Agenda packet, special meeting — Los Altos Hills City Council, June 18, 2025 (part 9 of 12)

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.
10758 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: JAN 28, 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

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
A ST
O A
ET

F C O L IF
I RN A

REGISTEREDPROFESSIONAL ENGINE
R

Y RR N C BE OH J

C IV IL
A4.1

DETAILS
ITEM 2A ATTACHMENT 9A

Page 830 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.
10758 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: JAN 28, 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 1/28/2025 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.

AERIAL ACCESS ROADWAY TO

BACK OF BUILDING, THIS

DIMENSION MAY BE INCREASED
TO 300' MAX. PER SEC 503.1.1,
EXCEPTION 1.
52'-6" 49'-3"

AERIAL ACCESS ROADWAY TO

BACK OF BUILDING, THIS

DIMENSION MAY BE
INCREASED TO 300' MAX. PER
SEC 503.1.1, EXCEPTION 1.

MITIGATION MEASURE #1

BUILDING EQUIPED THROUGHOUT W/

APPROVED AUTOMATIC SPRINKLER
SYSTEM PER CBC SEC. 903.3.1.1
MITIGATION MEASURE #1

BUILDING EQUIPED THROUGHOUT W/

APPROVED AUTOMATIC SPRINKLER
SYSTEM PER CBC SEC. 903.3.1.1
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.

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
MITIGATION MEASURE #2 SEPERATE

FIRE DEPARTMENT ACCESS THIS SIDE

OF BUILDING (NO OCCUPANT EGRESS
THIS SIDE OF BLD'G) EXCEPTION:

WHEELCHAIR RAMP IN FIRST 30'
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.

MITIGATION MEASURE #3

STANDPIPE OUTLETS ADDED AT

NORTH & SOUTH EXTERIOR WALLS
MITIGATION MEASURE #3

STANDPIPE OUTLETS ADDED AT

NORTH & SOUTH EXTERIOR WALLS
MITIGATION MEASURE #2 SEPERATE

FIRE DEPARTMENT ACCESS THIS SIDE OF

BUILDING (NO OCCUPANT EGRESS THIS
SIDE OF BLD'G) EXCEPTION: WHEELCHAIR
RAMP IN FIRST 50'
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
MITIGATION MEASURE #4
INCREASED FIRE RATING AT TYPE 1-A
SOUTH WALL, SEE ELEVATIONS A2.1
MITIGATION 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"
ITEM 2A ATTACHMENT 9A

Page 831 of 1435 ends

VAN

LOADING
1 2 EV EV EV

EV EV EV
EV EV
28 29 30
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 31
12 9 6 3 18 21 24 27 30 33 36
45 48
15 39 42
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10758 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: JAN 28, 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
SCALE:
1"=20'

FIRE EGRESS & OCCUPANCY NORTH

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 5 ROLL-UP DOOR
20' 40' 60'
LEVEL 2 BUILDING PLAN

FAN DUCTS TO GARAGE
UP
STORAGE 1STORAGE 2STORAGE 3STORAGE 4
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

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

NOT OCCUPIED

ELEC / MECH

NOT OCCUPIED

STORAGE
214 SF
S-2 200 DIAGONAL DISTANCE = 220'-8"
1 1
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
316 SF
B 50
6 2,447 SF
B 50
49 LEVEL 5/ROOF OCCUPANCY LOAD
1+1+6+49+42+65+6+5+8+15+6+44+52=300/2=150
150

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
(.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:

MECH

NOT OCCUPIED

JANITOR

NOT OCCUPIED

LOWER PODIUM BUILDING PLAN
DIAGONAL DISTANCE = 184'-4"
FAN

ROOM JANITOR

ELEVATOR
#1
EXIT
STAIR #1
DINING
DN

DOG RUN
12'6"X18'4

PUTTING GREEN
POWDER
ROOM
POWDER
ROOM
MECH.ROOM

KITCHEN

DECK REF BELOW
ROOM

TRASH FIRE PIT

MOVABLE

FURNITURE
COURT
755 SF
B 50
15 KITCHEN
640 SF
R-2 100
6 DINING
982 SF
A-3 15
65 CANOPY FIRE PIT
229 SF
B 50
5 DOG RUN
381 SF
B 50
8 SITTING AREA
MECH

NOT OCCUPIED
6 49
6 5
65 15
A5.1

OCCUPANCY & EGRESS PLANS

EXERCISE
500 SF
B 50
10 10
3 13

SUB BASEMENT OCCUPANCY LOAD
10+3=13
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 (13 OCCUPANTS) = 2.6"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (13 OCCUPANTS) = 2.0"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

EXERCISE ROOM
638 SF
R-2 200
3 FLOOR PLAN HR
DIAGONAL DISTANCE = 60'-11"

EXIT DISCHARGE
44" CORRIDOR
1031 SF
R-2 200
5 5
3 DIAGONAL DISTANCE = 72'-3"

UTILITY

NOT OCCUPIED

BASEMENT OCCUPANCY LOAD
3+5=8
0 25' TRAVEL DISTANCE
48' TRAVEL DISTANCE FROM MOST

REMOTE PORTION OF MOST

REMOTE UNIT TO COMMON PATH
OF TRAVEL. 73' TO EXIT STAIR.
48' 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

FLOOR PLAN HR

FLOOR PLAN BB

UTILITY
UP
IDF 8 JANITOR

JANITOR

NOT OCCUPIED
638 SF
R-2 200
3 44" CORRIDOR
1123 SF
R-2 200
6 3
DIAGONAL DISTANCE = 72'-3"

LOWER PODIUM OCCUPANCY LOAD
3+6=9
25' TRAVEL DISTANCE
48' TRAVEL DISTANCE FROM MOST

REMOTE PORTION OF MOST

REMOTE UNIT TO COMMON PATH
OF TRAVEL. 73' TO EXIT STAIR.
48' TRAVEL

DISTANCE
EXIT
STAIR #2

ELEVATOR
#2

FLOOR PLAN H

FLOOR PLAN BP
UP
9 638 SF
R-2 200
3 DECK
DECK
(.2"/OCCUPANT) x (9 OCCUPANTS) = 1.8"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (9 OCCUPANTS) = 1.4"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:
6 44" CORRIDOR
638 SF
R-2 200
3 1031 SF
R-2 200
5 3
26 35' TRAVEL DISTANCE
UP
EXIT
STAIR #2

FLOOR PLAN H

FLOOR PLAN BP
DECK

ELEVATOR
#2
50' TRAVEL DISTANCE FROM MOST

REMOTE PORTION OF MOST

REMOTE UNIT TO COMMON PATH
OF TRAVEL. 85' TO EXIT STAIR.
5 50' TRAVEL

DISTANCE
DECK
(.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:

PODIUM / GARAGE OCCUPANCY LOAD
36+1+5+3=45
EXIT SEPARATION: 150'-4"

DECK DECK

LAUNDRY

UTILITY
1,005 SF
R-2 200
5 1,004 SF
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
71' TRAVEL DISTANCE
58' TRAVEL

DISTANCE
58' TRAVEL DISTANCE FROM MOST REMOTE

PORTION OF MOST REMOTE UNIT TO COMMON
PATH OF TRAVEL. 104' TO EXIT STAIR.
44" CORRIDOR

FLOOR PLAN BR

FLOOR PLAN H

FLOOR PLAN AL

FLOOR PLAN D

ELEVATOR
#2
EXIT
STAIR #2
IDF
638 SF
R-2 200
3 UP
29' TRAVEL DISTANCE
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:

FAN CHASE

TO ROOF
44" CORRIDOR 5
729 SF
B
15 702 SF
B
14 DIAGONAL DISTANCE = 220'-8"
696 SF
R-2 200
3 7
2 3
3 695 SF
R-2 200
3 298 SF
R-2.1 200
2 2
1 2
50 50
1 2 2 15
275 SF
R-2.1 200
1 357 SF
R-2.1 200
2 305 SF
R-2.1 200
2 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 LEVEL 1 OCCUPANCY LOAD
5+1+1+5+7+2+1+2+14+15+2+2+1+2+3+4+3=70/2=35
35 35
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 (35 OCCUPANTS) = 7"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (35 OCCUPANTS) = 5.25"
*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 J FLOOR PLAN H

DECK DECK

DECK DECK DECK
UP

JULIET BALCONY
DINING
MEDIA

JULIET BALCONY

WORK STATION

SUPPLY ROOM

FLOOR PLAN K

FLOOR PLAN M FLOOR PLAN O

FLOOR PLAN Q
POWDER
ROOM
UP
22' TRAVEL DISTANCE
44" CORRIDOR
1,024 SF
R-2 200
5 DIAGONAL DISTANCE = 220'-8"
TRASH
143 SF
B 100
1 EXIT SEPARATION:156'-9"
1,392 SF
R-2 200
7 LEVEL 2 OCCUPANCY LOAD
5+1+5+7+5+7+7+3+4+3=47/2=23
1,006 SF
R-2 200
5 1,397 SF
R-2 200
7 1,463 SF
R-2 200
7 695 SF
R-2 200
3 737 SF
R-2 200
4 696 SF
R-2 200
3 497 SF
B 100
5 5
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

FLOOR PLAN E

FLOOR PLAN D

FLOOR PLAN F

FLOOR PLAN C
SALON

DECK DECK DECK DECK

DECK DECK
UP

FLOOR PLAN H FLOOR PLAN I FLOOR PLAN J
IDF
UP
1,024 SF
R-2 200
5 DIAGONAL DISTANCE = 220'-8"
TRASH
143 SF
B 100
1 1,392 SF
R-2 200
7 LEVEL 3 OCCUPANCY LOAD
8+4+1+5+7+5+7+7+5+5=54/2=27
1,006 SF
R-2 200
5 1,463 SF
R-2 200
7 1,079 SF
R-2 200
5 1,061 SF
R-2 200
5 380 SF
B 50
8 5
7 7
5 1
8 27 5 5 7
(.2"/OCCUPANT) x (27 OCCUPANTS) = 5.4"
*USE MIN. 44" WIDE PER SEC 1011.2
(.15"/OCCUPANT) x (27 OCCUPANTS) = 4.1"
*USE MIN. 44" WIDE PER SEC 1005.1
STAIR WIDTH:

COMPONENT WIDTH
OTHER THAN STAIRS:

ELEVATOR
#1
EXIT
STAIR #1
IDF
TRASH

FLOOR PLAN G

FLOOR PLAN E

FLOOR PLAN D

FLOOR PLAN F

FLOOR PLAN C

SITTING ROOM

DECK DECK DECK DECK

DECK DECK
UP

JULIET BALCONY

FLOOR PLAN A FLOOR PLAN B

SITTING RM
LEASING OFFICE 222 SF
B 50
4 LEASING OFFICE
4 44" CORRIDOR EXIT SEPARATION:156'-9"
27 84' TRAVEL DISTANCE 84' TRAVEL DISTANCE

ELEVATOR
#2
EXIT
STAIR #2
IDF
UP 7' TRAVEL DISTANCE
1,397 SF
R-2 200
7 DECK
1,024 SF
R-2 200
5 DIAGONAL DISTANCE = 220'-8"
TRASH
143 SF
B 100
1 1,392 SF
R-2 200
7 LEVEL 4 OCCUPANCY LOAD
7+4+1+5+7+5+5+7+5+5=51/2=26
1,006 SF
R-2 200
5 1,463 SF
R-2 200
7 MUSIC RM
330 SF
B 50
7 5
7 5
1 7
26 5 5 7
1,079 SF
R-2 200
5 197 SF
B 50
4 1,061 SF
R-2 200
5 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 E

FLOOR PLAN D

FLOOR PLAN B FLOOR PLAN A

FLOOR PLAN F

FLOOR PLAN C

DECK DECK DECK

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

FLOOR PLAN GR
44" CORRIDOR EXIT SEPARATION:156'-9"
26 84' TRAVEL DISTANCE 84' TRAVEL DISTANCE

ELEVATOR
#2
EXIT
STAIR #2
IDF
UP
7' TRAVEL DISTANCE
DECK
DECK
84' TRAVEL DISTANCE 84' TRAVEL DISTANCE
EXIT SEPARATION:156'-9" 150

ELEVATOR
#2
EXIT
STAIR #2
UP
TRASH
143 SF
B 100
1 POWDER
ROOM

PANTRY PREP ROOM

KITCHEN STORAGE

STORAGE

STORAGE
53 SF
S-2 200
1 8

MULTI PURPOSE
767 SF
A-3 15
52 52

ROOF GARDEN
GARDEN
285 SF
B 50
6 6

FLOOR PLAN I

DECK DECK
DECK

JULIET BALCONY

JULIET BALCONY
1,100 SF
R-2 200
5 60' TRAVEL DISTANCE FROM MOST REMOTE

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

DISTANCE
7 7' TRAVEL DISTANCE
40' TRAVEL

DISTANCE
40' TRAVEL DISTANCE FROM MOST REMOTE

PORTION OF MOST REMOTE UNIT TO COMMON
PATH OF TRAVEL. 105' TO EXIT STAIR.

JULIET BALCONY
4 737 SF
R-2 200
4 40' TRAVEL

DISTANCE
EXAM RM 1
EXAM RM 2

CRAFT ROOM
659 SF
A-3 15
44 ART ROOM
627 SF
A-3 15
42 MULTI PURPOSE ROOM

ART ROOM
44 CRAFT ROOM
42 1,024 SF
R-2 200
5 297 SF
R-2.1 200
2 278 SF
R-2.1 200
1 357 SF
R-2.1 200
2 FLOOR PLAN F FLOOR PLAN L FLOOR PLAN N FLOOR PLAN P

FLOOR PLAN C
1,392 SF
R-2 200
7 BMR BMR
BMR
ITEM 2A ATTACHMENT 9A

Page 832 of 1435 ends

UP
UP
DN
VAN

LOADING
1 2 EV EV EV

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

SPARE P C T
DN
UP
28 29 30
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 31
UP DN
12 9 6 3 18 21 24 27 30 33 36
45 48
570.8' 15
39 42
P C T
570.8'
UP DN
1BED 1BED 1BED
2BED PENTHOUSE
582.0'
P C T
582.0'
UP DN
593.2'
P C T
593.2'
UP DN
604.4'
P C T
604.4'
UP DN
615.6'
615.6'
DN
P C T
UP DN
Berry and Associates
Civil Engineer
Stevens Ferrone & Bailey
Engineering Company, Inc.
10758 MORA DRIVE
LOS ALTOS HILLS, CA 94024
Silver Oaks Senior Community
DATE: JAN 28, 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 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
17,325 SF (.397 ACRES)
FLOOR AREA RATIO: 4.20 FAR = 72,848 sf/17,325 sf BUILDING CODE FLOOR AREAS:

LEVEL AREA
BASEMENT CBC AREA 2,433 SF
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA
6,186 SF
6,206 SF
TOTAL TYPE 111-A 30,411 SF
TOTAL TYPE 1-A 22,042 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: TYPE 1-A (PER CBC)
TYPE 111-A
This level contains seperated occupancies: S-2 Parking Garage, B Office, R-2.1 Allowable Building Height (Table 504.3): Unlimited (R-2.1 Most Restrictive Use) Allowable Number of Stories (Table 504.4): Unlimited (R-2.1 Most Restrictive Use) Allowable Building Area (Table 506.2): Unlimited (R-2.1 Most Restrictive Use) Max Allowable Area per Story: Unlimited (R-2.1 Most Restrictive Use) Proposed: 22,042 sf
LEVEL (SUB BASE., BASE.,L.P, P/GARAGE, MEZ.) ALLOWABLE BUILDING AREA PER FLOOR (TYPE 1-A) LEVEL 1: R-2, R2.1, B
SUB BASEMENT CBC AREA 1,588 SF
MEZZANINE CBC AREA 4,887 SF
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): 30,411 sf OK COMPARTMENT-B: Proposed Building Area Levels 1,2,3,4,5, Roof (CBC): 17,469 sf OK LEVEL 1-5/ROOF ALLOWABLE BUILDING AREA TOTAL FOR EACH COMPARTMENT (TYPE 111-A) PODIUM /GARAGE CBC AREA 10,701 SF
LEVEL 5/ROOF CBC AREA (from Podium) 5,647 SF

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 FLOOR AREA DIAGRAM

DECK AREA COUNTED IN CBC

FLOOR AREA WHERE COVERED
BY PROJECTION ABOVE, 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, R-2 (ACCESSORY USE POOL)
LEVEL 4: R-2, B, A-3

LOWER PODIUM FLOOR

AREA DIAGRAM

DECK AREA COUNTED IN CBC

FLOOR AREA WHERE COVERED
BY PROJECTION ABOVE, TYP.

LOWER PODIUM CBC AREA 2,433 SF
2,433 SF
1,588 SF
10,701 SF
2,433 SF
R2.1 ASSISTED LIVING
A5.2

ALLOWABLE AREA CALC'S & CODE ANALYSIS
ZONING FLOOR AREAS:

LEVEL AREA
BASEMENT ENCLOSED AREA 2,567 SF

MEZZANINE ENCLOSED AREA
LEVEL 1 ENCLOSED AREA
LEVEL 2 ENCLOSED AREA
LEVEL 3 ENCLOSED AREA
LEVEL 5/ROOF ENCLOSED AREA 6,105 SF
11,184 SF
11,184 SF
5,339 SF
10,418 SF
TOTAL 72,848 SF
SUB BASEMENT ENCLOSED AREA 1,593 SF
LEVEL 4 ENCLOSED AREA 10,722 SF
PODIUM /GARAGE ENC'D AREA 11,169 SF
LOWER PODIUM ENCLOSED AREA 2,567 SF

BASEMENT CBC AREA

SUB BASEMENT CBC AREA

PODIUM /GARAGE CBC AREA

LOWER PODIUM CBC AREA

COMPARTMENT A COMPARTMENT B

COMPARTMENT - A
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA
4,501 SF
3,966 SF
TOTAL TYPE 111-A 17,469 SF
LEVEL 5/ROOF CBC AREA (from Podium) 0 SF

COMPARTMENT - B
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 = 6,186 sf OK 4,501 sf OK
Level 2 Proposed = 6,186 sf OK 4,501 sf OK
Level 3 Proposed = 6,186 sf OK 4,501 sf OK
Level 4 Proposed = 6,206 sf OK 3,966 sf OK
Level 5/Roof Proposed = 5,647 sf OK 0 sf OK
(note: Roof area is located on 5th level above front podium) COMP-A
TYPE 111-A
COMP-B
6,186 SF
4,501 SF
6,186 SF
4,501 SF
MEZZANINE CBC AREA 4,887 SF
TOTAL TYPE 1-A 22,042 SF
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA
6,186 SF
6,206 SF
TOTAL TYPE 111-A
LEVEL 5/ROOF CBC AREA (from Podium)
6,186 SF
6,186 SF
LEVEL 1 CBC AREA
LEVEL 2 CBC AREA
LEVEL 3 CBC AREA
LEVEL 4 CBC AREA
4,501 SF
3,966 SF
TOTAL TYPE 111-A 17,469 SF
LEVEL 5/ROOF CBC AREA (from Podium) 0 SF
4,501 SF
4,501 SF
30,411 SF
5,647 SF
ITEM 2A ATTACHMENT 9A

Page 833 of 1435 ends

PM-1
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:_________________________ 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 OWNER: FORREST LINEBARGER

EDGE OF SHEET
JOHN BERRY CIVIL ENGINEER RCE 18720
2149 AVY AVENUE, MENLO PARK, CA 94025
1 (650) 400-9003

PARCEL MAP

LINEBARGER SUBDIVISION
A SUBDIVISION OF A PORTION OF LOT NO. 3 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. 10758 MORA DRIVE ALSO SHOWN ON CERTIFICATE OF COMPLIANCE 23761713 RECORDED IN SANTA CLARA COUNTY, STATE OF CALIFORNIA, ON SEPTEMBER 26, 2017

TOWN OF LOS ALTOS HILLS SANTA CLARA COUNTY CALIFORNIA
MAY 2023

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
ITEM 2A ATTACHMENT 9A

Page 834 of 1435 ends

℄
℄
℄ MORA DRIVE
N 89° 19' 00" W 274.06'
S 06° 24' 40" W 62.81'
S 89° 19' 00" E 280.33' N 00° 41' 00" E 62.50'
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
10'0' 20' 40' SCALE:
1"=20'

LANDS OF MINTON
APN: 331-15-060
S.W. CORNER LOT 1,
'Y' MAPS 53 BASIS OF BEARINGS
FOUND 3/4" IRON PIPE,
OPEN, PER 827 MAPS 10

LANDS OF KLEIN
APN: 331-14-063

LANDS OF WINCHELL
APN: 331-15-023
SE CORNER OF LOT 3
'Y' MAPS 53
EAST LINE OF LOT 3
'Y' MAPS 53
FOUND 3/4" IRON PIPE,
OPEN, PER 827 MAPS 10
AND 736 MAPS 25 AND
201 MAPS 53
280.00' +/- 50' R.O.W.
25' ROW 25' ROW EϬϬΣϰϭΖϬϬΗ

SHEET 2 OF 2
PM-2

EDGE OF SHEET
JOHN BERRY CIVIL ENGINEER RCE 18720
2149 AVY AVENUE, MENLO PARK, CA 94025
1 (650) 400-9003
COMMON LOT LINE LOTS 2-3
'Y' MAPS 53
LEGEND

CENTERLINE

EASEMENT LINE

PRIVATE ACCESS

EASEMENT

LOT LINE

ADJOINING PROPERTY LINE
PAE

PRIVATE UTILITY

EASEMENT
PRUE

PRIVATE SANITARY

SEWER EASEMENT
PSSE

PRIVATE INGRESS AND

EGRESS EASEMENT
PIEE

EMERGENCY VEHICLE

ACCESS EASEMENT
EVAE

DISTINCTIVE BORDER

SEARCHED FOR NOT
FOUND
SFNF

EXISTING IRON PIPE

MONUMENT

NEW IRON PIPE

MONUMENT TO BE SET
TOTAL LENGTH 280.33'

PARCEL MAP

CLARA COUNTY RECORDS, A PORTION OF SAN ANTONIO RANCHO AND

TOWN OF LOS ALTOS HILLS SANTA CLARA COUNTY CALIFORNIA
MAY 2023
LOT 2,
'Y' MAPS 53
201 MAPS 53
PORTION OF LOT 3,
'Y' MAPS 53
TOTAL LENGTH 274.06'
LOT 3
17,325 SF +/-
.397 AC +/-

FOR CONDOMINIUM PURPOSES
CONSISTING OF 45 RESIDENTIAL UNITS

AND ONE COMMON LOT
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
ITEM 2A ATTACHMENT 9A

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Zoning and Site Development Consistency Review
32-unit development project at 10728 Mora Drive
May 30, 2025 Submittal
Development
Standard
Requirement Proposed/Status Compliant Yes or No
Lot Size 1 acre minimum 16,308 sq. ft./.374 Ac
Nonconforming lot
nonconforming lot
Setbacks 40 feet front
30 feet sides & rear
30 feet front
5 feet sides

16.8 feet rear
No
Building Height 27 feet sectional
35 feet low to high
84 feet 5 inches No
MDA 5,000 sq. ft.* 14,379 + 65,823 No
MFA 7,500 sq. ft.* 65,823 No
Lot Coverage No standard 88.2% -
Floor Area Ratio No standard 4.04 -
Parking 2 covered spaces plus 2
uncovered spaces SFR; 1
space ADU (No MF stds.)
27 total
(.62 spaces/unit) -
Accessible Parking Building Code 2 2 Yes
Bike Parking No standard 7 spaces -
Density Low Density Residential 32 units (3 affordable)**

85.6 units/acre
No
Affordable Units 10% 3 very low-income units Yes
Private open space No standard Decks/balconies -
Tree Removal Oaks with trunk diameter
12-inches or greater require
approval
10 trees to be removed;
trunk diameter for 6 oaks
not provided
TBD
Geotechnical
Clearance
Review by Town
Geotechnical Consultant
Preliminary review
completed
Yes
Grading See Grading Policy 14 feet cut/grading within
10 feet of property line
No
Exterior Color 50 LRV walls
40 LRV roof
Color light reflectivity
values provided
Yes
Environmental
Review
Initial Study and applicable
CEQA document to be
prepared
Environmental Checklist
provided
CEQA analysis
pending
Exterior Lighting See Lighting Policy Down directed fixtures proposed
TBD
Landscaping Compliance w/WELO 1,929 sq. ft. TBD
Green Building Build It Green or LEED Checklist not provided TBD Stormwater Compliance w/NPDES
permit/C.3
Stormwater plan provided;
reviewed by EOA
Yes, with conditions
Sanitary Sewer Connection to sewer 1 connection for lot; capacity available
Yes
Fire Safety Comply with SCCFD
requirements
Two AAMRs not approved No
*These values are not guaranteed for lots with LUF less than .50 **State Density Bonus applied
ITEM 2A ATTACHMENT 10A PAGE 1

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Unit Sizes & Locations - 10728 Mora Drive
May 30, 2025 Resubmittal
Unit Identifier Size (sq. ft.) location Total # of unit size 304 (BMR) basement 1
317 (BMR) basement 1
377 (BMR) level two 1
602 level four 1
1003 mezzanine 1
1023 mezzanine 1
1072 level one
level two
2 1232 level two
level three
2 1549 level one
level two
level three
3 1630 level one
level four
2 1710 level three
level four
2 1753 podium/garage 1
1759 level two
level three
level four
3 1777 mezzanine
level one
level two
level three
4 1799 level one 1
2306 basement/sub-basement 1
2322 level four 1
2596 level 5 1
2826 level 5 1
TOTAL UNITS 30
ITEM 2A ATTACHMENT 10A PAGE 2

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 **VIA EMAIL ONLY**
August 28, 2023
Forrest Linebarger
785 Castro Street, Suite A
Mountain View, CA 94041
Via email at [email protected]
RE: 57-unit development project
10728 Mora Drive
File # CDP23-0002
Dear Mr. Linebarger:

Pursuant to Government Code 65589, the Town has completed a Zoning and General Plan consistency review for your 57-unit development project at 10758 Mora Drive.

Staff has determined that the proposed project is inconsistent with the following standards:

1. Maximum floor area

2. Maximum development area

3. Building setbacks

4. Building height

5. Density
The following standards require further review:

1. Outdoor lighting

2. Exterior colors

3. Tree removal

4. Water Efficient Landscape Ordinance compliance

5. Stormwater treatment/C.3 compliance

6. Sewer connection and capacity
Please see Attachments 1 for a summary of zoning and site development standards. Attachment B includes applicable General Plan policies.

The project has not been cleared by the Town Geotechnical Consultant and Santa Clara County Fire Department. Comments from these reviewers must be addressed before it can be determined whether the project is in compliance with the Uniform Fire Code and geotechnical standards of care.

ITEM 2A ATTACHMENT 10B PAGE 1

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Lands of Linebarger
10758 Mora Drive
August 28, 2023

Page 2 of 2 ends

Once the application has been deemed complete, environmental review under the California Environmental Quality Act (“CEQA”) will commence in accordance with applicable law. Traffic analysis may be required as part of the environmental review. The appropriate CEQA documents will be prepared by an outside consultant and the fees will be based on actual cost.

I can be contacted by e-mail at [email protected] if you have any questions.

Sincerely,
Suzanne Avila
Suzanne Avila, AICP
Consultant Principal Planner
Attachments

1. Zoning and Site Development Standards Table

2. Applicable General Plan Policies
ITEM 2A ATTACHMENT 10B PAGE 2

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Unit Sizes & Locations - 10758 Mora Drive
May 25, 2025 Resubmittal
Unit Identifier Size (sq. ft.) location Total # of unit size 316 (BMR) level four 1
427 (BMR) basement 1
431 (BMR) basement 1
637 lower podium 1
751 basement 1
914 mezzanine 1
944 mezzanine 1
1079 level one
level two
level four
3 1096 lower podium 1
1247 level two
level three
2 1630 level one (2)
level two
level three
level four (2)
6 1710 level three 1
1759 level one
level two
level three
level four
4 1799 mezzanine
level one
level two
level three
level four
5 2264 basement/sub-basement 1
2313 level 5 1
2574 level 5 1
TOTAL UNITS 32
ITEM 2A ATTACHMENT 10B PAGE 3

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Zoning and Site Development Consistency Review
34-unit development project at 10758 Mora Drive
May 30, 2025 Submittal
Development
Standard
Requirement Proposed/Status Compliant Yes or
No
Lot Size 1 acre minimum 17,325 sq. ft./.397 Ac
Nonconforming lot
nonconforming lot
Setbacks 40 feet front
30 feet sides & rear
25 feet front
5 feet sides
35 feet 8-inches rear
(hardscape encroaches)
No
Building Height 27 feet sectional
35 feet low to high
80 feet 2 inches No
MDA 5,000 sq. ft.* 14,396 + 70,665 No
MFA 7,500 sq. ft.* 70,665 No
Lot Coverage No standard 83.1% -
Floor Area Ratio No standard 3.86 -
Parking 2 covered spaces plus 2
additional spaces SFR; 1
space ADU
(No standards for MF)
27 total
(.79 spaces/unit) -
Accessible Parking Building Code 2 2 Yes
Bike Parking No standard 7 spaces -
Density Low Density Residential 34 units

85.6 units/acre
No
Affordable Units 10% 3 very low-income units** Yes
Private open space No standard Decks/balconies -
Tree Removal Oaks with trunk diameter
12-inches or greater
require approval
11 trees to be removed;
trunk diameters not
provided for 9 oaks
TBD
Geotechnical
Clearance
Review by Town
Geotechnical Consultant
Preliminary Review
completed
Yes
Grading See Grading Policy 17 feet cut/grading within
10 feet of PL
No
Exterior Color 50 LRV walls
40 LRV roof
Color light reflectivity
values provided
Yes
Environmental
Review
Initial Study and
applicable CEQA
Environmental Checklist
provided
CEQA analysis
pending
Exterior Lighting See Lighting Policy Proposed fixture type compliant
TBD
Landscaping Compliance w/WELO 2,929 sq. ft. TBD
Green Building Build It Green or LEED Checklist not provided TBD Stormwater Compliance w/NPDES
permit/C.3
Stormwater plan provided;
review by EOA
Yes with conditions
Sanitary Sewer Connection to sewer 1 connection for lot; capacity available
Yes
Fire Safety Comply with SCCFD
requirements
Two AMMRs not
approved
No
*These values are not guaranteed for lots with LUF less than .50 **State Density Bonus applied
ITEM 2A ATTACHMENT 10B PAGE 4

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NOTICE DATE: June 6, 2025

TOWN OF LOS ALTOS HILLS

NOTICE OF CITY COUNCIL
PUBLIC HEARING – SPECIAL MEETING
Notice is hereby given to property owners that a PUBLIC HEARING will be held regarding adoption of findings and denial of an application for a senior residential development project at 10728 Mora Drive, Los Altos Hills, pursuant to Government Code section 65589.5(d) by the City Council as follows. This hearing was initially scheduled and opened on January 30, 2025, and was continued to March 20, 2025; on March 20, 2025, the hearing was continued to a date uncertain; the hearing is now scheduled for the date and time below.

Date/Time: Wednesday, June 18th, 2025 at 6:00 P.M., or as soon as thereafter practicable Public Hearing Item: 10728 Mora Drive – File #CDP23-0001 – Lands of Linebarger Adopt Findings and Deny an application for a residential development project to construct a multifamily senior residential development project on a vacant parcel at 10728 Mora Drive, pursuant to Government Code section 65589.5(d).

Staff recommendation is for the City Council to adopt a resolution making findings pursuant to Government Code Section 65589.5(d) and deny the application.

CEQA Recommendation: Per CEQA Guidelines Section 15270, CEQA does not apply to projects which a public agency rejects or disapproves.

A digital copy of the meeting agenda is available on the Community Development Department webpage:
https://www.losaltoshills.ca.gov/506/Agendas-Minutes-and-Packets. If you wish to review the project plans, a copy is available in Town Hall. If you have any questions or need additional information about this application, please contact Jay Bradford, Community Development Director at (650) 559-2244 or [email protected].

Applicants scheduled on this date are requested to be present (either virtually or in person) at the listed time or be represented by an authorized agent. Court challenges to the action of the Site Development Committee, Planning Commission, or City Council may be limited to issues raised at the public hearing, described in this notice, or in written correspondence received at Town Hall at, or prior to, the time of the public hearing.

To attend the meeting in person:

City Council Chambers, 26379 Fremont Road, Los Altos Hills, CA 94022 To provide Public Comment in person:

Members of the public wishing to speak are requested to complete a speaker card and submit it to the City Clerk at the meeting.

To participate in the meeting via Zoom Video Conference, please follow the instructions below:

1. If you wish to submit a public comment on agenda items in advance of the meeting, email the Planner for the project. If you choose to email your comments, indicate in the subject line “FOR PUBLIC COMMENT” and specify the File #. Written comments will be posted on the City website at www.losaltoshills.ca.gov subject to Staff’s ability to post the documents before the meeting.

ITEM 2A ATTACHMENT 11

Page 842 of 1435 ends

NOTICE DATE: June 6, 2025

2. If you wish to provide public comment during the meeting, follow this protocol: raise your hand in the Zoom application, before sharing your comment, identify yourself by name and where you reside.

3. To join from a PC, Mac, iPad, iPhone, or Android device, click this URL to join:
https://bit.ly/June18SpecialMeetingLAH6pm
Webinar ID: 827 8471 4526
Password: 94022
Public testimony will be taken at the direction of the Mayor and members of the public may only comment during times allotted for public comments. This meeting will be broadcast via live-stream service at http://www.losaltoshills.ca.gov.

ITEM 2A ATTACHMENT 11

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NOTICE DATE: June 6, 2025

TOWN OF LOS ALTOS HILLS

NOTICE OF CITY COUNCIL
PUBLIC HEARING – SPECIAL MEETING
Notice is hereby given to property owners that a PUBLIC HEARING will be held regarding adoption of findings and denial of an application for a senior residential development project at 10758 Mora Drive, Los Altos Hills, pursuant to Government Code section 65589.5(d) by the City Council as follows . This hearing was initially scheduled and opened on January 30, 2025, and was continued to March 20, 2025; on March 20, 2025, the hearing was continued to a date uncertain; the hearing is now scheduled for the date and time below.

Date/Time: Wednesday, June 18th, 2025 at 6:00 P.M., or as soon as thereafter practicable Public Hearing Item: 10758 Mora Drive – File #CDP23-0002 – Lands of Linebarger Adopt Findings and Deny an application for a residential development project to construct a multifamily senior residential development project on a vacant parcel at 10758 Mora Drive, pursuant to Government Code section 65589.5(d).

Staff recommendation is for the City Council to adopt a resolution making findings pursuant to Government Code Section 65589.5(d) and deny the application.

CEQA Recommendation: Per CEQA Guidelines Section 15270, CEQA does not apply to projects which a public agency rejects or disapproves.

To attend the meeting in person:

City Council Chambers, 26379 Fremont Road, Los Altos Hills, CA 94022 To provide Public Comment in person:

Members of the public wishing to speak are requested to complete a speaker card and submit it to the City Clerk at the meeting.

To participate in the meeting via Zoom Video Conference, please follow the instructions below:

ITEM 2A ATTACHMENT 11

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NOTICE DATE: June 6, 2025

ITEM 2A ATTACHMENT 11

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1 City Council Regular Meeting Agenda
March 20, 2025

NOTICE TO PUBLIC
Any writings or documents provided to a majority of the City Council regarding any item on the open session portion of this agenda will be made available for public inspection in the City Clerk’s office located at 26379 Fremont Road, Los Altos Hills, California during normal business hours. These materials will also be made available on the City website at www.losaltoshills.ca.gov subject to Staff’s ability to post the documents before the meeting.

Revision No.1 – Distributed on Monday, March 17, 2025

NOTICE IS HEREBY GIVEN THAT A REGULAR MEETING OF THE

LOS ALTOS HILLS CITY COUNCIL WILL BE HELD ON
THURSDAY, MARCH 20, 2025, AT 6:00 P.M.

Meetings of the City Council are held in-person. As a courtesy, and in compliance with applicable state law, staff and members of the public may participate in the meeting in person at Town Hall or virtually via Zoom Video Conference. Members of the City Council may participate remotely from time to time in accordance with the provisions of Government Code section 54953.

To attend the meeting in person:

City Council Chambers, 26379 Fremont Road, Los Altos Hills, CA 94022 To provide Public Comment in person:

Members of the public wishing to speak are requested to complete a speaker card and submit it to the City Clerk at the meeting.

To participate in the meeting via Zoom Video Conference, please follow the instructions below:

Public comment will also be accepted via email at [email protected] prior to the start of the meeting. Written comments will be posted on the website and distributed to the Council. If you choose to email your comments, please indicate in the subject line “FOR PUBLIC COMMENT” and indicate the item number. If you wish to submit a public comment during the meeting, please use the following information. Before speaking, please identify yourself by name and where you reside. The City Council meeting will be live-streamed on the Town’s website and via Zoom at the following location:
https://bit.ly/LAHRegularCityCouncilMtg
Meeting ID: 880 1278 9215
Password: 94022
Town of Los Altos Hills
City Council Regular Meeting Agenda

REVISED
Thursday, March 20, 2025 at 6:00 PM
Council Chambers, 26379 Fremont Road
Los Altos Hills, California
ITEM 2A ATTACHMENT 11

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2 City Council Regular Meeting Agenda
March 20, 2025
CALL TO ORDER (6:00 P.M.)

ROLL CALL

PLEDGE OF ALLEGIANCE

1. AGENDA REVIEW

2. PRESENTATIONS AND APPOINTMENTS
A. Proclamation Recognizing the Daughters of the American Revolution on its 75th Anniversary (Mayor Tankha)
B. Appointment to the Los Altos Hills Open Space Committee - Eric Bredo (Staff: A.

Miller)
C. Appointment to the Los Altos Hills Youth Committee - Lukas Jarschel (Staff: A.

Miller)
D. Reappointment to the Los Altos Hills Open Space Committee - Richard Contreras (Staff: A. Miller)
E. Appointment of the Cal Cities 2025 Voting Delegate (Staff: A. Miller)

3. PRESENTATIONS FROM THE FLOOR
Persons wishing to address the Council on any subject not on the agenda may do so now. Please complete a Speaker Card located on the back table of the Council Chambers and submit it to the City Clerk. Comments are limited to two (2) minutes per speaker. California law prohibits the Council from acting on items that do not appear on the agenda. Under a Resolution previously adopted by the Council, such items can be referred to staff for appropriate action, which may include placement on the next available agenda.

4. INFORMATIONAL REPORTS (ITEMS PROVIDED SOLELY FOR

INFORMATIONAL PURPOSES)
A. Treasurer's Report (Staff: T. Leung)
B. Disbursement Report (Staff: T. Leung)
ITEM 2A ATTACHMENT 11

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3 City Council Regular Meeting Agenda
March 20, 2025

5. CONSENT CALENDAR
A. Approval of City Council Regular and Special Meeting Minutes of January 30, 2025 (Staff: A. Miller)
B. Approval of the City Council Regular Meeting Minutes of February 20, 2025 (Staff: A. Miller)
C. Second Reading of an Ordinance amending Sections 10-1.202, 10-1.702, and various other associated sections of the Town of Los Altos Hills’ Municipal Ordinance to permit the residential land uses of transitional and supportive housing, residential care, farmworker and employee housing, and single-room occupancy (SROs) and to establish certain objective standards for said uses. (Staff: J.

Bradford)
D. Resolution Granting a Request for Extension of Planning and Appeals Permit at 23691 Camino Hermoso Drive (Staff: J. Bradford)
E. Resolution Awarding a Construction Contract to Smelly Mel’s Plumbing, Inc. for the 2025 Sanitary Sewer Repair and Replacement Project Not to Exceed $720,000, Including Construction Contingency (Staff: D. Liang)
F. Resolution Approving and Authorizing Execution of the Old Ranch Lane Sanitary Sewer Reimbursement Agreement between the Town of Los Altos Hills and William Little and Kathleen Moran Trustees of the Lutz Family Trust (Staff: D.

Liang)
G. Resolution Approving the Plans and Specifications for the Matadero Creek Restoration and Bank Stabilization Project; Authorizing Staff to Advertise the Projects for Formal Bid; and transferring $200,000 from the General Fund Capital Projects Reserve Funds to Supplement the Drainage In-Lieu Funding Source (Staff:

D. Liang)
H. Resolution Authorizing the City Manager to Issue a Request for Proposal for the Annual Landscape Maintenance Services for FY2025-2027 (Staff: W. Kim).

I. Resolution Updating the Cost Sharing Policy For The Construction of Broadband Infrastructure Within Public Ways To Expand Eligibility To Any Internet Service Provider Allowed Within The Town’s Right-Of-Way (Staff: J. Parcutilo) J. Appointment of Council Member George Tyson to the Ad Hoc Committee for the Sewer Project, serving alongside Mayor Tankha as a City Council liaison. (Staff:

W.Kim)
ITEM 2A ATTACHMENT 11

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4 City Council Regular Meeting Agenda
March 20, 2025

K. Approval of Joint City Council and Finance and Investment Committee Meeting to discuss the FY25-26 Proposed Budget on Thursday, May 22, 2025, at 4 pm (Staff:

T. Leung)
L. Resolution Adopting the CalPERS 457 Plan (Staff: T. Leung)

6. ONGOING BUSINESS

A. City Council recommendation on Housing Element Amendments inclusive of modifications to the General Plan, Land Use Element, Proposed Zoning, and Incentives (Staff: J. Bradford)

7. PUBLIC HEARINGS
 City Council Ex Parte Contacts Policy Disclosure

A. This item has been continued to a date uncertain - Adopt resolutions making findings and deny applications for residential development projects to construct multi-family senior residential developments consisting of 55 and 57 dwelling units on a vacant parcel at 10728 and 10758 Mora Drive, respectively (Nos. CDP23- 0001 and 0002) pursuant to Government Code section 65589.5(d). (Staff: S.

Mattas)

8. NEW BUSINESS
A. Resolution Granting the Extension Request for Building Permits at 26700 Palo Hills Drive (Staff: J. Bradford)

9. REPORTS FROM COMMITTEES, SUB-COMMITTEES, AND

COUNCILMEMBERS ON OUTSIDE AGENCIES
A. Ad Hoc Housing Element Committee Update and Development Agreement Update (Vice Mayor Bhateja and Councilmember Mok)

10. STAFF REPORTS
A. City Attorney
B. City Clerk
C. Planning Director
D. Finance Director
ITEM 2A ATTACHMENT 11

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5 City Council Regular Meeting Agenda
March 20, 2025
E. Public Works Director
F. City Manager

11. COUNCIL INITIATED ITEMS
A. Authorization to Send a Letter to Fremont Hills Country Club Regarding the Historic Landmark Application for the Water Tower (Council Member Swan) B. Discussion and Consideration of a Free Trial for a Speed Alert Device to Address Excessive Speeding on Town Roads (Vice Mayor Bhateja)

12. ADJOURN
Pursuant to Ordinance No. 506, the Council Meeting shall adjourn no later than 10:00 p.m., unless otherwise approved by a majority of the Councilmembers present.

ASSISTANCE FOR PERSONS WITH DISABILITIES
In compliance with the Americans with Disabilities Act, if you need special assistance to participate in the meeting, please contact the City Clerk at 650-941-7222. Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting.

Copies of all agenda reports and supporting data are available for inspection at Town Hall, 26379 Fremont Road and the Los Altos Main Library 72 hours in advance of the meeting. A complete agenda can be found on the Town’s webpage: http://www.losaltoshills.ca.gov. A complete packet of information is available for inspection during the meeting at the table to the back of the Council Chambers.

The Council may take action on any agendized matter in any manner deemed appropriate by Council.

ITEM 2A ATTACHMENT 11

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Los Altos Hills Regular and Special City Council Meeting Minutes Page 1 Thursday, January 30, 2025
Town of Los Altos Hills
City Council Regular and Special Meeting Minutes
Thursday, January 30, 2025, at 5:00 P.M.

Council Chambers, 26379 Fremont Road, Los Altos Hills, California

Present: Mayor Kavita Tankha, Vice Mayor Rajiv Bhateja, Council Member Stanley Mok, Council Member Linda Swan, Council Member George Tyson

Absent: None
Staff: City Manager Peter Pirnejad, Deputy City Manager Cody Einfalt, Community Development Director Jay Bradford, Public Works Director WooJae Kim, Finance Director Thomas Leung, and City Clerk Arika Birdsong-Miller CALL TO ORDER (5:00 P.M.)
Mayor Tankha called the Regular and Special Meeting to order at 5:00 P.M.

1. ROLL CALL
Mayor Kavita Tankha, Vice Mayor Rajiv Bhateja, Council Member Stanley Mok, Council Member Linda Swan, and Council Member Tyson were present.

2. PUBLIC COMMENT (Public Comment is Limited to Items which are Subject of the Special Meeting) - None

3. ADJOURN TO CLOSED SESSION TO DISCUSS THE FOLLOWING:

The City Council adjourned to a Closed Session to discuss the following:

Conference with Legal Counsel – Existing Litigation
(Pursuant to Government Code Section 54956.9(d)(1)
Linebarger v. Town of Los Altos Hills, Case No. 2015-1-CV-282970 Conference with Legal Counsel – Anticipated Litigation
(Pursuant to Government Code Section 54956.9(d)(2)
Significant Exposure to Litigation – Two Cases
3A. ADJOURN CLOSED SESSION
Mayor Tankha adjourned to Closed Session at 5:03 PM.
3B. REPORT OUT OF CLOSED SESSION
Attorney Steve Mattas reported no reportable action from the Closed Session.

4. ADJOURN
The meeting was adjourned.

CALL TO ORDER
ITEM 2A ATTACHMENT 11

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Los Altos Hills Regular and Special City Council Meeting Minutes Page 2 Thursday, January 30, 2025
Mayor Tankha called the City Council Regular Meeting for Thursday, January 30, 2025, to Order at 6:00 PM.

ROLL CALL
Mayor Kavita Tankha, Vice Mayor Rajiv Bhateja, Council Member Stanley Mok, Council Member Linda Swan, and Council Member Tyson were present.

5. PLEDGE OF ALLEGIANCE- Recited

6. AGENDA REVIEW
Vice Mayor Bhateja made a motion to remove Item 10A from the agenda, Council Member Swan seconded the motion. The motion passed with a unanimous vote of 5-0.

Council Member Mok made a motion to consider Item 10A at a later date. The motion failed due to a lack of a second.

7. INFORMATIONAL REPORTS (items provided solely for informational purposes) A. Treasurer’s Report – This item is provided solely for informational purposes.

B. Disbursement Report - This item is provided solely for informational purposes.

8. PRESENTATIONS FROM THE FLOOR

1. Namrata, a resident of Los Altos Hills, questioned why Item 10A was removed from consideration.

2. Karthik Kannan, a resident of Los Altos Hills, asked how the Town would meet the housing requirement.

3. Hari Sankar, a resident of Los Altos Hills, thanked the Mayor and City Council for listening to the concerns of residents and taking action. Mr. Sankar explained that he is looking forward to more collaborating between the Council and residents.

4. TT Ramgopal, a resident of Los Altos Hills, stated that he is happy that the formation of the Housing Element Subcommittee is on this agenda.

5. John O’Connell, a resident of Los Altos Hills, expressed that by having a certified Housing Element and not considering the Key Terms Agreement (Item 10A) the Town avoided a big mess.

6. Rafa Somerfield stated that while the Town can propose a Housing Element Amendment, it must be approved by the state.

9. PUBLIC HEARING
A. Adopt resolutions making findings and deny applications for residential development projects to construct multi-family senior residential developments consisting of 55 and 57 dwelling units on a vacant parcel at 10728 and 10758 Mora Drive, respectively (Nos. CDP23- 0001 and 0002) pursuant to Government Code section 65589.5(d).

Attorney Mattas explained to the Council that the applicant, Mr. Linebarger, had submitted new plans in the hours leading up to the meeting and that staff needed time to review them.

Mayor Tankha opened the Public Hearing for comments on this item.

ITEM 2A ATTACHMENT 11

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Los Altos Hills Regular and Special City Council Meeting Minutes Page 3 Thursday, January 30, 2025
There were no comments.

Vice Mayor Bhateja made a motion to defer this item to the March 20, 2025, Regular City Council Meeting. Council Member Swan seconded the motion. The motion passed with a unanimous vote of 5-0.

MOTION PASSED 5-0:

AYES: Tankha, Bhateja, Mok, Swan, Tyson
NOES: None
ABSTAIN: None
RECUSE: None
ABSENT: None

10. NEW BUSINESS
A. Consideration and adoption of resolution to approve a key term agreement between the Town of Los Altos Hills, Sea Landing, LP and Draco Nest, LLC related to a potential: (1) Development Agreement limiting residential development on the approximately 13.5 acres of Draco Nest, LLC owned land on the Twin Oaks property (APN Nos. 182-02 017, 182-02- 018, 182-02-019, 182-02-020, 182-02-021, and 182-02-022), (2) Housing element amendment for the Twin Oaks property, (3) Fence permit for the portion of the Twin Oaks property owned by Draco Nest, LLC and for the adjacent approximately 40-acre parcel owned by Sea Landing, LP (APN No. 182-02-016), (4) Removal and imposition of easements related to the portion of the Twin Oaks property owned by Draco Nest, LLC and for the adjacent approximately 40-acre parcel owned by Sea Landing, LP, (5) Farm uses on the non-residential portions of the Twin Oaks property owned by Draco Nest, LLC and the adjacent approximately 40-acre parcel owned by Sea Landing, LP, and potential single family residential use on 17 acres of approximately 40-acre parcel owned by Sea Landing, LP.
*THIS ITEM WAS REMOVED FROM THE AGENDA.

B. Discussion and Formation of the Housing Element Subcommittee/Ad Hoc Committee.

Public Comments:

1. Jim Waschura, a resident of Los Altos Hills, volunteered his help with the Housing Element Subcommittee/Ad Hoc Committee

2. Birgitta Indaco, a resident of Los Altos Hills, volunteered his help with the Housing Element Subcommittee/Ad Hoc Committee

3. John O’Connell, a resident of Los Altos Hills, suggested creating two Ad Hoc Committees, one composed of two City Council Members and another one composed of two Planning Commissioners

4. Carol Gottlieb, a resident of Los Altos Hills, suggested creating a Standing Committee that would allow more input from citizens.

5. Jitze Couperus, a resident of Los Altos Hills, suggests an Ad Hoc Committee or Subcommittee as long as both the Planning Commissioner and residents get to have input
ITEM 2A ATTACHMENT 11

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Los Altos Hills Regular and Special City Council Meeting Minutes Page 4 Thursday, January 30, 2025
Council Member Swan made a motion to appoint Vice Mayor Bhateja and Council Member Mok to the Housing Element Ad Hoc Committee. Council Member Tyson seconded the motion. The motion passed with a unanimous vote of 5-0.

MOTION PASSED 5-0:

AYES: Tankha, Bhateja, Mok, Swan, Tyson
NOES: None
ABSTAIN: None
RECUSE: None
ABSENT: None

11. ONGOING BUSINESS
A. Receive Council Direction on The Town’s Supplemental Public Safety Services – Specifically the Agreements with Flock Safety’s ALPR System and PalAmerican Private Security Patrols
Flock Safety’s ALPR System
Deputy City Manager Cody Einfalt explained that in April 2021, the Town entered into a contract with Flock Safety for the installation and maintenance of 40 ALPR cameras throughout the Town. The initial term of the contract was 12 months with a renewal period of 24 months. The current term of the contract is set to expire March 31, 2025.

Recently, Town staff was notified that Flock Safety intends to increase the annual cost of the cameras at the next renewal date for the Town – April 1, 2025. Under the current contract, the cameras cost $2,500/camera (or $100,000 annually for 40 cameras), however, Flock has raised the price per camera to $3,000/camera (or $120,000 annually for 40 cameras) should the Town renew the agreement.

For the current budget cycle (FY24-25), staff only budgeted $100,000 for this contract.

Given this price change, Staff began working with the Technology Committee to review the Town’s ALPR system. At the December 11, 2024, Technology Committee meeting the Committee passed a motion to recommend reducing the Town’s ALPR system down by nine cameras, from 40 to 31.

The Committee’s rationale behind reducing the ALPR cameras was to keep cameras at all entrances to the Town but remove cameras that are entirely in the interior. That way, every entrance is still covered (with some very slight exceptions) so that no vehicle can come into Town without passing an ALPR. Nine cameras fit this description.

Deputy City Manager Einfalt further explained that The Sheriff’s Office dedicated a large portion of hours in 2021 and 2022 to the Town’s ALPR system given the time needed for the cameras to be integrated into the processes of the Sheriff’s Office and the training that was needed on the platform. Investigated hours dedicated to the ALPR system have tapered off in 2023 and 2024 but remain higher than what detectives were billing before the introduction of the system into the Town pre-2021.

Should the City Council move forward with the Technology Committee’s recommendation of ITEM 2A ATTACHMENT 11

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reducing the number of ALPR cameras by nine cameras, from 40 to 31, the annual price to the Town would reduce to $93,000 per year and no additional funds would need to be appropriated. Staff would recommend a three-year agreement to lock in pricing.

On the other hand, should the City Council renew the Town’s lease for all 40 current ALPR cameras, the new contract amount would be $120,000. Therefore, the council would need to an additional $20,000 this fiscal year. Based on that direction staff would incorporate the remaining portion of the contract into the next budget cycle (FY 2024-25).

Separately, the staff is researching an option to allow residents to privately fund ALPR cameras in their neighborhoods and have those cameras managed by the Sheriff’s Office. It is unclear at this time how much oversight the Sheriff’s Office could provide for privately funded cameras; however, staff will report back on this effort when more is known.

Public Comments:

1. Jim Waschura, a resident of Los Altos Hills, explains that he wonders if spending $1 million dollars is helping reduce crime.

2. Sasha Zbrizek, a resident of Los Altos Hills, would like to see the FLOCK camera system canceled.

Council Member Tyson made a motion to approve the FLOCK camera system, reducing the number of cameras to 31. Council Member Mok seconded the motion. The motion passed with a unanimous vote of 5-0.

MOTION PASSED 5-0:

AYES: Tankha, Bhateja, Mok, Swan, Tyson
NOES: None
ABSTAIN: None
RECUSE: None
ABSENT: None
PalAmerican Private Security Patrols
Deputy City Manager Cody Einfalt explained that in April of 2023, the Town entered into an agreement with PalAmerican (previously known as Genesis Safety) for private security patrols of the Town’s streets. The Town started with 2 shifts per day for 7 days a week.

In response to the uptick in residential burglaries in September 2023, the Town increased the number of patrols from 2 shifts a day to 4 shifts a day for 7 days a week, including holidays.

The City Council took action to expand the service level and during the budget process appropriated the funding for the enhanced private security detail through the end of FY 23-24.

Patrol services have remained at 4 shifts a day, 7 days a week, since September 2023.

Although the council approved both the enhanced scope and allocated the funding, Town staff recently became aware that the private security contract was not renewed. The Town has been operating past the term of the contract (expired June 31, 2024). Staff wanted to bring this to the Council attention as soon as we realized the error but considering the Council had authorized the current service level and adopted the budget in June, Town staff continued to honor the ITEM 2A ATTACHMENT 11

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expired permit until we could agendize a more comprehensive conversation about public safety with the Council.

Town staff has continued to pay the monthly invoices on the contract until the Council could discuss this agreement alongside the expiring ALPR contract. Acting on this contract independent of a larger discussion would limit the Council’s options.

It should be noted that if the Council decides to extend the PalAmerican agreement at the current rate (four, 8-hour patrol shifts a day), the following would be the amount billed to the Town:
224 hours per week x $54.00 per. hour = $12,096.00 /per week or $628,992 annually Holidays: ~7 days recognized = $6,048 Annually
Total Annually: $635,040
Currently, the Town budgeted $550,000 for FY 24-25 for private security services, similar to the previous fiscal year (FY23-24). However, what was missed was the fact that in the beginning of FY 23-24, only two patrol shifts were occurring in Town for a couple months and holidays did not have extra patrols (as they do now).

At the conclusion of December, halfway through the FY24-25 budget cycle, the Town has spent roughly $317,000 on private security patrols. In reviewing the remaining public safety budget at this halfway point (which includes funding for the base services from the Sheriff and all the supplemental public safety services), staff anticipate needing approximately $65,000 of additional funds to maintain 4 private security patrol shifts through June 30, 2024. If the Council were to choose to continue this level of service it would require, we accommodate approximately $635,040 into next year’s budget (FY 2025-26), or an increase of $85,040 over the previous year’s budget for private security patrols with PalAmerican.

An option the Council can consider is reducing the number of shifts per day by 1 officer during the overlap period of 12:00 pm – 8:30 pm. This would result in the following schedule:
6:30 am – 3:00 pm (1 patrol officer)
12:00 pm – 8:30 pm (1 patrol officer)
3:00 pm – 11:30 pm (1 patrol officer)
Reducing the patrols by one officer would reduce the contract by roughly $160,000 annually.

Making this reduction would not require any additional funds to be appropriated in FY24/25, keeping the contract in budget.

Deputy City Manager Einfalt stated that staff would recommend a one-year renewal agreement with PalAmerican so that the Town can review this contract on an annual basis.

Council Member Tyson noted that during the goal-setting session, the Council added new priorities to the workload, including emergency notification, home ignition zones, and the housing element. While he supports these additions, he acknowledged that the Town ended the previous year with a planned deficit, which was barely balanced.

Given the increased workload, he emphasized the need to identify areas for budget cuts.

Council Member Tyson stated that he ultimately supports the staff’s recommendation to reduce ITEM 2A ATTACHMENT 11

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funding for PalAmerican security services. While he has never been fully convinced of the value of private security based on the available data, he was hesitant to eliminate it entirely.

Instead, he supported reducing one security shift and adjusting patrol times for better effectiveness.

Council Member Tyson recognized the deterrent aspect of private security but questioned its overall necessity. His recommendation was to remain within budget while creating a financial cushion to support other priorities, particularly fire safety initiatives and the housing element.

Council Member Mok reiterated that crime rates remain low and have been consistently monitored. Given this, he questioned the necessity of maintaining the current level of private security.

Council Member Mok proposed reducing a security shift from two personnel to one, estimating an annual savings of $160,000. He acknowledged that if this decision proved ineffective, the service could be reinstated.

Council Member Mok emphasized the financial challenges ahead, noting that the Town cannot sustain ongoing extra expenses, especially after increasing the budget by $1 million annually.

He recommended a measured approach of continued monitoring and adjustments, supporting the reduction of private security staffing to one person per shift.

Council Member Swan reflected on comments made by Jim Waschura, noting that the high burglary rates occurred during the pandemic when crime was affecting many areas. She pointed out that burglary rates have since declined in neighboring cities, some of which did not implement private security measures.

Given this context, Council Member Swan supported reducing private security by at least a third, emphasizing that it could always be reinstated if needed. She highlighted the Town's other pressing priorities, including fire safety, infrastructure, and the long-standing concerns about the bridge on Page Mill.

Council Member Swan questioned whether private security had a meaningful impact on crime reduction or if crime rates would have naturally declined due to economic and post-pandemic changes. Based on these considerations, she advocated for making even deeper cuts to private security funding.

Vice Mayor Bhateja highlighted that in 2023, the Town initially projected a higher burglary rate, but the actual number of incidents dropped after private security patrols increased in October. He attributed this decline to the presence of private security rather than Automated License Plate Readers (ALPRs), despite being a strong advocate for ALPR technology.

While acknowledging the Town’s current budget challenges, Vice Mayor Bhateja emphasized that private security provides greater value compared to the sheriff’s department. Based on his ride-along experience, he noted that sheriff’s deputies serve both Los Altos Hills and neighboring unincorporated areas, often needing to leave Town for reports or emergencies elsewhere. In contrast, private security is dedicated solely to Los Altos Hills, making them a more effective deterrent.

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Vice Mayor Bhateja stated that he would reluctantly support a reduction in private security from four to three patrol officers per shift, considering the budget constraints. However, he opposed any further cuts, arguing that private security is significantly more cost-effective than increasing sheriff’s patrols.

Mayor Tankha expressed reluctance about reducing private security but stated she would support a reduction of one patrol officer. She emphasized that safety is the most important assurance the Town can provide to its residents.

While acknowledging the Town's various expenditures, Mayor Tankha noted that the $160,000 savings from reducing private security is relatively small in the broader budget. Ultimately, she was willing to support reducing patrols to three officers per shift.

Council Member Swan reviewed the private security patrol schedule and noted significant overlap in coverage, particularly between 12:00 PM and 3:00 PM, which she suggested was not a peak burglary time.

Council Member Swan also referenced crime data from other cities, noting that burglary rates declined across the board from 2022, even in cities without private security. Given this context, she supported reducing private patrol staffing, suggesting a minimum reduction to three officers while considering potential schedule adjustments to maximize coverage during peak hours.

Public Comments:

1. Nick French, a resident of Los Altos Hills, stated that he appreciates everything the City Council does.

2. Allan Epstein, a resident of Los Altos Hills, explained that he believes decreasing the number of patrol officers is the right move.

3. Sasha Zbrozek, a resident of Los Altos Hills, stated that the funds we use for private security could be used to subsidize alarm systems in citizen’s homes.

4. Jitze Couperus, a resident of Los Altos Hills, stated that he is surprised that private security is more effective than the Flock Safety ALPR System.

5. Carol Gottlieb, a resident of Los Altos Hills, informed the Council that the neighborhood with its own private security pays about $2,000 per year per house.

Vice Mayor Bhateja made a motion to approve the PalAmerican Private Security Patrols, reducing the number to 3 patrol shifts per day with an increase in patrol on holidays. Mayor Tankha seconded the motion. The motion was approved by a vote of 4-1. Council Member Swan voted in opposition.

MOTION PASSED 4-1:

AYES: Tankha, Bhateja, Mok, Tyson
NOES: Swan
ABSTAIN: None
RECUSE: None
ABSENT: None
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12. REPORTS FROM COMMITTEES, SUB-COMMITTEES, AND COUNCIL

MEMBERS ON OUTSIDE AGENCIES
A. Council Member Tyson gave an update on the Undergrounding Rule 20A project and stated that the project is largely complete and PG&E will begin their portion next week.

13. COUNCIL INITIATED ITEMS
A. Request to Collaborate with the City of Monte Sereno and the Town of Los Altos Hills on Finance and Accounting.

Council Member Swan explained that the City of Monte Sereno has requested the Town’s help. The City of Monte Sereno would benefit from assistance from the Town of Los Altos Hills Finance and Accounting Department.

The Council did not reach a consensus for this item to move forward.

14. STAFF REPORTS
A. City Attorney Steve Mattas had no report.

B. City Clerk Arika Miller explained that the new electronic voting system will be implemented for City Council Meetings soon as the software was purchased earlier this week.

C. Community Development Director Jay Bradford had no report.

D. Public Works Director WooJae Kim reported the following:

Saddle Mountain to Stirrup Way Pathway:

This week, Town maintenance staff installed a 5’ wide off-road pathway, over 500 feet long, connecting existing pathway segments from Saddle Court, Berry Hill Court, and Stirrup Way. The Town maintenance Staff will finalize the fine grading of the path after the rainy season in April or May.

Heritage House Upgrade:

Heritage House Upgrade project is progressing. Staff has encountered numerous unforeseen issues during construction such as abatement of more than anticipated lead paint from walls and ceilings, termite and dry rot issues, camber or deflections on ceiling joists due to the age of the building, and more. The change order issued is already almost 10% of the contract amount, and there will likely be more changes orders. The project team is move forward to meet the CDBG deadlines, and making sure the project stays under the contract amount authorized by the City Council.

El Monte Fire Station Utility Undergrounding (Rule 20A):

El Monte Fire Station Utility Undergrounding (or Rule 20A) project is progressing well and on schedule. The construction of the joint trench infrastructure is almost complete. PG&E is scheduled to start their overhead utility conversion to underground through the joint trench next week. Their conversion work will take about three months to be followed by Comcast and AT&T’s overhead conversion work. If all goes well, we are anticipating fall 2025 for the full overhead to underground conversion and removal of the electrical poles within the Utility Underground District.

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Sal Bissada – Public Works Inspector:

Sal Bissada started as the new full-time Public Works Inspector earlier this month.

Last year, through the budget process, Council approved this new position for the Town. In the past, Public Works inspection services were contracted out or managed by Town engineers. Sal will be working on encroachment permits, capital improvement projects, tree surveys, erosion control inspections, and number of other tasks. Sal has extensive experience in construction, contracting, and project management.

Eusebio Garcia – Maintenance Worker:

Eusebio Garcia is our newest member of the maintenance team. He worked as the Town’s temporary maintenance worker in 2023 and 2024. Through a thorough recruitment process, Eusebio was hired to fill a full-time Maintenance Worker vacancy. Eusebio has proven himself as a diligent and skillful worker during his temporary post. He has experience in grading, concrete work, and landscaping.

E. Finance Director Thomas Leung explained the following:

Malia Siulangapo, who has been with the Town for more than a year as a consultant, was also recently hired by the Town of Los Altos Hills. With this new hire, the Finance Department is now fully staffed.

F. City Manager Peter Pirnejad presented the following:
• Landscape lighting is being upgraded outside the council chambers to provide better viability for people walking to their cars

• Headshots were taken of our new Councilmember today. The website will be updated with new pictures and info on liaisons and assignments to outside agencies

• Staff is kicking off the process of assembling the Town’s next 3-year IT strategic plan. We have reached out to the Tech Committee to get on their next Committee agenda to talk about the process

• On February 13th from 8:30am-noon, Town Hall will be closed for staff to conduct an emergency tabletop drill. Members from the County Office of Emergency Management, and the LAH County Fire District will be in attendance. This exercise will mimic how the Town’s EOC will function in the case of an emergency.

• One of our very own LAH residents has been directly impacted by the Palisades Fire and is willing to speak and share her tragic experience with us.  She is one of our Firewise Community Leads for Dawson LAH-015. and hopes to encourage more residents to become active members of the Firewise USA® program. Please join us this Sunday, Feb.2, 2025 at Town Hall at 2pm for a public in person meeting open to all LAH residents.

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• Congratulations to Neighborhood Watch Zone #16. They had their orientation this past weekend with the Sheriff’s Office and are up and operational. This marks 23 Neighborhood Watch zones across Town
• We sent out invitations for our upcoming Newcomers Event on March 2nd! Held every two years, this gathering welcomes all residents who have recently moved into town. It’s a great opportunity to meet neighbors, learn more about the community, and discover ways to get involved.
• The Santa Clara County Fire Department (SCCFD) is preparing to mail, on February 14th, the annual Wildland Urban Interface (WUI) enforced safety regulations letters to Los Altos Hills property owners who live in designated fire hazard severity zones. Please keep an eye out in the mail for these letters which will have information on what property owners will need to do to keep their property in compliance.

15. ADJOURN
The meeting was adjourned at 8:35 P.M.

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 **VIA EMAIL ONLY**
February 28, 2025
Forrest Linebarger
785 Castro Street, Suite A
Mountain View, CA 94041
Via email at [email protected]
RE: Resubmittal of Senior Residential Development Project 10728 Mora Drive
File # CDP23-0001
Dear Mr. Linebarger:

Thank you for resubmitting plansfor the above referenced senior residential development project located at 10728 Mora Drive (“Project”), received by the Town for review and processing on January 30 and February 25, 2025. Based on staff’sreview of both plans submitted, it appears that they are substantially similar. As stated in your January 30, and February 25, 2025 correspondences, you are revising the Project pursuant to Government Code section 65589.5(f)(7) to subject the Project to the provisions of that statute applicable as of January 1, 2025. The Town thus provides this comment letter in response to your resubmittals. This letter is not a final determination or decision regarding the Project. Staff is continuing to review the materials you provided and will forward any additional comments within 30 days from your February 25, 2025 submission. Any final determinations or decisions will be made in accordance with Government Code sections 65589.5 and 65589.5.1 and the applicable and requisite timelines contained therein.

PLANNING COMMENTS
The Town has identified items on the submitted plans that are incomplete or require further correction/clarifications. Please address or revise the plans based on the following comments:

1. The February 25, 2025 plans do not show unit sizes for the residential units proposed, whereas the January 30, 2025 plans included unit sizes. Please provide unit size information for the residential units proposed on the February 25 plans or confirm that the unit sizes remain the same as shown on the January 30, 2025 plans.

2. The highest sectional height is shown to be 81 feet 9-inches (north elevation, sheet A2.1) ITEM 2A ATTACHMENT 12

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 which is not consistent with the maximum height shown on section A-A on sheet A3.1.

Please make any necessary corrections to heights shown on elevations and section A-A.

3. Provide light reflectivity values for proposed exterior finishes. Color sample C appears to have a LRV greater than 40.

4. Please clarify how the Project density and affordability are calculated under Government Code section 65589.5 including subdivisions (f)(6)(C) and (h)(11)(C)(i)(I) and Government Code section 65915. Additionally, the number of units in the Proposed Land Uses Table on Sheet CO is 45. Therefore, the total market rate units in the Density Calculations Table should be 42 since three of the units are shown to be extremely low-income units. Please also correct the reference on Sheet CO to “Section 65589.5”.

ADDITIONAL PROJECT COMMENTS
Building Department Preliminary Review
• Review of the resubmittal is still in progress. Comments will be forwarded when the review is completed or by March 27, 2025.

Fire Department Review
• Santa Clara County Fire Department review is still in progress. Comments will be forwarded when received.

CONSISTENCY DETERMINATION
This section of the Comment Letter is provided pursuant to Government Code section 65589.5(j)(2)(A). Pursuant to the Town’s prior Consistency Review Comment Letter dated August 31, 2023, 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. Upon review of the January 30 and February 25, 2025 submittal, the revised project continues to be inconsistent with the following:
(1) Zoning Designation for the parcel;
(2) Lot size requirement (a Conditional Development Permit is required); (3) Development standards under Title 10, Chapter 1 of the Municipal Code; and (4) General Plan standards and policies.

These inconsistencies are described in greater detail in the Town’s August 31, 2023 Consistency Determination Letter, included as Attachment 1. Recognizing the Project density has been modified, the consistency determinations in that letter continue to apply.

ITEM 2A ATTACHMENT 12

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160

ENVIRONMENTAL REVIEW
As previously stated in the last comment letter dated December 21, 2023, this Project is not a ministerial project and is not exempt from the California Environmental Quality Act (“CEQA”) on that claim. The Town has instead determined, pursuant to Public Resources Code section 21080.1 and related CEQA Guidelines, that the proposed development is an activity subject to CEQA and may have a significant effect on the environment.1 The Town is required to consider all phases of the proposed Project including planning, operation, and implementation. 2It is expected 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.3 An Initial Study will need to be conducted for the project in order to determine the specific environmental analysis required.4 The Town is required to consider and adopt the proposed Mitigated Negative Declaration or consider and certify the Environmental Impact Report prepared for the Project, prior to making a decision on the project and make findings regarding the Project’s environmental impacts.5 The highest approving body making a decision on the proposed Project will be making the environmental determination and findings under CEQA.

Similarly, you were previously advised on December 21, 2023 that the Town has not moved forward with environmental review because there are outstanding Santa Clara County Fire Department comments which could result in changes to the scope of the Project. It is staff’s understanding that in order for the Project to address outstanding comments regarding fire road access distance requirements, 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. Until there is certainty that the building footprint and building size and the project is in compliance with Fire Department requirements, the Town is not able to commence environmental review.

Finally, you were previously advised that an Initial Study, once ready to commence, will be conducted by the Town and prepared by a third-party consultant retained by the Town. The applicant is responsible for all costs and expenses in conducting the Initial Study as well as all technical studies required for environmental review, including but not limited to traffic analysis.

The environmental review fee to be paid by the applicant will be based on actual cost to prepare the work based on an approved proposal from an outside consultant plus a 10% administrative fee to cover staff time in accordance with the Town’s adopted fee schedule. At commencement of the study, a cost estimate will be obtained from a qualified environmental review firm.

The Town will review your supplemental submissions and the entirety of the record as it conducts 1 CEQA Guidelines section 15060.
2 CEQA Guidelines section 15063.
3 Public Resources Code sections 21080.1-21080.3.
4 CEQA Guidelines section 15063.
5 Gov. Code section 65589.5(e); CEQA Guidelines sections 15074, 15090, 15091.

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 environmental review. However, as a preliminary matter, the Town disagrees with the conclusion asserted in your February 25 supplemental submission that there is substantial evidence in the record to demonstrate that Project, located in a suburban area on a site zoned for residential and agricultural uses and which proposes unusually high density and development intensity, qualifies for a Class 32 in-fill development exemption. Likewise, the Town disagrees with your claims that the Project 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. The Town further disagrees with your claim that the supplemental memorandum provided by RCH Group and Sicular Environmental Consulting provided substantial evidence to support your forgoing assertions. It should be noted that Government Code section 65589.5.1(c) specifies that statute is not to be construed as requiring a local agency to determine that a project is exempt if, on the record before the local agency, the project is not eligible for exemption.

COMMENTS RELATING TO PROJECT NOTICES
The Town received your “90-Day Notice Pursuant to AB 1633” prepared by Brian O’Neill (the “Notice”) and its attachments with your February 25, 2025 supplemental submission. At the outset, the Notice appears to be untimely under Government Code section 65589.5.1(a)(5)(E) and (F).

Notwithstanding the foregoing, out of an abundance of caution without forfeiting the timeliness issue, and also as a courtesy, this Notice and its attachments will be published on the Town’s website, filed with the Santa Clara County Clerk’s Office, and provided to individuals who made a written request for notices pursuant to subdivision (f) of Section 21167 of the Public Resources Code, within five working days from the date of receipt in accordance with Government Code section 65589.5.1.

The Town continues to review the Notice and the attachments as to their merits. The Town will consider all objections, comments, evidence, and concerns about the Project or the Notice in accordance with Government Code section 65589.5.1. As stated above, these comments do not constitute a final determination or decision regarding the Project. Any final determinations or decisions will be made in accordance with Government Code sections 65589.5 and 65589.5.1 and the applicable and requisite timelines contained therein.

Finally, the Town would like to take this opportunity to clarify that the Town has timely processed your submittals and provided abundant public hearing notices with regards to the consideration of the Project. The Town timely reviewed and responded to your Project submittals since their initial delivery on February 1, 2023. Before the January 30, 2025 public hearing was scheduled, the last set of plans was received by the Town on November 30, 2023 with no responses from you to address timely provided Town plan review and environmental analysis comments for well over a year. Thereafter, you were first advised of the potential hearing during an in-person meeting with the Town on January 17, 2025, well in advance of the previously scheduled January 30, 2025 public hearing. The Town mailed the public hearing notice for the January 30 hearing to your address on the County Assessor’s office property tax roll and posted physical notices at the Project site, both on January 19, 2025 and also well in advance of the hearing. The Town also overnight mailed and emailed public hearing notices to your second address on the application on January ITEM 2A ATTACHMENT 12

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 27 and 28, 2025. The Town has thus committed substantial efforts to maintain responsiveness and communication with you on its Project review and consideration.

I can be contacted by e-mail at [email protected] if you have any questions.

Sincerely,
Suzanne Avila
Suzanne Avila, AICP
Consultant Principal Planner
Attachment:

1. August 31, 2023 Consistency Determination Letter
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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 s
**VIA EMAIL ONLY**
February 28, 2025
Forrest Linebarger
785 Castro Street, Suite A
Mountain View, CA 94041
Via email at [email protected]
RE: Resubmittal of Senior Residential Development Project 10758 Mora Drive
File # CDP23-0002
Dear Mr. Linebarger:

Thank you for resubmitting plansfor the above referenced senior residential development project located at 10758 Mora Drive (“Project”), received by the Town for review and processing on January 30 and February 25, 2025. Based on our review of both plans submitted, it appears that they are substantially similar. As stated in your January 30, and February 25, 2025 correspondences, you are revising the Project pursuant to Government Code section 65589.5(f)(7) to subject the Project to the provisions of that statute applicable as of January 1, 2025. The Town thus provides this comment letter in response to your resubmittals. This letter is not a final determination or decision regarding the Project. Staff continues to review the materials you provided and will forward any additional comments within 30 days from your February 25, 2025 submission. Any final determinations or decisions will be made in accordance with Government Code sections 65589.5 and 65589.5.1 and the applicable and requisite timelines contained therein.

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2. The highest sectional height is shown to be 83 feet 5-inches (south elevation, sheet A2.1) which is not consistent with the maximum height shown on section A-A on sheet A3.1.

Please make any necessary corrections to heights shown on elevations and section A-A.

3. Provide light reflectivity values for proposed exterior finishes. Color sample C appears to have a LRV greater than 40.

4. Please clarify how the Project density and affordability are calculated under Government Code section 65589.5 including subdivisions(h)(11)(C)(i)(I) and (f)(6)(C) and Government Code section 65915. Additionally, the number of units in the Proposed Land Uses Table on Sheet CO is 45. Therefore, the total market rate units in the Density Calculations Table should be 42 since three of the units are shown to be extremely low-income units. Please also correct the reference on Sheet CO to “Section 65589.5”.

ADDITIONAL PROJECT COMMENTS
Building Department Preliminary Review
• Review of the resubmittal is still in progress. Comments will be forwarded when the review is completed or by March 27, 2025.

Fire Department Review
• Santa Clara County Fire Department review is still in progress. Comments will be forwarded when received.

CONSISTENCY DETERMINATION
This section of the Comment Letter is provided pursuant to Government Code section 65589.5(j)(2)(A). Pursuant to the Town’s prior Consistency Review Comment Letter dated August 31, 2023, 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. Upon review of the January 30 and February 25, 2025 resubmittals, the revised Project continues to be inconsistent with the following:
(1) Zoning Designation for the parcel;
(2) Lot size requirement (a Conditional Development Permit is required); (3) Development standards under Title 10, Chapter 1 of the Municipal Code; and (4) General Plan standards and policies.

ITEM 2A ATTACHMENT 12

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February 28, 2025

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ENVIRONMENTAL REVIEW
As previously stated in the last comment letter dated December 21, 2023, this Project is not a ministerial project and not exempt from the California Environmental Quality Act (“CEQA”). The Town has instead determined, pursuant to Public Resources Code section 21080.1 and related CEQA Guidelines, that the proposed development is an activity subject to CEQA and may have a significant effect on the environment.1 You were previously advised that the Town has determined that the proposed development does not qualify for an infill exemption or any other statutory or categorical exemption. The Town is required to consider all phases of the proposed Project including planning, operation, and implementation.2It is expected 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. 3 An Initial Study will need to be conducted for the project in order to determine the specific environmental analysis required.4 The Town is required to consider and adopt the proposed Mitigated Negative Declaration or consider and certify the Environmental Impact Report prepared for the Project, prior to making a decision on the project and make findings regarding the Project’s environmental impacts.5 The highest approving body making a decision on the proposed Project will be making the environmental determination and findings under CEQA.

Finally, we previously advised that an Initial Study, once ready to commence, will be conducted by the Town and prepared by a third-party consultant retained by the Town. The applicant is responsible for all costs and expenses in conducting the Initial Study as well as all technical studies required for environmental review, including but not limited to traffic analysis. The environmental review fee to be paid by the applicant will be based on actual cost to prepare the work based on an approved proposal from an outside consultant plus a 10% administrative fee to cover staff time in accordance with the Town’s adopted fee schedule. At commencement of the study, a cost estimate will be obtained from a qualified environmental review firm. 1 CEQA Guidelines section 15060.
2 CEQA Guidelines section 15063.
3 Public Resources Code sections 21080.1-21080.3.
4 CEQA Guidelines section 15063.
5 Gov. Code section 65589.5(e); CEQA Guidelines sections 15074, 15090, 15091.

ITEM 2A ATTACHMENT 12

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The Town will review your supplemental submissions and the entirety of the record as it conducts environmental review. However, as a preliminary matter, the Town disagrees with the conclusion asserted in your February 25 supplemental submission that there is substantial evidence in the record to demonstrate that Project, located in a suburban area on a site zoned for residential and agricultural uses and which proposes unusually high density and development intensity, qualifies for a Class 32 in-fill development exemption. Likewise, the Town disagrees with your claimsthat the Project 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. The Town further disagrees with your claim that the supplemental memorandum provided by RCH Group and Sicular Environmental Consulting provided substantial evidence to support your forgoing assertions. It should be noted that Government Code section 65589.5.1(c) specifies that statute is not to be construed as requiring a local agency to determine that a project is exempt if, on the record before the local agency, the project is not eligible for exemption.

COMMENTS RELATING TO PROJECT NOTICES
The Town received your “90-Day Notice Pursuant to AB 1633” (the “Notice”) and its attachments with your February 25, 2025 supplemental submission. At the outset, the Notice appears to be untimely under Government Code section 65589.5.1(a)(5)(E) and (F). Notwithstanding the foregoing, out of an abundance of caution and also as a courtesy, this Notice and its attachments will be published on the Town’s website, filed with the Santa Clara County Clerk’s Office, and provided to individuals who made a written request for notices pursuant to subdivision (f) of Section 21167 of the Public Resources Code, within five working days from the date of receipt in accordance with Government Code section 65589.5.1.

Finally, the Town would like to take this opportunity to clarify that the Town has timely processed your submittals and provided abundant public hearing notices with regards to the consideration of the Project. The Town timely reviewed and responded to your Project submittals since their initial delivery on February 1, 2023. Before the January 30, 2025 public hearing was scheduled, the last set of plans was received by the Town on November 30, 2023 with no responsesto timely provided Town plan reviewand environmental analysis comments for well over a year. Thereafter, you were first advised of the potential hearing during an in-person meeting with the Town on January 17, 2025, well in advance of the previously scheduled January 30, 2025 public hearing. The Town mailed the public hearing notice for the January 30 hearing to your address on the County Assessor’s office property tax roll and posted physical notices at the Project site, both on January 19, 2025 and also well in advance of the hearing. The Town also overnight mailed and emailed public hearing notices to your second address on the application on January 27 and 28, 2025. The ITEM 2A ATTACHMENT 12

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Town has thus committed substantial efforts to maintain responsiveness and communication with you on our Project review and consideration.

I can be contacted by e-mail at [email protected] if you have any questions.

Sincerely,
Suzanne Avila
Suzanne Avila, AICP
Consultant Principal Planner
Attachment:

1. August 31, 2023 Consistency Determination Letter
5564789.2
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Le er of Transmi al
550 Pilgrim Drive, Foster City, CA 94404 www.csgengr.com phone 650.522.2500
To: Town of Los Altos Hills Date: March 24, 2025 Review No: 1st 26379 Fremont Rd. CSG No.: 4502649
Los Altos Hills, CA 94022 Jurisdic on No. : CDP23‐0001
A n: Building Department Job Address: 10728 Mora Dr.

Job Descrip on:

Preliminary review ‐ New 43 unit mul family residen al development project with parking garage (Version #2) ‐ Linked to CSG #´s 4502651, 4502650, 4502648
Status: Plan requires correc ons. See a ached list. Plan is ready for permit issuance for the following:

Architectural Energy
Structural CalGreen
Mechanical Wildland Urban Interface
Plumbing Cer fied CASp
Electrical Other:
**For plans marked as requiring correc ons, please ensure that all departments and agencies complete their plan reviews before resubmi ng your project directly to the Town of Los Altos Hills for addi onal review.

We have reviewed the following documents (Digital):

X Plans Energy Compliance Documents
Structural Calcula ons CalGreen Checklist – Not Applicable X Geotechnical Report X Specifica ons
Geotechnical Review Le er Wildland Urban Interface
Truss Calcula ons CASp Documents
Truss Review Le er Response to Comments
Special Inspec on Form Other:

Special items to note:

Plans have been stamped by CSG.

Environmental Health Services approval required .

Special Inspec on is required.

Structural Observa on is required.

Valua on
X Please collect a plan review fee for 1.0 hour(s) of plan check.

Remarks:

From: Ted Mirzakhanian, PE, CASp
CSG Consultants
ITEM 2A ATTACHMENT 12

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4502649 Page | 1

TOWN OF LOS ALTOS HILLS

BUILDING DEPARTMENT
Date: March 24, 2025 Phone: 650.522.2552
Job Descrip on:

Preliminary review ‐ New 43 unit mul family residen al
development project with parking garage (Version #2) ‐ Linked to CSG #´s 4502651, 4502650, 4502648 Email: [email protected] Address: 10728 Mora Dr.

Town Permit # : CDP23‐0001

INSTRUCTIONS AND INFORMATION FOR THE NEXT PLAN REVIEW
CSG Consultants Inc. has completed the building permit plan review for this submi al. Please be aware that other departments and agencies may also be reviewing your project. Verify that you have addressed all the departments' and agencies' plan review comments before resubmi ng your project to the Town of Los Altos Hills. To check the status of the reviews by other departments and agencies, you can log into your account on the Town’s portal: h ps://trakit.losaltoshills.ca.gov/etrakit/ . If you haven’t set up an account yet, you can easily do so by reaching out to the Town staff at [email protected].

All resubmi als must be submi ed to the Town of Los Altos Hills.

DO NOT send resubmi als directly to CSG Consultants .

PLAN REVIEW COMMENTS

1. For electronically submi ed plans, please resubmit a complete set of plans and documents upon every resubmi al. Any missing plan sheets, missing stamps and/or signatures (where required) will delay the review process.

Response: ______________________________________________________________________

2. Submit wri en responses addressing each plan review comments below and a summary of changes for any addi onal modifica ons. In each response, r efer to specific detail or sheet, or specific page of the suppor ng documents. Show compliance with all comments within the construc on documents.

Response: ______________________________________________________________________ Architectural Plan Review Comments by |Ted Mirzakhanian, PE, CASp | A1. The following comments point out obvious deficiencies found on the preliminary plans. A complete review will be done upon receipt of complete construc on plans.

Response: ______________________________________________________________________ A2. Sheet CO: Occupancy groups A‐3 , S‐2, and R‐2.1 are not accessory uses to the structure. Aggregate accessory occupancies shall not occupy more than 10 percent of the floor area of the story in which they are located . All the specified occupancies are the main occupancy group within their respec ve floors. (508.2.3 CBC) Revise to primary occupancies.

Response: ______________________________________________________________________ A3. Dining areas including dining at level 1 or at the roo op shall be classified as A‐2 occupancy group , not A‐3 or B as shown on sheet A5.1. Please revise the cover sheet to include A‐2 occupancy group and revise sheet A5.1. (303.3 CBC)
Response: ______________________________________________________________________ A4. Sheet CO: Provide a list of occupancy groups for building A, a list of occupancy groups for Building B, and a list of occupancy groups for the building below the podium.

Response: ______________________________________________________________________ ITEM 2A ATTACHMENT 12

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4502649 Page | 2
A5. The en re Town of Los Altos is in a wildland Urban Interface area. The building shall comply with Chapter 7A CBC requirements.

Response: ______________________________________________________________________ A6. Sheet CO considers the mezzanine as a Type I‐A construc on type, but sheet A5.2 specifies a type III‐A for the mezzanine under the Proposed Occupancy sec on. It appears part of the mezzanine level is Type I‐ A and the other part is Type III‐A based on the loca on of the ver cal offset as shown on sheet A3.1. Please clarify.

Response: ______________________________________________________________________ A7. Sheet A3.1: Clarify the following on plans for use of Sec on 510.2:
a. The building sec on shows a ver cal offset of the 3 hour podium. Clearly show the ver cal offset wall on floor plans corresponding with a Type I‐A construc on.
b. The total occupant load of the roof shall not exceed 299 occupants. The en re roo op is classified as a Group A occupancy. Revised occupant load calcula ons in accordance with Table 1004.5 CBC shall be provided for the roof. Several areas, such as the dining, sea ng, fire pit, kitchen, garden, etc. shall be calculated with a net occupant load factor of 15. The plans show 150 occupants exi ng each stairway regardless of the occupant loads being shown wrong. The 5 th level and roo op A occupancy areas are not allowed.
c. The maximum building height in feet shall not exceed the limits set forth in Sec on 504.3 for the building having the smaller allowable height as measured from the grade plane. Provide a diagram showing the calcula on or the average grade plane to determine the allowable building height. See commentary Figures 202(23) and 202(24) a ached below:

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Response: ______________________________________________________________________ A8. Sheet A5.1: Revise the loca on of the up arrow in stair #2 podium level.

Response: ______________________________________________________________________ A9. Sheet A5.2: Please provide gridlines with sec on and eleva on call‐out references on the floor plans.

Response: ______________________________________________________________________ A10. Every building of any type of construc on or occupancy having floors used for human occupancy located more than 75 feet above the lowest floor level having building access (different from vehicle access). Building access shall be determined in accordance with the following per Chapter 2 CBC:

1.Suitable and available for fire department use.

2.Located not more than 2 feet above the adjacent ground level.

3.Leading to a space, room or area having foot traffic communica on capabili es with the remainder of the building.

4.Designed to permit penetra on through the use of fire department forcible‐entry tools and equipment unless other approved arrangements have been made with the fire authority having jurisdic on.

The Fire Department shall determine if the garage level may qualify as the building access. If a lower level is considered the building access, the building shall be a high‐rise building and shall comply with the applicable high‐rise provisions in the CBC.

Response: ______________________________________________________________________ A11. Plans shall show compliance with R‐2.1 occupancy group in accordance with the following . More code sec ons may apply once more informa on is provided on plans :
a. Plans shall make clear the type of assisted living facility proposed from the list provided in Sec on 310.3.1 CBC. Addi onal comments may apply based on the type of assisted living facility. b. Smoke barriers and ref uge areas where applicable in accordance with 420.6 and 435.5.1 CBC. c. Fire protec on systems in accordance with 435.7. All such systems shall be deferred to the Fire Department. d. Corridor widths in accordance with 435.8.4 CBC.

Response: ______________________________________________________________________ ITEM 2A ATTACHMENT 12

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A12. Sheet A5.2: Building height, number of stories, and areas:
a. Building A has a covered roof and Building B has a shade structure, which classifies it as a covered A‐2/A‐3 occupancy group at the fi h level. Group A occupancies are limited to 4 stories above the podium. The building is 5 stories. Please revise (Table 504.4 CBC). See also Code Sec on for Occupied Roofs 503.1.4 CBC if the roof at fi h above fi h level is removed.
b. There are several notes on the sheet specifying that stairway and elevator sha s are excluded from building area calcula ons. Only open sha s (without a roof on top), such as vent sha s, are allowed to be excluded from building area calcula ons. Include the area of all enclosed sha s and revise building area calcula ons. (Chapter 2 Defini on for “Area, Building”)
c. The Type III‐A building area calcula on is incorrect. It appears a single occupancy building is proposed, which shall give a tabular value of 14,000 square feet for the most restric ve A occupancy group with a Sa value of

3. Clearly determine if Equa on 5‐2 or 5‐3 is proposed and provide the calcula on accordingly. (506 CBC) Response: ______________________________________________________________________ A13. Sheet A4.1: Fire‐retardant‐treated wood is required for wood framing and sheathing in exterior walls in accordance with 2303.2 CBC for a Type III‐A building. (602.3 CBC) Response: ______________________________________________________________________ A14. Sheet A5.2: Plans show the firewall stopping at the 4 th level roof. The firewall shall be con nuous to the 5 th level roof in accordance with Sec on 706.6 CBC. Buildings A and B shall be completely separated by a firewall on all levels.

Response: ______________________________________________________________________ A15. Balconies and other projec ons shall comply with Table 705.2 CBC. This could not be verified from the preliminary drawings. Openings are limited per Table 705.8 CBC. The site plan shows less than 5 ’ from building edge to property line, which only allows 15% of the wall on each floor to have openings that are protected.

Response: ______________________________________________________________________ A16. Means of Egress:
a. Revise occupant load factors such that all rooms and spaces are in accordance with Table 1004.5 CBC.

Several rooms have the incorrect occupant load factor shown. b. The corridor doors at the firewall/horizontal exit on some floor may be required to swing in both direc ons (cross doors) if the occupant load on both sides of the firewall is over 49. (1010.1.2.1 CBC) c. Rooms and areas with 50 or more occupants shall have access to a minimum of 2 exits. The media and dining room at level 1 each need at least 2 exits.
d. The width and capacity of stairway 2 shall consider egress convergence from stories above and below in accordance with Sec on 1005.6 CBC.
e. Provide either a generator for the elevator or a horizontal exit. (1009.2.1 CBC) f. Refuge areas are required to be shown for the horizontal exit. (1026 CBC) g. There is no accessible route from elevator 2 or stair 2 to the public way. The site consists of several exterior stairways, which does not provide an accessible route. The building does not comply with accessible means of egress per Sec on 1009 CBC. See also accessibility comments below. h. Clarify if a ramp is shown to the access door of the laundry and u lity room at the mezzanine level. It appears the door is opening into the ramp slope. Clarify. i. Fire‐resistance‐rated corridors shall be con nuous from the point of entry to an exit, and shall not be interrupted by intervening rooms. Several rooms and spaces are open to the corridor, such as the media and the dining room. (1020.7 CBC)
j. Openings within 10 feet ver cally of the egress courts shall be protected in accordance with 1029.3 CBC. k. The R‐2.1 units do not qualify for the Type III‐A excep on and are required to have emergency egress windows. Fire Department approval is required with respect to access to the court. (1031.2 CBC) Response: ______________________________________________________________________ ITEM 2A ATTACHMENT 12

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A17. Verify the elevator can accommodate a stretcher. (3002.4 CBC) Response: ______________________________________________________________________ Disabled Access Plan Review Comments by |Ted Mirzakhanian, PE, CASp | DA1. Plans shall clearly specify if any public funding is granted for the construc on of the residen al or the assisted living por on of the building. Publicly funded projects shall comply with Chapter 11B. Otherwise, Chapter 11A shall apply to all residen al units (assisted living or otherwise) and to the associated common areas. Rooms and areas that are accessible to assisted living employees or staff shall be regulated under Chapter 11B regardless of Chapter 11A applicability for the rest of the building.

Response: ______________________________________________________________________ DA2. Sheet C5: Stairways along the sides of the property do not provide the required exterior accessible route. An accessible route is a con nuous unobstructed path connec ng accessible elements and spaces of an accessible site, building or facility that can be nego ated by a person with a disability using a wheelchair, and that is also safe for and usable by persons with other disabili es. Interior accessible routes may include corridors, hallways, floors, ramps, elevators and li s. Exterior accessible routes may include parking access aisles, curb ramps, crosswalks at vehicular ways, walks, ramps and li s. See Note at the end of Sec on 1110A.1 for sloped sites. (1110A.1 CBC)
Response: ______________________________________________________________________ DA3. When a building elevator or elevators are provided as a means of access to dwelling units other than dwelling units on a ground floor (see Sec on 1104A.2), the building is an elevator building. All dwelling units become covered mul family dwellings in that building . All dwelling units shall be adaptable.

Response: ______________________________________________________________________ DA4. Accessible parking spaces shall be located so that persons with disabili es are not compelled to wheel or walk behind parked cars other than their own. Plans shall be revised. (1109A.7 CBC) Response: ______________________________________________________________________ DA5. Parking accessibility for the EV spaces shall be in accordance with the Green Building Code.

Response: ______________________________________________________________________ DA6. The sub basement floor has a common use amenity and is required to be on an accessible route. No elevator is provided to this level. Please revise. (1119A.1 CBC)
Response: ______________________________________________________________________ DA7. All common use facili es shall be accessible, including but not limited to, toilet rooms, dining areas, laundry room, roo op swimming pool, mail room, etc. (1127A CBC) Response: ______________________________________________________________________ (End of Building Comments)
ITEM 2A ATTACHMENT 12

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 **VIA EMAIL ONLY**
March 27, 2025
Forrest Linebarger
785 Castro Street, Suite A
Mountain View, CA 94041
Via email at [email protected]
RE: Resubmittal of Senior Residential Development Project 10728 Mora Drive
File # CDP23-0001
Dear Mr. Linebarger:

Thank you for resubmitting revised plans for the above referenced senior residential development project located at 10728 Mora Drive (“Project”),received by the Town for review and processing on February 25, 2025. Based on staff’s review of both plans submitted, it appears that they are substantially similar. As stated in your January 30, and February 25, 2025 correspondences, you are revising the Project pursuant to Government Code section 65589.5(f)(7) to subject the Project to the provisions of that statute applicable as of January 1, 2025. A response letter was provided for the plans received on January 30, 2025. The Town thus provides this comment letter in response to your February 25, 2025 resubmittal as we continue to identify items that require correction or need to be completed on the plans resubmitted.

PLANNING COMMENTS:

The Town has identified items on the submitted plans that are incomplete or require further correction/clarifications. Please address or revise the plans based on the following comments:

2. The highest sectional height is shown to be 81 feet 9-inches (north elevation, sheet A2.1) which is not consistent with the maximum height shown on section A-A on sheet A3.1.

Please make any necessary corrections to heights shown on elevations and section A-A.

ITEM 2A ATTACHMENT 12

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10728 Mora Drive
March 27, 2025

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160

3. Provide light reflectivity values for proposed exterior finishes. Color sample C appears to have a LRV greater than 40.

5. Please upload any future resubmittals to the Town’s portal or submit them in person at Town Hall. In the event of a technical problem with the Town portal, please email [email protected].

6. As the Town has requested previously, please cloud all revisions on the plans or provide a written list of changes. You have submitted three renditions of plans within a short timeframe of each other, which all appear to be substantially similar but with nuanced changes. Clearly marking the changes on these plans with clouding or a written list would facilitate review by the Town and its consultants, as well as third party government agencies. We strongly request your cooperation in having all future resubmittals clouded or provide a list of written changes to avoid any undue administrative burden on the reviewing staff and agencies.

BUILDING COMMENTS:

Please see the attached memorandum from CSG Consultants for detailed building comments.

FIRE DEPARTMENT COMMENTS:

Please see the attached comment letter from Santa Clara County Fire Department for plan review comments.

ITEM 2A ATTACHMENT 12

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March 27, 2025

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 These inconsistencies are described in greater detail in the Town’s August 31, 2023 Consistency Determination Letter which was provided to you with the Town’s response letter dated February 28, 2025. Recognizing the Project density has been modified, the consistency determinations in that letter continue to apply.

ENVIRONMENTAL REVIEW
The Town is in receipt of your correspondence dated March 20, 2025 and will provide a separate response thereto.

I can be contacted by e-mail at [email protected] if you have any questions.

Sincerely,
Suzanne Avila
Suzanne Avila, AICP
Consultant Principal Planner
Attachment:

1. CSG Building Comments dated March 24, 2025

2. Santa Clara County Fire Department Comments dated March 25, 2025 ITEM 2A ATTACHMENT 12

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26379 Fremont Road Los Altos Hills California 94022 Phone (650) 941-7222 Fax: 650/941-3160 April 4, 2025
Brian O’Neill
Patterson & O’Neill, PC
600 California Street, 11th Floor
San Francisco, CA 94108
[email protected]
RE: Response to March 20, 2025 Correspondence for 10728 and 10758 Mor Drive Dear Mr. O’Neill:

This correspondence replies to your letter received by the Town of Los Altos Hills (“Town”) on March 20, 2025 regarding applicant Forrest Linebarger’s proposed senior residential developments at 10728 and 10758 Mora Drive (collectively, the “Project”). In summary, your letter asserts that the Town’s Comment Letter dated February 28, 2025 constituted an abuse of discretion under Government Code section 65589.5.1 and that the Town has made a California Environmental Quality Act (CEQA) determination without taking into account additional supplemental materials submitted by the applicant February 25, 2025. You also claim that the Town’s comments are inconsistent with the Permit Streamlining Act (PSA) and the Housing Accountability Act (HAA).

These assertions are false. The Town made it clear in its February 28, 2025 Comment Letter that the Town has not made any final determination or decision regarding the Project, and that Town staff continues to review the materials submitted. That letter, for example, specifically noted: “the Town will review your supplemental submissions and the entirety of the record as it conducts environmental review”; “the Town will consider all objections, comments, evidence, and concerns about the Project or the [AB 1633] Notice in accordance with Government Code section 65589.5.1”; “These comments do not constitute a final determination or decision regarding the Project. Any final determinations or decisions will be made in accordance with Gov. Code sections 65589.5 and 65589.5.1 and the applicable and requisite timelines contained therein” (Pages 1, 4; emphasis added). Additionally, the Town specifically advised Mr. Linebarger on December 21, 2023 and February 28, 2025 that the highest approving body for the Project makes the CEQA determination when it takes action on a project. No such decision has been made on environmental impacts nor action taken on this Project.

Thus, contrary to your assertions, the Town has not made any determinations on the Project with respect to CEQA or otherwise.

The Town, as the lead agency, is obligated by CEQA and the HAA to comply with CEQA even for projects claiming the Builder’s Remedy. The Town must consider whether a project may have a significant effect on the environment based on substantial evidence in light of the whole record.

CEQA requires the Town first to determine whether a project is subject to CEQA, then to conduct ITEM 2A ATTACHMENT 12

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26379 Fremont Road Los Altos Hills California 94022 Phone (650) 941-7222 Fax: 650/941- 3160
a preliminary review as to the level of environmental analysis required, and then to make a determination under CEQA prior to approving or carrying out a project.1 The Town follows this process for all development applications including the Project, and the highest approving body makes the CEQA determination prior to deciding on the application. In this case, Government Code section 65589.5.1 also provides that the Town, upon receiving an “AB 1633 notice” from an applicant, shall consider all comments and evidence and shall not make a determination until 60 days thereafter.

Accordingly, the Town specified in its February 28 letter that no final determinations are being made, and that it is reviewing the applicant’s submissions.

In light of the foregoing, your claims are incorrect. At the outset, we observe that a project must meet the requirements under Gov. Code section 65589.5.1(a)(1)-(5) in order for that statute to apply.

Next, neither CEQA nor the HAA automatically exempts Builder’s Remedy projects from environmental review. As explained in prior Town comment letters, the Project’s density and intensity proposed in a semi-rural, suburban setting, its need to address outstanding comments from the Santa Clara County Fire Department, and its unique site location and surrounding environment, all as documented in the record, support the Town’s preliminary review that an initial study and additional environmental analysis would be necessary. Likewise, evaluation of applicable CEQA exemptions would require each exemption and the “exception” under CEQA Guidelines section 15300.2 (a)-(f) be analyzed, due to the unique Project circumstances. The Town disagrees with your assertion that the Project can be blanketly exempt from CEQA by claiming the Builder’s Remedy without further analysis. As our February 28 letter stated, the Town continues to review the applicant’s CEQA memo and other documents in the record.

With respect to your assertions regarding application completeness and consistency review, the Town issued a comment letter determining the Project application complete on September 28, 2023, consistent with the PSA. The Town also followed the timeline under Gov. Code section 65589.5(j)(2) in the HAA to identify inconsistencies with applicable standards. However, since Mr. Linebarger’s January 30 and February 25, 2025 resubmittals modified several aspects of the Project plans, the Town continues to review these modifications. Staff identified additional items that require correction or needed to be completed on these revised plans and made additional plan check comments. These items need to be provided or addressed. Staff is prepared to continue review upon receiving the applicant’s resubmittal.

I can be contacted by email at [email protected] if you have any questions.

Sincerely,
Suzanne Avila
Suzanne Avila
Consultant Principal Planner
Town of Los Altos Hills
1 Gov. Code section 65589.5(e); Public Resources Code sections 21080.1, 21080.2; CEQA Guidelines sections 15060, 15060.5, 15061, 15062, 15063.

ITEM 2A ATTACHMENT 12

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ITEM 2A ATTACHMENT 13

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Lands of Linebarger
10758 Mora Drive
February 28, 2025

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2. The highest sectional height is shown to be 83 feet 5-inches (south elevation, sheet A2.1) which is not consistent with the maximum height shown on section A-A on sheet A3.1.

Please make any necessary corrections to heights shown on elevations and section A-A.

3. Provide light reflectivity values for proposed exterior finishes. Color sample C appears to have a LRV greater than 40.

ADDITIONAL PROJECT COMMENTS
Building Department Preliminary Review
• Review of the resubmittal is still in progress. Comments will be forwarded when the review is completed or by March 27, 2025.

Fire Department Review
• Santa Clara County Fire Department review is still in progress. Comments will be forwarded when received.

CONSISTENCY DETERMINATION
This section of the Comment Letter is provided pursuant to Government Code section 65589.5(j)(2)(A). Pursuant to the Town’s prior Consistency Review Comment Letter dated August 31, 2023, 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. Upon review of the January 30 and February 25, 2025 resubmittals, the revised Project continues to be inconsistent with the following:
(1) Zoning Designation for the parcel;
(2) Lot size requirement (a Conditional Development Permit is required); (3) Development standards under Title 10, Chapter 1 of the Municipal Code; and (4) General Plan standards and policies.

ITEM 2A ATTACHMENT 13

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February 28, 2025

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ENVIRONMENTAL REVIEW
As previously stated in the last comment letter dated December 21, 2023, this Project is not a ministerial project and not exempt from the California Environmental Quality Act (“CEQA”). The Town has instead determined, pursuant to Public Resources Code section 21080.1 and related CEQA Guidelines, that the proposed development is an activity subject to CEQA and may have a significant effect on the environment.1 You were previously advised that the Town has determined that the proposed development does not qualify for an infill exemption or any other statutory or categorical exemption. The Town is required to consider all phases of the proposed Project including planning, operation, and implementation.2It is expected 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.3 An Initial Study will need to be conducted for the project in order to determine the specific environmental analysis required.4 The Town is required to consider and adopt the proposed Mitigated Negative Declaration or consider and certify the Environmental Impact Report prepared for the Project, prior to making a decision on the project and make findings regarding the Project’s environmental impacts.5 The highest approving body making a decision on the proposed Project will be making the environmental determination and findings under CEQA.

ITEM 2A ATTACHMENT 13

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Lands of Linebarger
10758 Mora Drive
February 28, 2025

Page 4 of 5 ends

Finally, the Town would like to take this opportunity to clarify that the Town has timely processed your submittals and provided abundant public hearing notices with regards to the consideration of the Project. The Town timely reviewed and responded to your Project submittals since their initial delivery on February 1, 2023. Before the January 30, 2025 public hearing was scheduled, the last set of plans was received by the Town on November 30, 2023 with no responsesto timely provided Town plan reviewand environmental analysis comments for well over a year. Thereafter, you were first advised of the potential hearing during an in-person meeting with the Town on January 17, 2025, well in advance of the previously scheduled January 30, 2025 public hearing. The Town mailed the public hearing notice for the January 30 hearing to your address on the County Assessor’s office property tax roll and posted physical notices at the Project site, both on January 19, 2025 and also well in advance of the hearing. The Town also overnight mailed and emailed public hearing notices to your second address on the application on January 27 and 28, 2025. The ITEM 2A ATTACHMENT 13

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Lands of Linebarger
10758 Mora Drive
February 28, 2025

Page 5 of 5 ends

Town has thus committed substantial efforts to maintain responsiveness and communication with you on our Project review and consideration.

I can be contacted by e-mail at [email protected] if you have any questions.

Sincerely,
Suzanne Avila
Suzanne Avila, AICP
Consultant Principal Planner
Attachment:

1. August 31, 2023 Consistency Determination Letter
5564789.2
ITEM 2A ATTACHMENT 13

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Le er of Transmi al
550 Pilgrim Drive, Foster City, CA 94404 www.csgengr.com phone 650.522.2500
To: Town of Los Altos Hills Date: March 24, 2025 Review No: 1st 26379 Fremont Rd. CSG No.: 4502651
Los Altos Hills, CA 94022 Jurisdic on No. : CDP23‐0002
A n: Building Department Job Address: 10758 Mora Dr.

Job Descrip on:

Preliminary review ‐ New 45 unit mul family residen al development project with parking garage (Version #2) ‐ Linked to CSG´s 4502650, 4502649 & 4502648
Status: Plan requires correc ons. See a ached list. Plan is ready for permit issuance for the following:

We have reviewed the following documents (Digital):

X Plans Energy Compliance Documents
Structural Calcula ons CalGreen Checklist – Not Applicable X Geotechnical Report Specifica ons
Geotechnical Review Le er Wildland Urban Interface
Truss Calcula ons CASp Documents
Truss Review Le er Response to Comments
Special Inspec on Form Other:

Special items to note:

Plans have been stamped by CSG.

Environmental Health Services approval required .

Special Inspec on is required.

Structural Observa on is required.

Valua on
Please collect a plan review fee for hour(s) of plan check.

Remarks:

From: Ted Mirzakhanian, PE, CASp
CSG Consultants
ITEM 2A ATTACHMENT 13

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4502651 Page | 1

TOWN OF LOS ALTOS HILLS

BUILDING DEPARTMENT
Date: March 24, 2025 Phone: 650.522.2552
Job Descrip on:

Preliminary review ‐ New 45 unit mul family residen al
development project with parking garage (Version #2) ‐ Linked to CSG´s 4502650, 4502649 & 4502648 Email: [email protected] Address: 10758 Mora Dr.

Town Permit # : CDP23‐0002

All resubmi als must be submi ed to the Town of Los Altos Hills.

DO NOT send resubmi als directly to CSG Consultants .

PLAN REVIEW COMMENTS

Response: ______________________________________________________________________

2. Submit wri en responses addressing each plan review comment s below and a summary of changes for any addi onal modifica ons. In each response, r efer to specific detail or sheet, or specific page of the suppor ng documents. Show compliance with all comments within the construc on documents.

Response: ______________________________________________________________________ Architectural Plan Review Comments by |Ted Mirzakhanian, PE, CASp,| A1. The following comments point out obvious deficiencies found on the preliminary plans. A complete review will be done upon receipt of complete construc on plans.

Response: ______________________________________________________________________ A2. Sheet CO: Occupancy groups A‐3, S‐2, and R‐2.1 are not accessory uses to the structure. Aggregate accessory occupancies shall not occupy more than 10 percent of the floor area of the story in which they are located . All the specified occupancies are the main occupancy group within their respec ve floors. (508.2.3 CBC) Revise to primary occupancies.

Response: ______________________________________________________________________ A3. Dining areas including dining at level 1 or at the roo op shall be classified as A‐2 occupancy group, not A‐3 or B as shown on sheet A5.1. Please revise the cover sheet to include A‐2 occupancy group and revise sheet A5.1. (303.3 CBC)
Response: ______________________________________________________________________ A4. Sheet CO: Provide a list of occupancy groups for building A, a list of occupancy groups for Building B, and a list of occupancy groups for the building below the podium.

Response: ______________________________________________________________________ ITEM 2A ATTACHMENT 13

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4502651 Page | 2
A5. The en re Town of Los Altos is in a wildland Urban Interface area. The building shall comply with Chapter 7A CBC requirements.

Response: ______________________________________________________________________ A7. Sheet A3.1: Clarify the following on plans for use of Sec on 510.2:
a. The building sec on shows a ver cal offset of the 3 hour podium. Clearly show the ver cal offset wall on floor plans corresponding with a Type I‐A construc on.
b. The total occupant load of the roof shall not exceed 299 occupants. The en re roo op is classified as a Group A occupancy. Revised occupant load calcula ons in accordance with Table 1004.5 CBC shall be provided for the roof. Several areas, such as the dining, sea ng, fire pit, kitchen, garden, etc. shall be calculated with a net occupant load factor of 15. The plans show 150 occupants exi ng each stairway regardless of the occupant loads being shown wrong. The 5 th level and roo op A occupancy areas are not
allowed.
c. The maximum building height in feet shall not exceed the limits set forth in Sec on 504.3 for the building having the smaller allowable height as measured from the grade plane. Provide a diagram showing the calcula on or the average grade plane to determine the allowable building height. See commentary Figures 202(23) and 202(24) a ached below:

ITEM 2A ATTACHMENT 13

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4502651 Page | 3
Response: ______________________________________________________________________ A8. Sheet A5.1: Revise the loca on of the up arrow in stair #2 podium level.

Response: ______________________________________________________________________ A9. Sheet A5.2: Please provide gridlines with sec on and eleva on call‐out references on the floor plans.

Response: ______________________________________________________________________ A10. Sheet A5.2: No pool is proposed at the roof of this building. Please remove from the Proposed Occupancy sec on on the sheet.

Response: ______________________________________________________________________ A11. Every building of any type of construc on or occupancy having floors used for human occupancy located more than 75 feet above the lowest floor level having building access (different from vehicle access). Building access shall be determined in accordance with the following per Chapter 2 CBC:

1.Suitable and available for fire department use.

2.Located not more than 2 feet above the adjacent ground level.

3.Leading to a space, room or area having foot traffic communica on capabili es with the remainder of the building.

4.Designed to permit penetra on through the use of fire department forcible‐entry tools and equipment unless other approved arrangements have been made with the fire authority having jurisdic on.

Response: ______________________________________________________________________ A12. Plans shall show compliance with R‐2.1 occupancy group in accordance with the following . More code sec ons may apply once more informa on is provided on plans :
a. Plans shall make clear the type of assisted living facility proposed from the list provided in Sec on 310.3.1 CBC. Addi onal comments may apply based on the type of assisted living facility. b. Smoke barriers and refuge areas where applicable in accordance with 420.6 and 435.5.1 CBC. c. Fire protec on systems in accordance with 435.7. All such systems shall be deferred to the Fire Department.

ITEM 2A ATTACHMENT 13

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4502651 Page | 4
d. Corridor widths in accordance with 435.8.4 CBC.

Response: ______________________________________________________________________ A13. Sheet A5.2: Building height, number of stories, and areas:
a. Boths buildings A and B have a covered A‐2/A‐3 occupancy group at the fi h level. Group A occupancies are limited to 4 stories above the podium. The building is 5 stories. Please revise. (Table 504.4 CBC) See also Code Sec on for Occupied Roofs 503.1.4 CBC if the roof at fi h above fi h level is removed. b. There are several notes on the sheet specifying that stairway and elevator sha s are excluded from building area calcula ons. Only open sha s (without a roof on top), such as vent sha s, are allowed to be excluded from building area calcula ons. Include the area of all enclosed sha s and revise building area calcula ons. (Chapter 2 Defini on for “Area, Building”)
c. The Type III‐A building area calcula on is incorrect. It appears a single occupancy building is proposed , which shall give a tabular value of 14,000 square feet for the most restric ve A occupancy group with a Sa value of

3. Clearly determine if Equa on 5‐2 or 5‐3 is proposed and provide the calcula on accordingly. (506 CBC) d. The assisted living use is on level 1, which is above the podium slab. Revise Type I‐A building area analysis showing R‐2.1 as the most restric ve occupancy group.

Response: ______________________________________________________________________ A14. Sheet A4.1: Fire‐retardant‐treated wood is required for wood framing and sheathing in exterior walls in accordance with 2303.2 CBC for a Type III‐A building. (602.3 CBC) Response: ______________________________________________________________________ A15. Sheet A5.2: Plans show the firewall stopping at the 4 th level roof. The firewall shall be con nuous to the 5 th level roof in accordance with Sec on 706.6 CBC. Buildings A and B shall be completely separated by a firewall on all levels.

Response: ______________________________________________________________________ A16. Balconies and other projec ons shall comply with Table 705.2 CBC. This could not be verified from the preliminary drawings. Openings are limited per Table 705.8 CBC. The site plan shows less than 5 ’ from building edge to property line, which only allows 15% of the wall on each floor to have openings that are protected.

Response: ______________________________________________________________________ A17. Means of Egress:
a. Revise occupant load factors such that all rooms and spaces are in accordance with Table 1004.5 CBC.

Several rooms have the incorrect occupant load factor shown. b. The corridor doors at the firewall/horizontal exit on some floor may be required to swing in both direc ons (cross doors) if the occupant load on both sides of the firewall is over 49. (1010.1.2.1 CBC) c. Rooms and areas with 50 or more occupants shall have access to a minimum of 2 exits. The media and dining room at level 1 each need at least 2 exits.
d. The width and capacity of stairway 2 shall consider egress convergence from stories above and below in accordance with Sec on 1005.6 CBC.
e. Depending on the determina on of the grade plane on the property, two exits or access to exits may be required in the sub basement and basement levels. (Table 1006.3.4(1) CBC) f. Provide either a generator for the elevator or a horizontal exit. (1009.2.1 CBC) g. Refuge areas are required to be shown for the horizontal exit. (1026 CBC) h. There is no accessible route from elevator 2 or stair 2 to the public way. The site consists of several exterior stairways, which does not provide an accessible route. The building does not comply with accessible means of egress per Sec on 1009 CBC. See also accessibility comments below. i. Clarify if a ramp is shown to the access door of the laundry and u lity room at the mezzanine level. It appears the door is opening into the ramp slope. Clarify. j. Fire‐resistance‐rated corridors shall be con nuous from the point of entry to an exit, and shall not be interrupted by intervening rooms. Several rooms and spaces are open to the corridor, such as the media and ITEM 2A ATTACHMENT 13

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4502651 Page | 5
dining room, and the salon. (1020.7 CBC)
k. Openings within 10 feet ver cally of the egress courts shall be protected in accordance with 1029.3 CBC. l. The R‐2.1 units do not qualify for the Type III‐A excep on and are required to have emergency egress windows. Fire Department approval is required with respect to access to the court . (1031.2 CBC) Response: ______________________________________________________________________ A18. Verify the elevator can accommodate a stretcher. (3002.4 CBC) Response: ______________________________________________________________________ Disabled Access Plan Review Comments by |Ted Mirzakhanian, PE, CASp | DA1. Plans shall clearly specify if any public funding is granted for the construc on of the residen al or the assisted living por on of the building. Publicly funded projects shall comply with Chapter 11B. Otherwise, Chapter 11A shall apply to all residen al units (assisted living or otherwise) and to the associated common areas. Rooms and areas that are accessible to assisted living employees or staff shall be regulated under Chapter 11B regardless of Chapter 11A applicability for the rest of the building. Comments below assume no public funding.

Response: ______________________________________________________________________ DA6. The sub basement floor has a common use amenity and is required to be on an accessible route. No elevator is provided to this level. Please revise. (1119A.1 CBC)
Response: ______________________________________________________________________ DA7. All common use facili es shall be accessible, including but not limited to , toilet rooms, dining areas, laundry room, roo op dining and ac vi es, mail room, etc. (1127A CBC) Response: ______________________________________________________________________ (End of Building Comments)
ITEM 2A ATTACHMENT 13

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26379 Fremont Road Los Altos Hills California 94022 (650) 941-7222 Fax: 650/941-3160 s
**VIA EMAIL ONLY**
March 27, 2025
Forrest Linebarger
785 Castro Street, Suite A
Mountain View, CA 94041
Via email at [email protected]
RE: Resubmittal of Senior Residential Development Project 10758 Mora Drive
File # CDP23-0002
Dear Mr. Linebarger:

Thank you for resubmitting plansfor the above referenced senior residential development project located at 10758 Mora Drive (“Project”), received by the Town for review and processing on January 30 and February 25, 2025. Based on staff’sreview of both plans submitted, it appears that they are substantially similar. As stated in your January 30, and February 25, 2025 correspondences, you are revising the Project pursuant to Government Code section 65589.5(f)(7) to subject the Project to the provisions of that statute applicable as of January 1, 2025. A response letter was provided on February 28, 2025 for the plans received on January 30, 2025. The Town thus provides this comment letter in response to your February 25, 2025 resubmittal as we continue to identify items that require correction or need to be completed on the plans resubmitted.

2. The highest sectional height is shown to be 83 feet 5-inches (south elevation, sheet A2.1) which is not consistent with the maximum height shown on section A-A on sheet A3.1.

Please make any necessary corrections to heights shown on elevations and section A-A.

ITEM 2A ATTACHMENT 13

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Lands of Linebarger
10758 Mora Drive
March 27, 2025

Page 2 of 3 ends

3. Provide light reflectivity values for proposed exterior finishes. Color sample C appears to have a LRV greater than 40.

BUILDING COMMENTS:

Please see the attached memorandum from CSG Consultants for detailed building comments.

FIRE DEPARTMENT COMMENTS:

Please see the attached comment letter from Santa Clara County Fire Department for plan review comments.

CONSISTENCY DETERMINATION
This section of the Comment Letter is provided pursuant to Government Code section 65589.5(j)(2)(A). Pursuant to the Town’s prior Consistency Review Comment Letter dated August 31, 2023, 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. Upon review of the January 30 and February 25, 2025 resubmittals, the revised Project continues to be inconsistent with the following:
(1) Zoning Designation for the parcel;
(2) Lot size requirement (a Conditional Development Permit is required); (3) Development standards under Title 10, Chapter 1 of the Municipal Code; and (4) General Plan standards and policies.

These inconsistencies are described in greater detail in the Town’s August 31, 2023 Consistency Determination Letter, which was again provided to you on February 28, 2025. Recognizing the Project density has been modified, the consistency determinations in that letter continue to apply.

ENVIRONMENTAL REVIEW
The Town is in receipt of your correspondence dated March 20, 2025 raising additional CEQA issues, and will provide a separate response thereto.

Additionally, the Town makes two requests with the review of this resubmittal. First, as the Town has requested previously, please cloud all revisions on the plans or provide a written list of changes.

ITEM 2A ATTACHMENT 13

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Lands of Linebarger
10758 Mora Drive
March 27, 2025

Page 3 of 3 ends

You have submitted three renditions of plans within a short timeframe of each other, which all appear to be substantially similar but with nuanced changes. Clearly marking the changes on these plans with clouding or a written list would facilitate review by the Town and its consultants, as well as third party government agencies. We strongly request your cooperation in having all future resubmittals clouded or provide a list of written changes to avoid any undue administrative burden on the reviewing staff and agencies.

Finally, please upload any future resubmittals to the Town’s portal or submit them in person at Town Hall. In the event of a technical problem with the Town portal, please email [email protected].

I can be contacted by e-mail at [email protected] if you have any questions.

Sincerely,
Suzanne Avila
Suzanne Avila, AICP
Consultant Principal Planner
Attachments:

1. CSG Building Comments dated March 24, 2025

2. Santa Clara County Fire Department Comments dated March 25, 2025 ITEM 2A ATTACHMENT 13

Page 896 of 1435 ends

BLDG
PERMIT No.
25 0570 PLANREVIEW No.

DEVELOPMENTAL REVIEW COMMENTS
This project has been reviewed with respect to the following:

The California Fire (CFC) & Building (CBC) Code, 2022 edition, as adopted by the Town of Los Altos Hills Municipal Code (LAHMC) and California Code of Regulations (CCR). Note: Code review for building permit will be reviewed with respect to the fire/building codes in effect at time of permit application.

The scope of this project includes the following:

Proposed new 67,840 SF, five-story, Type IIIA/IA construction, R-2/R-2.1/A-3/S-2/B Occupancy apartment building with 2 podium levels and a basement.

Plan Status:

Plans are NOT APPROVED. Revise and resubmit drawings and provide a response letter addressing comments on this plan review.

Plan Review Comments:

Revision 8, dated 1/28/25, makes interior modifications to the building. The exterior dimensions and layout of the building are unchanged from the most recent submittal, Revision 5, dated 11/21/2023.

Therefore, the Fire Department’s ability to access the building remains unchanged.

As explained in plan review comments dated 4/5/2023, 8/14/2023, and 1/31/2024, the project is inconsistent with the fire apparatus access road requirements in California Fire Code Section 503.1.1, as adopted and amended by the Town of Los Altos Hills pursuant to Los Altos Hills Municipal Code Sections 8-1.8.01 and 8-1.8.02. Specifically, the project does not provide a fire apparatus access road within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building.

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR

OCCUPANCY

AREA LOAD
Tower Investments, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
2 OF 1
DATE
LAH 02/27/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI 2865 25% 2148

PROJECT TYPE OR SYSTEM
Design Review
10728 Mora Dr Los Altos Hills
ITEM 2A ATTACHMENT 14

Page 897 of 1435 ends

BLDG
PERMIT No.
25 0570 PLANREVIEW No.

DEVELOPMENTAL REVIEW COMMENTS
Plan Review Comments: (con't)
As explained in prior comments, the Fire Code Official did not approve an extension to the 150-foot requirement for the proposed development under Exception 1 to Section 503.1.1, as adopted and amended by the Town of Los Altos Hills, due to site-specific challenges, including but not limited to the site’s topography, varying access slopes and elevations adjacent to the sides and rear of building, minimal access widths between fencing and the building, a single access road on one side of the building, and the threat of wildfire. Because the exterior dimensions and layout of the building are unchanged, the Fire Code Official does not approve an extension under Exception 1 to Section 503.1.1 for the modified project for the same reasons.

This review shall not be construed to be an approval of a violation of the provisions of the California Fire Code or of other laws or regulations of the jurisdiction. A permit presuming to give authority to violate or cancel the provisions of the fire code or other such laws or regulations shall not be valid. Any addition to or alteration of approved construction documents shall be approved in advance [CFC, Ch.1, 105.3.6].

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR

OCCUPANCY

AREA LOAD
Tower Investments, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
2 OF 2
DATE
LAH 02/27/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI 2865 25% 2148

PROJECT TYPE OR SYSTEM
Design Review
10728 Mora Dr Los Altos Hills
ITEM 2A ATTACHMENT 14

Page 898 of 1435 ends

BLDG
PERMIT No.
25 0960 PLANREVIEW No.

DEVELOPMENTAL REVIEW COMMENTS
This project has been reviewed with respect to the following:

The California Fire (CFC) & Building (CBC) Code, 2022 edition, as adopted by the Town of Los Altos Hills Municipal Code (LAHMC) and California Code of Regulations (CCR).

The scope of this project includes the following:

Proposed new 69,369 SF, five-story, Type IIIA/IA construction, R-2/R-2.1/A-3/S-2/B Occupancy apartment building with 3 podium levels and a basement.

Plan Status:

The Fire Department recommends that the Town not approve Revision 9, dated 2/20/25.

Plan Review Comments:

The project as proposed in Revision 9, dated 2/20/25, is inconsistent with California Fire Code Section 503.1.1, as adopted and amended by the Town of Los Altos Hills pursuant to Los Altos Hills Municipal Code Sections 8-1.8.01 and 8-1.8.02. Specifically, the project does not provide a fire apparatus access road within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building.

In plan review comments to previous revisions of this project, the Fire Code Official did not approve an extension to the 150-foot requirement for the proposed development under Exception 1 to Section 503.1.1, as adopted and amended by the Town of Los Altos Hills, due to site-specific challenges, including but not limited to the site’s topography, varying access slopes and elevations adjacent to the sides and rear of building, minimal access widths between fencing and the building, a single access road on one side of the building, and the threat of wildfire. The Fire Code Official does not approve an extension under Exception 1 to Section 503.1.1 for the modified project for the same reasons. The proposed supplemental fire protection measures in Revision 9 (including those noted on Fire Access Plan A5.0) do not sufficiently address the site specific challenges and do not change the Fire Code Official's decision not to approve an extension.

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR

OCCUPANCY

AREA LOAD
Tower Investments, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
1 OF IA/IIIA 1
DATE
LAH 03/25/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI

PROJECT TYPE OR SYSTEM
Design Review
10728 Mora Drive Los Altos Hills
ITEM 2A ATTACHMENT 14

Page 899 of 1435 ends

BLDG
PERMIT No.
25 2538 PLANREVIEW No.

DEVELOPMENTAL REVIEW COMMENTS
This project has been reviewed with respect to the following:

The California Fire (CFC) & Building (CBC) Code, 2022 edition, as adopted by the Town of Los Altos Hills Municipal Code (LAHMC) and California Code of Regulations (CCR).

The scope of this project includes the following:

Proposed new 65,823 SF, five-story, Type IIIA/IA construction, R-2/A-3/S-2/B Occupancy apartment building with 3 podium levels, a basement, and an occupied roof.

Plan Status:

The Fire Department recommends that the Town not approve Revision 10, dated 5/29/25.

Plan Review Comments:

The project as proposed in Revision 10, dated 5/29/25, is inconsistent with California Fire Code Section 503.1.1, as adopted and amended by the Town of Los Altos Hills pursuant to Los Altos Hills Municipal Code Sections 8-1.8.01 and 8-1.8.02. Specifically, the project does not provide a fire apparatus access road within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building.

In plan review comments to previous revisions of this project, the Fire Code Official did not approve an extension to the 150-foot requirement for the proposed development under Exception 1 to Section 503.1.1, as adopted and amended by the Town of Los Altos Hills, due to site-specific challenges, including but not limited to the site’s topography, varying access slopes and elevations adjacent to the sides and rear of building, minimal access widths between fencing and the building, a single access road on one side of the building, and the threat of wildfire. Because the exterior dimensions and layout of the building are unchanged, the Fire Code Official does not approve an extension under Exception 1 to Section 503.1.1 for the modified project for the same reasons. The proposed supplemental fire protection measures in Revision 10 (including those noted on Fire Access Plan A5.0) do not sufficiently address the site specific challenges because they fail to properly mitigate the risks caused by the building's layout and siting, and do not change the Fire Code Official's decision not to approve an extension.

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR

OCCUPANCY

AREA LOAD
Tower Investments, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
1 OF IA/IIIA 1
DATE
LAH 6/10/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI

PROJECT TYPE OR SYSTEM
Design Review
10728 Mora Drive Los Altos Hills
ITEM 2A ATTACHMENT 14

Page 900 of 1435 ends

BLDG
PERMIT No.
25 0571 PLANREVIEW No.

DEVELOPMENTAL REVIEW COMMENTS
This project has been reviewed with respect to the following:

The scope of this project includes the following:

Proposed new 70,983 SF, five-story, Type IIIA/IA construction, R-2/R-2.1/A-3/S-2/B Occupancy apartment building with 3 podium levels and a basement.

Plan Status:

Plans are NOT APPROVED. Revise and resubmit drawings and provide a response letter addressing comments on this plan review.

Plan Review Comments:

Revision 8, dated 1/28/25, makes interior modifications to the building. The exterior dimensions and layout of the building are unchanged from the most recent submittal, Revision 5, dated 11/21/2023.

Therefore, the Fire Department’s ability to access the building remains unchanged.

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR
R-2.1

OCCUPANCY
LOAD
70983
AREA
Tower Investment, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
2 OF
7+bsmt
IA/IIIA 1
DATE
LAH 02/27/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI 2813 25% 2109

PROJECT TYPE OR SYSTEM
Design Review
10758 Mora Drive Los Altos Hills
ITEM 2A ATTACHMENT 15

Page 901 of 1435 ends

BLDG
PERMIT No.
25 0571 PLANREVIEW No.

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR
R-2.1

OCCUPANCY
LOAD
70983
AREA
Tower Investment, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
2 OF
7+bsmt
IA/IIIA 2
DATE
LAH 02/27/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI 2813 25% 2109

PROJECT TYPE OR SYSTEM
Design Review
10758 Mora Drive Los Altos Hills
ITEM 2A ATTACHMENT 15

Page 902 of 1435 ends

BLDG
PERMIT No.
25 0959 PLANREVIEW No.

DEVELOPMENTAL REVIEW COMMENTS
This project has been reviewed with respect to the following:

The California Fire (CFC) & Building (CBC) Code, 2022 edition, as adopted by the Town of Los Altos Hills Municipal Code (LAHMC) and California Code of Regulations (CCR).

The scope of this project includes the following:

Proposed new 73,944 SF, five-story, Type IIIA/IA construction, R-2/R-2.1/A-3/S-2/B Occupancy apartment building with 3 podium levels and a basement.

Plan Status:

The Fire Department recommends that the Town not approve Revision 9, dated 2/20/25.

Plan Review Comments:

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR

OCCUPANCY

AREA LOAD
Tower Investment, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
1 OF IA/IIIA 1
DATE
LAH 03/25/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI

PROJECT TYPE OR SYSTEM
Design Review
10758 Mora Drive Los Altos Hills
ITEM 2A ATTACHMENT 15

Page 903 of 1435 ends

BLDG
PERMIT No.
25 2537 PLANREVIEW No.

DEVELOPMENTAL REVIEW COMMENTS
This project has been reviewed with respect to the following:

The California Fire (CFC) & Building (CBC) Code, 2022 edition, as adopted by the Town of Los Altos Hills Municipal Code (LAHMC) and California Code of Regulations (CCR).

The scope of this project includes the following:

Proposed new 66,856 SF, five-story, Type IIIA/IA construction, R-2/A-3/S-2/B Occupancy apartment building with 3 podium levels, a basement, and an occupied roof.

Plan Status:

The Fire Department recommends that the Town not approve Revision 10, dated 5/29/25.

Plan Review Comments:

In plan review comments to previous revisions of this project, the Fire Code Official did not approve an extension to the 150-foot requirement for the proposed development under Exception 1 to Section 503.1.1, as adopted and amended by the Town of Los Altos Hills, due to site-specific challenges, including but not limited to the site’s topography, varying access slopes and elevations adjacent to the sides and rear of building, minimal access widths between fencing and the building, a single access road on one side of the building, and the threat of wildfire. Because the exterior dimensions and layout of the building are unchanged, the Fire Code Official does not approve an extension under Exception 1 to Section 503.1.1 for the modified project for the same reasons. The proposed supplemental fire protection measures in Revision 10 (including those noted on Fire Access Plan A5.0) do not sufficiently address the site specific challenges because they fail to properly mitigate the risks caused by the building's layout and siting, and do not change the Fire Code Official's decision not to approve an extension.

City
Y
E
PLANS
Y
E
SPECS
Y
E
NEW
Y
E
RMDL CONST. TYPE
BY
PAGE

SEC/FLOOR

OCCUPANCY

AREA LOAD
Tower Investment, Llc
ApplicantName

SILVER OAKS

NAME OF PROJECT LOCATION
Y
E
AS
1 OF IA/IIIA 1
DATE
LAH 06/10/2025
Mckenna, Matthew

PROJECT DESCRIPTION
Residential Development
TABULAR FIRE FLOW REDUCTION FOR FIRE SPRINKLERS REQUIRED FIRE FLOW @ 20 PSI

PROJECT TYPE OR SYSTEM
Design Review
10758 Mora Drive Los Altos Hills
ITEM 2A ATTACHMENT 15

Page 904 of 1435 ends

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
March 21, 2022
MEMORANDUM FOR: Planning Directors and Interested Parties FROM: Megan Kirkeby, Deputy Director
Division of Housing Policy Development
SUBJECT: Default Density Standard Option – 2020 Census Update Background Information: Pursuant to Government Code section 65583.2, subdivision (c)(3), the housing element must include analysis of identified sites which must demonstrate how adopted densities accommodate the regional housing need for lowerincome households. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower-income households.

As an option and alternative to preparing the analysis described above, Government Code section 65583.2, subdivision (c)(3)(B), allows local governments to utilize “default” density standards that are “deemed appropriate to accommodate housing for lower income households.” The default density option is not a mandated density. The default density standard provides a streamlined option for local governments to meet the density requirement. No analysis to establish the appropriateness of the default density is required, and the California Department of Housing and Community Development (HCD) must accept that density as appropriate in its review.

The default density option was adopted in 2003 by consensus with local government representatives, builders, planners, and advocates through the Housing Element Working Group, which was convened by HCD in 2003. Default densities are established using census population figures and based on methodology detailed in Government Code section 65583.2, subdivisions (b)(i)-(iv), and section 65583.2, subdivisions (d)-(f), as summarized below (refer to Table A for detailed information):
• Incorporated cities within non-metropolitan/rural counties and non-metropolitan counties with micropolitan areas (15 units or more per acre) • Unincorporated areas in all non-metropolitan counties (10 units or more per acre) • Suburban Jurisdictions (20 units or more per acre)
• Metropolitan Jurisdictions (30 units or more per acre) ITEM 2A ATTACHMENT 16

Page 905 of 1435 ends

2 Revised Default Density Standards Based on 2020 Census Data Release: Based on the release of 2020 Census data, HCD has updated the default density standards set forth in HCD’s June 20, 2012, technical assistance memo (Default Density Standard Option – 2010 Census Update). Specifically, Tables A and B in Appendix 1 of the June 20, 2012, memo have been revised based on current U.S. Census Bureau populationbased criteria as established in Government Code section 65583.2, subdivisions (c)(3) and (d)-(f).

The updated optional default density standards are based on either one of the following:

1. Increases in population of a Metropolitan Statistical Area above 2 million between the 2010 and 2020 Census-based estimates; or

2. Increases or decreases of an individual jurisdiction’s population between the 2010 and 2020 Census-based estimates.

Population changes to Metropolitan and Micropolitan Statistical Areas are reflected in Table A, below. Applicable jurisdiction level information on default densities for accommodating lower-income households is included as Appendix 1.

Timing and Applicability Regarding Future Housing Element Updates: Due to the timing of the release of the 2020 Census figures in late 2021, as a matter of policy when determining substantial compliance with State Housing Element Law (Gov. Code § 65585, subd. (d)), HCD will consider 2020 Census population figures applicable to all jurisdictions in the sixth planning period due after January 1, 2022. Housing elements due prior to January 1, 2022, may continue to use default densities identified in HCD’s June 20, 2012, technical assistance memo. Please note, changes related to default densities in the seventh planning cycle will be effective upon the release of population data for the 2030 Census.

If you have any questions or need assistance, please contact [email protected].

ITEM 2A ATTACHMENT 16

Page 906 of 1435 ends

3 TABLE A
Revised Default Densities Appropriate to Accommodate
Housing for Lower-Income Households by Region
(note: changes are indicated by underline)
Default Densities are optional and data is provided for informational purposes only I
Incorporated Cities
within nonmetropolitan/rural
counties (as outlined in
either Section I or II)
and
Non-metropolitan
counties with
micropolitan Areas
(listed below)
II
Unincorporated
Areas in all nonmetropolitan
counties not
included under I
III
Suburban
jurisdictions
IV
Metropolitan
jurisdictions
Nonmetropolitan
counties with
micropolitan Areas
include:

Del Norte County
Humboldt County
Lake County
Lassen County
Mendocino County
Nevada County
Tehama County
Tuolumne County
Non-metropolitan/
rural counties as
listed below (list
excludes those
counties including
Micropolitan Areas
as outlined in
section I)
Alpine County
Amador County
Calaveras County
Colusa County
Glenn County
Inyo County
Mariposa County
Modoc County
Mono County
Plumas County
Sierra County
Siskiyou County
Trinity County
Jurisdictions
(cities/counties)
located within a
Metropolitan
Statistical Area
(MSA) with a
population of less
than 2 million as
listed below unless a
city has a population
of greater than
100,000, in which
case it would be
considered
metropolitan.

Butte County
Fresno County
Imperial County
Kern County
Kings County
Madera County
Merced County
Monterey County
Napa County
San Joaquin County
San Luis Obispo
County
Santa Barbara
County
Jurisdictions
(cities/counties)
located within a
Metropolitan
Statistical Area (MSA)
with a population of
more than 2 million as
listed below unless a
jurisdiction has a
population of less
than 25,000, in which
case it would be
considered suburban.

Alameda County
Contra Costa County
El Dorado County
Los Angeles County
Orange County
Placer County
Riverside County
Sacramento County
San Benito County
San Bernardino
County
San Diego County
San Francisco County
at least 15 du/ac at least 10 du/ac at least 20 du/ac at least 30 du/ac ITEM 2A ATTACHMENT 16

Page 907 of 1435 ends

4 I
Incorporated Cities
within nonmetropolitan/rural
counties (as outlined in
either Section I or II)
and
Non-metropolitan
counties with
micropolitan Areas
(listed below)
II
Unincorporated
Areas in all nonmetropolitan
counties not
included under I
III
Suburban
jurisdictions
IV
Metropolitan
jurisdictions
Santa Cruz County
Shasta County
Solano County
Sonoma County
Stanislaus County
Sutter County
Tulare County
Ventura County
Yuba County
Marin County*
* Considered
Suburban
San Mateo County
Santa Clara County
Yolo County
at least 15 du/ac at least 10 du/ac at least 20 du/ac at least 30 du/ac ITEM 2A ATTACHMENT 16

Page 908 of 1435 ends

5 TABLE B
Summary of Changes
The following jurisdictions have moved from 20 to 30 du/acre since the last update:

Jurisdiction Reason
Barstow Metropolitan Jurisdiction now greater than 25,000 Campbell In a Metropolitan Statistical Area now greater than 2,000,000 Chico Suburban Jurisdiction now greater than 100,000
Clovis Suburban Jurisdiction now greater than 100,000
Cupertino In a Metropolitan Statistical Area now greater than 2,000,000 El Cerrito Metropolitan Jurisdiction now greater than 25,000 Galt* Metropolitan Jurisdiction now greater than 25,000 Gilroy In a Metropolitan Statistical Area now greater than 2,000,000 Hercules Metropolitan Jurisdiction now greater than 25,000 Hollister In a Metropolitan Statistical Area now greater than 2,000,000 Lafayette Metropolitan Jurisdiction now greater than 25,000 Los Altos In a Metropolitan Statistical Area now greater than 2,000,000 Los Gatos In a Metropolitan Statistical Area now greater than 2,000,000 Milpitas In a Metropolitan Statistical Area now greater than 2,000,000 Morgan Hill In a Metropolitan Statistical Area now greater than 2,000,000 Mountain View In a Metropolitan Statistical Area now greater than 2,000,000 Palo Alto In a Metropolitan Statistical Area now greater than 2,000,000 Santa Clara County In a Metropolitan Statistical Area now greater than 2,000,000 Santa Maria Suburban Jurisdiction now greater than 100,000 Saratoga In a Metropolitan Statistical Area now greater than 2,000,000 Seal Beach* Metropolitan Jurisdiction now greater than 25,000 Vacaville Suburban Jurisdiction now greater than 100,000 Yolo County* Metropolitan Jurisdiction now greater than 25,000 * Housing element due prior to January 1, 2022
The following jurisdiction moved from 15 to 10 du/acre since the last update:

Jurisdiction Reason
Inyo County* No longer in a Micropolitan Area
* Housing Element due prior to January 1, 2022
ITEM 2A ATTACHMENT 16

Page 909 of 1435 ends

6 APPENDIX 1
Housing Element Default Densities for Accommodating Lower-Income Households Government Code Section 65583.2
Default Densities are optional and data is provided for informational purposes only NOTE: Changes are indicated in yellow below and are based on one of the following factors as indicated:

1. Increase in population of a Metropolitan Statistical Area above 2 million between the 2010 and 2020 Census; OR

2. Increase or decrease in an individual locality’s population between the 2010 and 2020 Census; OR

3. No longer located in a Micropolitan Area
County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Alameda
County
IV Alameda 73,812 78,280 X
Alameda
County
141,266 152,107 X
Albany 18,539 20,271 X
Berkeley 112,580 124,321 X
Dublin 46,036 72,589 X
Emeryville 10,080 12,905 X
Fremont 214,089 230,504 X
Hayward 144,186 162,954 X
Livermore 80,968 87,955 X
Newark 42,573 47,529 X
Oakland 390,724 440,646 X
Piedmont 10,667 11,270 X
Pleasanton 70,285 79,871 X
San Leandro 84,950 91,008 X
Union City 69,516 70,143 X
Alpine
County
II Alpine County 1,175 1,204 X
Amador
County
II Amador City 185 200 X
Amador
County
21,831 26,390 X
Ione 7,918 5,141 X
Jackson 4,651 5,019 X
Plymouth 1,005 1,078 X
Sutter Creek 2,501 2,646 X
Butte
County
III Biggs 1,707 1,964 X
Butte County 83,758 75,966 X
Chico2 86,187 101,475 X
Gridley 6,584 7,421 X
Oroville 15,546 20,042 X
Paradise 26,218 4,764 X
ITEM 2A ATTACHMENT 16

Page 910 of 1435 ends

7 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Calaveras
County
II Angels 3,836 3,667 X
Calaveras
County
41,742 41,625 X
Colusa
County
II Colusa 5,971 6,411 X
Colusa
County
10,325 9,890 X
Williams 5,123 5,538 X
Contra
Costa
County
IV Antioch 102,372 115,291 X
Brentwood 51,481 64,292 X
Clayton 10,897 11,070 X
Concord 122,067 125,410 X
Contra Costa
County
159,785 178,527 X
Danville 42,039 43,582 X
El Cerrito2 23,549 25,962 X
Hercules2 24,060 26,016 X
Lafayette2 23,893 25,391 X
Martinez 35,824 37,287 X
Moraga 16,016 16,870 X
Oakley 35,432 43,357 X
Orinda 17,643 19,514 X
Pinole 18,390 19,022 X
Pittsburg 63,264 76,416 X
Pleasant Hill 33,152 34,613 X
Richmond 103,701 116,448 X
San Pablo 29,139 32,127 X
San Ramon 72,148 84,605 X
Walnut Creek 64,173 70,127 X
Del Norte
County
I Crescent City 7,643 6,673 X
Del Norte
County
20,967 21,070 X
El Dorado
County
IV El Dorado
County
149,266 159,108 X
Placerville 10,389 10,747 X
South Lake
Tahoe
21,403 21,330 X
Fresno
County
III Clovis2 95,631 120,124 X
Coalinga 13,380 17,590 X
Firebaugh 7,549 8,096 X
Fowler 5,570 6,700 X
Fresno 494,665 542,107 X
Fresno
County
171,705 162,396 X
ITEM 2A ATTACHMENT 16

Page 911 of 1435 ends

8 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Huron 6,754 6,206 X
Kerman 13,544 16,016 X
Kingsburg 11,382 12,380 X
Mendota 11,014 12,595 X
Orange Cove 9,078 9,649 X
Parlier 14,494 14,576 X
Reedley 24,194 25,227 X
San Joaquin 4,001 3,701 X
Sanger 24,270 26,617 X
Selma 23,219 24,674 X
Glenn
County
II Glenn County 14,665 14,326 X
Orland 7,291 8,298 X
Willows 6,166 6,293 X
Humboldt
County
I Arcata 17,231 18,857 X
Blue Lake 1,253 1,208 X
Eureka 27,191 26,512 X
Ferndale 1,371 1,398 X
Fortuna 11,926 12,516 X
Humboldt
County
71,916 72,286 X
Rio Dell 3,368 3,379 X
Trinidad 367 307 X
Imperial
County
III Brawley 24,953 26,416 X
Calexico 38,572 38,633 X
Calipatria 7,705 6,515 X
El Centro 42,598 44,322 X
Holtville 5,939 5,605 X
Imperial 14,758 20,263 X
Imperial
County
37,778 35,934 X
Westmorland 2,225 2,014 X
Inyo
County
II
3 Bishop 3,879 3,819 X
Inyo County 14,667 15,197 X
Kern
County
III Arvin 19,304 19,495 X
Bakersfield 347,483 403,455 X
California City 14,120 14,973 X
Delano 53,041 51,428 X
Kern County 297,932 308,253 X
Maricopa 1,154 1,026 X
McFarland 12,707 14,161 X
Ridgecrest 27,616 27,959 X
Shafter 16,988 19,953 X
Taft 9,327 8,546 X
ITEM 2A ATTACHMENT 16

Page 912 of 1435 ends

9 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Tehachapi 14,414 12,939 X
Wasco 25,545 27,047 X
Kings
County
III Avenal 15,505 13,696 X
Corcoran 24,813 22,339 X
Hanford 53,967 57,990 X
Kings County 34,166 31,423 X
Lemoore 24,531 27,038 X
Lake
County
I Clearlake 15,250 16,685 X
Lake County 44,662 46,452 X
Lakeport 4,753 5,026 X
Lassen
County
I Lassen
County
16,948 16,002 X
Susanville 17,947 16,728 X
Los
Angeles
County
IV Agoura Hills 20,330 20,299 X
Alhambra 83,089 82,868 X
Arcadia 56,364 56,681 X
Artesia 16,522 16,395 X
Avalon 3,728 3,460 X
Azusa 46,361 50,000 X
Baldwin Park 75,390 72,176 X
Bell 35,477 33,559 X
Bell Gardens 42,072 39,501 X
Bellflower 76,616 79,190 X
Beverly Hills 34,109 32,701 X
Bradbury 1,048 921 X
Burbank 103,340 107,337 X
Calabasas 23,058 23,241 X
Carson 91,714 95,558 X
Cerritos 49,041 49,578 X
Claremont 34,926 37,266 X
Commerce 12,823 12,378 X
Compton 96,455 95,740 X
Covina 47,796 51,268 X
Cudahy 23,805 22,811 X
Culver City 38,883 40,779 X
Diamond Bar 55,544 55,072 X
Downey 111,772 114,355 X
Duarte 21,321 21,727 X
El Monte 113,475 109,450 X
El Segundo 16,654 17,272 X
Gardena 58,829 61,027 X
Glendale 191,719 196,543 X
Glendora 50,073 52,558 X
ITEM 2A ATTACHMENT 16

Page 913 of 1435 ends

10 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Hawaiian
Gardens
14,254 14,149 X
Hawthorne 84,293 88,083 X
Hermosa
Beach
19,506 19,728 X
Hidden Hills 1,856 1,725 X
Huntington
Park
58,114 54,883 X
Industry 219 264 X
Inglewood 109,673 107,762 X
Irwindale 1,422 1,472 X
La Cañada
Flintridge
20,246 20,573 X
La Habra
Heights
5,325 5,682 X
La Mirada 48,527 48,008 X
La Puente 39,816 38,062 X
La Verne 31,063 31,334 X
Lakewood 80,048 82,496 X
Lancaster 156,633 173,516 X
Lawndale 32,769 31,807 X
Lomita 20,256 20,921 X
Long Beach 462,257 466,742 X
Los Angeles 3,792,621 3,898,747 X
Los Angeles
County
1,057,426 1,022,167 X
Lynwood 69,772 67,265 X
Malibu 12,645 10,654 X
Manhattan
Beach
35,135 35,506 X
Maywood 27,395 25,138 X
Monrovia 36,590 37,931 X
Montebello 62,500 62,640 X
Monterey
Park
60,269 61,096 X
Norwalk 105,549 102,773 X
Palmdale 152,750 169,450 X
Palos Verdes
Estates
13,438 13,347 X
Paramount 54,098 53,733 X
Pasadena 137,122 138,699 X
Pico Rivera 62,942 62,088 X
Pomona 149,058 151,713 X
ITEM 2A ATTACHMENT 16

Page 914 of 1435 ends

11 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Rancho Palos
Verdes
41,643 42,287 X
Redondo
Beach
66,748 71,576 X
Rolling Hills 1,860 1,739 X
Rolling Hills
Estates
8,067 8,280 X
Rosemead 53,764 51,185 X
San Dimas 33,371 34,924 X
San Fernando 23,645 23,946 X
San Gabriel 39,718 39,568 X
San Marino 13,147 12,513 X
Santa Clarita 176,320 228,673 X
Santa Fe
Springs
16,223 19,219 X
Santa Monica 89,736 93,076 X
Sierra Madre 10,917 11,268 X
Signal Hill 11,016 11,848 X
South El
Monte
20,116 19,567 X
South Gate 94,396 92,726 X
South
Pasadena
25,619 26,943 X
Temple City 35,558 36,494 X
Torrance 145,438 147,067 X
Vernon 112 222 X
Walnut 29,172 28,430 X
West Covina 106,098 109,501 X
West
Hollywood
34,399 35,757 X
Westlake
Village
8,270 8,029 X
Whittier 85,331 87,306 X
Madera
County
III Chowchilla 18,720 19,039 X
Madera 61,416 66,224 X
Madera
County
70,729 70,992 X
Marin
County
IV Belvedere 2,068 2,126 X
Corte Madera 9,253 10,222 X
Fairfax 7,441 7,605 X
Larkspur 11,926 13,064 X
Marin County 67,427 68,994 X
Mill Valley 13,903 14,231 X
Novato 51,904 53,225 X
ITEM 2A ATTACHMENT 16

Page 915 of 1435 ends

12 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Ross 2,415 2,338 X
San Anselmo 12,336 12,830 X
San Rafael 57,713 61,271 X
Sausalito 7,061 7,269 X
Tiburon 8,962 9,146 X
Mariposa
County
II Mariposa
County
18,251 17,131 X
Mendocino
County
I Fort Bragg 7,273 6,983 X
Mendocino
County
59,156 62,563 X
Point Arena 449 460 X
Ukiah 16,075 16,607 X
Willits 4,888 4,988 X
Merced
County
III Atwater 28,168 31,970 X
Dos Palos 4,950 5,798 X
Gustine 5,520 6,110 X
Livingston 13,058 14,172 X
Los Banos 35,972 45,532 X
Merced 78,958 86,333 X
Merced
County
89,167 91,287 X
Modoc
County
II Alturas 2,827 2,715 X
Modoc
County
6,859 5,985 X
Mono
County
II Mammoth
Lakes
8,234 7,191 X
Mono County 5,968 6,004 X
Monterey
County
III Carmel-bythe-Sea3,722 3,220 X
Del Rey Oaks 1,624 1,592 X
Gonzales 8,187 8,647 X
Greenfield 16,330 18,937 X
King City 12,874 13,332 X
Marina 19,718 22,359 X
Monterey 27,810 30,218 X
Monterey
County
100,213 104,482 X
Pacific Grove 15,041 15,090 X
Salinas 150,441 163,542 X
Sand City 334 325 X
Seaside 33,025 32,366 X
Soledad 25,738 24,925 X
Napa
County
III American
Canyon
19,454 21,837 X
ITEM 2A ATTACHMENT 16

Page 916 of 1435 ends

13 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Calistoga 5,155 5,228 X
Napa 76,915 79,246 X
Napa County 26,213 22,842 X
St. Helena 5,814 5,430 X
Yountville 2,933 3,436 X
Nevada
County
I Grass Valley 12,860 14,016 X
Nevada City 3,068 3,152 X
Nevada
County
66,656 68,344 X
Truckee 16,180 16,729 X
Orange
County
IV Aliso Viejo 47,823 52,176 X
Anaheim 336,265 346,824 X
Brea 39,282 47,325 X
Buena Park 80,530 84,034 X
Costa Mesa 109,960 111,918 X
Cypress 47,802 50,151 X
Dana Point 33,351 33,107 X
Fountain
Valley
55,313 57,047 X
Fullerton 135,161 143,617 X
Garden Grove 170,883 171,949 X
Huntington
Beach
189,992 198,711 X
Irvine 212,375 307,670 X
La Habra 60,239 63,097 X
La Palma 15,568 15,581 X
Laguna
Beach
22,723 23,032 X
Laguna Hills 30,344 31,374 X
Laguna
Niguel
62,979 64,355 X
Laguna
Woods
16,192 17,644 X
Lake Forest 77,264 85,858 X
Los Alamitos 11,449 11,780 X
Mission Viejo 93,305 93,653 X
Newport
Beach
85,186 85,239 X
Orange 136,416 139,911 X
Orange
County
121,160 132,877 X
Placentia 50,533 51,824 X
Rancho Santa
Margarita
47,853 47,949 X
ITEM 2A ATTACHMENT 16

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14 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
San Clemente 63,522 64,293 X
San Juan
Capistrano
34,593 35,196 X
Santa Ana 324,528 310,227 X
Seal Beach2 24,168 25,242 X
Stanton 38,186 37,962 X
Tustin 75,540 80,276 X
Villa Park 5,812 5,843 X
Westminster 89,701 90,911 X
Yorba Linda 64,234 68,336 X
Placer
County
IV Auburn 13,330 13,776 X
Colfax 1,963 1,995 X
Lincoln 42,819 49,757 X
Loomis 6,430 6,836 X
Placer County 108,128 113,001 X
Rocklin 56,974 71,601 X
Roseville 118,788 147,773 X
Plumas
County
II Plumas
County
17,903 17,690 X
Portola 2,104 2,100 X
Riverside
County
IV Banning 29,603 29,505 X
Beaumont 36,877 53,036 X
Blythe 20,817 18,317 X
Calimesa 7,879 10,026 X
Canyon Lake 10,561 11,082 X
Cathedral City 51,200 51,493 X
Coachella 40,704 41,941 X
Corona 152,374 157,136 X
Desert Hot
Springs
25,938 32,512 X
Hemet 78,657 89,833 X
Indian Wells 4,958 4,757 X
Indio 76,036 89,137 X
La Quinta 37,467 37,558 X
Lake Elsinore 51,821 70,265 X
Menifee 77,519 102,527 X
Moreno
Valley
193,365 208,634 X
Murrieta 103,466 110,949 X
Norco 27,063 26,316 X
Palm Desert 48,445 51,163 X
Palm Springs 48,445 44,575 X
Perris 68,386 78,700 X
ITEM 2A ATTACHMENT 16

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15 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Rancho
Mirage
17,218 16,999 X
Riverside 303,871 314,998 X
Riverside
County
504,392 391,140 X
San Jacinto 44,199 53,898 X
Temecula 100,097 110,003 X
Wildomar 32,176 36,875 X
Sacrament
o County
IV Citrus Heights 83,301 87,583 X
Elk Grove 153,015 176,124 X
Folsom 72,203 80,454 X
Galt2 23,647 25,383 X
Isleton 804 794 X
Rancho
Cordova
64,776 79,332 X
Sacramento 466,488 524,943 X
Sacramento
County
554,554 610,442 X
San Benito
County
IV1 Hollister 34,928 41,678 X
San Benito
County
18,479 20,442 X
San Juan
Bautista
1,862 2,089 X
San
Bernardino
County
IV Adelanto 31,765 38,046 X
Apple Valley 69,135 75,791 X
Barstow2 22,639 25,415 X
Big Bear Lake 5,019 5,046 X
Chino 77,983 91,403 X
Chino Hills 74,799 78,411 X
Colton 52,154 53,909 X
Fontana 196,069 208,393 X
Grand
Terrace
12,040 13,150 X
Hesperia 90,173 99,818 X
Highland 53,104 56,999 X
Loma Linda 23,261 24,791 X
Montclair 36,664 37,865 X
Needles 4,844 4,931 X
Ontario 163,924 175,265 X
Rancho
Cucamonga
165,269 174,453 X
Redlands 68,747 73,168 X
Rialto 99,171 104,026 X
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16 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
San
Bernardino
209,924 222,101 X
San
Bernardino
County
291,776 300,478 X
Twentynine
Palms
25,048 28,065 X
Upland 73,732 79,040 X
Victorville 115,903 134,810 X
Yucaipa 51,367 54,542 X
Yucca Valley 20,700 21,738 X
San Diego
County
IV Carlsbad 105,328 114,746 X
Chula Vista 243,916 275,487 X
Coronado 18,912 20,192 X
Del Mar 4,161 3,954 X
El Cajon 99,478 106,215 X
Encinitas 59,518 62,007 X
Escondido 143,911 151,038 X
Imperial
Beach
26,324 26,137 X
La Mesa 57,065 61,121 X
Lemon Grove 25,320 27,627 X
National City 58,582 56,173 X
Oceanside 167,086 174,068 X
Poway 47,811 48,841 X
San Diego 1,307,402 1,386,932 X
San Diego
County
486,604 517,904 X
San Marcos 83,781 94,833 X
Santee 53,413 60,037 X
Solana Beach 12,867 12,941 X
Vista 93,834 98,381 X
San
Francisco
County
IV San Francisco 805,235 873,965 X
San
Joaquin
County
III Escalon 7,132 7,472 X
Lathrop 18,023 28,701 X
Lodi 62,134 66,348 X
Manteca 67,096 83,498 X
Ripon 14,297 16,013 X
San Joaquin
County
141,995 163,397 X
Stockton 291,707 320,804 X
Tracy 82,922 93,000 X
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17 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
San Luis
Obispo
County
III Arroyo
Grande
17,252 18,441 X
Atascadero 28,310 29,773 X
El Paso de
Robles
29,793 31,490 X
Grover Beach 13,156 12,701 X
Morro Bay 10,234 10,757 X
Pismo Beach 7,655 8,072 X
San Luis
Obispo
45,119 47,063 X
San Luis
Obispo
County
118,118 124,127 X
San Mateo
County
IV Atherton 6,914 7,188 X
Belmont 25,835 28,335 X
Brisbane 4,282 4,851 X
Burlingame 28,806 31,386 X
Colma 1,792 1,507 X
Daly City 101,123 104,901 X
East Palo Alto 28,155 30,034 X
Foster City 30,567 33,805 X
Half Moon
Bay
11,324 11,795 X
Hillsborough 10,825 11,387 X
Menlo Park 32,026 33,780 X
Millbrae 21,532 23,216 X
Pacifica 37,234 38,640 X
Portola Valley 4,353 4,456 X
Redwood City 76,815 84,292 X
San Bruno 41,114 43,908 X
San Carlos 28,406 30,722 X
San Mateo 97,207 105,661 X
San Mateo
County
61,222 63,164 X
South San
Francisco
63,632 66,105 X
Woodside 5,287 5,309 X
Santa
Barbara
County
III Buellton 4,828 5,161 X
Carpinteria 13,040 13,264 X
Goleta 29,888 32,690 X
Guadalupe 4,828 8,057 X
Lompoc 13,040 44,444 X
Santa
Barbara
29,888 88,665 X
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18 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Santa
Barbara
County
133,417 140,115 X
Santa Maria2 99,553 109,707 X
Solvang 5,245 6,126 X
Santa Clara
County
IV1 Campbell 39,349 43,959 X
Cupertino 58,302 60,381 X
Gilroy 48,821 59,520 X
Los Altos 28,976 31,625 X
Los Altos Hills 7,922 8,489 X
Los Gatos 29,413 33,529 X
Milpitas 66,790 80,273 X
Monte Sereno 3,341 3,479 X
Morgan Hill 37,882 45,483 X
Mountain
View
74,066 82,376 X
Palo Alto 64,403 68,572 X
San Jose 945,942 1,013,240 X
Santa Clara 116,468 127,647 X
Santa Clara
County
89,960 90,830 X
Saratoga 29,926 31,051 X
Sunnyvale 140,081 155,805 X
Santa Cruz
County
III Capitola 9,918 9,938 X
Santa Cruz 59,946 62,956 X
Santa Cruz
County
129,739 133,153 X
Scotts Valley 11,580 12,224 X
Watsonville 51,199 52,590 X
Shasta
County
III Anderson 9,932 11,323 X
Redding 89,861 93,611 X
Shasta
County
67,266 66,850 X
Shasta Lake 10,164 10,371 X
Sierra
County
II Loyalton 769 740 X
Sierra County 2471 2496 X
Siskiyou
County
II Dorris 939 860 X
Dunsmuir 1,650 1,707 X
Etna 737 678 X
Fort Jones 839 695 X
Montague 1,443 1,226 X
Mount Shasta 3,394 3,223 X
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19 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Siskiyou
County
24,156 24,116 X
Tulelake 1,010 902 X
Weed 2,967 2,862 X
Yreka 7,765 7,807 X
Solano
County
III Benicia 26,997 27,131 X
Dixon 18,351 18,988 X
Fairfield 105,321 119,881 X
Rio Vista 7,360 10,005 X
Solano
County
18,834 19,492 X
Suisun City 28,111 29,518 X
Vacaville2 92,428 102,386 X
Vallejo 115,942 126,090 X
Sonoma
County
III Cloverdale 8,618 8,996 X
Cotati 7,265 7,584 X
Healdsburg 11,254 11,340 X
Petaluma 57,941 59,776 X
Rohnert Park 40,971 44,390 X
Santa Rosa 167,815 178,127 X
Sebastopol 7,379 7,521 X
Sonoma 10,648 10,739 X
Sonoma
County
145,186 134,046 X
Windsor 26,801 26,344 X
Stanislaus
County
III Ceres 45,417 49,302 X
Hughson 6,640 7,481 X
Modesto 201,165 218,464 X
Newman 10,224 12,351 X
Oakdale 20,675 23,181 X
Patterson 20,413 23,781 X
Riverbank 22,678 24,865 X
Stanislaus
County
110,236 111,593 X
Turlock 68,549 72,740 X
Waterford 8,456 9,120 X
Sutter
County
III Live Oak 8,392 9,106 X
Sutter County 21,420 20,410 X
Yuba City 64,925 70,117 X
Tehama
County
I Corning 7,663 8,244 X
Red Bluff 14,076 14,710 X
Tehama 418 435 X
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20 County MSA class.
see Table A
Jurisdiction 2010
Census
Population
2020
Census
Population
at
least
10 du/ac
at
least
15 du/ac
at
least
20 du/ac
at
least
30 du/ac
Tehama
County
41306 42440 X
Trinity
County
II Trinity County 13,786 16,112 X
Tulare
County
III Dinuba 21,453 24,563 X
Exeter 10,334 10,321 X
Farmersville 10,588 10,397 X
Lindsay 11,768 12,659 X
Porterville 54,165 62,623 X
Tulare 59,278 68,875 X
Tulare County 142,872 134,876 X
Visalia 124,442 141,384 X
Woodlake 7,279 7,419 X
Tuolumne
County
I Sonora 4,903 5,003 X
Tuolumne
County
50,462 50,617 X
Ventura
County
III Camarillo 65,201 70,741 X
Fillmore 15,002 16,419 X
Moorpark 34,421 36,284 X
Ojai 7,461 7,637 X
Oxnard 197,899 202,063 X
Port
Hueneme
21,723 21,954 X
San
Buenaventura
(Ventura)
106,433 110,763 X
Santa Paula 29,321 30,657 X
Simi Valley 124,237 126,356 X
Thousand
Oaks
126,683 126,966 X
Ventura
County
94,937 94,003 X
Yolo
County
IV Davis 65,622 66,850 X
West
Sacramento
48,744 53,915 X
Winters 6,624 7,115 X
Woodland 55,468 61,032 X
Yolo County2 24,391 27,491 X
Yuba
County
III Marysville 12,072 12,844 X
Wheatland 3,456 3,712 X
Yuba County 56,627 65,019 X
ITEM 2A ATTACHMENT 16

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21 Sources:

Census 2020 Data Cities: https://data.census.gov/cedsci/table?g=0400000US06%241600000&y=2020&d=DEC% 20Redistricting%20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P1 Census 2020 Data MSA's: https://data.census.gov/cedsci/table?g=0100000US%243100000&y=2020&d=DEC%20 Redistricting%20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P1 Metropolitan and
Micropolitan Statistical
Areas:
https://www.whitehouse.gov/wp-content/uploads/2020/03/Bulletin-20-01.pdf ITEM 2A ATTACHMENT 16

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10728 & 10758 Mora Drive, Los Altos Hills
Silver Oaks Senior Living Community
Fire Code and Safety Analysis Report
Prepared For:

Town of Los Altos Hills
Prepared By:

PYROANALYSIS LLC
1095 Hilltop Drive, Suite 200, Redding, CA 96003
June 13, 2025
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Table of Contents
1 BACKGROUND ........................................................................................................................................................5

1.1 PROJECT SETTING.....................................................................................................................................................5 2 FIRE RISKS AND HAZARDS DISCUSSION...................................................................................................................7

2.1 VULNERABILITY OF PROJECT LOCATION AND SURROUNDINGS ............................................................................................7

2.2 RISKS ASSOCIATED WITH THE INTENDED RESIDENT POPULATION ........................................................................................8

2.2.1 FIRE DEATHS AND INJURIES .............................................................................................................................................8

2.2.2 MEDICAL EMERGENCIES AND THE CRITICAL ROLE OF EMERGENCY ACCESS IN SENIOR FACILITIES................................................10

2.2.3 HIGH-RISE THRESHOLD RATIONALE AND EMERGENCY ACCESS LIMITATIONS AT SILVER OAKS ....................................................11 3 REGULATORY SETTING: LOS ALTOS HILLS FIRE CODE .............................................................................................12

3.1 THE APPLICABLE FIRE CODE PROVISIONS.....................................................................................................................12

3.1.1 ORIGIN AND NATURE OF THE INTERNATIONAL FIRE CODE ...................................................................................................12

3.1.2 FIRE CODE ADOPTION PROCESS IN CALIFORNIA: INCORPORATED CITIES VS. FIRE PROTECTION DISTRICTS ....................................13

3.2 LOS ALTOS HILLS FIRE CODE ADOPTION......................................................................................................................15

3.2.1 CURRENT ADOPTION OF THE CALIFORNIA FIRE CODE (2022 EDITION)..................................................................................15

3.2.2 LOCAL AMENDMENTS AND MODIFICATIONS TO THE FIRE CODE ...........................................................................................16 4 PROJECTS DO NOT MEET FIRE CODE REQUIREMENTS............................................................................................19

4.1 FIRE CODE REQUIREMENTS ......................................................................................................................................19 5 ADDITIONAL OBSERVATIONS................................................................................................................................22

5.1 EXPERT TECHNICAL CRITIQUE OF WILDLAND RES MGT ANALYSIS .....................................................................................22

5.2 APPLICABLE CODE REQUIREMENTS FOR HIGH-RISE DESIGNATION.....................................................................................26 6 IMPLICATIONS OF HIGH FIRE HAZARD SEVERITY ZONE RECLASSIFICATION............................................................27

6.1 BUILDING CONSTRUCTION STANDARDS (CBC CHAPTER 7A)............................................................................................27

6.2 DEFENSIBLE SPACE AND VEGETATION MANAGEMENT (CFC CHAPTER 49, PRC §4291, GC §51182)......................................27

6.3 EMERGENCY ACCESS AND EGRESS PROVISIONS.............................................................................................................28

6.4 ENFORCEMENT AND PERMITTING IMPLICATIONS...........................................................................................................29 7 REFERENCES .........................................................................................................................................................31 ITEM 2A ATTACHMENT 17

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1 Background

1.1 Project Setting
Forrest Linebarger and Tower Investments LLC propose the development of two senior residential projects, each consisting of a multistory, multi-family residential building, located at 10728 and 10758 Mora Drive in the Town of Los Altos Hills, Santa Clara County, California. The projects combined would introduce a total of 62 senior residential units. Forrest Linebarger refers to these new multistory buildings as the Silver Oaks Senior Living Community.

The two parcels are currently undeveloped and slope steeply downward to the east from Mora Drive into a densely vegetated drainage. A separately owned and developed single-family residence is situated between the two project sites. Both parcels front Mora Drive, which serves as the only access road. The area is characterized by steep topography and narrow, winding roadways that pose inherent challenges for emergency access and evacuation.

At 10728 Mora Drive (Lot 1), the proposed development comprises 30 residential units within a 67,716-square-foot, 8 to 9-level structure featuring an occupied roof and a mezzanine. The building is designed to follow the natural slope of the site, incorporating a sub-basement, basement, podium/garage, and a mezzanine level. The structure will occupy approximately 88.2% of the 0.374-acre parcel and reach a design height of 80 feet, 4 inches from the grade plane to the roof membrane. The height of the building’s east elevation, measured from the finished grade to the top of the parapet, is 112 feet, 9 inches. The podium-level garage will provide 27 parking spaces via a mechanical car stacker, featuring electric vehicle charging stations and long-term bicycle storage.

FIGURE 1: 10728 MORA DRIVE, NORTH ELEVATION
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The second building, located at 10758 Mora Drive (Lot 3), will be nearly identical in design and purpose, with 32 residential units and 70,665 square feet, 8 to 9-level structure with an occupied roof and a mezzanine. It will occupy

83.1% of the 0.397-acre lot and reach a design height of 80 feet, 2 inches from the grade plane to the roof membrane. The height of the building’s east elevation, measured from the finished grade to the top of the parapet, is approximately 120 feet. This structure will also feature a 27-space podium garage with accessible, visitor, and EVready parking, as well as bicycle storage facilities.

Figure 2: 10758 Mora Drive, North Elevation
Each building will offer a comprehensive range of senior-focused amenities, including roof decks, covered terraces, multipurpose and exercise spaces, media and laundry rooms, dining facilities, lobbies, music rooms, recreation spaces, roof gardens, sitting rooms, and elevators for those too frail or impaired to use the stairways. Combined, the two buildings represent 138,381 square feet of total development, with 54 parking spaces and capacity for 62 senior residential apartment units1
.

The project is designed to serve a retirement-age population. Staffing needs will be met by non-resident employees who will commute to the site to provide elderly care and operational support. 1 Revision Submittal. (2025, May). 10728 Mora Drive; Revision Submittal. (2025, May). 10758 Mora Drive ITEM 2A ATTACHMENT 17

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Overall, the Silver Oaks project represents a medium-density senior living development located in a constrained, fire-prone area with limited emergency access. The buildings are designed to meet current fire-resistive construction standards and include services and infrastructure tailored to support the comfort and well-being of an aging and potentially vulnerable population. A free shuttle service to downtown Los Altos Hills will be provided for residents between 10:00 AM and 4:00 PM, reducing vehicle trips and offering transportation to residents with mobility impairments.

Topographically, both parcels slope gently to the northeast across their central and western portions. The eastern sections of both lots descend more steeply into a wooded ravine, containing denser vegetation, including trees and brush. In contrast, the more open western and central areas are dominated by weedy, invasive plant species and scattered trees. Vegetation removal and replanting are integral to site preparation. Fourteen existing oak trees will be removed and replaced with fifteen newly planted oaks, along with landscaping and 6-foot-tall redwood fences surrounding the two buildings, as part of the landscape restoration plan. 2 Fire Risks and Hazards Discussion

2.1 Vulnerability of Project Location and Surroundings
The proposed Silver Oaks Senior Living Community projects are located at the terminus of Mora Drive, adjacent to the Rancho San Antonio County Park and Open Space Preserve. This setting introduces significant fire-related vulnerabilities that warrant thorough consideration. While the area is not presently designated as a Very High Fire Hazard Severity Zone (VHFHSZ) by the State Fire Marshal (CAL FIRE)2 , its proximity to natural open spaces—
characterized by steep, wooded ravines—creates a landscape highly susceptible to fire ignition and rapid spread.

For this reason, CAL FIRE’s 2025 Fire Hazard Severity Zone (FHSZ) maps classify the area as a High Fire Severity Zone (HFHSZ), and the Town of Los Altos Hills intends to designate the area as a VHFHSZ based on certain local conditions as of the preparation of this analysis. The eastern portions of the parcels descend sharply into vegetated draws, which, during wildfire events, can act as conduits for fast-moving flames and flying embers, especially under winddriven conditions.

The vegetative composition of the site further exacerbates fire risks. Despite partial clearing, the parcels maintain a moderate to dense understory of brush, invasive plants, and mature oaks—fuels that pose a latent threat, particularly in the context of prolonged droughts and increasing ambient temperatures in the region. Studies by CAL FIRE and academic institutions have consistently highlighted that wildland-urban interface (WUI) communities, such as Los Altos Hills, where natural areas abut residential developments, face heightened wildfire threats due to the combined influence of fuel continuity, climatic exposure, and limited evacuation routes.

A critical concern is that the only viable evacuation route is north via Mora Drive and Sunhills Drive, which serves as the sole ingress and egress to the proposed development. The proposed emergency egress to the south is through a locked gate along the meandering and underdeveloped Mora Trail, which runs through the Rancho San Antonio County Park and Open Space Preserve. This route is not open to the public for vehicular access and is used as a public recreation trail. In wildfire emergencies, such limited access can become a point of catastrophic failure.

Emergency vehicles may be delayed or entirely obstructed if traffic congestion, fallen trees or utility poles, or fire 2 CAL FIRE (n.d)
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conditions compromise the roadway. Concurrently, evacuation efforts may be hindered by bottlenecks, especially if multiple buildings evacuate simultaneously or if responding emergency vehicles congest the route. Historical precedents, such as the tragedies in Paradise and Lahaina, underscore the dire consequences of inadequate evacuation infrastructure in fire-prone areas.

Figure 3: Available Evacuation Routes North and South of the Senior Living Buildings from Mora Access Road

2.2 Risks Associated with the Intended Resident Population

2.2.1 Fire Deaths and Injuries
The design of the Silver Oaks buildings—situated on steep slopes with vertical heights exceeding 100 feet and served by narrow 5-foot-wide exterior stairways bordered by 6-foot wooden fencing, combustible landscaping, and dense riparian vegetation in the drainage east of the buildings—poses a severe fire and life safety risk for occupants of any age. However, the required evacuation travel distances, approaching the length of a football field, present a particular danger to older adults and mobility-impaired occupants, who may be unable to evacuate in time during a rapidly advancing fire.

The vulnerability of older adults in all kinds of fire scenarios is well-documented and statistically significant.

According to the U.S. Fire Administration (USFA), in 2023, individuals aged 65 and over faced a fire death rate of 33.0 deaths per million population, making them 2.5 times more likely to die in a fire compared to the general population.
• This risk escalates with age:
o Ages 65–74: 28.5 deaths per million; 2.2 times the general population's risk. o Ages 75–84: 37.5 deaths per million; 2.9 times the general population's risk o Ages 85 and over: 44.7 deaths per million; 3.4 times the general population's risk.

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• From 2014 to 2023, the fire death rate for adults aged 65 and over increased by 26%3 . Several factors contribute
to this heightened vulnerability:
o Reduced Mobility: Older adults are at increased fall risk and many older adults require assistance to move, making rapid evacuation challenging.
o Cognitive Impairments: Conditions such as dementia can delay recognition of danger and hinder decision-making during emergencies.
o Sensory Limitations: Hearing and vision impairments may prevent timely detection of alarms or evacuation signals.
o Pre-existing Medical Conditions and Medical Dependencies: Pre-existing conditions such as cardiovascular disease and reliance on medical equipment like oxygen concentrators can pose additional risks during fires, especially if evacuation is delayed.

The dangers associated with medical oxygen are particularly noteworthy. There have been multiple incidents where fires were ignited due to smoking near oxygen equipment, leading to fatalities among older adults.

In 2023 alone, 498 older adults in the United States died due to fire-related incidents. Given these factors, the importance of reliable emergency access cannot be overstated. Delays in medical response during fires can be fatal, especially for residents with high medical needs. Emergency services must have unobstructed, timely access to the buildings to perform rescues and provide medical care. The single-access route via Mora Drive and the distance of the building access from the roadway raise serious concerns about the feasibility of such emergency responses during a wildfire, building fire, or medical event.

Case Studies and Statistical Context
Older adults have repeatedly suffered the highest toll in major wildfires across the U.S., especially in California.

Multiple high-profile incidents since 2000 offer sobering examples of the acute vulnerability this population faces:
• Most of the 18 fatalities recorded in the 2025 Eaton Fire in Southern California were 65 or older, with the average age being 774
.
• During the 2023 Maui wildfires, over two-thirds of the 102 confirmed deaths were individuals aged 60 and older. Some lived in older structures with poor egress; others failed to receive evacuation orders or physically could not escape in time5
.
• In the 2022 Mill Fire in Weed, California, two elderly women were among the fatalities, illustrating that even relatively small fires can be deadly when evacuation timing or support is inadequate6 .
• In the 2020 East Troublesome Fire in Colorado, an elderly couple aged 86 and 84 perished in their home after choosing not to evacuate—a common issue when communication or trust in emergency messaging is lacking7
.
• In the 2018 Camp Fire, which destroyed the town of Paradise, California, 67 of the 85 confirmed fatalities were aged 65 and older8
.
3 U.S. Fire Administration. (2023)
4 Jimenez
5 Associated Press. (2023)
6 NBC Los Angeles
7 Spells
8 Auditor of the State of California
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These tragedies reinforce the need for proactive planning and infrastructure design that reflects the unique limitations of senior residents. In each case, delayed response, mobility impairment, and poor evacuation logistics contributed significantly to mortality.

Wildfires not only pose a direct threat from flames and heat but also create conditions that compromise the health and safety of medically fragile populations. Power outages disable critical medical equipment; road closures isolate residents; and smoke inhalation exacerbates respiratory and cardiovascular conditions common among older adults.

Facilities such as the proposed Silver Oaks Senior Living Community, which cater exclusively to seniors, must not only comply with baseline building codes but also adopt enhanced safety measures, including hardened structures, redundant communication systems, backup power, on-site emergency supplies, and specially trained staff capable of leading high-acuity evacuations under extreme conditions.

2.2.2 Medical Emergencies and the Critical Role of Emergency Access in Senior Facilities Older adults are disproportionately vulnerable not only to fire but also to medical emergencies that can arise even in the absence of external hazards. According to the Centers for Disease Control and Prevention (CDC), people aged 65 and older account for over 15 million emergency department visits annually in the U.S.—nearly a quarter of all emergency visits nationwide. The most common reasons include heart attacks, strokes, respiratory distress, and injuries from falls—many of which require urgent intervention to prevent death or long-term disability9 .

In facilities housing older adults, rapid access for paramedics and emergency responders is not just a matter of convenience—it is often the determining factor between a successful outcome and a fatality. The stakes are higher in settings like Silver Oaks, which proposes multi-level buildings housing senior residents. Every minute counts in a cardiac arrest or respiratory failure. The American Heart Association reports that for every minute without CPR or defibrillation during a cardiac arrest, the chance of survival drops by 7 to 10 percent10. Without immediate access to the patient, first responders may not reach them in time to render life-saving care.

In multistory buildings, response logistics become more complicated. When elevators are out of service—whether due to power outages during a wildfire, building fire, Public Safety Power Shutoff (PSPS), or mechanical failure—first responders are forced to carry patients down stairwells. This presents both practical and safety challenges:
• Stairwell navigation requires additional personnel, time, and equipment such as stair chairs or litters.

Transport times increase significantly for residents who are bedridden or non-ambulatory. • In emergencies involving multiple patients, such as wildfire evacuations, smoke inhalation incidents, or heat-related illnesses during an outage, these constraints can overwhelm response capacity.

During fire emergencies, the risk is compounded. Elevators are often disabled as a precaution or due to power disruption. If emergency personnel must carry residents down several flights of stairs—potentially in smoke-filled conditions or while navigating around evacuating residents—it significantly increases the danger and complexity of the evacuation.
9 Cairns
10 American Heart Association
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This is not hypothetical. In the 2003 E2 nightclub fire in Chicago and the 2017 Grenfell Tower fire in London, though different in origin, investigations revealed that a lack of emergency vertical mobility in multi-level structures disproportionately endangered vulnerable populations. In wildfire-prone regions like California, where building codes and emergency planning must account for power disruptions and simultaneous medical and fire risks, these limitations must be taken seriously11.

For these reasons, emergency planning for facilities like Silver Oaks must extend beyond structural fire compliance to include:
• Immediate fire department access for deployment of hose streams and ladders • Redundant elevator systems and backup generators
• Designated fire-rescue access zones and wide stairwells optimized for stretcher movement • Resident triage and evacuation plans tailored for limited-mobility individuals • Pre-coordination with fire and EMS agencies to ensure site familiarity and entry access under all conditions
Simply put, when senior residents experience a medical emergency, the difference between life and death can be measured in seconds. That difference hinges not only on medical training or equipment, but on the ability to reach the patient quickly. In a multistory, single-access development like Silver Oaks, emergency access must be treated as a critical design and policy priority.

2.2.3 High-Rise Threshold Rationale and Emergency Access Limitations at Silver Oaks The California Building Code (CBC) defines a high-rise building as one with an occupied floor more than 75 feet above the lowest level of fire department vehicle access. While this definition may appear arbitrary, it is based on practical constraints in firefighting operations and well-documented life safety considerations. The 75-foot benchmark represents the maximum effective reach of most fire department aerial ladder trucks under real-world conditions, which account for setback requirements, terrain, and the deployment angle of the ladder. Beyond this height, it becomes increasingly difficult—if not impossible—for fire personnel to conduct rescues or initiate firefighting efforts from outside the building12.

In such scenarios, emergency responders must rely entirely on internal stairwells and elevators to reach affected floors, often while carrying over 60 pounds of gear. This reliance is particularly problematic in a multi-level senior living facility, where elevators may be out of service due to power loss or fire safety protocols, and stairwell evacuations are especially difficult for residents with mobility impairments. For this reason, the IBC imposes additional fire safety requirements on buildings classified as high-rises, including pressurized stairwells, fire service elevators, and emergency voice/alarm communication systems13.

Given the proposed buildings geometry (heights and site layout) and the fact that the proposed fire department access plan show fire department operations at the front of the buildings or down narrow walks midslope on either side of the buildings and that the most recent resubmittal increased height of the projects’ buildings, the Silver Oaks Senior Living Community needs to be reviewed by the Town’s Building Official to determine whether the buildings qualify as high rises. However, even if assuming that the projects may narrowly avoid meeting the strict technical 11 BBC News
12 Mason
13 International Building Code
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threshold for a high-rise, by showing the lowest level of fire department access to the buildings midslope from Mora Drive, the topography of the site complicates the analysis. The buildings’ downhill-facing eastern elevations reach heights of more than 100 feet, and because these faces descend away from the fire department access point on Mora Drive, their effective vertical profile exceeds 75 feet from a response perspective. In addition, the extremely narrow west side of the buildings only allows aerial ladder access to a few of the apartments, while the majority are completely inaccessible by ladder. When combined with the lack of alternate vehicular access, the project should be treated functionally as a high-rise from an emergency planning perspective.

When aerial ladders cannot reach specific portions of a building due to terrain or setbacks, firefighters must deploy ground ladders. Ground ladders, while essential, are limited in height and difficult to deploy in sloped environments. The longest standard ground ladders typically extend to 35 or 40 feet and require multiple firefighters to maneuver and stabilize. This makes them ill-suited for accessing upper floors of buildings with four or more stories—especially on uneven or obstructed ground14.

To address these access issues, fire code officials often require the installation of ladder pads—flat, stable, and unobstructed areas near the base or sides of the building (with a minimum recommended size of 10 feet by 10 feet) — that allow for the safe placement of ground ladders. Ladder pads are particularly important in developments like the Silver Oaks buildings, where steep slopes, narrow sidewalks (5 feet), a 6-foot redwood perimeter fence, and dense vegetation make the installation of ladder pads and, thus, perimeter access via ladders, impossible. If firefighters are unable to reach upper floors via aerial apparatus and cannot safely deploy ground ladders due to terrain, then occupants—many of whom may be physically unable to self-evacuate—are placed at unacceptable risk.

Both the National Fire Protection Association (NFPA) and the Federal Emergency Management Agency (FEMA) emphasize the need for risk-based fire planning that goes beyond minimum code compliance in developments housing vulnerable populations. NFPA’s Community Risk Reduction (CRR) framework encourages the evaluation of unique site conditions and demographic profiles, while FEMA underscores the necessity of pre-planning for at-risk groups in constrained environments, such as senior care facilities in wildfire-prone areas1516.

Given these factors, Silver Oaks must not be evaluated solely on a literal code definition of a high-rise, but rather on the totality of its design, location, and population vulnerabilities. As a steeply sloped, multistory senior facility with limited emergency vehicle access, the project mirrors the operational challenges of a high-rise and must be held to equivalent safety standards.
3 Regulatory Setting: Los Altos Hills Fire Code

3.1 The Applicable Fire Code Provisions

3.1.1 Origin and Nature of the International Fire Code
State and local Fire Code regulations in California are grounded on the International Fire Code (IFC). Understanding the origin, development process, and structure of the IFC is essential when evaluating its application to constrained 14 Brush
15 National Fire Protection Association. (n.d.)
16 U.S. Fire Administration. (2022)
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or high-risk developments such as the Silver Oaks projects. Contrary to the misconception that the IFC is a subjective guideline, it is, in fact, a set of objective, consensus-based standards grounded in decades of fire protection engineering, real-world fireground experience, and professional best practices.

The IFC was first published in 2000 by the International Code Council (ICC), the result of a merger among the nation’s three leading code development organizations: the Building Officials and Code Administrators International (BOCA), the Southern Building Code Congress International (SBCCI), and the International Conference of Building Officials (ICBO). These groups brought together decades of knowledge from their respective model fire codes—the Uniform Fire Code (UFC), Standard Fire Prevention Code, and BOCA National Fire Prevention Code—to create a unified standard applicable across jurisdictions in the United States.

The IFC is a model code that consists of fire safety regulations and construction standards and is updated every three years through a transparent, structured, and evidence-driven process. Code change proposals are submitted by stakeholders—including fire officials, engineers, architects, manufacturers, and members of the public—and reviewed by technical committees in open hearings. Each proposal is vetted, revised through public comment, and voted on by ICC members, the majority of whom are code officials from jurisdictions nationwide. The resulting code reflects not just technical advancements and emerging threats, but a national consensus on what constitutes minimum acceptable fire safety.

Importantly, the IFC is built upon enforceable, objective performance criteria. While it includes specific prescriptive elements such as Section 503.1.1’s 150-foot fire apparatus access requirement, the code ensures that these provisions are based on measurable, technical factors like hose reach, water flow requirements, and tactical access needs. Its provisions are validated by data and field experience, and the code's authorship intentionally harmonizes real-world firefighting capabilities with construction and planning realities.

That said, the California Fire Code (CFC) and IFC do provide for limited flexibility, but only within a framework of equivalency. Sections 104.9 and 104.10 empower the authority having jurisdiction (AHJ) to approve alternative methods or materials only if the applicant can demonstrate that they provide equivalent or greater levels of fire protection. This allowance for engineered judgment is not a subjective loophole—it is a deliberate, codified mechanism for ensuring the code remains adaptable to complex scenarios without compromising on fire safety because of noncompliance with baseline standards. The IFC and CFC contemplate that all such decisions by an AHJ to deviate from the IFC’s or CFC’s baseline standards by using alternative methods must be documented, justified, and defensible.

As explained further below, the State of California has utilized the IFC to form the state’s fire prevention, protection, and mitigation standards. Specifically, the IFC is the core component and baseline of the CFC under Title 24 of the California Code of Regulations (CCR). Likewise, most incorporated cities in California adopt a fire code that is amended to meet local conditions as specified in the Health and Safety Code, Section 18941.5. These amendments are found in the municipal codes of Bay Area jurisdictions such as Daly City, Pacifica, and Santa Cruz, which have all adopted IFC section 503 as part of their fire code.

3.1.2 Fire Code Adoption Process in California: Incorporated Cities vs. Fire Protection Districts Incorporated cities and fire protection districts in California each follow distinct legal pathways for adopting and enforcing fire codes. Understanding the differences between these pathways is critical when evaluating project compliance.

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Fire Code Authority in California
California mandates the use of the CFC, Title 24, Part 9 of the CCR, which is based on the IFC and as amended by the California State Fire Marshal17. By way of background, Title 24 of the CCR—also known as the California Building Standards Code—include requirements for (1) building structural, plumbing, electrical and mechanical systems, and (2) fire, life safety, energy conservation, green building design, and accessibility in and about buildings18. The California Building Standards Commission (CBSC) oversees the adoption, approval, and publication of Title 24 pursuant to authority conferred upon it by Division 13, Part 2.5 of the Health and Safety Code, commencing with Section 18901.

Title 24 applies to all building occupancies, as well as related features and equipment, throughout the state19. As an initial matter, the CFC consists of provisions that the State Fire Marshal adopts from Title 24 as the state’s baseline fire regulations. Local building or fire officials are required to enforce Title 24 provisions shown as adopted by the State Fire Marshal 20. Incorporated cities, counties, and special fire protection districts may adopt the CFC by reference through ordinances enacted under Government Code §50022.1–50022.8. These provisions specify the required procedures for code adoption by reference, including public hearings and advance notice21. Additionally, as explained below, these local jurisdictions may adopt ordinances to implement more restrictive requirements than what Title 24 requires, including fire code requirements from Title 24 beyond what the State Fire Marshal has adopted in the CFC, by making findings and submitting the local amendments to the appropriate state agency as required by statute.

The most recent Title 24, including the CFC, was adopted by the CBSC in July 2022, effective January 1, 2023.

Incorporated Cities
Cities, such as the Town of Los Altos Hills, adopt the CFC by passing an ordinance that references the code and any amendments. This process includes public notice (pursuant to Government Code §6066), a public hearing, and adoption by a majority vote of the city council22. Any local amendments that are more stringent than the CFC must be justified through findings of necessity due to local climatic, geological, or topographical conditions, per Health & Safety Code §17958.723. These findings must be filed with the CBSC 24. Unlike fire protection district ordinances, incorporated cities are not required to file these findings with the Department of Housing and Community Development (HCD) when adopting ordinances to amend the Building Standards Code, including the Fire Code.

Independent Fire Protection Districts
Fire protection districts are governed by the Fire Protection District Law of 1987 (Health & Safety Code §13800 et seq.). These districts may adopt the CFC under the same procedures as cities (Government Code §50022 et seq.)25. 17 California Building Standards Commission. (2024, July) 18 California Building Standards Commission. (2022)
19 California Health & Safety Code §17950; see Footnote 14 CBSC Guide. 20 California Health & Safety Code §13145, 13146, and 13196. 21 California Government Code §§ 50022.1–50022.8. (2023) 22 California Government Code §6066 and §50022.3.
23 California Health & Safety Code §§17958, 17958.5, 17958.7, 18941.5. 24 California Health & Safety Code §17958.7.
25 California Health & Safety Code §13869.

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However, if the district enacts amendments that exceed the state code, it must provide proposed ordinance text and findings to affected cities or counties at least 30 days before holding a public hearing26.

Following adoption, the ordinance must be ratified by the legislative bodies of the affected cities or counties. The ratifying body may approve, deny, or modify the ordinance within 15 days, and must submit the adopted text and findings to the HCD27. Enforcement authority may then be delegated to the fire district’s fire chief or to the local building official per Health & Safety Code §13869.7(h).

Summary of Differences
While both cities and fire districts follow similar procedures to adopt the base fire code, cities have direct control over enforcement and do not require external ratification or submitting their adopted codes to state agencies other than the CBSC. In contrast, independent fire districts must seek approval from other jurisdictions when adopting more stringent provisions and must file the adopted ordinance with HCD. It is important to understand which procedure is applicable when examining locally adopted codes.

The implications for developments like the Silver Oaks projects are clear: the fire department access requirements adopted by the Town of Los Altos Hills constitute the minimum fire and building code standards, complying with state law and best practices. This intergovernmental process reinforces the essential nature of code compliance in high-risk, high-consequence developments.

3.2 Los Altos Hills Fire Code Adoption

3.2.1 Current Adoption of the California Fire Code (2022 Edition) Los Altos Hills has formally adopted the 2022 California Fire Code (CFC) as part of its municipal regulations. The locally adopted Fire Code was adopted on December 15, 202228, and went into effect on January 1, 2023. The Town’s Municipal Code Title 8 (Building Regulations), Chapter 1.8 “California Fire Code,” incorporates the 2022 CFC by reference, including standard fire code appendices for fire-flow and hydrants and Section 503 as amended. In practice, this means the latest statewide fire safety standards (Part 9 of Title 24, California Code of Regulations) apply to all development in Los Altos Hills, as amended by the Town pursuant to its authority conferred under state law. The Town’s adopted ordinance reflects the current fire code cycle and ensures consistency with Santa Clara County Fire Department (SCCFD) policies and operations, which serve as the Los Altos Hills County Fire District contract fire agency. In 2022, the Town adopted Ordinance 607, which aligned its regulations with the updated 2022 CFC, effective statewide as of January 1, 2023.

Fire protection, fire related development/building plan reviews, and fire code enforcement services are provided to the Town by the Santa Clara County Central Fire Protection District (Santa Clara County Fire Department) per a Fire and Emergency Medical Services agreement29 between Los Altos Hills County Fire District, the agency having responsibility for services, and the Santa Clara County Central Fire Protection District. If a building or development applicant disputes the conditions and requirements imposed by the SCCFD, the applicant may appeal the dispute to the City Council of the Town of Los Altos Hills, which has final authority in disputes related to fire code 26 California Health & Safety Code §13869.7(a)-(c).
27 California Health & Safety Code §13869.7
28 Town of Los Altos Hills (2022)
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requirements. In providing these services, the SCCFD reviews development project applications for compliance with the Fire Code as adopted by the Town. The CFC and California Building Code (CBC) are adopted by the Town of Los Altos Hills Health & Safety Code §17958.7, not the Los Altos Hills County Fire District.

3.2.2 Local Amendments and Modifications to the Fire Code Los Altos Hills has amended the CFC and other parts of the Building Standards Code under Title 24 by incorporating local provisions to address specific safety concerns within the community. These local modifications, enacted by Town ordinance, impose requirements or standards that exceed state minimums. Key amendments include:
• Expanded Fire Sprinkler Requirements: Los Altos Hills mandates automatic fire sprinkler systems in situations beyond the state requirements for new buildings. • Wildfire Hazard Construction Standards: Considering the Town’s high wildfire risk, Los Altos Hills has locally adopted Chapter R337 of the California Residential Code to apply throughout the town. • Additional Operational Permit Categories: The Town modified Section 105 of the Fire Code to broaden the types of operations that necessitate fire department permits. • High-Hazard Materials Storage Regulations: Los Altos Hills has established specialized rules to address largescale energy storage hazards. • Fire Apparatus Access and Water Supply: The Town adopted IFC Chapter 5, including Section 503.1.1, as amended.
• Administrative Provisions: The Town has introduced coordination requirements for final inspections and customized the fire code appeals process to designate the City Council as the Board of Appeals.

As part of its local amendments to the CFC, the Town elected to incorporate Section 503, which relates to fire apparatus access road requirements. Section 503 is a part of the IFC (which forms the basis for the CFC under Title 24), but the code section itself has not been adopted by the State Fire Marshal as a part of the baseline Fire Code.

Section 503 is only applicable, as is the case here, if a local jurisdiction adopts it with findings at the time it adopts the CFC. As the Town of Los Altos Hills has adopted the CFC with local amendments to add Section 503, it is the applicable standard here.

Section 503: 150-Foot Fire Department Access Rule
In the context of the Silver Oaks Senior Living Community, the fire department access limitations raise a critical lifesafety concern, particularly for senior residents. Section 503 of the IFC establishes prescriptive site access criteria that reflect the operational realities of fireground response. Among these, the 150-foot rule codified in Section 503.1.1 is paramount.

The requirement mandates that the fire department access road must extend to within 150 feet of all portions of the first story of any building. This distance is not arbitrary: it is rooted in the practical limits of preconnected hose lines carried by fire apparatus. Most engines are equipped with pre-connected attack lines of 150 feet, and that distance defines the outer limit of rapid intervention without requiring time-consuming hose extensions. Once that limit is exceeded, the speed and efficiency of initial fire attack are compromised, particularly on steep terrain or with multiple story buildings—both of which are present at the Silver Oaks sites.

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Historical evolution of the fire code confirms this requirement has long-standing roots in legacy codes such as the 1988 Uniform Fire Code, which required apparatus access within 150 feet of exterior walls. As firefighting apparatus and tactics standardized during the mid-20th century, codes coalesced around this number, formalizing it in both the IFC and NFPA standards (such as NFPA 14 for standpipes). The requirement remains unchanged through successive editions of the IFC, including the 2021 and 2024 versions, underscoring its enduring relevance.

At Silver Oaks, both proposed structures are sited on steeply sloped lots where only one access road—Mora Drive— serves the development. This single point of ingress and egress already presents substantial evacuation and response limitations, but the challenge is compounded by the inability of fire apparatus to get within 150 feet of all portions of the buildings (see Figure 4). These east-facing facades, which descend down slope, exceed 100 feet in height and lie beyond the code-defined reach of fire suppression equipment from the road.

Further complicating emergency response is the fact that the proposed senior living buildings, located hundreds of feet from the nearest intersecting road at the terminus of Mora Drive, will require fire response resources to queue up for extended distances on the narrow roadway. This will reduce the capabilities of additional fire engine pump and truck operations, force firefighters to haul hose and gear long distances to reach the buildings and narrow the roadway to less than 10 feet.

In these conditions, the fire department cannot initiate a standard hose stretch or conduct ladder rescues along the lower levels of the eastern elevations. Ground ladder deployment is also severely limited. Standard ground ladders extend from 35 to 40 feet and require flat terrain for stabilization—conditions not met by the ravine-like drop-off behind both buildings.
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 (45,720mm) 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. (emphasis added.)
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FIGURE 4: ILLUSTRATION OF 150’ HOSE PULL LIMITATIONS
Though the IFC allows for exceptions when terrain makes compliance infeasible (IFC 503.1.1 Exception 2), such exceptions are conditional. They require alternative fire protection measures that demonstrably offset the risk. The absence of a second vehicular access point, the ever-present wildfire threat, combined with the topographic inaccessibility to large portions of the structures, and the vulnerability of the senior population for which the housing is intended, preclude alternatives that will fulfill this fundamental safety benchmark.

The concern is not limited to firefighting access alone. As discussed in prior sections, older adults—particularly those with mobility or cognitive impairments—require rapid rescue during fire incidents. If fire crews cannot reach the building envelope with hose lines or ladders or must carry equipment hundreds of feet down slope or through constrained stairwells, the time to rescue increases dramatically. When measured in minutes, that delay can mean the difference between life and death for this vulnerable population.

Buildings sited midslope, as are both of the proposed Silver Oaks buildings, with stories above and below the access grade, are particularly challenging to firefighters. To access a fire below the access point, firefighters must extend hoses down interior stairways into the heat and smoke within the unpressurized stairwells, which creates a chimney effect. If a window on a lower story fails, superheated gases can envelope firefighters in the stairway or upper floors, as occurred in Boston’s Back Bay in March 26, 201430, in which two firefighters perished and the June 2, 2011, Berkeley Way fire in San Francisco31, which also claimed the lives of two firefighters. Further complicating the fire attack is a design that would require firefighters who may be responding from a distant fire station, who are unfamiliar with the building layout (or the location of the exterior standpipe), to haul hoses, nozzles, and tools down hundreds of feet of steps in fire and smoke conditions to access an exterior standpipe located on the building’s 30 Firehouse.com News
31 Bowyer
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exterior. Such proposed alternatives exacerbate the difficulty and danger associated with fighting fires and attempting occupant rescue on extremely tall buildings.

The Silver Oaks site designs, which locates tall multistory buildings along a slope with constrained frontage, functionally violates the intent of IFC Section 503. Without redesign or substantial compensating fire protection measures, it falls short of the access standard intended to ensure timely and effective fire suppression and rescue.

The imperative of rapid-fire control and search in buildings housing such a vulnerable population cannot be overemphasized; the 150-foot access rule is a codified reflection of the reach and capacity of fire crews under emergency conditions. The rule exists because buildings beyond that threshold have historically proven difficult— often impossible—to protect effectively. In high-risk, high-consequence settings such as a senior living facility, adherence to this requirement is not merely best practice—it is essential to life safety. 4 Projects Do Not Meet Fire Code Requirements

4.1 Fire Code Requirements
Section 503.1.1 Requirements and Project Deficiencies
Section 503.1.1 of the IFC and listed under Title 24, as adopted by the Town of Los Altos Hills in accordance with state regulations, mandates that fire apparatus access roads must extend to within 150 feet of all portions of the first story of any facility as measured by an approved route around the exterior of the building. This requirement is grounded in operational limitations of standard firefighting equipment—specifically the effective range of preconnected hose lines used in initial fire attack operations.

The Silver Oaks project fails to meet this requirement. Due to the site’s steep topography and the setback of the buildings on the descending slope, significant portions of the eastern elevations are situated beyond 150 feet from the nearest fire apparatus access point along Mora Drive. No approved alternate route is proposed to meet this requirement by equivalency. As detailed in official plan review comments from the SCCFD and Town project comment letters, revised site plans (including Revision 8 dated May 29, 2025) still fail to resolve the distance and access barriers. As such, the proposed buildings remain non-compliant with the Building and Fire Code safety standards, compromising SCCFD’s ability to conduct timely fire suppression and rescue operations.

Reasonableness of Fire Official’s Denial of AMMR
An Alternate Means and Methods Request (AMMR) is a formal process under CFC Section 104.10 that allows applicants to propose different design, material, or operational strategies to comply with the baseline fire code requirements when a design is unable to meet the minimum code standards, provided the proposed alternative measures are demonstrated to be equivalent or superior in terms of safety, durability, and effectiveness.

In this case, it was reasonable for the fire official to deny the AMMR submitted for Silver Oaks buildings because the proposed alternatives did not demonstrate equivalent fire protection or fulfill the intent of the code. The AMMR did not include:
• A credible analysis proving that fire hose deployments and egress times would remain within acceptable thresholds; Greater time is required to deploy a high-rise bundle or adaptors and wildland fire hose from a remote standpipe than from a fire engine positioned within 150 feet of all portions of the building ITEM 2A ATTACHMENT 17

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• That firefighters deploying hoselines down the stairways to protect the building and occupants from a wildland fire would not be placed in harm’s way.
• Engineered fire flow analyses or staffing models accounting for high-occupancy rescue in limited access conditions.
“The provisions of this code are not intended to prevent the installation of any material or to prohibit any design or method of construction not specifically prescribed by this code, provided that any such alternative has been approved. An alternative material, design or method of construction shall be approved where the fire code official finds that the proposed design is satisfactory and complies with the intent of the provisions of this code, and that the material, method or work offered is, for the purpose intended, not less than the equivalent of that prescribed in this code in quality, strength, effectiveness, fire resistance, durability and safety...”. CFC 104.10 The project’s latest revision and accompanying revised plans did not include any engineering evidence of equivalency, and the Fire Department's comments confirm that the proposed measures were insufficient. In past conversations with the SCCFD, the applicant proposed alternatives in lieu of providing fire department access routes to the lower building elevations. Those alternatives included sprinklers, water curtains, and other features already required by the code, such as the proposed standpipe. Denial of this AMMR request by SCCFD is reasonable, as even if the internal sprinklers were activated successfully, fire crews would be unable to perform critical exterior operations, such as ladder rescues or fire attack from the structure’s downhill face. The fire official's denial reflected the lack of operational equivalency and upheld both the intent and the language of the code.

This fact is supported by SCCFD’s willingness to approve an AMMR for a 10,400 square foot, 1-story amenity building at 1 Apple Park Way in Cupertino in November of 2023 (AMMR PC 23-2499). In this case, the AMMR was requested because some portions of the amenity structure were located more than 150 feet from the fire department access roadway. Since this structure was not a residential occupancy and was only 1 story in height, this alternative met or exceeded the fire code’s intent for operational equivalency. Unlike the Apple Park structure, which is a nonresidential occupancy of 1 story, the AMMR for the Silver Oaks buildings proposes an external standpipe connection on the east end of the 100-foot-tall, multistory, senior living facility, which does not constitute an operational equivalent or meet the intent of the fire code.

Why Proposed Measures Fail to Meet Section 503.1.1
The developer proposes a suite of conventional fire safety measures, including:
• NFPA 13-compliant fire sprinklers;
• Exterior standpipe connections;
• Defensible space and landscaping;
• Staff emergency training;
• Enhanced construction materials. (CBC 7A and R337)
Most of these components are required by the fire code, and none of them compensate for the complete lack of fire apparatus access to substantial portions of the building perimeter. Section 503.1.1’s primary objective is to ITEM 2A ATTACHMENT 17

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Los Altos Hills City CouncilJune 18, 2025

Los Altos Hills City Council
June 18, 2025