Agenda packet — Los Altos Hills City Council, October 16, 2025 (part 4 of 5)

5 page
Definitions
Multi-family Objective Design Standards

05. Definitions
The following definitions apply to the Multi-family Objective Design Standards in this section. Where there is a conflict between other definitions in the LAHMC and the definitions in this section, the definitions in this section shall apply.

Fully Shielded. A luminaire constructed in a manner such that all light emitted by the luminaire, either directly from the light source or a defusing element, or indirectly by reflection or refraction from any part of the luminaire is projected below the horizontal plane, by shielding that is permanently affixed as a structural part of the luminaire that extends below the lowest portion of the light source so that no light is able to be emitted above the horizontal plane or as certified by the manufacturer.

Monument. A sign supported by one or more uprights of braces on the ground, not exceeding 4 feet in height.

Screen. A visual and/or acoustic separation of an object or site by means of a fence, wall, berm, hedge or other barrier whereby 50% or more of the area or object is hidden from the view from a particular vantage point. Where vegetation is used for screening, the vegetation must be evergreen.

Recreation Space. Indoor or outdoor space designed, intended, and specifically improved for active or passive recreational use.

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6 page
Site Planning
Multi-family Objective Design Standards

06. Site Planning
The building placement, arrangement of activities, and design of the site are significant factors in maintaining the unique semi-rural character and scale of Los Altos Hills.

06.01 Recreation Areas
Intent: Provide access to recreation areas for multi-family residents to enjoy the natural beauty of Los Altos Hills at home.

06.01.01 Private Recreation Space
(a) Private recreation space shall meet the following minimum requirements:
(1) Private recreation space shall be no less than 5 feet in any direction.
(b) Private recreation space may consist of one or more of the following:
(1) Balconies
(2) Patios
(3) Gardens
(4) Porches/Stoops

06.01.02 Common Recreation Space
(a) Common usable recreation space shall meet the following standards:
(1) Be located adjacent to and visible from residential units of the development.
(2) Not be located within 60 feet of a public street or adjacent to service areas including areas for storage,
waste collection, property maintenance, and loading and deliveries.
(3) Have a minimum measurement of 25 feet in at least one direction.
(4) Include a minimum planted area of at least 20%.
(5) Not exceed 10% slope.
(6) Be screened when at least one side is within the
minimum required building setback adjacent to a singlefamily property.

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Site Planning
Multi-family Objective Design Standards

06.02 Parking, Access, and Circulation
Intent: Limit the visual, environmental and safety impacts of vehicle circulation, access, and parking.

06.02.01 Access Roads
(a) This section complements the provisions set forth in Chapter 9-1.7 of the LAHMC.
(1) Parking, vehicular and fire truck access, and turnarounds shall meet all applicable requirements and standards
identified in the California Fire Code and as locally
amended by the Town.
(2) Secondary vehicular access shall be required for projects with more than 100 dwelling units.

06.02.02 Underground Parking
(a) The entrance to a basement or underground garage shall be not more than 25 feet wide.

06.02.03 Surface Parking
(a) Surface parking shall meet the following requirements:
(1) Surface parking shall include no more than 8 continuous perpendicular or angled parking spaces without at least 1 space wide planted with at least 1 tree.
(2) The space between the perimeter of the parking lot and the nearest buildings shall be a minimum of 10 feet and contain a combination of trees, shrubs and sidewalk.
(3) Where there is surface parking, the perimeter shall be set back from side and rear property lines by at least
30 feet and screened from the public right-of-way and
properties. The setback area shall be planted with
vegetation in accordance with the Landscaping and
Screening section herein.
(4) Tree canopies shall occupy at least 30% of a paved
surface within 5 years of construction.
(5) Dividers shall be provided between garage doors
between adjacent units shall be planted with a tree,
shrub, or other perennial plant of at least four feet in height.

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Site Planning
Multi-family Objective Design Standards

06.03 Grading Design Standards
Intent: Promote the preservation of existing natural topography and vegetation within Los Altos Hills. Minimize grading and alteration of natural landforms. Retain significant existing natural features characteristics of the community. Preserve and incorporate existing topography and landforms, significant trees, drainage courses, rock outcroppings, vegetation, and views, to the maximum extent feasible, into the future development of the land. (a) Excluding cuts of an average depth of up to 6 feet beneath primary habitable buildings with underground parking, site grading shall be limited to:
(1) 1,500 cubic yards of total cuts and fills per acre of total site area.
(2) 1,000 cubic yards of total export material per acre of total site area.
(3) 500 cubic yards of imported fill per acre of total site area.
(b) As illustrated in Figure 1, Rounded Cuts and Fills, the topographic contours of all graded areas shall be rounded.

Finished grades shall not contain straight lines when viewed in cross section or topographic contour lines that are straight.

Figure 1. Rounded Cuts and Fills
(c) Grading (cut or fill) shall not exceed a grade of 50% (1 foot vertical per 2 feet horizontal) within 20 feet of the property line, except when grading for an accessory dwelling unit.

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Site Planning
Multi-family Objective Design Standards

06.04 Retaining Walls
Intent: Ensure that retaining walls and fencing blend into the natural surroundings and topography of a site.

06.04.01 Wall Height
(a) Where a retaining wall utilizes a cut slope, the retaining wall system shall not exceed the height of the nearest building wall or 15 feet, whichever is less.
(b) Where a retaining wall utilizes a fill slope, the maximum wall system height shall not be greater than 50% of the height of the building or 10 feet, whichever is less.
(c) Terracing shall be utilized for cuts exceeding 15 feet.

Figure 2. Retaining Wall System

06.04.02 Wall Design
(a) Retaining walls shall mimic the existing topographic contours through use of curvilinear wall elevations. Straight wall sections taller than 10 feet or longer than 20 feet may be allowed only where direct line of sight of said walls from public streets or residences on adjoining properties are blocked by the buildings on the multi-family development. (b) All retaining walls shall be integrated and planted with native plantings of climbing vines, shrubbery or trees that will screen or cover at least 50% of the wall surface within 5 years of construction.
(c) Retaining walls and planters shall be designed so that all visible faces are finished with stone, stained concrete, or textured surface. The Planning Commission may limit the colors of the wall materials to those on a color palette approved by the Planning Commission prior to the site
development or wall permit application.

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10 page
Building Design
Multi-family Objective Design Standards

07. Building Design
Multi-family residential building design standards are intended to enhance neighborhood character, ensure quality of building design, and result in buildings designed with appropriate bulk and mass for the neighborhood character.

07.01 Building Orientation
Intent: Develop a compatible relationship to the landforms, building placement and recreation spaces that characterize the rural community. Promote consistent development patterns for how a building is positioned on a site and how it interacts with its surroundings and adjacent properties.

07.01.01 Parking Garage/Structure Orientation
(a) Garage doors for individual units within 100 feet of the property line shall not face a public street, except to a side street when the building in which the garage is located is on a corner lot.
(b) All garage doors shall be screened from view from a public street by a wall, berm, or landscaping.
(c) Projects with a common enclosed parking garage shall have no more than two garage doors that open toward the street.

07.01.02 Building Grouping
(a) Projects with multiple buildings shall be grouped to create outdoor spaces such as central courtyards, forecourts, defined plazas, and gardens, or any other type of outdoor area, that is enclosed on at least 2 sides by a building. Planting, low walls, and fences may enclose an additional one or more sides of a usable outdoor space not enclosed by a building.

07.02 Building Form and Massing
Intent: The following standards soften the visual impact on the site and surrounding neighborhood by blending the form, mass, and profile of individual buildings in a way that respects the natural terrain and neighborhood character.

Figure 3. Building Form and Massing

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Building Design
Multi-family Objective Design Standards

07.02.01 Massing Breaks
(a) Multi-family developments shall use at least two of the horizontal articulation methods shown at an interval of not less than 50 feet.
(1) Change in material texture, patterning, or color. A change in material texture, patterning, or color that
extends the full height of the primary façade, excluding the ground level.

Figure 4. Material Texture, Pattern, and Color
(2) Horizontal offset or projection. A horizontal wall plane offset of at least 3 feet extending for at least 50% of the average height of the primary façade.

Figure 5. Horizontal Offset or Projection
(3) Change in roof height or form. A variation in parapet height of at least 3 feet or a change in roof form.

Figure 6. Roof Height or Form

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Building Design
Multi-family Objective Design Standards
(4) Change in fenestration pattern. A change in window size, style, or placement.

Figure 7. Fenestration Pattern
(5) Wall notch combination. A combination using at least one option from above, plus a wall notch. Wall notches shall be a minimum of 3 feet deep and 8 feet wide.

Figure 8. Wall Notch Combination

07.02.02 Minimize Foundation Visibility
(a) Where a daylit underground floor has an exposed wall, a 5-foot-wide landscaped area planted with plant types that can reach the finished floor height within two years from planting shall be provided.

07.02.03 Balconies and Unit Entrances
(a) Balconies shall not project more than three feet from primary façade unless such balcony abuts a wall on two or three sides.
(b) Balconies shall not be used for storage.

07.03 Materials and Colors
Intent: Establish and maintain local design principles, respond to regional climate conditions, and utilize local building practices and materials.

07.03.01 Building Materials
(a) Buildings shall not use any of the following materials:
(1) Glass curtain walls.
(2) Reflective or “mirrored” glass.
(3) Glass covering more than 40% of the area of any
building elevation.
(b) All sides and facades of a building or structure shall be finished in the method of manufacture, color, and material of the front facade of the primary or main (not accessory) building(s).

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Building Design
Multi-family Objective Design Standards

07.03.02 Building Colors.
(a) All exterior colors and materials shall have a light reflectivity value of 50 or less and roof materials shall have a light reflectivity value of 40 or less or as otherwise specified by a formal color board adopted by the Town.

07.04 Roof Design
Intent: Provide roof design consistent with local design principles, ensure mechanical and service equipment is not visible, and provide visual interest through variation and weather protection elements.

07.04.01 Roof Form
(a) Buildings shall not have flat roofs exceeding 25 feet in length. (b) Sloped roofs over 100 feet in length shall incorporate one of the following:
(1) A variation in the roof plane with architectural elements such as chimneys or dormers.
(2) A variation in roof form such as gable, hipped, or shed. (3) A variation in roof height of at least 3 feet.
(c) Changes in roof pitch orientation shall be accompanied by plan offsets on primary elevations.
(d) Changes in adjacent eave heights shall be paired with plan offsets.
(e) Buildings shall provide eaves and/or roof overhangs to create shadow lines and reduce the amount of view of striking glass surfaces.

07.04.02 Roof Type
(a) Building roofs shall include one or more of the following roof types:
(1) Gable
(2) Hipped
(3) Shed
(b) Pitched roofs shall include eaves and shall have a minimum roof pitch of not less than 4 feet vertical to 12 feet horizontal. (c) Flat roofs shall have a minimum projecting eave length of 12 inches or a parapet wall.
(d) Buildings with rooftop mechanicals shall have a minimum parapet height of 3 feet.

Figure 9. Roof Types
(e) All roofs shall conform to a color and light reflectivity value (LRV) specified in Exhibit A of the Town of Los Altos Hills Metal Roofing Policy.

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Building Design
Multi-family Objective Design Standards

07.05 Windows and Doors
Intent: Enhance the visual appeal of a building’s exterior by providing light, ventilation, views, privacy, and proportionality consistent with local principles.
(a) Windows shall be recessed from the building façade by not less than two inches to create shadow lines.
(b) Doors shall be recessed from the building façade by not less than twelve inches to create shadow lines.
(c) Large, glazed window areas longer than 25 feet shall be broken into smaller windowpanes not more than 5 feet in length.
(d) Garage door windows, panels, or other openings shall not emit light more than 30% of the door’s surface area. The emitting light shall be translucent, allowing no more than 30% of the interior light emission to pass through to the outside.

Figure 10. Recessed Windows and Doors

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15 page
Landscaping and Screening
Multi-family Objective Design Standards

08. Landscaping and Screening

08.01 Landscaping and Screening
Intent: Retain the existing natural features and promote the use of water-conserving native plant types appropriate for Los Altos Hills. The standards are also intended to soften, shade, and cool a building or associated structure. The density of vegetation should increase with the density of development. This section complements the provisions set forth in Title 5 Chapter 8, Sunlight, Daylight Access Rights of the LAHMC.
(a) All areas shall be vegetated unless used for building, parking, or other designated functions with California native plants in accordance with the Town of Los Altos Hills Landscaping Guide 2.1.
(b) All new screening trees planted on-site shall be a minimum 24-inch box size California native evergreen tree, and all shrubs shall be California-native evergreen shrubs of at least 15-gallon box size. Selected from the Town of Los Altos Hills Landscaping Guide 2.1.

08.01.01 Setback Landscaping
(a) At least 50% of the front and/or street-side minimum building setback areas shall be covered with tree canopy after five years’ growth, shrubs after two years’ growth, open fencing, walls less than three feet high, interrupted only by sidewalks and permitted driveway curb cuts.
(b) A minimum 20-foot-wide landscape screen shall be provided along the full length of the shared property line between a multi-family development and one or more abutting singlefamily residential properties. The buffer shall comply with all of the following:
(1) Where proposed, solid fences or walls over three feet in height shall be screened by trees and or shrubs.
(2) Trees shall be planted at a rate of at least one tree per 50 linear feet of shared property line. Trees may be
clustered to provide a more natural appearance.

08.01.02 Heritage Oak Tree Replacement
(a) If a project proposes to remove or damages, in the course of construction, a heritage oak tree as defined in Section 12-2.101 of the LAHMC, the applicant shall be required to provide replacement requirements in accordance with Section 12-2.3 of the LAHMC as well as providing the following tree replacement:
(1) For a heritage oak tree between 12 and 18 inches in trunk diameter: replacement with two 24-inch box
California native oak trees.
(2) For a heritage oak tree between 18 and 24 inches in trunk diameter: replacement with three 24-inch box
California native oak trees.
(3) For a heritage oak tree greater than 24 inches in trunk diameter: replacement with four 24-inch box California
native oak trees.

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Landscaping and Screening
Multi-family Objective Design Standards

08.02 Fencing and Walls
Intent: Preserve the beauty and semi-rural quality of the Town while acknowledging that residents have the right to fence their properties in order to protect their children, contain their animals, and maintain privacy. All fences, walls, gates, and columns shall follow the requirements set forth in Section 10-1.507 of the LAHMC.

08.02.01 Fence Height
(a) If fences and walls over 3 feet high face public streets, a landscaped screen at least 5 feet deep shall be installed on the street-facing side.

08.02.02 Fence Setback
(a) All walls and fences along a trail or pathway identified on the Town’s Master Path Plan shall be setback at least 18 inches from the edges of the pathway easement or 10 feet from the centerline of the pathway surface, whichever is greater, to allow for planting.
(b) Both sides of all fencing shall have the same materials, colors, and finish, or the side with the most structural supports, braces, and hardware shall face the owner’s property and away from the neighboring property.

08.02.03 Fence/Wall Location
(a) No fence or wall shall be located within a public road right-ofway or recorded pathway easement.

08.02.04 Fence Types
(a) The following types of fences are prohibited:
(1) Chain-link or cyclone fences.
(2) Barbed or razor wire fences.
(3) Electric fences.
(4) Any fence that may cause harm to people, pets, and/ or wildlife due to points, spikes, or sharpened edges on the top or bottom part of the fence. No fences shall have a projection above the top or bottom rail or common
elevation line except for vertical support posts.
(b) Any fence crossing, intersecting, or adjacent to a wildlife corridor or open space or conservation easement designated by formal action of the City Council via motion or resolution shall conform to the requirements specified in Section 10-

1.507 of the LAHMC.

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Landscaping and Screening
Multi-family Objective Design Standards

08.03 Lighting
Intent: Maintain visibility of the night skies, minimize light pollution, skyglow, and glare, enhance the pedestrian environment, and promote high-quality lighting fixtures consistent with local design principles.

No part of the total initial design fixture lumens shall be emitted at an angle of 70 degrees or higher from nadir
(straight down).
(3) Site lighting shall be controlled by timers to turn off after 10:00 p.m. except where otherwise required by law.
(4) All motion-sensitive lighting shall turn off after not more than five minutes.
(b) The following lighting features are permitted, and light emission and color temperatures of any light bulbs used shall be limited as follows:

Table 1. Light Emission and Color Temperature
Light Source
Maximum Light
Emission
(Lumens)
Maximum Color
Temperature
(Kelvin)
Path Lights 200 2700
Step Lights 110 2700
Exterior Wall Sconces 600 3000
Recessed Ceiling Lights 600 3000
Pendant Lights 600 3000
Gate Lights 600 3000
Temporary Construction Lighting 500 3000
(c) Pathway and driveway lighting shall be no taller than 18 inches. The spacing between pathway lights shall be not less than 20 feet on center.
(d) Overhead walkway or parking lighting shall be between 10 and 15 feet in height and at the minimum distance intervals necessary to comply with the California Building Standards Code.
(e) Recreation courts. No artificial lighting shall be permitted for tennis and other recreation courts, except as provided for in Section 10-1.703(n).

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Landscaping and Screening
Multi-family Objective Design Standards

Recessed lights and downlights in first floor roof eaves shall be positioned so that the light cone does not shine down into a neighboring property. No lighting shall be placed at or near the peak of the roof line of a gabled roof.
(c) Skylights shall not exceed 3 feet in any dimension and shall have a means of blocking the emission of interior light at night.
(d) Lightwells and basement stairs shall be the minimum size required by the Building Code or other applicable law. Such stairs shall include an awning or other non-translucent cover. (e) All lighting of rooftop common area facilities shall require non-translucent shades, panels or other means around the light source that obscure and prevent horizontal light toward the nearest edge of the building. Rooftop lighting shall not exceed 0.5 footcandles at the edge of the rooftop surface.

08.03.03 Signage Lighting
(a) Externally lighted signs shall use only shielded top mounted, downward directed light sources and shall not exceed a total combined 1,200 lumens or 3,000 Kelvin color temperature.

08.03.04 Prohibited Lighting Types
(a) Notwithstanding subsection 08.03.01 above, the following outdoor lighting types are prohibited:
(1) Any light beams that emit or stretch beyond the aerial space defined by the property lines
(2) Up-lighting of any kind
(3) Wall wash lighting of exterior walls
(4) Visible LED lighting strips, tape lights, and bistro lights (5) Bistro lights, pendant lights, and any similar lighting fixtures hung down from or amongst trees
(6) Tree lights

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Landscaping and Screening
Multi-family Objective Design Standards

08.04 Signage
Intent: Protect the Town’s semi-rural residential character from the adverse impact of unnecessarily large or an excessive number of signs. Signage design should be carefully integrated with the site and building design concepts to create a unified appearance for the total development. Within a multi-family project, signage should be consistent in location and design.

08.04.01 Signage Location
(a) No more than one sign per entry from a public street or road shall be permitted.

08.04.02 Signage Type
(a) Project signage is limited to monument sign types.

08.04.03 Signage Design
(a) For properties with more than 500 feet of street frontage and two driveways, a development may have up to 2 monument
signs, one at each road entry. No individual sign shall exceed 12 square feet in area excluding the area of supports or decorative features within two feet around the smallest rectangle containing the message of the sign.
(b) Monument signs shall not exceed 4 feet in height.
(c) Signage design shall be constructed with one or more of the architectural materials used on the primary building(s) and use no more than three colors.

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20 page
Utilities and Service Areas
Multi-family Objective Design Standards

09. Utilities and Service Areas
Intent: Mechanical equipment shall be designed and maintained so as to minimize visual, noise, and other impacts on the surrounding community and shall be planned, designed, located, and erected in accordance with the design and development standards in this section.

09.01 Mechanical Equipment Location and
Screening
Intent: Establish criteria for the design, location, and concealing of mechanical building features.

09.01.01 Equipment Location
(a) Mechanical equipment, electrical equipment, and trash enclosures shall not be located within any minimum building setback.
(b) All electrical and utility services for new construction shall be undergrounded.
(c) Utility and mechanical equipment shall not obstruct any pedestrian pathways shown on any approved development
plan, on any Town plan, or within any pathway or access easement.
(d) Ground-mounted utilities shall be screened using one or more of the following elements and located within the building envelope:
(1) Wall,
(2) Fence, and/or
(3) Landscaping

09.01.02 Equipment Screening
(a) Where mechanical and electrical equipment is located on the roof, it shall be located so that it is not visible from any angle from the public right-of-way, and enclosed or screened using the following techniques:
(1) Located toward the center of the roof so as not to be visible from the public right-of-way;
(2) Constructed with one or more of the architectural
materials used on the primary building; and
(3) Be at least the same height as the item being screened. (b) Trash enclosures shall not be visible from the public right-ofway, pedestrian/common areas, and neighboring properties.

The enclosure shall be constructed with one or more of the materials used on the primary building.
(c) All outdoor trash receptacles shall be fully enclosed and have a self-closing mechanism to reduce rodents.
(d) All outdoor trash receptacles shall be fully screened by walls, landscaping, and/or fencing.
(e) All ground-level mechanical equipment, service, parking, storage, shipping, and utility areas shall be screened by landscaping or walls at least the same height as the item being screened.

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Checklist
Multi-family Objective Design Standards
Appendix: Checklist for Multi-family Objective Design Standards Design Standard
Applicant City Use Only
Complete N/A Complete N/A

06. Site Planning

06.01 Recreation Areas

06.01.01 Private Recreation Space
(a) Private recreation space shall meet the following minimum requirements:
(1) Private recreation space shall be no less than 5 feet in any direction. (b) Private recreation space may consist of one or more of the following:
(1) Balconies
(2) Patios
(3) Gardens
(4) Porches/Stoops

06.01.02 Common Recreation Space
(a) Common usable recreation space shall meet the following standards:
(1) Be located adjacent to and visible from residential units of the development. (2) Not be located within 60 feet of a public street or adjacent to service areas including areas for storage, waste collection, property maintenance, and loading and devlieries. (3) Have a minimum measurement of 25 feet in at least one direction. (4) Include a minimum vegetated area of at least 20%.
(5) Not exceed a 10% slope.
(6) Be screened when at least one side is within the minimum required building setback adjacent to a single-family property.

ADDITIONAL APPLICANT COMMENTS (OPTIONAL) ADDITIONAL CITY COMMENTS (OPTIONAL)

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06.02 Parking, Access, and Circulation

06.02.01 Access Roads.
(a) This section complements the provisions set forth in Chapter 9-1.7 of the LAHMC. (1) Parking, vehicular and fire truck access, and turnarounds shall meet all applicable requirements and standards identified in the California Fire Code and as locally amended by the Town. (2) Secondary vehicular access shall be required for projects with more than 100 dwelling units.

06.02.02 Underground Parking
(a) The entrance to a basement or underground garage shall be not more than 25 feet wide.

06.02.03 Surface Parking
(a) Surface parking shall meet the following requirements:
(1) Surface parking shall include no more than 8 continuous perpendicular or angled parking spaces without at least 1 space wide planted with at least 1 tree.
(2) The space between the perimeter of the parking lot and the nearest buildings shall be a minimum of 10 feet and contain a combination of trees, shrubs and sidewalk.
(3) Where there is surface parking, the perimeter shall be set back from side and rear property lines by at least 30 feet and screened from the public right-of-way and properties. The setback area shall be planted with vegetation in accordance with the Landscaping and Screening section herein. (4) Tree canopies shall occupy at least 30% of a paved surface within 5 years of construction. (5) Dividers shall be provided between garage doors between adjacent units shall be planted with a tree, shrub or other perennial plant of at least four feet in height.

ADDITIONAL APPLICANT COMMENTS (OPTIONAL) ADDITIONAL CITY COMMENTS (OPTIONAL)

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06.03 Grading Design Standards
(a) Excluding cuts of an average depth of up to 6 feet beneath primary habitable buildings with underground parking, site grading shall be limited to:
(1) 1,500 cubic yards of total cuts and fills per acre of total site area. (2) 1,000 cubic yards of total export material per acre of total site area. (3) 500 cubic yards of imported fill per acre of total site area. (b) As illustrated in Figure 1, Rounded Cuts and Fills, the topographic contours of all graded areas shall be rounded. Finished grades shall not contain straight lines when viewed in cross section or topographic contour lines that are straight. (c) Grading (cut or fill) shall not exceed a grade of 50% (1 foot vertical per 2 feet horizontal) within 20 feet of the property line, except when grading for an accessory dwelling unit.

06.04 Retaining Walls

06.04.02 Wall Design
(a) Retaining walls shall mimic the existing topographic contours through use of curvilinear wall elevations. Straight wall sections taller than 10 feet or longer than 20 feet may be allowed only where direct line of sight of said walls from public streets or residences on adjoining properties are blocked by the buildings on the multi-family development. (b) All retaining walls shall be integrated and planted with native plantings of climbing vines, shrubbery or trees that will screen or cover at least 50% of the wall surface within 5 years of construction. (c) Retaining walls and planters shall be designed so that all visible faces are finished with stone, stained concrete, or textured surface. The Planning Commission may limit the colors of the wall materials to those on a color palette approved by the Planning Commission prior to the site development or wall permit application.

ADDITIONAL APPLICANT COMMENTS (OPTIONAL) ADDITIONAL CITY COMMENTS (OPTIONAL)

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07. Building Design

07.01 Building Orientation

07.01.01 Parking Garage/Structure Orientation
(a) Garage doors for individual units within 100 feet of the property line shall not face a public street, except to a side street when the building in which the garage is located is located on a corner lot. (b) All garage doors shall be screened from view from a public street by a wall, berm, or landscaping. (c) Projects with a common enclosed parking garage shall have no more than two garage doors that open toward the street.

07.02 Building Form and Massing

07.02.01 Massing Breaks
(a) Multi-family developments shall use at least two of the horizontal articulation methods shown in at an interval of not less than 50 feet.
(1) Change in material texture, patterning or color. A change in material texture, patterning or color that extends the full height of the primary façade, excluding the ground level. (2) Horizontal offset or projection. A horizontal wall plane offset of at least 3 feet extending for at least 50% of the average height of the primary façade.
(3) Change in roof height or form. A variation in parapet height of at least 3 feet or a change in roof form. (4) Change in fenestration pattern. A change in window size, style, or placement. (5) Wall notch combination. A combination using at least one option from above, plus a wall notch. Wall notches shall be a minimum of 3 feet deep and 8 feet wide.

ADDITIONAL APPLICANT COMMENTS (OPTIONAL) ADDITIONAL CITY COMMENTS (OPTIONAL)

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07.03 Materials and Colors

07.03.01 Building Materials
(a) Buildings shall not use any of the following materials:
(1) Glass curtain walls.
(2) Reflective or “mirrored” glass.
(3) Glass covering more than 40% of the area of any building elevation. (b) All sides and facades of a building or structure shall be finished in the method of manufacture, color, and material of the front facade of the primary or main (not accessory) building(s).

07.04 Roof Design

ADDITIONAL APPLICANT COMMENTS (OPTIONAL) ADDITIONAL CITY COMMENTS (OPTIONAL)

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Complete N/A Complete N/A
(2) A variation in roof form such as gable, hipped, or shed. (3) A variation in roof height of at least 3 feet.
(c) Changes in roof pitch orientation shall be accompanied by plan offsets. (d) Changes in adjacent eave heights shall be paired with plan offsets. (e) Buildings shall provide eaves and/or roof overhangs to create shadow lines and reduce the amount of view of striking glass surfaces.

07.04.02 Roof Type
(a) Building roofs shall include one or more of the following roof types:
(1) Gable
(2) Hipped
(3) Shed
(b) Pitched roofs shall include eaves and shall have a minimum roof pitch of not less than 4 feet vertical to 12 feet horizontal. (c) Flat roofs shall have a projecting eave length of 12 inches or a parapet wall. (d) Buildings with rooftop mechanicals shall have a minimum parapet height of 3 feet. (e) All roofs shall conform to a color and light reflectivity value (LRV) specified in Exhibit A of the Town of Los Altos Hills Metal Roofing Policy.

07.05 Windows and Doors
(a) Windows shall be recessed from the building façade by not less than two inches to create shadow lines. (b) Doors shall be recessed from the building façade by not less than twelve inches to create shadow lines. (c) Large, glazed window areas longer than 25 feet shall be broken into smaller windowpanes not more than 5 feet in length. (d) Garage door windows, panels, or other openings shall not emit light more than 30% of the door’s surface area. The emitting light shall be translucent, allowing no more than 30% of the interior light emission to pass through to the outside

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08. Landscaping and Screening

08.01 Landscaping and Screening
(a) All areas shall be vegetated unless used for building, parking or other designated functions with California native plants in accordance with the Town of Los Altos Hills Landscaping Guide 2.1. (b) All new screening trees planted on-site shall be a minimum 24-inch box size California native evergreen tree, and all shrubs shall be California-native evergreen shrubs of at least 15-gallon box size. Selected from the Town of Los Altos Hills Landscaping Guide 2.1.

08.01.01 Setback Landscaping
(a) At least 50% of the front and/or street-side minimum building setback areas shall be covered with tree canopy after five years’ growth, shrubs after two years’ growth, open fencing, walls less than three feet high, interrupted only by sidewalks and permitted driveway curb cuts.
(b) A minimum 20-foot-wide landscape screen shall be provided along the full length of the shared property line between a multi-family development and one or more abutting single-family residential properties. The buffer shall comply with all of the following:
(1) Where proposed, solid fences or walls over three feet in height shall be screened by trees and or shrubs. (2) Trees shall be planted at a rate of at least one tree per 50 linear feet of shared property line. Trees may be clustered to provide a more natural appearance.

08.01.03 Heritage Oak Tree Replacement
(a) If a project proposes to remove or damages, in the course of construction, a heritage oak tree as defined in Section 12-2.101, the applicant shall be required to provide replacement requirements in accordance with Section 12-2.3 of the LAHMC as well as providing the following tree replacement:
(1) For a heritage oak tree between 12 and 18 inches in trunk diameter: replacement with two 24-inch box California native oak trees.
(2) For a heritage oak tree between 18 and 24 inches in trunk diameter: replacement with three 24-inch box California native oak trees.
(3) For a heritage oak tree greater than 24 inches in trunk diameter: replacement with four 24-inch box California native oak trees.

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08.02 Fencing and Walls

08.02.01 Fence Height
(a) If fences and walls over 3 feet high face public streets, a landscaped screen at least 5 feet deep shall be installed on the street-facing side.

08.02.02 Fence Setback
(a) All walls and fences along a trail or pathway identified on the Town’s Master Path Plan shall be setback at least 18 inches from the edges of the pathway easement or 10 feet from the centerline of the pathway surface, whichever is less, to allow for planting.
(b) Both sides of all fencing shall have the same materials, colors and finish or the side with the most structural supports, braces, hardware shall face the owner’s property and away from the neighboring property.

08.02.03 Fence/Wall Location
(a) No fence or wall or future path shall be located within a public road right-of-way or recorded pathway easement.

08.02.04 Fence Types
(a) The following types of fences are prohibited:
(1) Chain-link or cyclone fences.
(2) Barbed or razor wire fences.
(3) Electric fences.
(4) Any fence that may cause harm to people, pets, and/or wildlife due to points, spikes, or sharpened edges on the top or bottom part of the fence. No fences shall have a projection above the top or bottom rail or common elevation line except for vertical support posts.
(b) Any fence crossing, intersecting, or adjacent to a wildlife corridor or open space or conservation easement designated by formal action of the City Council via motion or resolution shall conform to the requirements specified in Section 10-1.507 of this Code.

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08.03 Lighting

08.03.01 Outdoor Lighting.
(a) Except as otherwise provided in this chapter, all outdoor lighting relating to but not limited to the exterior of structures, along walkways, driveways, recreation courts, and swimming pools shall follow the provisions set forth in Article 10, entitled “Outdoor Lighting” of Chapter 2 entitled “Site Development of Title 10 of LAHMC. (1) Exterior building lighting shall be fully shielded and downward facing and limited to one exterior light fixture per exterior doorway, or the minimum necessary to comply with the California Building Standards Code. (2) Exterior lighting shall produce a maximum initial illuminance of no greater than 0.01 horizontal and vertical footcandles at the site boundary and beyond. No part of the total initial design fixture lumens shall be emitted at an angle of 70 degrees or higher from nadir (straight down). (3) Site lighting shall be controlled by timers to turn off after 10:00 p.m. except where otherwise required by law. (4) All motion-sensitive lighting shall turn off after not more than five minutes. (b) Light emission and color temperatures of any light bulbs are limited as identified in Table 3: Light Emission and Color Temperature.
(c) Pathway and driveway lighting shall be no taller than 18 inches. The spacing between pathway lights shall be not less than 20 feet on center.
(d) Overhead walkway or parking lighting shall be between 10 and 15 feet in height and at the minimum distance intervals necessary to comply with the California Building Standards Code. (e) Recreation courts. No artificial lighting shall be permitted for tennis and other recreation courts, except as provided for in Section 10-1.703(n).

08.03.02 Building Lighting
(a) Exterior building light fixtures shall be shielded and downward facing and limited to one exterior light fixture per exterior doorway, or the minimum necessary to comply with the California Building Standards Code. (b) Recessed lights and downlights shall not be installed in roof eaves except for first floor eaves located over entryways, garage doors, and private recreation space doorways only. Recessed lights and downlights in first floor roof eaves shall be positioned so that the light cone does not shine down into a neighboring property. No lighting shall be placed at or near the peak of the roof line of a gabled roof.

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(c) Skylights shall not exceed 3 feet in any dimension and shall have a means of blocking the emission of interior light at night.
(d) Lightwells and basement stairs shall be the minimum size required by the Building Code or other applicable law. Such stairs shall include an awning or other non-translucent cover. (e) All lighting of rooftop common area facilities shall require non-translucent shades, panels or other means around the light source that obscure and prevent horizontal light toward the nearest edge of the building. Rooftop lighting shall not exceed 0.5 footcandles at the edge of the rooftop surface.

08.03.03 Signage Lighting
(a) Externally lighted signs use only shielded top mounted, downward directed light sources and shall not exceed a total combined 1,200 lumens or 3,000 Kelvin color temperature.

08.03.04 Prohibited Lighting Types
(a) Notwithstanding subsection 08.03.01 above, the following outdoor lighting types are prohibited:
(1) Any light beams that emits or stretches beyond the aerial space defined by the property lines (2) Up-lighting of any kind
(3) Wall wash lighting of exterior walls
(4) Visible LED lighting strips, tape lights, and bistro lights (5) Bistro lights, pendant lights, and any similar lighting fixtures hung down from or amongst trees (6) Tree lights

08.04 Signage

08.04.01 Signage Location
(a) No more than one sign per entry from a public street or road shall be permitted.

08.04.02 Signage Type
(a) Project signage is limited to monument sign types.

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08.04.03 Signage Design
(a) For properties with more than 500 feet of street frontage and two driveways, a development may have up to 2 monument signs, one at each road entry. No individual sign shall exceed 12 square feet in area excluding the area of supports or decorative features within two feet around the smallest rectangle containing the message of the sign. (b) Monument signs shall not exceed 4 feet in height.
(c) Signage design shall be constructed with one or more of the architectural materials used on the primary building(s) and use no more than three colors.

09. Utilities and Service Areas

09.01 Mechanical Equipment Location and Screening

09.01.01 Equipment Location
(a) Mechanical equipment, electrical equipment, and trash enclosures shall not be located within any minimum building setback.
(b) All electrical and utility services for new construction shall be undergrounded. (c) Utility and mechanical equipment shall not obstruct any pedestrian pathways shown on any approved development plan, Town plan or within any pathway or access easement.
(d) Ground-mounted utilities shall be screened using one or more of the following elements and located within the building envelope:
(1) Wall,
(2) Fence, and/or
(3) Landscaping

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(2) Constructed with one or more of the architectural materials used on the primary building; and (3) Be at least the same height as the item being screened. (b) Trash enclosures shall not be visible from the public right-of-way, pedestrian/common areas, and neighboring properties.

The enclosure shall be constructed with one or more of the materials used on the primary building. (c) All outdoor trash receptacles shall be fully enclosed and have a self-closing mechanism to reduce rodents. (d) All outdoor trash receptacles shall be fully screened by walls, landscaping and/or fencing. (e) All ground-level mechanical equipment, service, parking, storage, shipping, and utility areas shall be screened by landscaping or walls at least the same height as the item being screened

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PREPARED BY

PREPARED FOR

TOWN OF LOS ALTOS HILLS
OCTOBER 2025

TOWN OF LOS ALTOS HILLS

MULTIFAMILY ZONE AND

OBJECTIVE DESIGN

STANDARDS PROJECT
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TOWN OF LOS ALTOS HILLS
Multifamily Zone and Objective Design Standards Project SB 131
Statutory Exemption Report
Lead Agency:

Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
Contact: Jay Bradford
Phone: 650.559.2244
Prepared by:

Michael Baker International
40810 County Center Dr #200
Temecula, CA 92591
Contact: Alicia Gonzalez
[email protected]
Phone: 909.974.4933
JN 196303
October 2025
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TABLE OF CONTENTS
I. Introduction ................................................................................................................... 1 II. Project Location and Setting ......................................................................................... 5 III. Project Description ...................................................................................................... 17 IV. Construction of Oil and Gas Infrastructure or a Distribution Center Analysis .......... 25 V. Natural and Protected Lands Analysis ........................................................................ 27 Criterion (a) ......................................................................................................................................... 27 Criterion (b) ......................................................................................................................................... 27 Criterion (c) ......................................................................................................................................... 27 Criterion (d) ......................................................................................................................................... 27 Criterion (e) ......................................................................................................................................... 27 Criterion (f).......................................................................................................................................... 28 Criterion (g) ......................................................................................................................................... 28 Criterion (h) ......................................................................................................................................... 28 Criterion (i) .......................................................................................................................................... 28 Criterion (j) .......................................................................................................................................... 29 Criterion (k) ......................................................................................................................................... 33 Criterion (l) .......................................................................................................................................... 33 Criterion (m) ....................................................................................................................................... 37 Criterion (n) ......................................................................................................................................... 37 Criterion (o) ......................................................................................................................................... 37 Criterion (p) ......................................................................................................................................... 41 V. Conclusion ................................................................................................................... 43 VI. References .................................................................................................................... 45

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IV. CONSTRUCTION OF OIL AND GAS INFRASTRUCTURE OR A

DISTRIBUTION CENTER ANALYSIS
List of Exhibits
Exhibit 1: Regional Vicinity .............................................................................................................................. 7 Exhibit 2: Local Vicinity ................................................................................................................................... 9 Exhibit 3: Twin Oaks Site ............................................................................................................................... 11 Exhibit 4: St. Nicholas School Site ................................................................................................................ 13 Exhibit 5: Foothill College Site ...................................................................................................................... 15 Exhibit 6: Existing Zoning ............................................................................................................................. 21 Exhibit 7: Proposed Zoning ........................................................................................................................... 23 Exhibit 8: Los Altos Hills Special Flood Hazard Area ............................................................................... 31 Exhibit 9: USFWS National Wetlands Inventory Map .............................................................................. 35 Exhibit 10: Fire Hazard Severity Zones ....................................................................................................... 39 List of Tables
Table 1: Twin Oaks Site Details ................................................................................................................... 18 Table 2: St. Nicholas School Site Details .................................................................................................... 20 Table 3: Foothill College Site Details ............................................................................................................ 20 List of Attachments
Attachment A Twin Oaks NRCS Soils Data
Attachment B Foothill College NRCS Soils Data
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SB 131 STATUTORY EXEMPTION REPORT
This report serves as the environmental determination for the proposed Multifamily Zone and Objective Design Standards Project (Project) for the Town of Los Altos Hills. The intent of the analysis is to document the Project’s eligibility as statutorily exempt from environmental review under the California Environmental Quality Act (CEQA) pursuant to Senate Bill 131 (SB 131). The report includes an introduction, Project description, and evaluation of the Project’s consistency with the requirements to qualify for the SB 131 statutory exemption.

I. INTRODUCTION
SB 131 was signed into law on June 30, 2025, and adds new Section 21080.085 to the Public Resources Code to exempt rezoning actions that implement the schedule of actions contained in an approved housing element pursuant to subdivision (c) of Section 65583 of the Government Code. The exemption does not apply to:
x Rezoning actions allowing the construction of oil and gas infrastructure or a distribution center, as defined by Public Resources Code Sections 21064.8 and 21060.4, respectively. x Rezoning actions allowing construction within any natural and protected lands, as defined by Public Resources Code Section 21067.5.

Public Resources Code Section 21064.8 defines “oil and gas infrastructure” as a facility used for the production, processing, transmission, storage, or distribution of petroleum or natural gas. Public Resources Code Section 21060.4 defines “distribution center” as a warehouse distribution center, as defined in Section 2100 of the Labor Code, that is 50,000 square feet or larger. Section IV of this report evaluates the Project against the Public Resources Code Sections 21064.8 and 21060.4 definitions of oil and gas infrastructure and distribution center.

Public Resources Code Section 21067.5 defines “natural and protected lands” as follows:
(a) The state park system, as described in Article 1 (commencing with Section 5001) of Chapter 1 of Division 5. (b) A wilderness area, as defined in Section 5093.32.
(c) A marine protected area, as defined in Section 2852 of the Fish and Game Code. (d) The national park system, as defined in Section 100102 of Title 54 of the United States Code. (e) A national recreation area.
(f) A national monument.
(g) The national wild and scenic rivers system, as defined in Section 1273 of Title 16 of the United States Code. (h) Any ecological reserve or wildlife management area acquired and managed by the Department of Fish and Wildlife pursuant to Article 2 (commencing with Section 1525) or Article 4 (commencing with Section 1580) of Chapter 5 of Division 2 of the Fish and Game Code.

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(i) A hazardous waste site that is listed pursuant to Section 65962.5 of the Government Code or a hazardous waste site designated by the Department of Toxic Substances Control pursuant to Section 25356 of the Health and Safety Code, unless either of the following apply:
(1) The site is an underground storage tank site that received a uniform closure letter issued pursuant to subdivision (g) of Section 25296.10 of the Health and Safety Code based on closure criteria established by the State Water Resources Control Board for the use proposed by the project. This paragraph does not alter or change the conditions to remove a site from the list of hazardous waste sites listed pursuant to Section 65962.5 of the Government Code.
(2) The State Department of Public Health, State Water Resources Control Board, Department of Toxic Substances Control, or a local agency making a determination pursuant to subdivision (c) of Section 25296.10 of the Health and Safety Code has otherwise determined that the site is suitable for the use proposed by the project.
(j) Within a regulatory floodway as determined by the Federal Emergency Management Agency in any official maps published by the Federal Emergency Management Agency, unless the development has received a no-rise certification in accordance with Section 60.3(d)(3) of Title 44 of the Code of Federal Regulations. (k) Lands under conservation easement.
(l) On, or within a 300-foot radius of, a wetland, as defined in the United States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993).
(m) An environmentally sensitive area within the coastal zone, as defined in Section 30107.5. (n) Lands protected as preserve areas or reserve lands pursuant to an adopted natural community conservation plan pursuant to the Natural Community Conservation Planning Act (Chapter 10 (commencing with Section 2800) of Division 3 of the Fish and Game Code) or habitat conservation plan pursuant to the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.).
(o) Within a very high fire hazard severity zone, as determined by the Department of Forestry and Fire Protection pursuant to Section 51178 of the Government Code, or within the state responsibility area, as defined in Section 4102. This subdivision does not apply to sites that have adopted fire hazard mitigation measures pursuant to existing building standards or state fire mitigation measures applicable to the development, including, but not limited to, standards established under all of the following provisions or their successor provisions:
(1) Section 4291 of this code or Section 51182 of the Government Code, as applicable. (2) Section 4290.
(3) Chapter 7A (commencing with Section 701A.1) of Part 2 of Title 24 of the California Code of Regulations.
(p) Either prime farmland or farmland of statewide importance, as defined pursuant to the United States Department of Agriculture land inventory and monitoring criteria, as modified for California, and designated on the maps prepared by the Farmland Mapping and Monitoring Program of the Department of Conservation, or land zoned ITEM 7A ATTACHMENT 4

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or designated for agricultural protection or preservation by a local ballot measure that was approved by the voters of that jurisdiction.

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II. PROJECT LOCATION AND SETTING
Project Location
The Town of Los Altos Hills (Town) is located in the northwestern portion of Santa Clara County, within the larger San Francisco Bay region; refer to Exhibit 1, Regional Vicinity. The cities of Stanford and Palo Alto are located to the north/northwest; unincorporated Santa Clara County lands are to the south and northwest; the Cities of Los Altos and Mountain View are to the northeast/east; and the City of Sunnyvale is to the east. The Town is approximately nine square miles in size. Regional access to Los Altos Hills is provided by Interstate 280 (I-280), which runs north-south, bisecting the Town.

Specifically, the proposed Multifamily Zone and Objective Design Standards Project (Project) would affect three groupings of parcels totaling approximately 19 acres within the Town boundary; refer to Exhibit 2, Local Vicinity. The parcels are herein referred to as the Twin Oaks site (in the northwestern portion of Los Altos Hills), Foothill College site (in the south-central portion), and St. Nicholas School site (in the southeastern portion).

Existing Site Conditions
Twin Oaks Site
The Twin Oaks site is located in the northwestern portion of Los Altos Hills and consists of three parcels totaling approximately 4.5 gross acres. The site is accessed via Twin Oaks Court from Arastradero Road which runs parallel to I-280. Residential uses on large-acre lots are present to the west and south; I-280 runs to the north and east just to the north, across Arastradero Road. Two of the three parcels at the Twin Oaks site are presently developed with single-family residential uses, while the remaining parcel is undeveloped/vacant. An aerial view of the site and the surrounding vicinity is provided in Exhibit 3, Twin Oaks Site.

The existing General Plan land use designation for the site is Single Family Residential, and the existing zoning for the site is Residential-Agricultural (R-A), which allows for single-family residential development.

St. Nicholas School Site
The St. Nicholas School site consists of two parcels located off El Monte Avenue with a gross area of approximately 17 acres; refer to Exhibit 4, St. Nicholas School Site. Existing uses include a school, a chapel, a parking lot, a residence used by the St. Nicholas Catholic Church, and open space. The school buildings, parking lot, and playfields encompass less than 50 percent of the total site and the facility consists of low-rise, single-story structures. The site is accessible from Voorhees Drive and El Monte Avenue. Two Santa Clara Valley Transportation Authority (VTA) bus lines (Route 40 and 52) serve the site, with stops located along the school’s El Monte Avenue frontage.

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The 6th Cycle Housing Element identifies a vacant, five-acre portion of the site located between El Monte Avenue and the campus facilities for potential development. The area is undeveloped and consists of undisturbed vegetation, including mature trees. This portion of the site has over 800 feet of frontage along El Monte Avenue and is accessible from an existing paved service road off the school access road in the western portion of the property. A separate entry gate and second access driveway, along with several internal service roads, are present in the eastern portion of the property near the intersection of El Monte Avenue and O'Keefe Lane. The access drive previously served the original estate and orchard uses on the property that have since been removed. Existing water, sewer, and other utilities are available to serve this portion of the property.

The existing General Plan land use designation for the site is Institutional Religious, Residential, and the existing zoning for the site is R-A.

Foothill Colleg e Site
The Foothill College site consists of a portion of three parcels located along El Monte Avenue with a gross area of approximately 124 acres. Access is provided via El Monte Avenue at the southern boundary of the site. Water, public sewer, and dry utilities are available on the property. The campus consists of multiple buildings, parking lots, and sports courts/fields. Surrounding uses include lowdensity residential, one faith-based facility (St. Luke’s Chapel in the Hills), and one kindergarten through 8th grade school (St. Nicholas Catholic School) within one mile of the site. This site also has access to Santa Clara VTA bus lines (Route 40 and 52) that serve Foothill Community College with several stops located on the campus as well as adjacent to the campus along El Monte Avenue. An aerial view of the site and surrounding vicinity is provided in Exhibit 5, Foothill College Site.

The existing General Plan land use designation for the site is Institutional Public School and the existing zoning for the site is R-A.

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III. PROJECT DESCRIPTION
The proposed Project would implement Program A-1 from the adopted 6th Cycle Housing Element (amended July 2025), resulting in the rezoning of at least 19 acres via the creation of two new multifamily zones. The rezone would ensure the Town has the appropriate zoning in place to achieve its RHNA requirement and a 15 percent buffer as outlined in the Housing Element. Exhibit 6, Existing Zoning, shows the current zoning of the sites identified to achieve the Town’s RHNA requirement.

The sites identified would be rezoned to one of two proposed individual zones: a multifamily zone or a multifamily overlay zone. The combined rezone and overlay zone would accommodate a minimum of 377 future residential dwelling units, as identified in the 6th Cyle Housing Element sites inventory.

Exhibit 7, Proposed Zoning, shows the proposed zoning changes that would be implemented by the Project. Specifically, the zones created, and acreages affected by the proposed Project are as follows:
x Multifamily Zone. This zone would rezone approximately 4.5 acres from the R-A zone to a new multifamily zone. The zone would permit future residential densities from 20-24 du/ac and would apply to the Twin Oaks site.
x Multifamily Overlay Zone. This overlay zone would be applied to a minimum of 15.3 acres on properties currently supporting institutional uses and zoned R-A. The overlay zone would allow residential densities from 20-24 du/ac and would apply to the Foothill College and St.

Nicholas School sites.

The multifamily zones would be adopted with Objective Design Standards that would provide for the future development of residential housing at a density of 20-24 du/ac. In addition, minor amendments to the General Plan Land Use Element would be made for consistency purposes. Both the Objective Design Standards and General Plan Land Use Element amendment are necessary to implement the schedule of actions contained in the Housing Element pursuant to subdivision (c) of Section 65583 of the Government Code and are also considered exempt from CEQA under CEQA Guidelines Section 15061(b)(3).

The zones would introduce a new housing typology (multifamily) that does not currently exist in the Town of Los Altos Hills. The three affected sites are described in detail below.

Twin Oaks Site
To implement the proposed Project, the affected parcels would be rezoned from R-A to the new Multifamily (20-24 du/ac) zone, allowing for future residential development at a minimum of 20 du/ac and up to 24 du/ac. The 6th Cycle Housing Element projects the Twin Oaks site to have a developable area of approximately 3.8 acres with a capacity of 92 dwelling units.

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A site summary, proposed zoning changes, and residential dwelling unit projections are provided in Table 1, Twin Oaks Site Details, below.

Table 1: Twin Oaks Site Details
Twin Oaks Description
Assessor Parcel Numbers 182-02-020, 182-02-021, 182-02-022 Size (gross acreage) 4.5 acres
Net Buildable/Developable Area 3.8 acres
Existing Zoning R-A
Existing General Plan Designation Single Family Residential Proposed Zoning Multifamily (20-24 du/ac)
Proposed General Plan Designation Multifamily
Maximum Yield Projection
Total Dwelling Units 92
Very Low Income 20
Low Income 10
Moderate Income 13
Above Moderate Income 49
St. Nicholas School Site
A vacant approximately 6.5-acre portion of the St. Nicholas School site would be rezoned from R-A to Multifamily Overlay, allowing residential densities of 20-24 du/ac. The 6th Cycle Housing Element identifies a projected unit capacity of 75 dwelling units for the St. Nicholas School site.

A site summary, proposed zoning changes, and residential dwelling unit projections are provided in Table 2, St. Nicholas School Site Details, below.

Table 2: St. Nicholas School Site Details
St. Nicholas School Description
Assessor Parcel Numbers 336-21-003, 336-21-004
Size (gross acreage) 17 acres
Net Buildable/Developable Area 6.5+ acres
Existing Zoning R-A
Existing General Plan Designation Institutional Religious, Residential Proposed Zoning R-A, Multifamily Overlay
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St. Nicholas School Description
Proposed General Plan Designation Institutional Religious, Residential, Multifamily Maximum Yield Projection
Total Dwelling Units 75
Very Low Income 25
Low Income 5
Moderate Income 5
Above Moderate Income 40
Foothill Colleg e Site
The Foothill College site would be rezoned from R-A to Multifamily Overlay to allow for development from 20-24 du/ac. The Project would allow Foothill Community College to develop approximately

8.8 cumulative acres on the 124-gross acre campus, as determined by the Housing Element to be the amount of acreage that could realistically be developed through redevelopment or building retrofitting without the displacement or removal of any existing on-site uses.

The 6th Cycle Housing Element identifies four existing surface parking lots, totaling approximately 8.8 acres in area, located throughout the campus property, as potential sites for future housing development. All sites can be accessed by the loop road that runs through the campus. The parking lots have access to existing utilities currently serving the campus and a lack of sensitive habitat or other environmental constraints due to their developed condition. Depending on the site and building design, a portion of the surface parking areas could be replaced with a parking structure.

The 6th Cycle Housing Element identifies a projected unit capacity of 210 dwelling units for the Foothill College site.

A site summary, proposed zoning changes, and residential dwelling unit projections are provided in Table 3, Foothill College Site Details, below.

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Table 3: Foothill College Site Details
Foothill College Description
Assessor Parcel Numbers 175-41-014, 175-41-015, 175-41-016 Size (gross acreage) 124 acres
Net Buildable/Developable Area 8.8 acres
Existing Zoning R-A
Proposed Zoning Multifamily Overlay
Existing General Plan Designation Institutional Public School Proposed General Plan Designation Institutional, Multifamily Maximum Yield Projection
Total Dwelling Units 210
Very Low Income 55
Low Income 25
Moderate Income 35
Above Moderate Income 95
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IV. CONSTRUCTION OF OIL AND GAS INFRASTRUCTURE OR A

DISTRIBUTION CENTER ANALYSIS
Public Resources Code Section 21064.8 defines “oil and gas infrastructure” as a facility used for the production, processing, transmission, storage, or distribution of petroleum or natural gas. Public Resources Code Section 21060.4 defines “distribution center” as a warehouse distribution center, as defined in Section 2100 of the Labor Code, that is 50,000 square feet or larger. As described in Section II, Project Description, the Multifamily Zone and Objective Design Standards Project does not propose construction of an oil and gas infrastructure or distribution center project. The multifamily zones would be adopted with Objective Design Standards and a Land Use Element amendment and would introduce a new housing typology (multifamily) that does not currently exist in the Town of Los Altos Hills. The multifamily zones, Objective Design Standards, and Land Use Element amendment would not allow for oil and gas infrastructure or distribution center uses. Thus, the Project would not involve zoning actions allowing the construction of oil and gas infrastructure or a distribution center, as defined by Public Resources Code Sections 21064.8 and 21060.4.

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V. NATURAL AND PROTECTED LANDS ANALYSIS
CRITERION (a) The State park system, as described in Article 1 (commencing with Section 5001) of Chapter 1 of Division 5.

The Twin Oaks, St. Nicholas, and Foothill College sites are not located within or near any established State Park.1
The nearest State park is Portola Redwoods State Park, located approximately 7 miles to the southwest of the Town in the Santa Cruz Mountains. The proposed Project location does not meet the Criterion (a) definition of natural and protected lands in this regard.

CRITERION (b) A wilderness area, as defined in Section 5093.32.

The Twin Oaks, St. Nicholas, and Foothill College sites are not located within or near any established wilderness areas.2
The nearest wilderness area is the Ventana Wilderness, located over 75 miles southeast of the Town. The proposed Project location does not meet the Criterion (b) definition of natural and protected lands in this regard.

CRITERION (c) A marine protected area, as defined in Section 2852 of the Fish and Game Code.

The Twin Oaks, St. Nicholas, and Foothill College sites are not located within or near a marine protected area, as defined in Section 2852 of the Fish and Game Code. The nearest marine protected area is the Blair Island State Marine Park, located approximately 12 miles northwest of the Town in Redwood City.3
The proposed Project location does not meet the Criterion (c) definition of natural and protected lands in this regard.

CRITERION (d) The national park system, as defined in Section 100102 of Title 54 of the United States Code.

There are no national park systems, as defined in Section 100102 of Title 54 of the United States Code, within Los Altos Hills. The nearest designated national park is Pinnacles National Park, located approximately 80 miles southeast of Los Altos Hills in the Gabilan Mountain range.4 The proposed
Project location does not meet the Criterion (d) definition of natural and protected lands in this regard.

CRITERION (e) A national recreation area.

There are no national recreation areas within Los Altos Hills. The nearest designated national recreation area is Golden Gate National Recreation Area, located approximately 38 miles to the 1 California State Parks, Park System Web Map, https://www.parks.ca.gov/?page_id=862, accessed September 2, 2025. 2 United States Department of Agriculture Forest Service, Wilderness & Wild Scenic Rivers & Wilderness Study Areas, https://data.fs.usda.gov/geodata/other_fs/wilderness/stateMap.php?stateID=CA, accessed September 2, 2025. 3 California Department of Fish and Wildlife, MPA Interactive Web Map, https://wildlife.ca.gov/Conservation/Marine/MPAs, accessed September 2, 2025. 4 National Park Service, Map Finder, https://www.nps.gov/planyourvisit/maps.htm, accessed September 2, 2025.

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northwest of Los Altos Hills in San Francisco.5 The proposed Project location does not meet the Criterion (e) definition of natural and protected lands in this regard.

CRITERION (f) A national monument.

There are no national monuments within Los Altos Hills. The nearest designated national monument is Muir Woods National Monument, located approximately 43 miles to the northwest of Los Altos Hills.6
The proposed Project location does not meet the Criterion (f) definition of natural and protected lands in this regard.

CRITERION (g) The national wild and scenic rivers system, as defined in Section 1273 of Title 16 of the United States Code.

There are no national wild and scenic rivers system, as defined in Section 1273 of Title 16 of the United States Code, in Los Altos Hills. The nearest national wild and scenic rivers system is the North Fork American River, located approximately 135 miles to the northeast of Los Altos Hills.7 The proposed Project location does not meet the Criterion (g) definition of natural and protected lands in this regard.

CRITERION (h) Any ecological reserve or wildlife management area acquired and managed by the Department of Fish and Wildlife pursuant to Article 2 (commencing with Section 1525) or Article 4 (commencing with Section 1580) of Chapter 5 of Division 2 of the Fish and Game Code.

There are no ecological reserves or wildlife management areas acquired and managed by the Department of Fish and Wildlife pursuant to Article 2 (commencing with Section 1525) or Article 4 (commencing with Section 1580) of Chapter 5 of Division 2 of the Fish and Game Code in Los Altos Hills. The nearest ecological reserve area is the Blair Island Ecological Reserve, located approximately 10 miles northwest of Los Altos Hills.8
The nearest wildlife management area is the Moss Landing Wildlife Area, located approximately 42 miles southeast of Los Altos Hills.9 The proposed Project
location does not meet the Criterion (h) definition of natural and protected lands in this regard.

CRITERION (i) A hazardous waste site that is listed pursuant to Section 65962.5 of the Government Code or a hazardous waste site designated by the Department of Toxic Substances Control pursuant to Section 25356 of the Health and Safety Code, unless either of the following apply:
5 Ibid.
6 Ibid.
7 National Park Service, Interactive Map of NPS Wild and Scenic Rivers, https://www.nps.gov/orgs/1912/plan-yourvisit.htm, accessed September 2, 2025. 8 California Department of Fish and Wildlife, Lands Viewer, https://wildlife.ca.gov/Lands/Places-to-Visit#landsviewer, accessed September 2, 2025. 9 Ibid.

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a) The site is an underground storage tank site that received a uniform closure letter issued pursuant to subdivision (g) of Section 25296.10 of the Health and Safety Code based on closure criteria established by the State Water Resources Control Board for the use proposed by the project. This paragraph does not alter or change the conditions to remove a site from the list of hazardous waste sites listed pursuant to Section 65962.5 of the Government Code.
b) The State Department of Public Health, State Water Resources Control Board, Department of Toxic Substances Control, or a local agency making a determination pursuant to subdivision (c) of Section 25296.10 of the Health and Safety Code has otherwise determined that the site is suitable for the use proposed by the project.

Government Code Section 65962.5 requires the Department of Toxic Substances Control (DTSC) and State Water Resources Control Board (SWRCB) to compile and update a regulatory sites list (pursuant to the criteria of the Section), known as the “Cortese List.” The California Department of Health Services is also required to compile and update, as appropriate, a list of all public drinking water wells that contain detectable levels of organic contaminants and that are subject to water analysis pursuant to Health and Safety Code Section 116395. Government Code Section 65962.5 requires the local enforcement agency, as designated pursuant to Section 18051 of Title 14 of the California Code of Regulations, to compile, as appropriate, a list of all solid waste disposal facilities from which there is a known migration of hazardous waste.

Health and Safety Code Section 25356 mandates that the DTSC compile and annually update a list of hazardous substance release sites subject to response actions under the California Hazardous Waste and Substance Reclamation Act. This list, included as part of the Cortese List, identifies sites requiring cleanup and is used to prioritize and manage response actions to protect human health and the environment.

A records search of the California Environmental Protection Agency (EPA) Cortese List Data Resources revealed that no hazardous waste sites exist within the Town.10 The proposed Project location does not meet the Criterion (i) definition of natural and protected lands in this regard.

CRITERION (j) Within a regulatory floodway as determined by the Federal Emergency Management Agency in any official maps published by the Federal Emergency Management Agency, unless the development has received a no-rise certification in accordance with Section 60.3(d)(3) of Title 44 of the Code of Federal Regulations.

Portions of Los Altos Hills fall into flood hazard zones as defined by the Federal Emergency Management Agency (FEMA). Exhibit 8, Los Altos Hills Special Flood Hazard Area, displays the special flood hazard areas in Los Altos Hills relative to the three rezoning sites. The vast majority of the Town 10 California Environmental Protection Agency, Cortese List Data Resources, https://calepa.ca.gov/sitecleanup/corteselist/, accessed February 22, 2024.

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falls into Zone X, which has a 0.2 percent or less annual chance of flooding; these areas are not subject to special standards.

As depicted on Exhibit 8, the Twin Oaks site and St. Nicholas School site are not located within special flood hazard zones as defined by FEMA. The Foothill College site is the only rezoning site that falls within the AE and AH zone, which indicate areas that are subject to inundation by 1 percent annual chance of shallow flooding. As described on page 209 of the 6th Cycle Housing Element, the Project does not propose development within regulatory floodways, which are water channels that directly convey stormwater and experience rapid velocities during wet weather events. According to the 6th Cycle Housing Element, while the Town has development standards for building near a creek bank, it is not considered a constraint to housing production as the flood zone areas on the campus do not overlap with the potential development sites for multifamily housing (which are limited to four existing surface parking lots). Furthermore, the Foothill College site is already disturbed with surface parking lots, and no proposed development would encroach on the adjacent creeks pursuant to §10-

1.1614, Preservation of Steep Hillsides, Ridgelines, Hilltops, and Creeks, of the Project’s proposed Objective Design Standards.

Pursuant to Public Resources Code Section 21080.085, an SB 131 statutory exemption still applies to a rezoning that contains within its boundaries any natural and protected lands as defined pursuant to Section 21067.5 if those natural and protected lands are excluded from the rezoning. Because the 6th Cycle Housing Element clearly states that the rezoning overlay does not apply to flood zone areas or floodways (6th Cycle Housing Element page 209) and §10-1.1614 of the proposed Objective Design Standards would ensure new development does not encroach onto adjacent creeks, the proposed Project location does not meet the Criterion (j) definition of natural and protected lands in this regard.

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Legend
Project Site
Town Boundary
Special Flood
Hazard Areas
(FEMA)
1% Annual Chance
Flood Hazard

0.2% Annual Chance
Flood Hazard
Regulatory Floodway
Special Floodway
Future Conditions 1%
Annual Chance Flood
Hazard
Area with Reduced Risk
Due to Levee
01 0.5
Miles Los Altos Hills Special Flood Hazard Area
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CRITERION (k) Lands under conservation easement.

There are no conservation easements within the Town of Los Altos Hills.11 According to the National Conservation Easement Database, the nearest conservation easement is located to the west of the Town in the Santa Cruz Mountains and is managed by the Midpeninsula Regional Open Space District. The proposed Project location does not meet the Criterion (k) definition of natural and protected lands in this regard.

CRITERION (l) On, or within a 300-foot radius of, a wetland, as defined in the United States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993).

The United States Fish and Wildlife (USFWS) Service Manual, Part 660 FW 2 (June 21, 1993) defines wetlands as: “lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water. For purposes of this classification, wetlands must have one or more of the following three attributes:

1. at least periodically, the land supports predominantly hydrophytes (plants specifically adapted to live in wetlands);

2. the substrate is predominantly undrained hydric (wetland) soil; and

3. the substrate is nonsoil and is saturated with water or covered by shallow water at some time during the growing season of each year.”
As shown in Exhibit 9, USFWS National Wetlands Inventory Map, the Twin Oaks site and Foothill College site are mapped by the USFWS National Wetlands Inventory as containing and/or being within a 300-foot radius of wetlands. No wetlands are mapped by the USFWS National Wetlands Inventory on or within a 300-foot radius of the St. Nicholas Catholic School site.

The USFWS National Wetlands Inventory is based on historic mapping that is updated periodically, and is not considered as accurate as field mapping. To determine the accuracy of the USFWS National Wetlands Inventory mapping on the Twin Oaks site and Foothill College site, Michael Baker’s regulatory permitting specialists reviewed the Twin Oaks site and Foothill College site against the USFWS Service Manual, Part 660 FW 2 (June 21, 1993) definition for wetlands. First, Natural Resources Conservation Service (NRCS) soils data was reviewed to determine if hydric (wetland) soil units have been mapped for the Twin Oaks site and Foothill College site and a 300-foot radius; refer to Attachment A, Twin Oaks NRCS Soils Data and Attachment B, Foothill College NRCS Soils Data.

Based on a review of the NRCS soils data, there are no mapped hydric (wetland) soils on or within a 300-foot radius of the Twin Oaks site and Foothill College site. Thus, the Twin Oaks site and Foothill College site do not satisfy the USFWS wetlands definition attribute of supporting a substrate that is 11 National Conservation Easement Database, NCED Planning Application, https://site.tplgis.org/NCED/planningapp/, accessed September 3, 2025.

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predominantly undrained hydric (wetland) soil. USFWS Wetland Attribute 2 is not satisfied in this regard.

Due to a lack of hydric soils and onsite slopes, the likelihood of hydrophytes being dominant is considered very low. Thus, the Twin Oaks site and Foothill College site do not satisfy the USFWS wetlands definition attribute of periodically supporting hydrophytes (plants specifically adapted to live in wetlands). USFWS Wetland Attribute 1 is not satisfied in this regard.

Further, review of the NRCS soil data for both sites and a 300-foot radius indicates the depth to the water table listed for most soil units present is more than 80 inches, indicating a deep water table.

Nonsoil substrate at the Twin Oaks and Foothill College sites would be organic matter that has accumulated over time on top of the soil layer(s). However, soils at and within a 300-foot radius of the Twin Oaks site and Foothill College site are non-hydric and are mapped as well-drained soils with a deep water table. Thus, the Twin Oaks site and Foothill College site do not satisfy the USFWS wetlands definition attribute of containing nonsoil substrates that are saturated with water or covered by shallow water at some time during the growing season of each year. USFWS Wetland Attribute 3 is not satisfied in this regard.

Accordingly, Michael Baker regulatory permitting specialists have concluded that water features mapped for the Twin Oaks and Foothill College sites do not meet the USFWS Service Manual, Part 660 FW 2 (June 21, 1993) definition of wetlands based on their nonhydric soil type (USFWS Wetland Attribute 2), very low likelihood of supporting hydrophytes (USFWS Wetland Attribute 1), and presence of a deep water table (USFWS Wetland Attribute 3). Rather, the mapped water features on the Twin Oaks and Foothill College sites appear to be ephemeral/intermittent drainages. For this reason, the Twin Oaks site and Foothill College site are not located on, or within a 300-foot radius of, a wetland, as defined in the United States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993).

The proposed Project location does not meet the Criterion (l) definition of natural and protected lands in this regard.12
12 It is noted that §10-1.1614, Preservation of Steep Hillsides, Ridgelines, Hilltops, and Creeks, of the Project’s proposed Objective Design Standards would protect ephemeral/intermittent drainages by ensuring no structures or grading is allowed within 50 feet of these resources, except as otherwise permitted by the California Department of Fish and Wildlife (CDFW). The Objective Design Standards would require that an applicant, property owner, or project sponsor submit a biological technical study demonstrating the presence or absence of creeks, streams, and riparian resources on the project site as a part of a development proposal. If such water resources are present based on the report, then the applicant or project sponsor would be required to submit a jurisdictional delineation report approved by CDFW identifying all jurisdictional waters of the State located on the project site.

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CRITERION (m) An environmentally sensitive area within the coastal zone, as defined in Section 30107.5.

According to the California Coastal Commission Coastal Zone Boundary, the Town is not located within a coastal zone, as defined in Section 30107.5.13 Accordingly, the proposed Project areas are not located within an environmentally sensitive area within the coastal zone. The proposed Project location does not meet the Criterion (m) definition of natural and protected lands in this regard.

CRITERION (n) Lands protected as preserve areas or reserve lands pursuant to an adopted natural community conservation plan pursuant to the Natural Community Conservation Planning Act (Chapter 10 (commencing with Section 2800) of Division 3 of the Fish and Game Code) or habitat conservation plan pursuant to the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.).

There are currently 17 approved Natural Community Conservation Plans (NCCPs) (including six subarea plans) within the state of California. There is one NCCP in Santa Clara County, the Santa Clara Valley Habitat Plan NCCP/Habitat Conservation Plan (HCP).14 The Town does not fall within the boundaries of the Santa Clara Valley Habitat Plan NCCP/HCP.15 Further, the Town does not fall within the boundaries of any HCPs pursuant to the Endangered Species Act of 1973. The proposed Project location does not meet the Criterion (n) definition of natural and protected lands in this regard.

CRITERION (o) Within a very high fire hazard severity zone, as determined by the Department of Forestry and Fire Protection pursuant to Section 51178 of the Government Code, or within the state responsibility area, as defined in Section 4102. This subdivision does not apply to sites that have adopted fire hazard mitigation measures pursuant to existing building standards or state fire mitigation measures applicable to the development, including, but not limited to, standards established under all of the following provisions or their successor provisions:
(1) Section 4291 of this code or Section 51182 of the Government Code, as applicable. (2) Section 4290.
(3) Chapter 7A (commencing with Section 701A.1) of Part 2 of Title 24 of the California Code of Regulations.
13 California Coastal Commission, Coastal Zone Boundary, https://california-coastal-commission-open-data-1-3- coastalcomm.hub.arcgis.com, accessed September 3, 2025. 14 California Department of Fish and Wildlife, California Natural Community Conservation Plans, August 2023. 15 Santa Clara Valley Habitat Agency, GIS Data & Key Maps, https://scvha.maps.arcgis.com/apps/webappviewer/index.html?id=f2268679c2fa49489e3f7d6e8377837e, accessed September 8, 2025.

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As depicted in Exhibit 10, Fire Hazard Severity Zones, the Town of Los Altos Hills is not located within a Very Fire Hazard Severity Zone (VFHSZ) or State Responsibility Area (SRA). The proposed Project location does not meet the Criterion (o) definition of natural and protected lands in this regard.

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CRITERION (p) Either prime farmland or farmland of statewide importance, as defined pursuant to the United States Department of Agriculture land inventory and monitoring criteria, as modified for California, and designated on the maps prepared by the Farmland Mapping and Monitoring Program of the Department of Conservation, or land zoned or designated for agricultural protection or preservation by a local ballot measure that was approved by the voters of that jurisdiction.

According to the California Department of Conservation, all three sites are classified as Urban and Built Up Land and are therefore not classified as prime farmland or farmland of statewide importance.16 The Twin Oaks site is zoned Residential Agricultural District (R-A). While the R-A permits agricultural uses, the site has a General Plan land use designation of Single Family Residential.

The St. Nicholas School site is zoned R-A and has a General Plan land use designation of Institutional Religious and Residential. The Foothill College site is zoned R-A and has a General Plan land use designation of Institutional Public School. As described in Section II, Project Location and Setting, none of the three rezoning sites support agricultural protection or preservation. The proposed Project location does not meet the Criterion (p) definition of natural and protected lands in this regard. 16 California Department of Conservation, California Important Farmland Finder, https://maps.conservation.ca.gov/dlrp/ciff/app/, accessed September 3, 2025.

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VI. CONCLUSION
Based on this analysis, the proposed Project meets all criteria for an SB 131 Statutory Exemption pursuant to Public Resources Code Section 21080.085. The Project would not involve zoning actions allowing the construction of oil and gas infrastructure or a distribution center, as defined by Public Resources Code Sections 21064.8 and 21060.4. Further, the Project is not located within natural and protected lands, as defined by Public Resources Code Section 21067.5. Therefore, the lead agency (the Town of Los Altos Hills) is not precluded from statutorily exempting the proposed Project from CEQA pursuant to Public Resources Code Section 21080.085.

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VII. REFERENCES
California Coastal Commission, Coastal Zone Boundary, https://california-coastal-commission-opendata-1-3-coastalcomm.hub.arcgis.com, accessed September 3, 2025.

California Department of Conservation, California Important Farmland Finder, https://maps.conservation.ca.gov/dlrp/ciff/app/, accessed September 3, 2025.

California Department of Fish and Wildlife, California Natural Community Conservation Plans, August 2023.

California Department of Fish and Wildlife, Lands Viewer, https://wildlife.ca.gov/Lands/Places-toVisit#lands-viewer, accessed September 2, 2025.

California Department of Fish and Wildlife, MPA Interactive Web Map, https://wildlife.ca.gov/Conservation/Marine/MPAs, accessed September 2, 2025.National Park Service, Map Finder, https://www.nps.gov/planyourvisit/maps.htm, accessed September 2, 2025.

California Environmental Protection Agency, Cortese List Data Resources, https://calepa.ca.gov/sitecleanup/corteselist/, accessed February 22, 2024.Federal Emergency Management Agency, FEMA Flood Map Service Center: Search By Address, https://msc.fema.gov/portal/search?AddressQuery=14414%20Saddle%20Mountain%20Dr %20Los%20Altos%20Hills%2C%20Ca, accessed September 3, 2025.

California State Parks, Park System Web Map, https://www.parks.ca.gov/?page_id=862, accessed September 2, 2025.

Federal Emergency Management Agency, FEMA Flood Map Service Center: Search By Address, https://msc.fema.gov/portal/search?AddressQuery=14414%20Saddle%20Mountain%20Dr %20Los%20Altos%20Hills%2C%20Ca, accessed September 3, 2025.

National Conservation Easement Database, NCED Planning Application, https://site.tplgis.org/NCED/planningapp/, accessed September 3, 2025.

National Park Service, Interactive Map of NPS Wild and Scenic Rivers, https://www.nps.gov/orgs/1912/plan-your-visit.htm, accessed September 2, 2025.

Santa Clara Valley Habitat Agency, GIS Data & Key Maps, https://scvha.maps.arcgis.com/apps/webappviewer/index.html?id=f2268679c2fa49489e3f7 d6e8377837e, accessed September 8, 2025.

Town of Los Altos Hills, 2023–2031 Housing Element, Amended July 2025.

Town of Los Altos Hills, Multi-Family Development Standards and Objective Design Standards – Final 7, September 16, 2025.

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United States Department of Agriculture Forest Service, Wilderness & Wild Scenic Rivers & Wilderness Study Areas,
https://data.fs.usda.gov/geodata/other_fs/wilderness/stateMap.php?stateID=CA, accessed September 2, 2025.

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Attachment A
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TOWN OF LOS ALTOS HILLS March 12, 2025
Staff Report to the Planning Commission
SUBJECT: UPDATE ON AD HOC COMMITTEE ACTIVITIES AND
RECOMMENDATIONS FOR THE AMENDMENT OF THE 6TH CYCLE
HOUSING ELEMENT.

FROM: Jay Bradford, Community Development Director
RECOMMENDATION:

That the Planning Commission receive and provide direction on the recommended approaches for amendment and modification of the 6th Cycle Housing Element.

BACKGROUND
The 6th Cycle Housing Element is a key component of the Town's General Plan, guiding the development and preservation of housing over an 8-year period (2023–2031). The Housing Element must comply with state laws, including policies established by the California Department of Housing and Community Development (HCD), which sets regional housing needs allocations (RHNA). The Town of Los Altos Hills is required to accommodate a specific number of housing units based on its RHNA.

The Town’s initial draft Housing Element was submitted to HCD for review and certification with the final document being adopted on January 30th, 2023, and certified by HCD on May 30, 2023. The implementation remains ongoing as the Community Development Department develops the programs contained in the element. In August of 2024, the Community Development Department published a Notice of Preparation (NOP) for a programmatic-level Environmental Impact Report (EIR) on the rezoning of the housing opportunity sites including the location adjacent to Twin Oaks Court. In addition to the study there were the subsequent series of meetings and community engagement events resulted in requests to amend the housing element. A concurrent effort led to the creation of a Key Terms Agreement with the owners of Twin Oaks Court which would have been the basis for a development agreement with the town to limit the impacts expressed as the need to amend the housing element. Ultimately the City Council decided to remain silent on the key terms agreement and instead created an ad hoc committee at the January 28th, 2025, City Council meeting. This ad hoc committee is composed of council members and Town residents to discuss a revision and amendment to the Housing Element which would modify the total proposed scope of development at the Twin Oaks site.

Since its creation, the ad hoc committee has met weekly to discuss a variety of approaches to amending the Housing Element with input from residents, the Town’s Housing Element consultants, representatives from HCD, and Town Council members and staff.

DISCUSSION:

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Planning Commission Page 2
Recommendations for the Amendment of the 6th Cycle Housing Element March 12, 2025
actionable plan that accommodates the Town’s housing needs and objectives. The Town of Los Altos Hills is committed to preserving its semi-rural character and protecting its unique environmental assets while meeting the state’s housing requirements. The proposed amendment to the Housing Element is designed to balance these priorities by incorporating flexibility in zoning and development strategies, while also addressing the need for more affordable and diverse housing options within the community.

The approaches in amending the Housing Element are presented by Town residents, Michael Baker International, and City Council members.

Option 1: John O’Connell Approach
The first option in modifying the Housing Element is presented by Los Altos Hills resident John O’Connell through discussion with the ad hoc committee. This approach adjusts the metric used to determine density on the subject parcels at Twin Oaks. The proposal is to adjust the density on the site from dwelling units per acre, which currently set at 20-30 units/acre in the current Housing Element, to square footage per acre and the creation of two classifications of rezoning in the form of R4 zoning (base) and R20. Under this approach, factors such as slope would be more heavily factored into the eligibility and development standards for multifamily zoning with lower slopes (less than or equal to 15%) being eligible for higher density zoning (R20).

Under this proposal, R4 zoning would require a maximum number of residential structures to be capped at 4 units/acre with a maximum number of residential units in the above-moderate income category set at 4*Lot Unit Factor (LUF). This proposal includes the Density Bonus units based on the percentage of lower and moderate-priced units included in the project totals. To accommodate lower-income units, a new “R20 zoning” classification would be placed on portions of lots 3, 5, and 6.

R20 zoning would incorporate R4 parcels which sit on a slope less than or equal to 15%. The maximum size of residential structures would be set at 2,000 square feet on “R20 site” yielding a total of ~22 units per acre to facilitate densities deemed suitable for lower-income housing. The Density Bonus units would then be based upon % of lower & moderate-income units included.

The resulting land use formulas for the sites would be: “R20 site” area(s) ≥ 0.5 LUF on parcels, lots or “site(s)” ≤ 15% gradient. R20 unit capacity = “R20 site” LUF*43,560/2,000.

The proposal centers on implementing an R4 standard on all seven Twin Oaks parcels resulting in 42 units before Density Bonus which under the assumptions of this proposal would meet the ITEM 7A ATTACHMENT 6

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Planning Commission Page 3
Recommendations for the Amendment of the 6th Cycle Housing Element March 12, 2025
RHNA allocation for the Town. Per this recommendation, this could result in 63 to 84 units being built after density bonus is factored in. R4 zoning would include the density bonus incentive mechanism to provide for the small number of some lower-income units required once the Housing Element amendment is complete. R4 zoning applied to the Housing Element Program A-12 would streamline this program to convert single-family housing to duplexes and triplexes for the approximately 50 sites specified and create approximately 100 of the required above-moderate- and moderate-income units.

This approach additionally recommends that changes be made to the existing land use element of the general plan to match zoning standards for all residential uses and establish the application pipeline for all R4 and R20 project submittals. This approach relies on the use of current ADU stock to count towards total RHNA allocation and a continuation of the same rate of ADU development for a total of 200 units over the course of the 8-year planning period.

Option 2: Michael Baker International Approach
Michael Baker International, the Town’s consultant which prepared the originally adopted Housing Element, has considered community feedback as well as input from the City Council, Town attorney, staff, and HCD in the preparation of another approach to amending or modifying the adopted Housing Element. The MBI approach factors in a prospective Land Use Element amendment, a Housing Element amendment, as well as upcoming multi-family zone and objective design standards with the combined result of compliance with state laws for multi - family housing and provide consistency with Town regulatory documents such as existing zoning law and standards.

The MBI approach focuses on reduction of maximum development potential (total units) while still meeting Housing Element RHNA unit commitments. This leaves the amendment option to reduce zoning acreage (from 14.5 to 4-5 acres) and reduction in maximum allowable base density from 30 du/ac to 24 du/acre as shown in the diagram below:

The MBI approach cites the following elements of state law as the basis for the modification approach:
65583.2 (h)(2): establishes the absolute minimum density of any rezone required to meet a RHNA shortfall – 20 du/ac for Suburban communities like Los Altos Hills. • “(2) These sites shall be zoned with minimum density and development standards that permit:
• at least 16 units per site …
• shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c) …” ITEM 7A ATTACHMENT 6

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Recommendations for the Amendment of the 6th Cycle Housing Element March 12, 2025
• There is no provision that allows for an alternative to this minimum density. 65583.2(c)(3)(B): sets the minimum allowable maximum density (e.g., 20 du/ac in Los Altos Hills).
• This provision allows a city to argue for less than the otherwise established minimum allowable maximum zoning density. For example, a city could argue for a maximum density of 28 du/ac instead of the standard 30 du/ac.
• This is not applicable in Los Altos Hills since the minimum allowable maximum density under Section 65583.2(c)(3) is 20 du/ac and the maximum density must be reasonably greater than the absolute minimum density of 20 du/ac (e.g., 24 du/ac)
This yields the following re-allocation of units in a revised approach to multifamily zoning:

This approach creates a new building placement concept through with a newly established Minimum Lot Size of approximately 4 acres, a height limitation of 50 ft (4 stories above ITEM 7A ATTACHMENT 6

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Planning Commission Page 5
Recommendations for the Amendment of the 6th Cycle Housing Element March 12, 2025
parking) and front, side, and rear setback lines set at 60ft. The MBI approach keeps the scope of change limited to the Twin Oaks opportunity sites without involving nearby parcels.

Option 3: Development Agreement Approach
This approach relies on the first two options, so it is additive. In the time since the AD Hoc committee was created the Town has received a preliminary SB-330 density bonus application.

For some 596 units at the Twin Oaks site. The proposed project far exceeds what is discussed in the housing element and was planned for implementation. This application in many ways represents the concerns voiced by the neighbors of the Twin Oaks site, who have focused on the density and total units considered in the new multifamily zones.

While the housing element amendments will provide an updated distribution of new units across the Twin Oaks site with lower maximum unit potentials, and a Development Agreement could offer relief from the application’s overall density and total number of units but that the town may need to make concessions that benefit the developer to secure the assurances for the town. This option was discussed during an update to the City Council at the February 20th meeting, but the Ad Hoc Committee Listening Sessions held on March 4th and 9th are the first-time details for those new discussions were shared with the public.

ANALYSIS
Through various public engagement events and the creation of the AD Hoc the town has spent hundreds of hours reviewing, discussing, and acting on resident feedback to ensure the intent of the housing element matches the community need. The most recent series of AD Hoc public listening sessions presents the most recent efforts regarding proposals to address concerns in multifamily and affordable housing development.

It’s important to note that these options come from multiple sources, and each have their own merits. Some of the options are more theoretical while others are steeped in past practice. For the options based on past practice there is some understanding of HCD’s expectations. For the other options, additional feedback from HCD is needed to ensure that unforeseen conflicts are mitigated prior to moving forward with a less tested option. To that end HCD has been contacted and there has been initial feedback provided by HCD. However, the full approach or impact of options has not been vetted with the agency in totality. This leaves some uncertainty in some of the options.

To that end, additional coordination with HCD is recommended, but from the initial feedback it appears a blending to the approaches appears to be the most viable options. The blended option would take the amendment to HE terminally from option 1, paired with the site area reduction in option 2, and using zoning options in option 1 and 2. All while continuing effort on option 3.

The third option for the amendment of the Housing Element involves a combination of approaches and the creation of a development agreement between the owners of the Twin Oaks site, the adjacent Fenwick property, and the Town to develop the ITEM 7A ATTACHMENT 6

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Planning Commission Page 6
Recommendations for the Amendment of the 6th Cycle Housing Element March 12, 2025

FISCAL IMPACT
The fiscal impact of the proposed amendments is thought to range from $100,000 to $200,000, as in some options the Town would be undertaking large-scale revision to the Housing Element.

Additionally, future implementation of the Housing Element may involve costs associated with infrastructure improvements, potential permitting expenditures for new development, staff time and consultant time for the administration of updated housing programs. These costs will be assessed in subsequent budgeting cycles.

NEXT STEPS

1. Planning Commission Review and Recommendation: Prior to proceeding to the City Council for a public hearing, the Planning Commission would provide direction on their recommendation for which approach to take in amending the Housing Element.

2. Council Review and Adoption:

The City Council is requested to review the proposed amendments and approve revised Housing Element. A public hearing will be scheduled to gather additional feedback and ensure that all community concerns are addressed before adoption.

3. Submission to HCD for Certification:

Once adopted by the City Council, the amended Housing Element will be resubmitted to the California Department of Housing and Community Development (HCD) for final review and certification.

4. Implementation of Revised Strategies:

After certification by HCD, the City will begin implementing the revised strategies outlined in the Housing Element, including potential zoning adjustments, outreach to developers, and ongoing community outreach.

ATTACHMENTS

1. Attachment 1: Presentation from John O’Connell, Los Altos Hills Resident

2. Attachment 2: Presentation from Dan Wery, Michael Baker International

3. Attachment 3: Presentation from Vice-Mayor Rajiv Bhateja Report prepared by: Jay Bradford, Community Development Director ITEM 7A ATTACHMENT 6

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THE TOWN OF LOS ALTOS HILLS May 1, 2025
Staff Report to the Planning Commission
SUBJECT: Discussion and Direction on Multi-Family Zoning and Objective Design Standards
Review and discuss Michael Baker International’s presentation on the Housing Element’s Multi-Family Zone and Objective Design Standards.

CEQA Review: Consider exemption pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15061(B)(3).

FROM: Jay Bradford, Community Development Director
RECOMMENDATION: That the Planning Commission takes the following actions:

Review and discuss Michael Baker International’s presentation on the Housing Element’s MultiFamily Zone and Objective Design Standards, and provide consensus on the guiding principles, content, and general parameters of the Town’s Multi-Family Zone and Objective Design Standards.

This item is informational only for the Planning Commission to review, discuss, and provide additional direction and feedback on the Town’s Multi-Family Zone and Objective Design Standards to the Planning Consultant, Michael Baker International.

BACKGROUND
At the January 28th, 2025 City Council meeting, an Ad Hoc committee composed of Vice Mayor Bhateja and Councilmember Mok was created to study an amendment to the Housing Element that would modify the total proposed scope of development at the Twin Oaks site. From January through March 2025, the Ad Hoc committee met weekly to discuss various approaches to amending the Housing Element with input from residents, the Town’s Housing Element consultants, representatives from HCD, two Council Members and staff.

Following its formation, the Housing Element amendment Ad Hoc committee conducted meetings with residents, consultants, and staff to discuss approaches to amending or modifying the Housing Element as well as technical feasibility for approvable options to present to HCD. The Ad Hoc Committee held listening sessions to receive resident feedback on the Housing Element amendment on March 4th and March 9th, 2025.

Three approaches emerged from these discussions including recommendations from Los Altos Hills resident John O’Connell, Town housing consultant Michael Baker International, and an approach that involved negotiations with the Twin Oaks property owners where terms of development are considered in a binding voluntary legal agreement. The legal agreement approach is commonly referred to as the development agreement.

ITEM 7A ATTACHMENT 7

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Planning Commission Page 2
Discussion and Direction on Multi-Family Zoning and Objective Design Standards May 1, 2025
On March 20, 2025, the City Council approved specific directions on how to proceed with the amendment to the Housing Element and directed staff to expand the scope of work to include amending the Land Use Element. The council made the following motions:
 Council Member Swan made a motion to only use the Michael Baker approach for amending the Housing Element. Council Member Tyson seconded the motion. The motion was approved, 4-1. Mayor Tankha voted in opposition.
 Council Member Swan made a motion directing the Ad Hoc to continue to negotiate the Development Agreement. Vice Mayor Bhateja seconded the motion. The motion was approved, Vote 5-0
 Council Member Tyson made a motion directing staff to prepare a Zoning Ordinance for Lots in compliance with the proposed Development Agreement terms. Meanwhile creating the MFZ for the Zoning Ordinance (ZO) and Objective Design Standards (ODS) for said Zoning Ordinance and the Land Use Element And prepare the EIR consistent with the Zoning Ordinance and Objective Design Standards, the Land Use Element, Housing Element amendment, and proposed Development Agreement terms. Council Member Swan seconded the motion. The motion was approved, Vote 5-0 The Council-directed Michael Baker International (MBI) approach to amend the Housing Element focuses on a reduction of maximum development potential (total units) at the Twin Oaks site while still meeting RHNA unit commitments. This amendment would focus on reducing the acreage proposed at the Twin Oaks site (from 14.5 to 4-5 acres) and reduce the maximum allowable base density from 30 du/ac to 24 du/ac.

The presentation, given by the Town’s consultant, Michael Baker International, will outline the guiding principles, objectives, and framework for developing the Town of Los Altos Hills’ new Multi-Family Zone and its Objective Design Standards, while incorporating the proposed Housing Element amendments.

Michael Baker International will also present the key elements of the Town of Los Altos Hills’ Multi-Family Zoning District’s Objective Design Standards. The draft standards can be found in Attachment 1. The presentation demonstrates how the Objective Design Standards will work with the Town of Los Altos Hills’ proposed Multi-Family Zoning District and identify the key elements that will be included in the Objective Design Standards. The Town’s current land use, zoning, residential building guide, and other development policies for the Residential-Agricultural District (R-A) Zoning District were reviewed for applicability for multi-family housing to determine which existing standards can be incorporated, which standards are required to change, and which will be entirely new for the Multi-Family Zoning District.

CALIFORNIA ENVIRONMENTAL QUALITY ACT
Staff recommends that the proposed actions are considered exempt pursuant to CEQA Guidelines Section 15061(B)(3) as the informational session and the presentation has no potential to create any physical changes on the environment.

ITEM 7A ATTACHMENT 7

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Discussion and Direction on Multi-Family Zoning and Objective Design Standards May 1, 2025

RECOMMENDATION
Staff recommends that the Planning Commission receive the informational Michael Baker International’s presentation, and review, discuss, and provide additional direction and feedback regarding the Town’s Draft Multi-Family Zone and its Objective Design Standards.

ATTACHMENTS

1. Multi-Family Development Standards and Objective Design Standards [DRAFT] Staff Report Prepared by: Jonathan Fox, Associate Planner ITEM 7A ATTACHMENT 7

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THE TOWN OF LOS ALTOS HILLS June 5, 2025
Staff Report to the Planning Commission
SUBJECT: Discussion and Direction on Multi-Family Zoning and Objective Design Standards
Review and discuss Michael Baker International’s presentation on the Housing Element’s Multi-Family Zoning and Objective Design Standards.

CEQA Review: Consider exemption pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15061(B)(3).

FROM: Jay Bradford, Community Development Director
RECOMMENDATION: That the Planning Commission takes the following action:

Review and discuss Michael Baker International’s presentation on the Housing Element’s MultiFamily Zoning and Objective Design Standards (Draft – Version 2). This item is informational only for the Planning Commission to review, discuss, and provide additional direction and feedback on the Town’s proposed Multi-Family Zoning and Objective Design Standards.

BACKGROUND
At the May 1st, 2025, Planning Commission meeting, Michael Baker International (MBI) presented the first draft of the Multi-Family Zoning and Objective Design Standards (Attachment 3). After receiving public comments, the Commission provided feedback on the draft standards, including the overall organization, addition of graphics, and clarification of definitions.

This discussion and the approaches considered were also impacted by actions taken by the City Council at its May 15, 2025, meeting. Several actions related to the Housing Element, including terminating the Development Agreement discussions with the owners of the Twins Oaks multifamily opportunity site, which was followed up with sunsetting of the Housing Element Ad Hoc Committee, and directions to staff to begin exploring alternative opportunity sites for multifamily zoning. Staff was directed to continue to facilitate the Housing Element amendment to reduce the maximum development potential (total units) at the Twin Oaks site while still meeting RHNA unit commitments. This amendment would focus on reducing the acreage proposed at the Twin Oaks Site (from 14.5 to 4-5 acres) and reduce the maximum allowable base density from 30 du/ac to 24 du/ac. This corresponds with a rezoning of Twin Oaks Lots 4, 5, and 6 to multi-family (Attachment 7).

DISCUSSION
The Planning Commission and City Council direction reinforced earlier recommendations from MBI and will allow for a streamlined approached to zoning. Council direction allows the Planning Commission, through the work with MBI, to focus on Lots 4, 5, and 6 of the Twin Oaks Property which impacts the range of design options considered in the Objective Design Standards. This means there may be additional changes needed to standards that were broadened to allow for more flexibility when considering design and construction on alternate lots of the Twin Oaks property that included steeper slopes and limited locations for development. That brings us back to the ITEM 7A ATTACHMENT 8

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Discussion and Direction on Multi-Family Zoning and Objective Design Standards June 5, 2025
direction provided by the Planning Commission at the May 1st meeting where key feedback was provided by the planning commission to staff and MBI.

Key feedback included directions to:
• streamline the document and to not repeat existing Town standards in MF zone and ODS. • remove the Equivalent Dwelling Unit (EDU) concept and pursue other methods to encourage smaller units without the need to increase density. • decrease the average size per dwelling unit.
• provide graphics to help visualize the massing and placement of buildings using the proposed zoning and ODS.
• limit or prohibit structures on hillside and ridgelines. • incorporate local design principles into the ODS.

Attachment 2 provides a detailed chart that organizes responsesto 91 comments by Commissioners by topic, comment, preliminary response, and recommended change. This matrix served as a guide to further refine the draft MFZ-ODS consistent with the direction by the Commissioners. MBI has prepared a 2nd draft of the MFZ-ODS (Attachment 4) for the Planning Commission to discuss.

Attachment 5 (redlined version) identifies the changes between V1 and V2.

NEXT STEPS
MBI will incorporate any additional revisions resulting from public feedback and direction from the Planning Commission at the June 5, 2025, meeting into a Version 3 (V3) draft for discussion at the July meeting. Then, the draft Programmatic Environmental Impact Report (PEIR), MFZ, ODS, and Land Use Element Update (LUE), will undergo a 45-day public review period between July and September 2025. Staff is anticipating that the Planning Commission will formally review the finalized documents in November 2025. The full Housing Element, MFZ, ODS, LUE schedule is provided as Attachment 6.

RECOMMENDATION
Staff recommends that the Planning Commission receive the informational Michael Baker International’s presentation, and review, discuss, and provide additional direction and feedback regarding the Town’s new Multi-Family Zone and its Objective Design Standards.

ATTACHMENTS

1. May 1, 2025 Planning Commission Recorded Meeting [LINK]

2. May 1, 2025 Planning Commission Response to Comments Matrix

3. Multi-Family Development Standards and Objective Design Standards [DRAFT] V1

4. Multi-Family Development Standards and Objective Design Standards [DRAFT] V2

5. Multi-Family Development Standards and Objective Design Standards [DRAFT] V2 Redlined ITEM 7A ATTACHMENT 8

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Discussion and Direction on Multi-Family Zoning and Objective Design Standards June 5, 2025

6. Housing Element, MFZ, ODS, LUE Schedule

7. Twin Oaks Zoning Map [DRAFT]
Staff Report Prepared by: Jonathan Fox, Associate Planner ITEM 7A ATTACHMENT 8

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THE TOWN OF LOS ALTOS HILLS
Staff Report to the Planning Commission
July 10, 2025
SUBJECT: Discussion and Direction on Multi-Family Zoning and Objective Design Standards
Review and discuss Michael Baker International’s presentation on the Housing Element's Multi-Family Zoning and Objective Design Standards.

CEQA REVIEW: Consider exemption pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15061(8)(3).

FROM: JayBradford, Community Development Director

RECOMMENDATION
That the Planning Commission takes the following action:

Review and discuss Michael Baker International’s presentation on the Housing Element's MultiFamily Zoning and Objective Design Standards (Draft - Version 3). This item is informational only for the Planning Commission to review, discuss, and provide additional direction and feedback on the Town's proposed Multi-Family Zoning and Objective Design Standards (MFZODS).

BACKGROUND
The first study session to review the MFZ-ODS was held at the May 1, 2025, Planning Commission meeting (Attachment 1). Michael Baker International (MBI) presented the initial draft (Version 1 or V1) of the proposed standards and received feedback that informed subsequent revisions.

The development of the ODS were moved forward by City Council action at the May 15, 2025 City Council meeting, where the Council voted to suspend several alternative approaches that were under consideration as part of the multifamily rezoning efforts. As part of this direction, the Council also approved a reduction in the site area of the Twin Oaks multifamily opportunity site, impacting and narrowing the scope of both the adopted Housing Element and the draft versions of MFZ-ODS.

MBI returned to the Planning Commission on June 5, 2025 (Attachment 2) with a revised version of the MFZ-ODS (Version 2 or V2). They also provided a response to comments matrix that summarized how previous feedback from the Commission and Committees had been addressed. A similar format has been used for this meeting. Attachment 3 includes an updated comment matrix, while Attachments 4 and 5 provide Versions 2 and 3 of the MFZ-ODS for comparison.

ITEM 7A ATTACHMENT 9

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Discussion and Direction on Multi-Family Zoning and Objective Design Standards July 10, 2025

DISCUSSION
The Planning Commission and City Council direction reinforced earlier recommendations from MBI and will allow for a streamlined approach to zoning. Council direction allows the Planning Commission, through the work with MBI, to focus on the development of standards for multifamily development which can be applied to all the opportunity sites identified in the Housing Element.

Attachment 3 provides a matrix that organizes and responds to 102 comments from Commissioners, categorized by topic, individual comment, preliminary response, and recommended change. This matrix served as a guide to further refine the draft MFZ-ODS in line with the direction provided by the Commission.

Key feedback from the June 5th Planning Commission presentation focused on:
• Preparing a revised comment response matrix (Attachment 3) • Provide further details on realistic proposed unit mixes to reflect common development scenarios
• Further streamlining of the standards to eliminate redundancies from the existing code. • Further clarification for definitions around terms such as height, screening, and ridgelines. • Specify handling of historic sites, open spaces, exemptions, and reduce potential inconsistencies with existing general plan policies around these sites. • Create more specificity around signage, landscape screening, grading, mechanical equipment location, and other exterior design elements
• Provide more clarity on the project review pipeline for multifamily units.

MBI has prepared a third draft of the MFZ-ODS, included as Attachment 5, for Planning Commission discussion. Attachment 5 is a redlined version of the document, showing changes made between Versions 2 and 3.

In Version 3 of the MFZ-ODS, MBI provided more detail on Contiguous Buildable Area (CBA).

This measurement refers to the area of a site with a minimum dimension not less than 50 feet wide (reduced from 75 feet wide in V2) and excluding areas of steep slopes greater than 25% measured over a minimum horizontal distance of 25 feet. This revised standard functionally reduces the buildable area of both the Saint Nicholas School opportunity site as well as the Twin Oaks site. While the total units may still be possible, the exact placement on the site of these units would be more limited. The heightened threshold for slope construction has been factored into Version 3 of the draft ODS.

NEXT STEPS
MBI will incorporate any additional revisions resulting from Planning Commission and public feedback received at the July 10, 2025 meeting into a Version 4 (V4) draft. That version will be used in the preliminary Programmatic Environmental Impact Report (PEIR), the MFZ-ODS, and the Land Use Element (LUE) Update. These documents will be subject to a 45-day public review ITEM 7A ATTACHMENT 9

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Discussion and Direction on Multi-Family Zoning and Objective Design Standards July 10, 2025
period between July and September 2025.

Staff anticipates that the Planning Commission and City Council will formally review the finalized documents in November 2025. The full schedule for the Housing Element, MFZ-ODS, and LUE update is included as Attachment 6.

CALIFORNIA ENVIRONMENTAL QUALITY ACT
Staff recommend that the proposed actions are considered exempt pursuant to CEQA Guidelines Section 15061(B)(3) as the infom1ational session and the presentation has no potential to create any physical changes on the environment.

ATTACHMENTS

1. Recording of the May 1st, 2025 Planning Commission meeting [LINK]

2. Recording of the June 5th 2025 Planning Commission meeting [LINK]

3. July 10, 2025, Planning Commission Response to Comments Matrix

4. Multi-Family Development Standards and Objective Design Standards [DRAFT] V2

5. Multi-Family Development Standards and Objective Design Standards [DRAFT] V3 Redlined

6. Housing Element, MFZ, ODS, LUE Schedule
Staff Report Prepared by: Tim McBirney, Community Development Analyst ITEM 7A ATTACHMENT 9

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THE TOWN OF LOS ALTOS HILLS
Staff Report to the Planning Commission
July 24, 2025
SUBJECT: Discussion and Direction on Amendments to the Adopted 6th Cycle Housing Element and Land Use Element and creation of Multi-Family Zoning and Objective design Standards
Review and continue discussion of Michael Baker International’s presentation on the amended Housing Element and Land Use Element and creation of Multi-Family Zoning and Objective Design Standards.

CEQA REVIEW: Consider exemption pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15061(8)(3).

FROM: JayBradford, Community Development Director

RECOMMENDATION
That the Planning Commission review and discuss Michael Baker International’s (MBI) presentation on the Housing Element and Land Use Element Amendments (Attachments 1 and 2), as well as the Multi-Family Zoning and Objective Design Standards (MFZ-ODS) (Draft – Version 4). This is an informational item intended to provide the Planning Commission with an update on the progress of the Housing Element and Land Use Element amendments and to solicit feedback on the ongoing MFZ-ODS efforts.

BACKGROUND
In 2024, the Town began implementation of its 6th Cycle Housing Element. As part of this effort, staff initiated work on several programs identified in the Housing Element implementation schedule, including development of MFZ-ODS. During the third quarter of 2024, as initial discussions on the MFZ-ODS began, community feedback raised broader concerns that prompted a reevaluation of the existing programs and overarching goals of the Housing Element, including the consideration of zoning alternatives.

At its regular meeting on April 17, 2025 (Attachment 3), the City Council voted to proceed with an amendment to the adopted Housing Element and authorized a $256,000 contract extension for MBI. This action expanded MBI’s scope to include preparation of the Housing Element Amendment (HEA), while continuing support for implementation of the multifamily zoning program.

Development of the MFZ-ODS began with a study session at the May 1, 2025, Planning Commission meeting (Attachment 4), where MBI presented the initial draft (Version 1). The Commission provided feedback that informed subsequent revisions.

At its May 15, 2025, meeting, the City Council voted to streamline the multifamily zoning program by suspending several alternative zoning approaches previously under consideration. As part of ITEM 7A ATTACHMENT 10

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Discussion and Direction on the Housing Element Amendment and Multi-Family Zoning Objective Design Standards
July 24, 2025
this direction, the Council also approved a reduction in the site area for the Twin Oaks multifamily opportunity site. These changes narrowed the scope of both the adopted Housing Element and the MFZ-ODS, and have since been incorporated into the draft Housing Element Amendment.

MBI returned to the Planning Commission on June 5, 2025 (Attachment 5), with a revised draft of the MFZ-ODS (Version 2), along with a response-to-comments matrix summarizing how feedback from the Commission and Town Committees had been addressed. A third draft (Version 3) was presented at the July 10, 2025, Planning Commission meeting (Attachment 6), which included additional updates and an overview of the revised response matrix.

DISCUSSION
To address City Council direction and maintain alignment with the Housing Element implementation schedule, staff and Michael Baker International (MBI) have prepared draft amendments to both the adopted 6th Cycle Housing Element and the Land Use Element. The Housing Element Amendment (HEA) reflects a reduced development strategy for the Twin Oaks multifamily opportunity site, while the Land Use Element Amendment (LUEA) provides the supporting policy framework for the Multifamily Zoning and Objective Design Standards (MFZODS) and complements the broader zoning efforts.

Housing Element Amendment (HEA)
The HEA primary changes include:
• Reducing the maximum density on the Twin Oaks site from 30 to 24 du/ac of Contiguous Buildable Area.
• Limiting the rezoning area to Lots 4–6 of Twin Oaks, the front portion of St. Nicholas School, and a minimum of 8.8 acres of CBA at Foothill College.
• Redistributing the previously projected 92 units across the revised portions of the Twin Oaks site.

Land Use Element Amendment (LUEA)
The LUEA redlines focus on implementing the new MF zoning consistent with Program A-1 of the Housing Element. The amendments define the location, rationale, and context for establishing the new MF land use designation, and introduce key components of the zoning standards:
• Permitted uses
• Density: 20–24 du/ac based on Contiguous Buildable Area, excluding slopes over 25% • Height limits and exceptions
• Setbacks from adjacent zones
• Maximum floor area
• Minimum lot size (3.5 acres for MF development over 20 du/ac) • Use of overlay zoning to enable MF development on portions of the St. Nicholas School and Foothill College sites
ITEM 7A ATTACHMENT 10

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Discussion and Direction on the Housing Element Amendment and Multi-Family Zoning Objective Design Standards
July 24, 2025
The amendments maintain flexibility where needed (e.g., using “generally” for setbacks) and clarify that MF uses would occur on underutilized portions of school properties without displacing existing uses. The narrative was amended only where necessary to support the MF zoning framework, preserving the broader structure of the General Plan Land Use Element as last updated in 2005.

Mapping Updates
Minor refinements are underway for both the HEA and LUEA maps. These will reflect a more precise zoning boundary on the St. Nicholas School site to maintain a minimum 25-foot buffer from existing structures, consistent with the proposed MF zoning standards. Revised maps will be provided with the next revision to the MFZ-ODS.

MFZ-ODS
The Town remains on track to meet the January 31, 2026, deadline for multifamily zoning implementation. As part of this effort, MBI has prepared Version 4 of the draft MFZ-ODS for discussion at the July 24, 2025, special Planning Commission meeting (Attachment 7). This draft incorporates all requested revisions from the July 10, 2025 Planning Commission meeting and integrates comments received from Claire on July 17, based on her review of the third draft (dated June 27, 2025).

Version 4 of the MFZ-ODS includes tracked changes from the previous draft. The majority of updates are clarifications or refinements rather than major strategic changes. Notable revisions include:
• Defining the new “Floating MF Overlay” (MFO) zone.
• Replacing “high density” with a specified range of 20–24 dwelling units per acre (du/ac) of Contiguous Buildable Area.
• Clarifying the relationship of the MFZ to Title 10, including where provisions are exempt, superseded, or in conflict.
• Revising language to enhance clarity, reduce redundancy, and align with state law and Town objectives (e.g., redefining screening, removing outdated references, and refining development standards for unit sizes, setbacks, recreation space, lighting, fences, and color compatibility).

The revised MFZ-ODS retains certain standards (e.g., hillside and riparian protections) that are not currently addressed elsewhere in the Municipal Code but are limited in application to multifamily uses. Other topics discussed—such as fire safety, viewshed protection, or landscape maintenance— were not addressed in this draft because they are not unique to multifamily uses and are more appropriately addressed through Town-wide regulations.

MBI will incorporate feedback from the July 24, 2025, meeting into a final draft for formal Planning Commission review and recommendation at a regular meeting in August or September.

The final version will then be presented to the City Council for consideration in the fall, prior to submittal to the California Department of Housing and Community Development (HCD).

ITEM 7A ATTACHMENT 10

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Discussion and Direction on the Housing Element Amendment and Multi-Family Zoning Objective Design Standards
July 24, 2025

ATTACHMENTS

1. 6th Cycle Housing Element Draft Amendment (redlines)

2. Land Use Element Draft Amendment (redlines)

3. Recording of the April 17th, 2025 City Council meeting [LINK]

4. Recording of the May 1st, 2025 Planning Commission meeting [LINK]

5. Recording of the June 5th 2025 Planning Commission meeting [LINK]

6. Recording of the July 10th, 2025 Planning Commission Meeting [LINK]

7. Multi-Family Zoning and Objective Design Standards(Draft - Version 4) (redlines) Staff Report Prepared by: Tim McBirney, Community Development Analyst ITEM 7A ATTACHMENT 10

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THE TOWN OF LOS ALTOS HILLS
Staff Report to the Planning Commission
August 7, 2025
SUBJECT: Discussion and Direction on Amendments to the Adopted 6th Cycle Housing Element and Land Use Element and creation of Multi-Family Zoning and Objective Design Standards
Review and continue discussion of Michael Baker International’s presentation on the amended Housing Element and proposed Multi-Family Zoning and Objective Design Standards.

CEQA REVIEW: Consider exemption pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15061(8)(3).

FROM: Jay Bradford, Community Development Director

RECOMMENDATION
That the Planning Commission review and discuss Michael Baker International’s presentation on the draft amended Housing Element and continue the study and review of the Multi- Family Zoning and Objective Design Standards (Draft - Version 5). This item is informational only for the Planning Commission to review, discuss, and provide additional direction and feedback on the Town's ongoing Housing Element Amendment process and the proposed Multi-Family Zoning and Objective Design Standards (MFZ-ODS), .

BACKGROUND
The City Council voted to proceed with an amendment to the adopted Housing Element at the April 17, 2025, City Council regular meeting (Attachment 1). Mchael Baker International (MBI) is assisting in Housing Element implementation and the creation of an amended Housing Element Document to make key changes to the scope of multifamily development in alignment with resident feedback and City Council discussion. There were two primary and parallel tasks within MBI scope of work: creation of the amendment, and the production of MFZ-ODS for the proposed multifamily zoning which was included in the Housing Element. The first study session to review the MFZ-ODS was held at the May 1, 2025, Planning Commission meeting (Attachment 2). Michael Baker International (MBI) presented the initial draft (Version 1) of the proposed standards and received feedback that informed subsequent revisions.

ITEM 7A ATTACHMENT 11

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Discussion and Direction on the Housing Element Amendment and Multi-Family Zoning Objective Design Standards
August 7, 2025
These changes in scope have been reflected in the draft Housing Element amendment document.

MBI returned to the Planning Commission on June 5, 2025 (Attachment 3) with a revised version of the MFZ-ODS (Version 2). They also provided a response to comments matrix that summarized how previous feedback from the Commission and Committees had been addressed. At the July 10, 2025 Planning Commission meeting, the Commissioners reviewed the Version 3 of the MFZ-ODS and received a presentation on the comment response from MBI. Along with this draft, MBI prepared a draft amendment to the main Housing Element document which was still under staff review at the time of the July 10 meeting (Attachment 4). Following the July 10 meeting, the Housing Element Amendment draft was presented to the Commission at a special meeting on July 24 for the Commissioners and public to review and provide comments on in advance of the item proceeding for draft review by the California Department of Housing and Community Development (HCD).

Beginning on July 25, the Housing Element draft (attachment 5) amendment was made public for a 7-day comment period during which residents could provide feedback on the contents of the amendment and the presentation at the July 24th meeting (attachment 6). Updates have been made based on feedback received as of August 1, 2025.

DISCUSSION
The revisions for MFZ-ODS (attachment 7) reflect public and commissioner comment at the Planning Commission Meeting on July 24, 2025. They reflect the first time the planning commission saw the first draft of the Draft Land Use Element Amendment, the Multifamily Zone and objective design standards, and rounded out by the draft Housing Element Amendment (attachments 8, and 9) and Land Use Element revisions (attachment 10) The 5th set of revisions to the draft MF and ODS include:

1. Replacement of “high density” with “multi-family housing between 20 and 24 dwelling units per acres of contiguous buildable area.”

2. Consistent listing of all 3 zones – MF, MFO, and FMFO.

3. Relocation of the Preservation of Steep Hillsides, Ridgelines, Hilltops, and Creeks and relevant definitions and Figures from the ODS to Article 16 of the Zoning Code.

4. Update of the Basement and Underground Garage Height Measurement to reflect the 32- foot max and the measurement to the midpoint between the eave and ridge of the roof.

5. Correction of the callout for the Measurement to the Top of the Ridgeline to reflect the minimum 400 feet above mean sea level.

6. Deletion of the “maximum height of a building or structure on a hilltop shall not exceed 19 feet.”

7. Clarified that only the “minimum required” common usable open space is subject to the noted standards.

8. Clarified and corrected the minimum fence setback as the “greater” of 18” from the pathway edge or 10 feet from the centerline of the pathway.

9. Amended the Building Lighting ODS to include:
a. “Skylights shall not exceed 3 feet in any dimension and shall have a means of blocking the emission of interior light at night.
b. Lightwells and basement stairs shall be the minimum size required by the Building Code or other applicable law. Such stairs shall include an awning or other nontranslucent cover.

ITEM 7A ATTACHMENT 11

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Discussion and Direction on the Housing Element Amendment and Multi-Family Zoning Objective Design Standards
August 7, 2025
c. All lighting of rooftop common area facilities shall require non-translucent shades, panels or other means around the light source that obscure and prevent horizontal light toward the nearest edge of the building. Rooftop lighting shall not exceed 0.5 footcandles at the edge of the rooftop surface.”

10. Reduced and clarified the entry monument sign number and size as follows:
a. “No individual sign shall exceed 12 square feet in area. Each side of a sign shall count toward the maximum sign area.”

11. Added a new pathway requirement as follows:
a. “When the Town Pathways Plan identifies a pathway connection on the subject property, the new Town Pathway shall be constructed and completed to Town Pathway Plan specifications concurrent with any multifamily development improvements.”
The 2nd set of proposed amendments to the Land Use Element are shown in yellow highlighted track changes. The prior proposed amendments are still shown in normal, unhighlighted track changes. The 2nd set of revisions included:

1. Refinement of Policy 1.4 to clarify the location considerations for the MF zones as “collector and arterial” roads; contiguous buildable areas (excluding slopes >25%); and access to public sewer services.

2. Inclusion of the new Land Use Map

3. Revision of Policy 2.2 to add “approximately” before the 3.5 acre minimum lot area for the 3 MF zones.

MBI will incorporate any additional revisions resulting from Planning Commission and public feedback received at the August 7, 2025 regular meeting into a subsequent version of the draft Housing Element document and making necessary adjustment to Version 5 draft MFZ-ODS documents and third draft Housing Element amendment. The MFZ-ODS will come back to the Planning Commission for formal review at the September 4th, 2025 regular meeting for a public hearing and recommendation to the City Council. During this time, the draft Housing Element Amendment will also be reviewed by HCD. The Housing Element Amendment and the MFZODS are being run on separate tracks as they have their own specific compliance measurements and deadlines.

ATTACHMENTS
ITEM 7A ATTACHMENT 11

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Discussion and Direction on the Housing Element Amendment and Multi-Family Zoning Objective Design Standards
August 7, 2025

1. Recording of the April 17th, 2025 City Council meeting [LINK]

2. Recording of the May 1st, 2025 Planning Commission meeting [LINK]

3. Recording of the June 5th 2025 Planning Commission Meeting [LINK]

4. Recording of the July 10th, 2025 Planning Commission Meeting [LINK]

5. 6
th Cycle Housing Element Draft Amendment [LINK]

6. Recording of the July 24th, 2025 Planning Commission Special Meeting [LINK]

7. Updated Multifamily Zone ODS Draft (July 31, 2025)

8. Summary of Housing Element Amendment Changes (July 31, 2025)

9. Draft Housing Element Amendment Document (July 31, 2025)

10. Draft Land Use Element Changes (July 30, 2025)
Staff Report Prepared by: Tim McBirney, Community Development Analyst ITEM 7A ATTACHMENT 11

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THE TOWN OF LOS ALTOS HILLS
Staff Report to the Planning Commission
September 4, 2025
SUBJECT: Consideration of adoption of a resolution making recommendations to City Council regarding adoption of a Land Use Element Amendment, an Ordinance Amending Title 10 of the Municipal Code Creating Multi-Family Zoning Districts and related zoning/development standards, and Objective Design Standards for Multi-Family Zoning Districts.

CEQA REVIEW: Consider statutory exemption under Pubic Resources Code Section 21080.085 and the “common sense” exemption pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3).

FROM: Jay Bradford, Community Development Director

RECOMMENDATION
That the Planning Commission adopt a resolution (Attachment 1) recommending the City Council adopt the following legislative amendments and document:
(1) Proposed Ordinance rezoning certain parcels to Multi-Family, Multi-Family Overlay, and Floating Multi-Family Overlay zones and establishing zoning and development standards (Attachment 2);
(2) Proposed Land Use Element Amendment making conforming changes to the rezoning (Attachment 3); and
(3) Proposed Objective Design Standards For Multi-Family Zoning Districts (Attachment 4).

BACKGROUND
Housing Element and Rezoning Requirements
As previously presented to the Planning Commission and City Council, California Housing Element Law (Government Code section 65580 et seq.) requires each jurisdiction to identify in their housing elements and have sufficient land zoned to accommodate their Regional Housing Need Allocation (“RHNA”) share by unit number and also by income category, including extremely low-, very low- and low-income units, during an eight-year planning period. There are also additional requirements in the Housing Element Law, including Government Code sections 65583, 65583.2, and 65863, that govern the required rezoning, minimum density, and maintenance of adequate sites to accommodate RHNA throughout the planning period.

The RHNA obligation for the Town of Los Altos Hills (“Town”) during the 2023-2031 planning period is 489 units including 197 extremely low-, very low- and low-income units. Consistent with Housing Element Law, if a site is developed below the density projected in the Housing Element, or at a different income than projected, the Town must have adequate sites available to accommodate the remaining balance of the RHNA, or it must identify and rezone new sites that ITEM 7A ATTACHMENT 12

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Discussion and Recommendation to the City Council regarding Multi-Family Rezoning and Objective Design Standards
September 4, 2025
can accommodate the remaining need. This is commonly referred to as the “no-net-loss” rule.

For these reasons, the Housing Element included a buffer of 15 percent above RHNA in each income category, for a total planned capacity of 563 units with 227 lower (low and very low) income units in its site inventory.

The Town adopted its 2023-2031 Housing Element as a part of the General Plan in January 2023.

It has since been engaged in numerous efforts to implement the goals and programs set forth in the Housing Element to facilitate housing production and working towards meeting its RHNA goals including the no-net-less buffer. As a part of its RHNA strategy, the Housing Element analyzed and identified three sites in the Town, identified as portions of Foothill College (“Foothill Site”), portions of St. Nicholas School (“St. Nicholas Site”), and several parcels located in northwest Los Altos Hills along Arastradero Road that collectively are known as the “Twin Oaks” property (“Twin Oaks Site”), to be rezoned from their current ResidentialAgricultural (R-A) zoning district to respective Multi-Family and Multi-Family Overlay zones to facilitate multi-family development.

The Housing Element analyzed rezoning approaches for all three sites, including identifying portions of the properties with highest development potentials, taking steep slopes, easements, and other site constraints into account, establishing development standards to facilitate housing construction, and considering realistic development capacities when calculating maximum unit yield projections. The Housing Element projected an anticipated yield of 210 units for the Foothill Site, 75 units for the St. Nichlas Site, and 92 units for the Twin Oaks Site.

Program A-1 of the Town’s Housing Element sets forth the schedule of action to rezone these inventory sites by January 30, 2026. It is imperative that the Town meet this rezoning deadline to maintain its Housing Element certification and its ability to make progress in meeting RHNA goals.

In relation to assigning RHNA obligations, state housing laws have also implemented a number of requirements to streamline housing production and development review timeframes, in order to facilitate the increase in housing supply. For example, the Housing Crisis Act of 2019 (Government Code section 66300 et seq.) prohibits local governments from imposing or enforcing design standards established on or after January 1, 2020, that are not objective standards. The Housing Accountability Act (Government Code section 65589.5) also limit local authority to disapprove a housing development or impose conditions that render the project infeasible if the housing development project complies with applicable objective standards and regulations. As defined by statute, “objective standards” are those that involve no personal or subjective judgment by a public official and being uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both a development applicant or proponent and the public official.

In response to the rezoning deadline and these legislative mandates, the Town has prepared (1) an Ordinance to rezone the Foothill and St. Nicholas Sites to multi-family overlay zones, and the Twin Oaks Site to a multi-family zone, and to establish zoning and development standards for these new land use districts (“MF Rezoning”) (Attachment 2); (2) a Land Use Element ITEM 7A ATTACHMENT 12

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Discussion and Recommendation to the City Council regarding Multi-Family Rezoning and Objective Design Standards
September 4, 2025
Amendment to align that part of the General Plan with the proposed multi-family zoning districts and projected multi-family development (“LUE Amendment”) (Attachment 3); and (3) a set of Objective Design Standards that would apply to multi-family developments in the new multifamily zones (“MF ODS”) (Attachment 4).

Planning Commission Study sessions and Review
At its April 17, 2025 meeting, the City Council gave direction to Town staff and the Town’s consultant Michael Baker International (“MBI”) to proceed with these legislative amendments and adoption of standards. The first study session to review the MF Rezoning and MF ODS was held at the May 1, 2025, Planning Commission meeting (Attachment 6). Michael Baker International (MBI) presented the initial draft (Version 1) of the proposed standards and received feedback that informed subsequent revisions.

MBI and Town staff returned to the Planning Commission on June 5, 2025 (attachment 7) with a revised version of the MF Rezoning and MF ODS (Version 2). MBI also provided a response to comments matrix that summarized how previous feedback from the Commission and Committees had been addressed. At the July 10, 2025 Planning Commission meeting, Commissioners reviewed further revised versions of the MF Rezoning and MF ODS (Version 3), the draft LUE Amendment, and received a presentation on the comment responses from MBI.1 Staff proceeded to the August 7, 2025 Planning Commission meeting with an updated draft of the MF Rezoning and MF ODS (Version 4) as well as a revised LUE Amendment for a final session of discussion, feedback, and direction with staff and consultants before the item went back to the Commission for a formal recommendation to the City Council to adopt the MF Rezoning, LUE Amendment, and MF ODS (Attachment 10).

DISCUSSION
The most recent revisions for MF Rezoning and MF ODS reflect both public feedback and Commissioner comments at Planning Commission study sessions, most recently on August 7, 2025.

Attachments 2, 3 and 4 have been updated accordingly to reflect those revisions, summarized as follows:

MF Rezoning & MF ODS Draft #6

1. 10-1.1603 Applicability - Amended to:
a. Delete redundant wording “and replace”; and
b. Add “when in conflict” for clarity.

2. Hilltop Definition and Regulation:
1 At this meeting and at a special meeting on July 24, 2025, Town staff and MBI presented a draft amendment to the Housing Element making further clarification and consistency changes to better explain the rezoning approach. The draft amendment has been submitted to the state Housing and Community Development Department (HCD) for review. It is not the subject of this meeting but will return to the Commission when feedback is received from HCD.

ITEM 7A ATTACHMENT 12

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Discussion and Recommendation to the City Council regarding Multi-Family Rezoning and Objective Design Standards
September 4, 2025
a. Revised definition to reference the two lowest elevations within a 1,500 foot radius of the highpoint
b. Delete the prior Hilltop Definition figure (this can be redrawn later if desired) c. Re-established the previously proposed height limit of 19 feet on a Hilltop.

3. Ridgeline Definition - revised to:
a. Change the base elevation datum from the two nearest streets to the two lowest elevations within a 1,500 foot radius of the highpoint
b. Better describe a ridgeline as an elongated crest or crests at the apex of steep hillsides of two opposite slopes containing steep hillsides
c. Delete the prior Ridgeline Definition figure (this can be redrawn later if desired) d. Delete the prior Measurement to Top of Ridgeline figure. (this can be redrawn later if desired)

4. MF Building Height Measurement and Building Mass figures – revised the height dimension from 35 to 32 feet: Figures: 4, and 9-12.

5. Pathway Connections
a. Made requested minor wording changes

6. Fence Types – amended Prohibited to provide more objective metrics to better define what is meant by “points, spikes, or sharpened edges.”
Land Use Element Amendments (LUE Amendment) Draft #3

1. Revised section 112- Development Potential – to delete “addition of a new” so the new paragraph begins with “The multifamily designation allows approximately...”

2. Updated Policy 1.4 to reference freeway and expressway.

Sites identified for MF Rezoning
As part of this effort, the Planning Commission is asked to formally review the rezoning of certain parcels identified in the Housing Element to new multi-family zoning districts as follows:
• Twin Oaks Site: APNs 182-02-020, 182-02-021, and 182-02-022 (Lots of 4, 5, and 6 of Twin Oaks Estates, respectively), from Residential-Agricultural (R-A) to Multifamily (MF). • St. Nicholas Site: Portions of APNs 336-21-003 and 336-21-004 (portions of the St. Nicholas School property), from Residential-Agricultural (R-A) to Multifamily Overlay (MFO). • Foothill Site: APNs 175-41-014, 175-41-016, and 175-41-015 (portions of the Foothill College property), from Residential-Agricultural (R-A) to Floating Multifamily Overlay (FMFO).

The proposed MF Rezoning Ordinance also implements revisions to the Town’s Zoning Map. This map depicts the base and overlay districts for land use regulation purposes in Los Altos Hills. A ITEM 7A ATTACHMENT 12

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Discussion and Recommendation to the City Council regarding Multi-Family Rezoning and Objective Design Standards
September 4, 2025
revised map is included as Attachment 2B.

Staff recommends that the Planning Commission adopt a resolution recommending the City Council adopt the proposed MF Rezoning, LUE Amendment, and MF ODS. If the Commission has further comments and revisions to these proposed legislative changes and ODS, staff recommends the Planning Commission make the recommendation to Council at this meeting with those revisions identified and included.

CALIFORNIA ENVIRONMENTAL QUALITY ACT
As previously presented to the City Council and Planning Commission, the Town’s Multi-Family Rezoning efforts contemplated the preparation of a Programmatic Environmental Impact Report (“EIR”) to meet California Environmental Quality Act (“CEQA”) requirements. On June 30, 2025, however, Governor Newsom signed Senate Bill 131 into law creating, among other things, a statutory CEQA exemption under Public Resources Code Section 21080.085 for rezonings to implement housing elements as required by state law. This law immediately went into effect on July 1, 2025.

Specifically, this new CEQA exemption applies to “a rezoning that implements the scheduled of actions contained in an approved housing element” pursuant to state housing element law. This exemption excludes (1) rezonings that would allow oil and gas infrastructure/distribution centers, or (2) rezonings that would include narrowly defined “natural and protected lands” such as areas within a state or national park, state farm land, conservation easement, CalFire Very High fire hazard zones, or hazardous waste sites. Based on these criteria, the Town’s proposed Multi-Family Rezoning qualifies under the new law. The rezoning implements the Town’s certified Housing Element under Program A-1. It covers pre-selected sites (Foothill, St. Nicholas, and Twin Oaks Sites) in the Housing Element inventory. It does not allow oil and gas infrastructure/distribution centers, nor does it propose to rezone any natural and protected lands as defined by statute. Therefore, it is recommended that the Planning Commission find the proposed rezoning is statutorily exempt from CEQA pursuant to Public Resources Code Section 21080.085.

Staff also recommends that the Planning Commission find the proposed LUE Amendment is exempt from CEQA under the same statutory exemption pursuant to Public Resources Code Section 21080.085 for the same reasons stated above, as the proposed amendment is a part of the rezoning action necessary to implement the Housing Element and achieve internal consistency. Further, it is recommended that the Commission find the LUE Amendment and MF ODS are exempt from CEQA pursuant to CEQA Guidelines section 15061(b)(3), because it can be seen with certainty that there is no possibility that the proposed amendment and standards may have a significant impact on the environment. These amendment and standards do not approve projects, issue entitlements, or make any physical environmental changes, but are regulatory actions taken by the Town to implement state law, Housing Element, and streamline development review processes.

ATTACHMENTS
ITEM 7A ATTACHMENT 12

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Planning Commission Page6
Discussion and Recommendation to the City Council regarding Multi-Family Rezoning and Objective Design Standards
September 4, 2025

1. Draft Resolution- Recommendation to the City Council on Multi-Family Zoning, Land Use Element Amendment, and Multi-Family Objective Design

2. Draft Ordinance- Multi-Family Zoning (also Exhibit A to Resolution in Attachment 1) • Ordinance Exhibit A: Multi-Family Development Standards • Ordinance Exhibit B: Revised Zoning Map

3. Draft Multi-Family Objective Design Standards (also Exhibit B to Resolution in Attachment 1)

4. Draft Land Use Element Amendment (also Exhibit C to Resolution in Attachment 1)

5. Recording of the April 17th, 2025 City Council meeting [LINK]

6. Recording of the May 1st, 2025 Planning Commission meeting [LINK]

7. Recording of the June 5th 2025 Planning Commission Meeting [LINK]

8. Recording of the July 10th, 2025 Planning Commission Meeting [LINK]

9. Recording of the July 24th, 2025 Planning Commission Special Meeting [LINK]

10. Recording of the August 7th, 2025 Planning Commission Meeting [LINK] ITEM 7A ATTACHMENT 12

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TOWN OF LOS ALTOS HILLS March 20, 2025
Staff Report to the City Council
SUBJECT: CITY COUNCIL RECOMMENDATION ON HOUSING ELEMENT

AMENDMENTS INCLUSIVE OF MODIFICATIONS TO THE GENERAL
PLAN, LAND USE ELEMENT, PROPOSED ZONING, AND INCENTIVES.

FROM: Jay Bradford, Community Development Director
APPROVED: Peter Pirnejad, City Manager
RECOMMENDATION:

That the City Council receive and provide direction on the recommended approaches for amendment and modification of the 6th Cycle Housing Element.

Staff recommends that the City Council prioritize the Housing Element and Land Use Element amendments, incorporating HCD feedback, to maximize the Town’s benefits in meeting its housing goals.

In addition to addressing community concerns about development density, these approaches are recommended to mitigate exposure to current and future SB330 applications. It is recommended that the Town take proactive steps to reduce the total land area and maximum allowable density in both the Housing Element and Land Use Element, as well as in the Zoning Ordinance (ZO) and Objective Design Standards (ODS). These amendments should be prioritized and implemented as soon as the City Council is prepared to take action. By refining zoning parameters and land use designations, the Town can better align with its planning objectives while minimizing unintended development pressures under SB330.

The Town’s initial draft Housing Element was submitted to HCD for review and certification with the final document being adopted on January 30th, 2023, and certified by HCD on May 30, 2023.

The implementation remains ongoing as the Community Development Department develops the programs contained in the element. In August of 2024, the Community Development Department published a Notice of Preparation (NOP) for a programmatic-level Environmental Impact Report (EIR) on the rezoning of the housing opportunity sites including the location adjacent to Twin Oaks Court. In addition to the study there were the subsequent series of meetings and community engagement events resulted in requests to amend the housing element. A concurrent effort led to ITEM 7A ATTACHMENT 13

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City Council Page 2
Recommendations for the Amendment of the 6th Cycle Housing Element March 20, 2025
the creation of a proposed Key Terms Agreement with the owners of Twin Oaks Court which would have been the basis for a development agreement with the town to limit the impacts expressed as the need to amend the housing element. Ultimately the City Council decided to remain silent on the key terms agreement and instead created an Ad Hoc committee at the January 28th, 2025, City Council meeting. This Ad Hoc committee is composed of Vice Mayor Bhateja and Councilmember Mok and invited Town residents to discuss a revision and amendment to the Housing Element which would modify the total proposed scope of development at the Twin Oaks site. Since its creation, the Ad Hoc committee has met weekly to discuss a variety of approaches to amending the Housing Element with input from residents, the Town’s Housing Element consultants, representatives from HCD, and Town Council members and staff.

Following its formation, the Housing Element amendment Ad Hoc committee conducted weekly meetings with residents, council members, consultants, and staff to discuss both approaches to amending or modifying the Housing Element as well as technical feasibility for approvable options to present to HCD. The Ad Hoc Committee held listening sessions to receive resident feedback on the Housing Element amendment on March 4th and March 9th, 2025.

At the March 12, 2025 Planning Commission special meeting, a report was given from Community Development Director Jay Bradford on approaches to amending the Housing Element including recommendations from Los Altos Hills resident John O’Connell, Town housing consultant Michael Baker International, and a development agreement approach. The Planning Commission received a recap of the various Ad Hoc Committee listening sessions and expressed support for the Committee's options. The Commission recommended that staff refine the range of Housing Element Amendment options and incorporate direct analysis from HCD when presenting to the City Council, with emphasis on investigating and prioritizing options based on duration, feasibility, and overall benefit to the Town. The Commission voted 5-0 in favor of the motion.

DISCUSSION:

The proposed amendments to the Housing Element are intended to strengthen the Town’s compliance with state law while taking into account the feedback received from both HCD and the local community. These changes will ensure that the Housing Element remains an effective, actionable plan that accommodates the Town’s housing needs and objectives. The Town of Los Altos Hills is committed to preserving its semi-rural character and protecting its unique environmental assets while meeting the state’s housing requirements. The proposed amendment to the Housing Element is designed to balance these priorities by incorporating flexibility in zoning and development strategies, while also addressing the need for more affordable and diverse housing options within the community.

The approaches in amending the Housing Element are presented by Town residents, Michael Baker International, and City Council members.

Option 1: R4 R20 w/ LUF Approach
The first option in modifying the Housing Element is presented by Los Altos Hills resident John O’Connell through discussion with the Ad Hoc committee. This approach adjusts the metric used ITEM 7A ATTACHMENT 13

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City Council Page 3
Recommendations for the Amendment of the 6th Cycle Housing Element March 20, 2025
to determine density on the subject parcels at Twin Oaks. The proposal is to adjust the density on the site from dwelling units per acre, which currently set at 20-30 units/acre in the current Housing Element, to square footage per acre and the creation of two classifications of rezoning in the form of R4 zoning (base) and R20. Under this approach, factors such as slope would be more heavily factored into the eligibility and development standards for multifamily zoning with lower slopes (less than or equal to 15%) being eligible for higher density zoning (R20).

The resulting land use formulas for the sites would be: “R20 site” area(s) ≥ 0.5 LUF on parcels, lots or “site(s)” ≤ 15% gradient. R20 unit capacity = “R20 site” LUF*43,560/2,000.

The proposal centers on implementing an R4 standard on all seven Twin Oaks parcels resulting in 42 units before Density Bonus which under the assumptions of this proposal could potentially meet the RHNA allocation for the Town. Per this recommendation, this could result in 63 to 84 units being built after density bonus is factored in. R4 zoning would include the density bonus incentive mechanism to provide for the small number of some lower-income units required once the Housing Element amendment is complete. R4 zoning applied to the Housing Element Program A-12 would streamline this program to convert single-family housing to duplexes and triplexes for the approximately 50 sites specified and create approximately 100 of the required above-moderateand moderate-income units.

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City Council Page 4
Recommendations for the Amendment of the 6th Cycle Housing Element March 20, 2025
pipeline for all R4 and R20 project submittals. This approach relies on the use of current ADU stock to count towards total RHNA allocation and a continuation of the same rate of ADU development for a total of 200 units over the course of the 8-year planning period.

Option 2: 24 Units/Acre Approach
Michael Baker International (MBI), the Town’s consultant which prepared the originally adopted Housing Element, has considered community feedback as well as input from the City Council, Town attorney, staff, and HCD in the preparation of another approach to amending or modifying the adopted Housing Element. The MBI approach factors in a prospective Land Use Element amendment, a Housing Element amendment, as well as upcoming multi-family zone and objective design standards with the combined result of compliance with state laws for multi - family housing and provide consistency with Town regulatory documents such as existing zoning law and standards.

The MBI approach cites the following elements of state law as the basis for the modification approach in alignment with:

Housing Element Program A-5 references 65583.2 (h)(2)
65583.2 (h)(2): establishes the absolute minimum density of any rezone required to meet a RHNA shortfall – 20 du/ac for Suburban communities like Los Altos Hills. • “(2) These sites shall be zoned with minimum density and development standards that permit:
• at least 16 units per site …
• shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c) …” • There is no provision that allows for an alternative to this minimum density. 65583.2(c)(3)(B): sets the minimum allowable maximum density (e.g., 20 du/ac in Los Altos Hills).
• This provision allows a city to argue for less than the otherwise established minimum allowable maximum zoning density. For example, a city could argue for a maximum density of 28 du/ac instead of the standard 30 du/ac.

ITEM 7A ATTACHMENT 13

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City Council Page 5
Recommendations for the Amendment of the 6th Cycle Housing Element March 20, 2025
• This is not applicable in Los Altos Hills since the minimum allowable maximum density under Section 65583.2(c)(3) is 20 du/ac and the maximum density must be reasonably greater than the absolute minimum density of 20 du/ac (e.g., 24 du/ac)
This yields the following re-allocation of units in a revised approach to multifamily zoning:

This approach creates a new building placement concept through a newly established Minimum Lot Size of approximately 4 acres, a height limitation of 50 ft (4 stories above parking) and front, side, and rear setback lines set at 60ft. The MBI approach keeps the scope of change limited to the Twin Oaks opportunity sites without involving nearby parcels.

Option 3: Development Agreement Approach
Option 3 the Development Agreement approached was highlighted at the meeting but not discussed in any detail.

ITEM 7A ATTACHMENT 13

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City Council Page 6
Recommendations for the Amendment of the 6th Cycle Housing Element March 20, 2025

ANALYSIS
Through various public engagement events and the creation of the Ad Hoc the town has spent hundreds of hours reviewing, discussing, and acting on resident feedback to ensure the intent of the housing element matches the community need. The most recent series of Ad Hoc public listening sessions presents the most recent efforts regarding proposals to address concerns in multifamily and affordable housing development.

In keeping with ongoing certification of the Housing Element, care should be taken in gathering as much information as possible from HCD, consultants, and staff on the compliance and feasibility of amendments prior to formal submission to HCD for review. Additionally, the current Housing Element will be under examination through the scheduled HCD mid-cycle review to assess progress the Town has made in the implementation of the Housing Element. The Town has submitted ongoing status updates to HCD through the required Annual Progress Report (APR) which is submitted in the first quarter of the year and covers all building and planning activity for the previous calendar year. The Town is in good standing and compliance with building, planning and implementation and is currently in the process of collecting data to submit the 2024 Housing Element APR to HCD. Any changes to the Housing Element implementation or follow-up impact on building and planning metrics will appear in the 2025 APR.

FISCAL IMPACT
The fiscal impact of the proposed amendments is thought to range from $100,000 to $200,000, as in some options the Town would be undertaking large-scale revision to the Housing Element.

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City Council Page 7
Recommendations for the Amendment of the 6th Cycle Housing Element March 20, 2025
and consultant time for the administration of updated housing programs. These costs will be assessed in subsequent budgeting cycles.

NEXT STEPS

1. City Council Initial Public Hearing and Review: Prior to proceeding with further action, the Council would provide direction on the Planning Commission recommendation at a public hearing to gather additional feedback and ensure that all community concerns are addressed before adoption.

2. Council Adoption:

The City Council would adopt the agreed upon approach to amending the Housing Element.

3. Submission to HCD for Certification:

Once adopted by the City Council, the amended Housing Element will be resubmitted to the California Department of Housing and Community Development (HCD) for final review and certification.

4. Implementation of Revised Strategies:

After certification by HCD, the Town will begin implementing the revised strategies outlined in the Housing Element, including potential zoning adjustments, outreach to developers, and ongoing community outreach.

ATTACHMENTS

1. Attachment 1: Presentation from Jay Bradford, Community Development Director

2. Attachment 2: Presentation from John O’Connell, Los Altos Hills Resident Report prepared by: Jay Bradford, Community Development Director ITEM 7A ATTACHMENT 13

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Approved July 21, 2025 Town of Los Altos Hills
City Council Regular Meeting
Thursday, May 15, 2025, at 6:00 P.M.

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

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

Absent: None
Staff: City Manager Peter Pirnejad, Deputy City Manager Code Einfalt, Public Works Director WooJae Kim, Community Development Director Jay Bradford, Finance Director Thomas Leung, Community Services Supervisor Emina Mahic, and City Clerk Arika Birdsong-Miller
CALL TO ORDER (6:00 P.M.)
Mayor Tankha called the meeting to order at 6:00 P.M.

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

1. AGENDA REVIEW
Mayor Tankha asked the Council Members if they wished to pull any agenda items.

Council Member Swan requested to pull Item 11B and discuss it at a later date.

2. PRESENTATIONS AND APPOINTMENTS
A. Proclamation Recognizing PRIDE Month
Council Member Swan presented a proclamation recognizing the June 4, 2025, grand opening of the Foothill College Pride Center. The Center supports and celebrates LGBTQ students, staff, and allies, providing a safe, inclusive space on campus.

B. Proclamation Recognizing Foster Care/Resource Parent Awareness Month Mayor Tankha proclaimed May 2025 as Foster Care Month in the Town of Los Altos Hills.

The proclamation highlighted the importance of supporting children and youth in foster care and recognized the contributions of caregivers who provide them with love, stability, and guidance.

She noted the growing demand in Santa Clara County and urged residents to learn how they could help foster children and families.

C. Proclamation Recognizing Public Works Week
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Public Works Director Kim announced that May 18–24, 2025, was National Public Works Week, marking its 65th anniversary and sponsored by the American Public Works Association.

This year’s theme, People, Purpose, Presence, honors the vital work of public works professionals in maintaining infrastructure and essential services. He concluded by reading a statement on behalf of the Mayor and Council, and the Town of Los Altos Hills proclaiming the week and encouraged residents to recognize the contributions of public works staff.

3. PRESENTATIONS FROM THE FLOOR
Mayor Tankha opened PRESENTATIONS FROM THE FLOOR.

Joe Iyer, Los Altos Rotary Club member and sponsorship chair for the annual Fine Art in the Park show, spoke about the upcoming 50th anniversary event, scheduled for August 9–10, 2025, at Lincoln Park. He requested a $1,000 grant from the Town to support the event, like a contribution made two years ago under then-Mayor Swan. Ayer emphasized that the show was the Rotary Club’s major fundraiser, with proceeds supporting local and international grants, scholarships, and programs. The well-attended event features juried art, food, entertainment, and community engagement, and is widely promoted.

Daniel Dulitz, Palo Alto resident and owner of Next Level Infrastructure, gave an update on the Los Altos Hills Community Fiber project. The 10 Gigabit network, anchored by a head-end cabinet near Town Hall, included both existing and new segments—some reimbursed by the Town under a prior agreement. The fiber also supported public safety and education, including a link to the emergency facility near Foothill College.

The Fremont Road to Town Hall segment was in permit review, with construction expected to start soon and finish by December. The Stonebrook, Prospect, and La Loma segments were entering the permitting phase.

Gautham Agrawal, a Los Altos Hills resident, provided further updates, noting steady progress on all segments, including an unexpectedly smooth process for the I-280 crossing. That portion may be ready for Council review by July 1. He expressed optimism and made himself available for any questions from the Council.

Vice Mayor Bhateja thanked Community Fiber and Next Level Infrastructure for their progress and collaboration with staff and the technology committee.

Council Member Mok expressed satisfaction with the I-280 crossing.

Dr. Agrawal noted that the project was progressing well and encouraged interested residents to reach out.

Council Member Swan also thanked the team and requested ongoing updates.

Michael Grady, a Los Altos Hills resident, spoke about the importance of transparency and compliance with the California Public Records Act.

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Allan Epstein, a resident of Los Altos Hills, requested that the Council agendize a discussion on excessive building fees charged between July 1, 2020, and April 2022.

John O’Connell, a resident of Los Altos Hills, spoke about a March 2023 meeting involving representatives of the Twin Oaks and Fenwick properties. He referenced documents suggesting a proposal for 320 units and asked whether the Council had been informed of the meeting or the proposal.

He noted the importance of transparency and requested clarification on how the information was shared with the Council.

4. INFORMATIONAL REPORTS (items provided solely for informational purposes) A. Treasurer’s Report (Staff: T. Leung)
B. Disbursement Report (Staff: T. Leung)
C. Quarterly Investment Report (Staff: T. Leung)
City Manager Pirnejad noted that these reports were for informational purposes only and no oral staff report was necessary.

5. CONSENT CALENDAR
Mayor Tankha pulled Item 5D from the Consent Calendar for discussion.

Council Member Mok requested to pull Item5E from the CONSENT CALENDAR for discussion.

A. Approval of the Special City Council Meeting Minutes March 9, 2025 B. Resolution Accepting an Open Space Easement at 12889 Viscaino Place; Lands of Fremont Hills Country Club; File #ER25-0001
C. Resolution Requesting the Santa Clara County Tax Collector to Collect Delinquent Sewer Charges and the FY2025-26 Sewer Service Charges for both the Palo Alto and Los Altos Dewer Basins
D. Letter from the Town Council Opposing SB79
This item was pulled from the CONSENT CALENDAR for a separate discussion.

Mayor Tankha expressed support for affordable housing along transit corridors, in line with SB 79’s intent. She emphasized the need to avoid high-density development on steep slopes due to safety concerns and clarified that her position was not anti-housing but pro-responsible planning.

Council Member Swan supported housing near transit corridors but opposed SB 79 as written, citing concerns over the lack of local review within a half mile of transit stops. She warned the law could allow incompatible high-density developments in single-family neighborhoods and called for amendments to include local oversight.

Mayor Tankha noted the importance of not being perceived as anti-housing and advocated for thoughtful and appropriate development.

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Council Member Swan agreed with Mayor Tankha that transit corridors were appropriate for housing but cautioned against a cart blanche allowance for development within a half mile of transit stops without local review. She compared SB79 to other broad state mandates, like the builder’s remedy, and emphasized the need for oversight.

Council Member Tyson supported pro-housing sentiments and criticized SB79 as a blunt, onesize-fits-all approach. He emphasized the need for local control and thoughtful planning, stating that while the housing need was clear, this bill was an appropriate place to push back.

Council Member Mok emphasized the need for truly affordable housing, not just high-cost developments that may not serve those most in need. He suggested exploring financial incentives, such as housing vouchers, for towns that actively support housing. He expressed concern that SB79’s one-size-fits-all approach was inappropriate for Los Altos Hills and could negatively impact the character of the community.

Vice Mayor Bhateja supported housing near transit corridors and noted prior discussions with State Senator Josh Becker on the issue. He opposed SB79 for removing local discretion in planning. Citing the example of California Avenue in Palo Alto, he argued the bill ignored important land-use distinctions and undermined cities’ ability to make thoughtful, contextspecific decisions.

Mayor Tankha opened the Public Comments.

No public comments.

Mayor Tankha closed the Public Comments.

Council Member Swan motioned to APPROVE this item and have a letter sent from the Town Council opposing SB79 unless it’s amended. Vice Mayor Bhateja seconded.

MOTION PASSED: 5-0
AYES: Tankha, Bhateja, Mok, Swan, Tyson
NOES: None
RECUSE: None
ABSTAIN: None
ABSENT: None
E. Resolution Awarding a Construction Contract to B and D Excavation & Construction for the Matadero Creek Restoration and Bank Stabilization Project not to Exceed $465,840, including Construction Contingency, and Approving Second Amendment to the Consultant Services Agreement with ENGEO for Additional Services not to Exceed $133,010.

This item was pulled from the CONSENT CALENDAR for a separate discussion.

Council Member Mok noted a significant cost difference between the initial and current estimates for the Matadero Creek project. He recalled the original estimate being over $1 million ITEM 7A ATTACHMENT 14

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and asked Public Works Director Kim to explain the reason for the reduced costs, suggesting it may be due to the project being completed in phases.

Public Works Director Kim explained that the initial high-cost estimates for the Matadero Creek project were due to a broader project scope, which included constructing an additional retaining wall to accommodate a future bike lane. After determining that this addition was not immediately necessary, the scope was reduced, and the project was rebid. This lowered costs significantly, with the current bid coming in within the engineer’s estimate at approximately $65,000.

Council Member Mok motioned to Approve this Resolution. Council Member Tyson seconded.

MOTION PASSED: 5-0
AYES: Tankha, Bhateja, Mok, Swan, Tyson
NOES: None
RECUSE: None
ABSTAIN: None
ABSENT: None
F. Resolution Authorizing Award of the Landscape Maintenance Services Agreement for Fiscal Years 2025-27 to Frank and Grossman Landscape Contractors, Inc. not to Exceed $195, 848 G. Resolution Approving the Plans and Specifications for the Lower Arena Improvements at Westwind Community Barn Project and Authorizing Staff to Advertise the Project for Formal Bid
H. Resolution Approving the First Amendment to the Open Space Stewardship and Education Agreement with Grassroots Ecology for a Two-Year Term Extension Not to Exceed $205,659 Vice Mayor Bhateja noted that while the project relied on volunteer labor, the estimated value of that contribution was around $35,000. He emphasized the importance of transparency, pointed out that the town contributed $100,000, and acknowledged the project's educational and community value.

I. Resolution Approving the Fiscal Year 2025/26 Project List for Annual Pavement Rehabilitation and Drainage Improvement to be Funded by State Senate Bill 1, the Road Repair and Accountability Act of 2017
J. Termination of Appointment to the Open Space Committee - Wendie Ward K. Approval of the Special City Council Meeting Minutes March 20, 2025 L. Approval of the Special City Council Meeting Minutes April 14, 2025 Vice Mayor Bhateja motioned to Approve the Consent Calendar. Council Member Swan seconded.

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MOTION PASSED: 5-0
AYES: Tankha, Bhateja, Mok, Swan, Tyson
NOES: None
RECUSE: None
ABSTAIN: None
ABSENT: None

6. ONGOING BUSINESS – NONE

7. PUBLIC HEARINGS
City Council Ex Parte Contacts Policy Disclosure
A. Consideration of an Ordinance (First Read) Adopting Amendments to the California Fire Marshall's Fire Hazard Severity Zone Base Map in Los Altos Hills Mayor Tankha recused herself from the discussion of this item. Vice Mayor Bhateja presided over the meeting in her place.

Council Member Tyson explained that when a potential conflict of interest exists—such as a Council Member living within 500 feet of an affected property—they are legally required to recuse themselves and leave the room. This was the reason for a recent recusal.

Vice Mayor Bhateja added that recusal requirements vary by proximity and visibility—if a property was within visual sight, the threshold was 1,000 feet; if not, it was 500 feet.

City Attorney Mattas clarified that multiple distance standards applied to conflicts of interest:
500 feet and 1,000 feet. For properties between those distances, additional factors must be considered. He noted that, as with many legal issues, the rules were more complex than they may initially appear.

Ex Parte:

Council Members Tyson and Swan had communications with Jay Logan, the General Manager of the Fire District.

Vice Mayor Bhateja and Council Member Mok reported having informal communications with several residents, though they did not record the individuals' names.

Community Development Director Bradford presented the staff report, which explained 2 options for fire hazard mapping:

1. Adopt the CalFire base maps as mandated by the State of California (Exhibit A, Option 1), OR

2. Adopt locally developed maps (Exhibit A, Option 2).

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Council Member Swan asked whether a property's designation as being in a "Very High" or "Extreme" wildfire category would affect its ability to be rebuilt after a disaster or developed initially and staff responded that the standards would affect new construction.

Council Member Swan then inquired whether an increase in a property's wildfire risk rating was permanent. She asked if a rating based on brush or vegetation, could it be downgraded if the hazardous materials were later cleared and staff responded that once the CalFire maps were updated, there were no processes in place to amend them.

Council Member Swan requested clarification on a reference in Exhibit A, Option 2 (page 17) regarding assessments related to participation in the Santa Clara County multi-jurisdictional program, noting she did not understand its meaning.

Director Bradford explained that while the General Plan and Safety Element may not directly reference the matter, the Town participated in cooperative agreements related to risk management and broader regional mitigation efforts. The proposed local amendments were consistent with those regional strategies and planning documents.

Council Member Mok raised concerns about the potential impact of wildfire risk maps on the pricing and availability of fire insurance for residents. He referenced a flyer indicating rates would not increase under an alternative map but expressed skepticism toward assurances from the State and Federal governments. He asked whether insurance companies use their own composite maps or rely solely on CalFire and other
Director Bradford explained that insurers used multiple, dynamic, and property-specific risk models—not just Cal Fire maps—to determine fire insurance coverage. These models were informed by sources such as the State Insurance Office, insurance-related nonprofits, the Insurance Institute for Business & Home Safety (IBHS), and Triple-I. While private insurers were not obligated to provide coverage in California, the State offered a backstop fire insurance option. maps for underwriting decisions.

Council Member Mok emphasized the importance of the topic of wildfire risk, noting that any municipal ordinance should apply town-wide rather than to just a specific area. He suggested considering a phased approach, starting with a portion of the town and expanding it later.

Council Member Swan commented that insurance companies were already using more detailed, parcel-specific maps than CalFire. She shared that, according to information from a meeting hosted by Assemblymember Papin, insurers could cancel coverage for minor issues like overhanging tree limbs. She questioned the actual impact of CalFire maps, given insurers' stricter standards.

Council Member Mok emphasized the importance of Town-wide fire prevention efforts, including clearing weeds, removing dead trees, and maintaining defensible space. He referenced fire-prone areas like Malibu and Pacific Palisades and expressed concern that similar conditions existed locally, urging proactive measures to reduce wildfire risk.

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Council Member Tyson asked if stricter fire zones could be adjusted if conditions changed, citing road improvements like widening a narrow road as a valid reason.

Director Bradford seemed to agree with this and clarified that once fire zone designations were made locally, they could be easily changed without state action. These designations were made with a long-term view (typically 50 years), considering factors like fuel loading, weather conditions, and climate change, rather than immediate changes like road widening. The focus was on properties with high-risk factors, such as narrow roads in high severity zones, to ensure safety for residents in case of emergencies.

Vice Mayor Bhateja thanked Director Bradford for his work, acknowledging its personal importance and effort. Bhateja then asks if the requirements imposed by the "very high" and "high" fire hazard severity ratings could be achieved through alternative methods, such as building codes, zoning, or local ordinances, without changing the actual fire hazard severity zones.

Director Bradford explained that while wildland-urban interface (WUI) standards and Cal Fire’s high and very high fire hazard severity zones used the same construction and defensible space requirements, the key difference was local control—WUI standards could be locally modified through the building code process, unlike CalFire designations. He noted that communities often used mapping to define WUI areas, as the Town did in 2015 before later removing them.

Vice Mayor Bhateja asked if the Town could require more defensible space based on property conditions, such as being on a slope or having reduced risk due to vegetation changes or road widening, confirming that the Town would have local control such as reversing designations.

City Manager Pirnejad noted that Assembly Bill 306, if passed, could limit the Town’s ability to amend the building code, though not the zoning or municipal codes. He cautioned that the State may reduce local control in this area.

Council Member Swan asked if the Town could leave the CalFire maps as they were but designate individual parcels as within the wildland-urban interface (WUI) to apply building requirements, without those parcels appearing on the CalFire very high fire severity zone map.

Director Bradford confirmed the Council could choose to designate individual parcels as WUI, but noted staff was recommending specific properties due to their alignment with CalFire designations. He explained that CalFire mapped areas in 20-acre blocks, sometimes missing parcels that should logically fall under the same designation.

Council Member Swan questioned how they handled properties split between high and lower fire severity zones on the CalFire map and asked if the proposal was to apply the highest severity designation to the entire parcel and Director Bradford deferred to the City Attorney to provide guidance.

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Vice Mayor Bhateja noted that while the Department of Insurance stated fire severity zoning maps were not used by insurance companies, there was nothing to prevent insurers from using them in the future. He expressed concern that designating the entire Town as very high risk could impact future insurance ratings.

Director Bradford explained that insurers often viewed communities that self-imposed higher hazard mitigation standards more favorably, and participation in such efforts could reduce risk and improve insurance access, while lack of mitigation was a key reason for insurance loss.

Council Member Mok suggested adopting municipal codes to make the Town a recognized Firewise community, which could help residents lower insurance costs and improve access to coverage.

Council Member Swan suggested inviting the guest from the fire department to share his expert opinion on this item and Vice Mayor Bhateja agreed.

Assistant Fire Marshal with the Santa Clara County Fire Department Jeremy Davis explained that his agency has worked closely with the Town through several meetings to assist with adopting the Local Responsibility Area (LRA) maps, addressing many public concerns. The changes in the maps were largely due to improved technology and more localized weather data from remote automated stations, offering a more accurate picture of fire risk. He noted that CalFire maps did not align with property lines and if any part of a parcel fell within a fire severity zone, the highest rating applied to the entire parcel, which was a state decision. Davis emphasized that while weather and topography couldn’t be changed, fuel management and defensible space could reduce fire risk, and their assessments followed CalFire’s standards to help inform local decisions.

Council Member Mok asked whether fires would spread faster in wildlands and preserves or in populated areas with buildings.

Fire Marshal Davis responded that fire spread depended on conditions, but dry grass—known as light flashy fuel—ignited easily and could cause fires to spread quickly.

Council Member Swan asked if fast-burning light fuels like dry grass were less dangerous than brush, suggesting they burn out quickly.

Fire Marshal Davis replied that neither was more or less dangerous; light fuels burned faster and were easier to extinguish, but factors like wind and slope made them challenging. He explained that heavy fuels burned slower but with more energy, so all fuel types posed risks and difficulties in firefighting.

Vice Mayor Bhateja confirmed that the Fire Department reviewed specific areas and provided input to Town staff but clarified that they were not recommending which fire severity maps municipalities should adopt.

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Fire Marshal Davis confirmed that the department provided expert information and supported fire safety efforts but did not recommend specific map options, instead offering observations and answering questions to assist municipalities.

Vice Mayor Bhateja confirmed with Fire Marshal Davis that the decision on the fire severity maps mainly impacted property owners and their fire mitigation responsibilities, while it had little to no direct effect on the fire department’s operational response.

Fire Marshal Davis assured the Council that the fire department’s response would be the same for all residents, regardless of whether they were in the WUI or any fire severity zone.

Vice Mayor Bhateja thanked Fire Marshal Davis for attending and sharing his expertise on the matter and opened the Public Comments.

Public Comments
Walter Wilson, a Los Altos Hills resident, expressed concern that his property on Buena Vista Drive was incorrectly elevated to a severe fire risk level due to a mistaken assessment of access routes, arguing there were three exits rather than a dead-end road. He also shared that his property insurance was canceled last year—not due to fire risk but because of the home's value—forcing him to seek coverage out of state in Ohio at an unaffordable cost of $84,000 per year, which he described as devastating. Wilson felts the Town was under State pressure regarding housing and fire standards and believed it was not the right time to adopt the new maps, recommending the Town maintain the current designations.

Jim Waschura, a Los Altos Hills resident, commented that both adopting wildfire (WU) zones or hazard maps seemed to achieve similar outcomes by increasing building code requirements, but since only about 15 homes were built or remodeled each year, this approach alone may be insufficient. He emphasized the need for stronger code enforcement and enforceable rules focused on ongoing maintenance and fuel reduction across the Town, especially in higher-risk fire areas, and questioned whether either approach would better support those efforts.

John O’Connell, a Los Altos Hills resident, expressed that increasing fire severity ratings beyond the minimum maps provided by CalFire was unjustifiable and may be based on incomplete information; he urged the council to accept only the minimum maps and seek other ways to encourage property owners to maintain their land instead of raising severity levels arbitrarily.

Eric Bredo, a Los Altos Hills resident, emphasized the importance of local, detailed knowledge—highlighting that his property benefited from strong water pressure and nearby fire hydrants—and suggested that revising fire severity maps required expertise and time; he also shared that his insurance was canceled but reinstated after minor tree trimming, showing insurers do consider specific property conditions.

Allan Epstein, a Los Altos Hills resident, expressed concern the Town hasn’t provided enough legal basis for raising the standards. He questioned the consistency of street classifications, ITEM 7A ATTACHMENT 14

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mentioning his own wide, short street, Arroyo Oaks, and encouraged the council to follow existing state standards.

Peter Perlegos, a Los Altos Hills resident, urged the Town to improve its tree removal permitting process. He noted that faster approval for removing problematic trees—especially those flagged by the fire department—would make current mapping efforts more effective.

Vice Mayor Bhateja paused the meeting at 7:45PM to address technical issues with the A/V system.

Vice Mayor Bhateja reconvened the meeting at 7:53PM and resumed the Public Comments.

Sasha Zbrozek, a Los Altos Hills resident, urged the town to adopt practical changes to better reduce fire risk. He suggested allowing homeowners to create non-flammable surfaces like gravel without permits, remove certain trees near structures freely, and ease grading rules to help terrace properties and create fire breaks. Sasha also encouraged the Town to improve fuel clearing around public spaces, widen roads, trim overhanging trees, and enforce fuel clearing standards more strictly to enhance community safety.

Gerda Cristal, a resident of Los Altos Hills, emphasized that there were already many regulations in place, and once new rules were written, they could be difficult to change. She urged for simplicity in any new measures, echoing others’ suggestions, believing this approach would be appreciated by most residents.

Vice Mayor Bhateja closed the Public Comments.

Council Member Tyson acknowledged the community's concerns, noting they largely fell into two camps: fear of increased insurance risk and trust in CalFire’s expertise. While keeping things simple was tempting, he emphasized the importance of thoughtful, locally tailored decisions rather than defaulting to the state's broad approach. He praised staff for their careful work and acknowledged that while the process wasn't perfect, it was defensible and responsible. Tyson also stressed the importance of community-wide fire preparedness and personal responsibility, expressing support for continuing with higher safety standards and leaning toward adopting Option 2.

Council Member Swan emphasized the need to balance wildfire preparedness with the potential impact on residents. She expressed concern about future regret if action wasn’t taken now and lives were lost in a major fire. Acknowledging the difficulty of the decision, she showed openness to either fully applying WUI standards to all listed parcels or supporting Option 2, aiming to ensure maximum safety and preparedness for the community.

Council Member Mok supported adopting Option 2 and emphasized the need for stronger municipal ordinances requiring residents to maintain defensible space and reduce fire hazards on their properties. Drawing from personal experience with a neighbor’s house fire, he stressed that relying solely on emergency response was not enough and urged collective responsibility and ITEM 7A ATTACHMENT 14

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proactive measures. He also advocated for eventually applying fire safety standards Town-wide to better protect against future wildfire risks.

Council Member Swan asked Director Bradford whether the Town could assign a WUI (Wildland-Urban Interface) designation to the 45–50 identified parcels—giving them the same fire safety requirements as if they were mapped in a Very High Fire Hazard Severity Zone—and whether that approach could be expanded beyond those parcels. She also asked if this would be equivalent in effect to Option 2.

Director Bradford confirmed that the Council could choose not to designate the parcels now and could instead apply WUI (Wildland-Urban Interface) standards to them in the future. He affirmed Council Member Swan’s idea was valid and added that he would show mapping tools used in the evaluation process to provide more context about the parcels and the public feedback received.

Council Member Swan expressed a strong preference for designating the identified parcels as WUI (Wildland-Urban Interface) immediately, rather than postponing the decision. She emphasized that if she was to support Option 1, she wanted the WUI designations to be included at the same time, not delayed for future action.

City Attorney Mattas clarified that adding properties to the WUI (Wildland-Urban Interface) designation was not on the agenda for that meeting, so the Council could not take that action at this time. However, the Council could direct staff to bring it back for future consideration, potentially when updating building codes.

Council Member Tyson clarified that updating the WUI (Wildland-Urban Interface) designation affected more than just new construction. While someone mentioned only 15 new houses were being built per year, Tyson emphasized that the regulations applied to all properties within the designated zones—not just new builds. Therefore, changing the WUI designation impacted a broader group of residents, not a small subset.

Vice Mayor Bhateja questioned whether there are ways to mandate wildfire safety requirements for all town residents—not just those involved in new construction. He expressed interest in exploring the broader implementation of safety standards regardless of building activity.

Director Bradford explained how the town used Cal Fire’s GIS data to inform fire hazard designations and made minor local adjustments based on topography, weather, and public feedback. He clarified that in some cases, properties already had high or very high designations from Cal Fire, even if residents thought otherwise. Bradford emphasized that the Town has taken a careful, measured approach and supports continued investment in wildfire mitigation, noting that risk factors were consistent across the town and not confined to specific areas.

Vice Mayor Bhateja opposed increasing fire hazard severity zones due to potential impacts on property values. He supported using the state maps and implementing Town-wide fire prevention ITEM 7A ATTACHMENT 14

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through local ordinances. He emphasized the need for defensible space, easier hazardous tree removal, and broader mitigation efforts. He concluded by calling for a motion.

Vice Mayor Bhateja then asked City Attorney Mattas about a draw vote on a motion, and he responded that there needed to be a minimum vote of 3 votes to pass.

Council Members Mok and Swan restated their interest in which option they would support.

Council Member Tyson offered comments to support his earlier statements.

Vice Mayor Bhateja supported a measured approach, suggesting the Town adopt the state fire severity maps but act quickly to pass local ordinances requiring defensible space measures. He emphasized the flexibility of ordinances over permanent severity zone designations, warning that increased zones could negatively impact property values and insurance. He advocated for a solution that balanced fire safety with minimizing financial harm to residents.

A discussion regarding the pros and cons of the two options between the Council Members ensued.

City Attorney Mattas clarified that the ordinance presented included both options, and for the record, the motion being considered should specify adopting the parts related to Option 2 and removing the language that pertains to relying solely on the CalFire map (Option 1).

Council Member Tyson n made a motion to adopt of the Local Amendment map (Option 2) and make findings that, based on substantial evidence in the record, the requirements of Government Code Section 51182 are necessary for effective fire protection within certain areas of the Town and designate areas not identified as Very High and High Fire Hazard Severity Zones by the State Fire Marshal, as Very High, and High Fire Hazard Severity Zones. It should be noted that the above stated findings are required only for the purposes of increasing certain parcel designations to Very High Fire Hazard Severity Zones. Council Member Swan seconded.

APPROVED, VOTE 3-1
MOTION PASSED: 3-1
AYES: Mok, Swan, Tyson
NOES: Bhateja
RECUSE: Tankha
ABSTAIN: None
ABSENT: None

8. NEW BUSINESS
A. Consideration and Direction Regarding the Town of Los Altos Hills' 70th Anniversary Celebratory Activities
Community Services Supervisor Emina Mahic presented an update on planning for the Town of Los Altos Hills' 70th anniversary celebration. She explained that the idea originated from a Council-initiated item in April, prompting both the History Committee and the Parks and Recreation and Community Events Committee to meet and brainstorm ideas. The History ITEM 7A ATTACHMENT 14

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Committee recommended a modest three-part celebration in 2025, followed by a larger gala event in 2030 for the 75th anniversary. Their proposed activities include formal recognition during the December Council reorganization with a birthday cake, potential heritage house tours (pending renovation completion), and historical displays or open houses throughout the year involving students and the community. Additionally, they suggested including a birthday cake at the Town Picnic to reach a broader audience.

Meanwhile, the Parks and Recreation and Community Events Committee considered a variety of celebratory formats, ranging from formal events like a masquerade ball or black-tie gala to smaller events throughout the year. They proposed several potential venues—including local country clubs and wineries—with estimated ticket prices ranging from $150 to $220 per person. Entertainment options discussed included a DJ and interactive elements such as a community cake contest. The committee is still gathering details on venue availability and pricing before making final recommendations. Emina concluded by requesting City Council direction on how staff should proceed with planning the 70th anniversary activities.

Public Comments:

Jim Waschura, a Los Altos Hills resident, suggested that waiting until the 75th anniversary of the Town of Los Altos Hills is the best idea for a big event. Mr. Waschura thinks we should celebrate the Town’s 70th birthday in collaboration with the annual Town Picnic.

Kjell Karlsson, a Los Altos Hills resident, thinks the Town should celebrate the 70th anniversary and the 75th anniversary.

Duffy Price, a Los Altos Hills resident, loved the idea that we should celebrate the 70th anniversary at the Town Picnic and the History Committee can do a tour of the Heritage House.

Mrs. Price suggested creating a committee to organize the anniversary events.

There was a consensus of the City Council to celebrate the 70th Anniversary in collaboration with current Town events (i.e., Council Reorganization and Town Picnic). The History Committee will work on an Anthology to celebrate the 75th Anniversary of the Town of Los Altos Hills.

B. Review and Reappointment of Active Ad Hoc Committees ITEM 7A ATTACHMENT 14

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C. Consideration of Adding a City Council Meeting on Monday, July 21, 2025, and Canceling the Scheduled Regular City Council Meeting on Thursday, August 21, 2025 Council Member Swan made a motion to add a Regular City Council Meeting on Monday, July 21, 2025 and Cancel the Scheduled Regular City Council Meeting on Thursday, August 21, 2025.

Council Member Mok seconded the motion. APPROVED, VOTE 5-0

9. REPORTS FROM COMMITTEES, SUB-COMMITTEES, AND COUNCIL MEMBERS ON

OUTSIDE AGENCIES
A. Work Summary and request for increased staffing and budget for the Planning Department Planning Commission Chair Rajiv Patel provided an update on Planning Commission activities, including staffing and budgeting needs for the Planning Department. He reported that many Housing Element-related activities, ordinance updates, and ministerial checklist tasks are progressing slower than appropriate, while other important topics such as fire safety, road safety, tree ordinances, and landscape policy reviews are not currently prioritized. He noted that activities that should be performed by staff are being offloaded to contractors, resulting in a loss of critical institutional knowledge. Chair Patel recommended reviewing and planning Planning Department staffing to an adequate level, using consultants as needed for expertise or peak workloads, and hiring staff ahead of anticipated needs, particularly as workload will increase with multi-family housing planning and increased ministerial reviews.

Chair Patel also summarized updates from the May 1, 2025, Planning Commission meeting, which included discussions and clarifications on SB-9 ordinance floor area exemptions (clarifying there are no exemptions for SB-9 developments, only for ADUs), SB-9 maximum floor area for sub-acre lots under SB 450, interpretations of the Town’s grading policy for height restrictions on decks, balconies, and terraces, updates to the Water Efficient Landscape Ordinance, and ongoing work on multi-family zoning and objective design standards.

PUBLIC COMMENTS:

Jim Waschura, a Los Altos Hills resident, emphasized that the Planning Commission has already stripped away everything nonessential and is only working on urgent items. Waschura explained that the main issue is not whether residents feel well-served in the permitting process, but rather fulfilling state housing mandates and completing housing element requirements on time and adequately. He noted that while resident input does create some hurdles, it must be integrated, and with the pace of quick changes, mistakes will occur and need correction later.

Waschura stated that the increasing workload is not temporary or at a peak level that can be handled by hiring consultants, but is a growing demand due to ministerial approvals and related work. He recommended the Town prepare for this increasing workload by hiring ahead of need, suggesting that if four staff are needed, five should be hired, especially given the quick turnover rate of about one and a half years. He concluded by emphasizing that there is no longer an option to sort urgent from important tasks, as only important obligations to the state and housing element remain, and those are his main concerns.

Peter Pertegos, a Los Altos Hills resident, provided live statistics on current permit timelines experienced by residents. He shared that it currently takes approximately seven months to receive an encroachment permit needed to prune trees in the public road area, work which the fire ITEM 7A ATTACHMENT 14

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department has mandated to obtain final permit approval. Additionally, driveway modification or improvement permits are taking about six months. Pertegos agreed with Planning Commission Chair Rajiv Patel that some items do not need to be outsourced to third-party consultants. He noted that plan-checking an existing driveway improvement for simple resurfacing should not require a full plan check, as it adds unnecessary burden and delays. Clarifying his example, Pertegos explained that while the fire department approves access routes and may recommend tree pruning for fire truck clearance, it is the Town’s permit process for this pruning that took seven months. He concluded by stating there is a shortage of staff and suggested that there should be a way to fast-track simple permit requests.

John O’Connell, a Los Altos Hills resident, stated that there is no question the experience and knowledge of the Town’s code have decreased over time, noting that it takes time to build up this understanding because the code is complex, though not intentionally so. He commented that while the Town should increase ministerial approvals for planning applications, fast-tracking is not the solution, as it allows inappropriate projects to go through due to staff not knowing the code well enough. Instead, he recommended revising the code to enable ministerial approvals, which would mean that applications not meeting the clear standards would simply be rejected, discouraging architects from submitting noncompliant plans. O’Connell emphasized that this approach requires significant work and experienced staff. He concluded by saying the key message he heard was that the Town does not have enough people, and while Planning Commission Chair Rajiv Patel suggested forming a committee to determine staffing needs, O’Connell proposed directly hiring three new planners to improve staff capacity and experience in planning.

Sabrina Powers, a Los Altos Hills resident, shared that she received her temporary occupancy last week and will be moving in this week. She stated that based on her experience with the planning and building process over the past four years, she agrees with Planning Commission Chair Rajiv Patel that the Town needs to hire more staff, as the permitting process is slow.

Bowers described situations where she began the permitting process only to later be told her proposal was not allowed, resulting in wasted time and fees. She suggested that having more senior planners would be helpful and noted that Jeremy Lowe, their first planner, was excellent.

Bowers expressed appreciation for improvements made by Jay Bradford, such as allowing digital submissions, which eliminated the need for her to personally drive plans to CSG to save processing time. She concluded by emphasizing that while these changes have helped, the department remains short-staffed, and she would be happy to speak with anyone further about her experiences, as they have not yet received their permanent occupancy.

Allan Epstein, a Los Altos Hills resident, stated that well-run systems require measurements and feedback, and the reason questions cannot be answered is that performance is not being measured. He noted that the Planning Department is supposed to produce monthly reports detailing the number of houses coming in for permits, but no such reports have been issued in 2025. Epstein emphasized that measuring system performance, having a feedback loop, and evaluating processes are necessary. He praised Jay Bradford for doing a fabulous job despite ITEM 7A ATTACHMENT 14

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being overwhelmed with work, describing him as a “one-handed paper hanger” needing more assistance. Epstein added that to implement administrative processes effectively, the Town needs clear procedures, checklists, and detailed guidelines. He commented that in the past, excessive building permits resulted from a lack of procedures on how policies should be implemented, combined with staff turnover, leading people to do their best without clear direction. He concluded by stating that better procedures, measurement, feedback, and additional staff are needed.

Vice Mayor Bhateja made a motion directed staff to establish a date for a Study Session to discuss Performance and Staffing in the Planning Department. Council Member Mok seconded the motion. APPROVED, VOTE 5-0
B. Ad Hoc Committee recommendation regarding the process for consideration of potential housing sites
Vice Mayor Bhateja and Council Member Stanley Mok jointly presented Item 9B (Ad Hoc Committee Recommendation Regarding the Process for Consideration of Potential Housing Sites) and Item 9C (Ad Hoc Committee Report on the Development Agreement Option) as a combined item.

C. Ad Hoc Committee Report on Development Agreement Option Vice Mayor Bhateja explained that the City Council had directed them to pursue three options: one proposed by Resident John O’Connell, one proposed by the consultants including Veronica Tam and representatives from Michael Baker, and a third for the ad hoc committee to revisit a possible development agreement. At the March 20th Council meeting, one option was removed, leaving only the consultant proposal and the development agreement option. Vice Mayor Bhateja stated that their approach to the development agreement was to represent the Town’s interests and achieve the goals defined for them, using a win-win mentality with the owner and considering resident input and Town ordinances. They held over 60 hours of meetings with the owner’s representatives, the city attorney, staff, and residents during two study sessions. Despite making several attempts to come to a meeting of the minds and being very close on a couple of occasions, there were continual, abrupt, and sudden changes, reversals, and reneges from the other side, often happening late in the process, such as 48 hours before a Council meeting, making it very challenging to reach an agreement. Vice Mayor Bhateja noted that development agreements are far more complicated and difficult to negotiate than key terms agreements, and since they were not meeting with success even on key terms, they felt it did not bode well for pursuing a development agreement. Therefore, their efforts failed, and they are recommending terminating the ad hoc committee and giving up on the development agreement option. The only remaining option is to amend the land use element and housing element according to the consultants’ proposal, which focuses development on lots 4, 5, and 6, whereas the ad hoc committee approach focused more on lots 1 and part of lot 2.

Council Member Mok added that there are 20 months until the mid-cycle review on January 31, 2027, and by that time some permits should be drawn. In his opinion, this is not going to be possible with Twin Oaks, the current sites, or Saint Nicholas School, as they have not given positive input.

Foothill College reduced the number of units they are allowing from 200 down to 50, and there is no assurance of progress on any sites at this point. Council Member Mok explained that site ITEM 7A ATTACHMENT 14

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selection is a very long and extraordinarily complex process and recommended starting consideration of alternative sites now to help with the current cycle and prepare for the next. He noted that at every meeting he and Vice Mayor Bhateja had a different set of documents to review than previously agreed upon, and final documentation always came back different. Each side had attorneys reviewing the documents, and despite getting very close, the agreements always fell apart due to other issues. He thanked City Attorney Steve Mattas for always being there for them, including during holidays and expressed gratitude to City Manager Peter Pirnejad for his diligence, patience, and willingness to attend meetings even on weekends and holidays, despite some meetings not being kind. Council Member Mok also thanked staff, consultants Michael Baker and Associates, and residents for their valuable input and participation, emphasizing that their involvement is important because the work is not done yet.

Council Member Mok concluded, recommending that the ad hoc committee be dissolved and the development agreement option terminated. He noted they gave it every try and while they failed temporarily, it is not a permanent condition, and they will continue until there is a resolution. He recommended proceeding with zoning under the plan proposed by the consultants, and if there are any needed changes, they will make those recommendations as well. Finally, he suggested directing staff to begin considering alternative sites for multifamily housing, acknowledging that although this is not a low-resource task, having viable alternative sites available would be beneficial to meet RHNA numbers by 2031 or for use in the next cycle.

Public Comment:

1. John O’Connell, Town of Los Altos Hills resident, reminded the Council that during the housing element scoping discussions, he had written to them on February 9th emphasizing that identifying additional housing element sites was a key decision, but the Council decided not to pursue it at that time. He stated that it now needs to be done quickly, as he believes the letter recently received indicates a far bigger problem than just the mid-cycle review. He expressed concern that the letter was deliberately intended to make it impossible for the Town to move forward with developing lots 4, 5, and 6, which would trigger a 180-day clock and could result in the housing element becoming decertified, something he described as Council Member Linda’s greatest fear becoming reality. O’Connell emphasized the urgency of the situation and clarified that the housing element amendment he proposed had been narrowed down to a discussion comparing the Michael Baker proposal with his approach to dwelling units per acre. He recommended first recalculating the remaining need to reduce the problem’s scale, then recalculating the buffers, and finally to identify 50 sites and complete the work. He concluded by stating that if his first recommended step had not been terminated, the Town would have been ready to submit the housing element amendment to HCD by the end of this month.

Vice Mayor Bhateja made a motion terminate the discussion on the Twin Oaks Development Agreement and dissolve the Housing Element Ad Hoc Committee. Council Member Tyson seconded the motion. APPROVED, VOTE 5-0.

MOTION PASSED: 5-0
AYES: Tankha, Bhateja, Mok, Swan, Tyson
NOES: None
RECUSE: None
ABSTAIN: None
ABSENT: None
ITEM 7A ATTACHMENT 14

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Council Member Tyson made a motion to extend the City Council Meeting past 10 PM in compliance with Ordinance No. 506. Mayor Tankha seconded the motion. APPROVED, VOTE 5-0
Council Member Swan made a motion to not direct staff to consider alternate sites for multifamily. The motion failed due to a lack of a second.

Vice Mayor Bhateja made a motion that we direct staff to proceed with considering alternate sites for multifamily housing without disrupting the January 31st deadline. Mayor Tankha seconded the motion. APPROVED, VOTE 4-1.

MOTION PASSED: 4-1
AYES: Tankha, Bhateja, Mok, Tyson
NOES: Swan
RECUSE: None
ABSTAIN: None
ABSENT: None

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

B. City Clerk Arika Miller provided an update on the implementation of the electronic voting system. At this time, we are still working through a few remaining technology-related issues that need to be resolved before we can fully roll out the software.

C. Planning Director Jay Bradford expanded on the organization's staffing levels as a follow up to a presentation made by the Planning Commissioner Rajiv Patel. This report highlighted the balance between current planning responsibilities and additional long-range planning items being added to staff workload as the department assesses long-term staffing needs to match the projected tasks through the coming budget cycle. Director Bradford also reviewed the department's recent work, preparing new Fire Hazard Severity Zone maps for Council hearing and highlighted ongoing work on long-range planning efforts, including the Housing Element Amendment and key ordinance amendments, which are being heard at the Planning Commission level. The report included an update on the department's summer Internship program, which concluded interviews this week, and is slated to begin with two new interns are joining the team in early June.

D. Finance Director Thomas Leung provided the following update: Intern Interviews: We held interviews this week for our upcoming internship program. We look forward to welcoming a new intern who will support a range of Town projects this summer. FY 2025–26 Proposed Budget: The Proposed Budget is now available online at the Town's website. Printed copies are also available at Town Hall for City Council and FIC members. Two key meetings are scheduled:

On May 22 at 4:00 PM, there will be a joint Council and Finance & Investment Committee meeting to present the Proposed Budget. On June 26 at 6:00 PM, the Council will consider and adopt the final budget. Annual Interim Audit: Our annual interim audit for FY 2024–25 is currently underway. The external auditors are reviewing our financial systems, internal controls, and preliminary balances in preparation for the year-end audit. This is a standard part of our annual financial reporting process, and I want to thank staff for their cooperation. Routine State Audit – Gas Tax & RMRP: The State Controller’s Office will be conducting an on-site audit beginning May 19. This will cover the Town’s Special Gas Tax Street Fund 7 City Council ITEM 7A ATTACHMENT 14

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20 City Council May 15, 2025, Regular Meeting Minutes
Regular Meeting Recap May 15, 2025 and Road Maintenance and Rehabilitation Program for the fiscal year ending June 30, 2024. The audit may include review of transactions as far back as the last Gas Tax audit, which ended in 2003. Fieldwork is expected to last about four weeks.

E. Public Works Director WooJae Kim provided the following update: Mowing Schedule Every year around this time in spring, residents inquire and request vegetation mowing around the Town. The Public Works maintenance staff mow along public ROW, pathways, and open space. The Town’s mowing work started last month, and it will continue through the summer, even during some Saturdays. We try to start mowing to minimize a second round of mowing needed. Staff request that residents continue to submit mowing requests on the non-emergency, “Report a Problem” portal, on the Town’s website. Speed Limit Signs on Altamont Road The vehicle speed limit for Altamont Road is 30 MPH. Upon a request from the Sheriff’s Office, staff will be installing few more speed limit signs along Almonte Road between Page Mill and Moody as an attempt to make drivers more aware of the traffic speed limits and also so that speed enforcements can occur. Speed Feedback Sign For the new speed feedback sign, the Town recently received the sign with a new trailer. This unit can be hauled to different streets in the Town to flash speeds of vehicles and also to keep track of excessive vehicular speeds. This information can be shared with the Sheriff’s Office to conduct more focused traffic enforcement.

Staff will start rolling out the sign soon after receiving training on the cloud application that keeps track of the speed data. Summerhill Avenue Pathways – Phase II Staff was asked to report out on the schedule of the Summerhill Pathway project. Phase II of the project involves installing pathways on the remainder of Summerhill Road between Nicole Lane to Magdalena. Phase II project had to be postponed due to other priority projects being added to the Council Work Plan.

Staff is still working with the County for the encroachment permit, which is pending approval of the final plans, mitigation plan for trees being removed, and maintenance and indemnification agreement for the pathway to be built. There is still one property where an easement is required for the project to move forward. Staff is aiming spring of next year to secure the encroachment permit from the County and start construction by summer 2026. Biking Advisory Signages for Pathways As a Council Initiated Item on April 17, the City Council directed staff to bring back an item to Council to request the Pathways Committee to investigate safety concerns of bikes on pathways and make recommendations. Staff initiated the discussion with the Pathways Committee at their April 28th meeting. They will review the issue and recommend advisory signages for bicyclists to slow down at certain pathways. Staff will bring back Pathways Committee’s recommendations to Council for consideration at a future time. Ford F250 Replacement At the February 20th meeting, Council authorized the replacement of the Ford F250 truck, 8 City Council Regular Meeting Recap May 15, 2025 which required a new engine and a radiator. Last week, the Town received the replacement truck from Ford Store in Morgan Hill.

The truck is almost fully equipment. The Town was able to obtain Ford F450 with higher payloads and towing capacity for only a couple of thousand more, but well within the amount authorized by Council.

F. City Manager Peter Pirnejad provided the following update: The City Manager acknowledged the dedication and hard work of Town staff in supporting the evolving goals of the City Council. Despite being a lean team, staff members routinely go above and beyond— often working extended hours and even adjusting personal time—to ensure Council initiatives and priority projects remain on track. PalAmerican Contract The current contract with PalAmerican, which covers Fiscal Year 2024–2025, is set to expire on June 30, 2025. In alignment with City Council discussion held in February, staff is proposing to enter into a new agreement for Fiscal Year 2025–2026, maintaining the existing service level of three patrol shifts per day. Unless concerns are raised, staff will proceed with executing the contract for the next ITEM 7A ATTACHMENT 14

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21 City Council May 15, 2025, Regular Meeting Minutes
fiscal year. KMVT Services KMVT broadcasting services are scheduled to begin in July. A preliminary demonstration was conducted during the meeting, and the service appears to have been positively received. “Short-Sleeve” Study Session Staff is planning an informal "ShortSleeve" Study Session with the City Council in late September. This session will serve as an opportunity to discuss a range of emerging topics relevant to the Town, including: • South County Fire District • 2035 mandate for electric vehicle transitions • Garbage contract renewal • Westwind Barn improvements (arenas, barn, paddocks) • Town communication strategies • Emergency preparedness • Long-term fiscal sustainability, including revenue and expenditure alignment Coyote Town Hall The Town and its partner agency, Palo Alto Animal Control, have seen an increase in calls regarding coyote activity. To enhance public education on coexistence and safety practices, staff is organizing a Coyote Town Hall. The event—last held eight years ago—is tentatively scheduled for late June and will be promoted via the Town’s weekly newsletter and website. Internship Program Staff has begun interviewing candidates for the summer internship program. The Town anticipates filling five intern positions for the June– August term. Contract Management System – Laserfiche A new contract management module has been implemented within the Town’s Laserfiche system. The platform will assist staff in tracking expiring agreements and, for added transparency, allow the public to access contracts through an online portal. Upcoming Events 78th Annual Los Altos Kiwanis Pet Parade The Town of Los Altos Hills will participate in the 78th Annual Los Altos Kiwanis Pet Parade on Saturday at 10:00 AM in Downtown Los Altos. Residents are invited to walk with 9 City Council Regular Meeting Recap May 15, 2025 the Town banner and showcase their pets in this cherished community tradition. Town Picnic – Sunday, June 1, 2025 The annual Town Picnic will feature a barbecue lunch by Coyote Sergio BBQ (new this year), along with beverages, ice cream, live entertainment, and games for all ages. The 15th Classic Car Show will also be held, highlighting vehicles owned by local residents. This event is organized by the Parks, Recreation, and Community Events Committee with support from dedicated community volunteers. Preregistration is required for accurate meal planning, and attendees must present proof of residency.

Please note that pets are not permitted at the event.

COUNCIL INITIATED ITEMS
A. Discussion and Consideration of Opposition to Assembly Bill 306 There was a Consensus of the Council to bring this item back on a future agenda City Council Meeting Agenda.

B. Consider and create a City Council Ad Hoc Committee to Review Fire Service Options for the Town
*This item was removed from consideration at this meeting.

C. Status of the current issue of Our Town
Public Comments:

Mike Salameh, spoke in support of the OurTown news publication.

Duffy Price, spoke in support of the OurTown news publication.

Dave Stewart, spoke in support of the OurTown news publication.

Jitze Couperis, spoke in support of the OurTown news publication.

ITEM 7A ATTACHMENT 14

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22 City Council May 15, 2025, Regular Meeting Minutes
Kjell Karlsson, spoke in support of the OurTown news publication.

ADJOURN
Mayor Tankha adjourned the meeting, which will be continued on June 18th to continue Item 7A at 11:28 PM.

Respectfully submitted,
Arika Birdsong-Miller
City Clerk
ITEM 7A ATTACHMENT 14

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Page 1 of 1 ends

ERRATA SHEET - AGENDA ITEM #7A
City Council Meeting
October 16, 2025
Amendments to the Draft Rezoning Ordinance
The following changes, reflected in redline (with red double underline indicating addition and strikethrough indicating deletion), will be made to Attachment 2 Exhibit A – Draft Ordinance.

Sections, paragraphs, and other texts not modified by this Errata Sheet are not included and shall remain as proposed in the agenda packet or remain effective in full force and effect. §10-1.1603 Applicability
These multi-family zone standards and requirements shall be implemented on all parcels designated as MF, MFO, and FMFO on the zoning map. Multi-family developments shall be subject to all applicable provisions of Title 10 Zoning of the Los Altos Hills Municipal Code except where exempted, superseded by, or in conflict with the provisions of this Article 16. For areas where the MF zone is applied as an Overlay (MFO) or Floating MFO, the MFO zone standards and permitted uses supersede the single-family residential uses and the agriculture uses, and shall supersede the development standards of the underlying Residential-Agricultural (R-A) zone when in conflict. All public and private school uses shall be subject to the otherwise applicable standards of the underlying R-A zone.
§10-1.1607 Conditional Uses (MFO)
The following uses may be established in the Multi-Family Overlay (MFO) and Floating Multi-Family Overlay (FMFO) zones subject to the approval of the Planning Commission, and the issuance of a conditional development permit therefor pursuant to the provisions of this Title per Section 10-1.1004:
(a) Public schools and related facilities that serve the school where designated on the General Plan Land Use Diagram where at least 50% of the gross floor area is multi-family residential use. (b) Private schools and related facilities that serve the school where designated on the General Plan Land Use Diagram where at least 50% of the gross floor area is multi-family residential use.

ITEM 7A

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From: K Z
To: City Council
Cc: Jay Bradford; Peter Pirnejad; League of Women Voters of LAMV (LWV-LAMV) Subject: October 16, 2025, Council Agenda Item 7A (Land Use Element and Multifamily Zoning Date: Tuesday, October 14, 2025 11:43:19 AM
Attachments: LAH CC-Land Use Element 10_16_25.pdf
Dear Mayor Tankha and Los Altos Hills City Council:

Attached is a letter from the League of Women Voters regarding item 5.1 on the October 16, 2025, Council agenda Agenda Item 7A (Land Use Element and Multifamily Zoning).

Thank you for your attention to this matter.

Sincerely,
Katie Zoglin
President
Los Altos-Mountain View Area League of Women Voters
ITEM 7A, Supplement 1

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October 14, 2025
Re: October 16, 2025 Council Meeting, Agenda Item 7A
(Land Use Element and Multifamily Zoning)
Dear Mayor Tankha and Los Altos Hills City Council:

The League of Women Voters (LWV) supports actions that increase the stock of housing and particularly those that increase affordable housing.

The League is concerned that the proposed 3.5 acre minimum for multifamily projects and the 750 square foot per unit maximum floor area in the Land Use Element amendments may create constraints on development. (Draft Land Use Element, p. LU13, Goal 2.) No private lot in the site inventory meets the 3.5 acre minimum. The Housing Element specifies that the Town would work to “promote site sizes between 1 and 10 acres.” (Housing Element, program A-11, p. 228.) The maximum floor area (Draft Land Use Element, p. LU-6) does not accommodate units with multiple bedrooms, and it is unclear whether this maximum would comply with the minimum floor-to-area-ratio requirements set forth in Government Code 65913.11.

The LWV suggests that the Town remove references to a maximum density of 24 dwelling units per acre (Draft Zoning Code, p. 12; Land Use Element, p. LU-16) and base density on normal acreage rather than “contiguous buildable area” given the acreage language in the Town’s currently certified Housing Element. (Housing Element, p. 209.)
Please send any questions about this letter to Susan Russell, Co-Chair of the Housing Committee, at [email protected].

Sincerely,
/S/
Katie Zoglin
President
Los Altos-Mountain View Area LWV
C: Jay Bradford
Peter Pirnejad
ITEM 7A, Supplement 1A

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October 14, 2025
Via Email: [email protected]
Hon. Chair and Members of the Los Altos Hills Planning Commission The Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
Re: Planning Commission Special Meeting on Tuesday, October 14, 2025 at 6 pm Item 3: Study Session Regarding Housing Element Implementation

FOR PUBLIC COMMENT
Dear Chair and Members of the Planning Commission:

Our office represents The Roman Catholic Bishop of San Jose, a California corporation sole, as Trustee of The Roman Catholic Diocese of San Jose Master Irrevocable Trust U/D/T dated August 8, 2011 (the "Roman Catholic Diocese"). The Roman Catholic Diocese is the owner of 12816 El Monte Road, Los Altos Hills ("St. Nicholas School Site") on which it operates St. Nicholas Catholic School ("St. Nicholas School"). St.

Nicholas School has been serving the students of Los Altos Hills for 70 plus years at this location. The school offers classes from transitional kindergarten through eighth grade and is a National Blue Ribbon School.

The property consists of two lots (A.P.N. 336-21-003 and 336-21- 004) with the school buildings straddling the lot line. In addition to the school grounds, the St. Nicholas School Site houses a rectory which includes a church. The property is an active religious institution and thus protected from unduly burdensome or discriminatory land use and zoning regulations by the provisions of the Religious Land Use and Institutionalized Persons Act of 2020 ("RLUIPA") set forth at 42 USC § 2000cc, et seq.

The Town of Los Altos Hills' 6th Cycle (2023-2031 ) Draft Amendment to the Housing Element contemplates a new multi-family overlay zoning on six acres of the St. Nicholas School in an effort to accommodate the Town's lower income regional housing need allocation ("RHNA").
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Page 741 of 796 ends

Hon. Chair and Members of the Los Altos Hills Planning Commission October 14, 2025

Page 2 ends

Included in the Agenda Package for this Special Meeting is an October 10, 2025 letter from Paul McDougall, Senior Project Manager for the Department of Housing and Community Development, Division of Housing Policy Development directed to Jay Bradford, Director of the Town of Los Altos Hills Community Development Department.

In that letter, Mr. McDougall states that the Town of Los Altos Hills' housing element:
"should evaluate whether developers or property owners continue to be interested in redevelopment on all nonvacant sites proposed to be rezoned to accommodate the RHNA (e.g., Twin Oaks, Foothill College, Saint Nicholas). If developers or property owners continue to be interested in redevelopment, then no additional analysis is necessary. If developers or property owners are no longer interested in redevelopment, then the element must demonstrate the potential for redevelopment on all nonvacant sites proposed to be rezoned to accommodate the RHNA." As set forth in my letter of October 17, 2022 addressed to the Town Council and Planning Commission, the Roman Catholic Diocese is not interested in the development of any portion of the St. Nicholas School site for multi-unit housing given the significant adverse impact such development would have on the school. The Roman Catholic Diocese intends to continue to use this site for decades to come as a religious school and place of worship and has no intention of pursuing multi-family residential development or selling the property to a developer for multifamily residential development.

Thus, the St. Nicholas site should not be included in the Town's Housing Element as a potential multi-family development and should not be subject to a multifamily overlay zoning. Rather the Town should explore other means of satisfying its RHNA.

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From: Kit Gordon
To: City Council
Subject: Oct 16 council meeting, item 7
Date: Wednesday, October 15, 2025 7:57:55 AM
Attachments: Creek Object Standard LAH PC.docx
Dear Council,
Protecting our creeks from development is required by state and federal laws. These rules not only protect the multitude of species that depend on our waterways but also protects properties from the dangerous forces of water.

In 2022, our Town received a warning email (attached) from the CA Department of Fish and Wildlife (Brenda Blinn, Kristin Garrison) and Water Quality Control Board (Brian Wines) on the importance of protection the many small tributaries in within our town borders. Insure that private properties receive a jurisdictional determination (JD) by a trained professional. For example, there is conflicting information on waterways for the Twin Oaks property. The CA Aquatic Resource Inventory shows two headwater streams on Twin Oaks property that flow to a culvert under HWY 280 This culvert was built to direct water from this property under 280. It is irrational to not acknowledge that this large culvert was built to carry water from this property.

Please see attached memo for more information on our creeks.

With flowing thanks,
Kit
ITEM 7A, Supplement 3

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To: Los Altos Hills Council
Date: October 14, 2025
Re: Council Meeting October 16, 2025
From: Kit Gordon
Below is a recommended procedure for determining locations of creeks within our Town. Background information is provided, and more information can be provided as requested. The Open Space Committee members look forward to assisting.

Why protect creeks?
The federal Clean Water Act is enforced by the EPA and US Army Corp of Engineers and regulated locally by the SF Bay Regional Water Quality Control Board and CA Dept of Fish and Wildlife. The Clean Water Act states that jurisdictional water bodies are defined by evidence. The EPA funded the creation the California Aquatic Resource Inventory (CARI) as a tool for government agencies to assist with planning. The CARI database shows the likely location for all streams, large and small, within our Town.

Objective Standard for determining creek location in Town.

1. Review existing easements of property. Over the past years, creeks have been protected with Open Space Easements, Conservation Easements and Storm Drain Easements. Existence of any of these easements may indicate a creek.

Previous Geotech reports of the property often indicate creeks and are evidenced by bridges, culverts, concrete swales, alluvial soil and colluvial soil.

2. Review the property on the CARI database: www.ecoatlas.org A blue line on this database may indicate a creek.

3. If either condition 1 or 2 exist, conduct an onsite physical evaluation of the property. The EPA has specific evidence requirements to determine a jurisdictional creek and that procedure should be followed.

4. If the developer doesn’t agree with Town assessment, a professional can be hired to make a jurisdictional stream assessment.

5. Developments should be kept away from top of bank of creeks and riparian vegetation preserved.

Valley Water’s Watershed Stewardship and Planning Department can assist the Town in defining language and procedures. The Assistant Officer is Lisa Bankosk, [email protected].

FAQ:

Creek vs Stream?
Local, State and Federal documents use the term “stream”, but our Town uses “creek”.

They are the same and are considered jurisdictional waters.

How was the California Aquatic Resource Inventory (CARI) map made? ITEM 7A, Supplement 3A

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CARI is the most complete inventory of surface waters throughout California based on a standard mapping procedure consistent with state and federal standards and guided by a statewide technical committee of the CA Water Quality Monitoring Council. It incorporates regional and local data that meet CARI standards.

State jurisdiction is mainly determined and enforced through Regional Water Quality Control Boards. Federal Jurisdiction is determined by the US Army Corps of Engineers and/or the US Environmental Protection Agency.

Definition from EPA website
The Clean Water Act defines “tributaries” as waters that are characterized by the presence of physical indicators of flow—bed and banks and ordinary high water mark— and that contribute flow directly or indirectly to a traditional navigable water, an interstate water, or the territorial seas. The rule concludes that such tributaries are “waters of the United States.” The great majority of tributaries as defined by the rule are headwater streams that play an important role in the transport of water, sediments, organic matter, nutrients, and organisms to downstream waters. The physical indicators of bed and banks and ordinary high water mark demonstrate that there is sufficient volume, frequency, and flow in such tributaries to a traditional navigable water, interstate water, or the territorial seas to establish a significant nexus. “Tributaries,” as defined, are jurisdictional by rule.

What about those very small creeks and swales?
Los Altos Hills terrain is continually being shaped by water. Any topographical ravine likely has a creek. The majority of creeks in town are small, no-name headwater creeks.

These small headwater creeks are essential for water quality and nutrient cycling.

Below is a note sent specifically to our Town regarding protection of these small creeks.

Our Town requires protection of swales in addition to creeks. A swale is a drainage area without defined bed and bank. i.e., does not qualify as a jurisdictional creek.

Comment sent to the Town from Brian Wines, Regional Water Quality Control Board
From: "Wines, Brian@Waterboards" <[email protected]> Subject: Extent of jurisdictional waters of the State
Date: March 8, 2022 at 4:29:53 PM PST
To: "[email protected]" <[email protected]>, "[email protected]" <[email protected]> Cc: Kit Gordon <[email protected]>, "Blinn, Brenda@Wildlife" <[email protected]>, "Garrison, Kristin@Wildlife" <[email protected]>, Oscar Antillon
<[email protected]>
Hello Mr. Loh
I have been informed that there has been some discussion at the Town of Los Altos Hills about the extent of waters that must be protected as waters of the

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Los Altos Hills City CouncilOctober 16, 2025

Los Altos Hills City Council
October 16, 2025