Los Altos Hills City Council
September 18, 2025

THE TOWN OF LOS ALTOS HILLS July 10, 2025
Staff Report to the Planning Commission
SUBJECT: Discussion on Proposed Amendments to the Town’s Story Pole Policy under Housing Element Program B-16 to Streamline the Story Pole Requirement or Allow Alternatives in Lieu of Story Poles
FROM: Bageshri Thakar, Assistant Planner
Jonathan Fox, Senior Planner
APPROVED: Jay Bradford, Community Development Director
RECOMMENDATION: That the Planning Commission take the following action:

Provide direction and feedback on potential amendments to the Town’s Story Pole Policy.

BACKGROUND
The Town of Los Altos Hills maintains a Story Pole Policy (Attachment 1), originally adopted on September 8, 1999, and last revised on January 8, 2016. The policy requires the installation of story poles, height markers, and orange fencing prior to the approval of certain development projects. As part of the Town’s 6th Cycle Housing Element, Implementation Program B-16 calls for the development of a process to streamline the story pole requirement or allow digital renderings to be provided in lieu of story poles by Q3 2025. This report serves as an introduction to the discussion. Any modifications to the Story Pole Policy would require a formal recommendation from the Planning Commission, followed by final action by the City Council.

Current Story Pole Policy
The Story Pole Policy is intended to provide the City Council, Planning Commission, staff, volunteer committees, and community members with a clear visual representation of a proposed development's height, massing, and spatial relationship to its surroundings, thereby facilitating a true representation of the proposed structure prior to construction as part of the decision-making process.

Story poles and other field demarcations are currently required for the following types of development projects:
• New buildings
• Second story additions
• Additions exceeding 900 square feet and increases in roof height • Accessory structures (exceeding 900 square feet)
• Second units (if in conjunction with new residence or major addition) • Driveway entrance modifications, sports court and pools (outlined with stakes and ribbon at ground level)
• Open Space easements
ITEM 7C ATTACHMENT 4

• Trees proposed to be removed (marked with ribbons or tags or some type of obvious marker) Exceptions may be granted by the Planning Department based on scope of work proposed.

Story poles are required to be installed approximately two weeks before a public hearing notice is mailed and remain in place through the hearing and appeal period. For instance, a new residence reviewed at a Fast Track public hearing requires story poles to be installed for approximately 7 weeks total to account for two weeks prior to public notice, 10-day public notice, and a 3-week appeal period. Story poles may remain in place for a significantly longer period if a project requires multiple public hearings.

Figure 1. Story Poles for New Residence
Figure 2. Story Poles for Major Addition
ITEM 7C ATTACHMENT 4

Based on a Housing Element Survey conducted from February 2022 to August 2022, participants expressed frustration in navigating the development process in terms of time, cost, and certain development requirements. Story poles being one of the issues daylighted in the survey. This issue was incorporated and addressed in Housing Element Program B-16 where the town outlined a process to streamline story pole requirements or allow digital renderings to be provided in lieu of story poles.

Regional Policy Review
Staff conducted a comparative analysis of story pole requirements across Santa Clara County jurisdictions to assess recent policy trends. Among the 15 cities and towns in Santa Clara County, 11—including Campbell, Cupertino, Gilroy, Los Altos, Morgan Hill, Mountain View, San Jose, Santa Clara, Saratoga, Milpitas, and Sunnyvale—do not have a formal story pole policy or requirement. Only four jurisdictions in the county—Los Altos Hills, Town of Los Gatos, Monte Sereno, and Palo Alto require story pole installation as part of the development review process.

Additional research included policies from seven other California jurisdictions: the cities of Piedmont, Orinda, Berkeley, Corte Madera, Foster City, Monterey, and Santa Barbara. Example Story Poles Policies from the jurisdictions are included in Attachment 2 for reference.

Of the eight other jurisdictions surveyed the following jurisdictions have made updates to their story pole policies within the last five years:
• City of Los Altos: In March 2023, the City eliminated story pole requirements for all development applications as part of its Housing Element implementation. • City of Saratoga: In June 2024, the City removed story pole requirements for all new housing projects.
• Town of Los Gatos: In April 2024, the Town revised its policy to limit story pole requirements to specific project criteria and introduced digital renderings as an alternative for multi-family developments.
• City of Monterey: The City amended its requirements for affordable multi-family housing projects to allow 3D modeling or comparable visual simulation methods in lieu of story poles.

No changes have been made in the past five years to the story pole policies in the cities of Monte Sereno, Palo Alto, Piedmont, Orinda, Berkeley, Corte Madera, Foster City, or Santa Barbara.

Potential Changes to Story Pole Requirements
As part of Housing Element Program B-16 implementation, staff has identified a range of potential modifications to the Town’s existing Story Pole Policy for Planning Commission discussion.

These alternatives aim to balance the community’s interest in visualizing proposed development with the need to streamline the review process and reduce barriers to housing production. These alternatives are intended to prompt discussion on updating the Story Pole Policy to better align with current planning priorities, technological advancements, and state housing mandates.

ITEM 7C ATTACHMENT 4

The potential alternatives include:
• Alternative Visualization Methods: Permit the use of digital renderings, physical models, or augmented reality (AR) simulations as an alternative to physical story poles, either on a case-by-case basis or as an allowable alternative. • Duration of Installation: Reduce the required story pole installation period to 10 days prior to a public hearing. Allow story poles to be removed immediately following approving of a site development permit.
• Installation Materials: Allow alternative materials for story pole construction that are more sustainable, cost-effective, or easier to install. Consider permitting bamboo poles or reusable aluminum framing systems for vertical supports, and biodegradable jute or cotton fabric bands in place of conventional plastic netting or tape. • Applicability Thresholds: Modify the criteria for when story poles are required, including:
o Single-family residences only;
o Non-residential projects only;
o Projects exceeding 27 feet in height or seeking a height variance; o Two-story structures only
o Development within a specified distance of adjacent property lines o Sites with slopes exceeding a specified percentage
Figure 3. Digital Rendering for New Residence

ENVIRONMENTAL REVIEW
The suggested policy amendments or modifications are categorically exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15378, and 15061(b)(3), as this does not constitute a project.

ITEM 7C ATTACHMENT 4

CONCLUSION
Staff recommends that the Planning Commission receive the informational report on Housing Element Program B-16 and provide direction and feedback on potential amendments to the Town’s Story Pole Policy. Staff anticipates bringing a revised Story Pole Policy to City Council in September 2025 to align with the Housing Element implementation schedule.

ATTACHMENTS

1. Town of Los Altos Hills Story Pole Policy

2. Story Pole Policy Examples
ITEM 7C ATTACHMENT 4

THE TOWN OF LOS ALTOS HILLS September 4, 2025
Staff Report to the Planning Commission
SUBJECT: Consideration of and recommendation to City Council regarding Proposed Amendments to the Town’s Story Pole Policy under Housing Element Program B-16 to Streamline the Story Pole Requirement or Allow Alternatives in Lieu of Story Poles
FROM: Jonathan Fox, Senior Planner
APPROVED: Jay Bradford, Community Development Director
RECOMMENDATION: That the Planning Commission take the following action:

1. Forward a recommendation to the City Council to amend the Town’s Story Pole Policy for compliance with Housing Element Program B-16.

BACKGROUND
The Town of Los Altos Hills maintains a Story Pole Policy (Attachment 1), originally adopted on September 8, 1999, and last revised on January 8, 2016. The policy requires the installation of story poles, height markers, and orange fencing prior to the approval of certain development projects. As part of the Town’s 6th Cycle Housing Element, Implementation Program B-16 calls for the development of a process to streamline the story pole requirement or allow digital renderings to be provided in lieu of story poles by Q3 2025.

DISCUSSION:

July 10, 2025 Planning Commission Public Hearing
At the July 10, 2025, Planning Commission meeting, staff initiated a discussion regarding potential modifications to the policy. Staff identified four broad categories under which potential modifications could be considered: (1) use of alternative visualization methods to replace traditional story poles, (2) adjustments to the required duration for story pole installation; (3) use of alternative installation materials; (4) review of applicability thresholds, such as project size, height, or location, that trigger the story pole requirement. The staff report from the July 10, 2025, meeting is included as Attachment 3. The Planning Commission provided the following feedback and directions for staff to return at a subsequent meeting:

Planning Commission Feedback Staff Analysis
Add an exemption to the story pole
requirement for single-family residences that
are no more than 19 feet in height and 4,000
square feet in floor area, and that do not request
variances or exceptions. To qualify, larger
public notice signs to be posted on site and
increase public notice to 1,000 feet.

Added exemption. Increase to public
notification radius is outside the scope of the
Story Pole Policy. See following section of this
report for more in-depth analysis.

ITEM 7C ATTACHMENT 5

Specify that the policy applies to single-family
residences, duplexes, and triplexes.

Added.

Allow alternative materials for single-family
residences, duplexes, and triplexes.

Added.

Allow alternative visualization methods for
multi-family developments exceeding three
units per building.

Added.

Public Noticing Requirements
The Planning Commission suggested an exemption to the story pole requirement for single-family residences that are no more than 19 feet in height and 4,000 square feet in floor area, and that do not request variances or exceptions. However, to qualify for this exemption, the Commission suggested enhanced public noticing measures, including expanding the notification radius from 500 feet to 1,000 feet and requiring a larger on-site public notice sign.

Currently, the Story Pole Policy does not establish specific requirements for the extent of public notification. Instead, story pole installation timing simply coincides with the public notification that is mandated by the Municipal Code. For reference, the Municipal Code requires a 300-foot radius for Site Development Committee-level projects such as additions ranging from 900 to 1,500 square feet, swimming pools, and recreation courts. A 500-foot radius is required for Fast Track and Planning Commission-level items, including new single-family residences, second-story additions, and additions exceeding 1,500 square feet.

Staff notes that modifying the public noticing requirements within the Story Pole Policy could introduce inconsistencies with the existing provisions of the Municipal Code. In reviewing patterns of public hearing participation, staff finds that concerns regarding the visual impact of proposed structures most often originate from owners of directly adjacent properties. Expanding the notification radius to 1,000 feet for single-family residences that are no more than 19 feet in height and 4,000 square feet in floor area may result in less effective public outreach efforts. Therefore, staff recommends maintaining the 500-foot notification radius for all Fast Track and Planning Commission-level items.

Timing
According to the current policy, story poles are to be installed approximately two weeks before a public hearing notice is mailed and must remain in place through the hearing and any applicable appeal period. For example, a new residence reviewed at a Fast Track public hearing requires story poles to be installed for approximately 7 weeks total to account for two weeks prior to public notice, 10-day public notice, and a 3-week appeal period. Story poles may remain in place for a significantly longer period if a project requires multiple public hearings.

In practice, however, story poles are typically installed 10-14 days before the public hearing to coincide with public notification. If story poles are not installed at the proper time, then the public hearing is rescheduled to a future date.

ITEM 7C ATTACHMENT 5

To ensure consistency between the policy and current practice, staff recommends amending the policy to formally require installation of story poles 10 days prior to the public hearing, rather than the approximate three-week period currently stated.

ENVIRONMENTAL REVIEW
The suggested policy amendments or modifications are categorically exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15378, and 15061(b)(3), as this does not constitute a project.

CONCLUSION
Staff has incorporated the Planning Commission’s feedback into a redline version of the Story Pole Policy, reflecting the proposed revisions discussed at prior meetings. This includes staff’s recommended change to the timing requirement, aligning the policy with current practice by requiring story poles to be installed 10 days prior to the public hearing. However, feedback that could result in inconsistencies with the Municipal Code has not included in the draft, to maintain alignment with current Town regulations.

ATTACHMENTS

1. Town of Los Altos Hills Story Pole Policy [REDLINE]

2. Town of Los Altos Hills Story Pole Policy [CLEAN-No Change]

3. Planning Commission July 10, 2025 Staff Report
ITEM 7C ATTACHMENT 5

ITEM 7D
TOWN OF LOS ALTOS HILLS SEPTEMBER 18, 2025
Staff Report to the City Council
SUBJECT: WAIVER OF READING AND INTRODUCTION OF AN ORDINANCE AMENDING TITLE 4, CHAPTER 1 “EMERGENCY ORGANIZATION
AND FUNCTION,” TITLE 2, CHAPTER 4 “PURCHASING SYSTEM,”
AND TITLE 6, CHAPTER 5 “NUISANCE ABATEMENT” OF THE LOS

ALTOS HILLS MUNICIPAL CODE TO ADD NEW MANAGEMENT

POSITIONS, REVISE AND REMOVE OUTDATED PROVISIONS, AND

ESTABLISH NEW AUTHORITY AND PROCEDURES FOR

EMERGENCY RESPONSE
FROM: Joram Parcutilo, Management Analyst JP
APPROVED: Peter Pirnejad, City Manager PP
RECOMMENDATION: That the City Council:

1. Waive reading and introduce an Ordinance Amending Title 4, Chapter 1 (“Emergency Organization and Function”), Title 2, Chapter 4 (“Purchasing System”), and Title 6, Chapter 5 (“Nuisance Abatement”) of the Los Altos Hills Municipal Code to:
a. Add new management positions;
b. Revise and remove outdated terms, memberships, and bodies that no longer reflect the Town’s structure; and
c. Add new authority and procedures to ensure effective emergency management and compliance with state law.

BACKGROUND:

State law provides the Town with the discretion to establish an emergency organization and assign duties to fulfill emergency organization roles. Title 4, Chapter 1 of the Los Altos Hills Municipal Code was originally adopted to establish the Town’s emergency organization and define procedures for responding to disasters. While effective at the time of its adoption, the provisions have not been comprehensively updated within the last few years.

As a result, several elements of the ordinance are outdated, redundant, or inconsistent with current Town policies and procedures. Since the ordinance was last updated, significant changes have occurred at the state, regional, and local levels that affect how the Town must organize for emergencies.

The current ordinance includes references to positions, memberships, and structures (such as the “Citizen Corps Council”) that are no longer in use. These outdated references create confusion and may impede effective emergency response. In response to these gaps, staff has prepared a comprehensive update to Title 4, Chapter 1. The revisions are intended to:

1. Modernize the Town’s emergency organization to reflect current best practices;

Staff Report to City Council
Ordinance Amending the Municipal Code to Modernize Emergency Management Structure September 18, 2025 2

2. Remove outdated structures and obsolete terminology; and

3. Clarify the authority of the mayor, the Director of Emergency Services and staff to act swiftly and legally during an emergency.

In 2025, staff in coordination with the Town’s Emergency Management Consultant and the City Attorney’s Office took the proactive approach in reviewing the current Municipal Code and made steps in updating the code.

This ordinance will ensure that the Town of Los Altos Hills is legally compliant, operationally prepared, and better positioned to protect the community in the event of a disaster.

DISCUSSION:

Town Staff, the City Attorney’s Office, and the Town’s Emergency Consultant completed review of the Municipal Code in September 2025. A redline version showing which portions of the current Code were updated is included with this report (Attachment 2).

Staff presented the proposed changes to the Town’s Emergency Preparedness and Response Committee (EPRC) to provide an update and receive confirmation to move forward with the proposed changes. The EPRC recommended moving forward with the Council to adopt these changes. Staff is now moving forward with introducing the proposed ordinance amendments at the September 18, 2025, City Council Meeting.

The proposed ordinance amendments to Title 4, Chapter 1 focus on three major areas of improvement:

1. Add New Positions
The existing ordinance does not fully reflect the organizational structure identified in the Town’s Emergency Operations Plan (EOP). Specifically, there is no clear recognition of modern emergency management positions or functions that are essential for compliance with the Standard Emergency Management System (SEMS) and the National Incident Management System (NIMS).

The ordinance would add the following positions:
• Emergency Services Coordinator – responsible for the day-to-day administration of the Office of Emergency Services.
• Emergency Manager – supports and implements a comprehensive disaster and emergency preparedness program that includes education and community engagement.

The ordinance would add responsibilities to the following position:
• Assistant Director of Emergency Services – prepares the Emergency Operations Plan and other emergency plans, manages the emergency programs within the Town, and succeeds the Director of Emergency Services if the Director is unavailable.

Staff Report to City Council
Ordinance Amending the Municipal Code to Modernize Emergency Management Structure September 18, 2025 3
*One thing to note is that due to the Town’s small staff size, there may be times in the event of an emergency in which a staff member will hold multiple positions until adequate staff can be reached.

2. Revise and Remove Outdated Terms, Memberships and Bodies The current ordinance includes references to terms, positions and bodies that are no longer accurate, functional or necessary. Specifically, it uses an outdated reference to the Americans with Disabilities Act (ADA) for integrated emergency planning and older definitions for different types of emergencies. It also establishes a Los Altos Hills Disaster Council composed of local officials and community members. Under Government Code Section 8610, cities are permitted to establish local disaster councils by ordinance. While relevant at the time of adoption, the composition of this Disaster Council is outdated. There are positions and groups in the Disaster Council that no longer have any practical relevance within the Disaster Council Membership. Retaining these outdated references creates confusion about roles and responsibilities during an emergency. The ordinance would update and streamline the Municipal Code to ensure that the Town’s emergency organization reflects only those positions that are active, accountable, and integrated into modern emergency management systems.

The ordinance would update the integrated emergency planning section with current ADA language.

The ordinance would update the definitions for the following terms:
• Local emergency
• State of emergency
• State of war emergency
The ordinance proposes the following modifications to the Los Altos Hills Disaster Council:
• Appoint the Assistant Director of Emergency Services as vice chair. • Remove representatives of civic, business, institutional, non-profit, or other organizations having an official emergency responsibility.

The ordinance would remove the following outdated bodies and terms:
• Los Altos Hills Citizen Corps Council
• Los Altos Hills Emergency Communication Committee
• Ham Radio training

3. Add New Authority and Procedures
The ordinance also strengthens and clarifies the authority of the Mayor and the Director of Emergency Services, and the procedures to be followed during an emergency. It also makes related updates in Title 2, Chapter 4 and Title 6, Chapter 5. Key updates include:
• Emergency Chief Executive Powers – Pursuant to Government Code Section 38791, the Mayor is authorized to exercise all constitutional and general law police powers only during extreme disasters such as extraordinary fire, flood, storm, epidemic, earthquake, sabotage, or enemy attack.
• Clarified Authority to Proclaim Local Emergency – The Director of Emergency Services (City Manager) is already authorized to proclaim a local emergency when the

Staff Report to City Council
Ordinance Amending the Municipal Code to Modernize Emergency Management Structure September 18, 2025 4
City Council is not in session, subject to ratification by the City Council within the timeframe required by California Government Code §8630. The ordinance would clarify that the Director would also be authorized to proclaim a local emergency when the City Council is otherwise unable to convene.
• Emergency Contracting Procedures – Municipal Code Section 2-4.01 is updated pursuant to Public Contract Code Section 22050, to authorize the Town to undertake emergency contracting with authority delegated to the Director of Emergency Services. • Emergency Building Abatement Procedures – Municipal Code Section 6-5.01 is updated to include emergencies as instances of nuisances that may require building abatement.
• Succession of Authority – The ordinance updates a clear line of succession when the Director is unavailable. This ensures continuity of leadership during critical incidents when immediate decision-making is required.
• Emergency Operations Center (EOC) Procedures – Provisions are added to update who may activate the EOC.

Together, these updates provide the Town with a modernized and legally sound framework for emergency response, ensuring that officials can act quickly, effectively, and in coordination with regional and state partners. The proposed ordinance is included as Attachment 1.

ANALYSIS:

If adopted, the proposed ordinance would represent a comprehensive modernization of the Town’s emergency management framework. The analysis below highlights the key benefits and considerations:
• Legal Compliance – The amendments bring the Municipal Code into alignment with CESA, SEMS, and NIMS, ensuring the Town is compliant with state and federal requirements. This compliance is critical both for legal defensibility of emergency actions and for eligibility to receive disaster recovery funding. • Operational Efficiency – By eliminating outdated positions and streamlining organizational responsibilities, the Town reduces redundancies and potential confusion during emergencies.
• Authority and Responsiveness – Clear delegation of authority to the Director of Emergency Services, with provisions for succession, ensures that decision-making is not delayed during a disaster. This provides the Town with the ability to act quickly while maintaining Council oversight through ratification procedures. • Regional Integration for Mutual Aid and Multi-Agency Coordination – The ordinance better positions the Town to coordinate with the Los Altos Hills County Fire District, Santa Clara County Fire Department, and neighboring jurisdictions. This integration is essential during large-scale incidents where mutual aid and multi-agency coordination are required.
• Community Resilience – Ultimately, the ordinance enhances the Town’s ability to protect lives, property, and infrastructure by establishing a clear, updated, and effective emergency management structure. This strengthens public confidence and provides residents with assurance that the Town is prepared to respond to both natural and human-caused disasters.

Staff Report to City Council
Ordinance Amending the Municipal Code to Modernize Emergency Management Structure September 18, 2025 5
Overall, the proposed amendments strike a balance between clarity, flexibility, and accountability, ensuring the Town’s emergency organization is both modern and practical.

ENVIRONMENTAL REVIEW:

The proposed ordinance is exempt from California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) of the CEQA Guidelines. Amendments to the Municipal Code do not create any physical changes, approve any projects, or alter any environmental or land uses and therefore does not have the potential or possibility to create significant environmental effects. As such, the proposed Ordinance is exempt from CEQA. 2024-2025 CITY COUNCIL WORK PLAN:

Although updating Title 4, Chapter 1 of the Municipal Code and related updates in Title 2, Chapter 4 and Title 6, Chapter 5 were not identified as one of the Council’s priorities for the 2024-2025 workplan, staff and the Town’s Emergency Management Consultant took the proactive approach to update the code now to ensure that in the event of an emergency, the Town had a modernized and legally sound framework for emergency response.

FISCAL IMPACT:

There is no direct fiscal impact associated with adoption of the ordinance. Implementation of the updated framework will be handled within existing staff resources, and certain activities may be eligible for state or federal reimbursement during disaster response and recovery.

GENERAL PLAN:

The proposed ordinance is consistent with and supports the Los Altos Hills General Plan by enhancing the Town’s ability to provide quick, coordinated responses to emergencies under Goal 7 of the Safety Element.

ATTACHMENTS:

1. Proposed Ordinance

2. Exhibit A to the Proposed Ordinance – Proposed Amendments to Chapter 1 of Title 4, Chapter 4 of Title 2, and Chapter 5 of Title 6 of the Town of Los Altos Hills Municipal Code

ITEM 7D, ATTACHMENT 1
ORDINANCE ______
AN ORDINANCE OF THE TOWN OF LOS ALTOS HILLS AMENDING TITLE 4, CHAPTER 1 “EMERGENCY ORGANIZATION AND FUNCTION,” TITLE 2, CHAPTER 4 “PURCHASING SYSTEM,” AND TITLE 6, CHAPTER 5 “NUISANCE ABATEMENT” OF THE LOS ALTOS HILLS MUNICIPAL CODE TO ADD NEW

MANAGEMENT POSITIONS, REVISE AND REMOVE OUTDATED PROVISIONS,

AND ESTABLISH NEW AUTHORITY AND PROCEDURES FOR EMERGENCY

RESPONSE
WHEREAS, Title 4, Chapter 1 of the Los Altos Hills Municipal Code (“Emergency Organization and Function”) was adopted to establish the Town’s emergency organization and define procedures for disaster response; and
WHEREAS, the Ordinance has not been comprehensively updated in several years and contains outdated provisions, redundant terminology, and references to positions or bodies, such as the “Los Altos Hills Citizen Corp Council,” that are no longer functional or consistent with the Town’s current structure; and
WHEREAS, since the last update of the Ordinance in 2018, significant changes at the state, regional, and local levels, including the requirements of the California Emergency Services Act (CESA), the Standardized Emergency Management System (SEMS), and the National Incident Management System (NIMS), have reshaped the standards for municipal emergency preparedness and response; and
WHEREAS, the proposed amendments modernize the Town’s emergency management framework by introducing new organizational positions that reflects functions necessary to comply with CESA, SEMS and NIMS, specifically the Emergency Services Coordinator and the Emergency Manager;
WHEREAS, the proposed amendments revise and remove outdated terms, memberships, and bodies, such as updating the integrated emergency planning section with current Americans with Disability Act language; updating the definitions of “local emergency,” “state of emergency,” and “state of war emergency” to be consistent with CESA; updating the positions and memberships within the Los Altos Hills Disaster Council; and removing the Los Altos Hills Citizen Corps Council;
WHEREAS, the proposed amendments strengthens and clarifies the authority of the Mayor and the Director of Emergency Services by authorizing the mayor to have emergency chief executive powers only during extreme disasters and clarifying the authority of the Director to proclaim a local emergency when the City Council is otherwise unable to convene; WHEREAS, the proposed amendments enhances the Town’s operational readiness and legal compliance by adding responsibilities for the Assistant Director of Emergency Services, updating the line of succession when the Director of Emergency Services is unavailable, and updating who may activate the Emergency Operations Center; WHEREAS, the additional proposed amendments in Title 2, Chapter 4 and Title 6, Chapter 5 authorizes emergency procedures such as emergency contracting pursuant to Public

Contract Code Section 22050 and building abatement during emergencies, which are among any preventative measure that the Town may take to protect and preserve public health during emergencies under Health and Safety Code Section 101475; WHEREAS, adoption of this proposed Ordinance will improve the Town’s ability to coordinate with regional partners, streamline its emergency structure, and strengthen community resilience while ensuring consistency with state and federal law; WHEREAS, on XXXXX, the City Council conducted a duly noticed public hearing to consider the proposed Ordinance. At the public hearing, the City Council considered all evidence and testimony presented before it and all interested parties were provided an opportunity to be heard.

NOW, THEREFORE, the City Council of the Town of Los Altos Hills hereby ordains as follows:

SECTION I. FINDINGS.

Based on the entirety of the record as described above, the City Council for the Town of Los Altos Hills hereby makes the following findings:

1. All of the facts and recitals above are true, correct, incorporated herein, and made a part hereof.

2. Based on the entirety of the record before it, the City Council hereby finds that this proposed Ordinance is exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3). Under Section 15061(b)(3), CEQA applies only to projects that have the potential for causing a significant effect on the environment, and where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA. In this case, the proposed amendments do not create any physical changes, approve any projects, or alter any environmental or land uses and therefore does not have the potential or possibility to create significant environmental effects. As such, the proposed Ordinance is exempt from CEQA.

3. The proposed Ordinance is consistent with and supports the Los Altos Hills General Plan by enhancing the Town’s ability to provide quick, coordinated responses to emergencies under Goal 7 of the Safety Element.

SECTION II. AMENDMENT.

Chapter 1 of Title 4, Chapter 4 of Title 2 and Chapter 5 of Title 6 of the Town of Los Altos Hills’ Municipal Code, are hereby amended to read as set forth in Exhibit A to this Ordinance, which is hereby incorporated as though set forth in full herein.

SECTION III. SEVERABILITY.

If any provision of this Ordinance or the application thereof to any person or circumstance is held invalid or unconstitutional the remainder of this Ordinance, including the application of such part or provision to other persons or circumstances shall not be affected thereby and shall

continue in full force and effect. To this end, provisions of this Ordinance are severable. The City Council of the Town of Los Altos Hills hereby declares that it would have passed each section, subsection, subdivision, paragraph, sentence, clause, or phrase hereof irrespective of the fact that any one or more sections, subsections, subdivisions, paragraphs, sentences, clauses, or phrases be held unconstitutional, invalid, or unenforceable.

SECTION IV. EFFECTIVE DATE AND PUBLICATION.

Pursuant to the provisions of Government Code Section 36933, a summary of this Ordinance shall be prepared by the City Attorney. At least five (5) days prior to the Council meeting at which this Ordinance is scheduled to be adopted, the City Clerk shall (1) publish the Summary, and (2) post in the City Clerk’s Office a certified copy of this Ordinance. Within fifteen (15) days after the adoption of this Ordinance, the City Clerk shall (1) publish the summary, and (2) post in the City Clerk’s Office a certified copy of the full text of this Ordinance along with the names of those City Council members voting for and against this Ordinance or otherwise voting.

This Ordinance shall become effective thirty (30) days from and after its adoption.

INTRODUCED: ______________, 2025
PASSED: _______________, 2025
AYES:

NOES:

ABSTENTIONS:

ABSENT:

BY: _________________________
Mayor
ATTEST:
_________________________
City Clerk
APPROVED AS TO FORM:
_________________________
City Attorney

ITEM 7D, ATTACHMENT 2

EXHIBIT A
SECTION I. Revisions to “Emergency Organization and Function” of Title 4, Chapter 1 The following sections in Title 4, Chapter 1 are amended as follows, with additions in red double underline and deletions in strikethrough. Sections, subsections, paragraphs, and texts not modified by this amendment are not included below and shall remain in full force and effect. § 4-1.01. Purposes.

The declared purposes of this chapter are to provide for the preparation and carrying out of plans for the protection of persons, property and environment within the Town in the event of an emergency, the direction of the emergency organization, and the coordination of the emergency functions of the Town with all other public agencies, corporations, organizations and affected private persons.
§ 4-1.01.1. Inclusion.

In accordance with Title II of the Americans with Disabilities Act ("ADA," Pub. L. 101-336), an integrated approach to emergency planning shall be taken to provide people with disabilities and others with access and functional needs the same opportunities to benefit from emergency programs, information, services and activities as people without disabilitiesthose provided to others.
§ 4-1.02. Definitions.

Emergency, as used in this chapter, means the actual or threatened existence of conditions of disaster or of extreme peril to the safety of persons, property and environment within or affecting the Town caused by such conditions as air pollution, drought, earthquake, epidemic, fire, flood, human acts, plant or animal infestation or disease, riot, severe weather, sudden and severe energy shortage, technological interruptions, the Governor's warning of an earthquake or volcanic prediction, or other conditions including conditions resulting from war or imminent threat of war, but other than conditions resulting from a labor controversy, which conditions are or are likely to be beyond the control of the services, personnel, equipment, and facilities, requiring the combined forces of other political subdivisions to combat.

Emergency services mean the preparation and carrying out of all emergency functions, other than functions for which the military forces are primarily responsible, to prevent, minimize, and repair injury and damage resulting from disaster. It shall not include preparation for any conditions relating to a labor controversy.

Local emergency means the duly proclaimed, actual or threatened, existence of conditions of disaster or of extreme peril to the safety of persons, property and environment, within or affecting the territorial limits of the Town, which are, or are likely to be, beyond the control of Town services, personnel, equipment and facilities and requiring the combined forces of other public agencies to combat. Conditions may include air pollution, cyberterrorism, deenergization event, drought, earthquake, electromagnetic pulse attack, epidemic, fire, flood, human acts, plant or animal infestation or disease, riot, severe weather, storm, sudden and severe energy shortage,

technological interruptions and conditions such as, the Governor's warning of an earthquake or volcanic prediction, or other conditions including conditions resulting from war or imminent threat of war. "Local emergency" does not include, nor does any provision of this chapter apply to, any conditions resulting from a labor controversy.

State of emergency means the duly proclaimed existence of conditions of disaster or of extreme peril to the safety of persons, property, and environment within or affecting the State caused by such conditions as air pollution, cyberterrorism, deenergization event, drought, earthquake, electromagnetic pulse attack, epidemic, fire, flood, human acts, plant or animal infestation or disease, riot, severe weather, storm, sudden and severe energy shortage, technological interruptions, the Governor's warning of an earthquake or volcanic prediction, or other conditions, which conditions, by reason of their magnitude, are, or are likely to be, beyond the control of the services, personnel, equipment and facilities of any single county, city and county, or city, and require the combined forces of a mutual aid region or regions to combat. "State of emergency" does not include, nor does any provision of this chapter apply to, any conditions resulting from a labor controversy or conditions causing a "state of war emergency." State of war emergency means the condition that exists immediately, with or without a proclamation thereof by the Governor, whenever this State or Nation is attacked by an enemy of the United States or upon receipt by a sthe State of a warning from the Federal government indicating that such an enemy attack is probable or imminent. § 4-1.03. Emergency organization.

All officers and employees, together with those volunteer forces enrolled to aid them during an emergency, and all groups, organizations, and persons who may by agreement or operation of law, including persons impressed into service under the provisions of Section 4-1.05(c)(3) of this chapter, be charged with duties incident to the protection of life, property and environment during such emergency, shall constitute the emergency organization of the Town of Los Altos Hills. § 4-1.04. Director and Assistant Director of Emergency Services. (a) There is hereby created the office of Director of Emergency Services. The City Manager shall be the Director of Emergency Services. The Director shall oversee the Office of Emergency Services.
(b) There is hereby created the office of Assistant Director of Emergency Services, who shall be appointed by the Director. In the absence or incapacity of the Director, the Assistant Director of Emergency Services shall also have the day-to-day responsibility for the management and operation of the Office of Emergency Services. The Assistant Director shall exercise all powers vested by this chapter in the Director.
(c) There is hereby created the position of Emergency Services Coordinator, who shall be appointed by the Director.
(d) There is hereby created the position of Emergency Manager, who shall be appointed by the Director.
§ 4-1.05. Powers and duties of the Director and Assistant Director of Emergency Services.

It shall be the duty of the Director of Emergency Services, and he/she is hereby empowered, to develop and recommend for adoption by the City Council, emergency and mutual aid plans and agreements and such ordinances and resolutions and rules and regulations as are necessary to implement such plans and agreements.
(a) The Director of Emergency Services or acting Director (if the Director is unavailable) is hereby empowered:
(1) To request the City Council to proclaim the existence or threatened existence of a "local emergency" if the governing body is in session, or to issue such proclamation if the City Council is not in session or otherwise unable to convene. Whenever a local emergency is proclaimed by the Director, the City Council shall take action to ratify the proclamation within seven days thereafter or the proclamation shall have no further force or effect.
(2) To request that the Governor through appropriate channels proclaim a state of emergency when, in the opinion of the Director, Assistant Director or acting Director, the resources of the Town are inadequate to cope with an emergency. (3) To represent or provide representation of the Town in all dealings with public or private agencies pertaining to civil preparedness in the event of an emergency. (4) Control and direct the effort of this emergency organization for the accomplishment of the purposes of this chapter.
(5) Direct cooperation between and coordination of services and staff of this emergency organization; and resolve questions of authority and responsibility that may arise between them.
(b) The Assistant Director shall, under the supervision of the Director and with the assistance of Disaster Council representatives, prepare the Emergency Operations Plan and emergency plans and manage the emergency programs of this jurisdiction; and shall have such other powers and duties as may be assigned by the Director.
(c) The Emergency Services Coordinator, or the City Manager’s designee, shall be responsible for the day-to-day administration of the Office of Emergency Services. (d) The Emergency Manager shall be responsible for supporting and implementing a comprehensive disaster and emergency preparedness program that includes education and community engagement.
(c)(e)In the event of the proclamation of a "local emergency" as herein provided, the proclamation of a "state of emergency" by the Governor or the Secretary of the California Office of Emergency Services, or the existence of a "state of war emergency," the Director is hereby empowered to:
(1) Make and issue rules and regulations on matters reasonably related to the protection of life, property and environment as affected by the emergency; provided, however, that the rules and regulations must be confirmed at the earliest practicable time by the City Council;

(2) Obtain vital supplies, equipment and other properties found lacking and needed for the protection of the life, property and environment of the people, and bind the Town for the fair value thereof and if required immediately, to commandeer the same for public use;
(3) Require emergency services of any Town officer or employee and, in the event of the proclamation of a state of war emergency or a state of emergency by the Governor in the region in which this Town is located, to command the aid of as many members of this community as are deemed necessary in the execution of his or her duties; such persons shall be entitled to all privileges, benefits, and immunities as are provided by State law for registered disaster service workers;
(4) Requisition necessary personnel or material of any Town department or agency; (5) Execute all ordinary power as City Manager, all of the special powers conferred by this chapter or by resolution or eEmergency Operations pPlan adopted pursuant hereto, and all powers conferred upon the Director by any statute, agreement approved by the City Council, or by any other lawful authority. (d)(f) The Director of Emergency Services shall designate the order of succession to that office, to take effect in the event the Director is unavailable to attend meetings and otherwise perform duties during an emergency. The order of succession shall be:
(1) City Manager or his/her designee;
(2) Public Works Director;
(3) Planning Director;
(4) Administrative Services Director;
(5) City Clerk;
(6) Other employees designated by the City Manager;
(7) Most senior elected official with required National Incident Management Systems (NIMS) training.
§ 4-1.06. Disaster Council membership.

The Los Altos Hills Disaster Council shall consist of the following:
(a) The Director of Emergency Services who shall be chair. (b) The Public WorksAssistant Director of Emergency Services who shall be the vice chair. (c) The Public Works Director.
(c)(d) The Mayor, or City Council designee, who shall be the liaison. (d) The Assistant Director of Emergency Services.
(e) Such chiefs of emergency services as are provided for in a current eEmergency oOperations pPlan of this jurisdiction, adopted pursuant to the ordinance codified in this section.

(f) Such representatives of civic, business, institutional, non-profit, public, or other organizations having an official emergency responsibility, as may be appointed by the Director with the advice and consent of the City Council. § 4-1.07. Disaster Council powers and duties.
(a) It shall be the duty of the members of the Los Altos Hills Disaster Council, and they are hereby empowered, to engage in emergency response and recovery planning; to review and provide input on emergency and mutual aid plans and agreements and such ordinances and resolutions and rules and regulations as are necessary to implement such plans and agreements.
(b) The Director of Emergency Services shall advise the Disaster Council with regard to the preparation and maintenance of the Emergency Operations pPlan in whole or in part. (c) The Disaster Council shall develop and maintain strategic emergency planning partnerships with other local agencies.
(d) The Disaster Council shall comply with the California Emergency Services Act and abide by the California Disaster and Civil Defense Master Mutual Aid Agreement. (e) The Disaster Council, accredited by the State of California, is empowered to register and direct the activities of disaster service worker (DSW) volunteers within the sphere of influence of the Town.
(f) The Disaster Council agrees to follow established rules and regulations relating to the various classes of disaster service workers, scope of duties of each class, and manner of registration pursuant to the provisions of Government Code Section 8585.5. (g) The Disaster Council will also serve as the Los Altos Hills Citizen Corps Council withhave the following additional responsibilities:
(1) Approve DSW volunteer training and planning to ensure compliance with current DSW regulations and guidelines.
(2) The Assistant Director of Emergency Services will coordinate Community Emergency Response Team (CERT) training and exercises with the Los Altos Hills County Fire District, Ham Radio training with the Los Altos Hills Emergency Communication Committee (ECC) and other DSW volunteer training, as identified. (3) The City Manager, City Clerk, Assistant Director of Emergency Services, CERT Coordinator, Emergency Communications Committee Chair or others as designated by the City Manager or his/her designee shall be the Authorized Representative(s) for the registration form processing of DSW volunteers Disaster Service Workers.

The City Manager, City Clark and Assistant Director of Emergency Services and shall review and approve volunteer training activities, as necessary, when the Disaster Council is not in session.
(4) Self-certification of DSW volunteers may occur under two circumstances.

(i) During proclaimed emergencies, when monitored and screened by the Director of Emergency Services, an authorized representative identified in subsection (g)(3) or the CERT Incident Commander and CERT General Staff may administer self-certification volunteer DSW volunteer registration forms for spontaneous volunteers.
(ii) During approved Santa Clara County Fire Department (SCCFD) CERT Academy classes or refresher classes when monitored and screened by SCCFD employee CERT instructors.
(h) The Disaster Council shall meet upon call of the chair or, upon call of the vice chair (in the absence of the chair).
§ 4-1.08. Emergency Operations Plan.
(a) The Town of Los Altos Hills has adopted the Standardized Emergency Management System (SEMS) and the National Incident Management System (NIMS) as the prevention, preparedness, mitigation, response and recovery framework for the Emergency Operations Plan.
(b) The Los Altos Hills Disaster Council shall be responsible for the development of the Emergency Operations Plan (Plan), and Annexes specific to the Plan as identified, which shall provide for the effective mobilization of all of the resources of this jurisdiction, both public and private, to meet any condition constituting a local emergency, state of emergency, or state of war emergency; and shall provide for the organization, powers and duties, services and staff of the emergency organization.
(c) The pPlan shall also identify the sources of outside support which might be provided (through mutual aid and specific statutory authorities) by other jurisdictions, State and Federal agencies, and the private sector.
(d) Such pPlan shall take effect upon adoption by resolution of the City Council. (e) The pPlan may be activated by any of the following Town representatives:
(1) Those listed in Section 4-1.05(d)(f) under the Director of Emergency Services Order of Succession.
(2) Any City Councilmember with required NIMS training. (3) Any Emergency Communications Committee volunteer with required NIMS training.
(4)(3) Any CERT supervisor with required NIMS training. § 4-1.09. Preservation of local government during an emergency—Succession.

In order to preserve local government during an emergency, the City Council shall meet as soon as possible, ascertain the damage incurred as a result of the emergency, and fill vacancies with standby officers of the Council, as prescribed by California Government Code Sections 8635 through 8644.

In the absence of a quorum, remaining council member(s) shall determine the availability of missing council members and fill seats with standby officers. Standby officers of the Council are the former members of the Council, beginning with the immediate past Ccouncil members, and then to prior years, beginning with the most recent.
…
§ 4-1.12. Emergency Chief Executive Powers.

In accordance with California Government Code Section 38791, during periods of great calamity, such as extraordinary fire, flood, storm, epidemic, earthquake, sabotage or enemy attack, the mayor shall have complete authority over the Town and the right to exercise all police power vested in the Town by the Constitution and general laws.
§ 4-1.13. Mutual Aid.

Emergency plans adopted and approved by the City Council shall provide for the interchange of mutual aid and for coordination with the emergency plans of the county operational area. § 4-1.14. Emergency Contracting Procedures.

The Town shall undertake emergency contracting as described in § 2-4.01(b) in accordance with California Public Contract Code Section 22050. The Director of Emergency Services is delegated authority to order any action pursuant to Section 22050. § 4-1.15. Emergency Building Abatement Procedures.

The Town shall undertake emergency building abatement as described in § 6-5.

SECTION II. Revisions to “Purchasing System” of Title 2, Chapter 4 The following sections in Title 2, Chapter 4 are amended as follows, with additions in red double underline and deletions in strikethrough. Sections, subsections, paragraphs, and texts not modified by this amendment are not included below and shall remain in full force and effect. § 2-4.01. Purchases on behalf of Town—General rules.
(a) City Manager as Purchasing Agent. The City Manager shall have full authority to purchase or provide for the purchase of all materials, supplies, services, and equipment for the use of all departments, commissions, and boards comprising the Town government, in accordance with the provisions of this chapter, except articles required by the state codes to be purchased otherwise.
(b) Emergency Purchasing and Contracting. No purchase of an article, service or thing shall be made by any department head independently of the City Manager except in cases of immediate emergency that occur when the office of the City Manager is not open for the conduct of the City's business. In such instances, the department head may make the necessary emergency purchase and shall report the same in writing to the City Manager within 24 hours, accompanied by a definite statement of the occasion and reasons for such

emergency purchase. In the case of an emergency, the City Manager may undertake contracting procedures in accordance with the provisions of California Public Contract Code Section 22050.
(b)(c)Prohibition on Splitting Procurement. Under no circumstances may any procurement or purchase contemplated in this chapter be split or separated into smaller components to avoid procurement or purchasing procedures and/or determine the awarding authority. …
§ 2-4.03. Open market orders for purchases and procurements of $60,000 or less.

All purchases or procurements of professional and facility services, public projects, supplies, materials, equipment, or other personal property, the cost of which is $60,000 or less, may be made in the open market without newspaper advertisement. When deemed appropriate by the City Manager, open market purchases shall be based on at least three competitive bids or quotes and shall be awarded on the basis of the bid most advantageous to the Town. The City Manager may solicit bids directly from prospective vendors by mail, email, or by telephone. The City Manager shall keep a record of all open market orders and bids submitted thereon which shall be open to public inspection. Public projects of $60,000 or less may be performed by the employees of the Town by force account or may be performed by negotiated contract. Notwithstanding the provisions of this section, procurement of public projects as defined in the California Public Contracts Code shall comply with all applicable provisions of the Public Contracts Code. § 2-4.04. Formal and informal procedures for the purchase and procurement of goods, services, and public projects in excess of $60,000.
…
(b) Procurement of Public Projects.
(1) Informal Bid Procedures for Procurement of Public Projects. In accordance with Public Contract Code Sections 22032 and 22034, for the procurement of public projects $200,000 or less, the Town shall engage in the following procedures:
(i) Contractors List. A list of contractors shall be developed and maintained in accordance with the provisions of Section 22034 of the Public Contracts Code and criteria promulgated from time to time by the California Uniform Construction Cost Accounting Commission. (ii) Notice Inviting Informal Bids. Where a public project is to be performed which is subject to the provisions of this section, a notice inviting informal bids shall be mailed, faxed, or emailed to all contractors for the category of work to be bid, as shown on the contractor list, and to all construction trade journals as specified by the California Uniform Construction Cost Accounting Commission in accordance with Section 22036 of the Public Contracts Code. The notice inviting informal bids shall describe the project in general terms and how to obtain more detailed information about the project, and state the time and place for the submission of bids. All mailing of notices to contractors pursuant to this subdivision shall be completed not less than 10 calendar days before bids are due. Additional contractors and/or construction trade journals may be notified at the discretion of the department soliciting bids; provided, however:
…

SECTION III. Revisions to “Nuisance Abatement” of Title 6, Chapter 5 The following sections in Title 6, Chapter 5 are amended as follows, with additions in red double underline and deletions in strikethrough. Sections, subsections, paragraphs, and texts not modified by this amendment are not included below and shall remain in full force and effect. § 6-5.01. Definition of nuisance.

Nuisance means anything which (1) is injurious or threatening to health or safety, (2) obstructs the customary free use or passage of any stream, park, street, pathway, public easement, or highway, or (3) is specifically declared by this Code or state law to be a nuisance. Examples of a nuisance include, but are not limited to:
(a) Any explosives, flammable liquids or hazardous materials which are stored in a manner or an amount contrary to state law or this Code;
(b) Any building or structure which is made, erected, altered, maintained, partially destroyed or abandoned, including such instances due to an emergency as defined in §4-1.02, or contrary to state law or this Code;
…
§ 6-5.06. Other remedies.

Nothing in this chapter shall affect, prevent or prejudice any other remedy or penalty, civil or criminal, for the creation or maintenance of a nuisance. Nothing in this chapter shall prohibit the summary and immediate abatement of a nuisance upon the order of the City Council or any Town officer as authorized by law if the Council or officer determines that the nuisance constitutes an immediate threat to the public health or safety, including a nuisance necessitated by an emergency as defined in §4-1.02.

THE TOWN OF LOS ALTOS HILLS September 18, 2025
Staff Report to the City Council
SUBJECT: REVIEW AND ACCEPT THE ANNUAL GREENHOUSE GAS (GHG)

INVENTORY UPDATE TO TRACK PROGRESS TOWARD THE
TOWN’S 2030 REDUCTION TARGET
PREPARED BY: Jay Bradford, Community Development Director APPROVED: Peter Pirnejad, City Manager
RECOMMENDATION: That the City Council:

1. Receive and consider the 2023 Government Operations and Community Greenhouse Gas Inventories update.

2. Provide direction to staff and the Environmental Initiatives Committee (EIC) on priority measures to support continued GHG reductions.

3. Review and accept the annual GHG inventory update to track progress toward the Town’s 2030 reduction target.

BACKGROUND
The Town of Los Altos Hills has demonstrated a long-standing commitment to addressing climate change at the local level. In 2016, the City Council adopted the Town’s first Climate Action Plan (CAP), establishing a framework of strategies to reduce greenhouse gas (GHG) emissions and align with statewide climate mandates.

Consistent with regional and state practice, the CAP uses 2005 as the baseline year for measuring GHG emissions. Although the CAP itself was adopted in 2016, the 2005 baseline was selected because it represents the earliest year with reliable local data and provides a consistent reference point for tracking progress against reduction targets.

Since adoption of the CAP, the Town has funded additional inventories (2013, 2018, and most recently 2023), invested staff and committee time, and implemented a range of local policies that demonstrate leadership in climate action.

Building on these early actions, the Town’s Climate Action Plan (CAP) was developed to guide emissions reduction strategies with a target of 52 percent below 2005 levels by 2030. For context, other Bay Area cities have adopted more aggressive goals, such as Palo Alto at 80 percent and Menlo Park at 90 percent reductions by 2030. Nonetheless, Los Altos Hills has consistently positioned itself as a leader in innovative policy adoption, particularly through collaboration with Silicon Valley Clean Energy (SVCE) and by serving as a model for other small jurisdictions.

The Environmental Initiatives Committee (EIC), with assistance from staff and consultants, has now completed the 2023 update of both the community-wide and government operations inventories. These results are intended to provide a clear picture of the Town’s progress toward its ITEM 8A STAFF REPORT

City Council Page 2
Green Housing Gas Inventory
September 18, 2025
2030 target, highlight where reductions have been successful, and identify areas where additional action and Council direction are needed.

DISCUSSION
Government Operations Inventory (2005–2023)
The 2023 government operations inventory indicates that Los Altos Hills has reduced emissions from municipal sources by 65 percent compared to 2005, surpassing the Town’s interim target of a 50 percent reduction by 2025. These reductions were achieved through deliberate and sustained measures, including the conversion of Town vehicles, fire, and garbage fleets to renewable diesel; electrification of municipal facilities; and Town participation in SVCE’s 100 percent renewable electricity program.

While these achievements are significant, the inventory also highlights areas where emissions have increased. Notably, police service emissions have risen by 184 percent since 2005, reflecting both the expansion of services and continued reliance on gasoline-powered vehicles. This underscores the need for targeted strategies in the years ahead. Future opportunities include transitioning police and private security fleets to electric vehicles, converting all Town buildings to all-electric operations, and establishing policies to reduce or offset staff air travel emissions.

Community-Wide Inventory (2005–2023)
Community-wide emissions have declined by 22 percent since 2005, demonstrating measurable progress but falling short of the pace needed to reach the Town’s 52 percent reduction goal by 2030. The most substantial gains have occurred in electricity use, with residential emissions reduced by 91 percent and commercial by 67 percent. These results reflect the community’s widespread participation in SVCE, extensive adoption of rooftop solar, and updated electrification codes.

Transportation emissions have also declined, with on-road travel emissions reduced by 40 percent.

This trend is strongly supported by the exceptionally high rate of electric vehicle adoption among Los Altos Hills residents — estimated at 40 to 50 percent of new vehicle purchases, compared to 22 percent statewide and 7 percent nationally. However, these reductions could also be attributed to other outside factors including the COVID pandemic that restricted community travel substantial and gave raise to remote work which is now returning to pre pandemic levels.

At the same time, certain sectors have shown increases. Air travel remains a significant and growing contributor to emissions, and waste-related emissions have not declined as anticipated.

The greatest ongoing challenge, however, is the use of natural gas and propane for water and space heating in residential and commercial buildings, which continues to account for a large share of community emissions despite incentives and reach code requirements.

Education and Engagement
The inventory results also highlight a need for expanded community education. While residents have embraced EVs out of concern for climate change, most households still rely on gas-fired appliances. With nearly half of new vehicle buyers motivated by environmental concerns, there is an opportunity to channel that same interest toward electrification of household heating systems.

ITEM 8A STAFF REPORT

City Council Page 3
Green Housing Gas Inventory
September 18, 2025
Staff and the EIC recommend that the Town expand outreach through quarterly “Our Town” climate articles that focus on local solutions such as heat pump water heaters and HVAC systems.

This strategy would complement existing incentive programs, provide trusted information from the Town, and help residents make cost-effective, climate-conscious choices at the time of equipment replacement.

Comparison with Neighboring Jurisdictions
Palo Alto has set an 80 percent by 2030 target, and Menlo Park a 90 percent target. Los Altos Hills’ 52 percent by 2030 target is modest by comparison, but the Town has demonstrated steady progress in several key sectors. Like other Bay Area cities, Los Altos Hills uses inventories to track sector-specific progress and calibrate its climate action programs.

Regional Comparison of Greenhouse Gas (GHG) Inventories and Climate Targets Table* Jurisdiction 2030
Target
(from
2005/1990
baseline)
Latest
Inventory
Year
% Reduction Achieved
to Date
Key Sector
Progress
Key Challenges
Los Altos Hills 52%
(2005
baseline)
2023 -22% community-wide,
-65% government ops
Strong EV
adoption (40–
50% of new
sales), SVCE
renewable
electricity,
Town
fleet/facility
electrification
Residential/commercial
heating fuels, rising air
travel emissions
Palo Alto 80%
(1990
baseline)
2022 ~49% reduction Large solar +
renewable
electricity
portfolio,
natural gas
reduction in
new builds,
extensive EV
infrastructure
Natural gas use in
existing buildings,
transportation demand
Menlo Park 90%
(2005
baseline)
2022 ~41% reduction Building
electrification
reach codes, EV
promotion,
waste diversion
Retrofitting existing
buildings, embodied
carbon in development
Mountain View 80%
(2005
baseline,
aligned
2022 ~36% reduction Post-pandemic
EV growth,
renewable
electricity,
Air travel rebound,
natural gas in
residential/commercial
sectors
ITEM 8A STAFF REPORT

City Council Page 4
Green Housing Gas Inventory
September 18, 2025
with
CAP)
waste sector
progress
Sunnyvale 56%
(1990
baseline,
“Game
Plan
2028”)
2022 ~44% reduction CEQA GHG
thresholds,
CAP Playbook
implementation,
EV readiness
Older building stock
gas reliance, regional
VMT growth
Cupertino 45%
(2010
baseline;
carbon
neutrality
by 2040)
2021 ~30% reduction Community
solar, updated
inventory
methodology,
electrification
incentives
Natural gas in
homes/businesses, high
per-capita travel
emissions
East Palo Alto 40% per
capita
reduction
by 2030
(2005
baseline)
2021 ~18% reduction CAP actions in
electrification,
fleet, waste
Limited staff/capacity,
growth pressures,
vehicle dependence
Alameda (City) 50% by
2030
(2005
baseline),
net zero
2045
2022 ~35% reduction Clean energy
transition,
electrification,
CARP
implementation
Sea-level rise
adaptation, air travel
Alameda County
(Unincorporated)
40% by
2030
(2005
baseline),
net zero
2045
2022 ~28% reduction Updated
Community
Climate Action
Plan, renewable
portfolio
Transportation sector,
dispersed suburban
development
* = Denotes that the table and its contents were generated using AI.

FISCAL IMPACT
Under the current contract, the Town has allocated $19,123 annually from the General Fund, for a total of $57,370 over the three-year period covering 2023, 2024, and 2025.

ENVIRONMENTAL REVIEW
This action is exempt from CEQA as it does not constitute a project under the California Environmental Quality Act, as it will not result in a direct or reasonably foreseeable physical change in the environment (CEQA Guidelines § 15378(b)(5)). Future actions proposed as a result of this report will be evaluated for CEQA applicability.

ITEM 8A STAFF REPORT

City Council Page 5
Green Housing Gas Inventory
September 18, 2025
2024-25 CITY COUNCIL WORK PLAN:

This item is a part of the 2024-25 City Council Work Plan under the category of Service Delivery / Governance.

ATTACHMENTS:

1. EIC presentation on 2023 LAH GHG Inventory and Climate Action Plan Impact ITEM 8A STAFF REPORT

Los Altos Hills
Green House Gas (GHG)
Reduction Initiatives
Presentation to Town Council
September 18, 2025
ITEM 8A ATTACHMENT 1

Rising Public Demand for Climate Action
LAH has an Opportunity to Lead
ITEM 8A ATTACHMENT 1

Outline
•Green House Gas Reduction Progress
•Opportunities for Faster Progress
•City Actions Requested
ITEM 8A ATTACHMENT 1

Who We Are
• Environmental Initiatives Committee (EIC)
Climate Subcommittee
• Anand Ranganathan, Steve Schmidt, Mike Salameh
• Count emissions to measure our progress
• Supported by
• Other EIC members
• Vrinda Bhandarkar, George Lee, April Anair, Aileen Lee, Johann George • CSG Consultants
• Jay Bradford and other City Staff
ITEM 8A ATTACHMENT 1

LAH GHG Initiatives Summary
•LAH committed to reducing GHG since 2005
• Funding GHG inventories
•Climate Action Plan
•Dollars and staff time
•LAH goal: Reduce GHG 52% by 2030
•By comparison Palo Alto 80%, Menlo Park 90%
•LAH a leader in Reach Codes
ITEM 8A ATTACHMENT 1

Two GHG Inventories
Community
• Home energy use
• Driving
• Air travel
• Foothill College
• Etc.

Government
• Town Hall, Westwind Barn
• Fire, Garbage, Police
• Etc.

ITEM 8A ATTACHMENT 1

Two Inventories
Government Community
Government only 0.2% but:
-Sets the example and tone
-Provides leadership
-Proves out the technology
ITEM 8A ATTACHMENT 1

2030 Target
2025
Target
Garbage goes
Renewable Diesel
Fire goes
Renewable Diesel
Government Emissions MT CO2E
More
Police
ITEM 8A ATTACHMENT 1

Government GHG Changes (2005 → 2023)
-450
-400
-350
-300
-250
-200
-150
-100
-50
0 50
100
Renewable Diesel
Driven by S Schmidt EIC
Net Reduction
Since 2005
2023
Actual
-65%
Decreases Increases
Garbage -90%
Fire -92%
Town Fleet -76%
Town Bldgs -60%
Emp Commute -55%
Police +184%
Renewable Diesel
Driven by Anand EIC
Free EV Charging
Switch to SVCE
Conversion to EVs and
Renewable Diesel
2030 Target -50%
MT
CO2E
ITEM 8A ATTACHMENT 1

Government Improvement Opportunities
•In estimated order of impact
•Police → EVs
•Private Security → EVs
• Not in ‘23 inventory, will be counted in ‘24
•More Employees → EVs
•All buildings → Electric
•Employee business air travel
ITEM 8A ATTACHMENT 1

0 20,000
40,000
60,000
80,000
100,000
Air Travel (est )
Auto Travel (VMT)
Commercial Natural Gas
Commercial Electricity
Waste (Solid & Liquid)
Residential Heating Fuel
Residential Electricity
2030 Target
Community Emissions MT CO2E
ITEM 8A ATTACHMENT 1

Community GHG Changes (2005 → 2023)
-25000
-20000
-15000
-10000
-5000
0 5000
High EV Adoption &
Work from Home
Net Reduction
Since 2005
2023
Actual
-22%
(2030 tgt -52%)
Decreases Increases
(Waste & Air Travel)
Auto -40%
Residential
Elec. -91%
Comm Elec. -67%
Res. Heat Fuel -5%
Converted to SVCE
-Down 5% despite ~5%
Population Increase
- Electrification Codes
& Incentives
-Turning
Ocean Liner
a tiny bit
MT
CO2E
ITEM 8A ATTACHMENT 1

Community Progress
Gas Pool at
Foothill College
would add
~5% to LAH
GHG emissions
Sep 5,2023
Sep 18,2023
. ”But EIC members Steve Schmidt and Anand
Ranganathan are dissatisfied with the approach.”
ITEM 8A ATTACHMENT 1

Opportunity to Bend the Curve
•Residential Heating: Prime Target
•Half of all LAH GHG emissions
•LAH/SVCE/State can influence through:
• Incentives for HPWH and HP HVAC
• Codes
• Education: Powerful but Under-utilized
ITEM 8A ATTACHMENT 1

Education Opportunity: LAH Ready for Change
• 40 to 50% of new vehicles bought by LAH residents are EVs • vs. 22% for California and 7% for the US
• Many buying EVs due to climate change concerns
• But vast majority still use gas for water and air heating •Opportunity to bend the curve: Education
• For those replacing a gas water heater or HVAC system • GHG impact of gas heating
• Zero emissions alternatives
• Heat Pump Water Heaters and HVAC Systems
• Cut carbon footprint without cost or lifestyle compromise ITEM 8A ATTACHMENT 1

City Actions Requested
• Continue to Support
• Enhanced Reach Codes
• Keep Turning the GHG Ocean Liner
• GHG inventory
• GHG reduction by Government
• Foothill Pool Electrification
• City-backed Education about Environmental Initiatives:
• Message endorsed by City is credible and powerful
• For ex: Regular Coverage in Our Town & City Manager Newsletter • Local oriented, factual, not preachy, provides solutions • For ex: LAH GHG initiative, HPWH, Water , Wildfire
ITEM 8A ATTACHMENT 1

THE TOWN OF LOS ALTOS HILLS September 18, 2025
Staff Report to the City Council
SUBJECT: Discussion and direction on a proposed ordinance amending Title 8 (Building Regulations) of the Los Altos Hills Municipal Code and Adopting by Reference the 2025 California Building Standards Code, including but not limited to Administrative, Building, Residential Building, Electrical, Mechanical, Plumbing, Energy, Historical Building, Existing Building, and Referenced Standards, Including Local Modifications and Amendments to the Codes
PREPARED BY: Jay Bradford, Community Development Director APPROVED: Peter Pirnejad, City Manager

RECOMMENDATION
Staff recommends that the City Council receive an update on committee and staff proposed local amendments to the 2025 California Building Code Standards and provide direction as to which options to pursue.

BACKGROUND
The California Building Standards Code (Title 24 of the California Code of Regulations and hereinafter “Standards”) includes the California Building, Residential, Electrical, Mechanical, Plumbing, Energy, Fire, Wildland-Urban Interface, and Existing Building Codes and the Green Building Standards. The Standards are maintained by the California Building Standards Commission (Commission) which generally updates, amends and republishes the Standards every three years. The Commission bases its updates on changes to national and international “model codes”, which reflect the best current understanding of the building industry on issues ranging from life safety to energy and water efficiency. The Commission published its most recent update to the Standards on July 1, 2025 (the 2025 Standards).

The Town of Los Altos Hills is a local jurisdiction with authority to implement and enforce the Standards. Under state law, the 2025 Standards, as published by the Commission, become effective to all occupancies throughout California on January 1, 2026. The California Health and Safety Code require the City Council to adopt the 2025 Standards but also allows the City Council to adopt local amendments to the Standards based on local climatic, geological or topographical conditions, which the City previously did for § 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022 Standards. If the City does not adopt local amendments to the 2025 Standards by January 1, 2026, the 2025 Building Standards go into effect without any local amendments. All local amendments must be filed with the California Building Standards Commission in order to be effective. While Energy Code amendments must be cost effective and reviewed by the California Energy Commission.

ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025
This report provides Council with an overview of the local amendments being proposed by the Chief Building Official and various town committees to address unique local conditions, together with recommended policies that will assist the Chief Building Official in implementing the locally amended Standards. Based on the direction received, staff will finalize the adopting ordinances for consideration by the City Council in late October and early November so that the locally amended Standards go into effect on January 1, 2026.

DISCUSSION
As mentioned in the background, building codes are reviewed and revised through national and statewide processes that allow for updates every three years. However, in June 2025, the California State Legislature adopted Assembly Bill (AB) 130, a budget trailer bill that included amendments affecting local community development policies for planning and building departments.

AB 130, enacted as part of the 2025 housing budget package, has significantly reshaped the State’s code adoption process. While the 2025 California Building Standards Code (Title 24) will still take effect on January 1, 2026, the legislation establishes a six-year moratorium on most amendments to residential building standards, effective October 1, 2025, through June 1, 2031.

The intent of this pause is to provide regulatory stability for residential development and reduce the continual layering of new requirements that could otherwise affect housing production.

During this period, modifications to the residential code will only be permitted under the following circumstances:

1. The Building Standards Commission deems changes necessary as emergency standards to protect health and safety.

2. Relate to home hardening and proposed for adoption by the Office of the State Fire Marshal or a fire protection district.

3. Are proposed to address single-exit single-stairway apartment houses.

4. Necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10, 2025, and permits mixed-use residential construction consistent with federal law while also incentivizing all-electric construction as part of an adopted GHG reduction strategy.

5. Proposed to the adaptive reuse standards working group, reduce potable water use in new residential buildings, or support risk-based water quality standards for the onsite and reuse of nonpotable water for certain residential buildings.

6. Ensure the latest editions of the model codes are incorporated into the California Building Standards Code.

7. Necessary to incorporate updates to accessibility requirements that align with minimum federal accessibility laws, standards, and regulations.

ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025

8. The changes or modifications are substantially equivalent to standards filed by the local government or were in effect before September 20, 2025.

For towns like Los Altos Hills, these exemptions provide practical pathways to continue pursuing local policy priorities while remaining compliant with the statute. Preserving and readopting current local amendments before the September 30, 2025 deadline will ensure continuity. Fire safety provisions, especially those aligned with Wildland-Urban Interface or Fire Hazard Severity Zone standards, can be advanced under the home hardening exception. Climate-oriented reach codes may proceed if structured as incentives and properly tied to the Town’s adopted Climate Action Plan or General Plan framework. Together, these avenues allow the Town to balance the stability mandated by AB 130 with its ongoing objectives in safety, resilience, and sustainability.

The 2025 California Building Standards Code (Title 24) introduces several substantive updates intended to strengthen safety, resilience, and efficiency across the built environment. Key enhancements include the adoption of a fully restructured Wildland–Urban Interface (WUI) Code, replacing the prior Building Code Chapter 7A and Residential Code R337 with more comprehensive wildfire-resilient standards; updated provisions for seismic retrofits to improve the performance of existing buildings; incorporation of new NFPA 72 requirements for two-way communication systems in stairwells and elevator lobbies to enhance life safety; and continued advancement of the State’s energy standards to support electrification and greenhouse gas reduction goals.The Wildland–Urban Interface (WUI) Code specifically has been a focal point in Los Altos Hills’ code past code adoption discussions. With the standards being reorganized at the state level, recommendations coming from Town committees, and new Fire Hazard Severity Zone (FHSZ) maps recently adopted, it is important to understand when the Town first began considering these provisions. The conversation dates back to 2019, when the Los Altos Hills City Council adopted the 2019 California Building Standards Code as part of the State’s triennial code cycle. That adoption, approved unanimously on a 5–0 vote, incorporated all required model codes—Building, Residential, Electrical, Mechanical, Plumbing, Energy, Fire, Existing Building, Historical Building, and Green Building Standards—along with local amendments tailored to the Town’s conditions.

During this same period, the Los Altos Hills County Fire District requested that the Town adopt Section R337 of the California Residential Code, the WUI standards. Section R337 introduced ignition-resistant construction requirements, including the use of non-combustible or emberresistant exterior materials, to mitigate wildfire risks in high-hazard areas. Councilmember Tyson introduced the item, and the Council directed staff to bring the amendments directly to Council for consideration, rather than routing them through the Planning Commission, in order to expedite their review. Public comment reflected strong community support for rapid adoption, recognizing the wildfire threat facing the Town.

The incorporation of WUI standards presented both benefits and challenges. On the positive side, it strengthened the Town’s wildfire resilience, aligned local codes with CAL FIRE and regional safety priorities, and responded to resident concerns about fire risk. On the other hand, it introduced ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025
higher construction costs, increased administrative review, and raised concerns from some developers and homeowners who viewed the requirements as restrictive.

Taken together, the 2019 cycle established a framework in which Los Altos Hills not only complied with the State’s mandate to adopt updated building codes but also laid the groundwork for enhanced wildfire safety standards. The Council’s unanimous action on the base code adoption, paired with consensus to move forward with Section R337, reflected a clear policy direction: meet State obligations while advancing stronger wildfire resilience tailored to the community’s needs.

Something the current Council will be asked to continue support for. Therefore, next steps would be for the staff to come back to council with findings and actions to adopt the proposed amendments to the building code that support fire hardening. Staff intends to work with EPRC, the Fire District, and the County Fire Department to bring recommendations back to the City Council for consideration and potential adoption.

Los Altos Hills Municipal Code. The Town purposes incorporating the Building Standards Code within Title 8 of the Municipal Code in the following divisions:

CH 8-0. GENERAL PROVISIONS AND PENALTIES
Ch 8-1.1 CALIFORNIA ADMINISTRATIVE CODE
Ch 8-1.2 CALIFORNIA BUILDING CODE (VOLUMES 1 AND 2)
Ch 8-1.2.5 CALIFORNIA RESIDENTIAL CODE
Ch 8-1.3 CALIFORNIA ELECTRICAL CODE
Ch 8-1.4 CALIFORNIA MECHANICAL CODE
Ch 8-1.5 CALIFORNIA PLUMBING CODE
Ch 8-1.6 CALIFORNIA ENERGY CODE
Ch 8-1.7 CALIFORNIA WILDLAND–URBAN INTERFACE
Ch 8-1.8 CALIFORNIA HISTORICAL BUILDING CODE
Ch 8-1.9 CALIFORNIA FIRE CODE
Ch 8-1.0 CALIFORNIA EXISTING BUILDING CODE
Ch 8-1.11 CALIFORNIA GREEN BUILDING STANDARDS CODE
Ch 8-1.12 CALIFORNIA REFERENCED STANDARDS CODE
Ch 8-2 SAFETY ASSESSMENT PLACARDS
ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025
Ch 8-3 MOVING OF BUILDINGS
Ch 8-4 GREEN BUILDING REGULATIONS
Ch 8-5 BUILDING CONSTRUCTION STANDARDS
Ch 8-6 SIGNS AND ADVERTISING STRUCTURES
Ch 8-7 BUILDING CONSTRUCTION AND STRUCTURAL ADDITION CHARGES Ch 8-8 CODE ADMINISTRATION AND ENFORCEMENT
Ch 8-9 SMALL RESIDENTIAL ROOFTOP SOLAR EXPEDITED PERMITTING Ch 8-10 CONSTRUCTION TIME LIMITS
Ch 8-11 STREAMLINED PERMITTING PROCESS FOR ELECTRIC VEHICLE

CHARGING STATIONS
Reviewing the 2025 Standards for adoption, staff is proposing to retain the existing standards found in Title 8, including the Town’s Zero NOx policy, except where specific local amendments are identified. The Town’s current building code amendments can be found here:
https://ecode360.com/43997546. The proposed amendments, along with related policies and fees to support their administration, are outlined and discussed below. Over the past 2 years, in preparation for the 2025 Building Code Updates, staff has been gathering input from committees, community members, and other stakeholders, while also reviewing best practices. The following section provides a summary of that effort and the recommendations that have emerged.

Proposed Local Amendments. Staff is proposing a series of local amendments to the various standard codes to reflect local conditions and clarify authority for certain actions. These local amendments are presented by division below.
8-0 GENERAL PROVISIONS AND PENALTIES
a. The Standards contain inconsistent language relating to the Building Official’s authority to grant extensions to permits. Staff is proposing a local amendment that will consistently give the Building Official the discretion to extend all types of building permits by adopting a consistent administrative guide. b. Adopt the existing local amendment which allows the Building Official to issue refunds on fees paid. This local amendment requires that all refund requests must be made in writing within 180 days of application. When such requests are made, the Building Official may authorize the following refunds:

1. 100% of any erroneously calculated or charged fee;
ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025

2. 90% of any plan review fee if the refund request is made before the review work begins (the 10% retention covers the cost of intake and refund issuance); and

3. 90% of any building, plumbing, electrical or mechanical permit fee if the refund request is made before the work and any inspections begin (again, the 10% retention covers the cost of intake and refund issuance).
c. Adopt local amendments which allows the Building Official to adjust fees and covers the collection process for unpaid fees.
d. Adopt a Concealed Construction Guidelines to help staff address the risks to life, health and public safety created when construction is covered or concealed without inspection.
e. Adopt penalties for not completing construction projects and for work without permits.
f. Adopt noticing process for unsafe structures.
g. Adopt code provisions that allow the penalties included in Division 8-0 to apply uniformly across chapter 8-1 through 8-12 in order to minimize inconsistency in administration.
h. Consider a new local amendment that requires applicants using a Contractor’s State Licensing Board license to be the license holder him/herself or have the license holder’s written permission. This modification is aimed at individuals have claimed they are pulling permits of behalf of their company or other licensed individuals while truly utilizing the licensee’s credentials without the owner’s permission causing undue hardship for the licensees and the home owner. This can lead to financial claims and improper construction. This amendment is aimed at curtailing this type activity.
i. Consider a new local amendment that allows the Building Official to require photographic evidence, a physical inspection or similar documentation of existing conditions prior to a permit being issued for residential alterations and repairs. This amendment is meant to give plan reviewers and inspectors more tools to insure minimum building code standards are being maintained.

8.1.2– Building Code
a. Adopt the local amendment which cross-references the Fire Code (Municipal Code Section 8-9) for address numbering and fire protection standards. b. Adopt the local amendment which requires developers to fund third-party expert special seismic inspections.

ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025
8-1.2.5 – Residential Code:
a. Adopt the local amendments that clarify that all regulation of fire sprinklers is governed by Division 8-9(Fire Code).
b. Adopt amendments to require Class A Roofing assemblies for all new construction or re-roofs to reduce the risk of fire spread. Roofing assemblies are made of three separate building materials; roof coverings aka shingles, underlayment, and roof sheathing. When materials are combined they are classified by their ability to resists a number of environmental forces. Roofing assemblies are broken into three categories Class A, B, and C. Class A roof assemblies being the category that are the most effective against severe fire exposure. This proposed new amendment is being adopted across Sonoma County and is seen as a way to increase resistance to wildfires.
c. Consider a new amendment to require self-sealing or ember intrusion resistant vents for attics and crawl spaces. Self-sealing or ember intrusion resistant vents limit the ability for fire or embers to enter a home by either stopping movement of air completely in the case of self-sealing vents or capturing embers prior to entering the home in a non-combustible screen. Along the same lines as the provision above self-sealing or ember intrusion resistant vents are seen as a way to limit the exposure to wildfires.
8-1.3 – Electrical Code
a. Adopt local amendment that requires replacement of Federal Pacific and Zinsco electrical panels to include both main and subpanels and to align with PG&E standards.
8-1.9 – Fire Code:
a. Adopt amendments proposed by Santa Clara County Fire Department. 8-1.11 – Green Building Code:
a. Adopt the Tier I measures for voluntary upgrades to residential and non-residential structures excluding energy efficiency standards.
8-4 – Green Building Regulations
Removal is recommended due to advancements in the base California building standards.
8-5 – Building Construction Standards
Adopt specific standards to clarify the use of underground transformers for private property.

ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025
8-10 - Construction Time Limits
Adopt adjustments to conditions of policy that allow Building Official to grant extensions.

Proposed Committee Policies. Like staff the town’s committees also had recommendations for code amendment. Committee recommendations for some policies have been separated out between code amendments for building versus other parts of the municipal code like other title contained in the same code. This section focus on building due to the pending code cycle change while zoning modification will be brought as work on the housing and planning commission schedule allows over the next few months, with the zoning work forecasted for the first quarter of 2026.

1. Gas Earthquake Safety Shutoff Valve Program with permit fee waivers and education program as recommended by the Technology Committee.

2. Part 7 California Wildland–Urban Interface adoption town wide including noncombustible fencing within 5 feet of structures as recommended by the Emergency Preparedness and Response Committee.

3. Transition from air conditioning to heat pumps at time of replacement and impose Zero NOx requirements for multifamily housing as recommended by the Environmental Initiatives Committee.

FISCAL IMPACT
Adoption of the 2025 California Building Standards Code and associated local amendments will not result in a direct fiscal impact to the Town’s General Fund. Implementation costs associated with enforcement of the code are covered through existing permit, plan check, and inspection fees.

Any additional costs for recordation or processing of amendments will be borne by applicants as part of standard permit fees.
2024-25 CITY COUNCIL WORK PLAN
This item is a part of the 2024-25 City Council Work Plan under the category of Service Delivery / Governance.

ENVIRONMENTAL REVIEW
Adoption of the 2025 California Building Standards Code and related local amendments is exempt from review under the California Environmental Quality Act (CEQA). Pursuant to CEQA Guidelines Section 15061(b)(3), this action has no potential to cause a significant effect on the environment because it consists of adopting state-mandated building standards with limited local amendments that either maintain existing requirements or enhance life-safety, fire-resilience, and sustainability provisions.

ITEM 8B STAFF REPORT

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Local Amendments to 2025 California Building Code Standards September 18, 2025

ATTACHMENTS
N/A
ITEM 8B STAFF REPORT

LOCAL AMENDMENTS TO THE 2025 CALIFORNIA

BUILDING STANDARDS CODE

CITY COUNCIL
SEPTEMBER 18, 2025

BACKGROUND
• Promulgated by the California Building Standards Commission on a 3-year cycle. • Includes errata, supplemental, and intervening code cycles, as well as changes in state law.
• 2025 Building Code Standards are published July 1, 2025. • Standards take effect January 1, 2026.
• Local amendments may be adopted based on climatic, geological, or topographical conditions.
• If not adopted, State Standards apply without local amendments.

ASSEMBLY BILL 130 (2025)
• AB 130 (part of the 2025 housing budget package) reshaped the State’s code adoption process.
• 2025 California Building Standards Code (Title 24) still takes effect on January 1, 2026.
• Establishes a six-year moratorium on most residential building standard amendments (Oct 1, 2025 – Jun 1, 2031).
• Purpose: provide regulatory stability and reduce continual layering of requirements that could hinder housing production.

ASSEMBLY BILL 130 (2025)

ALLOWED BUILDING CODE AMENDMENTS
• The Building Standards Commission deems changes necessary as emergency standards to protect health and safety.
• Relate to home hardening and proposed for adoption by the Office of the State Fire Marshal or a fire protection district.
• Are proposed to address single-exit single-stairway apartment houses. • Necessary to implement a local code amendment that is adopted to align with a General Plan approved on or before June 10, 2025, and permits mixed-use residential construction consistent with federal law while also incentivizing allelectric construction as part of an adopted GHG reduction strategy.

ASSEMBLY BILL 130 (2025)
ALLOWED BUILDING CODE AMENDMENTS CONT.
• Proposed to the adaptive reuse standards working group, reduce potable water use in new residential buildings, or support risk-based water quality standards for the onsite and reuse of nonpotable water for certain residential buildings. • Ensure the latest editions of the model codes are incorporated into the California Building Standards Code.
• Necessary to incorporate updates to accessibility requirements that align with minimum federal accessibility laws, standards, and regulations. • The changes or modifications are substantially equivalent to standards filed by the local government or were in effect before September 20, 2025.

RECOMMENDATION
City Council to receive an update on committee and staff proposed local amendments to the 2025 California Building Code Standards and provide direction on which options to pursue.

Process for This Session:
• Overview of each proposed amendment will be presented. • Public comment will be taken.
• Council will be polled after each item to determine:
• Support for the amendment, or
• Need for additional background.
• Council may adjust the final recommendations to staff.

Next Steps:
• Staff will use Council feedback to prepare the local ordinance amendments. • Ordinance amendments will return to City Council in October for formal consideration.

COMMITTEE RECOMMENDATIONS
Technology Committee:
• Gas earthquake safety shutoff valve program
Emergency Preparedness Committee:
• WUI adoption townwide
• Noncombustible fencing near structures
Environmental Initiatives Committee:
• Transition to heat pumps
• Zero NOx policy for multifamily
Recommendation:

To work with the Town Committees, Santa Clara County Fire Dept, and Los Altos Hills Fire District to prepare amendments in these areas and bring back polices and/or resolutions/ordinances for consideration and potentially adoption.

WILDLAND–URBAN INTERFACE (WUI) CODE
• 2019 Code Cycle – Town adopted CRC Section R337 with recommendations from the Fire District. • 2022 Code Cycle – Standards were readopted with local amendments. • 2025 Code Cycle – CRC R337 and CBC Chapter 7A have been removed and consolidated into Part 7 of the California Building Standards Code.
• Amendments are developed in coordination with Santa Clara County Fire Department and the local jurisdictions they serve, including:
• Los Gatos
• Monte Sereno
• Saratoga
• Cupertino
Recommendation:

To bring back to the Council recommendations to adopt Part 7 of the CBCS (Formerly R337) with local modifications to apply Town Wide.

FIRE CODE AMENDMENT
• California Fire Code amendments are developed in coordination with Santa Clara County Fire Department.
• No new amendments proposed — only refinements to previously adopted standards.
• Updates are based on operational demands.
• Intended to provide clarity for enforcement and consistency county wide Recommendation:

To work with the SCC Fire Department to bring any proposed clarifications back to the City Council for consideration and adoption.

ADMINISTRATIVE AMENDMENTS
8-0 General Provisions and Penalties
• Standardize authority for the Building Official to grant permit extensions through a consistent administrative guide.
• Retain existing local amendment allowing fee refunds (requests must be in writing within 180 days):
• 100% refund for erroneously calculated/charged fees.
• 90% refund of plan review fees if requested before review work begins. • 90% refund of building, plumbing, electrical, or mechanical permit fees if requested before work/inspections begin.
• Adopt amendments allowing fee adjustments and collection of unpaid fees.

Recommendation:

To bring back modifications to the administrative section of the Building Code with necessary changes to help enforce said code and the administration and safeguards in the issuance of refunds and fee collection.

ADMINISTRATIVE AMENDMENTS CONTINUED
8-0 General Provisions and Penalties Continued
• Adopt Concealed Construction Guidelines to address safety risks when work is hidden without inspection.
• Adopt penalties for incomplete construction projects and unpermitted work. • Adopt a noticing process for unsafe structures.
• Apply Division 8-0 penalties uniformly across Chapters 8-1 through 8-12 for consistent enforcement.
• Consider amendment requiring contractors to be the license holder or to present written permission from the license holder, preventing misuse of credentials. • Consider amendment allowing Building Official to require photographic evidence, inspections, or documentation of existing conditions before issuing permits for alterations/repairs.

Recommendation:

To bring back modifications to the administrative section of the Building Code with necessary changes to help clarify enforcement and penalties to maintain compliance with the Building Code Standards.

TECHNICAL AMENDMENTS
8-1.2 – Building Code
• Cross-reference Fire Code (Section 8-9) for address numbering and fire protection standards. • Require developers to fund third-party expert seismic inspections. 8-1.2.5 – Residential Code
• Clarify that all regulation of fire sprinklers is governed by Division 8-9 (Fire Code). • Require Class A Roofing assemblies for new construction or re-roofs to reduce fire spread risk. • Consider requiring self-sealing or ember-resistant vents for attics and crawl spaces to limit ember intrusion during wildfires.
8-1.3 – Electrical Code
• Require replacement of Federal Pacific and Zinsco electrical panels (main and subpanels) to align with PG&E standards.

Recommendation:

To bring back technical amendments to the Building, Residential and Electrical Codes.

TECHNICAL AMENDMENTS CONTINUED
8-1.9 – Fire Code
• Adopt amendments proposed by Santa Clara County Fire Department. 8-1.11 – Green Building Code
• Adopt Tier I measures for voluntary upgrades to residential and non-residential structures (excluding energy efficiency standards). 8-4 – Green Building Regulations
• Recommend removal due to advancements in base California standards. 8-5 – Building Construction Standards
• Clarify standards for underground transformers on private property. 8-10 – Construction Time Limits
• Adopt adjustments allowing the Building Official to grant extensions under specified conditions.

Recommendation:

To bring back technical amendments for Fire, Green Building Code, Building Construction Standards, and Construction Time Limits and eliminate the chapter on Green Building Regulation.

QUESTIONS /COMMENTS?

THANK YOU
Local Amendments to the 2025 California Building Standards Code Prepared and Presented by: Jay Bradford, Community Development Director

TOWN OF LOS ALTOS HILLS September 18, 2025
Staff Report to the City Council
SUBJECT: CONSIDERATION OF AN APPEAL FROM THE PROPERTY OWNER OF 12251 STONEBROOK DRIVE (APN: 336-28-067) OF THE CITY ENGINEER’S

DETERMINATION ON THE PARCEL FRONTAGE SEWER EXTENSION
REQUIREMENT FOR SEWER REVIEW APPLICATION NO. SR25-0013; AND

ADOPT A RESOLUTION MAKING FINDINGS AND GRANTING OR

DENYING THE APPEAL AND AUTHORIZING THE CITY MANAGER TO

EXECUTE A SEWER CONSTRUCTION AND DEDICATION AGREEMENT
FROM: WooJae Kim, Public Works Director/City Engineer
Daniel Liang, Utility Engineering Manager
APPROVED: Peter Pirnejad, City Manager
RECOMMENDATION: That the City Council:

1. Consider an appeal from the property owner of 12251 Stonebrook Drive (APN: 336-28- 067) of the City Engineer’s determination on the parcel frontage sewer extension requirement for Sewer Review Application No. SR25-0013; and

2. Adopt a resolution making findings and either granting (Attachment 1) or denying (Attachment 2) the appeal and authorizing the City Manager to execute a Sewer Construction and Dedication Agreement.

BACKGROUND:

Pursuant to Los Altos Hills Municipal Code Section 6-4.446 “Extension of Sewer Main Facilities”, sewer main facilities may be extended by an applicant in accordance with plans and specifications approved by the City Engineer. Under Section 6-4.446(1), when a sewer main is to be extended to serve a parcel, that main “shall extend the full frontage of said parcel” unless it is determined by the City Engineer that “the main is not likely to be extended to serve any other property.” Section 6-4.111, located in the same Municipal Code chapter and article that govern sewer extension and other related issues, provides that the City Engineer’s determination, as an administrative official’s decision, may be appealed to the City Council by filing a written notice of appeal with the City Clerk within 10 days after receiving a notice of the determination accompanied by the required appeal fees. Upon receiving the appeal, the City Clerk is required to put the matter on the next open agenda for a hearing at a regularly scheduled Council meeting.

DISCUSSION:

The property owner of 12251 Stonebrook Drive is proposing to develop an SB 9 unit and an ADU on his property. The property has an existing primary unit of 3,263 square feet, which is currently served by a private septic tank for sewer disposal. In conjunction with the development applications, the property owner submitted a sewer review application (SR25-0013) to the Town ITEM 8C

Staff Report to City Council Page 2
12251 Stonebrook Drive Sewer Main Extension Appeal
September 18, 2025
2 on May 5, 2025, proposing to abandon the septic tank for the primary house and to connect the existing home, along with the proposed SB 9 unit and ADU, to the Town’s sanitary sewer system.

The Town’s current SB 9 Ordinance (Title 10, Chapter 1, Articles 15) requires all newly created dwelling units to be connected to either the public sewer or be served by an onsite wastewater treatment system (i.e., septic tank) that is approved by the Santa Clara County Department of Environmental Health (DEH). DEH enforces the State regulations on onsite wastewater treatment systems for the Town and the County. Likewise, the Town’s current ADU Ordinance (Title 10, Chapter 1, Articles 14) requires ADUs constructed with a new single-family home on the same lot to be either connected to the public sewer system or to a septic tank approved by DEH.

According to the Town’s Sewer Ordinance, a property is required to connect to the Town’s public sewer if there is an existing sewer main within 200 feet of the property line. Per Section 6-4.102 of the Municipal Code, “. . . All new residences and major additions shall be connected to an approved public sewer when such sewer is within 200 feet of the property line, except when the elevation of the existing sewer main does not facilitate gravity flow and is not subject to a sewer reimbursement agreement. Sewer connection exceptions are subject to the approval of the City Engineer and/or the Health Officer.”
Since 12251 Stonebrook Drive property is not within 200 linear feet of the Town’s closest sewer main on Stonebrook Court, the proposed development on the subject property is not subject to the requirements of Section 6-4.102 to connect to the Town’s sewer system.

Although the Town is not requiring either the primary home or the proposed SB 9 unit and ADU to connect to the Town’s sewer system, the property owner is requesting connection, because, according to the owner, upgrading the current septic tank system as required by DEH for the proposed development would substantially reduce the buildable area and create challenges to construct and maintain three separate dwelling units on the 1.311-acre lot. By connecting to the Town’s sewer system, the property owner claims that he can maximize the buildable area on his property.

Applicant’s Proposal and Town’s Sewer Review
The Town received the 12251 Stonebrook Drive Sewer Main Extension Plans on April 29, 2025, and the “Application for Project Review” form with project plans (Attachment 3) on May 5, 2025.

The scope of work for the sewer main extension includes constructing a new eight-inch sewer main approximately 220 feet along Stonebrook Drive from an existing sewer manhole at the intersection of Stonebrook Court and Stonebrook Drive, and terminating with a new sewer manhole near the northeasterly corner of the property (see Figure 1) where a new four-inch private sewer lateral for the property would connect to the new manhole.

Staff Report to City Council Page 3
12251 Stonebrook Drive Sewer Main Extension Appeal
September 18, 2025
3 Figure 1: Proposed Sewer Main Extension – 12251 Stonebrook Drive The proposed termination location of the new sewer main extension may be the shortest distance needed to connect to the Town’s sewer system. However, Sewer Ordinance Section 6-4.446(1) states that for a sewer main extension, the main line needs to be extended the full frontage of the property, not to the nearest point of private lateral connection for the property, unless the sewer main extension will not serve any other property.
§ 6-4.446(1) Parcel frontage extension for sewer mains.

Where a main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer that the main is not likely to be extended to serve any other property.

Currently, there are thirteen properties with frontage on Stonebrook Drive, between Stonebrook Court and Prospect Avenue. According to the Town’s sewer map (Attachment 4), seven of the thirteen properties are currently on the septic system, and the remaining six properties are connected to the public sewer as follows:

No. Address Sewer Disposal
1 12211 Stonebrook Drive Septic system
2 12231 Stonebrook Drive Septic system
3 12241 Stonebrook Drive Septic system
4 12251 Stonebrook Drive Septic system (requesting connection to Town sewer system)
5 12358 Priscilla Lane Septic system
6 24737 Prospect Avenue Septic system

Staff Report to City Council Page 4
12251 Stonebrook Drive Sewer Main Extension Appeal
September 18, 2025
4 7 24719 Prospect Avenue Septic system
8 12321 Stonebrook Court Public sewer, connected on Stonebrook Court 9 12352 Priscilla Lane Public sewer, connected on Priscilla Lane 10 12354 Priscilla Lane Public sewer, connected Priscilla Lane 11 12356 Priscilla Lane Public sewer, connected on Priscilla Lane 12 12101 Oak Park Court Public sewer, connected on Oak Park Court 13 24000 Oak Knoll Circle Public sewer, connected on Oak Park Court Since there are six properties (excluding the applicant property) on Stonebrook Drive that are not currently connected to the public sewer, which can be served by the proposed sewer main extension in the future, the sewer main extension for 12251 Stonebrook Drive would require extension along the full frontage of the parcel per Section 6-4.446 (1) of the Municipal Code.

On May 12, 2025, the Utility Engineering Manager responded to the applicants of SR25-0013 with review comments requiring extension of the proposed sewer main along the full frontage of the property. This would require approximately 190 linear feet of additional sewer main extension to the southeasterly corner of the property from the current proposed extension that ends at the northeasterly property corner.

Opposing Arguments to Staff Response
ADU Collective, representing the 12251 Stonebrook Drive property, responded to the Town’s comments in letters dated July 9 and August 1, 2025 (Attachment 5). ADU Collective stated that extending the sewer connection along the entire frontage of the property would increase the project cost by approximately $100,000, and such an increase may render the housing project financially infeasible.

Furthermore, ADU Collective argued that the Town’s request to extend the sewer main along the full frontage of the property conflicts with State housing laws for SB 9 and ADU projects, is inconsistent with the Town’s municipal code, and contradicts the City’s latest 6th Cycle Housing Element. Specifics of the arguments raised are summarized below:
 The sewer main extension requirement involves subjective judgment by the City Engineer and is therefore inconsistent with state laws requiring objective standards be applied to SB 9 units and ADUs.
 The property at 12251 Stonebrook Drive is located within a built-out environment, not on the outskirts of the Town, and surrounding neighboring properties are already on existing sewer and septic systems. Thus, requiring a sewer main extension for “indeterminate, future” use would be subjective, wasteful, and cost-prohibitive for the housing proposal.  The property owner has tried to ask the neighbors for an easement to pump sewer uphill to connect to the existing sewer main on Stonebrook Court, as an alternative to the proposed sewer main extension on Stonebrook Drive. However, the property owner could not get the neighboring properties at 12321 and 12331 Stonebrook Court to agree.

Staff Report to City Council Page 5
12251 Stonebrook Drive Sewer Main Extension Appeal
September 18, 2025
5  The Town’s Housing Element calls for removal of unnecessary governmental constraints and impediments to housing development. It also calls for the removal of unnecessary increases in housing development costs. Further, the Housing Element also states that SB 9 and ADUs would be reviewed ministerially with objective standards. Therefore, requiring a sewer main extension for full property frontage would be inconsistent with these goals and policies; the authority of the City Engineer to determine an exception is also inconsistent with the objectivity of SB 9 and ADU review.

Staff’s position is that the Town has implemented the requirements of Section 6-4. 446(1) in an objective manner because if there is one or more properties upstream that have not been connected to the Town’s sewer, the City Engineer would not grant an exception to the full frontage sewer extension requirements. If there is even one property not on sewer, granting an exception potentially means that other property owner needs to extend the sewer main further to their property frontage in the future when they decide to connect. As such, the Town implements this requirement equally for all properties in Los Altos Hills. Additionally, the Housing Element does not identify sewer connection/extension as a governmental constraint. The Town continues to receive SB 9 applications and is currently exceeding its ADU production goals identified in the Housing Element to promote housing.

The text of Section 6-4.446(1) gives the City Engineer the authority to make an exception to the frontage extension requirement where “the main is not likely to be extended to serve any other property.” In practice, the City Engineer implements this requirement by determining whether there are any parcels upstream of the subject property on septic systems that may connect to the sewer system in the future. On the other hand, if all surrounding parcels are connected to sewer, then an exception would be granted by the City Engineer since there are no other properties that may extend the main to connect.

Appeal of City Engineer’s Determination
Since there is one or more properties on Stonebrook Drive that can connect to the proposed sewer extension in the future, the City Engineer’s position is that the proposed sewer main should be installed along the full frontage of the property. On September 3, 2025, the Public Works Director/City Engineer officially denied the request to limit the sewer main extension to the point of the sewer lateral service line (Attachment 6). The City Engineer’s determination cited Municipal Code Section 6-4.446(1) as its basis because there is one or more properties on Stonebrook Drive that can connect to the proposed sewer extension in the future.

On September 8, 2025, the property owner of 12251 Stonebrook Drive, Sanjay Uppal, timely filed an appeal (Attachment 7) to the City Council of the City Engineer’s determination to require full frontage sewer main extension for the Sewer Review Application SR25-0013.

Result of Granting or Denying the Appeal
If the City Council grants the appeal, the appellant would only be required to construct the sewer extension from the existing sewer manhole located in the public right-of-way at the intersection of Stonebrook Court and Stonebrook Drive to the point of the proposed private lateral connection for 12251 Stonebrook Drive near the northeasterly corner of the property. If other surrounding

Staff Report to City Council Page 6
12251 Stonebrook Drive Sewer Main Extension Appeal
September 18, 2025
6 properties desire to connect to this sewer main extension in the future, the sewer main would need to be extended along the full frontage of 12251 Stonebrook Drive and to the full frontages of those parcels.

On the other hand, if the City Council denies the appeal, the appellant would be required to construct the sewer extension and have it cover the entire frontage of the property. This requirement would be consistent with Section 6-4.446(1) and the Town’s implementation practice of requiring all parcels to comply with the frontage extension rule unless no surrounding parcels can connect to sewer in the future.

The frontage extension obligation does represent an incremental project responsibility for the proposed SB 9/ADU development project, which is an important housing source for the Town.

Compliance with this obligation is consistent with the established municipal code, which ensures equitable treatment of all property owners. It also prevents the costs and responsibilities of future sewer extensions from being unfairly shifted onto neighboring properties. If a neighboring property were to later propose an ADU or SB 9 unit, the obligation to extend the sewer across their frontage could likewise be viewed as an additional project responsibility, thereby underscoring the importance of consistent application of this requirement. It is also correct that all properties surrounding the subject site are currently served by public sewer or private septic system.

The City Council’s decision on this appeal is separate and apart from the proposed SB 9 unit and ADU applications at 12251 Stonebrook Drive. Those applications are being concurrently reviewed and commented upon by Planning, Building, and Engineering Departments, as well as the County Fire Department for Fire Code compliance. However, it should also be noted that sewer connection or septic service is a required component of building permit issuance, and ultimately, the units cannot be occupied without approved sewer disposal service or facilities.

Authorize City Manager to Execute the Sewer Construction and Dedication Agreement Normally, construction of the sewer main extensions would be expected to commence after the final project plans are approved by the Town, the City Council approves a Sewer Construction and Dedication Agreement, and once an encroachment permit is issued for the project.

For this appeal case on the sewer main extension for 12251 Stonebrook Drive, to streamline the administrative and review process, the resolutions propose that the City Council, in conjunction with the decision on the appeal, authorize the City Manager to accept dedication of the sewer main extension and execute the Sewer Construction and Dedication Agreement on behalf of the Town once the Town has reviewed the plans to be consistent with the Council’s decision on appeal and with all other applicable Town standards. This would eliminate the need for the sewer extension to return to the Council a second time. Both resolutions include this authorization for the City Manager.

Staff Report to City Council Page 7
12251 Stonebrook Drive Sewer Main Extension Appeal
September 18, 2025
7 ENVIRONMENTAL REVIEW:

The consideration of this appeal is not subject to the California Environmental Quality Act, as it is a code interpretation issue and does not make any physical changes to the environment; therefore, it has no potential to cause significant environmental effects. 2024-2025 CITY COUNCIL WORK PLAN:

This action was not identified on the 2024 City Council Work Plan, but it supports the council priorities to “Maintain Quality of Life” and “Protect and Maintain Infrastructure.” FISCAL IMPACT:

There is no fiscal impact. The property owner has paid all the necessary deposits and fees associated with this appeal.

ATTACHMENTS

1. Resolution Granting Appeal

2. Resolution Denying Appeal

3. SR25-0013 Sewer Extension Plan

4. Los Altos Hills Sewer Map

5. July 9 and August 1, 2025 Letters from ADU Collective

6. City Engineer’s Determination- September 3, 2025

7. Appellant’s Appeal and Supporting Documents

Resolution Page 1
RESOLUTION NO.

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS

ALTOS HILLS MAKING FINDINGS AND GRANTING THE APPEAL ON

THE PARCEL FRONTAGE SEWER EXTENSION REQUIREMENT FOR
SEWER REVIEW APPLICATION NO. SR25-0013 FOR 12251
STONEBROOK DRIVE (APN: 336-28-067) AND AUTHORIZING THE

CITY MANAGER TO EXECUTE A SEWER CONSTRUCTION AND

DEDICATION AGREEMENT
WHEREAS, on April 29 and May 5, 2025, the Town of Los Altos Hills (“Town”) received a sewer extension application from Sanjay Uppal (“Applicant” or “Appellant”) for the property at 12251 Stonebrook Drive (No. SR25-0013, APN 336-28-067); and WHEREAS, Appellant is proposing to develop an SB 9 unit and an accessory dwelling unit (“ADU”) on his property located at 12251 Stonebrook Drive with an existing primary unit of 3,263 square feet and is currently served by a septic tank for sewer disposal; and WHEREAS, in conjunction with his development proposals, Appellant proposes to abandon the septic tank for his primary house and connect the existing home, along with the proposed SB 9 unit and the proposed ADU, to the Town’s sanitary sewer system; and WHEREAS, the Town’s SB 9 Ordinance (Title 10, Chapter 1, Articles 15) requires all newly created dwelling units to be connected to either the public sewer or be served by an onsite wastewater treatment system (i.e., septic tank) approved by the Santa Clara County Department of Environmental Health; and
WHEREAS, likewise, the Town’s current ADU Ordinance (Title 10, Chapter 1, Articles 14) requires ADUs constructed with a new single-family home on the same lot to be either connected to public sewer or to a septic tank system approved by the County; and WHEREAS, Section 6-4.102 of the Municipal Code requires all new residences and major additions to be connected to an approved public sewer when such sewer is within 200 feet of the property line, except when the elevation of the existing sewer main does not facilitate gravity flow and is not subject to a sewer reimbursement agreement: and WHEREAS, 12251 Stonebrook Drive property is not within 200 linear feet of the Town’s closest sewer main on Stonebrook Court, and the proposed development on the subject property is not subject to the requirements of Section 6-4.102 to connect to the Town’s sewer system; and WHEREAS, the property owner is requesting connection to the Town’s sewer system, because, according to the owner, upgrading the current septic tank system as required by the County for the proposed development would substantially reduce the buildable area and create challenges to construct and maintain three separate dwelling units on the 1.311-acre lot; and WHEREAS, the scope of work for Appellant’s proposed sewer main extension includes constructing a new eight-inch sewer main from an existing sewer manhole at the intersection of Stonebrook Court and Stonebrook Drive and terminating at a new manhole near the northeasterly ITEM 8C, ATTACHMENT 1

Resolution Page 2
property line of 12251 Stonebrook Drive where a new four-inch private sewer lateral for the property is proposed to be connected; and
WHEREAS, Section 6-4.446(1) of the Municipal Code requires that when a sewer main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer/Public Works Director that the main is not likely to be extended to serve any other property; and
WHEREAS, the City Engineer implements this requirement under Section 6-4.446(1) by determining whether there are any parcels upstream of the subject property on septic and may connect to the sewer system in the future, based on publicly available property tax roll and sewer connection permit records; and
WHEREAS, if all surrounding parcels upstream are connected to public sewer, then an exception would be granted since there are no other properties that may extend the sewer main; and
WHEREAS, On Stonebrook Drive, there are six properties (excluding the applicant property) that are not currently connected to the public sewer, which can be served by the proposed sewer main extension in the future, hence the sewer main extension for 12251 Stonebrook Drive would require extension along the full frontage of the parcel per Section 6-4.446 (1) of the Municipal Code; and
WHEREAS, Appellant has requested that the City Engineer grant an exception to the full frontage sewer main extension requirement, and allow limiting the extension to the point of the sewer lateral service line; this means that the new sewer main would only run approximately 210 linear feet from the existing sewer manhole on Stonebrook Court to a shortest distance point of the property frontage where the property sewer lateral would connected; and WHEREAS, on September 3, 2025, the Public Works Director/City Engineer officially denied the exception request via an email to limit the sewer main extension to the point of the sewer lateral service line by citing Municipal Code Section 6-4.446(1) as its basis, because there is one or more properties on Stonebrook Drive that can connect to the proposed sewer extension in the future; and
WHEREAS, Section 6-4.111 of Municipal Code provides that the City Engineer’s determination under Section 6-4.446(1), as an administrative official’s decision, may be appealed to the City Council by filing a written notice of appeal with the City Clerk within 10 days after receiving a notice of the determination accompanied by the required appeal fees; and WHEREAS, on September 8, 2025, Appellant timely appealed the City Engineer’s September 3 determination to the City Council, accompanied by the applicable appeal fees; and WHEREAS, on September 18, 2025, the City Council conducted a duly noticed public meeting to hear the appeal, considered all evidence, testimony, and records presented before it, and provided the Appellant and all interested parties with an opportunity to be heard; and WHEREAS, the consideration of this appeal is not subject to the California Environmental Quality Act, as it is a code interpretation issue and does not make any physical changes to the environment; therefore, it has no potential to cause significant environmental effects.

Resolution Page 3
NOW, THEREFORE, BE IT RESOLVED by the City Council of the Town of Los Altos Hills:

Based on the entirety of the record before it, which includes, without limitation, the Los Altos Hills Municipal Code; all reports, minutes, and public testimony submitted as part of the City Council’s duly noticed September 18, 2025 public hearing; and any and all other evidence (within the meaning of Public Resources Code §21080(e) and §21082.2), the City Council of the Town of Los Altos Hills hereby finds as follows:

1. General Findings.
a. The foregoing recitals are true and correct and made a part of this Resolution. b. The documents and other material constituting the record for these proceedings are located at the Public Works Department for the Town of Los Altos Hills, 26379 Fremont Road, Los Altos Hills, and in the custody of the Public Works Director.

2. Findings Regarding the Appeal.
a. Appellant proposes to develop an SB 9 unit and an ADU on his property located at 12251 Stonebrook Drive. The property has an existing primary unit of 3,263 square feet and is currently served by a septic tank for sewer disposal. Appellant proposes to abandon the septic tank and to connect all three existing and proposed units to the Town’s sewer system.
b. Under the Town’s SB 9 Ordinance (Title 10, Chapter 1, Articles 15) requires all newly created dwelling units to be connected to either the public sewer or be served by an onsite wastewater treatment system (i.e., septic tank) approved by the Santa Clara County Department of Environmental Health. Likewise, the Town’s current ADU Ordinance (Title 10, Chapter 1, Articles 14) requires ADUs constructed with a new single-family home on the same lot to be either connected to sewer or to a septic tank system approved by the County. Similarly, under Section 6-4.102 of the Municipal Code, new homes and major additions to homes are only required to connect to public sewer when the sewer is within 300 feet of the property line. The property lines of 12251 Stonebrook Drive are more than 200 feet away from the nearest Town sewer main line.
c. Although the Municipal Code does not require either the primary home, the SB 9 unit or the ADU to connect to sewer, Appellant states that he does not wish to have the septic tank system for this property as the requirements would substantially reduce the buildable area and create challenges for him to construct and maintain three separate dwelling units on a 1.311-acre lot. By connecting to the public sewer, Appellant claims that he would be able to maximize the buildable area on his property.
d. Appellant is correct that sewer extension for the full property frontage creates additional cost burdens on the proposed SB 9/ADU development project, both of which are important housing sources for the Town. The staff report and Appellant’s submittal notes that there would be at least an additional cost increase of $100,000 to the related development project. It also appears that utilizing the existing septic tank reduces the developable area on the lot and has the potential to constrain construction for the ADU and SB 9 units proposed, which the Town is also required to permit by state law.

Resolution Page 4
e. The property at 12251 Stonebrook Drive is located within a built-out environment, not on the outskirts of the Town, and surrounding neighboring properties are already on existing sewer and septic systems. Appellant has also explored options with neighboring properties to pump sewer upstream to connect to another existing sewer main on Stonebrook Court. It appears from the staff report that properties upstream are all either connected to sewer system or are on functioning septic systems, and there is no indication that any of those properties would require a different connection or would have a need to connect to sewer in the immediate future. While it could be said that there is the potential for upstream properties on septic to connect to sewer, the same can be equally said that all those properties have satisfactory sewer disposal services without any evidence to show the switch to sewer system is necessary.
f. The City Council notes that it disagrees with Appellant’s argument that the frontage extension requirement is inconsistent with state ADU/SB 9 law for being subjective, or that it is inconsistent with the Town’s Housing Element. It appears based on the accompanying staff report and the record that the Town has implemented the requirements of Section 6-4.446(1) in an objective manner because if there is one property upstream that has not connected to sewer, the City Engineer would not grant an exception from the frontage extension requirements.

If there is even one property not on sewer, granting an exception potentially requires that future property owner(s) carry more distance from their property frontage to the Town’s sewer main in the public right of way. As such, the Town implements this requirement equally for all properties in Los Altos Hills. Also, the Housing Element does not identify sewer connection/extension as a governmental constraint. The Town continues to receive SB 9 application and is currently exceeding its ADU production goals identified in the Housing Element. g. Notwithstanding the above, the City Council views ADUs and SB 9 units as an important housing source for the Town, and the record before the Council does contain showing that utilization of the existing septic tank on the 12251 Stonebrook Drive property creates challenges for development and reduces the ability of the property owner to develop these units. Given that the upstream properties are all properly served by some form of sewer disposal services, and there is no indication that sewer connection is necessary in the immediate future, granting an exception from the frontage extension requirement under Section 6-

4.446(1) would not be inconsistent with the text of the ordinance (i.e. unlikely to serve other properties) and is not inequitable given the circumstances of the neighboring properties and development proposal.

BE IT FURTHER RESOLVED based on the entirety of the record before it and on the foregoing facts and findings, the City Council hereby GRANTS the appeal regarding the City Engineer’s determination on parcel frontage sewer extension requirement for 12251 Stonebrook Drive, Los Altos Hills (Sewer Review Application No. SR25-0013). The City Council’s decision is limited to Sewer Application No. SR25-0013 and not a decision on any other entitlement, permit, or approval Appellant may be seeking from the Town. This decision does not reduce or relieve the Appellant from complying with all other applicable requirements in pursuing development.

BE IT FURTHER RESOLVED that the City Council authorizes the City Manager to accept and execute a Sewer Dedication Agreement, on behalf of the Town, for any subsequent dedication of the sewer main extension for 12251 Stonebrook Drive pursuant to Application No. SR25-0013 provided that the construction of said sewer main extension is (1) consistent with this Resolution;

Resolution Page 5
(2) meets all required specifications and standards and is consistent with plans approved by the Town; and (3) has been accepted by the City Engineer.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the day of September 2025, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY:

Kavita Tankha, Mayor
ATTEST:

Arika Birdsong-Miller, City Clerk

ITEM 8C Attachment 2
UPDATED 09.18.2025
RESOLUTION NO.

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS

ALTOS HILLS MAKING FINDINGS AND DENYING THE APPEAL ON

THE PARCEL FRONTAGE SEWER EXTENSION REQUIREMENT FOR
SEWER REVIEW APPLICATION NO. SR25-0013 FOR 12251
STONEBROOK DRIVE (APN: 336-28-067) AND AUTHORIZING THE

CITY MANAGER TO EXECUTE A SEWER CONSTRUCTION AND

DEDICATION AGREEMENT
WHEREAS, on April 29 and May 5, 2025, the Town of Los Altos Hills (“Town”) received a sewer extension application from Sanjay Uppal (“Applicant” or “Appellant”) for the property at 12251 Stonebrook Drive (No. SR25-0013, APN 336-28-067); and WHEREAS, Appellant is proposing to develop an SB 9 unit and an accessory dwelling unit (“ADU”) on his property located at 12251 Stonebrook Drive with an existing primary unit of 3,263 square feet and is currently served by a septic tank for sewer disposal; and WHEREAS, in conjunction with his development proposals, Appellant proposes to abandon the septic tank for his primary house and connect the existing home, along with the proposed SB 9 unit and the proposed ADU, to the Town’s sanitary sewer system; and WHEREAS, the Town’s SB 9 Ordinance (Title 10, Chapter 1, Articles 15) requires all newly created dwelling units to be connected to either the public sewer or be served by an onsite wastewater treatment system (i.e., septic tank) approved by the Santa Clara County Department of Environmental Health; and
WHEREAS, likewise, the Town’s current ADU Ordinance (Title 10, Chapter 1, Articles 14) requires ADUs constructed with a new single-family home on the same lot to be either connected to public sewer or to a septic tank system approved by the County; and WHEREAS, Section 6-4.102 of the Municipal Code requires all new residences and major additions to be connected to an approved public sewer when such sewer is within 200 feet of the property line, except when the elevation of the existing sewer main does not facilitate gravity flow and is not subject to a sewer reimbursement agreement: and WHEREAS, 12251 Stonebrook Drive property is not within 200 linear feet of the Town’s closest sewer main on Stonebrook Court, and the proposed development on the subject property is not subject to the requirements of Section 6-4.102 to connect to the Town’s sewer system; and WHEREAS, the property owner is requesting connection to the Town’s sewer system, because, according to the owner, upgrading the current septic tank system as required by the County for the proposed development would substantially reduce the buildable area and create challenges to construct and maintain three separate dwelling units on the 1.311-acre lot; and WHEREAS, the scope of work for Appellant’s proposed sewer main extension includes constructing a new eight-inch sewer main from an existing sewer manhole at the intersection of Stonebrook Court and Stonebrook Drive and terminating at a new manhole near the northeasterly

Resolution Page 2
property line of 12251 Stonebrook Drive where a new four-inch private sewer lateral for the property is proposed to be connected; and
WHEREAS, Section 6-4.446(1) of the Municipal Code requires that when a sewer main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer/Public Works Director that the main is not likely to be extended to serve any other property; and
WHEREAS, the City Engineer implements this requirement under Section 6-4.446(1) by determining whether there are any parcels upstream of the subject property on septic and may connect to the sewer system in the future, based on publicly available property tax roll and sewer connection permit records; and
WHEREAS, if all surrounding parcels upstream are connected to public sewer, then an exception would be granted since there are no other properties that may extend the sewer main; and
WHEREAS, On Stonebrook Drive, there are six properties (excluding the applicant property) that are not currently connected to the public sewer, which can be served by the proposed sewer main extension in the future, hence the sewer main extension for 12251 Stonebrook Drive would require extension along the full frontage of the parcel per Section 6-4.446 (1) of the Municipal Code; and
WHEREAS, Appellant has requested that the City Engineer grant an exception to the full frontage sewer main extension requirement, and allow limiting the extension to the point of the sewer lateral service line; this means that the new sewer main would only run approximately 210 linear feet from the existing sewer manhole on Stonebrook Court to a shortest distance point of the property frontage where the property sewer lateral would connected; and WHEREAS, on September 3, 2025, the Public Works Director/City Engineer officially denied the exception request via an email to limit the sewer main extension to the point of the sewer lateral service line by citing Municipal Code Section 6-4.446(1) as its basis, because there is one or more properties on Stonebrook Drive that can connect to the proposed sewer extension in the future; and
WHEREAS, Section 6-4.111 of Municipal Code provides that the City Engineer’s determination under Section 6-4.446(1), as an administrative official’s decision, may be appealed to the City Council by filing a written notice of appeal with the City Clerk within 10 days after receiving a notice of the determination accompanied by the required appeal fees; and WHEREAS, on September 8, 2025, Appellant timely appealed the City Engineer’s September 3 determination to the City Council, accompanied by the applicable appeal fees; and WHEREAS, on September 18, 2025, the City Council conducted a duly noticed public meeting to hear the appeal, considered all evidence, testimony, and records presented before it, and provided the Appellant and all interested parties with an opportunity to be heard; and WHEREAS, the consideration of this appeal is not subject to the California Environmental Quality Act, as it is a code interpretation issue and does not make any physical changes to the

Resolution Page 3
environment; therefore, it has no potential to cause significant environmental effects.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the Town of Los Altos Hills:

Based on the entirety of the record before it, which includes, without limitation, the Los Altos Hills Municipal Code; all reports, minutes, and public testimony submitted as part of the City Council’s duly noticed September 18, 2025 public hearing; and any and all other evidence (within the meaning of Public Resources Code §21080(e) and §21082.2), the City Council of the Town of Los Altos Hills hereby finds as follows:

1. General Findings.
a. The foregoing recitals are true and correct and made a part of this Resolution. b. The documents and other material constituting the record for these proceedings are located at the Public Works Department for the Town of Los Altos Hills, 26379 Fremont Road, Los Altos Hills, and in the custody of the Public Works Director.

2. Findings Regarding the Appeal.
a. Appellant proposes to develop an SB 9 unit and an ADU on his property located at 12251 Stonebrook Drive. The property has an existing primary unit of 3,263 square feet and is currently served by a septic tank for sewer disposal. Appellant proposes to abandon the septic tank and to connect all three existing and proposed units to the Town’s sewer system.
b. Under the Town’s SB 9 Ordinance (Title 10, Chapter 1, Articles 15) requires all newly created dwelling units to be connected to either the public sewer or be served by an onsite wastewater treatment system (i.e. septic tank) approved by the Santa Clara County Department of Environmental Health. Likewise, the Town’s current ADU Ordinance (Title 10, Chapter 1, Articles 14) requires ADUs constructed with a new single-family home on the same lot to be either connected to sewer or to a septic tank system approved by the County. c. Further, under the Town’s Sewer Ordinance under Section 6-4.102 of the Municipal Code, new homes and major additions to homes are only required to connect to public sewer when the sewer is within 200 feet of the property line, unless the elevation of the existing sewer main does not facilitate gravity flow and is not subject to a sewer reimbursement agreement. However, the property lines of 12251 Stonebrook Drive are more than 200 feet away from the nearest Town sewer main line.
d. As such, the subject parcel is not required to connect to sewer; it may be either connected to the Town’s public sewer system or utilize the existing septic tank with approval from Santa Clara County. Appellant claims that he does not wish to have the septic tank system for this property as the requirements would substantially reduce the buildable area and create challenges for him to construct and maintain three separate dwelling units on a 1.311-acre lot. However, Appellant has not provided a clear showing of how utilizing the existing septic tank would prevent three dwelling units to be located on the 1.311-acre lot. e. The Town, through its City Engineer, implements the requirement of Municipal Code Section 6-4.446(1) by determining how many properties upstream of the subject parcel is on septic and thus may connect to the sewer system in the future.

Resolution Page 4
The accompanying staff report notes that, based on property tax roll (which includes collection of sewer fees) and permit records, which are all publicly available information, the Town determines whether or not a property is connected to the public sewer. In this case, there are seven properties with frontage to Stonebrook Drive that are not connected to the public sewer.

Therefore, the proposed sewer extension at 12251 Stonebrook Drive can and would serve those other properties in the future. As such, the exception requested by Appellant is not consistent with Section 6-4.446(1) and if an exception were granted, it would not be equitable as to how other applicants were required to comply with the same standard and the upstream properties owners who have to carry additional sewer extension length at the time of a proposed connection. f. Appellant also raises several arguments on appeal, as noted in more detail in the accompanying staff report, that the frontage extension requirement violates state ADU and SB 9 laws because it is a subjective standard, creates cost prohibitive burdens, and is inconsistent with the Town’s Housing Element. The City Council is not persuaded by those arguments. It appears based on the accompanying staff report and the record that the Town has implemented the requirements of Section 6-4. 446(1) in an objective manner because if there is one property upstream that has not connected to sewer, the City Engineer would not grant an exception from the frontage extension requirements. If there is even one property not on sewer, granting an exception potentially requires that future property owner(s) carry more distance from their property frontage to the Town’s sewer main in the public right of way. As such, the Town implements this requirement equally for all properties in Los Altos Hills. As mentioned above, Appellant has not demonstrated that this standard, applicable to all other property owners in Town, would be prohibitive to development on a 1.311-acre lot. Finally, the Housing Element does not identify sewer connection/extension as a governmental constraint. The Town continues to receive SB 9 applications and is currently exceeding its ADU production goals identified in the Housing Element to promote housing.

BE IT FURTHER RESOLVED based on the entirety of the record before it and on the foregoing facts and findings, the City Council hereby DENIES the appeal regarding the City Engineer’s determination on parcel frontage sewer extension requirement for 12251 Stonebrook Drive, Los Altos Hills (Sewer Review Application No. SR25-0013). The City Council’s decision is limited to Sewer Application No. SR25-0013 and not a decision on any other entitlement, permit, or approval Appellant may be seeking from the Town. This decision does not reduce or relieve the Appellant from complying with all other applicable requirements in pursuing development.

BE IT FURTHER RESOLVED that the City Council authorizes the City Manager to accept, and execute a Sewer Dedication Agreement, on behalf of the Town, for any subsequent dedication of the sewer main extension for 12251 Stonebrook Drive pursuant to Application No. SR25-0013 provided that the construction of said sewer main extension is (1) consistent with this Resolution; (2) meets all required specifications and standards and is consistent with plans approved by the Town; and (3) has been accepted by the City Engineer.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the day of September 2025, by the following vote:

Resolution Page 5
AYES:

NOES:

ABSTAIN:

ABSENT:

BY:

Kavita Tankha, Mayor
ATTEST:

Arika Birdsong-Miller, City Clerk

ITEM 8C, ATTACHMENT 3

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' ''
579.5' 0''
471.5' 0''
351' 6'' VCP
433.8' 0''
406.4' 0''
331' 8'' AC
266' 0''
303' 8'' PE
270.8' 0''
319' 6'' VCP
332' 6'' AC
354' 6'' VCP
233.7' 0''
191.5' 0''
246' 6'' VCP
178.7' 0''
205.2' 0''
184.1' 0''
263' 8'' PVC
166' 8'' PE
172.9' 0''
156.6' 0''
142.2' 0''
135' 6'' VCP
201' 6'' VCP
520' 0''
68' 0''
173' 6'' VCP
70' 6'' VCP
70' 8'' PE
139' 8'' PVC
78' 6'' VCP
354' 6'' VCP
PMH1118
PMH1117
LCO1003
LMH1148 LMH1147
LMH1145
LMH1141
LMH1137 LMH1138LMH1139 LMH1136
LMH1134 LMH1133 LMH1132
LMH1131 LMH1130
LMH1129
LMH1128
LMH1127
LMH1126
LMH1125
LMH1124
LMH1123
LMH1122
LMH1120
LMH1119
LMH1118
LMH1117
LMH1116
LMH1115
LMH1114
LMH1113
LMH1112 LMH1111
LMH1110
LMH1109
LMH1108
LMH1107
LCO1002
LCO1001
KMH1124
KMH1122
12335
12355
12400
12365
12237
12215
25070
12241
12200
25426
12150
12331
12251
25310
12352
12231
12380
12341
12356
12175
12388
12250
12354
25463
25431
25449
25440
12321
12384
12366
12364
25000
12386
12360
12362
12387
12020
12370
24925
12451
12359
25466
25045
25020
12100
12113
12305
12000
12358
24940
12368
25484
25445
12211
25051
24965
24931
24985
11600
25005
12155
12109
25487
12378
25342
24911
24875
25325
12145
12117
12372
24821
12105
25090
12120
24737
25508
12376
El Monte
280
Ramp
Oneonta
Moody
Stonebrook
Ramp
280
Ramp
Ramp
304' 8'' PE
246' 8'' PVC
182' 6'' AC
150.1' 0''
78' 8'' PE

83.7' 0''
28' 4'' VCP

64.1' 0''
79' 6'' VCP
107' 6'' VCP
105' 6'' VCP
65' 8'' PVC

63.6' 8'' PVC
90' 8'' AC
290' 6'' AC
252' 6'' PVC
70' 6'' VCP
PMH1075
LMH1146
LMH1144
LMH1142
LMH1140
LMH1121
Priscilla
Elena
Adobe
Summit Wood
Edgecliff
Tepa
Source: Esri, Maxar, Earthstar Geographics, and the GIS User Community 0 100 200 300 400
Feet Town of Los Altos Hills Sanitary Sewer System
1 inch = 254 feet 1:3,047
K4
P1
L4 L3
Legend
!2! MANHOLE
$1 CLEANOUT

JUNCTION
Ú[ PUMPSTA
Owner, (Pipe Type)
Town of Los Altos Hills
(Gravity)
Town of Los Altos Hills
(Force Main)
Private (Gravity)
Private (Force Main)
City of Los Altos
City of Palo Alto
Future (?)
I L1
ITEM 8C, ATTACHMENT 4

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!2!
789.8' 0''
266' 0''
322' 6'' VCP
300' 8'' PVC
304' 6'' VCP
286' 8'' PVC
197' 6'' VCP
215' 8'' PVC
227' 6'' VCP
186' 8'' PVC
230' 6'' VCP
166' 8'' PE
117' 6'' VCP
191' 8'' PVC
252' 6'' PVC
194' 8'' PVC
201' 6'' VCP
58' 6'' PVC
194' 6'' VCP
224' 6'' PVC
49' 6'' VCP
140' 6'' VCP
86' 6'' VCP
96' 6'' PVC
187' 6'' VCP
73' 8'' PVC
88' 6'' VCP
99' 6'' VCP
86' 8'' PVC
53' 6'' PVC
96' 6'' VCP
224' 6'' PVC
PMH1173
PMH1171
PMH1170
PMH1169
PMH1168
PMH1167
PMH1166
PMH1165
PMH1164
PMH1120 PMH1118
PMH1117
PMH1105
PMH1103
PMH1099
PMH1098
PMH1095
PMH1094
PMH1092
PMH1091 PMH1089
PMH1088
PMH1084
PMH1083
PMH1081 PMH1082
PMH1080
PMH1079
PMH1078
PMH1077
PMH1076
PMH1073
LMH1145
LMH1120
PMH1177
KFM1007 24840
12335
24008
24680
12012
12160
25947
12051
24005
12237
12215
12000
24910
24719
24012
12119
25398
24960
24018
12241
12101
25396
12200
25394
25071 24052
24920
12231
24801
24930
25051
25955
25386
25426
25010
12150
12009
12002
24001
24004
12211
24785
12251
24000
24990
12100
12105
25005
25362
12180
24048
24965
12060
12356
12175
12107
12250
12109
12001
12080
12008
12354
12120
12358
24755
24855
25440
24025
25431
24900
25041
12366
24875
12020
12364
12145
24905
24911
12005
24737
12360
12117
12155
12368
12362
25400
12113
24821
24021
12372
24915
25031
28000
24931
24941
12167
12121
25070
12087
28008
25346
25111
24009
25466
12187
25090
24020
12370
25026
12374
12331
25100
12352 12386
12067
25091
12365
12341
25449
25055
24015
Kate
Sto
n
e
broo
k
L
a
L
o
m
a
Oak Knoll
Finn
Emerald Hill
295' 6'' VCP
325.4' 6'' VCP 256' 6'' VCP 255' 6'' VCP
151' 6'' VCP
249' 6'' PVC
142' 6'' VCP
110' 6'' PVC
209' 8'' PVC
80' 6'' VCP 111' 6'' VCP
182 319' 6'' VCP
' 6'' AC
205.2' 0''
122' 6'' VCP
208' 8'' PVC
157' 6'' PE
104' 6'' VCP
68' 6'' VCP
55' 6'' VCP
85' 8'' PVC 161' 8'' PVC
52' 6'' VCP PMH1096
PMH1172
PMH1119
PMH1107 PMH1106
PMH1102
PMH1101
PMH1100
PMH1097
PMH1175
PMH1093
PMH1087
PMH1086
PMH1085
PMH1075
PMH1064
PMH1176
Prospect
E
d
g
e
cliff
Teresa
Priscilla
Adobe
Oak Park
ummit Wood
Source: Esri, Maxar, Earthstar Geographics, and the GIS User Community 0 100 200 300 40
F
0 eet Town of Los Altos Hills Sanitary Sewer System
1 inch = 254 feet 1:3,047
O2
P3
P2 P1
Legend
!2! MANHOLE
$1 CLEANOUT

JUNCTION
Ú[ PUMPSTA
Owner, (Pipe Type)
Town of Los Altos Hills
(Gravity)
Town of Los Altos Hills
(Force Main)
Private (Gravity)
Private (Force Main)
City of Los Altos
City of Palo Alto
Future (?)
I L3

ITEM 8C, ATTACHMENT 5

1 Daniel Liang
From: WooJae Kim
Sent: Wednesday, September 3, 2025 4:07 PM
To: sanjay uppal
Cc: Kavita Tankha; Peter Pirnejad; Arika Miller; Daniel Liang; Melissa Elian-Carrillo Subject: RE: update on ADU/SB9 project at my property
Hi Sanjay,
As we discussed today, I, as the Public Works Director/City Engineer, can only apply the Town policies in place.

Your sewer main extension request for 12251 Stonebrook Drive to limit the extension only to the point of the sewer lateral service line does not comply with the following Town’s Sewer Ordinance:
§ 6-4.446(1)Parcel frontage extension for sewer mains.

Where a main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer that the main is not likely to be extended to serve any other property.
(§ 1, Ord. 440, eff. October 15, 2005)
Since there is one or more properties on Stonebrook Drive that can connect to the proposed sewer extension in the future, the sewer main has to be installed along the full frontage of your property on Stonebrook Drive if you choose to connect to the Town's sanitary sewer.

If you wish to appeal this decision per the following Sewer Ordinance Section 6-4.111, please submit an appeal in writing to Arika Miller, the City Clerk ([email protected]). § 6-4.111Appeals.

Any person aggrieved by a determination of any administrative official may appeal such determination to the Council by filing a written notice of appeal with the City Clerk within 10 days after receiving a notice of the determination of the administrative official. There shall be paid a nonrefundable filing fee for each such appeal, and, in addition thereto, there shall be paid a deposit for services. The City Clerk shall put the matter on the next open agenda for a hearing at a regularly scheduled Council meeting. The amounts of the filing fee and deposit shall be set by resolution.

Here is the Engineering Fee Schedule for the sewer appeal fee and deposit (highlighted below) that needs to be collected with the appeal:

ITEM 8C, ATTACHMENT 6

2 Please feel free to reach out to me if you have any questions. Thank you.

WooJae
From: sanjay uppal <[email protected]>
Sent: Tuesday, August 26, 2025 5:45 PM
To: WooJae Kim <[email protected]>
Cc: Kavita Tankha <[email protected]>; Peter Pirnejad <[email protected]> Subject: Re: update on ADU/SB9 project at my property
Hi Woo Jae,
I understand per the message from Cody that the sewer application was discussed last week. I have not heard an update yet and have paid the addl $15K deposit per the email from Marco.

This is the last puzzle piece and we'd like to get moving on the project - would appreciate a n update. Also happy to talk on the phone if that helps.
thx,
Sanjay
6508239900
On Tue, Aug 26, 2025 at 10:34 AM Peter Pirnejad <[email protected]> wrote:

Thanks for your email Sanjay.

I am adding WooJae Kim, our public works director who would be most appropriate to answer your questions
Peter Pirnejad, ICMA-CM
City Manager

TOWN OF LOS ALTOS HILLS
26379 Fremont Road
Los Altos Hills, CA 94022
Phone: (650) 941-7222
Fax: (650) 941-3160
www.losaltoshills.ca.gov
Application for Appeal

1. APPELLANT INFORMATION: ** Please print or type. **
Name: Sanjay Uppal Affiliation with decision being appealed:Homeowner Appellant’s Mailing Address:12251 Stonebrook Drive, Los Altos Hills, CA 94022 Home Phone: Mobile Phone: Email Address:

Representative’s Name (if applicable): Phone: Email Address:

Representative’s Mailing Address:

2. APPEALING DECISION OF:

X
Planning
Commission
Planning
Director
Public Works
Director
Regarding (address of project): 12251 Stonebrook Drive, Los Altos Hills, CA 94022 Date Decision was Made: Sep 3, 2025
Please attach a formal letter informing the Planning Commission or City Council of your request, any relevant research you may have, and the action you would like to be taken.

3. FEES AND DEPOSITS:

Fees and deposits, payable to the Town of Los Altos Hills, are required to process all applications.

Fee: $ 900.00 Receipt #:

Deposit: $2,000.00 File #:

Total: $2,900.00 Payment Date:

4. SIGNATURE OF APPELLANT(S) OR AGENT:
(Please Note: Agent requires letter of authorization from appellant.) I, the undersigned petitioner or authorized agent, hereby make an application for the purposes set forth above in accordance with the provisions of the City Ordinances, and I hereby certify that the information given is true and correct and to the best of my Sewer Appeal Filing Fee - $585.00
Sewer Appeal Deposit ($875) already collecting through SR25-0013.

Sewer Review Application - SR25-0013
ITEM 8C, ATTACHMENT 7

September 8, 2025
Regarding: Sewer Extension at 12251 Stonebrook Drive, Los Altos Hills (LAH File #SR25-0013) Dear City Council,
Thank you for your time and attention to this matter. On May 14, 2025, I applied for a construction permit to build one ADU and one SB 9 unit at my property at 12251 Stonebrook. We also applied for a connection to the City’s municipal sewer system. Since that time, my project team and its land use counsel have been trying to resolve a disagreement with the Town’s Public Works Director regarding the extent of sewer extensions. In connection with my project, the Town has requested (pursuant to Municipal Code Section 6-4.446(1)) a sewer extension. Extending the municipal system to my property is amenable, and will cost approximately $140,000. However, the Town is requiring that we further extend the sewer system along the entire front of our property (i.e., beyond the point of connection) which will cost an estimated additional $100,000 to the project.

My permit expediter (Jessica Resmini of ADU Collective) wrote the town on July 9th (see attached), apprising the Town that this extra requirement violates state housing laws (mainly, ADU and SB 9). Also, requiring an applicant to improve a municipal sewer system above and beyond what is required for the project violates state constitutional protections (nexus and rough proportionality).

While a longer-term solution would be for the Town amend its Ordinance to make clear that the entire frontage expansions are not applicable to ADU and SB 9 projects, a near-term solution is as follows:
- Condition the Town’s approval of my construction permits on future compliance “with the Town’s sewer requirements, as applicable” (this will allow us to break ground on construction before the dig moratorium resumes in October).
- Direct an administrative exemption, which is allowed per Municipal Code Section 6-4.446(1) whenever a main extension is not likely to serve further properties. Here: neighboring properties are already on existing sewer and septic systems. The Public Work’s Director has determined that because he has made others in the past extend the full distance along their property line, he would need to make the same consistent determination again, but has kindly advised me to appeal to the City Council to review. This is the very reason the state has put current housing laws in place to prevent unnecessary barriers and additional burden to the creation of housing.

Below are bullet points of the state housing laws that support such a determination. We would ask that you carefully look into this matter.

Thank you,
(signed)
Sanjay Uppal

PLANCHECK COMMENT
Please extend the 8-inch sewer main to the full frontage of the parcel per Municipal Code, Section 6-4.446(1). § 6-4.446(1) Parcel frontage extension for sewer main.

Where a main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer that the main is not likely to be extended to serve any other property.

COST
First extension: $140,000 for the 200 linear foot sewer extension Extra 190 linear feet of sewer main: $100,000.

DISCUSSION
Full extension along the entire front of the property:

1. conflicts with state housing laws and Creates Barriers;

2. is inconsistent with the City’s municipal code and requires Subjective Review;

3. contradicts the City’s latest 6th Cycle Housing Element to review and Reduce Burdens.

1. State ADU, SB9 and Housing Laws
Gov. Code § 66324 (d), (e) states, “a local agency, special district, or water corporation may require a new or separate utility connection directly between the accessory dwelling unit and the utility.” ● The preparation, adoption, amendment, and implementation of local ordinances shall not unduly restrict the creation of ADUs and SB9 units.
● Gov. Code § 66311 states, “It is the intent of the Legislature that an accessory dwelling unit ordinance adopted by a local agency has the effect of providing for the creation of accessory dwelling units and that provisions in this ordinance relating to matters including unit size, parking, fees, and other requirements, are not so arbitrary, excessive, or burdensome so as to unreasonably restrict the ability of homeowners to create accessory dwelling units in zones in which they are authorized by local ordinance.” (Emphasis added.)
● Capital expenditures that should be borne by the Town or by all ratepayers to a particular homeowner is considered an excessive burden.

2. Municipal Code Section to Serve Other Properties
“Where a main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer that the main is not likely to be extended to serve any other property.” ● Rely on the personal or subjective judgment of a single public official. Gov. Code § 66313 (i) states “Objective standards” are, instead, those “that involve no personal or subjective judgment by a public official and are uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official prior to submittal.” Giving unilateral and sole authority to the City Engineer — without reference to any such “objective standards” – to determine when and when not to extend a sewer main to another property the entirety of that municipal code section inapplicable to SB9 and ADU housing proposals. ● In the case of 12251 Stonebrook Drive, however, the neighboring properties are already on existing sewer and septic systems. Requiring a sewer main extension for “indeterminate, future” use would be subjective, wasteful and cost prohibitive.
● When we met with the acting City Engineer, he suggested asking the neighbors for an easement or pumping sewer uphill and going through another neighbor's property. The purpose of public roads and right of ways is to contain such utilities and services. It would be unwise for any neighbor to grant an easement or for the homeowner to pump sewer uphill.
● California’s legislative enactments protect ADU and SB 9 projects from exactly this kind of subjective review process. These state laws are in place to allow “direct” connection for new housing to public utilities.

3. Los Altos Hills Housing Element

The City adopted its Housing Element for the Sixth RHNA Cycle in January, 2023, and HCD certified it on May 30th, 2023. The Housing Element includes goals, policies and programs to meet the Town’s housing needs. On

constraints to the development, improvement, and maintenance of housing where feasible and legally permissible.” (Emphasis added.) To help to achieve such a goal, the Town established both of the following:“ Policy 2.1: Review Town policies and regulations on a regular basis to ensure that the regulations, the process, and the fees do not lead to unnecessary impediments to housing development nor unnecessary increases in housing development costs…

July 9, 2025
Mr. Peter Pirnejad
Town of Los Altos Hills’ City Manager
26379 Fremont Road, Los Altos Hills, CA 94022
(650) 941-7222 | [email protected]
Regarding: Sewer Extension at 12251 Stonebrook Drive, Los Altos Hills (LAH File #SR25-0013) Dear Mr. Pirnejad,
This letter concerns a proposed project at 12251 Stonebrook Drive, Los Altos Hills. The project includes a new 850 sq. ft. detached ADU and a new 900 detached SB9 Unit. The existing single family dwelling is 3,263 sq. ft. and has a septic system that cannot be expanded to support the two new units. Sanjay Uppal, the homeowner, has applied for a main sewer extension (application number: LAH File #SR25-0013) to (i) abandon the current septic system and (ii) connect to the Town’s sewer system. The extension would begin from the corner of Stonebrook Court and Stonebrook Drive and run south on Stonebrook Drive for approximately 200 feet to the northeast corner of the property; there it would attach to a new sewer lateral.

A plan check comment was received on May 12th, 2025 for the proposed main sewer line extension stating, “(1)(a)Please extend the 8-inch sewer main to the full frontage of the parcel per Municipal Code, Section 6-4.446(1).” That section of the municipal code reads:
§ 6-4.446(1) Parcel frontage extension for sewer main.

Where a main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer that the main is not likely to be extended to serve any other property.

The homeowner received an estimate of $140,000 for the 200 linear foot sewer extension to the northeast corner of the property. Further extending the main sewer line from the northeast corner of the parcel to the southeast corner (a) would require an extra 190 linear feet of sewer main and (b) would increase the cost by approximately $100,000. This represents a substantial percentage of the entire project cost, and such an increase may render the project financially infeasible.

Further, we believe requiring an extension to the sewer main along the entire front of the property:

1. conflicts with state housing laws (e.g., ADU, SB9);

2. is inconsistent with the City’s municipal code, because such an extension is unlikely to be used by the surrounding properties; and

3. contradicts the City’s latest 6th Cycle Housing Element.

RE: Sewer Extension at 12251 Stonebrook Drive, Los Altos Hills (LAH File #SR25-0013)

1. State ADU, SB9 and Housing Laws
California’s ADU and SB 9 laws are intended to address barriers, streamline approvals, and expand our state’s capacity for housing. The preparation, adoption, amendment, and implementation of local ordinances shall not unduly restrict the creation of ADUs and SB9 units. Requiring an additional extension of the sewer main for this project — at a six-figure cost — conflicts with multiple state laws by unnecessarily burdening the creation of new housing, especially the types of smaller housing the state has sought and the Town has promised in the Housing Element. State law allows a local jurisdiction to require sewer connections, but mandatory connections must be “directly” related to the project at hand, without additional extensions, burden or subjective judgement by a single public official.

Gov. Code § 66324 (d), (e) states, “a local agency, special district, or water corporation may require a new or separate utility connection directly between the accessory dwelling unit and the utility.” Gov. Code § 66311 states, “It is the intent of the Legislature that an accessory dwelling unit ordinance adopted by a local agency has the effect of providing for the creation of accessory dwelling units and that provisions in this ordinance relating to matters including unit size, parking, fees, and other requirements, are not so arbitrary, excessive, or burdensome so as to unreasonably restrict the ability of homeowners to create accessory dwelling units in zones in which they are authorized by local ordinance.” (Emphasis added.) In this project, the additional sewer main extension being demanded is not only unreasonable, but it would effectively make this project financially infeasible. A city's sewer main is essential infrastructure, often constructed and paid for by a local agency, such as Los Altos Hills. Asking an individual homeowner who is building an ADU and an SB 9 project is effectively shifting the capital expenditures that should be borne by the Town or by all ratepayers to a particular homeowner. This type of project belongs in the sewer utility’s capital budget or a town-wide capital improvement plan. Service fees typically go into city-wide aggregate planning. Placing a portion of the Town’s own responsibility on the back of SB9 and ADU housing projects would be beyond “Reasonable Restrictions” and unreasonably increase the cost of badly needed housing. The spirit of these housing laws is to produce and deploy housing, especially for these small units to be approved ministerially and without undue burden.

Further, the Municipal Code section referenced above would rely on the personal or subjective judgment of a single public official. Gov. Code § 66313 (i) states “Objective standards” are, instead, those “that involve no personal or subjective judgment by a public official and are uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official prior to submittal.” Giving unilateral and sole authority to the City Engineer — without reference to any such “objective standards” – to determine when and when not to extend a sewer main to another property the entirety of that municipal code section inapplicable to SB9 and ADU housing proposals.

2. Municipal Code Section to Serve Other Properties
As discussed above, the critical plan check comment refers the homeowner to Municipal Code, Section 6-4.446 (1), which reads: “Where a main is to be extended to serve a parcel, said main shall extend the full frontage of said parcel unless it is determined by the City Engineer that the main is not likely to be extended to serve any other property.”
The property at 12251 Stonebrook Drive is not on the outskirts of the Town, but rather in the middle of a built-out subdivision. This municipal code section, when written, was likely intended for a property being newly developed RE: Sewer Extension at 12251 Stonebrook Drive, Los Altos Hills (LAH File #SR25-0013)

adjacent to empty lots not otherwise having infrastructure or services. In the case of 12251 Stonebrook Drive, however, the neighboring properties are already on existing sewer and septic systems. Requiring a sewer main extension for “indeterminate, future” use would be subjective, wasteful and cost prohibitive.

When we met with the acting City Engineer, he suggested asking the neighbors for an easement or pumping sewer uphill and going through another neighbor's property. The purpose of public roads and right of ways is to contain such utilities and services. It would be unwise for any neighbor to grant an easement or for the homeowner to pump sewer uphill.

California’s legislative enactments protect ADU and SB 9 projects from exactly this kind of subjective review process. These state laws are in place to allow “direct” connection for new housing to public utilities.

3. Los Altos Hills Housing Element
The City adopted its Housing Element for the Sixth RHNA Cycle in January, 2023, and HCD certified it on May 30th, 2023. The Housing Element includes goals, policies and programs to meet the Town’s housing needs. On

constraints to the development, improvement, and maintenance of housing where feasible and legally permissible.” (Emphasis added.) To help to achieve such a goal, the Town established both of the following:“ Policy 2.1: Review Town policies and regulations on a regular basis to ensure that the regulations, the process, and the fees do not lead to unnecessary impediments to housing development nor unnecessary increases in housing development costs…
Policy 2.5: Establish objective design standards to facilitate streamlined project permitting. (Page 205, emphasis added.)
Specifically addressing SB9 Units, item (i) on page 145 states, “All newly created dwelling units shall be connected to public sewer or provide a private wastewater system that is fully contained within the parcel boundaries.” Contrary to the plan check comment identified above, this portion of the Housing Element does not state that additional, burdensome, and unnecessary sewer main upgrades shall be imposed on homeowners seeking to provide the variety of housing sought by the state and promised by the Town. An engineering requirement to extend the sewer main that “might” possibly be used at some indeterminate time in the future works directly against the objective to facilitate and streamline the production of housing. Further, as applied to ADU and SB 9 projects, this requirement may run directly in conflict with the programs and policies of the Housing Element itself. Per Housing Element Law, HCD “shall review any action or failure to act by [the City] that it determines is inconsistent with an adopted housing element…, including any failure to implement any program actions included in the housing element….” (Gov. Code, § 65585(i)(1)(A).) Similarly, at page 146, the Housing Element states, “All SB 9 dwelling units and subdivisions are reviewed and approved without discretionary review or a public hearing and must meet the objective design requirements set forth in Article 15.” Any sewer main extension for this project shall be ministerially reviewed with objective standards. The subjective language of Municipal Code Section 6-4.446(1) does not satisfy these requirements for ministerial review of SB 9 projects (or similar requirements for ADU projects). Gov. Code Section 66313(i) “Objective standards” means standards that involve no personal or subjective judgment by a public official and are uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official prior to submittal.

RE: Sewer Extension at 12251 Stonebrook Drive, Los Altos Hills (LAH File #SR25-0013)

The “unless it is determined by the City Engineer that the main is not likely to be extended to serve any other property” portion of the City’s requirement is inherently subjective and cannot apply it to ADU and SB 9 Projects.

Conclusion
The request in the plan check comment to extend the sewer main along the front of 12251 Stonebrook Drive at an additional cost estimated at $100,000 goes against the commitments the Town of Los Altos Hills has made in its Housing Element. It also conflicts with multiple state guidelines. The extension is unlikely to be used by the surrounding properties. A reasonable person is left concluding that the entire frontage requirement does not and should not apply to this project. Accordingly, the plan check comment should be withdrawn.

Thank you,
Jessica Resmini
Architect, LEED AP
Resmini Architects, Inc | ADU Collective
PO Box 1394, Palo Alto, CA 94302
415.823.3213
cc:

WooJae Kim, Public Works Director, [email protected] Daniele Liang, Utility Engineer Manager, [email protected] RE: Sewer Extension at 12251 Stonebrook Drive, Los Altos Hills (LAH File #SR25-0013)

August 1st, 2025
Mr. Peter Pirnejad
Town of Los Altos Hills’ City Manager
26379 Fremont Road, Los Altos Hills, CA 94022
(650) 941-7222 | [email protected]
Regarding: Sewer Extension at 12251 Stonebrook Drive, Los Altos Hills (LAH File #SR25-0013) Dear Mr. Pirnejad,
This letter concerns a proposed project at 12251 Stonebrook Drive, Los Altos Hills. The project includes a new 850 sq. ft. detached ADU and a new 900 detached SB9 Unit. The existing single family dwelling is 3,263 sq. ft. and has a septic system that cannot be expanded to support the two new units. Sanjay Uppal, the homeowner, has applied for a main sewer extension (application number:

LAH File #SR25-0013) to (i) abandon the current septic system and (ii) connect to the Town’s sewer system. The extension would begin from the corner of Stonebrook Court and Stonebrook Drive and run south on Stonebrook Drive for approximately 200 feet to the northeast corner of the property; there it would attach to a new sewer lateral.

On July 29th, 2025 while considering the application for a direct connection to the City Sewer system, the town of Los Altos Hills inquired why the project would not simply remain on a septic system rather than hook up to the City Sewer infrastructure. During the initial feasibility studies in January of 2025 in consultation with Lea & Braze Engineering, ADU Collective Architects and the contractor Tecobuild, it was determined that the proposed project would be best served by sewer connection rather than septic.

Septic system sizing in Los Altos Hills is dictated by county and local requirements, which mandate that any parcel accommodate the entire dispersal field as well as a full reserve area of equal size. For a property with seven bedrooms, projected wastewater generation (1,050–1,200 gallons per day per prevailing code) necessitates a dispersal (leach) field between approximately 1,000 and 1,600 square feet or more. Most local soils require the higher end of this range and, with reserve requirements, this effectively doubles the total required area for subsurface disposal. An estimate for the total leach line length is 1,200 square feet ÷ 3 feet = 400 linear feet of trench plus area for full reserve would be 800 linear feet of trench.

In practical application, after accounting for setbacks from property lines, structures and slopes the usable buildable area is significantly reduced. Multiple housing units further complicate system design, as separation distances must be strictly maintained. When the required field and reserve areas are superimposed on a 1.311 acre lot, the cumulative system footprint plus regulatory setbacks surpass the available usable land, leaving insufficient space for compliant septic installation.

While theoretical sizing for 7 bedrooms can sometimes fit on larger, more regularly-shaped parcels, the constraints imposed by setbacks and the need for completely undisturbed reserve land make it unfeasible on a 1.311 acre lot, especially for three separate dwelling units.

This conclusion is consistent with both engineering practice and preliminary site planning under the Town’s septic system policies and Santa Clara County’s Onsite Systems Manual.

Given these technical and regulatory barriers, I respectfully request the Town’s acknowledgment that a compliant septic solution is not achievable for this site configuration and capacity. Thank you for your consideration.

Thank you,
Jessica Resmini
Architect, LEED AP
Resmini Architects, Inc | ADU Collective
PO Box 1394, Palo Alto, CA 94302
415.823.3213

From: allan epstein
To: Arika Miller
Subject: Agenda Item 8C: APPEAL FROM THE PROPERTY OWNER OF 12251 STONEBROOK DRIVE (APN: 336-28-067) OF THE CITY ENGINEER"S DETERMINATION ON THE PARCEL FRONTAGE SEWER EXTENSION REQUIREMENT Date: Wednesday, September 17, 2025 5:00:55 PM
Hi Arika,
Please add these comments to the September 18, 2025 Regular Council Meeting Agenda, Thank you,
Best,
Allan
Agenda Item 8C: APPEAL FROM THE PROPERTY OWNER OF 12251 STONEBROOK DRIVE (APN: 336-28-067) OF THE CITY ENGINEER’S DETERMINATION ON THE PARCEL FRONTAGE

SEWER EXTENSION REQUIREMENT
Town should deny appeal for the following reasons:

1. Property is not within 200 feet of an existing sewer main and is not required to connect to the sewer system. The applicant wants to connect to the Sewer system to maximize development area.

2. The Sewer Ordinance requires extension along the full frontage of the property, unless the sewer main will not serve other properties. There are seven additional properties on Stonebrook Drive that are on septic systems and may benefit from the sewer extension.

3. The applicant’s appeal arguments are incorrect. There is no subjective judgement required by the City Engineer for this property. The ordinance requires the main to extend the length of the property when there are other properties on septic nearby that would be served by this main. Exemption only applies if there are no properties that could benefit, e.g. if the applicant was the last house on the street.

4. This has been the policy for the past 20 years. The Town does not build sewer mains, residents do. In part, as a result of this policy, sewer lines have been continuously extended all over Town. Since we built the sewer main on Ravensbury Avenue, the main has been extended to serve another eight homes, and enabled sewer main extensions on Old Ranch Road and Camino Hermosa providing services to more than a dozen additional homes.

5. Providing an exemption in this case would be a bad precedent and would transfer the expense of building the main past the applicant’s property to his neighbors,

6. The ADU Collective claims extending the main past the full length of the applicant’s frontage would increase the cost $100,000. The Collective fails to recognize the savings the applicant would enjoy by not building a septic system and the financial benefit of the additional development area provided by not having to use land to build the septic system. Considering construction and permitting costs in this area, it is unlikely that this “additional” expense will significantly change the financial feasibility of this project.

ITEM 8C, Supplement 1

Los Altos Hills
Fire Mitigation Plan

CITY COUNCIL
SEPTEMBER 18, 2025

BACKGROUND
• During the FHSZ map ordinance adoption on June 20, 2025, the City Council directed staff to evaluate options for town-wide mitigation measures in coordination with the Emergency Preparedness and Response Committee (EPRC), with an emphasis on community-wide strategies rather than individual property measures. • Staff subsequently met with the EPRC on August 5 and September 2 to review potential approaches.
• Note: Fire Hazard Severity Zones (FHSZ) were formally adopted on June 24, 2025, and became effective on July 24, 2025.
2

PROJECT TIMELINE
3 Phase 1
June/July
Phase 2
August &
September
Phase 4
October &
November
Phase 3
September
EPRC
Subcommittee
Research and
report
EPRC
Committee
Report, gather
feedback
Council
Check-in
on direction
Continued
collaboration/
Research/
Reporting
Final
Report
Phase 5
TBD

CURRENT WILDFIRE MITIGATION RESOURCES
• Community Wildfire Protection Plan
• A regionally coordinating document for wildfire mitigation projects, Anex 4 Applies to LAH.
• Weed Abatement and Defensible Space Requirements
• Minimum Fire Safety Standards, is mandatory for all property owners in the Los Altos Hills County Fire District.
• SCCFD Weed Abatement Service : Santa Clara County Weed Abatement Services for hazard weed abatement
4

MITIGATION STRATEGIES
• Community Programs Sponsored by State Agencies and Non-Profits • Local Building Code Amendments
• Structural Harding
• New Construction
• Existing Construction
• Defensible Space – Vegetation Management (Private Property) • Zone 1: Immediate zone, 0–5 feet around structures
• Zone 2: Intermediate zone, 5–30 feet from structures
• Zone 3: Extended zone, 30–100 feet (and beyond, where applicable) • Conservation, Open Space, and Other Property Encumbrances 5

COMMUNITY

PROGRAMS
Programs Mitigation Approach Impact on Owners
Cost to
Owners Applicability
Safer from
Wildfires
State Regulation: Structure +
yard + community actions
Mandatory insurance
discounts for compliant
owners
Contractor
costs or DIY for
upgrades (no
certification
fee)
Statewide CA
Wildfire
Prepared Home
(IBHS)
Parcel-level certification (base
or plus level)
Proof of reduced risk; may
improve insurability or
rates
Application fee
+ upgrade cost
Voluntary; CA and
OR mainly
Firewise USA® Community organization,
planning, mitigation actions
Enhanced community
resilience, possible
insurance credits
Low (volunteer
time, small
event costs)
Nation-wide; local
neighborhoods
Fire Risk
Reduction
Community
(FRRC)
City/county level planning, code
enforcement, defensible space
Insurers consider
designation in pricing;
access to state grants
Indirect –
homeowner
might benefit
via city
programs
Eligible CA
municipalities only
Saratoga has
adopted

TOWN SPECIFIC POLICY UPDATES
7 Topic Area Current Code Regulation Considerations for Fire-Safe Modifications Tree Ordinances Tree preservation ordinances prevent limbing up trees, limiting ability to create defensible space.

Review ordinances to allow limbing up and removal of
flammable vegetation near structures. Balance with
environmental priorities.

Fence
Regulations
Fences may be restricted in placement close to homes or on certain property lines. Materials not always fireresistant.

Permit fire-safe fences close to structures. Allow use of ignition-resistant materials like metal or composite in WUI zones.

Property Rights High sensitivity to private property rights may limit enforcement of vegetation management.

Clarify language in ordinances to support health and safety mitigation. Provide incentives instead of mandates.

Roofing
Requirements
Shake roofs currently not permitted but may not be strictly enforced.

Strictly prohibit wood shake roofs. Promote or require Class A fire-rated roofing in WUI.

Zoning and
Permitting
Current permits may not account for fire mitigation
considerations. Fire-safe practices like mulch/fences up to home not explicitly allowed.

Update zoning codes to allow defensible space treatments like fences or mulch up to structures. Fast-track permits for firehardening retrofits.

EMERGENCY PREPAREDNESS COMMITTEE:

RECOMMENDATIONS
Structural Hardening
• WUI adoption townwide
• Noncombustible fencing near structures
Defensible Space
• Review and revise Municipal Code Standards to remove conflicts and evaluate fuel load management by exploring increase to what qualifies as a heritage oak* Community Programs
• Continued Participation in Firewise
• Fire Risk Reduction Community (FRRC) form the CAL FIRE’s Office of the State Fire Marshal** * Require Discussion with other Committees (EDPC, Open Space, Planning Commission) ** Require Discussion and Collaboration with the Fire District and County Fire Dept.

QUESTIONS /COMMENTS?

THANK YOU
Los Altos Hills
Fire Mitigation Plan
Prepared and Presented by: Jay Bradford, Community Development Director

ITEM 11A
ITEM 11A – External Access and Dara Security Concerns re: Flock ALPR Data Evanston shuts down license plate cameras, terminates contract with Flock Safety - Evanston RoundTable https://evanstonroundtable.com/2025/08/26/evanston-shuts-downlicense-plate-cameras-terminates-contract-with-flock-safety/ CBP Had Access to More than 80,000 Flock AI Cameras Nationwide https://www.404media.co/cbp-had-access-to-more-than-80-000-flock-ai-camerasnationwide/ Denver City Council cancelled its contract with Flock:
https://www.denver7.com/news/local-news/denver-city-council-rejects-contractexpansion-for-license-plate-recognition-cameras-in-the-city Flock admits federal agents access local police data | 9news.com https://www.9news.com/article/news/local/flock-federal-immigration-agents-accesstracking-data/73-a8aee742-56d4-4a57-b5bb-0373286dfef8 License plate camera company halts cooperation with federal agencies among investigation concerns https://www.yahoo.com/news/articles/license-plate-cameracompany-halts-225436172.html