- 11'-4"

BASEMENT
- 22'-6"
LEVEL 2
+ 11'-2"
LEVEL 3
+ 22'-4"
LEVEL 4
+ 33'-7"
LEVEL 5
+ 44'-9"
+ 56'-0"

SUB BASEMENT
- 33'-8"
LEVEL 1
+ 0'-0"
LEVEL 2
+ 11'-2"
LEVEL 3
+ 22'-4"
LEVEL 4
+ 33'-7"
LEVEL 5
+ 44'-9"
ROOF
+ 56'-0"

NATURAL & FINISH GRADE
A

C F TYP
H TYP
J
A1
TYP
A1
TYP
B
G
TYP
G TYP
G
L
TYP
L
TYP
L
TYP
F TYP
A
C
H
C TYP
J
TYP
TYP G
A
A H
C
F TYP
H
L
TYP
J
TYP
TYP
F
TYP
D
H
TYP
J
TYP 10'-0" 1 10'-2 3/8"
2 TYP.

TYP. 2
2 TYP
APPROXIMATE SQUARE FOOTAGE:

THIS IS ONE BUILDING OF APPROXIMATELY 69,369 SQ.FT. 100% OF THE BUILDING IS RESIDENTIAL AND RESIDENTIAL ACCESSORY USES.

ACCESSORY USE BREAKDOWN:

R-2 (RESIDENTIAL)
A-3
B
S-2
47,347 sq.ft.
2,001 sq.ft.
8,857 sq.ft.
7,590 sq.ft.

ACCESSORY 1,005 sq.ft.
11'-2 3/8"
+ 67'-3" 80'-8" 10'-2 3/8"
+ 67'-3"
11'-2 3/8"
ROOF
F TYP
F TYP
10"
10" 10"
K
R-2.1 (ASSISTED LIVING) 2,569 sq.ft.

B
C
C C
C
C
Materials & Colors
NOTE: SEE COLOR SAMPLES ON THIS SHEET FOR

SAMPLE IMAGES AND COLORS

STONE CLADDING, SILVER TRAVERTINE

STEEL FASCIA , SILLS, & ACCENTS
SW 7020 BLACK FOX A
B

CEMENT PLASTER, STEEL TROWEL SMOOTH FINISH
SW 7666 FLEUR DE SEL C

STEEL ACCENT
SW 6431 LEAPFROG F

CEMENTITIOUS HORIZONTAL SIDING

ARTISAN V-RUSTIC, OVER RAINSCREEN G
42" TALL 12MM CLEAR TEMP GLASS
GUARDRAIL. H
WINDOWS: DOUBLE PANE BLACK ALUMINUM

FRAMED J
DOORS: STEEL DOOR
SW 7020 BLACK FOX K

CEMENT PLASTER, STEEL TROWEL SMOOTH FINISH
SW 7020 BLACK FOX A1

FABRIC AWNING OVER ALUMINUM FRAME, COLOR

TO MATCH L A

METAL GARAGE DOOR
SW 6198 SENSIBLE HUE D
B
A1
TYP C
B 4'-0"

FINISH & NATURAL GRADE BEYOND

NATURAL GRADE
3 CANOPY WITH APPROVED COVERING

HAVING A FLAME SPREAD INDEX OF NOT
GREATER THAN 25
NOTE: CBC BUILDING HEIGHTS MEASURED TO TOP OF ROOF MEMBRANE A2.1

ELEVATIONS
H TYP
4 3 EXIT DISCHARGE PATH, 48" CLEAR WIDTH
4 ROOF MEMBRANE
5 TYP
5 HAND RAIL, TYP.
5 TYP
K
K
General Notes

FINISH GRADE SHALL SLOPE AWAY FROM
FOUNDATIONS AT A 5% MIN. SLOPE FOR A MIN. OF
10' 0" AT SOIL AND A MIN. OF 3' 0" AT CONCRETE.

FINISH GRADE SHOWN AT BUILDING FOR ELEVATIONS

1. 2.

FIRE RESISTANCE RATING FOR EXTERIOR WALLS SHALL
COMPLY WITH CBC TABLE 705.5

3. MAXIMUM AREA OF EXTERIOR WALL OPENINGS SHALL
COMPLY WITH CBC TABLE 705.8

4. 2 TYP.
2 TYP.

TYP. 2
EXTERIOR LIGHT FIXTURE TOTAL - 95
SURFACE MOUNTED LIGHT FIXTURE - 94, SEE SHEET 3/A4.1
RECESSED SOFFIT LIGHT FIXTURE - 01, SEE SHEET 4/A4.1
TYP. 2 74'-6" LOWEST BLD'G ACCESS TO ROOF DECK
3/4 HOUR GLASS
1 HOUR GLASS
3/4 HOUR GLASS

SUPPLEMENTAL FIRE
PROTECTION MEASURE #3

STANDPIPE OUTLETS ADDED

AT NORTH & SOUTH

EXTERIOR WALLS
SUPPLEMENTAL FIRE PROTECTION MEASURE #4
INCREASE FIRE RATING OF TYPE 1-A EXTERIOR
NON-BEARING WALLS FROM 1 HOUR (REQ'D) TO
2 HOURS, ALONG SOUTHERN WALL ADJACENT
TO FIREFIGHTER ACCESS PATH.

SUPPLEMENTAL FIRE PROTECTION MEASURE #5
REMOVAL OF GLASS BELOW 10' FROM

FIREFIGHTER'S INGRESS PATH AND INCREASE

FIRE RESISTANCE OF REMAINING GLASS, SEE
ELEVATIONS A2.1 10' MIN. TYP.

NOTE: SEE FIRE ACCESS PLAN A5.0 FOR

MORE INFORMATION ON

SUPPLEMENTAL FIRE PROTECTION

MEASURES
10"
10" 10"
L TYP

MEZZANINE

MEZZANINE
2'-6" PARAPET, TYP.

ITEM 2A ATTACHMENT 8A

Page 569 of 1435 ends

558.0'
560.0'
562.0'
564.0'
566.0'
568.0'
570.0'
572.0'
574.0'
576.0'
578.0'
580.0' 580.0' EDGE OF

PAVEMENT
556.0'
554.0'
582.0'
584.0'
586.0'
588.0'
590.0'
592.0'
635.6' T.O. PARAPET
594.0'
596.0'
598.0'
600.0'
585.5' B.O. PODIUM
586.8' T.O. PODIUM
602.0'
604.0'
606.0'
608.0'
612.0'
614.0'
616.0'
618.0'
620.0'
622.0'
624.0'
626.0'
628.0'
630.0'
632.0'
634.0'
610.0'
608.0' B.O. JOISTS
609.2' T.O. SHEATHING
596.8' B.O. JOISTS
598.0' T.O. SHEATHING
619.2' B.O. JOISTS
620.4' T.O. SHEATHING
630.4' B.O. JOISTS
631.6' T.O. SHEATHING
574.3' B.O. PODIUM
575.6' T.O. PODIUM
563.1' B.O. JOISTS
564.3' T.O. SHEATHING
552.0'
550.0'
548.0'
546.0'
544.0'
542.0'
540.0'
538.0'
551.9' B.O. JOISTS
553.1' T.O. SHEATHING
540.7' B.O. SLAB
541.9' T.O. SLAB

EXIT STAIRS

VENT STACK
558.0'
560.0'
562.0'
564.0'
566.0'
568.0'
570.0'
572.0'
574.0'
576.0'
578.0'
580.0' 580.0' EDGE OF

PAVEMENT
556.0'
554.0'
582.0'
584.0'
586.0'
588.0'
590.0'
592.0'
594.0'
596.0'
598.0'
600.0'
585.5' B.O. PODIUM
586.8' T.O. PODIUM
602.0'
604.0'
606.0'
608.0'
612.0'
614.0'
616.0'
618.0'
620.0'
622.0'
624.0'
626.0'
628.0'
630.0'
632.0'
634.0'
610.0'
608.0' B.O. JOISTS
609.2' T.O. SHEATHING
596.8' B.O. JOISTS
598.0' T.O. SHEATHING
619.2' B.O. JOISTS
620.4' T.O. SHEATHING
630.4' B.O. JOISTS
631.6' T.O. SHEATHING
574.3' B.O. PODIUM
575.6' T.O. PODIUM
563.1' B.O. JOISTS
564.3' T.O. SHEATHING
552.0'
550.0'
548.0'
546.0'
544.0'
542.0'
540.0'
538.0'
551.9' B.O. JOISTS
553.1' T.O. SHEATHING
540.7' B.O. SLAB
541.9' T.O. SLAB
645.8' T.O. PARAPET
641.6' B.O. JOISTS
642.8' T.O. SHEATHING
636.0'
638.0'
640.0'
642.0'
644.0'
646.0'
577.4'
557.1'

LANDING

EXIT STAIRS ELEVATOR
SHAFT
OPEN

TO BEYOND

VENT STACKVENT STACK
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8
11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-4" 11'-2 3/8" 11'-2 3/8" 78'-7" TOTAL BUILDING HEIGHT TO FINISH GRADE 78'-7" TOTAL BUILDING HEIGHT TO FINISH GRADE 68'-2" TOTAL BUILDING HEIGHT TO FINISH GRADE 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-4" 11'-2 3/8" 11'-2 3/8"

NATURAL GRADE
SCALE: 5'0' 10' 20'
1"=10'

NORTH ELEVATION
3 5'0' 10' 20' SCALE:
1"=10'

EAST ELEVATION
4 COLOR SAMPLES
SW 7666

FLEUR DE SEL
C
SW 6431

LEAPFROG
F
SW 7020

BLACK FOX
A
SW 6198

SENSIBLE HUE
D

CEMENTITIOUS HORIZONTAL SIDING

ARTISAN V-RUSTIC
G
F
C
H A
C
F TYP
L
TYP
H
TYP
G
LEVEL 1
+ 0'-0"
- 11'-4"

BASEMENT
- 22'-6"
LEVEL 2
+ 11'-2"
LEVEL 3
+ 22'-4"
LEVEL 4
+ 33'-7"
LEVEL 5
+ 44'-9"
ROOF
+ 56'-0"

SUB BASEMENT
- 33'-8"

PODIUM / GARAGE
LEVEL 1
+ 0'-0"
- 11'-4"

BASEMENT
- 22'-6"
LEVEL 2
+ 11'-2"
LEVEL 3
+ 22'-4"
LEVEL 4
+ 33'-7"
LEVEL 5
+ 44'-9"
+ 56'-0"

SUB BASEMENT
- 33'-8"

PODIUM / GARAGE
G
TYP
J
TYP
A1
TYP
A1
TYP
TYP
F TYP
J
TYP
H
L
C
A1
TYP
TYP
C
H
F
TYP
F 7'-6"
1 2
TYP
2 TYP
2 TYP
TYP 2
2 TYP 10'-0"
1 10'-0" 1 80'-6"
+ 67'-3"
K
TYP
F
C C
B
C
C
G
C
C
F TYP

C F TYP
Materials & Colors
NOTE: SEE COLOR SAMPLES ON THIS SHEET FOR

SAMPLE IMAGES AND COLORS

STONE CLADDING, SILVER TRAVERTINE

STEEL FASCIA , SILLS, & ACCENTS
SW 7020 BLACK FOX A
B

CEMENT PLASTER, STEEL TROWEL SMOOTH FINISH
SW 7666 FLEUR DE SEL C

STEEL ACCENT
SW 6431 LEAPFROG F

CEMENTITIOUS HORIZONTAL SIDING

ARTISAN V-RUSTIC, OVER RAINSCREEN G
42" TALL 12MM CLEAR TEMP GLASS
GUARDRAIL. H
WINDOWS: DOUBLE PANE BLACK ALUMINUM

FRAMED J
DOORS: STEEL DOOR
SW 7020 BLACK FOX K

CEMENT PLASTER, STEEL TROWEL SMOOTH FINISH
SW 7020 BLACK FOX A1

FABRIC AWNING OVER ALUMINUM FRAME, COLOR

TO MATCH L A

METAL GARAGE DOOR
SW 6198 SENSIBLE HUE D
B
G
TYP
TYP
B
F
TYP

CANOPY WITH APPROVED COVERING

HAVING A FLAME SPREAD INDEX OF NOT
GREATER THAN 25 4'-0"
NOTE: CBC BUILDING HEIGHTS MEASURED TO TOP OF ROOF MEMBRANE 9'-0" APPROXIMATE SQUARE FOOTAGE:

THIS IS ONE BUILDING OF APPROXIMATELY 69,369 SQ.FT. 100% OF THE BUILDING IS RESIDENTIAL AND RESIDENTIAL ACCESSORY USES.

ACCESSORY USE BREAKDOWN:

FINISH LEVEL
NATURAL & FINISH GRADE 78'-6"84'-6"
A2.2

ELEVATIONS

CANOPY WITH APPROVED COVERING

HAVING A FLAME SPREAD INDEX OF NOT
GREATER THAN 25 74'-9" LOWEST BUILDING ACCESS TO ROOF DECK TYP
H
TYP
TYP
TYP
4 4
3 TYP 2
TYP 5
General Notes

FINISH GRADE SHALL SLOPE AWAY FROM
FOUNDATIONS AT A 5% MIN. SLOPE FOR A MIN. OF
10' 0" AT SOIL AND A MIN. OF 3' 0" AT CONCRETE.

FINISH GRADE SHOWN AT BUILDING FOR ELEVATIONS

1. 2.

FIRE RESISTANCE RATING FOR EXTERIOR WALLS SHALL
COMPLY WITH CBC TABLE 705.5

3. MAXIMUM AREA OF EXTERIOR WALL OPENINGS SHALL
COMPLY WITH CBC TABLE 705.8

4. TYP 2
EXTERIOR LIGHT FIXTURE TOTAL - 95
SURFACE MOUNTED LIGHT FIXTURE - 94, SEE SHEET 3/A4.1
RECESSED SOFFIT LIGHT FIXTURE - 01, SEE SHEET 4/A4.1

ELEVATORS AND STAIRWELLS ARE EXEMPT FROM
HEIGHT REQUIREMENTS PER CBC 504.3.

ALL LIGHT SOURCES AT EXTERIOR SHALL BE FULL
CUT-OFF DARK SKY COMPLIANT. FOR SURFACE
MOUNTED LIGHT FIXTURE, SEE SHEET 3/A4.1. FOR
RECESSED SOFFIT LIGHT FIXTURE, SEE SHEET 4/A4.1
Work Notes
1 2
3 EXIT DISCHARGE PATH, 48" CLEAR WIDTH
4 ROOF MEMBRANE
5 HAND RAIL, TYP.

SUPPLEMENTAL FIRE PROTECTION MEASURE #3

STANDPIPE OUTLETS ADDED AT NORTH & SOUTH
EXTERIOR WALLS 10' MIN. TYP.
3/4 HOUR
GLASS
3/4 HOUR
GLASS
3/4 HOUR
GLASS
NOTE: SEE FIRE ACCESS PLAN A5.0 FOR

MORE INFORMATION ON

SUPPLEMENTAL FIRE PROTECTION
MEASURES 81'-9"
10" 10"
10" 10"
R-2 (RESIDENTIAL)
A-3
B
S-2
47,347 sq.ft.
2,001 sq.ft.
8,857 sq.ft.
7,590 sq.ft.

ACCESSORY 1,005 sq.ft.

R-2.1 (ASSISTED LIVING) 2,569 sq.ft.

H
F
TYP

MEZZANINE

MEZZANINE
ITEM 2A ATTACHMENT 8A

Page 570 of 1435 ends

558.0'
560.0'
562.0'
564.0'
566.0'
568.0'
570.0'
572.0'
574.0'
576.0'
578.0'
580.0' 580.0' EDGE OF

PAVEMENT
556.0'
554.0'
582.0'
584.0'
586.0'
588.0'
590.0'
592.0'
594.0'
596.0'
598.0'
600.0'
585.5' B.O. PODIUM
586.8' T.O. PODIUM
602.0'
604.0'
606.0'
608.0'
612.0'
614.0'
616.0'
618.0'
620.0'
622.0'
624.0'
626.0'
628.0'
630.0'
632.0'
634.0'
610.0'
608.0' B.O. JOISTS
609.2' T.O. SHEATHING
596.8' B.O. JOISTS
598.0' T.O. SHEATHING
619.2' B.O. JOISTS
620.4' T.O. SHEATHING
630.4' B.O. JOISTS
631.6' T.O. SHEATHING
574.3' B.O. PODIUM
575.6' T.O. PODIUM
563.1' B.O. JOISTS
564.3' T.O. SHEATHING
Section
552.0'
550.0'
548.0'
546.0'
544.0'
542.0'
540.0'
538.0'
536.0'
534.0'
532.0'
530.0'
551.9' B.O. JOISTS
553.1' T.O. SLAB
540.5' B.O. SLAB
541.9' T.O. SLAB
645.8' T.O. PARAPET
641.6' B.O. JOISTS
642.8' T.O. SHEATHING
636.0'
638.0'
640.0'
642.0'
644.0'
646.0'
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8

LOOKING NORTH
10'-5 5/8"
8'-6 7/8"

NATURAL GRADE
79'-10 3/8"
70'-9 5/8"
LEVEL 2
LEVEL 3
LEVEL 4
LEVEL 1

BASEMENT

SUB BASEMENT
PL
PL
EP
5%
20%
2%
8%
580.0'
579.0'
571.85' 571.0'
564.3'
81'-7 15/16"
PODIUM
11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 8'-0"

TRASH ROOM
5% BEYOND
TRASH PATH BEYOND 577.5' F.S.

ELEVATOR & STAIR IN
FOREGROUND 66"66"66"

CAR STACKER
WELL, TYP.

GARAGE

EQUIPMENT ROOF
SCALE: 5'0' 10' 20'
1"=10'

SECTION A-A
1 564.2'
564.0'
566.0'

5.1%
6%
8'-10 3/8"
11'-2 3/8"
LEVEL 5/ ROOF TERRACE 11'-2" 9'-10"
557.0'
551.7'
553.1'
540.5'
541.9'

RETAINING WALL W/

BACKDRAIN

RETAINING WALL W/

BACKDRAIN
4 C4
4 C4
4 C4

FINISH GRADE

AT DRIVEWAY

FINISH GRADE AT CAR

STACKER BEYOND

FINISH GRADE

AT DRIVEWAY

FINISH GRADE AT CAR

STACKER BEYOND
VENT SHAFT 2'-1"
LEVEL 5 TYP. 8'-6"

CANOPY WITH APPROVED COVERING

HAVING A FLAME SPREAD INDEX OF NOT
GREATER THAN 25
A3.1

SECTIONS

STEEL POST
ELEVATOR STAIR #2

MEZZANINE
ITEM 2A ATTACHMENT 8A

Page 571 of 1435 ends

4'-0" 8'-0" 6'-0" 2'-0"
4 x 4 PT POST 1 x 6 REDWOOD SMOOTH
BOARDS W/ 1
2" GAP IN BETWEEN
12" DIA. X 18" DEEP CONC. FOOTING

SET AT EACH POST
2 x 12 PT BOTTOM RAIL
2 x 4 PT STIFFNER
2" CRUSHED ROCK
3" GALVI. DECK SCREWS
4 x 4 PT POST
2 x 4 PT STIFFNER BLIND
FASTENED W/ 2" EXT. GRADE DECK SCREWS
1 x 6 REDWOOD SMOOTH
BOARDS W/ 1
2" GAP IN BETWEEN
4'-0"
PLAN

ELEVATION
4'-0" 4'-0" 8'-0" SECTION
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8

DETAILS

SURFACE MOUNTED LIGHT FIXTURE
NTS 3 ROOF EVE & EXTERIOR FINISH DETAIL

WILDFIRE URBAN INTERFACE ZONE
SCALE: NTS
6 RECESSED SOFFIT LIGHT FIXTURE, TYP
NTS 4

FENCE DETAIL, TYP
SCALE: 1/4"=1'-0" 2

FASCIA DETAIL
SCALE: 3"-1'-0" 1
FASCIA
3 MM THICK
GALV. STEEL
2 5/8"
7 1/4"
1/4" DENSDECK @ TOP &

INSIDE OF CURB
1/4" DENSDECK OVER 2" MIN.

FOAM INSULATION SLOPED
1/4" PER FOOT
80 MIL TPO ROOFING

MEMBRANE
2 X 8 CONTINUOUS

NAILED / SCREWED TO PLY

ROOF SHEATHING

SEE STRUCTURAL
5/8" DENSDECK

UNDER FASCIA &
UNDER STUCCO @
EAVE

NAIL / SCREW

PLYWOOD TO

RAFTER TAILS
1 1/8" PLYWOOD

UNDER FASCIA

RIPPED TO SIZE
3/4"

ROOF FRAMING

SEE STRUCTURAL
1 5/8" 3/4"
3 1/2"
4"
2" 1" STUCCO @

BOTTOM OF EAVE
R-15 FIBERGLASS

BATT INSULATION
5/8" DENSGLASS FIREGAURD
SHEATHING ESR-3087 EXTEND FROM

THE TOP OF THE FOUNDATION TO
THE ROOF. FOR ENCLOSED EAVES,
TERMINATE AT THE ENCLOSURE.

EXTERIOR

SHEATHING

EXTERIOR

CLADDING
1" CEMENT PLASTER AT EAVES &

ARCHITECTURAL PROJECTIONS

FASCIA, SEE
DETAIL 1/A4.1

ROOF SHEATHING, SEE

STRUCTURAL DRAWINGS
R-30 FIBERGLASS

BATT INSULATION
INSULATION: POLYISO CLOSED CELL

FOAM CORE PANELS, SLOPE TO
DRAIN, 2" MIN TO 6" MAX, AVG
DEPTH 3" R-16.8
BARRIER BOARD: 1/4" DENSDECK

ROOF BOARDS BY GEORGIA PACIFIC
2" CLOSED CELL
INSULATION TYP.
@ EAVES AND

ROOF DECKS

DECKING, WHERE OCCURS
ROOFING MEMBRANE: 80 MIL TPO

SINGLE PLY ROOFING MEMBRANE

BY CARLISLE SYNTEC SYSTEMS
1/4" MAX
12"

ROOF RAFTERS, TYP
1 1/8" PLYWOOD
CONTINUOUS 2 x 8
5 NOT IN USE
NTS
A4.1

DETAILS
ITEM 2A ATTACHMENT 8A

Page 572 of 1435 ends

135.00'
135.68'
S 06°24'40" W
N 00°41'00" E
w
N 00° 41' 00" E

68.00'
S 06° 24' 40" W 59.00' S 89° 19' 00" E 260.52' S 88° 36' 00" W 255.12' N 00° 41' 00" E 62.50'
S 06° 24' 40" W 62.81' S 89° 19' 00" E 280.33' N 89° 19' 00" W 274.06'

25.00' 176.83' 5'
R=20' 185.00' 125.00'
100.00'
5'

25.00'
R.O.W.

70.00' 30.00' 30.00' 155.00'
R=20' Δ=41° L=14'-4"
R=40' Δ=41.95° L=29.29'
266.31' 393.13'

75.00'
N 00° 41' 00" E

45.00'

E E E E E E E E E E E
30" PINE
20" MONKEY PUZZLE
19" PINE
22" PINE
10" d MAGNOLIA
8" d GRAPEFRUIT
562 564 566 568 570 572 574 576 578 580 Mora Dr.
10758 Mora 10728 Mora Moraquita Court 70'-8 1/8"
LEVEL 1
LEVEL 2
LEVEL 3
LEVEL 4
PL
30'-0"AERIAL ACCESS ROADWAY 28'-0"DISTANCE TO BUILDING
5%
20%
2%

0.0'
-7.65'
11'-2 3/8" 11'-2 3/8" 11'-2 3/8" 11'-2 3/8"

TRASH ROOM
5% BEYOND

TRASH PATH BEYOND

ELEVATOR
& STAIR IN

FOREGROUND
GARAGE
EQUIP. ROOF 11'-2 3/8"
70°

55.84°
20'-0"(E) ROADWAY
60'-8 11/16"

0.8' 1.0'
67'-9"
LADDER SHOWN AT 80' 9'-0"
CL
Mora Dr.

Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/9/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 2/20/2025 Revision 7

FIRE ACCESS PLAN
THIS PROJECT SHALL COMPLY WITH THE FOLLOWING:

CALIFORNIA FIRE CODE (CFC) & BUILDING (CBC) CODE,
2022 EDITION, AS ADOPTED BY THE TOWN OF LOS ALTOS

HILLS MUNICIPLE CODE (LAHMC) AND CALIFORNIA CODE

OF REGULATIONS (CCR)

FIRE DEPARTMENT NOTES

1. SITE PLAN
15'0' 30' 60' SCALE:
1"=30'

SECTION A NORTH
5'0' 10' 20' SCALE:
1"=10'

HYDRANT SPOTTING PLAN
50'0' 100' 200' SCALE:
1"=100'
NORTH
60'-0" 22'-6"
22'-0" 72'-10"
(N) E.P.
(N) E.P.
(N) E.P. 30'-0" 30'-0" 30'-0" 30'-0" 244'-4" 244'-4"
R=28' TYP.

AERIAL ACCESS ROADWAY 26'
MIN. UNOBSTRUCTED WIDTH,

POSITIONED PARALLEL TO ONE
ENTIRE SIDE OF BUILDING.

AERIAL ACCESS ROADWAY 26'
MIN. UNOBSTRUCTED WIDTH,

POSITIONED PARALLEL TO ONE
ENTIRE SIDE OF BUILDING.

NEW DEAD END FIRE APPARATUS

ACCESS TURNAROUND PER
FIGURE D103.1 (APPENDIX D)
"ACCEPTABLE ALTERNATIVE TO
120' HAMMERHEAD"
5%3% 22'-1"

OVERHEAD UTILITY & POWER

LINES TO UNDERGROUNDED

WITHIN THE AERIAL ACCESS
ROADWAY, TYP. AT BOTH LOTS
(E) POLE

TO REMAIN
A
---

AERIAL APPARATUS

POSITIONED PARALLEL

TO ONE ENTIRE SIDE
OF BUILDING.

Mora Dr.
52'-6" 49'-3"
60'-0"
279'-0"
261'-0"
FDC
L=360'
LEGEND

FIRE HYDRANT

LOCATION

HOSE PULL ROUTE FROM HYDRANT ON

ACCESS ROAD AROUND BUILDING
DISTANCE FROM HYDRANT ON ACCESS L=XXX' ROAD MEASURED AROUND BUILDING L=287'
L=286'
10758 Mora
10728 Mora
(E) FIRE

HYDRANT
(E) FIRE

HYDRANT
(N) FIRE HYDRANT, SEE SITE PLAN FOR

ADDITIONAL DIMENSIONS
L=348'

PROPOSED FIRE

HYDRANT SPACING

PROPOSED FIRE

HYDRANT SPACING
(N) FIRE HYDRANT
PIV

PRIOR TO PERFORMING ANY WORK, THE APPLICANT

SHALL MAKE APPLICATION TO, AND RECIEVE FROM, THE

BUILDING DEPARTMENT ALL APPLICABLE CONSTRUCTION
PERMITS.

2. A STANDPIPE SYSTEM WILL BE INSTALLED AS A DEFERRED
SUBMITTAL.

3. A NEW HYDRANT WILL BE INSTALL AT 10758 MORA DRIVE,

AND NO COMBUSTIBLE CONSTRUCTION CONSTRUCTION
SHALL OCCUR PRIOR TO HYDRANT INSTALLATION.

4. A TWO-WAY COMMUNICATION SYSTEM WILL BE
INSTALLED AS A DEFERRED SUBMITTAL.

5. RADIO COVERAGE WILL BE INSTALLED AS A DEFERRED
SUBMITTAL.

6. 7. A FIRE ALARM WILL BE INSTALLED AS A DEFERRED SUBMITTAL.

AN APPROVED AUTOMATIC SPRINKLER SYSTEM WILL BE
INSTALLED AS A DEFERRED SUBMITTAL.

8. CONSTRUCTION SITE FIRE SAFETY: ALL CONSTRUCTION

SITES MUST COMPLY WITH APPLICABLE PROVISIONS OF
THE CFC CHAPTER 33 AND SCCFD STANDARD DETAIL S1-7

9. ADDRESS IDENTIFICATION: INSTALL APPROVED ADDRESS

NUMBERS PLACED IN A POSITION THAT IS PLAINLY LEGIBLE
AND VISIBLE FROM THE STREET. THE NUMBERS SHALL
CONTRAST WITH THEIR BACKGROUND. PROVIDE IN
ADDITIONAL LOCATIONS IF REQUIRED BY FIRE OFFICIAL.

ADDRESS NUMBERS SHALL BE ARABIC NUMBERS OR
ALPHABETICAL LETTERS. NUMBERS SHALL BE A MINIMUM
OF 4" HIGH WITH MIN. STOKE WIDTH OF 0.5", ADDRESS
NUMBERS SHALL BE MAINTAINED CFC SEC. 505.1

10. WATER SUPPLY REQUIREMENTS: POTABLE WATER SUPPLIES

SHALL BE PROTECTED FROM CONTAMINATION CAUSED BY
FIRE PROTECTION SUPPLIES. COMPLY WITH THE

REQUIREMENTS OF CALIFORNIA WATER SERVICE FOR THE
DESIGN OF WATER BASED FIRE PROTECTION SYSTEMS.

11. LOWEST LEVEL
OF FIRE DEPT.

VEHICULAR
ACCESS

HIGHEST OCCUPIED
FLOOR LEVEL 52'-1"

NOT A HIGH

RISE BUILDING
78'-0" 4'-0" 26'-0" 10'-0"
FIRE DEPT. AERIAL APPARATUS TURNAROUND DRIVING

SURFACE SHALL BE CAPABLE OF SUPPORTING THE

IMPOSED LOAD OF FIRE APPARATUS WEIGHING AT LEAST
75,000 POUNDS.

12. 279'-0"
26'-3" 26'-3" 24'-7 1/2"24'-7 1/2"

FIRE DEPARTMENT APPARATUS ACCESS ROAD (MORA DRIVE)
TO BE MAXIMUM 15% GRADE PER SEC. 503.2.7 OF THE
2022 CFC AS AMENDED BY THE TOWN OF LOS ALTOS HILLS.

13. 3' TRELLIS

PROJECTION
2' BUILDING

PROJECTION
(SHOWN BEYOND

FOR CLARITY)
2' AWNING

PROJECTION

GLASS RAIL

AT DECK

TREES TO BE

REMOVED

TREES TO
REMAIN
2' BLD'G & 3' TRELLIS

PROJECTIONS

TREES TO BE

REMOVED

TREE TO REMAIN
2' BLD'G & 3' TRELLIS

PROJECTIONS
A
---

OVERHEAD UTILITY & POWER

LINES TO UNDERGROUNDED

WITHIN THE AERIAL ACCESS
ROADWAY, TYP. AT BOTH LOTS
PIV
FDC
FDC'S SHALL BE EQUIPPED WITH A MINIMUM OF TWO (2),
TWO-AND-ONE-HALF INCH (2 1/2") NATIONAL STANDARD
THREADED INLET COUPLINGS. ORIENTATION OF THE fdc'S

SHALL BE SUCH THAT HOSE LINES MAY BE READILY AND

CONVENIENTLY ATTACHED TO THE INLETS WITHOUT
INTERFERENCE. FDC'S SHALL BE PAINTED SAFETY YELLOW.
(SCCFD, SP-2 STANDARD)

14. (N) E.P.
(N) E.P.

FIRE DEPT. APPARATUS

ACCESS ROAD
LEVEL 5/ROOF TERRACE

PRIMARY
ROOF
A5.0

FIRE ACCESS PLAN
4' WIDE UNOBSTRUCTED

WALKWAY W/ ALL WEATHER
SURFACE, TYP. THIS SIDE AND
AROUND BACK.
4' WIDE UNOBSTRUCTED

WALKWAY W/ ALL WEATHER
SURFACE, TYP. THIS SIDE AND
AROUND BACK.
4' WIDE UNOBSTRUCTED

WALKWAY W/ ALL WEATHER
SURFACE, TYP. THIS SIDE AND
AROUND BACK. 4' WIDE UNOBSTRUCTED

WALKWAY W/ ALL WEATHER
SURFACE, TYP. THIS SIDE AND
AROUND BACK.

INTERIOR EXIT STAIRWAY WITH
44" WIDE UNOBSTRUCTED EXIT

DISCHARGE TO PUBLIC WAY
INTERIOR EXIT STAIRWAY WITH 44" WIDE

UNOBSTRUCTED EXIT DISCHARGE TO PUBLIC
WAY. OCCUPANTS EGRESS THROUGH LOBBY
PER CBC SEC 1028.2, EXCEPTION 1.

INTERIOR EXIT STAIRWAY WITH
44" WIDE UNOBSTRUCTED EXIT

DISCHARGE TO PUBLIC WAY
ELV
ELV
INTERIOR EXIT STAIRWAY WITH 44" WIDE

UNOBSTRUCTED EXIT DISCHARGE TO
PUBLIC WAY. OCCUPANTS EGRESS
THROUGH LOBBY PER CBC SEC 1028.2,
EXCEPTION 1.

SUPPLEMENTAL FIRE PROTECTION MEASURE # 3

STANDPIPE OUTLETS ADDED AT NORTH & SOUTH

EXTERIOR WALLS
SUPPLEMENTAL FIRE PROTECTION MEASURE #2

SEPERATE FIRE DEPARTMENT ACCESS THIS SIDE

OF BUILDING AT GARAGE (NO OCCUPANT

EGRESS THIS SIDE OF BLD'G)
261'-0"
(E) FIRE

HYDRANT
(E) FIRE
HYDRANT 50% OCCUPANTS EXIT DISCHARGE 50% OCCUPANTS EXIT DISCHARGE 50% OCCUPANTS EXIT DISCHARGE 50% OCCUPANTS EXIT DISCHARGE

WHEELCHAIR
RAMP

WHEELCHAIR
RAMP
SUPPLEMENTAL FIRE PROTECTION MEASURE #4
INCREASED FIRE RATING AT TYPE 1-A SOUTH
WALL, SEE ELEVATIONS A2.1
SUPPLEMENTAL FIRE PROTECTION MEASURE #5
REMOVAL OF GLASS BELOW 10' FROM

FIREFIGHTER'S INGRESS PATH AND INCREASE

FIRE RESISTANCE OF REMAINING GLASS, SEE
ELEVATIONS A2.1
57'-0"

57.68°
4'-4"
SUPPLEMENTAL FIRE PROTECTION MEASURE # 3

STANDPIPE OUTLETS ADDED AT NORTH & SOUTH

EXTERIOR WALLS
SUPPLEMENTAL FIRE PROTECTION MEASURE #2

SEPERATE FIRE DEPARTMENT ACCESS THIS SIDE

OF BUILDING AT GARAGE (NO OCCUPANT

EGRESS THIS SIDE OF BLD'G)

SIGHT VISIBILITY

TRIANGLE

SIGHT VISIBILITY TRIANGLE

SIGHT VISIBILITY TRIANGLE

SIGHT VISIBILITY

TRIANGLE
150' SIGHT VISIBILITY TRIANGLE:

PLANTS & OBSTRUCTIONS 3' MAX

TALL, BOTTOM OF TREE CANOPIES
TO BE MAINTAINED AT 14' MIN. 15'-0" 15'-0"8'-0"
SUPPLEMENTAL FIRE PROTECTION MEASURE #6

PROJECT SHALL COMPLY WITH WILDLIFE URBAN

INTERFACE BUILDING METHODOLOGIES PER
SECTION R337 OF THE 2022 CBC

AERIAL ACCESS ROADWAY TO BACK OF

BUILDING, THIS DIMENSION MAY BE
INCREASED TO 300' MAX. PER SEC 503.1.1,
EXCEPTION 1. SEE MEASURE #1 NOTE ABOVE
SUPPLEMENTAL FIRE PROTECTION MEASURE #1
2002 CFC 503.1.1 EXCEPTION 1.1

BUILDING EQUIPED THROUGHOUT W/ APPROVED
AUTOMATIC SPRINKLER SYSTEM PER CBC SEC.
903.3.1.1
NOTE: CFC 503.1.1 WAS NOT ADOPTED BY THE STATE FIRE

MARSHALL AND THE LAH FIRE CODE WAS NOT PROPERLY

ADOPTED PURSUANT TO THE REQUIREMENTS OF HEALTH
AND SAFETY CODE SECTION 13869.7 AND IS NOT
EFFECTIVE SO THIS ITEM IS SUPPLEMENTAL.

AERIAL ACCESS ROADWAY TO BACK OF

BUILDING, THIS DIMENSION MAY BE
INCREASED TO 300' MAX. PER SEC 503.1.1,
EXCEPTION 1. SEE MEASURE #1 NOTE ABOVE
SUPPLEMENTAL FIRE PROTECTION MEASURE #1
2002 CFC 503.1.1 EXCEPTION 1.1

BUILDING EQUIPED THROUGHOUT W/ APPROVED
AUTOMATIC SPRINKLER SYSTEM PER CBC SEC. 903.3.1.1
NOTE: CFC 503.1.1 WAS NOT ADOPTED BY THE STATE FIRE

MARSHALL AND THE LAH FIRE CODE WAS NOT PROPERLY

ADOPTED PURSUANT TO THE REQUIREMENTS OF HEALTH
AND SAFETY CODE SECTION 13869.7 AND IS NOT EFFECTIVE
SO THIS ITEM IS SUPPLEMENTAL.

ITEM 2A ATTACHMENT 8A

Page 573 of 1435 ends

VAN

LOADING
1 2 EV
30 29 28
EV EV

EV EV EV
EV EV
31 27
3,4,5 6,7,8 9,10,11 12,13,14 15,16,17 18,19,20 21 22
24 25 26
23 12 9 6 3 18 21 24 27 30 33 36
45 48
15 39 42 10
8 8
7 7 10 OFF 10
8 8
7 7 10 OFF
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8
SCALE:
1"=20'

FIRE EGRESS & OCCUPANCY NORTH
20' 40' 60'
LEVEL 2 BUILDING PLAN
LEGEND
UNIT 211
1,257 SF
R-2 200
6 6

LOCATION
AREA

USE OLF
# OCCUPANTS
# OCCUPANTS AND

DIRECTION OF EXIT

EXIT PASSAGE LOCATION AND

DIRECTION OF EXIT

PASSAGEWAY

LOCATION AND

DIRECTION OF EXIT

DISCHARGE

EXIT DISCHARGE
LEVEL 3 BUILDING PLAN
LEVEL 4 BUILDING PLAN
LEVEL 5/ROOF PLAN

BASEMENT BUILDING PLAN SUB BASEMENT BLD'G PLAN

PODIUM / GARAGE BUILDING PLAN

MEZZANINE BUILDING PLAN
LEVEL 1 BUILDING PLAN

EGRESS PLAN NOTES
CORRIDOR CONSTRUCTION TYPE:

PER TABLE 1020.2: 1 HOUR WITH SPRINKLER SYSTEM

1. CORRIDOR MIN. WIDTH: 44"
PER TABLE 1020.3:

AREAS WITH AN OCCUPANT LOAD LESS THAN 50: 36"

2. EXIT CAPACITY OF A 36" SINGLE DOOR = 36/0.2=180 PERSONS.

ALL SINGLE DOOR EXITS BELOW THIS CAPACITY ARE NOT
INDIVIDUALLY CALCULATED.

3. EXIT CAPACITY OF A 72" DOUBLE DOOR = 72/0.15=480 PERSONS.

ALL DOUBLE DOOR EXITS BELOW THIS CAPACITY ARE NOT
INDIVIDUALLY CALCULATED.

4. EXIT CAPACITY OF A 44" MIN. WIDE CORRIDOR =
44/0.15=293 PERSONS.

CORRIDORS BELOW THIS CAPACITY ARE NOT INDIVIDUALLY
CALCULATED.

5. EXIT CAPACITY OF A 48" MIN. WIDE STAIR =
48/0.2=240 PERSONS.

STAIRS BELOW THIS CAPACITY ARE NOT INDIVIDUALLY
CALCULATED.

6. ONE EXIT IS ALLOWABLE FOR OCCUPANT LOADS LESS THAN:

R-2 10 AT 200SF/PERSON
(2,000 SF; NO UNITS EXCEED THIS SIZE)
A:50 750 SF AT 15 SF/PERSON
B:50 OCCUPANT LOAD FACTORS VARY DEPENDING ON USE

FITNESS
551 SF
B 50
11 11
3 14
DIAGONAL DISTANCE = 58'-8"

SUB BASEMENT OCCUPANCY LOAD
11+3=14
37' TRAVEL

DISTANCE
37' TRAVEL DISTANCE

FROM MOST REMOTE

PORTION OF MOST

REMOTE UNIT TO

COMMON PATH OF
TRAVEL. 43' TO EXIT.
(.2"/OCCUPANT) x (14 OCCUPANTS) = 2.8"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (14 OCCUPANTS) = 2.1"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

FITNESS ROOM

EXIT DISCHARGE
44" CORRIDOR
1031 SF
R-2 200
5 5
3 DIAGONAL DISTANCE = 69'-4"

UTILITY

NOT OCCUPIED

BASEMENT OCCUPANCY LOAD
3+5=8
0 34' TRAVEL DISTANCE
46' TRAVEL DISTANCE FROM MOST

REMOTE PORTION OF MOST

REMOTE UNIT TO COMMON PATH
OF TRAVEL. 78' TO EXIT STAIR.
46' TRAVEL

DISTANCE
(.2"/OCCUPANT) x (8 OCCUPANTS) = 1.6"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (8 OCCUPANTS) = 1.2"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

EXIT
STAIR #2

ELEVATOR
#2

UTILITY UP
IDF
DECK
8 JANITOR

JANITOR

NOT OCCUPIED

ELEVATOR
#1
EXIT
STAIR #1

TRASH ROOM

DRIVEWAY
ELEC
MPOE

ACCESSIBLE PATH OF TRAVEL
MECH
FAN
ROOM

GARAGE OVHD GATE

CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT CAR LIFT

PLANTERS
STORAGE 1 ROLL-UP DOOR
UP

PARKING
7,158 SF
S-2 200
36 19
18 TRASH

NOT OCCUPIED

ELEC / MECH

NOT OCCUPIED

STORAGE
41 SF
S-2 200 DIAGONAL DISTANCE = 220'-8"
1 EXIT SEPARATION: 150'-4"

PODIUM / GARAGE OCCUPANCY LOAD
36+1+5+3=45
(.2"/OCCUPANT) x (45 OCCUPANTS) = 9.0"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (45 OCCUPANTS) = 6.8"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:
44" CORRIDOR
638 SF
R-2 200
3 1036 SF
R-2 200
5 3
26 35' TRAVEL DISTANCE
UP
EXIT
STAIR #2
DECK

ELEVATOR
#2
50' TRAVEL DISTANCE FROM MOST

REMOTE PORTION OF MOST

REMOTE UNIT TO COMMON PATH
OF TRAVEL. 85' TO EXIT STAIR.

DECK DECK

DECK DECK

LAUNDRY

UTILITY
1,011 SF
R-2 200
1,004 SF 5
R-2 200
5 1,006 SF
R-2 200
5 LAUNDRY
224 SF
B 100
2 5
3 DIAGONAL DISTANCE = 116'-1" 5
5 2
20 MEZZANINE OCCUPANCY LOAD
2+5+5+5+3=20

UTILITY

NOT OCCUPIED
74' TRAVEL DISTANCE
58' TRAVEL

DISTANCE
58' TRAVEL DISTANCE FROM MOST REMOTE

PORTION OF MOST REMOTE UNIT TO COMMON
PATH OF TRAVEL. 108' TO EXIT STAIR.
44" CORRIDOR
(.2"/OCCUPANT) x (20 OCCUPANTS) = 4.0"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (20 OCCUPANTS) = 3.0"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

ELEVATOR
#2
EXIT
STAIR #2
IDF

FAN CHASE

TO ROOF
44" CORRIDOR
702 SF
B
14 DIAGONAL DISTANCE = 220'-8"
341 SF
R-2.1 200
2 2
3 4
2 318 SF
R-2.1 200
1 396 SF
R-2.1 200
2 1 2
50 1 2 2 13
14 TRASH
143 SF
B 100
1 MAIL
123 SF
B 100
1 LOBY
476 SF
B 100
5 MAIL
39 SF
B 100
0 1
1 26
26 EXIT SEPARATION: 178'-2"

EXIT DISCHARGE
98' TRAVEL DISTANCE 98' TRAVEL DISTANCE
40' TRAVEL DISTANCE FROM MOST REMOTE

PORTION OF MOST REMOTE UNIT TO COMMON
PATH OF TRAVEL. 128' TO EXIT STAIR.
(.2"/OCCUPANT) x (26 OCCUPANTS) = 5.2"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (26 OCCUPANTS) = 3.9"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

IDF

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH
LOBBY

PACKAGE ROOM

MAIL ROOM
BATH

FLOOR PLAN F

FLOOR PLAN C

DECK DECK

DECK DECK DECK
UP

JULIET BALCONY
DINING
MEDIA

JULIET BALCONY

JULIET BALCONY

WORK STATION

SUPPLY ROOM

FLOOR PLAN L FLOOR PLAN N FLOOR PLAN P
POWDER
ROOM
44" CORRIDOR
DIAGONAL DISTANCE = 220'-8"
TRASH
143 SF
B 100
1 EXIT SEPARATION:156'-9"
LEVEL 2 OCCUPANCY LOAD
5+1+5+7+5+7+7+3+4+3=47/2=23
R-2 200
5 1398 SF
R-2 200
7 526 SF
B 100
5 5
7 7
5 1
5 23 3 4 3
7 23
84' TRAVEL DISTANCE 84' TRAVEL DISTANCE
(.2"/OCCUPANT) x (23 OCCUPANTS) = 4.6"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (23 OCCUPANTS) = 3.5"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

ELEVATOR
#2
EXIT
STAIR #2

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH

FLOOR PLAN G

DECK DECK DECK DECK

DECK DECK
UP
IDF
DIAGONAL DISTANCE = 220'-8"
TRASH
143 SF
B 100
1 5
7 5
1 5
23 5 5 7
(.2"/OCCUPANT) x (23 OCCUPANTS) = 4.6"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (23 OCCUPANTS) = 3.5"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH

YOGA ROOM

DECK DECK DECK DECK

DECK DECK
UP

JULIET BALCONY
DIAGONAL DISTANCE = 220'-8"
TRASH
143 SF
B 100
1 MUSIC RM
330 SF
B 50
7 5
7 5
1 7
26 5 5 5
197 SF
B 50
4 4 5
60' TRAVEL

DISTANCE
60' TRAVEL DISTANCE FROM MOST REMOTE

PORTION OF MOST REMOTE UNIT TO COMMON
PATH OF TRAVEL. 137' TO EXIT STAIR.
(.2"/OCCUPANT) x (26 OCCUPANTS) = 5.2"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (26 OCCUPANTS) = 3.9"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH

FLOOR PLAN B FLOOR PLAN A

DECK DECK DECK

DECK DECK DECK DECK

MUSIC ROOM
BATH
ROOF
48" HT. GLASS RAIL
UP 48" HT. GLASS RAIL
DECK

FAN DUCTS TO GARAGE
282 SF
B 50
6 2,100 SF
B 50
42 LEVEL 5/ROOF OCCUPANCY LOAD
2+7+1+42+43+44+11+6+3+6+7+4+40+7+46+31=300/2=150
150
(.2"/OCCUPANT) x (150 OCCUPANTS) = 30"
*USE MIN. 44" WIDE STAIR PER SEC 1011.2
(.15"/OCCUPANT) x (150 OCCUPANTS) = 22.5"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

DIAGONAL DISTANCE = 192'-0"

ELEVATOR
#1
EXIT
STAIR #1
DN
POOL

DOG RUN
POWDER
ROOM
POWDER
ROOM
MECH.ROOM

ROOF GARDEN

KITCHEN

BALCONY BELOW
REF ROOM PANTRY 86' TRAVEL DISTANCE
86' TRAVEL DISTANCE

ROOF GARDEN
222 SF
B 50
4 POOL
359 SF
R-2 50
7 KITCHEN
657 SF
R-2 100
7 DINING
665 SF
A-3 15
44 CANOPY COURT
297 SF
B 50
6 DOG RUN
347 SF
B 50
7 SITTING AREA
MECH

NOT OCCUPIED
7 42
44 3
10 31
11 4
7 MULTI PURPOSE
470 SF
A-3 15
31 DINING

MULTI PURPOSE ROOM

UNCOVERED

SITTING AREA

CONOPY COVERED

SITTING AREA

UNCOVERED

SITTING AREA
A5.1

FIRE EGRESS & OCCUPANCY
673 SF
R-2 200
3 638 SF
R-2 200
3 FLOOR PLAN FR
DECK
5 50' TRAVEL

DISTANCE
DECK
638 SF
R-2 200
3 UP
26' TRAVEL DISTANCE
44" CORRIDOR
UP
22' TRAVEL DISTANCE
UP 7' TRAVEL DISTANCE
44" CORRIDOR EXIT SEPARATION:156'-9"
23 84' TRAVEL DISTANCE 84' TRAVEL DISTANCE

ELEVATOR
#2
EXIT
STAIR #2
IDF
UP
DECK
44" CORRIDOR EXIT SEPARATION:156'-9"
26 84' TRAVEL DISTANCE 84' TRAVEL DISTANCE

ELEVATOR
#2
EXIT
STAIR #2
IDF
UP
EXIT SEPARATION:156'-9"
150

ELEVATOR
#2
EXIT
STAIR #2
UP
POWDER
ROOM

PREP ROOM
TRASH

KITCHEN STORAGE

SITTING AREA
TRASH
143 SF
B 100
1 SHUFFLE BOARD

FIRE PIT
7 130 SF
B 50
3 FIRE PIT

POOL DECK
597 SF
A-3 15
40 40
6 558 SF
B 50
11 SITTING AREA
POOL DECK 104 SF
B 50
2 SITTING AREA
2 630 SF
B
13 696 SF
R-2 200
3 695 SF
R-2 200
3 342 SF
R-2.1 200
2 50
316 SF
R-2.1 200
1 408 SF
R-2.1 200
2 359 SF
R-2.1 200
2 FLOOR PLAN J FLOOR PLAN H

FLOOR PLAN K

FLOOR PLAN M

FLOOR PLAN O

FLOOR PLAN Q

FLOOR PLAN I
737 SF
R-2 200
4 3
5 7
1,024 SF
R-2 200
5 1,387 SF
R-2 200
7 JULIET BALCONY
40' TRAVEL

DISTANCE

FLOOR PLAN HR

FLOOR PLAN BB

FLOOR PLAN H

FLOOR PLAN BP

FLOOR PLAN BR

FLOOR PLAN H

FLOOR PLAN AL

FLOOR PLAN D
LEVEL 1 OCCUPANCY LOAD
5+1+1+5+7+2+1+2+6+5+2+2+1+2+3+4+3=52/2=26

DECK DECK
1,359 SF
R-2 200
7 695 SF
R-2 200
3 737 SF
R-2 200
4 696 SF
R-2 200
3 FLOOR PLAN E

FLOOR PLAN H FLOOR PLAN I FLOOR PLAN J
1,024 SF
R-2 200
5 1,387 SF
R-2 200
7 1,006 SF
R-2 200
5 FLOOR PLAN D

GIFT SHOP
40' TRAVEL

DISTANCE
40' TRAVEL DISTANCE FROM MOST REMOTE

PORTION OF MOST REMOTE UNIT TO COMMON
PATH OF TRAVEL. 105' TO EXIT STAIR.
1,359 SF
R-2 200
7 1,079 SF
R-2 200
5 1,061 SF
R-2 200
5 FLOOR PLAN E

FLOOR PLAN A FLOOR PLAN B
526 SF
B 100
5 DECK

JULIET BALCONY
1,024 SF
R-2 200
5 1,387 SF
R-2 200
7 1,006 SF
R-2 200
5 FLOOR PLAN D FLOOR PLAN G

FLOOR PLAN F

FLOOR PLAN C
1,398 SF
R-2 200
7 7
7' TRAVEL DISTANCE
60' TRAVEL DISTANCE FROM MOST REMOTE

PORTION OF MOST REMOTE UNIT TO COMMON
PATH OF TRAVEL. 137' TO EXIT STAIR.
60' TRAVEL

DISTANCE
LEVEL 3 OCCUPANCY LOAD
5+1+5+7+5+7+7+5+5=47/2=23
1,079 SF
R-2 200
5 1,061 SF
R-2 200
5 1,359 SF
R-2 200
7 1,026 SF
R-2 200
5 7' TRAVEL DISTANCE
1,024 SF
R-2 200
5 FLOOR PLAN C
1,387 SF
R-2 200
7 FLOOR PLAN F
1,006 SF
R-2 200
5 FLOOR PLAN D
LEVEL 4 OCCUPANCY LOAD
7+4+1+5+7+5+5+7+5+5=51/2=26

FLOOR PLAN E

ART ROOM

CRAFT ROOM
644 SF
43 ART
CRAFT
696 SF
A-3 15
46 A-3 15
43 46

BMR BMR
BMR
ITEM 2A ATTACHMENT 8A

Page 574 of 1435 ends

541.9' UP
553.1' DN
UP
557.1'
VAN

LOADING
1 2 EV
30 29 28
EV EV

EV EV EV
EV EV
31 3Y 3Y 3Y 3Y
SPARE
3Y
SPARE
3Y

SPARE P C T
UP DN
564.3'
27 3,4,5 6,7,8 9,10,11 12,13,14 15,16,17 18,19,20 21 22 24 25 26
23 575.6'
12 9 6 3 18 21 24 27 30 33 36
45 48
586.8'
15 586.8'
39 42
P C T
598.0'
P C T
609.2'
P C T
620.4'
620.4'
P C T
631.6'
P C T 10
8 8 7 7 10 OFF 108 8
7 7 10 OFF
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8 NORTH

ALLOWABLE AREA CALCULATIONS & CODE ANALYSIS
30' 60' 90' 120'

BASEMENT FLOOR

AREA DIAGRAM

SUB BASEMENT FLOOR

AREA DIAGRAM

PODIUM / GARAGE FLOOR AREA DIAGRAM

MEZZANINE FLOOR AREA DIAGRAM
LEVEL 1 FLOOR AREA DIAGRAM
LOT AREA:

FLOOR AREAS
16,308 SF (.374 ACRES)
FLOOR AREA RATIO: 4.25 FAR = 69,369sf/16,308sf
ZONING FLOOR AREAS:

LEVEL AREA
BASEMENT ENCLOSED AREA 2,438 SF

MEZZANINE ENCLOSED AREA
LEVEL 1 ENCLOSED AREA
LEVEL 2 ENCLOSED AREA
LEVEL 3 ENCLOSED AREA
LEVEL 5/ ROOF ENCLOSED AREA 5,227 SF
11,060 SF
11,060 SF
5,215 SF
11,060 SF
TOTAL 69,369 SF
BUILDING CODE FLOOR AREAS:

LEVEL AREA
BASEMENT CBC AREA 2,291 SF
6,300 SF
6,300 SF
6,300 SF
6,300 SF
TOTAL TYPE 111-A 30,147 SF
TOTAL TYPE 1-A 19,614 SF

CBC FLOOR AREA INCLUDES ALL EXTERIOR
BALCONIES COVERED BY PROJECTION ABOVE.

VERTICAL SHAFTS EXCLUDED

BUILDING AREA INCLUDES THE AREA WITHIN THE SURROUNDING EXTERIOR WALLS EXCLUSIVE OF VENT SHAFTS AND COURTS. AREAS NOT PROVIDED WITH SURROUNDING WALLS ARE INCLUDED WHEN SUCH AREA IS WITHIN THE HORIZONTAL PROJECTION OF THE ROOF OR FLOOR ABOVE. OPEN TO BELOW AREAS

IN MULTI-STORY VOIDS WITHIN THE BUILDING ARE EXCLUDED FROM THE BUILDING AREA - ONLY THE FIRST FLOOR OF A MULTI-STORY SPACE IS INCLUDED. REFER TO PLANS ON THIS SHEET FOR INPUTS.

CODE ANALYSIS
CONSTRUCTION TYPE: SUB BASEMENT - PODIUM /GARAGE:

MEZZANINE & LEVEL 1-5/ROOF AREA:
1-A (SPRINKLERED - NFPA 13)
111-A (SPRINKLERED - NFPA 13)
PROPOSED OCCUPANCY: SUB BASEMENT - PODIUM /GARAGE:

MEZZANINE:

S-2, B, R-2
R-2, B
SPECIAL PROVISIONS USED: CBC 510.2 Horiz. Building Separation Allowance A building shall be considered as separate and distinct buildings for the purpose of determining area limitations, continuity of fire walls, limitation of number of stories and type of construction where all of the following conditions are met:"
BUILDING AREA: (PER CBC) TYPE 1-A
TYPE 111-A
This level contains seperated occupancies: S-2 Parking Garage, B Office, R-2 Allowable Building Height (Table 504.3): Unlimited (R-2 Most Restrictive Use) Allowable Number of Stories (Table 504.4): Unlimited (R-2 Most Restrictive Use) Allowable Building Area (Table 506.2): Unlimited (R-2 Most Restrictive Use) Max Allowable Area per Story: Unlimited (R-2 Most Restrictive Use) Proposed: 19,614 sf
LEVEL (BASEMENT, PODIUM 1, PODIUM 2) ALLOWABLE BUILDING AREA PER FLOOR (TYPE 1-A) LEVEL 1: R-2, R2.1, B
SUB BASEMENT ENCLOSED AREA 1,547 SF
LEVEL 4 ENCLOSED AREA 10,718 SF
SUB BASEMENT CBC AREA 1,443 SF
5,068 SF
Allowable Building Height (Per Table 504.3): 85' (With Out Area Increase) Allowable Number of Stories (Table 504.4): 5 (With Out Area Increase) Allowable Building Area Per Story, Per CBC 506.2.3, equation 5-2 where Sa = 1 Aa = [At + (NS x If)] x Sa
At = Tabular Allowable area factor per table 506.2 = 24,000 sf (SM) (With Height Increase) NS = Tabular allowable area factor per table 506.2 for nonsprinklered bldg = 24,000 sf If = Area factor increase due to frontage (percent) = 0 Sa = 1 per floor
Aa = [24,000 + (24,000 × 0] × 1
Aa = [24,000 + (0)] × 1
Aa = 24,000 sf per Floor

COMPARTMENT-A COMPARTMENT-B
Level 1 Proposed = 6,300 sf OK 4,470 sf OK
Level 2 Proposed = 6,300 sf OK 4,470 sf OK
Level 3 Proposed = 6,300 sf OK 4,470 sf OK
Level 4 Proposed = 6,300 sf OK 3,991 sf OK
Level 5/Roof Proposed = 4,947 sf OK 0 sf OK
(note: Roof area is located on 5th level above front podium) LEVEL 1-5 & ROOF ALLOWABLE BUILDING AREA PER FLOOR (TYPE 111-A) Allowable Building Height (Per Table 504.3): 85' (With Out Area Increase) Allowable Number of Stories (Table 504.4): 5 (With Out Area Increase) Allowable Building Area, Per CBC 506.2.3, equation 5-2 where Sa = 2 Aa = [At + (NS x If)] x Sa
At = Tabular Allowable area factor per table 506.2 = 24,000 sf (With Height Increase) NS = Tabular allowable area factor per table 506.2 for nonsprinklered bldg = 24,000sf If = Area factor increase due to frontage (percent) = 0 Sa = 2
Aa = [24,000 + (24,000 × 0] × 2
Aa = [24,000 + (0)] × 2
Aa = 48,000 sf FOR EACH COMPARTMENT
COMPARTMENT-A: Proposed Building Area Levels 1,2,3,4,5/ Roof (CBC): 30,147 sf OK COMPARTMENT-B: Proposed Building Area Levels 1,2,3,4,5/ Roof (CBC): 17,401 sf OK LEVEL 1-5 ALLOWABLE BUILDING AREA TOTAL FOR EACH COMPARTMENT (TYPE 111-A) PODIUM /GARAGE CBC AREA 10,812 SF
PODIUM /GARAGE ENC'D AREA 11,044 SF
4,947 SF
TOTAL TYPE 111-A VERTICAL SHAFTS NOT COUNTED
IN CBC FLOOR AREA, TYP.

VERTICAL SHAFTS NOT COUNTED
IN CBC FLOOR AREA, TYP.

LEVEL 2 FLOOR AREA DIAGRAM
LEVEL 3 FLOOR AREA DIAGRAM
LEVEL 4 FLOOR AREA DIAGRAM
LEVEL 5/ROOF TERRACE AREA DIAGRAM

DECK AREA COUNTED IN CBC

FLOOR AREA WHERE COVERED
BY PROJECTION ABOVE, TYP.

VERTICAL SHAFTS NOT COUNTED
IN CBC FLOOR AREA, TYP.

VERTICAL SHAFTS NOT COUNTED
IN CBC FLOOR AREA, TYP.

VERTICAL SHAFTS NOT COUNTED
IN CBC FLOOR AREA, TYP.

VERTICAL SHAFTS NOT COUNTED
IN CBC FLOOR AREA, TYP.

STAIR & ELEVATOR NOT COUNTED IN

CBC FLOOR AREA FOR ROOF LEVEL

STAIR & ELEVATOR NOT COUNTED IN

CBC FLOOR AREA FOR ROOF LEVEL

UNCOVERED DECK AREA NOT

COUNTED IN CBC FLOOR AREA
LEVEL 2-3: R-2, B
LEVEL 5/ROOF: A-3, B, R-2 (ACCESSORY USE KITCHEN)
LEVEL 4: R-2, B, A-3
R2.1 ASSISTED LIVING

COMPARTMENT A COMPARTMENT B

COMPARTMENT A COMPARTMENT B

COMPARTMENT A COMPARTMENT B

COMPARTMENT A COMPARTMENT B

COMPARTMENT-A

COMPARTMENT-A
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA
4,470 SF
4,470 SF
4,470 SF
3,991 SF
TOTAL TYPE 111-A 17,401 SF
LEVEL 5/ROOF CBC AREA (from Podium) 0 SF

COMPARTMENT-B

COMPARTMENT-B
COMP-A
TYPE 111-A
TOTAL TYPE 111-A
COMP-B
A5.2

ALLOWABLE AREA CALC'S & CODE ANALYSIS
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA

MEZZANINE CBC AREA
LEVEL 5/ROOF CBC AREA (from Podium)
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA
LEVEL 5/ROOF CBC AREA (from Podium)

BASEMENT CBC AREA

SUB BASEMENT CBC AREA

PODIUM /GARAGE CBC AREA
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA
LEVEL 5/ROOF CBC AREA (from Podium)
TOTAL TYPE 1-A

MEZZANINE CBC AREA
2,291 SF
19,614 SF
1,443 SF
5,068 SF
10,812 SF
6,300 SF
6,300 SF
6,300 SF
6,300 SF
30,147 SF
4,947 SF
4,470 SF
4,470 SF
4,470 SF
3,991 SF
17,401 SF
0 SF
ITEM 2A ATTACHMENT 8A

Page 575 of 1435 ends

PM-1

PARCEL MAP

LINEBARGER SUBDIVISION
A SUBDIVISION OF A PORTION OF LOT NO. 1 AS SHOWN UPON THE MAP OF TRACT NO. 10, MAP OF JO MORA RANCH, SANTA CLARA COUNTY, STATE OF CALIFORNIA, A SUBDIVISION OF A PORTION OF LOT 40, HALE RANCH SUBDIVISION AS RECORDED IN BOOK 1 OF MAPS, PAGES 48 AND 49, SANTA

CLARA COUNTY RECORDS, A PORTION OF SAN ANTONIO RANCHO AND

WHICH SAID MAP WAS FILED FOR RECORD IN THE OFFICE OF THE RECORDER OF THE COUNTY OF SANTA CLARA, STATE OF CALIFORNIA, ON JUNE 2, 1932 IN BOOK "Y" OF MAPS, PAGE 53. 10728 MORA DRIVE ALSO SHOWN ON CERTIFICATE OF COMPLIANCE 23761710 RECORDED IN SANTA CLARA COUNTY, STATE OF CALIFORNIA, ON SEPTEMBER 26, 2017

TOWN OF LOS ALTOS HILLS SANTA CLARA COUNTY CALIFORNIA
JOHN BERRY CIVIL ENGINEER RCE 18720
2149 AVY AVENUE, MENLO PARK, CA 94025
SHEET 1 OF 2

WE HEREBY STATE THAT WE ARE THE OWNERS OF, OR HAVE SOME RIGHT, TITLE OR

INTEREST IN AND TO THE REAL PROPERTY INCLUDED WITHIN THE SUBDIVISION

SHOWN UPON THIS MAP, AND WE ARE THE ONLY PERSONS WHOSE CONSENT IS

NECESSARY TO PASS CLEAR TITLE TO SAID REAL PROPERTY, AND WE HEREBY

CONSENT TO THE MAKING AND RECORDING OF SAID MAP AND SUBDIVISION AS SHOWN WITHIN THE DISTINCTIVE BORDER.

OWNER'S STATEMENT

OWNER DATE

OWNER'S ACKNOWLEDGEMENT

A NOTARY PUBLIC OR OTHER OFFICER COMPLETING THIS CERTIFICATE

VERIFIES ONLY THE IDENTITY OF THE INDIVIDUAL WHO SIGNED THE

DOCUMENT TO WHICH THIS CERTIFICATE IS ATTACHED, AND NOT THE TRUTHFULNESS, ACCURACY, OR VALIDITY OF THAT DOCUMENT.

STATE OF CALIFORNIA )
COUNTY OF _________________________________)
ON_____________________BEFORE ME,_________________________________, (INSERT NAME AND TITLE OF OFFICER)
PERSONALLY APPEARED,__________________________________, WHO

PROVED TO ME ON THE BASIS OF SATISFACTORY EVIDENCE TO BE THE

PERSON(S) WHOSE NAME(S) IS/ARE SUBSCRIBED TO THE WITHIN

INSTRUMENT AND ACKNOWLEDGED TO ME THAT HE/SHE/THEY

EXECUTED THE SAME IN HIS/HER/THEIR AUTHORIZED CAPACITY(IES),

AND THAT BY HIS/HER/THEIR SIGNATURE(S) ON THE INSTRUMENT THE

PERSON(S), OR THE ENTITY UPON BEHALF OF WHICH THE PERSON(S) ACTED, EXECUTED THE INSTRUMENT.

WITNESS MY HAND
SIGNATURE:__________________________________________________________ PRINTED NOTARY'S NAME:____________________________________________ COUNTY OF NOTARY'S PRINCIPLE PLACE OF BUSINESS:_________________ NOTARY'S COMMISSION NUMBER:_____________________________________ EXPIRATION DATE OF NOTARY'S COMMISSION:_________________________

A SOILS REPORT HAS BEEN PREPARED BY STEVENS FERRONE & BAILEY ENGINEERING COMPANY, INC. REGISTRATION NO'S. 3101, GE2513, 2070 ENTITLED "GEOTECHNICAL INVESTIGATION" DATED 8 JUNE 2023, A COPY OF WHICH HAS BEEN FILED WITH THE TOWN OF LOS ALTOS HILLS.

SOILS REPORT NOTE
I, DEBORAH L. PADOVAN, CLERK OF THE TOWN OF LOS ALTOS HILLS,

COUNTY OF SANTA CLARA, STATE OF CALIFORNIA, HEREBY STATE THAT

THE CITY COUNCIL OF SAID CITY, AT ITS REGULAR SCHEDULED MEETING HELD ON THE _____ DAY OF ___________________ , 20____, DULY APPROVED

THE WITHIN MAP, AND ACCEPTED , SUBJECT TO IMPROVEMENTS, ON

BEHALF OF THE PUBLIC, THE DEDICATION OF ALL EASEMENTS OFFERED

FOR DEDICATION, AS SHOWN ON SAID MAP WITHIN SAID SUBDIVISION, IN CONFORMITY WITH THE TERMS OF THE OFFER OF DEDICATION.

CITY CLERK'S STATEMENT
_________________________________________ ___________________ DEBORAH L. PADOVAN DATE

CLECK OF THE TOWN OF LOS ALTOS HILLS

RECORDER'S STATEMENT
FILED THIS ________ DAY OF _________________ , 20____, AT ______ ___ .M.

IN BOOK ____OF______, AT PAGES _____SANTA CLARA COUNTY RECORDS AT THE REQUEST OF _________________________________ .

FILE NO: ______________
FEE: ______________

REGINA ALCOMENDRAS

SANTA COUNTY COUNTY RECORDER
BY: ______________________________________
DEPUTY

THIS MAP WAS PREPERED BY ME OR UNDER MY DIRECTION AND IS BASED

UPON A FIELD SURVEY MADE IN CONFORMANCE WITH THE REQUIREMENTS OF

THE SUBDIVISION MAP ACT AND LOCAL ORDINANCE AT THE REQUEST OF FORREST LINEBARGER ON FEBRUARY 10, 2022. I HEREBY STATE THE SURVEY IS

TRUE AND COMPLETE AS SHOWN, THAT ALL MONUMENTS ARE OF THE

CHARACTER AND OCCUPY THE POSITIONS INDICATED OR THAT THEY WILL BE SET IN SUCH POSITIONS ON OR BEFORE APRIL 15, 2023, AND ARE SUFFICIENT TO ENABLE THE SURVEY TO BE RETRACED; AND THAT THIS PARCEL MAP

SUBSTANTIALLY CONFORMS TO THE APPROVED OR CONDITIONALLY

APPROVED TENTATIVE MAP, IF ANY

SURVEYOR'S STATEMENT
DATE:___________ __________________________________
JOHN C. BERRY RCE 18720

I HEREBY STATE THAT I HAVE EXAMINED THIS MAP AND THAT THE

SUBDIVISION SHOWN HEREON IS SUBSTANTIALLY THE SAME AS IT APPEARED

ON THE TENTATIVE MAP, IF REQUIRED, AND ANY APPROVED ALTERATIONS THEREOF; THAT ALL PROVISIONS OF THE CALIFORNIA SUBDIVISION MAP ACT

AND ANY LOCAL ORDINANCES APPLICABLE AT THE TIME OF APPROVAL OF THE TENTATIVE MAP, IF REQUIRED, HAVE BEEN COMPLIED WITH.

CITY ENGINEER'S STATEMENT
___________________________________ WEI LIEN LIANG, RCE 68845

TOWN OF LOS ALTOS HILLS
_______________ DATE

I HEREBY STATE THAT I HAVE EXAMINED THIS MAP, AND I AM SATISFIED THAT SAID MAP IS TECHNICALLY CORRECT IN ACCORDANCE WITH SECTION 66442 OF THE GOVERNMENT CODE (SUBDIVISION MAP ACT).

CITY SURVEYOR'S STATEMENT
___________________________________ ANNE-SOPHIE TRUONG, PLS 8998_______________ DATE MAY 2023
1 (650) 400-9003
OWNER: FORREST LINEBARGER

EDGE OF SHEET
ITEM 2A ATTACHMENT 8A

Page 576 of 1435 ends

℄
℄ MORA DRIVE
S 88° 36' 00" W 255.12'
S 06° 24' 40" W 59.00'
S 89° 19' 00" E 260.52' N 00° 41' 00" E 68.00'
LOT 1
16,308 SF +/-
THE BEARING N 0° 41' 00" E BETWEEN

FOUND MONUMENTS IN THE EAST LINE OF
MORA DRIVE, 50 FEET WIDE, AS SHOWN ON

THAT RECORD OF SURVEY RECORDED IN
BOOK 827 OF MAPS AT PAGE 10, SANTA

CLARA COUNTY OFFICIAL RECORDS, WAS

TAKEN AS THE BASIS OF BEARINGS FOR
THIS SURVEY.

BASIS OF BEARINGS
LEGEND

CENTERLINE

EASEMENT LINE

PRIVATE ACCESS

EASEMENT

LOT LINE

ADJOINING PROPERTY LINE
10'0' 20' 40' SCALE:
1"=20'

LANDS OF KLEIN
APN: 331-15-021
FOUND 3/4" IRON

PIPE, OPEN,
201 MAPS 53
FOUND 3/4" IRON PIPE WITH
TAG (SFNF), PER 201 MAPS 53

POINT OF BEGINNING
S.W. CORNER LOT 1,
'Y' MAPS 53 BASIS OF BEARINGS
FOUND 3/4" IRON PIPE,
OPEN (827 MAPS 10)

LANDS OF KLEIN
APN: 331-14-063

LANDS OF MINTON
APN: 331-14-060
NE CORNER OF LOT 1
"Y" MAPS 53
EAST LINE OF LOT 1
"Y" MAPS 53
N.W. CORNER
OF LOT 1
"Y" MAPS 53
FOUND 3/4" IRON PIPE
OPEN, PER 827 MAPS 10
AND 736 MAPS 25 AND
201 MAPS 53 77.00' 50' R.O.W.
25' ROW 25' ROW
PAE

PRIVATE UTILITY

EASEMENT
PRUE

PRIVATE SANITARY

SEWER EASEMENT
PSSE

PRIVATE INGRESS AND

EGRESS EASEMENT
PIEE

EMERGENCY VEHICLE

ACCESS EASEMENT
EVAE
.374 AC +/-
DISTINCTIVE BORDER EϬϬΣϰϭΖϬϬΗ

LOT 2,
'Y' MAPS 53
PORTION OF LOT 1,
'Y' MAPS 53
SHEET 2 OF 2
PM-2

EDGE OF SHEET

SEARCHED FOR NOT
FOUND
SFNF

EXISTING IRON PIPE

MONUMENT

NEW IRON PIPE

MONUMENT TO BE SET

PARCEL MAP

LINEBARGER SUBDIVISION
A SUBDIVISION OF A PORTION OF LOT NO. 1 AS SHOWN UPON THE MAP OF TRACT NO. 10, MAP OF JO MORA RANCH, SANTA CLARA COUNTY, STATE OF CALIFORNIA, A SUBDIVISION OF A PORTION OF LOT 40, HALE RANCH SUBDIVISION AS RECORDED IN BOOK 1 OF MAPS, PAGES 48 AND 49, SANTA

CLARA COUNTY RECORDS, A PORTION OF SAN ANTONIO RANCHO AND

WHICH SAID MAP WAS FILED FOR RECORD IN THE OFFICE OF THE RECORDER OF THE COUNTY OF SANTA CLARA, STATE OF CALIFORNIA, ON JUNE 2, 1932 IN BOOK "Y" OF MAPS, PAGE 53. 10728 MORA DRIVE ALSO SHOWN ON CERTIFICATE OF COMPLIANCE 23761710 RECORDED IN SANTA CLARA COUNTY, STATE OF CALIFORNIA, ON SEPTEMBER 26, 2017

TOWN OF LOS ALTOS HILLS SANTA CLARA COUNTY CALIFORNIA
JOHN BERRY CIVIL ENGINEER RCE 18720
2149 AVY AVENUE, MENLO PARK, CA 94025
MAY 2023
1 (650) 400-9003
TOTAL LENGTH 260.52'
TOTAL LENGTH 255.12'
201 MAPS 53
MULTIPLE FINAL MAPS: PURSUANT TO SECTION 66456.1 OF

THE SUBDIVISION MAP ACT, THE DEVELOPER RESERVES
THE RIGHT TO FILE MULTIPLE FINAL MAPS. ONLY THE

IMPROVEMENTS REQUIRED TO SUPPORT THE LEVEL OF

DEVELOPMENT, OF EACH PARTICULAR FINAL MAP NEEDS
TO BE COMPLETED OR BOUNDED.

1. NOTES

FOR CONDOMINIUM PURPOSES
CONSISTING OF 43 RESIDENTIAL UNITS

AND ONE COMMON LOT
ITEM 2A ATTACHMENT 8A

Page 577 of 1435 ends

135.00'
N 00°41'00" E
w
N 00° 41' 00" E

68.00'
N 00° 41' 00" E 62.50' N 89° 19' 00" W 274.06'

25.00' 176.83' 5'
R=20'
100.00'
5'
137.81' N 00° 41' 00" E
N 00° 41' 00" E 45.00'

E E E E E E E E E E
30" PINE
20" MONKEY PUZZLE
19" PINE
22" PINE
10" d MAGNOLIA
8" d GRAPEFRUIT WM

SWITCHGEAR SWITCHGEAR WM

MPOE MPOE
10758 Mora 10728 Mora Moraquita Court
Mora Dr.

JOINT TRENCH INTENT

FIELD ADJUST SPLICE BOXES TO KEEP CLEAR OF

SIDEWALK, DRIVEWAYS, AND EXISTING FACILITIES
(TYPICAL)

JOINT TRENCH NOTES

1. SITE PLAN
10'0' 20' 40' SCALE:
1"=20'
NORTH

ELEC POLE & LINE DIAGRAM
50'0' 100' 200' SCALE:
1"=100'
NORTH
(E) E.P.
(N) E.P.
(E) POLE-BOLTED TRANSFORMER TO
BE CONVERTED TO U.G. (E) POLE TO

BE 'TOPPED' AND TO SERVE AS

SECONDARY RISER POLE TO
MAINTAIN (E) O.H. SERVICES.
324'-0"
LEGEND

ELECTRIC POLE

LOCATION
3 PHASE OVERHEAD

ELECTRIC WIRES

GUY WIRE SUPPORT
10758 Mora
10728 Mora
(E) ELEC POLE &

GUY WIRES
172'-0"
(N) E.P.

INT-1

JOINT TRENCH INTENT
9 C4
(E) 3 PHASE

OVERHEAD
(E) ELEC POLE
(E) 3 PHASE

OVERHEAD
(E) ELEC POLE
3 PHASE UNDERGROUND

ELECTRIC WIRES
(E) DRIVEWAY
(E) 1 PHASE OVERHEAD

ELECTRIC WIRES
(E) 1 PHASE

OVERHEAD ELEC
(E) ELEC POLE &

GUY WIRES
(E) 1 PHASE

OVERHEAD ELEC
(N) ELEC POLE
& GUY WIRE
(E) 1 PHASE

OVERHEAD ELEC
(N) 3 PHASE

UNDERGROUND
(N) 3 PHASE

OVERHEAD
(E) ELEC POLE
(N) 3 PHASE

OVERHEAD
(N) ELEC POLE
& GUY WIRE
(E) ELEC POLE

TO REMAIN
(N) 3 PHASE

UNDERGROUND
(E) O.H. SERVICE

TO REMAIN
(E) POLE TO
REMAIN
(E) O.H. SERVICE

TO REMAIN

PG&E TO SET (N)

PRIMARY RISER
POLE W/ +/- 12'

LEAD-ANCHOR
(N) 3 PHASE

UNDERGROUND
(E) POLE

TO REMAIN
(E) O.H. DISTRIBUTION

TO REMAIN
34'-0" 136'-0"
Mora Dr.
60'-0"
NEW UNDERGROUND SERVICE: 308'-0"
(E) E.P.
90" x 106" TEMP POWER PAD
MOUNT TRANSFORMER, 3'
CLEAR SPACE SIDES & BACK, 8'

CLEAR FRONT, BOLLARDS
REQ'D. (UP TO 1000A @ 480V)
10' L +/- 7M ROTARY GAS
METER, 3' CLEAR SPACE

REQ'D ON FRONT SIDE
5'X6' BELL HOLE FOR EXISTING GAS
SVC. CUT-OFF. WHEN EXCAVATING

OR TRENCHING KEEP CLEAR OF
EXISTING FACILITIES. (TYPICAL)
CAUTION!! ENERGIZED FACILITIES!!

HAND EXCAVATE ONLY IN
PRESENCE OF INSPECTOR.
(TYPICAL OF 2 PLACES)
DETAIL
N.T.S.
3 INT-1

PG&E ENCLOSURE CLEARANCES
DIM "X"
3' MIN. TYP.
3' MIN. 3'0" x 5'0" ENCLOSURES
4' MIN. 4' x 6'6" x 5'0" ENCLOSURES
5' MIN. 4'6" x 8'6" x 6'0" ENCLOSURES
(OR EASEMENT REQUIRED)
3' MIN. TYP.

DIM "X"

CLEAR WORKING
SPACE
DIM "X"

CLEAR WORKING
SPACE
DETAIL
N.T.S.
1 INT-1

TYPICAL PRIMARY BOX EXCAVATION USING CONDUIT
NOTE:

1. CONTRACTOR TO EXCAVATE TRANSITIONS

FROM MAIN-LINE TRENCH TO VAULTS AS
REQUIRED BY EACH UTILITY.

2. TRANSITIONS NOT SHOWN ON COMPOSITE

DRAWING FOR CLARITY

3. CONTRACTOR TO INCLUDE COST OF
TRANSITIONS IN VAULT EXCAVATION COST.

JOINT TRENCH TRANSITION

JOINT TRENCH
X Y X
Z
'X'
'Y'
'X'
'Y'

BEND PRIMARY BOX SIZE
"A"
"B"
3' x 5'
4'-6" x 8'-6"
3' x 5'
4'-6" x 8'-6"

DISTANCE (WHEN CONDUIT ENTERS BOX)
"X"
24'
24'
32'
32'
"Y"
7'
11'
7'
11'
"Z"
5'
7'
5'
7'
NOTES
BEND IS 60" RADIUS WITH AN ANGLE OF 10 DEG. USE 2-5
COUPLINGS WITH 1-5' CONDUIT SECTION FOR EACH BEND SHOWN.

BEND IS 30" RADIUS WITH AN ANGLE OF 15 DEG. USE 3-5 COUPLINGS WITH 2-2 1/2' CONDUIT SECTION FOR EACH BEND SHOWN.

MAIN LINE JOINT TRENCH
PG&E TELEPHONE C.A.T.V.
5'X6' BELL HOLE FOR EXISTING GAS
SVC. CUT-OFF. WHEN EXCAVATING

OR TRENCHING KEEP CLEAR OF
EXISTING FACILITIES. (TYPICAL)
CAUTION!! ENERGIZED FACILITIES!!

HAND EXCAVATE ONLY IN
PRESENCE OF INSPECTOR.
(TYPICAL OF 2 PLACES)
(E)

DRIVEWAY
4' X 6' PRIMARY J-BOX

VAULT IN LANDSCAPE
AREA. (NOT FVT)

ASPHALT

PAVEMENT

ASPHALT

PAVEMENT
(N) 3 PHASE

UNDERGROUND
(N) TELE COM & CATV

UNDERGROUND

UCD TRANSFORMER VAULT
5' X 10' +/-, FVT
(PG&E APPROVAL REQ'D)
1200A, 480/277V
SWITCHGEAR 5' MIN
LEGEND

UCD TRANSFORMER VAULT
5' X 10' +/-, FVT
(PG&E APPROVAL REQ'D)
1200A, 480/277V

SWITCHGEAR

TEL & CATV VAULTS
(SIZES TBD)
JOINT TRENCH 5' MIN.

CLEARANCE FROM WATER
& SEWER UTILITIES
60' +/- OF 18" X 26" GAS
SERVICE TRENCH W/ 2" GAS

SERVICE PIPE (NO TREES
W/IN 5')
60' +/- OF 18" X 26" GAS
SERVICE TRENCH W/ 2" GAS

SERVICE PIPE (NO TREES
W/IN 5')
90" x 106" TEMP POWER PAD
MOUNT TRANSFORMER, 3'
CLEAR SPACE SIDES & BACK, 8'

CLEAR FRONT, BOLLARDS
REQ'D. (UP TO 1000A @ 480V)
10' L +/- 7M ROTARY GAS
METER, 3' CLEAR SPACE

REQ'D ON FRONT SIDE
4' X 6' PRIMARY J-BOX

VAULT IN LANDSCAPE
AREA. (NOT FVT)

TEL & CATV VAULTS
(SIZES TBD)

PG&E TO SET (N) PRIMARY
RISER POLE W/ +/- 12'

LEAD-ANCHOR
E
MPOE
8' WALL SPACE
MPOE
8' WALL SPACE

TEL & CATV
VAULTS
(SIZES TBD)

TEL & CATV
VAULTS
(SIZES TBD)
30" X 48" SVC TRENCH W/ MAX 5-5"

SVC CONDUITS, SVC CONDUCTORS
NOT TO EXCEED 50' (W/ +/- 7' OF
'CONDUCTOR TAILS' REQ'D AT EA. END)
(5' CLEARANCE FROM WATER &
SEWER REQ'D) 30" X 48" SVC TRENCH W/ MAX 5-5"

SVC CONDUITS, SVC CONDUCTORS
NOT TO EXCEED 50' (W/ +/- 7' OF
'CONDUCTOR TAILS' REQ'D AT EA. END)
(5' CLEARANCE FROM WATER & SEWER
REQ'D)
4' X 6' SUB-SURFACE

J-BOX, BEHIND CURB
50" X 52" PAD MOUNT

TRANSFORMER W/IN

LANDSCAPE AREA

TEL & CATV

VAULTS (SIZES TBD)

TRANSITION TO VAULTS FROM TRENCH NOT
SHOWN, SEE TRANSITION DETAIL SHEET INT-1
(TYPICAL)

2. MAINTAIN 3' CLEARANCE AND LEVEL AREA

AROUND PRIMARY SPLICE BOXES &

TRANSFORMERS

3. (E) POLE TO
REMAIN
(E) E.P.
(E) E.P.
(N) E.P.
(E) OVERHEAD DISTRIBUTION TO REMAIN,
PG&E TO EXTEND 3RD PRIMARY OH WIRE,

AND UPGRADE WIRE SIZE, TO PROVIDE
3-PHASE TO PROJECT
(E) O.H. SERVICES

TO REMAIN
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10728 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: FEB 20, 2025
NO. DATE REVISION
2/1/2023
4/10/2023
1 2 Revision 1
3 5/17/2023 Revision 2
4 8/24/2023 Revision 3
5 11/21/2023 Revision 4
6 5/5/2024 Revision 5
7 10/1/2024 Revision 6
8 1/28/2025 Revision 7
9 2/20/2025 Revision 8
UT-1
C4
9 C4
UT-1
C4
UT-2
C4
9 C4
ITEM 2A ATTACHMENT 8A

Page 578 of 1435 ends

☐ Application / Response(s) to Comments
☐ Accessibility Exemption Form (Commercial)
☐ Arborist Report
☐ Bay Area Air Quality Management J#
☐ CalGreen Checklist
☐ COP (Construction Operation Plan)
☐ Electrical Load Calculations
☐ Energy Code documents (ex: CF1R)
☐ Manufacturer’s Specifications
☐ PCB’s Demo Program Screening
Assessment
☐ Photos of road & path prior to construction
☐ SCC Environmental Health Department
permit and/or approved stamped site plan
☐ Soils/Geotechnical Report
☐ Special Inspection Form
☐ Structural Calculations
☐ Truss Calculations
☐ Truss Diagrams
☐ Utility Shut-Off Letter
☐ Waste Management Plan

TOWN OF LOS ALTOS HILLS
26370 Fremont Road
Los Altos Hills, CA 94022
Phone: (650) 941-7222
Email: [email protected]
www.losaltoshills.ca.gov
Supplemental Documents Index
Project Information
For initial submittals, include this index after the application. For all resubmittals, include this index at the beginning of the SUP document PDF.

Permit No: __________________________________ File Name: _________________________________ APN: _______________________________________ Date Submitted:_____________________________ Project Address: __________________________________________________________________________ Legal Owner:______________________________________________________________________________ Applicant:_________________________________________________________________________________ Scope of Work: ______________________________________________________________________ Notes: Each time the SUP file is uploaded, the PDF must be complete and include all documents required for permit issuance. Keep all documents in the SUP file in the same order each time.

Supplemental Documents Checkmark all items included in SUP file Additional Documents Please list additional items below

1. _____________________________________

2. _____________________________________

3. _____________________________________

4. _____________________________________

5. ___________________________________

6. ___________________________________

7. ___________________________________

8. ___________________________________
____________________________________________________________________________________________ ____________________________________________________________________________________________ CDP23-0002 CDP23-0002_V6_SUP
331-15-062 1/30/2025
10758 MORA DRIVE, LOS ALTOS HILLS

FORREST LINEBARGER

FORREST LINEBARGER
PROPOSED BUILDERS REMEDY 45 UNIT MULTIFAMILY RESIDENTIAL DEVELOPMENT PROJECT ✔
ITEM 2A ATTACHMENT 9

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ITEM 2A ATTACHMENT 9

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ITEM 2A ATTACHMENT 9

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Wildland Res Mgt (510) 502-4737
316 California Ave. #68
Reno NV 89509 [email protected]
January 29, 3025
City Council
Town of Los Altos Hills
I am writing to indicate the reasons why the Proposed projects at 10728 Mora Drive and 10758 Mora Drive should be approved, which is that it complies with the 2022 Fire Code. I I head the operations of Wildland Res Mgt, which, first, does business in California, as well as other states. I have more than 45 years of experience, building on an education in Forestry and Wildland Fire Science from the University of California, Berkeley. I have delivered authored more than a hundred presentations and articles, and a textbook used by Cal Poly, Fire in the Urban-Wildland Interface: Practical Solutions for Local Government, Planners, Fire Authorities, Developers, and Homeowners. Presentations and publications address plan use planning, interagency collaboration, fire behavior modeling, ecological sensitivities in fuel reduction treatments, and best practices in fire hazard reduction planning and implementation.

I have led and served on boards of the International Association of Wildland Fire (co-founder), California-Nevada-Fire Council, National Fire Protection Association Wildland Fire Section (co-founder), and Northern California Fire Prevention Officers (WUI Committee Co-chair). (Gov. Code § 65589.5(o).) states that the building permit for these projects will be reviewed against the fire/building codes in effect at the time that the preliminary application for the projects were submitted. The preliminary applications were submitted February 1, 2023, when the California 2022 Fire Code was in effect.

The site is not designated as a Very High Fire Hazard Severity Zone within the City of Los Alto Hills. Therefore Chapter 49 of the Fire Code (which covers risk assessment, access and egress, vegetation management, water supply and other infrastructure) does not apply.

Similarly, Chapter 7A of the California Building Code which directs the design and construction of buildings to resist wildfire is not applicable to the site because it is not in a VHFHSZ.

The Proposed projects at 10728 Mora Drive and 10758 Mora Drive meet all requirements of the adopted 2022 California Fire Code.

The staff report dated January 30, 2025 documents a series of applicant submittals and review comments by the Santa Clara Fire Department. The main objection by the fire department rests on Section 503.1.11
, which states:
503.1Where required.

Fire apparatus access roads shall be provided and maintained in accordance with Sections 503.1.1 through 503.1.3.
1 https://codes.iccsafe.org/s/CAFC2022P1/chapter-5-fire-service-features/CAFC2022P1- Commented [BO1]: Please say something about your
experience with fire safety etc, also please include a cv.

ITEM 2A ATTACHMENT 9

Page 582 of 1435 ends

503.1.1Buildings and facilities.

Approved fire apparatus access roads shall be provided for every facility, building or portion of a building hereafter constructed or moved into or within the jurisdiction. The fire apparatus access road shall comply with the requirements of this section and shall extend to within 150 feet (45 720 mm) of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Exceptions:

1.The fire code official is authorized to increase the dimension of 150 feet (45 720 mm) where any of the following conditions occur:

1.1. The building is equipped throughout with an approved automatic sprinkler system installed in accordance with Section 903.3.1.1, 903.3.1.2 or 903.3.1.3.

1.2. Fire apparatus access roads cannot be installed because of location on property, topography, waterways, nonnegotiable grades or other similar conditions, and an approved alternative means of fire protection is provided.

1.3. There are not more than two Group R-3 or Group U occupancies.

Section 503 of the Model Code was NOT adopted by the State Fire Marshal as part of the 2022 California Fire Code. See the adopted code matrix for 2022 on the figure below. Note the California State Fire Marshal, labeled “SFM” in the matrix, contains the symbol “┼” which identifies the section 503 as not adopted.

Instead, State requirements for Fire Department access are found in Title 19 of the California Code of Regulations, which states:
§ 3.05. Fire Department Access and Egress.
(a) Roads. Required access roads from every building to a public street shall be all-weather hardsurfaced (suitable for use by fire apparatus) right-of-way not less than 20 feet in width. Such right-of-way shall be unobstructed and maintained only as access to the public street.

Los Altos Hills adopted amendments to the 2022 California Fire Code, which differs from Section 503.1.1 of the Model Code. The local amendment states:
503.1.1 Buildings and facilities. Approved fire apparatus access roads shall be provided for every facility, building or portion of a building hereafter constructed or moved into or within the jurisdiction. The fire apparatus access road shall comply with the requirements for this section and shall extend to within 150 feet (45,720 mm) of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Exceptions:

1. In other than R-3 or U occupancies, when the building is equipped throughout with an approved automatic sprinkler system, installed in accordance with Section 903.3.1.1 the dimension may be increased to a maximum of 300 feet when approved by the fire code official.

2. When there are not more than two Group R-3 or accessory Group U occupancies, the dimension may be increased to a maximum of 200 feet.

3. When apparatus roads cannot be installed because of topography, waterways, nonnegotiable grades or other similar conditions, an approved alternative means of fire protection shall be provided.

ITEM 2A ATTACHMENT 9

Page 583 of 1435 ends

The Project Meets State Fire Department Access Requirements The projects meet the California Fire Department Access and Egress of Title 19, as the buildings are proposed to be accessible to a public street (Mora Drive) by an unobstructed all-weather hard-surfaced right-of-way not less than 20 feet in width. It must be noted that the projects will improve upon the safety of the area by providing a fire turn-around for aerial trucks at the top of Mora Drive, which currently is not served by aerial fire trucks. This is to be improved through increased maintenance of the trees over Mora Drive along the City right-of-way. This is an improvement to a road that was deemed suitable for fire response by the Santa Clara Fire Department in 20122 and verified by Stevens, Ferrone, and Bailey, a
Geotechnical Engineering firm3
. This improvement supports multiple evacuation routes, and constitutes a benefit to the neighborhood.

The Projects Meet the Requirements to Increase The Distance from the Fire Road Access While the applicable code for this project review is the California Fire Code, the project also meets the requirement of the Los Altos Hills fire code. The applicant states that the projects would include a sprinkler system that is consistent with Section 903.3.1.1, 903.3.1.2 or 903.3.1.3 (i.e., per NFPA 13D).

The current plans (Sheet A5.0) indicate that the distance from fire access road to the rear of the structure less than 300 feet, which is within the specified distance from an access road. The project thereby satisfies the requirements to qualify for Exception 503.1.1.1 under the Town’s code. Although the applicant proposed the sprinklers and distance in an October 8, 2024 Alternative Means Methods Request (AMMR), an AMMR was not necessary because the projects meets the requirements to increase the distance to an access road to 300 feet.

Because the conditions for an exception are provided in Section 503.1.1.1, there is no need for an AMMR. The project should be deemed compliant with the Town’s Fire Code.

Further, Section 503.1.1.2 indicates that when apparatus roads cannot be installed because of topography or other conditions, and “approved alternative means of fire protection” must be provided. However, the alternative means of fire protection is necessary only if the project cannot comply with Exception 503.1.1.1. As explained above, the project meets Exception 503.1.1.1, and no alternative means is required.

Although no alternative means application is necessary, the applicant has gone beyond code requirement to increase fire safety. The alternative means process is intended to provide equivalent fire protection to the intent of provision of the code that the applicant seeks to amend. The ICC commentary on Section 503.1.1.1 states that the intent of the provision is to limit the maximum length of hose needed to reach the exterior of a building and specifically lists standpipes as an appropriate alternative means to meet the intent of Section 503.1.1.1. Again, although the project already meets Exception 503.1.1.1 and no alternative means is necessary, the applicant proposed a standpipe towards the back of the building to limit the maximum hose length needed to reach the exterior of the building. The project as proposed with a standpipe and sprinklers increases fire safety beyond what it is required by code.

One comment from the Fire Department concerning the lack of two exits should be clarified. Occupants of the proposed property locations have two choices of exits. The obvious exit is along Mora Drive, and the other fire access is to take Sunhills Drive to West Loyola Drive to Magdalena Avenue that is located 2 Letter dated September 20, 2012, from Doug Harding, DFM II to Cynthia Richardson, regarding the consideration of Mora Drive for annexation.
3 Letter dated June 9, 2023, from Kenneth Farrone to Forrest Linebarger regarding fire truck access weight bearing.

ITEM 2A ATTACHMENT 9

Page 584 of 1435 ends

just a few parcels away from the proposed project. See Figure X. When the project is in place, only 14 parcels must traverse the end of Mora Drive before reaching the intersection of SunHills Dr. and Mora Dr. Even the updated California Fire Code Appendix D.107.1 notes that “Where there are more than 30 dwelling units accessed from a single public or private fire apparatus access road and all dwelling units are equipped through with an approved automatic sprinkler system in accordance with Section 903.3.1.1, 903.3.1.2 or 903.3.1.3, access from two directions shall not be required.4”

The applicant has demonstrated a commitment to exceed the codes and standards and to enhance the fire safety of the area. The plans meet those codes and standards and should be considered compliant.

Sincerely,
Carol Rice
Figures:
4 https://codes.iccsafe.org/content/CAFC2022P1/appendix-d-fire-apparatus-access-roads Commented [FL2]: It seems like we don’t meet this
requirement
ITEM 2A ATTACHMENT 9

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Two different access/egress routes
Approximate
project site
ITEM 2A ATTACHMENT 9

Page 586 of 1435 ends

Properties that have one exit prior to the intersection of SunHill and Mora Dr.

ITEM 2A ATTACHMENT 9

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Adoption Matrix for the 2002 Model Fire Code, identifying section 503 as not adopted by State Fire Marshal

ITEM 2A ATTACHMENT 9

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CAROL L. RICE
Carol Rice provides expertise in fire management, with specialized knowledge in fire behavior (i.e. spread and potential loss) along with fire codes and policies, hazard and risk assessment, structural ignition potential, fire ecology, defensible space creation and maintenance, fuel and vegetation management.

PROFESSIONAL EXPERIENCE
General Manager, Wildland Res Mgt, Reno Nevada and Alamo, CA. Since 2013.

President, Wildland Resource Management, Inc., Walnut Creek and Alamo, CA. Head of consulting firm focusing on fire management. Responsible for marketing, and program planning as well as contract performance. 1979-2013.

Associate Director, Fire Research Institute, Roslyn, WA and Walnut Creek, CA. Established and comanaged a non-profit international organization of fire researchers and managers, from 1983-1992.

Resource Analyst, Arabian American Oil Co., Community Services Programs and Planning, Dhahran, Saudi Arabia. Authored project proposals, performed analysis of department issues. Was responsible for cost estimates and proponent representation for expenses totaling $11 million. 1976-79.

Fire Ecologist, USDA Forest Service, Big Bar, CA. Designed and conducted study of fire ecology in the Trinity Alps, Shasta Trinity National Forest. 1975.

EDUCATION
Bachelor of Science, 1975 (forestry), University of California at Berkeley.

Masters of Science, University of California, Berkeley, Wildland Resource Sciences Program. The master's thesis evaluates potential fire behavior in the urban interface of the Berkeley/Oakland hills. 1987.

SELECTED PROFESSIONAL RECOGNITION
™ Co-Chair, Wildland Urban Interface Committee, Northern California Fire Prevention OƯicers. 2011- 2015
™ California Wildfire Coordinating Group Prevention Committee. 2012-2017. ™ Certified Senior Wildland Fire Manager, from the Association for Fire Ecology. 2012 ™ Education Award, American Planning Association, Northern California Section 2011 for the Book Managing Fire in the Urban Wildland Interface.
™ Outstanding Environmental Resource Document for the book Managing Fire In the Urban Wildland Interface, Association of Environmental Professionals. 2011.

BOARD OF DIRECTOR EXPERIENCE
™ International Association of Wildland Fire: Vice-President, Secretary of Board of Directors. 1998- 2008. Program Co-Chair Second International Congress on Fire Ecology and Management, 2003, Steering Committee Coordinator, California's 2001 Wildfire Conference. ™ National Fire Protection Association: Member of Task Force to establish Wildland Fire Section, 1987-

88. Second Vice-chair of Wildland Fire Section, 1990-1994. Managing Editor, Section newsletter, 1988-90.
™ California-Nevada-Hawaii Forest Fire Council: Chair 1985-86, Vice-Chair 1984-85, Program Chair 1983, 2001 and 2014. Secretary 2015-2018.

ITEM 2A ATTACHMENT 9

Page 589 of 1435 ends

More than 50 publications, presentations regarding wildland urban interface, fire behavior and fuel modification.

SELECTED PUBLICATIONS, PRESENTATIONS AND REPORTS
Curtis Alline, Heather Blair, Carol Rice, Molly Mowery. 2020 Fire Resiliency and CEQA. Webinar hosted by the California Chapter of the Association of Environmental Professionals.

Carol L. Rice. 2014. Planning to Live with Fire: Tools and best Practices. Invited presentation to the Board of Forestry, December 4, 2014.

Rice, Carol and Laing, George. 2014. Insurance Industry De-Mystified, Closing Remarks. Northern California Fire Prevention OƯicers Training, October 28, 2014, Roseville, CA, Carol L. Rice, Sarah McCaƯrey and Molly Mowery. 2013. Community Wildfire Protection Planning. An invited webinar as part of the Planning for Growth and Open Space Conservation webinar series.

November 6, 2013.

Carol L. Rice 2012. Planning to Live with Fire: Designing and Retrofitting Communities with Fire in Mind.

Webinar presented January 26, 2012. http://uc-d.adobeconnect.com/p13qiwdmlmk/ California Fire Science Consortium.

George Laing and Carol Rice. 2011. Risk Assessment: Fire Protection Planning and Mitigation Options from 30,000 feet. Invited Presentation at the California Fire Prevention Institute, Buellton, CA. March 11- 14, 2011.California Fire Prevention OƯicers.

Kenneth S. Blonski, Cheryl Miller and Carol L. Rice. 2010. Fire in the Urban-Wildland Interface:

Practical Solutions for Local Government, Planners, Fire Authorities, Developers, and Homeowners.

Solano Press, Pt. Arena, CA. 396 pgs.

Cheryl Miller, Ken Blonski and Carol L. Rice. 2010. You too can prevent wildfires. Environmental Monitor.

Fall, 2010.

Rice, Carol L., Ronny J. Coleman and Mike Price. 2010. Incorporating Fire Behavior into Evacuation Plans. Presented at the International Association of Wildland Fire Conference on Fire Behavior and Fuels. October 24-28, 2010. Spokane, WA.

Rice, Carol L., Ronny J. Coleman and Mike Price. 2010.Clarifying Evacuation Options Through Fire Behavior and TraƯic Modeling. Presented at the International Association of Wildland Fire Conference on Human Dimensions. April 26-29, 2010, San Antonio, TX. In press.

George Laing, Mike Mentink, Carol Rice and Brian Collins , 2008. Parcel-Based Risk Rating to Motivate Fuel Management. Presented at The ’88 Fires: Yellowstone and Beyond, September 22-27, 2008.

Jackson Hole, WY, International Association of Wildland Fire.

Kenneth S. Blonski, Cheryl Miller and Carol L. Rice. 2005. Get Real! Community Based Solutions for your WUI Issues – Using Collaboration Beyond Planning. Presentation at Wildland Fire 2005, February 16-18, 2005, Albuquerque, NM.

Rice, Carol L. 2006. Fire Hazard Reduction Plan, Orlando Lawrence Berkeley National Laboratory.

Unpublished report prepared for Eldon Beck Associates, Pt. Richmond, CA.

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Gettle, Guy L. and Carol L. Rice 2002. Criteria for determining the safe separation between structures and wildlands. IV International Conference on Forest Fire Research and 2002 Wildland Fire Safety Summit, Nov 18-2, Luso, Portugal. Published by Associacao para o Desenvolvimento da Aerodinamica Industrial, Coimbra, Portugal.

McClure, Rich, Carol Rice, and Kate Bolton. 2001. Developing a fire-safe sustainable landscape at the Lawrence Berkeley National Laboratory. California's 2001 Wildfire Conference, October 10-13, 2001, Oakland, CA.

McClure, Rich, Carol Rice, and Kate Bolton. 2001. Perhaps burned through, but NOT burned out.

California's 2001 Wildfire Conference, October 10-13, 2001, Oakland, CA.

Rice, Carol L. 2000. Getting things done – Lessons learned in California. Interface Fires 2000, Halifax, Nova Scotia, May 7-10, 2000. Invited presentation available at www.fires2000.org.

Rice, Carol L. 2000. Fire prevention in the Urban-Wildland Interface. Fire Department Instructors Conference, Sacramento, CA, March 28-31, 2000. Invited presentation.

Rice, Carol L. 1998. Urban and Community Forestry and Fire Prevention, California-Nevada- Hawaii Fire Council, Kailua, Hawaii. April 23-25, 1998. Invited Presentation.

Rice, Carol L. and Cheryl Miller. 1997. Working to have it all in the urban wildland interface: Ways to minimize environmental impacts of fuel reductions at the urban wildland interface. Fire in California Ecosystems: Integrating Ecology, Prevention and Management, Nov. 17-20, 1997, San Diego.

Rice, Carol L. 1997. The role of land use planning in reconciling fire safety and ecosystem management.

Invited presentation at the California Under Fire - A Prescription for a Fire Safe future, Partnership Summit, Diamond Bar, CA. June 24-26, 1997. pg 8 In Summary Report. Forest Resources Assessment Program, California Department of Forestry and Fire Protection.

Rice, Carol L., Kate Bolton, and Rich McClure. 1997. Maintenance program for a fire-safe sustainable landscape at the Ernest Orlando Lawrence Berkeley National Laboratory. The Second International Wildland Fire Conference. May 25-30, 1997. Vancouver, BC.

Rice, Carol L. and Cheryl Miller. 1997. FARSITE modeling in the urban/wildland intermix. Pgs 561-570 In:
13th Conference on Fire and Forest Meteorology. International Association of Wildland Fire, Lorne, Australia, October 26-31, 1996.

Rice, Carol L. 1996. Fire Ecology. pgs. 162-176, Chapter 14 in California’s I-Zone: Urban/Wildland Fire Prevention and Mitigation, Training textbook, compiled and edited by California Fire Marshal OƯice.

Rice, Carol L. 1996. Fire Hardening your home. pg 15-20 In After the Vision Fire - Restoration, Safety & Stewardship for the Inverness Ridge Communities. Published by the Environmental Action Committee of West Marin. 83 pg.

Rice, Carol L. 1994. A balanced approach: Dr. Biswell's solution to fire issues in urban interface and wildland ecosystems. pgs 147-149 In The Biswell Symposium - Fire Issues and Solutions in Urban Interface and Wildland Ecosystems; Feb. 17-19, 1994, Walnut Creek, CA. Gen Tech.

Rep. PSW-GTR-158. Albany, CA Pacific Southwest Research Station, USDA For. Serv. 199 p.

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Rice, Carol L. 1994. Aftermath of the Oakland Hills Fire. pgs. 26-33, In the 46th Annual Conference of the California Weed Science Society, January 17-19, San Jose, CA.

Rice, Carol L. and Cheryl Miller. 1994. Regional vegetation management for fire hazard reduction in the wildland-urban interface of the East Bay Hills. Invited presentation to the Annual Conference of the National Fire Protection Association, May 17, 1994, San Francisco, CA.

Rice, Carol L. 1992. Fire and fuels at the wildland/urban interface. Pgs. 61-62. In Proceedings of Fire in Pacific Northwest Ecosystems: Exploring Emerging Issues, January 21-24, Portland, OR. Oregon State University, Corvallis, OR.

Carol Rice. 1991. Realizing benefits of interagency cooperation and volunteerism. Selected for recognition at the Western Association of College and University Business OƯicers 53rd.

Meeting, Scottsdale Az. May 5-8 1991.

Carol Rice and James B. Davis. 1991. Land use planning may reduce fire damage in the urban- wildland intermix. Pacific Southwest Forest and Range Experiment Station General Technical Report PSW-127.

Rice, Carol L. 1990. Restoration of the University of California, Berkeley Hill Area through fire hazard reduction. California Native Plant Society, Bay Area Chapter; January 24, 1990. Invited presentation.

Rice Carol, and James B. Davis. 1989. Minimizing fire damage through local land use planning.

Presented at the Meeting Global Wildland Fire Challenges - the People, the Land, the Resources, Boston. MA, July 23-26, 1989.

Rice, Carol L. 1988. Programs that address urban/wildland Interface fire problems, California- NevadaHawaii Fire Council, April 13-14, Honolulu, Hawaii. Invited Presentation.

Rice, Carol. 1988. How wildfire behaves: what we need to know to protect our neighborhoods. Survival by Design Workshop, March 29-30, 1988. California Department of Forestry and Fire Protection, USDA Forest Service, and California State Universities. Invited Presentation.

Rice, Carol and Elaine Bild. 1988. The fire hazard reduction program in the University of California Berkeley Hill Area. pgs. 182-183. In Protecting People and Homes from Wildfire in the Interior West, October 5-8, 1987. Missoula, MT. USDA Forest Service GTR-INT 251; Ogden, UT 213p.

Rice, Carol L. 1987. What will the western wildlands be like in the year 2000? Future perfect or future imperfect? pgs. 26-32 In Wildland Fire 2000, South Lake Tahoe, CA. April 27-30, 1987. GTR PSW-101, Pacific Southwest For. and Range Expt. Sta., Berkeley, CA.

Rice, Carol L. 1988. The value of scientific meetings - closing remarks. pg. 281 In Ninth Conference on Fire and Forest Meteorology. Rice and Fujioka, editors. April 21-24, 1987, San Diego, CA. American Meteorological Society, Boston, MA. 281p.

Rice, Carol L. 1986. Vegetation hazard assessment. Vegetation Management at the Urban Interface, La Canada, Ca. March 3-5,1986. Los Angeles County Department of Foresters and Fire Warden. Invited presentation.

Rice, C.L. and C.R. Aronson. 1985. The fire management program in the East Bay Regional Park District. pp.172-178. In Fire Management: the Challenge of Protection and Use. April, 1985, Logan Utah. Utah State University.

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PATTERSON & O’NEILL, PC
San Francisco, CA 9410
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
January 30, 2025

VIA E-MAIL
Los Altos Hills City Council
Town Hall Council Chambers
26379 Fremont Road
Los Altos Hills, CA 94022
Re: Agenda Item 9A
Housing Development Project Applications (File Nos. CDP23-0001 and CDP23-0001) 10728 Mora Drive and 10758 Mora Drive (Forrest Linebarger) Dear Mayor Tankha and Councilmembers:

Our office represents Forrest Linebarger. Our client submitted development project applications for the construction of two housing development projects located on 10758 Mora Drive and 10728 Mora Drive. These projects will provide much needed senior housing, a segment of the population that currently has very few living options in the Town.

As the staff report admits, Mr. Linebarger submitted the preliminary applications at a time when the Town was out of compliance with the Housing Element Law and subsequently submitted development applications pursuant to Government Code Section 65589.5(d)(5), commonly referred to as the Housing Accountability Act (“HAA”) “builder’s remedy.” Under the builder’s remedy, a local government cannot deny an affordable housing development project, even if the project is inconsistent with the jurisdiction’s zoning and general plan. unless the local government can make one of five enumerated findings.

Due to the historic housing crisis in our state, California has passed dozens of housing laws to reduce local impediments to housing. Our firm specializes in the enforcement and litigation of state housing laws when local agencies fail to carry out their duties under those laws. We have represented the non-profit housing advocacy group Yes In My Back Yard (YIMBY) Law in numerous successful lawsuits, including the first published case regarding the Housing Crisis Act, Yes In My Back Yard v. City of Culver City (2023) 96 Cal. App. 5th 1103, and also brought a lawsuit that resulted in one of the first superior court decisions upholding the builder’s remedy, Jha v. City of Los Angeles (July 24, 2024, Los Angeles. Superior Court Case No. 23STCP03499).

ITEM 9A, Supplement 31a
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YIMBY Law is tracking local government compliance with the Housing Accountability Act (“HAA”), and has already initiated several lawsuits against agencies that have refused to approve builder’s remedy projects. YIMBY Law has submitted a letter in support of Mr. Linebarger’s project, as has the nonprofit advocacy organization California Housing Defense Fund, formerly known as CARLA, the organization at the center of the seminal HAA case Cal. Renters Legal Advocacy & Educ. Fund v. City of San Mateo, 68 Cal.App.5th 820.) The Legislature recently enacted AB 1893, which made significant changes to the HAA to strengthen the builder’s remedy provision. The legislative author explained that the intent of AB 1893 was to “modernize the builder’s remedy to make it clear, objective, and easily usable” and that “the message to local jurisdictions is clear — when it comes to housing policy, the days of shirking your responsibility to your neighbors are over.” As explained below, the proposed action to disapprove Mr. Linebarger’s projects is premature, including because he has utilized his rights under AB 1893 to revise his project to meet the new definition of a “builder’s remedy project.” The project under consideration by Council is no longer the applicable project. However, if the Council insists on taking an action to disapprove the projects over my client’s request for a continuance, the Town’s action would constitute an unlawful disapproval and constitute a violation of the HAA.

The Project Plans Under Consideration are No Longer Applicable AB 1983 provides applicants with existing applications that are deemed complete prior to January 1, 2025 with the option to be subject to “any or all of the provisions of this section applicable as of January 1, 2025.” (Gov. Code Sec. 65589.5(f)(7).) Further, this subdivision allows an applicant to “revise their application so that the project is a builder’s remedy project, without being required to resubmit a preliminary application.” The staff report erroneously argues that the project is not a builder’s remedy project because the applicant had not yet revised the application to reflect the new provisions in AB 1893 that went into effect January 1, 2025. First, a project with a complete application may choose whether to be subject to the new provisions or continue to be processed under the prior version of the builder’s remedy. In other words, an applicant does not need to meet the new definition of “builder’s remedy project” in subd. (h)(11) cited in the staff report – unless the applicant chooses to be subject to that definition.

Regardless, the applicant has chosen to revise his application to meet the definition of “builder’s remedy project” in subd. (h)(11). The revisions include significant changes such as reducing the number of units, amending the affordability levels, amending the fire access plans, and amending the proposed accessory uses, parking, and elevations. The project plans that are the subject of the January 30 hearing no longer exist and have been replaced with new application materials. As a result, the proposed public hearing notices, resolutions, findings, and attached project plans are ITEM 2A ATTACHMENT 9

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all describing a project that the Town has no authority to act upon, as the applicant has now exercised his right to revise the applications under Gov. Code Sec. 65589.5(f)(7).

The new project plans have not been reviewed by Town staff and any proposed action would be premature, including because the Town is required to provide 10-days’ advanced notice prior to any hearing. (Gov. Code § 65094.) That is impossible here, as the revised application materials were only submitted today. In sum, the Council does not have the authority to act on the project and this hearing must be continued.

The Proposed Findings Are Inadequate to Disapprove the Project Colloquially known as the “builder’s remedy,” a local government is required to approve housing, or not otherwise condition approval in a manner that renders the housing development project infeasible, unless the local government can make certain written findings based upon a preponderance of the evidence. Under Gov. Code § 65589.5, subd. (d)(5), a local government cannot deny a housing development project for low-income households, even if the project is inconsistent with the jurisdiction’s zoning and inconsistent with the general plan land use designation, unless the local government can make written findings, supported by a preponderance of the evidence in the record, that it has adopted a housing element in substantial compliance with the Housing Element law. Otherwise, a local government must make written findings that one of the other four enumerated sets of circumstances exist.

As the staff report admits, a preliminary application for the project was submitted before the Town had adopted a substantially compliant housing element. The purpose of the preliminary application is to “vest” the standards that are in effect at the time a complete preliminary application is submitted. In other words, housing development projects are only subject to the standards that were adopted and in effect at the time a complete preliminary application is submitted. (Gov Code § 65589.5 subd. (o)(1).) Therefore, if the preliminary application submittal occurs at a time when a jurisdiction does not have a compliant housing element, any potential benefits afforded to the applicant as a result of the jurisdiction’s noncompliant status, including the builder’s remedy, remain throughout the entitlement process.

The staff report claims that there are three reasons to support the proposed disapproval. Each is addressed in more detail below.

The Project Meets the Requirements of the Builder’s Remedy As explained above, the staff report argues that the project does not qualify for the new definition of builder’s remedy in Gov. Code Sec. 65589.5(h)(11), which did not go into effect until January 1, 2025. Pursuant to Gov. Code Sec. 65589.5(f)(7), the applicant can choose whether to be subject to this definition. Prior to January 1, 2025, any project that met the prior definition of “housing for very low, low-, or moderate-income households,” qualifies for the builder’s remedy. This project previously provided 20% of the units as affordable to low-income ITEM 2A ATTACHMENT 9

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households, meeting the definition of “housing for very low, low-, or moderate-income households.” Moreover, the applicant has since revised the project to meet the new definition of builder’s remedy project as explicitly permitted by Gov. Code Sec. 65589.5(f)(7). Either way, the projects are eligible for the protection of the builder’s remedy. Staff’s assertion otherwise is without merit. As a result, the disapproval finding no. 3 is not a legally valid reason to deny the project.

The Town has Not Identified Any Specific State or Federal Laws that the Project Fails to Meet The staff report erroneously claims that the project is inconsistent with the California Fire Code, citing Section 503.1.1. Presumably, the Town is suggesting that the project does not meet regulations adopted into Title 24 of the California Code of Regulations, which contains the California Building Standards Code. First, we note that Title 24 includes regulations, not state laws, that are adopted by various state agencies and implemented by the California Building Standards Commission.

However, the Town’s claim that Section 503.1.1 is part of the California Fire Code is simply wrong. The Office of the State Fire Marshal (SFM) is solely responsible for promulgating regulations for inclusion in Part 9 of the State Building Codes, also referred to as the California Fire Code. In 2022, the SFM chose not to adopt Section 503 of the International Code Council (ICC) Fire Code.1
In the most recent proposed update, the SFM once again is proposing not to adopt Section 503 into the California Fire Code.2
In short, the Town’s citation to an ICC model code that has not been adopted by the SFM, and is not a part of Title 24, is erroneous. Section 503.1.1 has no force and effect in California. The Town has not identified any specific state or federal laws that the project fails to meet, and disapproval finding no. 2 is not legally valid reason to deny the project. 1 The State Building Codes are all based on ICC code standards. When the State Building Code is updated, each responsible agency may choose to adopt, amend, or not adopt portions of the ICC Code. Because the ICC’s codes are copyrighted, the ICC is the only entity that is allowed to publish the State Building Code. The ICC publishes both the ICC’s “model code” along with the California amendments (in italics) in one document. Each chapter of the code begins with an “adoption matrix” that indicates which ICC model codes have been adopted by the relevant California agency. Chapter 5 of the Fire Code matrix confirms that Section 503 has not been adopted by the SFM and is therefore not part of the California Fire Code. https://codes.iccsafe.org/content/CAFC2022P1/chapter-5-fire-service-features 2 See SFM Final Statement of Reasons, available at https://www.dgs.ca.gov/- /media/Divisions/BSC/03-Rulemaking/2024-Triennial-Cycle/Commission-Meetings/2025-02- 26/SFM-06-24-FSOR-PT9.pdf
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The Town has Not Identified Any Specific, Adverse Impact Upon the Public Health or Safety The staff report suggests that the project would have a specific, adverse impact upon the public health or safety based on Section 503.1.1, again erroneously claiming that this section is part of the California Fire Code. This section was not adopted by the SFM and is not part of the California Fire Code.

The Town did adopt a local amendment to the state Fire Code into the Town’s Fire Code in January 2023,3
to add and amend Section 503.1.1 of the ICC model code language. The local code provision states as follows:
503.1.1: Approved fire apparatus access roads shall be provided for every facility, building or portion of a building hereafter constructed or moved into or within the jurisdiction. The fire apparatus access road shall comply with the requirements for this section and shall extend to within 150 feet (45,720 mm) of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Exceptions:

1. In other than R-3 or U occupancies, when the building is equipped throughout with an approved automatic sprinkler system, installed in accordance with Section 903.3.1.1 the dimension may be increased to a maximum of 300 feet when approved by the fire code official.

The HAA defines “specific, adverse impact” to mean a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions. (Gov. Code § 65589.5(d)(2).) The HAA further defines “objective” to mean standards that require “no personal or subjective judgment by a public official” that are “knowable by both the development applicant or proponent and the public official.” (Gov. Code § 65589.5(h)(8).) The HAA’s objectivity requirement applies to all applicable development 3 In addition, the Town’s fire code violates the Housing Crisis Act, which prohibits the Town from enacting or implementing any new code standards that reduce the intensity of land use or reduce a site’s residential development capacity. (Gov. Code § 66300(b)(1)(A).) The Town’s fire code ordinance reduces the amount of space on a parcel where housing can be built, which clearly reduces a site’s residential capacity in violation of the Housing Crisis Act, and is therefore void. (Gov. Code § 66300(b)(2).) Further, the Housing Crisis Act prohibits the Town from imposing or enforcing design standards that are not objective design standards. (Gov. Code § 66300(b)(1)(C).) The Town’s ordinance imposes design standards that are not objective and is therefore void. (Gov. Code § 66300(b)(2).)
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standards, conditions, and policies, which necessarily includes local fire code requirements. (See Gov. Code § 65589.5(j)(1).)
In addition, consistency review is subject to the “reasonable person” standard in subdivision (f)(4), which states that a project must be deemed consistent with applicable objective standards “if there is substantial evidence that would allow a reasonable person to conclude” that the project is consistent. (Gov. Code § 65589.5(f)(4).) Courts have explained that these two provisions work in tandem, and the reasonable person standard “complements and reinforces” the HAA’s objectivity requirement and “[w]hether one focuses on the first, subdivision (j)(1) question or on the second, applying subdivision (f)(4), the effect is the same.” (Cal. Renters Legal Advocacy & Educ. Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 845.) Courts have also explained that to the extent the question of consistency “is close,” the burden is clearly on the agency to demonstrate that it has complied with the HAA. (Id.) The Town’s local fire code requirements fail to meet the HAA’s definition of objective by giving fire officials broad and subjective authority to determine consistency on an ad hoc basis.

Specifically, the code requires “approved” fire apparatus access roads to be sited no more than 150 feet away from the exterior of a building from an “approved” route but specifically allows the distance to be increased to 300 feet with an “approved” automatic sprinkler system when “approved” by the fire code official. The Town’s local code is littered with subjective determinations that may be approved or denied at the whim of the subjective determination of the local agency. The Town’s subjective code requirement therefore cannot form the legal basis for a denial of the project.

Moreover, the Project does, in fact, meet the objective requirements of the Town’s ordinance.

The project provides a fire apparatus access road that is sited to within 300 feet of a proposed building that is equipped with an automatic sprinkler system that will be installed in accordance with Section 903.3.1.1. This exception, unlike exception 3, does not require an “alternative means” of compliance. In other words, so long as the project meets the sprinkler requirement, the maximum distance is increased to 300 feet.

Even if this consistency determination were “close,” which it is not, under the “reasonable person” standard using the substantial evidence test, the project can be found consistent with the Town’s requirements. Fire consultant Carol Rice, who has decades of experience in fire safety and forestry, confirmed that the project meets the Town’s Section 503 requirements. This provides substantial evidence that a reasonable person could conclude the project meets the Town’s requirements. This is particularly true since the HAA must be interpreted and implemented to “afford the fullest possible weight to the interest of, and the approval and provision of, housing.” (Gov. Code § 65589.5(a)(2)(L).) The Town’s prejudicial and subjective interpretation, ignoring the objective 300 foot extension allowed by exception 1.1, is an interpretation tailored to deny housing.

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We further note that the Town’s staff report seems to suggest that the Zoning Code’s Lot Unit Factor (LUF) requirements are a public health and safety standard related to slope and reducing fire risk. The Town’s LUF requirements are nothing more than a development standard meant to reduce the size of buildings. Regardless, the HAA expressly prohibits inconsistency with zoning ordinances from constituting a public health and safety impact. (Gov. Code 65589.5 § (d)(2)(A).) The Project is Deemed Compliant with the Town’s Requirements.

The Town sent a new letter on February 22, 2024, claiming that the project was inconsistent with fire code requirements. The fact that these comments were from the Santa Clara County Fire Department (“SCCFD”) is immaterial, as the HAA applies to any “local agency,” which is broadly defined to include “a county, city, whether general law or chartered, city and county, school district, special district, authority, agency, any other municipal public corporation or district, or other political subdivision of the state.” (Gov. Code § 66000(c).).4 LAHFD is a Special Fire District established pursuant to Health and Safety Code § 13800, and clearly falls within the definition of a local agency. Thus, the letter must adhere to HAA requirements. As explained below, the letter was untimely and is based on subjective standards that fail to meet the requirements of state law.

The HAA requires a local agency to provide written documentation identifying any inconsistencies with any applicable plan, program, policy, ordinance, standard, requirement, or other similar provision “[w]ithin 30 days of the date that the application for the housing development project is determined to be complete” or the project is deemed consistent as a matter of law. (Gov’t. Code § 65589.5(j)(2).)
The Town’s September 28, 2023 completeness determination stated that the Town included the Town’s written documentation of code consistency. The Town also previously acknowledged that the fire department was required to comply with the HAA’s deadlines, stating in its March 3, 2023 completeness determination that the fire department will conduct substantive review of the plans “in accordance with applicable timelines.” Despite this commitment, the Town failed to send the fire department’s comments for nearly five months after the application was deemed complete. These comments were not timely, and therefore the project has been deemed compliant with all applicable plan, program, policy, ordinance, standard, requirements that were not identified within 30 days after the application was deemed complete (i.e. October 28, 2023). 4 We note that the Town, not SCCFD, sent the letter directly to Mr. Linebarger, and the Town refused to send the letter for several weeks until Planning staff reviewed its contents. We are unclear whether these comments are from Planning staff, SCCFD staff, or whether the two agencies are collaborating to provide joint comments. However, as explained above, the difference is immaterial because both the Town and SCCFD are local agencies bound by the HAA’s requirements.

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The Town has Not Demonstrated That There Are No Feasible Mitigation Measures.

As explained above, the project is both compliant in fact and deemed compliant in law with the Town’s fire code requirements. But even if it were not, the Town has failed to demonstrate that there are no feasible mitigation measures to address the purported health and safety impacts. The Town points to the Town’s Fire Department’s denial of an application for a Use of Alternate Materials or Method of Construction or Modification of Code, referred to as an AMMR.

Despite meeting the requirements of the Town’s code and the fact that no AMMR is required, my client takes fire risk very seriously and has worked closely with the Town’s department to identify potential mitigation measures that go above and beyond code requirements to reduce fire risk. While the specific AMMRs were not approved, this does not demonstrate that there are no possible feasible mitigation measures available. In fact, the Town’s Fire Department has confirmed via email they believe mitigating fire risk is possible for the project – which is why the Department encouraged my client to go through the AMMR process. My client has reached out to Fire Department staff and continues to work with the Department in an effort to further reduce potential fire risk. The Town’s claim that no feasible mitigation exists is simply false.

We further note that the Town’s financial analysis, which the Town suggests supports their finding that no mitigation is available, is significantly flawed. Regardless, the analysis the Town provides fails to show that the Town’s preferred mitigation of reducing density and residential space is financially infeasible. The difference in return between the proposed project and the Town’s proposed mitigation is minimal.

The Council’s Actions Are Not Ripe and Violate the Applicant’s Due Process Rights.

As the staff report admits, consistency with the Town’s local fire code requirements, contained in Title 8 of the Town’s municipal code, is supposed to be determined by a building official during the post-entitlement building permit phase. For other projects, the Town does not require Fire Department AMMR approval until after the project receives a planning entitlement.5 Here, staff
is singling out my client’s project for differential treatment simply for asserting his rights under the builder’s remedy. Not only is this a violation of my client’s due process rights, but this is also a violation of the HAA that prohibits a local government from imposing “any requirement, process, practice, or procedure . . . that applies to a project solely or partially on the basis that the project is a builder’s remedy project.” (Gov. Code § 65589.5(f)(6)(E).) The Council, acting on a Conditional Development Permit, are limited to reviewing a project for consistency with Town’s Zoning and Site Development Standards contained in Chapter 10. (See Code § 10-1.1007(3) regarding findings for approval or denial of permits). As the staff report admits, the applicant has not yet even submitted a building permit application to the Town. We 5 See Lands of Bowers – 26875 Nina Place – File# SD21-0061, Condition 38 https://www.losaltoshills.ca.gov/DocumentCenter/View/5365/26875-Nina-Pl-COA?bidId= ITEM 2A ATTACHMENT 9

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further note that, under state law and the Town’s own code, the Planning Commission is required to hold a public hearing on conditional permits before a hearing at the City Council. (Code § 10-

1.1004 and Gov. Code § 65901 and 65902.)
The Town has decided to skip the required steps and rush to disapprove my client’s project, failing to even inform Mr. Linebarger of the pending hearing when the City Manager and City Attorney met with my client on January 17, 2025 (without our office’s consent). The Town’s actions are clearly evidence of bad faith, as staff kept its disapproval plans a secret from the applicant and attempted to gain information to support a denial without his attorney present. The Town has skipped over Planning Commission review, refused to continue the hearing, and attempts to deny the project based on building code requirements that are not yet at issue. We can only assume that the Town is attempting to rush this disapproval through to try to prevent my client from converting the application to the new, strengthened builder’s remedy provisions of AB 1893. Attempting to skirt state law is not a valid reason to disapprove a project and further demonstrates bad faith.

We note that post-entitlement phase permits are subject to their own process under Gov. Code 65913.3. Moreover, building code compliance issues, including fire code issues, are also subject to appeal to the Building Standards Commission (see Health and Safety Code §§ 1893-18949) and the state fire marshal (see 19 CCR § 2.03). The Town is attempting to short circuit the proper process, deny my client his appeal rights, prevent my client from being able to properly prepare for a surprise hearing, and prematurely disapprove the project. Even if the Town’s code basis for disapproval were legally valid, which they are not, the Town’s actions are a violation of my client’s due process rights to a fair hearing.

Quasi-judicial proceedings are subject to federal and state due process requirements, the fair hearing requirement of Code of Civil Procedure section 1094.5, and additional requirements applicable to particular hearings. Relying on these authorities, California courts have held that administrative hearings must be fair and that administrative decision makers must be impartial.

Code of Civil Procedure § 1094.5(b) creates a statutory right to a fair hearing, which must be conducted before an impartial tribunal. (Clark v. City of Hermosa Beach (1996) 48 Cal.App.4th 1152.)
As a quasi-judicial proceeding, the Town is required to afford the Applicant due process. Due process “unlike some technical rules, is not a technical conception with a fixed content unrelated to time, place and circumstances [citations omitted].” (Mathews v. Eldridge (1976) 424 US 319, 334). .) The ability to bring evidence and to respond to evidence presented against oneself, the entitlement to adjudicators to pay attention to the proceedings and review the evidence, and the provision of adequate notice are all features of this comprehensive right.

We urge the Council not to take any action, at minimum, until my client has sufficient time to prepare a rebuttal to the staff’s surprise hearing.

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Mayor Tankha and Councilmembers
January 30, 2025

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Conclusion
The Town’s rushed disapproval findings are based on flawed analysis and the proposed action is legally invalid. The Town must review the revised version of the project, consistent with the provisions of AB 1893. If the Town acts to disapprove the prior project in an attempt to extinguish his rights under the builder’s remedy, my client may have no choice but to take legal action. Thank you for your prompt attention to this matter.

Very truly yours,
PATTERSON & O’NEILL, PC
____________________________________ Brian O’Neill
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DECLARATION OF FORREST LINEBARGER
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PATTERSON
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MONTGOMERY STREET, SUITE 950 SAN
FRANCISCO, CALIFORNIA 94104

DECLARATION OF FORREST

LINEBARGER
Builder’s Remedy Project Applications
10758 and 10728 Mora Drive
I, Forrest Linebarger, declare as follows:

1. I am the owner of 10728 Mora Drive and 10758 Mora Drive in the town of Los Altos Hills in Santa Clara County, California. I make this declaration based on personal knowledge of the following facts, except to those matters stated on information and belief, and as to those matters, I believe them to be true. If called as a witness to testify, I could and would competently testify thereto.

2. On February 1, 2025 I went to the Town of Los Altos Hills to submit applications under the “Builder’s Remedy” provision of the Housing Accountability Act (“HAA”) and the Permit Streamlining Act (“PSA”) to the Town of Los Altos Hills (Town”) for projects located at 10758 Mora Drive, Los Altos Hills, CA and 10728 Mora Drive, Los Altos Hills, CA.

3. I met with Planner Elaine Ling and City Manager Peter Pirnejad. The Town staff refused to accept the applications, stating they did not know how to charge for them as there was no line in their fee schedule for the Builder’s Remedy. I told them I had my checkbook and was prepared to pay any application fees. Mr. Pirnejad eventually stated he would “receive” the applications but not “accept” them, and he took the submittal documents but not any fees. A true and correct version of this email is attached as Exhibit A.

4. Mr. Pirnejad responded to the applications on March 3, 2023, claiming the Town was not in violation of the Housing Element law as it had “self-adopted” its Housing Element. He also required the payment of fees of $5,200 for a major variance in its zoning code, and refused to process the applications further until that fee was paid.

ITEM 9A, Supplement 31b
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5. I received a second comment letter from Consultant Principal Planner Susanne Avila for each project, dated March 3, 2023. The items the Town requested varied, but the letters claimed to attach a Pre-Application Checklist. However, that document was not provided. Most of the items requested were not included on any Pre-Application Checklist.

6. The Town’s Housing Element was not found in compliance with the Housing Element law at the time of the submission or at the time of Mr. Pirnejad’s March 3, 2023 letter. Our submissions on February 1, 2023 contained all 17 elements required under the Permit Streamlining Act for a complete preliminary application submittal.

7. On April 18, 2023 I received the Santa Clara County Fire Department (“Fire Dept.”) comment letter (dated April 5, 2023) our 10758 Mora Proposal. This letter was the first Fire responses, 76 days after the submission of our PSA application. The plan reviewer was Kenny Ip.

8. On May 8, 2023 I received the first Fire Dept. response to our 10728 Mora Proposal, 84 days after the submission of our PSA application. The plan reviewer was Caleb Flanagan.

9. I had worked with both Kenny Ip and Caleb Flanagan before as they were the regular reviewer for projects in our area at the Fire Department. I asked James Bevan, who worked with me on these and other projects, to take the lead on responses to the Fire Dept. comments.

10. After reaching out to the Fire Dept. reviewers, Mr. Bevan informed me he had solutions to the comments based on his communications with the Fire Dept. and the only remaining issues were a Hydrant Spotting Plan and hydrant water flow tests at the hydrants.

11. The Hydrant Spotting Plan and the hydrant water flow tests were approved on April 25, 2023.

12. The fire department response was not received until September 28, 2023, when we received fire department comments for both projects dated September 27, 2023.

13. Despite our many efforts to get objective code references from the Fire Dept. reviewer, they were unable to articulate what they wanted to see in our submissions or explain why our plan that met the objective code requirements were not being accepted.

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PATTERSON
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14. After numerous submittals and letters to the Fire Dept. We were unable to get the Fire Department to apply State Fire Codes rather than the Los Altos Hills Fire Codes, or to apply the Exception in Section 503 that allows the distance from access roads to be increased when a building is fully sprinklered. I asked to have a meeting to try to resolve the issues.

15. On May 22, 2024 I had a meeting with Assistant Fire Chief Brian Glass, Aaron Forbath, Brad Fox, and Brian O’Neill, as well as others from the fire department. Mr. Glass informed me that the Fire Department considered its contract with Los Altos Hills required it to apply the codes that the Town wished to apply, in this case the Los Altos Hills CFC, rather than the California CFC. Mr. Glass also told me that under the contract the Fire Dept. was required to follow the Town’s interpretation of the Los Altos Hills CFC and they could not issue an approval letter that went against the Town’s recommendation. After the meeting, the Fire Department sent me a copy of the Department’s contract with the Town. A true and correct copy of the contract the Department sent me is attached as Exhibit B.

16. After further submissions and responses, we were still unable to get the Fire Department to apply State fire code or approve the project based on local code. Attached as Exhibit C is a true and correct copy of a letter my attorney submitted after the meeting. This led me to request another meeting with Fire Dept. staff.

17. On August 28, 2024 I had a meeting with Mathew McKenna, Brian Glass, Brad Fox, Kenny Ip, Caleb Flanegan, Rob Campbell and others from the Fire Dept. to hash out potential solutions that would satisfy them, even if they were not required by the CFC. The Fire Dept. team, particularly Mathew McKenna and Brad Fox drove the discussion and suggested and agreed to the four solutions: 1) retain the fire sprinkler systems per 903.3.1.1 2) Separate the fire department access from the occupant egress along the sides of the building adjacent to the parking area, except where the ADA ramp brought the two paths together; 3) add standpipe outlets on the exterior walls on the lower portion of the building to provide places for them to attach fire hoses; 4) Increase the fire rating at the wall to Type 1-A for the non bearing walls at sides of the parking garage; 5) Remove most of the glass and openings below 10’ from grade at the firefighters egress side and increase the fire rating of the remaining glass to ¾ of an hour ITEM 2A ATTACHMENT 9

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DECLARATION OF FORREST LINEBARGER
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rating. Mr. Mckenna and Mr. Fox both made clear that the solutions still had to be approved by the Fire Chief but that they felt the solutions were workable and adequate. I faithfully executed those mitigation measures and put them on the plans in the form of an AMMR.

18. The Fire Department in their response to the AMMR on 10578 Mora Dr. rejected all of the solutions that we had come up with together. The Fire Department never responded to the AMMR on the 10728 Mora Drive.

19. On January 15, 2025 at 3:46 pm Los Altos Hills City Manager Peter Pirnejad called my on the telephone to set up a meeting to discuss my Builders Remedy Projects. We decided to meet on January 17, 2025 at the Town City Hall. He told me he would check with “Steve” also.

I did not know who he was talking about as there has been a lot of staff turnover in the last few years. He did not identify Steve at the Town’s Attorney nor did he suggest I invite my attorney.

20. On January 17, 2025 I arrived at City Hall for our meeting, both Peter Pirnejad and Steve Mattus, the City Attorney, were sitting in the conference room. Before we began Steve asked if it was OK to have this meeting be a confidential settlement and I said it was OK. They did not suggest that I have my attorney present. Neither Peter Pirnejad nor Steve Mattas told me about a planned city council meeting to consider denial of my projects on January 30, 2025.

21. On January 29, 2025 I received an email from an outside consultant, Suzzane Avila, that I was advised that of the January 30 city council meeting during my meeting on January 17, 2025 with Mr. Pirnejad and Mr. Mattus. This is not true, and it breached the confidentiality of the meeting. Attached is a true and correct copy of the email. See email attached as Exhibit D.

22. On January 31, 2025 I had a phone call with my attorney, Brian O’Neill about the meeting with the City Attorney on January 30, 2025. Mr. O’Neill he told me that the Town should have informed him of the meeting and received consent if it involved the City Attorney and but he was not informed, nor did he provide consent.

23. The Town’s Staff Report dated January 30, 2025 contains an ad hoc feasibility study and exegesis on page 18. As a developer, it is clear to me that this evaluation was not done by a developer or finance expert, and contains numerous flaws in the analysis. The study assumes ITEM 2A ATTACHMENT 9

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Builders Remedy Submissions Feb 1, 2023
Forrest Linebarger <[email protected]> Wed, Feb 1, 2023 at 4:11 PM
To: [email protected]
Bcc: Brian O'Neill <[email protected]>, Ryan Patterson <[email protected]>, Usha Rani Kodali <[email protected]>, James Bevan <[email protected]> Elaine,
Thank you for meeting with me today when I came in to submit my "Builder's Remedy" SB 330 Preliminary Applications and formal Development Applications for two residential development projects, one at 10728 Mora Drive and the other at 10758 Mora Drive. In that meeting Peter Pirnejad, the City Manager, told me you were receiving the applications but not accepting them. I urged you to accept the applications. You both told me you could not figure out what fees to charge as nothing seemed applicable from the Town's fee chart. I told you repeatedly that I was ready to pay any applicable fees right there and then, but the Town could not figure out what to charge.

You also requested that I needed to email an open Dropbox type link to your email of all the application materials. I have included the links below. 10758 Mora Submittal Package Dropbox link:
https://www.dropbox.com/scl/fo/n9sg5tixdy5tg48622f4h/h?dl=0&rlkey=oxy2vs6dxoep0l6u77osesblf 10728 Mora Submittal Package Dropbox link:
https://www.dropbox.com/scl/fo/qlc9j1wv2o1226coxq4hz/h?dl=0&rlkey=9iirxuhva7tofpjohlny80adp Peter told me that the Town would look at the documents and tell me what else was needed before accepting them, but would do so expeditiously. I asked that he accept the applications there and then and then merely respond to them of course, anything missing could be taken care of in the response stage.

Please let me know if you have any trouble accessing the documents or with anything else.

I look forward to your response.

Thank you,
Forrest Linebarger
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PATTERSON & O’NEILL, PC
235 Montgomery Street, Suite 950
San Francisco, CA 94104
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
June 4, 2024

VIA E-MAIL
Brian Glass, Assistant Fire Chief
Santa Clara County Fire Department
14700 Winchester Blvd.

Los Gatos, CA 95032
Re: Housing Development Project Applications 10728 Mora Drive (File No. CDP23-0001) & 10758 Mora Drive (File No. CDP23-0002)
Dear Mr. Glass:

As you are aware, our office represents Forrest Linebarger, owner of 10728 Mora Drive in Los Altos Hills. Our client submitted two development project applications for the construction of a multi-unit housing development projects on 10728 and 0758 Mora Drive. These projects will provide much needed senior housing, a segment of the population that currently has very few living options in the Town.

Due to the historic housing crisis in our state, California has recently passed dozens of housing laws to reduce local impediments to housing. Our firm specializes in the enforcement and litigation of state housing laws when local agencies fail to carry out their duties under those laws.

We have represented the non-profit housing advocacy group Yes In My Back Yard (YIMBY) Law in numerous successful lawsuits, including the first published case regarding the Housing Crisis Act, Yes In My Back Yard v. City of Culver City (2023) 96 Cal. App. 5th 1103. YIMBY Law is tracking local government compliance with the Housing Accountability Act (“HAA”), and has already initiated several lawsuits against agencies that have refused to approve Builder’s Remedy projects.

On September 28, 2023, the Town of Los Altos Hills (“Town”) confirmed that the project application was complete pursuant to the Permit Streamlining Act. On February 22, 2024, the Town forwarded a letter from the Santa Clara County Fire District (“SCCFD”), dated January 31, 2024. The letter stated that the project plans are “NOT APPROVED,” and the Town has informed my client that it will not process the proposed application based on SCCFD’s disapproval.

We appreciate the time you and your staff took to meet with us on May 22, 2024 to discuss this project, and we wanted to follow-up with an additional explanation as to why SCCFD must ITEM 2A ATTACHMENT 9

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Brian Glass, Assistant Fire Chief
June 4, 2024

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approve the project as submitted. As explained in more detail below, approval of the project plans is required by the HAA, including because the project has been deemed consistent with fire code requirements by operation of law and the project meets all objective fire code requirements.

The Fire Department is Subject to State Law Requirements.

The HAA applies to any “local agency,” which is broadly defined to include “a county, city, whether general law or chartered, city and county, school district, special district, authority, agency, any other municipal public corporation or district, or other political subdivision of the state.” (Gov. Code § 66000(c).) LAHFD is a Special Fire District established pursuant to Health and Safety Code § 13800, and clearly falls within the definition of a local agency. Thus, SCCFD acting in its capacity as LAHFD must adhere to HAA requirements.

The California Department of Housing and Community Development (“HCD”) has confirmed that special districts must adhere to the HAA’s requirements, regardless of whether an application was submitted directly to the special district.1 Because all local agencies are bound by the HAA, HCD “recommends coordination between all local agencies that may be involved in either the entitlement or post-entitlement process.” In short, the HAA’s requirements clearly apply to LAHFD’s review of this project.

The Project is Deemed Consistent with all Fire Code Requirement by Operation of Law.

The Housing Accountability Act (“HAA”) requires a local agency to provide written documentation identifying any inconsistencies with any applicable plan, program, policy, ordinance, standard, requirement, or other similar provision “[w]ithin 30 days of the date that the application for the housing development project is determined to be complete.” (Gov. Code § 65589.5(j)(2)(A).) If an agency fails to provide written document of a code inconsistency, the project “shall be deemed consistent, compliant, and in conformity with the applicable plan, program, policy, ordinance, standard, requirement, or other similar provision. (Id. subd. (B).) Any purported code inconsistencies for this project were required to be identified within 30 days after the application was deemed complete on September 28, 2023 (i.e. by October 28, 2023.) On February 22, 2024, nearly five months after the application was deemed complete, the applicant received a letter claiming that the project was inconsistent with local fire code requirements.

These comments were untimely, and thus pursuant to Gov. Code § 65589.5(j)(2)(B), the project has already been deemed consistent with the local fire code by operation of law.

The Town’s September 28, 2023 completeness determination stated that the Town included the Town’s written documentation of code consistency. The Town also previously acknowledged that LAHFD review was required to comply with the HAA’s deadlines, stating in its March 3, 1 See HCD, SB 330 Preliminary Application Vesting Rights and Local Agencies – Letter of Technical Assistance, dated July 20, 2023, available at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/ranchocucamonga-ta-072023.pdf.

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2023 completeness determination that the fire department will conduct substantive review of the plans “in accordance with applicable timelines.” Despite this commitment, the applicant did not receive the fire department’s comments for nearly five months after the application was deemed complete. These comments were not timely, and therefore the project has been deemed compliant with all applicable plan, program, policy, ordinance, standard, requirements that were not identified within 30 days after the application was deemed complete (i.e. October 28, 2023), including local fire code requirements.

We note that according to the contract between the Town and SCCFD, SCCFD is required to review and return all development review items within ten working days. (See Fire and Emergency Medical Services Agreement (Hereinafter “Fire Services Agreement,” § 3.4.) Thus, even though fire review in this case required inter-agency communications, SCCFD should have been able to provide review well within the HAA’s timelines. Whether the delay was due to the Town’s delay in relaying information or the time it took SCCFD to review the project plans, the result is the same. The project has been deemed consistent with all fire code requirements by operation of law.

The Project is Consistent with all Objective Fire Code Requirements.

HAA subdivision (f)(1) only permits local agencies to require housing development projects to comply with “objective, quantifiable, written development standards, conditions, and policies.” The HAA defines “objective” to mean standards that require “no personal or subjective judgment by a public official” that are “knowable by both the development applicant or proponent and the public official.” (Gov. Code § 65589.5(h)(8).) The HAA’s objectivity requirement applies to all applicable development standards, conditions, and policies, which necessarily includes local fire code requirements. (See Gov. Code § 65589.5(j)(1).)
In addition, consistency review is subject to the “reasonable person” standard in subdivision (f)(4), which states that a project must be deemed consistent with applicable objective standards “if there is substantial evidence that would allow a reasonable person to conclude” that the project is consistent. (Gov. Code § 65589.5(f)(4).) Courts have clarified that these two provisions work in tandem, and the reasonable person standard “complements and reinforces subdivision (j)’s objectivity requirement” and “[w]hether one focuses on the first, subdivision (j)(1) question or on the second, applying subdivision (f)(4), the effect is the same.” (Cal. Renters Legal Advocacy & Educ. Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 845.) Courts have also explained that to the extent the question of consistency “is close,” the burden is clearly on the agency to demonstrate that it has complied with the HAA. (Id.) Further, the Legislature has commanded that the HAA must be interpreted and implemented to “afford the fullest possible weight to the interest of, and the approval and provision of, housing. (Gov. Code § 65589.5(a)(2)(L).) Said another way, if there are two reasonable interpretations of a code requirement, the interpretation that is most benefits the approval of housing must be utilized.

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Brian Glass, Assistant Fire Chief
June 4, 2024

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During our meeting, Assistant Fire Marshal Brad Fox suggested that SCCFD must review the plans according to the Town’s interpretation of its local fire code. However, the Fire Services Agreement makes clear that SCCFD is required to check development plans to certify compliance “with all ordinances, statutes and regulations applicable to the CITY, the County or the LAHCFD as the case may be . . .” (Agreement § 3.2.1.) In other words, SCCFD is not just required to review projects for local fire code compliance in isolation, but SCCFD is contractually and statutorily obligated to independently review projects while taking into account all statutes and regulations, including the HAA.

At our meeting, Deputy County Counsel Arron Forbath asked which portion of the LAHFC 503.1 requirements should be struck. The HAA does not provide a formulaic approach that would eliminate specific subjective words. Rather, as explained herein, SCCFD must utilize a wholistic approach that interprets the code in manner that afford the fullest possible weight to the approval of housing and asks whether a reasonable person could conclude that the project is consistent with an interpretation that fully favors project approval. Under such an inquiry, this project must be found consistent with fire apparatus access roads requirements.

The Town is Refusing to Process the Projects Pending Fire Department Approval.The Town has informed Mr. Linebarger that it will not continue to process his application until the project receives SCCFD approval, squarely placing the responsibility for fire review on SCCFD alone. (See Exhibit A.) Although the Town is the entity that will ultimately take final action on the project entitlements, the HAA limits the ability of all local agencies to enforce subjective standards via subdivision (f) and (j). In short, SCCFD must review the project consistent with the HAA’s requirements.

The Town’s local fire code requirements fail to meet the HAA’s definition of objective bygiving fire officials broad and subjective authority to determine code consistency on an ad hoc basis.

Specifically, the state fire code regarding fire apparatus access roads allows an access road to be sited more than 150 feet away from the exterior of a building when the building is equipped throughout with an approved automatic sprinkler system installed in accordance with CFC Section 903.3.1.1, 903.3.1.2 or 903.3.1.3. The LAHFC, on the other hand, gives unfettered subjective authority to fire officials when an access road is located more than 150 feet away.

LAHFC 503.1 states that “In other than R-3 or U occupancies, when the building is equipped throughout with an approved automatic sprinkler system, installed in accordance with Section 903.3.1.1 the dimension may be increased to a maximum of 300 feet when approved by the fire code official.” This addition, which inserts an entirely subjective component to determine when the distance can be increased, and imposing this subjective requirement is in violation of the HAA.

Moreover, the project meets the objective fire apparatus access roads requirements. Specifically, the proposed access road is less than 300 feet away from the exterior of the building and the building is proposed to be equipped with an approved automatic sprinkler system throughout, installed in accordance with Section 903.3.1.1. Any reasonable person would conclude that a ITEM 2A ATTACHMENT 9

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fully-sprinklered project that includes an access road within 300 feet of the building meets the CFC and LAHFC 503.1 requirements, particularly since the HAA must be interpreted and implemented to “afford the fullest possible weight to the interest of, and the approval and provision of, housing. (Gov. Code § 65589.5(a)(2)(L).) Yet, SCCFD is still unlawfully withholding its approval based on the entirely subjective portion of LAHFC. Whether the Department utilizes the CFC version of 503.1, or the objective requirements LAHFC 503.1, the result is the same. The project must be approved as submitted because there is substantial evidence that would allow a reasonable person to conclude the project complies with 503.1’s requirements, and any ambiguity must be afforded for the approval of housing, not to its hinderance.

The Project is Only Subject to the Requirements in Effect When the Preliminary Application was Submitted.

Finally, we note that the SCCFD’s letter states that the building permit for this project will be reviewed against the fire/building codes in effect at the time of the building permit application.2 Although we understand that SFFCD believes that the Town will decide what codes to apply, please be advised that this project is only subject to the ordinances, policies, standards, and fees adopted and in effect on the date that the preliminary application for this project was submitted. (Gov. Code § 65589.5(o).) HCD has confirmed that these vesting rights apply to any entity that meets the definition of a “local agency” reviewing the project as part either the entitlement or post-entitlement permitting process.3
Thus, SCCFD is required to only review the project against the fire/building code in effect at the time the preliminary application for this project was submitted (i.e. February 1, 2023) regardless of the Town’s position.

Conclusion
Again, we appreciate the time SCCFD has taken to meet with us and consider our comments. We urge SCCFD to take a closer look at the project plans vis-à-vis the HAA’s legal requirements.

Mr. Linebarger takes fire safety very seriously, and has worked closely with fire officials to go above and beyond the code requirements to ensure that the project is safe for residents and fire personnel. The project meets all objective fire code requirements, and therefore Mr. Linebarger requests that SCCFD issue project approvals. I am available at (415) 907-9110 or at [email protected] if you would like to discuss this matter further. 2 We note that an earlier SCCFD letter did not contain this language, and this appears to be a new requirement that was not previously identified. 3
See HCD, SB 330 Preliminary Application Vesting Rights and Local Agencies – Letter of Technical Assistance, dated July 20, 2023, available at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/ranchocucamonga-ta-072023.pdf.

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Brian Glass, Assistant Fire Chief
June 4, 2024

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Very truly yours,
PATTERSON & O’NEILL, PC ____________________________________ Brian O’Neill ITEM 2A ATTACHMENT 9

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From: Suzanne Avila <[email protected]>
Date: Fri, May 24, 2024, 10:05 AM
Subject: 10728 & 10758 Mora Drive
To: Forrest Linebarger <[email protected]>
Cc: Bradley Evanson <[email protected]>, Peter Pirnejad <[email protected]>
Forrest,
I am circling back to your previous inquiry regarding the Town starting environmental review process under the California Environmental Quality Act (CEQA) for the 10728 and 10758 Mora Drive projects (CDP23-0001 and 002). Although the Town is preparing to solicit an environmental consultant to perform this work, the analysis cannot be started because there are outstanding Fire Department comments which could result in changes to the scope of the project. In the Town’s review of Fire Department comments dated January 31, 2024, it is staff's understanding that in order for the projects to address outstanding comments regarding aerial apparatus and building and facilities access, the development plans will likely need to be modified significantly. Significant modifications to the plans would likely result in substantial changes to the scope of the projects and thereby impact the Town’s ability as the lead agency to prepare a project description and scope of review as required by CEQA.

Additionally, the Town understands that you have submitted a request for Alternate Materials, Methods of Construction (AMMR) to the Santa Clara County Fire Department on March 21, 2024, and that request was rejected by the Fire Department on April 23, 2024. Staff is not aware of any resubmittals for the projects since then.

Thus, until there is certainty that the building footprints and building sizes can proceed as proposed and in compliance with Fire Department requirements, the Town is not able to commence environmental review. Please note that as the applicant, you would be responsible for providing a deposit and payment of fees for the environmental review prior to commencement of analysis and studies.

Additionally, I wanted to take this opportunity to remind you that all requests and applications for the projects must go through the Town as it is the ultimate reviewing body for the development applications. The Town was notified by the Fire Department ITEM 2A ATTACHMENT 9

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that you submitted the AMMR request, and you did not include the Town in your submittals. Failure to include the Town on project requests and submittals curtails Town staff's ability to timely review applications and provide comments. If you plan to submit another AMMR request or any additional application materials, please submit to the Town directly or concurrently include the Town on your submittals to the Fire Department.

If you have any questions I can be reached by email or phone.

Thank you,
Suzanne

SUZANNE AVILA, AICP
Principal Planner
she/her
408-340-5642 X-128 c 408-477-5820
a new design on urban planning
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Exhibit
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10728 & 10758 Mora Dr
Suzanne Avila
hours ago)
to me, Forrest, Jay, Jonathan
Forrest,
The Town intends to proceed with the public hearing tomorrow evening. You were apparently advised of the hearing date at the January 17 meeting with the Town Manager and City Attorney.

You can request a continuance at the meeting, which the Council can then decide whether or not to grant.

Suzanne

SUZANNE AVILA, AICP
Principal Planner
she/her
408-340-5642 X-128 c 408-477-5820
a new design on urban planning
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-1-

DECLARATION OF JAMES BEVAN
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28

PATTERSON
& O`NEILL, PC 235
MONTGOMERY STREET, SUITE 950 SA
N
F
RA

NCISCO, C
A
LIFO
RNIA 94104 DECLARATION OF JAMES BEVAN 10758 and 10728 Mora Drive I, James Bevan, declare as follows:

1. I make this declaration based on personal knowledge of the following facts, except to those matters stated on information and belief, and as to those matters, I believe them to be true. If called as a witness to testify, I could and would competently testify thereto.

2. I worked for Tower Investments LLC throughout 2023 through October 9, 2024.

During that time, I was involved in communications, preparations of plans, attachments and On or about October 9, 2024 I
am no longer employed at Tower Investments LLC

3. On April 18, 2023 I received the comment letter from the Santa Clara County Fire Dept. response from our February 1, 2023 submittal.

4. On April 20, 2023, I spoke with Kenny Ip via telephone for 35 minutes about the above comment letter. We discussed the exceptions to CFC 503.1.1 (item 5) and item 7. Mr. Ip told me the addition of NPFA 13 Fire Sprinklers per 903.3.1.1 would both extend the distance to and the distance from the fire hydrant around the building to 400 feet, resolving both issues.

My preparation notes for that meeting were written in pencil on the letter. A true and correct ITEM 9A, Supplement 31c
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DECLARATION OF JAMES BEVAN
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28

PATTERSON
& O`NEILL, PC 235
MONTGOMERY STREET, SUITE 950 SA
N
F
RA

NCISCO, C
A
LIFO
RNIA 94104
copy of my notes from the meeting with Mr. Ip is attached as Exhibit A. The notes in various color ink are later additions.

5. On May 8, 2023 I received a comment letter directly from the Fire Dept., dated April 25, 2023, from Caleb Flanagan for 10728 Mora Drive. This letter was the first response from the Fire Dept. we received on our Feb 1, 2023 submission.

6. On or about Tuesday May 2, 2023, I had a phone conversation with our plan reviewer, We discussed
how to respond to the Fire Departments April 25, 2023 comment letter that I had already spoken with Kenny Ip about similar issues. On Comment #4 Building and Facilities Access based on California Fire Code Sec 503.1.1, he told me to add a note stating that the fire sprinklers would comply with Sec. 903.3.1.1 (of the California Fire Code) to extend the 150 foot access exception to 300 feet. He told me this issue was not a big concern as they regularly resolved the 150-foot distance issue in Sec. 503.1.1 with this solution as permitted by code.

7. In the same meeting Mr. Flanagan and I discussed creating a Hydrant Spotting Plan where we would add an additional hydrant by 10758 Mora and show that fire hoses could make it around the both buildings and providing the length of hoses needed to reach around the structures. We also discussed submitting a Hydrant Spotting Plan and he could review it.

8. I used sheet A5.0, dated May 9, 2023, to address all the fire code comments. Per my I also included the Hydrant Spotting Plan and we submitted it directly to the Fire Dept., which approved the plan, Attached as Exhibit B, that showed how a hose could reach all exterior points of the building. We used the same sheet, A5.0 for both projects and it combined both lots with one fire turn-around on one sheet and included the solutions I had discussed with both reviewers for both projects. We included a comment letter with our response directly to the Fire Dept. which is attached as Exhibit C.

9. On July 3, 2023, we also submitted the same sheet A5.0, along with Fire Dept. responses, to the Town of Los Altos Hills along with the rest of our submittal sets for both projects.

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DECLARATION OF JAMES BEVAN
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28

PATTERSON
& O`NEILL, PC 235
MONTGOMERY STREET, SUITE 950 SA
N
F
RA

NCISCO, C
A
LIFO
RNIA 94104 10. On August 28, 2023 I received an email with the Fire Dept., response letters dated August 14, 2023 in response to our 10758 Mora Dr. application, 56 days after our submission on July 3, 2023. Attached as Exhibit D is a true and correct copy of the email where I received the responses.

11. On August 28, 2023 I received an email with the Fire Dept., response letters dated August 14, 2023 in response to our 10728 Mora Dr. application, 56 days after our submission on July 3, 2023. Attached as Exhibit E is a true and correct copy of the email where I received the responses.

12. Both Fire Department response letters dated August 24, 2023 had a number of additions and comment that were not included in the previous letters. The Code review standard in the with respect to the fire/building code
Dept. responses stated that review would be by the 2022 CFC codes as adopted by the Town of Los Altos Hills. This addition is not accurate for a Permit Streamlining Act application. Four comments were added that had not been included in previous response letters. The additional comments were # 18, #19, #20, & #21 on page 5 and which cited California Building Code sections rather than California Fire Code sections. True and correct copies of the August 14, 2023 comment letters from the Fire Dept. and the Comments are attached as Exhibit F & G.

13. The new CBC sections in the Fire Dept. letters attached as Exhibit D & E appeared to be carefully coordinated with an entirely new comment letter from the Town of Los Altos Hills titled
2023. A true and correct copy of which is Attached as Exhibit H.

14. Comment 18 from the Fire Dept. letters (Exabits F & G) correspond to bullet 1 on page 2 of the H) regarding stair separation CBC section 1027; comment 19 corresponds to bullet 5 page 2 regarding exit discharge 1CBC section 1028.5; Item 21 corresponds to bullet points 2 and 3 page 1 regarding exterior wall ratings. Neither of these review letters were necessary and they arrived in close proximity to each other. In my ITEM 2A ATTACHMENT 9

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Tower Investment LLC
Co/James Bevan
785 Castro St. Ste A.

Mountain View, CA 94041
May 9, 2023
RE: 10728 Mora Drive Response to Comment Letter dated April 25, 2023 SSCFD File # 23 1486
LAH File # CDP23-0001
Caleb Flanagan
Santa Clara County Fire Department
14700 Winchester Blvd.

Los Gatos, CA 95032
ITEM 2A ATTACHMENT 9

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From: James Bevan <[email protected]>
Sent: Wednesday, January 29, 2025 7:11 PM
To: Forrest Linebarger <[email protected]>
Subject: 10758 email chain with attached comment letter From: Caleb Flanagan <[email protected]>
Sent: Monday, August 28, 2023 2:39 PM
To: LAH Plan Check Comments <[email protected]> Cc: James Bevan <[email protected]>
Subject: Fwd: SCCFD Review - CDP23-0002 10758 Mora Dr PC 23-2595 Good afternoon,
The applicant informed me they have not received the comments for 10728 and 10758 Mora.

Please see attached.

Caleb Flanagan | Deputy Fire Marshal I
Fire Prevention Division
Santa Clara County Fire Department
[email protected] | 408-341-4441
From: [email protected]
To: "LAH Plan Check Comments" <[email protected]> Sent: Monday, August 14, 2023 12:27:09 PM
Subject: SCCFD Review - CDP23-0002 10758 Mora Dr PC 23-2595 Please see attached for subject review comments.

Respectfully,
Kenny Ip
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Deputy Fire Marshal I
Fire Prevention Division
Santa Clara County Fire Department
16795 Lark Ave | Los Gatos, CA 95030
tel: 408.341.4437 | fax: 408.378.9342 | [email protected] ITEM 2A ATTACHMENT 9

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Exhibit
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From: James Bevan <[email protected]>
Sent: Wednesday, January 29, 2025 7:10 PM
To: Forrest Linebarger <[email protected]>
Subject: 10728 email chain with attached comment letter From: Caleb Flanagan <[email protected]>
Sent: Monday, August 28, 2023 2:39 PM
To: LAH Plan Check Comments <[email protected]> Cc: James Bevan <[email protected]>
Subject: Fwd: SCCFD Review CDP23-0001 - 10728 Mora Dr - PC 23 2718 Good afternoon,
The applicant informed me they have not received the comments for 10728 and 10758 Mora.

Please see attached.

Caleb Flanagan | Deputy Fire Marshal I
Fire Prevention Division
Santa Clara County Fire Department
[email protected] | 408-341-4441
From: [email protected]
To: "LAH Plan Check Comments" <[email protected]> Sent: Monday, August 14, 2023 11:04:26 AM
Subject: SCCFD Review CDP23-0001 - 10728 Mora Dr - PC 23 2718 Please see attached for subject review comments.

ITEM 2A ATTACHMENT 9

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Caleb Flanagan | Deputy Fire Marshal I
Fire Prevention Division
Santa Clara County Fire Department
[email protected] | 408-341-4441
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Exhibit
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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 September 19, 2023
Preliminary Building Code Review of 10728 & 10758 Mora Dr.

This document is a Preliminary Building Code Review of the plans for the proposed projects at 10728 and 10758 Mora Dr in Los Altos Hills. This review is not intended to be a complete plan review, rather a review to identify significant code issues that may affective overall building design. The order of the code issues listed is in no particular order of importance and addressing one or more issues may well lead to code issues not currently shown.
10728 Mora Dr.

Code Assumptions based on information included on plans:
67,475 Sq Ft
Total Occupant Load per plans is 669
Construction Type
Podium Garage S-2 Type l-A Sprinklered
R-2, R-2.1, A-3 & B Type lll-A Sprinklered
Significant Code Issues
• CBC Section 202 defines a High-Rise structure as every building of any type of construction or occupancy having floors used for human occupancy located more than 75 feet above the lowest floor level having building access. Based on this definition this building is considered a high-rise building and shall comply with CBC sections 403.2 through 403.7. • Per CBC Table 601, the bearing walls of Type l-A buildings shall have a 3-hour Fire-Resistive Rating. Per CBC Table 705.5 the Fire-Resistance Rating for the exterior walls of a Type l-A building, with a Fire Separation Distance of less than 30 feet, shall be 1-hour rated. Therefore, the maximum area of exterior wall openings shall comply with CBC Table 705.8. • Per CBC Table 601, the exterior walls of Type lll-A buildings shall have a 1-hour Fire-Resistive Rating. Per CBC Table 705.5 the Fire-Resistance Rating for the exterior walls of a Type lll-A building, with a Fire Separation Distance of less than 30 feet shall be 1-hour rated. Therefore, the maximum area of exterior wall openings shall comply with CBC Table 705.8. • Per CBC Table 504.4, A-3 occupancies in buildings of Type lll-A construction may not be more than 4 stories above grade plane. The A-3 Occupancy is shown to be located on the 5th level above grade plane and therefore per CBC Table 504.4 is not allowed.

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Preliminary Building Code Review
10728 & 10758 Mora Dr.

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 • Per CBC Section 1027.5, Exterior exit stairways and ramps shall have a minimum fire-separation distance of 10 feet measured at right angles from the exterior edge of the stairway or ramps, including landings, to adjacent lot lines.
• Per CBC Section 1028.3, the minimum width or required capacity of the exit discharge shall not be less than the minimum width or required capacity of the exits being served. Based on occupant load of 669, the minimum exit discharge width would be 100”. (669/2 = 334.5 * 0.3 = 100”) exit discharge paths shown on plan are 48” on the north side of the and 36” on the south side of the building. The width of these exit discharge elements is insufficient to meet code. • Per CBC 1005.7.1 Doors, when fully opened, shall not reduce the required width of the exit discharge by more than 7 inches. Doors in any position shall not reduce the required width by more than one-half. Exit door from front stairwell and doors from trash enclosure reduce the required exit passageway width by more than 7”.
• Per CBC Section 1005.4, the minimum width or required capacity of the means of egress required from any story of a building shall not be reduced along the path of egress travel until arrival at the public way. The convergence of exit discharge paths at the front of the building in an area designated for emergency vehicles will restrict access to the public way, affecting both egress and emergency response.
• CBC 1028.5 requires the exit discharge shall provide a direct unobstructed access to the public way, when that cannot be provided, as per the inadequate exit discharge width above, a safe area of dispersal shall be provided where all of the following shall be met:

1. The area shall be of a size to accommodate not less than 5 square feet for each person.

2. For other than Group E buildings, the area shall be located on the same lot not less than 50 feet away from the building requiring egress. • Rear yard area shown does not show a code compliant area of safe dispersal as it is smaller than required to accommodate 5 sq. ft. per person and cannot be located 50’ from the building. 10758 Mora Dr.

Code Assumptions based on information included on plans:
71,034 Sq Ft
Total Occupant Load per plans is 666
Construction Type
Podium Garage S-2 Type l-A Sprinklered
R-2, R-2.1, A-3 & B Type lll-A Sprinklered
Significant Code Issues
• CBC Section 202 defines a High-Rise structure as every building of any type of construction or occupancy having floors used for human occupancy located more than 75 feet above the lowest floor level having building access. Based on this definition this building is considered a high-rise building and shall comply with CBC sections 403.2 through 403.7.

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Preliminary Building Code Review
10728 & 10758 Mora Dr.

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 • Per CBC Table 601, the bearing walls of Type l-A buildings shall have a 3-hour Fire-Resistive Rating. Per CBC Table 705.5 the Fire-Resistance Rating for the exterior walls of a Type l-A building, with a Fire Separation Distance of less than 30 feet, shall be 1-hour rated. Therefore, the maximum area of exterior wall openings shall comply with CBC Table 705.8. • Per CBC Table 601, the exterior walls of Type lll-A buildings shall have a 1-hour Fire-Resistive Rating. Per CBC Table 705.5 the Fire-Resistance Rating for the exterior walls of a Type lll-A building, with a Fire Separation Distance of less than 30 feet shall be 1-hour rated. Therefore, the maximum area of exterior wall openings shall comply with CBC Table 705.8. • Per CBC Table 504.4, A-3 occupancies in buildings of Type lll-A construction may not be more than 4 stories above grade plane. The A-3 Occupancy is shown to be located on the 5th level above grade plane and therefore per CBC Table 504.4 is not allowed. • Per CBC Section 1028.3, the minimum width or required capacity of the exit discharge shall not be less than the minimum width or required capacity of the exits being served. Based on occupant load of 666, the minimum exit discharge width would be 100”. (666/2 = 333 * 0.3 = 100”) exit discharge paths shown on plan are 48” on the north side of the and 36” on the south side of the building. The width of these exit discharge elements is insufficient to meet code. • Per CBC 1005.7.1 Doors, when fully opened, shall not reduce the required width by more than 7 inches. Doors in any position shall not reduce the required width by more than one-half. Exit door from front stairwell and doors from trash enclosure reduce the required exit passageway width by more than 7”.
• Per CBC Section 1005.4, the minimum width or required capacity of the means of egress required from any story of a building shall not be reduced along the path of egress travel until arrival at the public way. The convergence of exit discharge paths at the front of the building in an area designated for emergency vehicles will restrict access to the public way, affecting both egress and emergency response.
• CBC 1028.5 requires the exit discharge shall provide a direct unobstructed access to the public way, when that cannot be provided, as per the inadequate exit discharge width above, a safe area of dispersal shall be provided where all of the following shall be met:

1. The area shall be of a size to accommodate not less than 5 square feet for each person.

2. For other than Group E buildings, the area shall be located on the same lot not less than 50 feet away from the building requiring egress. • Rear yard area shown does not show a code compliant area of safe dispersal as it is smaller than required to accommodate 5 sq. ft. per person and cannot be located 50’ from the building.

Gregory J McFann
Interim Building Official
Town of Los Alto Hills
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Exhibit
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-----Original Message-----
From: james bevan <[email protected]>
Sent: Monday, January 27, 2025 3:22 PM
To: Forrest Linebarger <[email protected]>
Subject: Fwd: Alternative Means And Methods Request (PR# 23 1147) for project at 10728 Mora Drive, Los Altos Hills (PR# 23 4780)
---------- Forwarded message ---------
From: Matthew McKenna <[email protected]>
Date: Mon, Apr 29, 2024 at 1:35 PM
Subject: Re: Alternative Means And Methods Request (PR# 23 1147) for project at 10728 Mora Drive, Los Altos Hills (PR# 23 4780)
To: james bevan <[email protected]>
Cc: <[email protected]>
Good Afternoon James,
Thank you for the email. I appreciate the chance to clear up what appears to be a bit of confusion. I did not say that I did not see any proposed mitigation measures that I felt would be satisfactory for the project to move forward. I said your current proposal did not appear to provide satisfactory mitigation, which is why the plan review comments asked for additional clarification.

I will work with our staff to find a meeting time that works for everyone, and follow up with additional information.

However, we will not be able to make you proposed time for next week work.

Respectfully,
Matthew L. McKenna | Senior Deputy Fire Marshal
Fire Prevention Division
Santa Clara County Fire Department
[email protected] | (408) 341-4420
----- Original Message -----
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From: "james bevan" <[email protected]>
To: "matthew mckenna" <[email protected]>
Cc: [email protected]
Sent: Friday, April 26, 2024 6:46:07 PM
Subject: Alternative Means And Methods Request (PR# 23 1147) for project at 10728 Mora Drive, Los Altos Hills (PR# 23 4780)
Mathew,
It was good speaking with you yesterday about our Alternative Means and Methods request for the project at 10728 Mora Drive in Los Altos Hills. I was disappointed to hear that you did not see any proposed mitigation measures that you felt would be satisfactory for the project to move forward.

We would like to set up an in-person meeting to find a solution. Here are a couple of times that could work on our end:

Monday May 6th at 1:00pm
Tuesday May 7th at 11:00am
If either of these times work for you please let us know, otherwise suggest a time that works better for you.

We will have our legal counsel present at the meeting and thought it best if you could have both senior management and SCCFD's outside legal counsel in attendance as well.

We want to work with you to find a solution and feel that having all parties involved in the decision present at the meeting offers the best pathway toward that solution.

James Bevan
(805)405-5654
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☐ Application / Response(s) to Comments
☐ Accessibility Exemption Form (Commercial)
☐ Arborist Report
☐ Bay Area Air Quality Management J#
☐ CalGreen Checklist
☐ COP (Construction Operation Plan)
☐ Electrical Load Calculations
☐ Energy Code documents (ex: CF1R)
☐ Manufacturer’s Specifications
☐ PCB’s Demo Program Screening
Assessment
☐ Photos of road & path prior to construction
☐ SCC Environmental Health Department
permit and/or approved stamped site plan
☐ Soils/Geotechnical Report
☐ Special Inspection Form
☐ Structural Calculations
☐ Truss Calculations
☐ Truss Diagrams
☐ Utility Shut-Off Letter
☐ Waste Management Plan

TOWN OF LOS ALTOS HILLS
26370 Fremont Road
Los Altos Hills, CA 94022
Phone: (650) 941-7222
Email: [email protected]
www.losaltoshills.ca.gov
Supplemental Documents Index
Project Information
For initial submittals, include this index after the application. For all resubmittals, include this index at the beginning of the SUP document PDF.

Permit No: __________________________________ File Name: _________________________________ APN: _______________________________________ Date Submitted:_____________________________ Project Address: __________________________________________________________________________ Legal Owner:______________________________________________________________________________ Applicant:_________________________________________________________________________________ Scope of Work: ______________________________________________________________________ Notes: Each time the SUP file is uploaded, the PDF must be complete and include all documents required for permit issuance. Keep all documents in the SUP file in the same order each time.

Supplemental Documents Checkmark all items included in SUP file Additional Documents Please list additional items below

1. _____________________________________

2. _____________________________________

3. _____________________________________

4. _____________________________________

5. ___________________________________

6. ___________________________________

7. ___________________________________

8. ___________________________________
____________________________________________________________________________________________ ____________________________________________________________________________________________ CDP23-0002 CDP23-0002_V7_SUP
APN 331-15-062 February 25, 2025
10758 Mora Drive, Los Altos Hills, CA
Forrest Linebarger
Tower Investments LLC
Supplimental Response to Builder's Remedy Project including Class 32 CEQA Exemption Memo ✔
Feb. 20, 2025 Project Drawing Set
Exhibit 1 Applicant Letter
Exhibit 2 Attorney Letter
Exhibit 3 Class 32 CEQA Exemption
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Exhibit 1

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WŽƌƚŽůĂsĂůůĞLJ͕ϵϰϬϮϴ
February 25, 2025
Supplemental Submission
Senior Housing Builders Remedy
10758 Mora Drive, Los Altos Hills
File CDP23-0002
Susanne Avila, Consultant Principal Planner
Planning Department
26379 Fremont Road
Los Altos Hills, CA 94022
Ms. Avila,
As you are aware, we submitted a revised builders remedy application to meet the requirements of AB 1893 (2024) on January 30, 2025. We had been working on that submission for about two months but were surprised that staff had scheduled our project for denial at the January 30, 2025 City Council Meeting. We had very little notice of that event and Town staff gave no indication that a denial action would be imminent after refusing to take any action on our application for over a year. Since the Town denied our request to delay the hearing, we were forced to submit the revised plans without all the pieces we intended to provide before the January 30 hearing date. We are now supplementing the previous submittal with additional documents and a revised drawing set.

Despite our numerous requests, the Town refused to complete an Initial Study to determine the necessary level of CEQA review for over a year in violation of state law. This is a substantial revision of the project, with a 25% reduction in density, the addition of the Density Bonus Law, modifications to fire, occupancy, utilities, and enactment of AB 1893 are substantial revisions that will require the Town to make a new CEQA determination. We have provided substantial evidence that the project qualifies for a Class 32 Infill Exemption under CEQA.

This submission is a revision as permitted by AB 1893. (Gov. Code § 65589.5(f)(7)(B). The revision is not a new application, and fees and other components carry forward from our February 1, 2023 original builders remedy application. The Geotechnical, Grading and C.3 components on the project have not changed.

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Ϯ
ATTACHMENTS:

Exhibit 1 Plan Revision dated February 20, 2025 on cover sheet Exhibit 2 AB 1633 Notice of Abuse of Discretion from our Attorneys, Patterson & O’Neill, PC.

Exhibit 3 Class 32 CEQA Exemption Memo by RCH Group and Sicular Environmental Consulting
Thank you for your consideration,
Forrest Linebarger,
Applicant and owner
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Exhibit 2

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PATTERSON & O’NEILL, PC
235 Montgomery Street, Suite 950
San Francisco, CA 94104
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
February 24, 2025
VIA E-MAIL AND U.S. MAIL
Suzanne Avila
Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
Re: 10758 Mora Drive (File No. CDP23-0002) Housing Development Application 90-Day Notice Pursuant to AB 1633 (Gov. Code § 65589.5(h)(6)(E)(vi)(I)) Dear Ms. Avila:

Our office represents Forrest Linebarger, owner of 10758 Mora Drive in Los Altos Hills. Our client submitted a housing development project application for the construction of a multi-unit housing development project on 10758 Mora Drive. The proposed project is a 45-unit, 72,848 square-foot multifamily residential development with a parking garage. The proposed building height to finish grade would be 59 feet 7 inches on the west elevation facing Mora Drive, and 80 feet 1 inch on the east elevation. The garage would provide 27 total spaces and 7 long-term bicycle spaces. The proposed building would include a variety of accessory uses including roof decks, a covered terrace, activity rooms, gift shop, and nursing station. The site is currently vacant.1
Pursuant to AB 1633, PLEASE TAKE NOTICE that the Town has committed an abuse of discretion because there is substantial evidence in the record to demonstrate that the project qualifies for a Class 32 in-fill development exemption, but the City has failed to determine that the project is exempt from CEQA. The City has 90 days of this written notice to correct this abuse of discretion and if the City fails to do so, this action will constitute an unlawful disapproval of the project pursuant to the Housing Accountability Act (“HAA”). (Gov. Code § 65589.5.1(a).)2
1 This paragraph provides the information specified in paragraphs (1), (2), (5), and (6) of subdivision (a) of Section 15062 of Title 14 of the California Code of Regulations. 2 Please be advised that the Town must post this notice on the Town’s website, provide a copy of the notice to any person who has made a written request for notices pursuant to subdivision (f) of Section 21167 of the Public Resources Code, and file the notice with the county clerk within five working days of receiving this notice.

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Suzanne Avila
Town of Los Altos Hills
February 24, 2025

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The Project Site is Located in an Area that is Subject to AB 1633 As demonstrated by the attached memorandum by RCH Group and Sicular Environmental Consulting, there is substantial evidence that the housing development project is not located on a site specified in subparagraphs (A) to (C) or subparagraphs (E) to (K) of paragraph (6) of subdivision (a) of Section 65913.4. Specifically, the property is not located within the coastal zone; is not prime farmland or farmland of statewide significance; is not wetlands; is not a hazardous waste site; is not within a delineated earthquake fault zone; is not within a special flood hazard area or regulatory floodway; is not within a land identified for conservation in an adopted natural community conservation plan; is not habitat for protected species, and is not under a conservation easement. In addition, the project site is not within a very high fire severity zone.

As such, there is substantial evidence that the housing development project is located on a site that is subject to AB 1633. (See Gov. Code § 65589.5.1(a)(1).)

The Project Site is Located in an Urbanized Area that is Subject to AB 1633 The housing development project is located on a legal parcel within an urbanized area as defined by Public Resources Code § 21071. Specifically, Los Altos Hills is an incorporated city that is contiguous with not more than two incorporated cities (Palo Alto and Los Altos), that have a combined population that exceeds at least 100,000 persons. (See PRC § 21071(a)(2).3 3 According to most recent data from the U.S. Census Bureau, the population of Palo Alto is 68,572
(https://data.census.gov/profile?q=population%20palo%20alto&g=160XX00US0640998), the population of Los Altos is 31,625 (https://data.census.gov/all?q=los%20altos%20population), and the population of Los Altos Hills is 8,489
(https://data.census.gov/all?q=los%20altos%20hills%20population) for a total population of 108,686 persons.

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Suzanne Avila
Town of Los Altos Hills
February 24, 2025

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In addition, parcels that are developed with urban uses adjoin three sides of the four-sided parcel.

Specifically, the parcels to the north, east, and west sides of the four-sided project site are developed with residential uses, which meet the definition of a qualified urban use pursuant to Pub. Resources Code § 21072.

As such, the project site is located within an urbanized area that is subject to AB 1633. (See Gov.

Code § 65589.5.1(a)(2).)
The Project Meets the Minimum Density to Qualify for AB 1633 The density of the housing development project exceeds 15 dwelling units per acre. Specifically, the project site is approximately .77 acres in size and proposes 88 units, a density of approximately 114 units per acre. As such, the Project meets the minimum density to qualify for AB 1633. (See Gov. Code § 65589.5.1(a)(3).)
The Project Meets the Criteria for a CEQA Class 32 Exemption Where a project is categorically exempt, the project is not subject to CEQA requirements and “may be implemented without any CEQA compliance whatsoever.” (Working Fams. of Monterey Cnty. v. King City Plan. Comm’n (2024) 106 Cal. App. 5th 833.) Thus, if a project fits within an exemption, a local agency is required to find that the project is exempt from CEQA regardless of any purported environmental impact because such projects are those that the Governor’s Office of Planning and Research and the Secretary of the Natural Resources Agency “have already determined do not, in fact, ‘have a significant effect on the environment.’” (Berkeley Hillside Pres. v. City of Berkeley (2015) 60 Cal. 4th 1086, 1108.) This exemption ITEM 2A ATTACHMENT 9

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Suzanne Avila
Town of Los Altos Hills
February 24, 2025

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process carries out the Legislature’s intent that CEQA and the CEQA Guidelines shall not be interpreted “in a manner which imposes procedural or substantive requirements beyond those explicitly stated.” (Pub. Res. Code § 21083.1.)
AB 1633 was enacted to address the fact that “[s]ome local agencies conduct redundant environmental review to avoid CEQA lawsuits from neighbors or interest groups at best, or to delay a project indefinitely in the hopes of shrinking or killing it at worst.” To that end, AB 1633 added provisions to the HAA that broaden the scope of a housing project “disapproval” to include instances where a local government requires more environmental review than legally necessary and provides applicants with a legal process to challenge such actions in court. (Gov.

Code § 65589.5.1.)
In enacting AB 1633, the Legislature recognized that the “HAA and CEQA take different approaches to housing development. The intersection of these two Acts therefore can result in gray areas or conflict.” The purpose of AB 1633 was to clarify this gray area and put a thumb on the scale in favor of housing by requiring a local government to end environmental review and adopt certain CEQA documents when housing projects are involved.

AB 1633 does more than simply reiterate how CEQA applies to housing projects; it adds an entirely new framework for judicial review of a local government’s CEQA decisions in the specific context of housing. Courts have recognized that when the Legislature enacts an amendment to clarify how two parts of state law interact, such as the interplay between the HAA and CEQA, “it is logical to regard the amendment as a legislative interpretation of the original act — a formal change.” (Carter v. Department of Veterans Affairs (2006) 38 Cal.4th 914, 923.) The Legislature recognized that the HAA “generally puts the burden of proof on the local agency to demonstrate that its decisions meet the HAA’s requirements.” The Legislature has also made clear that if there is any ambiguity in the law, the HAA must “be interpreted and implemented in a manner to afford the fullest possible weight to the interest of, and the approval and provision of, housing.” (Gov. Code § 65589.5(a)(2)(L).) Thus, in any decision a local government makes involving housing — now including CEQA decisions — the Legislature has directed local governments to err on the side of approving housing or run the risk of severe penalties. (See Gov. Code § 65589.5(k)(1)(A)-(B).) And importantly, courts have confirmed that decisions under the HAA are different, and therefore “it is inappropriate” for courts to defer to local agency decisions. (Cal. Renters Legal Advocacy & Educ. Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 844 (Cal. Ct. App. 2021)
The Legislature has made clear that any failure to find a qualifying project exempt is an abuse of discretion and constitutes a project disapproval. (Gov. Code § 65589.5.1(a).) AB 1633 states that it is an abuse of discretion if there is “substantial evidence in the record before the local agency that the housing development project is eligible for an exemption sought by the applicant.” (Gov.

Code § 65589.5.1(a)(4)(A).) Substantial evidence is defined as “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a ITEM 2A ATTACHMENT 9

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Suzanne Avila
Town of Los Altos Hills
February 24, 2025

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conclusion, even though other conclusions might also be reached.” (Cal. Code Regs. tit. 14 § 15384.)
Thus, in the context of AB 1633, the only question is whether there is enough relevant information that a fair argument can be made that this Project qualifies for a Class-32 Exemption regardless of whether there is contrary evidence that a project does not so qualify. (See Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.) Nor is the question whether substantial evidence supports whatever conclusion the Town decides to make. The Town has enough relevant information to make a fair argument that the Project qualifies for a Class-32 Exemption and therefore must do so.

The Legislature has limited the protections of AB 1633 to those projects that meet the site criteria of Gov Code § 65913.4 (“SB 35”) – which the Legislature has already determined should be entirely exempt from CEQA. The Legislature has therefore created a higher bar to subject qualifying housing projects to more in-depth CEQA review, including because the Legislature has also recognized the housing crisis “is a critical problem” that “threatens the economic, environmental, and social quality of life in California.” (Gov. Code § 65589.5 (a)(1)(A).) The housing crisis is “hurting millions of Californians, robbing future generations of the chance to call California home, stifling economic opportunities for workers and businesses, worsening poverty and homelessness, and undermining the state’s environmental and climate objectives.” (Gov. Code § 65589.5(a)(2)(A). The Legislature has recognized that the environmental cost of not approving housing, particularly high density housing in areas that meet SB 35’s environmental criteria, clearly outweighs any purported impact from approving housing.

There can be no question that the applicant has provided enough relevant information that a fair argument can be made that the project qualifies for a Class 32 In-fill Exemption. In the extensive memorandum prepared by RCH Group and Sicular Environmental Consulting, who together have more than 50 years of CEQA compliance experience, the evidence demonstrates that the project meets the five criteria for a Class 32 Exemption.

Moreover, this project now qualifies as a “builder’s remedy” project pursuant to the recently enacted AB 1893 that went into effect January 1, 2025. The explicit purpose of AB 1893 was to “moderniz[e] the builder’s remedy to make it clear, objective, and easily usable.” The bill analysis states that the Legislature’s “message to local jurisdictions is clear — when it comes to housing policy, the days of shirking your responsibility to your neighbors are over.” In short, AB 1893 was intended to ensure that builder’s remedy projects will be constructed. Were there any doubt that a builder’s remedy project can qualify for a Class 32 Exemption, that doubt was laid to rest when the California Department of Housing and Community Development stated emphatically that a builder’s remedy project does qualify for a Class 33 Exemption. (See Exhibit A)
The HAA now explicitly allows an applicant for a housing development project deemed complete before January 1, 2025 to revise their application so that the project meets the new ITEM 2A ATTACHMENT 9

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Suzanne Avila
Town of Los Altos Hills
February 24, 2025

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definition a builder’s remedy project. (Gov. Code § 65589.5(f)(7).) The applicant has chosen to utilize this provision and has submitted revisions to the existing application to qualify as a builder’s remedy project as defined in HAA subd. (h)(11).

The Town had previously indicated that the previous higher-density version of this project did not qualify for an exemption. The Town made this conclusory statement without any analysis, or any evidence, at all. Despite multiple requests by the applicant to begin CEQA review, the Town simply refused to take any steps to begin the CEQA process for over 12 months, arguing that the scope of the project could change based on erroneous interpretations by the Los Altos Hills County Fire District regarding site access. Now the scope of the project has substantially changed due to the revisions the applicant has made to qualify as a builder’s remedy project. The Town’s prior statements do not preclude a later determination that the project is eligible for an exemption following the submission of supplemental environmental information. (Hilltop Grp. v.

Cnty. of San Diego (2024) 318 Cal. Rptr. 3d 336.)
The Class 32 Exemption is Not Barred by an Exception
For projects that seek a Categorical Exemption, a project must also demonstrate that there is “substantial evidence in the record before the local agency that the application of that categorical exemption is not barred by one of the exceptions set forth in Section 15300.2 of those guidelines.” (Gov. Code § 65589.5.1.(a)(5)(B).) Again, in the context of AB 1633, the question is not whether there is contrary evidence, nor is the question whether there is substantial evidence to support whatever conclusion an agency’s conclusion. The only question is whether there is substantial evidence that the project is not barred by an exception. The answer to that question is clearly yes.

As explained in the CEQA memorandum, there are no scenic resources, hazardous waste sites, or historical resources in the vicinity of the project. The surrounding area is nearly fully developed or designated as open space, so there is no potential for cumulative impacts of successive projects of the same type in the same place. Further, there is nothing unusual about the project site that meets all of the site criteria in SB 35, nor is there anything unusual about a project that meets the statutory definition of a builder’s remedy project. The project is similar in scope to other Class 32 exempt projects, and the Town routinely exempts residential development on sites with similar characteristics. In short, there is substantial evidence that the project is not barred by one of the exemption exceptions.

The Project Must Be Approved
As thoroughly explained in our January 30, 2025 letter to the City Council and prior correspondence, the builder’s remedy significantly limits the Town’s ability to disapprove this project. AB 1893 only strengthens the Legislature’s clear intent that local governments must approve builder’s remedy projects.

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Suzanne Avila
Town of Los Altos Hills
February 24, 2025

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Town staff previously erroneously recommended disapproval of the project based on purported public health and safety impacts due to inconsistency with Section 503 of the California Fire Code. As explained below, Section 503 is not an adopted part of the California Fire Code.

Moreover, the local fire code has not been properly adopted, is not in effect, and therefore cannot be used as a basis to disapprove the project.

Section 503 Was Not Adopted as Part of the California Fire Code The State Fire Marshal establishes fire safety rules and regulations for buildings, also known as the California Fire Code, which are published in Part 9 of the California Building Standards Code (Cal. Code Regs., Title 24). The California Fire Code is based off the International Fire Code, a model code that is published triennially by the International Code Council (“ICC”).

Every three years, the State Fire Marshal reviews the International Fire Code and adopts amendments to the ICC’s model code, which then becomes that California Fire Code. In addition, the State Fire Marshal also adopts minimum standards for the general prevention of fire and the protection of life and property against fire, explosion, and panic that is published in Title 19 of the California Code of Regulations.

The California Fire Code is only published by the ICC. The ICC chooses to print the California Fire Code embedded within its own “model code.” In other words, the California Fire Code is not available as a separate stand-alone document. The ICC publishes its International Fire Code with various notations to explain the amendments to model code that were adopted by the State Fire Marshal. Each chapter begins with a “matrix adoption table” that shows users which sections of the model code have been adopted, repealed, amended or added. California amendments to the model code are shown in italics throughout the published document.

Chapter 5 of the California Fire Code provides requirements for buildings and occupancies regarding access roads, building openings, roof, water supply, equipment, and other fire service features. The State Fire Marshal has adopted all sections of Chapter 5, with the exception of Sections 503 and 510.3, as shown is the Chapter 5 matrix adoption attached as Exhibit B.

Section 503 addresses Fire Apparatus Access Roads.

The State Fire Marshal has not adopted this section and instead relies on the requirements for fire department access and egress in Section 3.05(a) of Title 19. This section states:

Roads. Required access roads from every building to a public street shall be all-weather hard-surfaced (suitable for use by fire apparatus) right-of-way not less than 20 feet in width. Such right-of-way shall be unobstructed and maintained only as access to the public street.

EXCEPTION: The enforcing agency may waive or modify this requirement if in his opinion such all-weather hard-surfaced condition is not necessary in the interest of public safety and welfare.

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Suzanne Avila
Town of Los Altos Hills
February 24, 2025

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In short, Section 503 of the ICC model code is not a part of the California Fire Code and the Town’s attempt to disapprove the project on this basis was erroneous The Local Fire Code is Not in Effect
Each fire protection district is provided with the authority to adopt building standards relating to fire and panic safety, so long as the standards are more stringent than those building standards adopted by the State Fire Marshal and contained in the California Building Standards Code.

Health and Safety Code Section 13869.7 provides a process wherein a fire protection district may recommend amendments to the California Fire Code to a city or county, and the city or county may ratify, modify, or deny the amendments proposed by a fire district. Any amendments proposed by a fire district are not effective within a particular jurisdiction unless ratified by the city or county.

In addition, Health and Safety Code Section 13869.7 states that when local amendments to the California Fire Code are adopted, a city or county “shall file a copy of the findings of the district, and any findings of the city, county, or city and county, together with the adopted ordinance expressly marked and identified to which each finding refers, with the Department of Housing and Community Development.” The Department of Housing and Community Development has made clear through administrative guidance, attached as Exhibit C, that local amendments to the California Fire Code are not effective until the amendments are filed with the Department as required by state law.

During the last California Fire Code update in 2022, the Santa Clara County Fire Department (“SCCFD”) recommended local amendments to the Town of Los Altos Hills pursuant to its authority under Health and Safety Code Section 13869.7, ss explained in the Town’s staff report attached as Exhibit D. After SCCFD and the Town agreed on modifications to the local amendments, the Town took an action to adopt local amendments to the California Fire Code.

The local amendments included adoption of Section 503 of the International Fire Code, with further amendments.

However, after further research, the Town has not taken the steps necessary to make the local amendments to the California Fire Code effective. Specifically, the Town has not filed the amendments with the Department of Housing and Community Development. It appears that the Town attempted to file the amendments with the Building Standards Commission in December 2022. In a letter dated April 5, 2023, attached as Exhibit E, the Building Standards Commission specifically informed the Town that fire protection district ordinances must be filed with the Department of Housing and Community Development rather than the Commission.

In response to a Public Records Act request, attached as Exhibit F, the Department of Housing and Community Development states that it has no records showing that the Town has filed its local amendments to the California Fire Code with the Department. As a result, the Town’s Local Fire Code is still not in effective within the jurisdiction. The only fire safety standards that ITEM 2A ATTACHMENT 9

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☐ Application / Response(s) to Comments
☐ Accessibility Exemption Form (Commercial)
☐ Arborist Report
☐ Bay Area Air Quality Management J#
☐ CalGreen Checklist
☐ COP (Construction Operation Plan)
☐ Electrical Load Calculations
☐ Energy Code documents (ex: CF1R)
☐ Manufacturer’s Specifications
☐ PCB’s Demo Program Screening
Assessment
☐ Photos of road & path prior to construction
☐ SCC Environmental Health Department
permit and/or approved stamped site plan
☐ Soils/Geotechnical Report
☐ Special Inspection Form
☐ Structural Calculations
☐ Truss Calculations
☐ Truss Diagrams
☐ Utility Shut-Off Letter
☐ Waste Management Plan

TOWN OF LOS ALTOS HILLS
26370 Fremont Road
Los Altos Hills, CA 94022
Phone: (650) 941-7222
Email: [email protected]
www.losaltoshills.ca.gov
Supplemental Documents Index
Project Information
For initial submittals, include this index after the application. For all resubmittals, include this index at the beginning of the SUP document PDF.

Permit No: __________________________________ File Name: _________________________________ APN: _______________________________________ Date Submitted:_____________________________ Project Address: __________________________________________________________________________ Legal Owner:______________________________________________________________________________ Applicant:_________________________________________________________________________________ Scope of Work: ______________________________________________________________________ Notes: Each time the SUP file is uploaded, the PDF must be complete and include all documents required for permit issuance. Keep all documents in the SUP file in the same order each time.

Supplemental Documents Checkmark all items included in SUP file Additional Documents Please list additional items below

1. _____________________________________

2. _____________________________________

3. _____________________________________

4. _____________________________________

5. ___________________________________

6. ___________________________________

7. ___________________________________

8. ___________________________________
____________________________________________________________________________________________ ____________________________________________________________________________________________ CDP23-0002 CDP23-0002_V8_SUP
APN 331-15-062 May 29, 2025
10758 Mora Drive, Los Altos Hills, CA
Forrest Linebarger
Tower Investments LLC
Response to Comments for Builder's Remedy Project
✔
May. 29, 2025 Project Drawing Set
ATT 0 Response Letter
ATT 1 Attorney Letter
ATT 2 RCH Group CEQA Response
ATT 3 Building Department Respons
ATT 4 Revisions to Plans
ATT 5 Fire Department AMMR Appr
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1 Tower Investments LLC
Forrest Linebarger
151 Cervantes Rd.

Portola Valley, CA 94028
May 29, 2025
Response to February 28, 2025 & March 27, 2025 Comment Letters Multifamily Residential Development Project
10758 Mora Drive, Los Altos Hills
File CDP23-0002
Susanne Avila, Consultant Principal Planner
Planning Department
26379 Fremont Road
Los Altos Hills, CA 94022
Ms. Avila,
Thank you for your comments. The following are responses to The Town of Los Altos Hills’ Comment Letters dated February 28, 2025 & March 27, 2025. Your February 28, 2025 comment letter responded to both of our January 30, 2025 submission and our February 25, 2025 submission.

Please note the following changes: 1) The project is no longer utilizing Density Bonus Law, Gov.

Code Sec 65915. 2) Per Gov. Code Sec. 65589.5(f)7)(A), a development proponent with an application that was deemed complete before January 1, 2025 may choose to be subject to “any or all” of the provisions of AB 1893. The original housing development project application was deemed complete before January 1, 2025. As the development proponent for the project, we choose to be subject to the provisions applicable as of January 1, 2025, except for the provision Gov. Code Sec. 65589.5(f)(6)(G)(ii). 3) The R-2.1 occupancy for assisted living has been removed. 4) A list of revisions to the plans that are not related to the comments provided herein has been provided for your convenience as Attachment # 4. We have done our best to identify all notable revisions between the last submittal and this one, but the list may not be all-inclusive. We have also included some that were also discussed in the response letters where the response seemed only partially or tangentially related to the change to make sure the changes are transparent to the reviewers.

RESPONSE TO TOWN’S FEBRUARY 28, 2025 COMMENT LETTER
The numbering sequence below aligns with the sequence of your comment letter for clarity and convenience.

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2 PLANNING COMMENTS

1. Unit sizes are shown on the units themselves on sheets A1.1 and A1.2

2. The measurements you reference on Section A-A of sheet A3.1 and the Elevations on sheet A2.1 have been adjusted so they are now taken from the same absolute location, so they are now consistent with each other. A CBC grade plane has been added to provide a consistent absolute location.

3. Exterior building colors have been modified and light reflectivity values added. The proposed exterior color sample C has been show with an LVR or 40 or lower, see sheet A2.1 and A2.2.

4. The error in the calculation on sheet CO has been corrected. The total number of units has been reduced.

BUILDING COMMENTS
No comments provided.

FIRE DEPARTMENT COMMENTS
No comments provided.

ENVIRONMENTAL REVIEW
We disagree with your comment that the memorandum provided by RCH Group and Sicular Environmental Consulting (RCH) did not provide substantial evidence of an a CEQA class 32 Exemption. Nonetheless, in response to your comment, RCH has provided a separate response to your comment provided as Attachment #2. Please note that this response is supplementary in nature and does not alter the conclusions of RCH Exemption Memo.

RESPONSE TO MARCH 27, 2025 COMMENT LETTER

PLANNING COMMENTS
The four numbered planning comments provided in this letter are identical to the comments provided in your February 28, 2025 letter, so have been addressed above in that section.

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3 BUILDING COMMENTS by CGS CONSULTANTS
Please see Attachment #3 for the individual comments to CSG Consultants March 24, 2025 letter.

FIRE DEPARTMENT PLAN REVIEW COMMENTS DATED 03/25/25
Sheet A5.0 includes the Supplementary Fire Protection Measure #1 that states that the building has been provided with fire sprinklers per sec 901.3.1.1. It meets the requirements of CFC 503.1.1 exception 1.1. Moreover, CFC 503 was not adopted by the State Fire Marshal, so this item does not apply. Lastly, Los Altos Hills’ fire code modifications were not legally adopted per Health and Safety Code sec. 13869.7 and this project is a Builder’s Remedy project and for both reasons the local CFC amendments to the Fire Code do not apply to this project. The applicability of CFC 503.1.1 has been exhaustively addressed in our attorney’s letter to Los Altos Hills City Council dated January 30, 2025, which was also sent to the Santa Clara County Central Fire District (SCCFD).

A Public Records Act request made to the SCCFD found that both projects that addressed the CFC 503.1.1 through an AMMR process by utilizing a standpipe at the rear of the building were APPROVED by the SCCFD. Comment from the SCCFD approval letters requested that the standpipes be “wet manual standpipe per NFPA-14 and SCCFD standards.” The proposed project includes provision for TWO standpipes at the rear each of the buildings as shown on Sheets A5.0, A2.1 & A2.2 as Supplementary Fire Protection Measure #3. We have modified the language of the notes to add “wet manual standpipe per NFPA-14 and SCCFD standards.”
ATTACHMENTS:

In addition to the revised plan set and this letter, we have provided the following attachements.

1. Attorney Letter from Patterson &
O’Neill, PC, dated March 29, 2028

2. Additional Response from RCH
Group, dated March 29, 2025

3. Response to CSG Building
Department Comments dated
March 29, 2025

4. Revisions to Plans

5. Fire Department AMMR
Approvals on CFC 503.1.1
In addition to the above attachments, revised plans- dated March 29, 2025 on sheet CO- have been provided to the Town.

Per your letter this response may be submitted on the Town’s Portal or in person at Town Hall, or in the event of technical problems with the Town’s portal, they can be emailed to [email protected]. We were unable to schedule a meeting with the Town’s Jay ITEM 2A ATTACHMENT 9

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4 Bradford to resolve the technical issues with our access to the Towns’ Portal, so have sent the this submittal to [email protected]. We have also included a dropbox link in a separate email in case the file is too large.

Thank you for your consideration,
Forrest Linebarger,
For Tower Investments LLC
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PATTERSON & O’NEILL, PC
235 Montgomery Street, Suite 950
San Francisco, CA 94104
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
May 29, 2025
VIA E-MAIL AND U.S. MAIL
Suzanne Avila
Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
Re: 10728 Mora Drive and 10758 Mora Drive (File Nos. CDP23-0001, -0002) Builder’s Remedy Housing Development Applications
Dear Ms. Avila:

As you are aware, on January 30, 2025, our client resubmitted applications with revisions to the housing development projects proposed at 10728 Mora Drive and 10758 Mora Drive to meet the new definition a “builder’s remedy” project pursuant to the Housing Accountability Act (“HAA”). (Gov. Code § 65589.5(f)(7).) In addition, on February 25, 2025, our client also submitted a memorandum detailing why the projects qualify for a California Environmental Quality Act (“CEQA”) Class 32 In-fill exemption and a 90-Day Notice pursuant to AB 1633 explaining that the Town’s refusal to issue a CEQA exemption would constitute an abuse of discretion. (Gov. Code § 65589.5.1.)
As explained below, the project applications are complete and the project’s must be found consistent with all applicable standards. The applicant has chosen to voluntarily address some of the items contained in the City’s February 28, 2025 comment letter, and make additional adjustments to the project plans, but does so voluntarily without waiving his rights.

The Resubmitted Applications are Complete
The Town sent a letter in response to the submittals on February 28, 2025. We understand the February 28, 2025 letter to be a determination of project consistency and that the applications have been accepted as complete pursuant to the Permit Streamlining Act (“PSA”). Pursuant to the PSA, an agency is required to “provide an applicant with an exhaustive list of items that were not complete” within 30 days of an application submittal, and the exhaustive list of items “shall be limited to those items actually required on the lead agency's submittal requirement checklist.” (Gov. Code § 65943.) The Town’s February 28, 2025 letters asked for minor corrections or clarifications to the submittals and failed to identify any missing items from the Town’s submittal checklist. In other words, the Town’s requests for clarifications and corrections do not constitute valid items to deem an application incomplete.

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Suzanne Avila
Town of Los Altos Hills
May 29, 2025

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The Projects Are Consistent With All Applicable Standards The Town’s February 28, 2025 letter states that the projects continue to be inconsistent with standards, policies, and requirements under the Los Altos Hills General Plan, Zoning Law, and other applicable standards and requirements in the exact same manner as the prior iterations of the Project and simply attached its prior inconsistency determinations to the February 28 letter.

As we explained in our March 20, 2025 letter, the projects meet the definition of a “builder’s remedy” project and are therefore subject to the requirements of AB 1893. AB 1893 states that that “a local agency may only require the project to comply with the objective, quantifiable, written development standards, conditions, and policies that would have applied to the project had it been proposed on a site with a general plan designation and zoning classification that allow the density and unit type proposed by the applicant.” (Gov. Code § 65589.5(f)(6)(A).) There are no existing general plan designations and zoning classifications in the Town that allow the density and unit type proposed by the applicant and therefore the Town cannot require compliance with any existing code standards. Further, HAA subparagraph (f)(6)(D) confirms that any project that meets the definition of a builder’s remedy project “shall be deemed consistent, compliant, and in conformity with an applicable plan, program, policy, ordinance, standard, requirement, redevelopment plan and implementing instruments, or other similar provision for all purposes. . .”
Our March 20, 2025 letter explained that the Town’s description of these deemed-consistent-bylaw builder’s remedy applications as inconsistent with standards that the Town is statutorily prohibited from applying is a clear violation of the HAA. The Town’s April 4, 2025 response stated that the Town has “not made any determinations on the Project with respect to CEQA or otherwise.” We understand this as an admission that the City has failed to provide a compliance determination within 30 days of the January 30, 2025 submittal. As such, the projects have been deemed complete by operation of law. (Gov. Code § 65589.5(j)(2).) If our understanding is incorrect and the Town has made a compliance determination, please clarify the Town’s position.

Subsequent to the February 28, 2025 letter, the Town sent additional comments from the Building Department and Santa Clara County Fire Department identifying more purported inconsistencies. Even if the February 28, 2025 letter was the City’s compliance determination, the comments from the Building and Fire Department were provided beyond the 30-day deadline in Gov. Code § 65589.5(j)(2) to identify any code inconsistencies. As such, the projects have been deemed consistent with any applicable plan, program, policy, ordinance, standard, requirement, or other similar provision that was not identified in the February 28, 2025 letter.

Response to The Town’s Comments
The Town’s April 4, 2025 stated that the Town has “identified additional items that require correction or needed to be completed” from the January 30, 2025 resubmittal and that staff “is prepared to continue review upon receiving the applicant’s resubmittal.” As explained above, the ITEM 2A ATTACHMENT 9

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Suzanne Avila
Town of Los Altos Hills
May 29, 2025

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project application is complete and deemed consistent, and therefore no items need to be provided for the Town to process the applications. However, Mr. Linebarger has voluntarily decided to resubmit the project plans to address some of the comments contained in the February 28, 2025 letter. Mr. Linebarger does not waive any rights based on this resubmittal.

Further, the Town made clear in its April 4, 2025 letter that the City was continuing to process our client’s February 25, 2025 90-Day Notice pursuant to AB 1633. Despite stating that the City had made no CEQA determination, the April 4 letter again asserted that the Town has predetermined that the Project cannot be found exempt from CEQA. Our client’s CEQA consultant has provided a response to the City’s various erroneous, unsubstantiated assertions.

Please be advised that the Town is still obligated to make a final determination with respect to the AB 1633 within 90 days of the City’s May 20, 2025 letter of extension of time.

Finally, the City’s April 4 letter states that the applicant still needs to address outstanding comments from the Santa Clara County Fire Department (“SCCFD”). Our understanding is that the Town, not SCCFD, has ultimate authority regarding how to interpret and implement the Town’s fire code through the Los Altos Hills County Fire Districts contract with SCCFD. While the Town’s letter states that SCCFD’s comments must be addressed, the Town is the decisionmaking body that determines fire code consistency.

We understand this comment relates to Local Fire Code § 503.1.1 adopted pursuant to the procedures of Health and Safety Code § 13869.7.1
These procedures require that when local
amendments to the California Fire Code are adopted, a city “shall file a copy of the findings of the district, and any findings of the city, county, or city and county, together with the adopted ordinance expressly marked and identified to which each finding refers, with the Department of Housing and Community Development (“HCD”).” HCD has made clear through administrative guidance that local amendments to the California Fire Code are not effective until the amendments are filed with HCD as required by state law. The Town failed to file its Local Fire Code with HCD, and as a result, Local Fire Code § 503.1.1 has not been adopted and is not in effect. In short, the projects do not need to address any outstanding comments related to Local Fire Code § 503.1.1.

That said, Mr. Linebarger has had many discussions with SCCFD personnel and researched the types of fire protection measures that the Department would typically require to address access issues related to Fire Code § 503.1.1. Projects in Santa Clara County that that utilized the exception to Fire Code § 503.1.1 though installation of section 903.3.1.1 fire sprinklers have been systematically approved. This makes since the objective language of the Fire Code §

5.03.1.1 specifically allows for the 903.1.1.exception. Likewise, in both projects that utilized the AMMR process to satisfy a Fire Code § 503 through the installation of a standpipe, both were approved. (See Exhibit A.) This also makes sense, as Fire Code § 503.1.1 is intended to address 1 Fire Code § 503.1.1 was not adopted by the State Fire Marshal and is not part of the California Fire Code.

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Suzanne Avila
Town of Los Altos Hills
May 29, 2025

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maximum hose length to reach all sides of a building and the addition of standpipes will allow hoses to reach areas of a building that would otherwise be unreachable.

Although no modifications are required because the Town failed to properly adopt its local fire code, Mr. Linebarger has nonetheless modified the fire protection measures to add section 903.3.1.1 fire sprinklers and two wet manual standpipes per NPFA 13 and SCCFD standards at the rear of each of the buildings.

Conclusion
As explained above, the applicant understands that the Town has accepted the applications as complete and the projects have been deemed consistent with all applicable standards. We look forward to the City’s completing its CEQA review no later than August 18, 2025, and for the projects to be swiftly approved thereafter. Thank you for your prompt attention to this matter.

Very truly yours,
PATTERSON & O’NEILL, PC
__________________________
Brian O’Neill
____________________ _____________
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Exhibit $
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Response to Comments
Class 32 CEQA Exemption Memo
for the Silver Oaks Senior Living Community,
10728 & 10758 Mora Drive, Los Altos Hills, California
Prepared by
Dan Sicular, Sicular Environmental Consulting,
and
Paul Miller, RCH Group
May 29, 2025
This is a response to the two comment letters from the Town of Los Altos Hills (“the Town”) dated February 28, 2025, wherein the Town claims that the Class 32 CEQA exemption memo for the Silver Oaks Senior Living Community Project (“Exemption Memo”) provided by our firms “did not provide substantial evidence to support” a Class 32 infill exemption under CEQA. The Town issued these comments in a response letter just three days after the 490-page Exemption Memo was submitted to the Town on February 25, 2025.

Attached to this response are three exhibits that provide additional substantial evidence to support a Class 32 exemption, and that corroborate the conclusions in the Exemption Memo. Exhibit 1 is the State Fire Marshall's Fire Severity Zones Map of Los Altos Hills (“Fire Map”) which was updated on February 24, 2025, just after the Exemption Memo was prepared. Exhibit 2 is a biological resources evaluation report of the Project site, prepared by Live Oak Associates (May 28, 2025), and Exhibit 3 is the letter from the State Attorney General to the Town of Woodside that is cited in the biological resources evaluation report.

The Town’s two comment letters, which are nearly identical except that one addresses the portion of the Project located at 10728 Mora Drive, and the other 10758 Mora Drive, make the following points with respect to environmental issues, all of which we disagree with, for the reasons detailed below:

Town Comments
Comment 1: The Town cites Government Code section 65589.5(j)(2)(A) and states that the proposed Project is inconsistent with standards, policies, and requirements under the Los Altos Hills General Plan, Zoning Law, and other applicable standards and requirements, specifically:
(1) Zoning Designation for the parcel;
(2) Lot size requirement;
(3) Development standards under Title 10, Chapter 1 of the Municipal Code; and (4) General Plan standards and policies
(comment letters, page 2).

Comment 2: The Town expects that the Project will have environmental impacts, which may constitute significant impacts, in areas including but not limited to traffic, noise, air quality, utilities and energy, and emergency response services. The Town states that either a Mitigated Negative Declaration or an Environmental Impact Report would be required. The Town states that an Initial Study will need to be conducted for the project in order to determine the specific environmental analysis required (comment letters, page 3).

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Silver Oaks Senior Living Community Class 32 Exemption Memo Response to Comments / Page 2
Comment 3: The Town disagrees with the conclusion in the Exemption Memo that there is substantial evidence in the record to demonstrate that the Project qualifies for a Class 32 in-fill development exemption, that it meets the criteria for an infill exemption under CEQA Guidelines section 15332, and that it is not barred by the “Unusual Circumstances” exception under section 15300.2 (comment letters, page 4).

Comment 4: The Town implies that the Project site is not an infill site, because it is located in a suburban area on a site zoned for residential and agricultural uses (comment letters, page 4).

Comment 5: The Town disagrees that the Exemption Memo provided substantial evidence to support its conclusions (comment letters, page 4).

Responses to Comments
As a general response, the Town does not back any of the claims made in its comments with substantial evidence. All of the points asserted by the Town in these comments are unsubstantiated, speculative, and factually untrue. As detailed in depth in the Exemption Memo, and as supported by substantial evidence provided in the memo and in supporting documents attached to it, the proposed Project (consisting of the proposed developments at both 10758 and 10728 Mora Drive) meets the legal definition of an infill development, would not result in a significant effect on the environment, and meets all of the requirements for a Class 32 exemption pursuant to CEQA Guidelines Section 15332. Furthermore, as also supported by substantial evidence provided in the Exemption Memo and in supporting documents attached to it, the Project is not excluded from a Class 32 exemption by any of the applicable criteria stated in CEQA Guidelines Section 15300.2, nor is it excluded from use of a CEQA categorical exemption for a Builder’s Remedy project by any of the criteria stated in Government Code Sections 65589.5(h)(6)(I)(i) and 65913.4.

Comment 1: The Town cites Government Code section 65589.5(j)(2)(A) and states that the proposed Project is inconsistent with standards, policies, and requirements under the Los Altos Hills General Plan, Zoning Law, and other applicable standards and requirements, specifically:
(1) Zoning Designation for the parcel;
(2) Lot size requirement;
(3) Development standards under Title 10, Chapter 1 of the Municipal Code; and (4) General Plan standards and policies.

Response to Comment 1: As stated in section 3(a) of the Exemption Memo, commencing on page 14, Pursuant to Government Code section 65589.5, subdivision (f)(6)(D)(iii), a qualifying Builder’s Remedy project, “…shall be deemed consistent, compliant, and in conformity with an applicable plan, program, policy, ordinance, standard, requirement, redevelopment plan and implementing instruments, or other similar provision for all purposes, and shall not be considered or treated as a nonconforming lot, use, or structure for any purpose.”
Pursuant to this section of the Government Code, the Town does not have discretion to find that the Project is inconsistent with General Plan standards and policies, Zoning designation, lot size requirements, or Municipal Code development standards. Pursuant to Government Code section 65589.5, subdivision (f)(6)(D)(iii), the Project meets the requirement that a Project must be consistent with General ITEM 2A ATTACHMENT 9

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Silver Oaks Senior Living Community Class 32 Exemption Memo Response to Comments / Page 3
Plan designation and policies and with Zoning designation and regulations to qualify for a Class 32 exemption. Furthermore, as discussed in the Exemption Memo commencing on page 15, the Project is consistent with policies contained in the Town’s 6th Cycle Housing Element. In its comments, the Town makes no attempt to refute these findings of consistency and ignores this key provision of the State Housing Accountability Act.

Comment 2: The Town expects that the Project will have environmental impacts, which may constitute significant impacts, in areas including but not limited to traffic, noise, air quality, utilities and energy, and emergency response services. Thus, either a Mitigated Negative Declaration or an Environmental Impact Report would be required.

Response to Comment 2: The Exemption Memo provides extensive discussion, supported by substantial evidence, that the Project would not have a significant impact related to traffic, noise, air quality, utilities, or emergency response services:

Traffic and Emergency Response Services
Exemption Memo section 3(d)(1), commencing on page 21, examines potential impacts of the Project on traffic, and considers each of the four questions pertaining to traffic in the CEQA Guidelines, Appendix G checklist:
a) Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? b) Would the project conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)?
c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? d) Would the project result in inadequate emergency access? The Exemption Memo concludes that the Project would not have any of these potential impacts. These conclusions are supported by a traffic study completed for the Project by Hexagon Transportation Consultants (included as Attachment C-13), which constitutes substantial evidence in support of the conclusions of no significant impact.

In addition to consideration of emergency access to the Project site addressed in this section of the Exemption Memo, adequacy of emergency response services, specifically fire protection and police projection, to serve the Project are considered in Exemption Memo section 3(e)(1)(a and b). These discussions find, based on substantial evidence cited in the memo, that existing emergency response services are adequate to serve the Project. The scope of the analysis and the methodologies used meet current standards of practice for CEQA reviews, and are typical of higher-level reviews, such as an Initial Study or EIR. The Town in its comments provides no evidence that the Project would result in a significant impact related to traffic or emergency response services.

Noise (including vibration)
The Exemption Memo, section 3(d)(2), commencing on page 24, examines potential impacts of the Project on noise, including vibration, and considers each of the three questions pertaining to noise and vibration in the CEQA Guidelines, Appendix G checklist:

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Silver Oaks Senior Living Community Class 32 Exemption Memo Response to Comments / Page 4
a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? Based on substantial evidence, including a Noise Technical Report prepared for the Project by RCH Group (and included as Attachment C-10) which itself is based on recent ambient noise monitoring at the Project site and modeling of future construction and operational noise levels, the Exemption Memo concludes that the Project would not have a significant noise impact during Project construction or operation, or from Project-related traffic. The scope of the analysis and the methodologies used meet current standards of practice for CEQA reviews and are typical of higher-level reviews, such as an Initial Study or EIR. The Town in its comments provides no evidence that the Project would result in an impact related to noise.

Air Quality
The Exemption Memo, section 3(d)(3), commencing on page 30, examines potential impacts of the Project on air quality, and considers each of the four questions pertaining to noise and vibration in the CEQA Guidelines, Appendix G checklist:
a) Would the project conflict with or obstruct implementation of the applicable air quality plan? b) Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
c) Would the project expose sensitive receptors to substantial pollutant concentrations? d) Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The Air Quality analysis is based on an Air Quality Technical Report prepared by RCH Group, which is attached to the Exemption Memo (Attachment C-9). The Air Quality Technical Report uses air emissions modeling to estimate construction and operational air emissions and compares the results to the Bay Area Air Quality Management District’s recommended thresholds of significance. The Air Quality Technical Report includes a full health risk assessment, which follows guidance from the Bay Area Air Quality Management District and the State Office of Environmental Health Hazard Assessment. For each checklist question, the Exemption Memo concludes, based on substantial evidence, that the Project would not have a significant impact. The scope of the analysis and the methodologies used meet current standards of practice for CEQA reviews, and are typical of higher-level reviews, such as an Initial Study or EIR. The Town in its comments provides no evidence that the Project would result in an impact related to air quality.

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