Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 181 Town Policies
Fund Balance
This policy is intended to ensure that the Town has sufficient cash flow to meet current and future needs and provide transparency to its residents by establishing fund reserve targets for each of the Town’s governmental funds. Reserve funds are needed to provide funding for planned and unplanned events. Planned events include, but are not limited to, (1) accumulating balances to fund operating and capital needs; (2) debt service obligations; and (3) funding for employee-related pension and other post-employment benefits. Unplanned events include, but are not limited to, (1) accounting for revenue shortfalls; (2) unanticipated expenses; and (3) paying for unforeseen emergency events.
Adequate fund reserves are of value to: (1) provide working capital to fund operating needs; (2) provide a financial cushion for dealing with unanticipated financial needs and emergencies; and (3) are a component of achieving favorable credit ratings which can help reduce the costs of issuing debt. This policy designates specific reserve accounts. For each reserve, this policy specifies the reserve purpose, the threshold amount, allowable uses of reserves, and replenishment of the reserve. This policy establishes committed and assigned reserves. Committed or Assigned reserves may be established, changed, applied, and deleted by Council resolution. Committed reserves may be used for one or more limited activities noted in the purpose or usage of the reserve. Assigned reserves are not limited to one single activity and may be used for any Town specific activity described in the purpose or usage of the reserve.
Fund Balance Classifications
To set forth the Town’s policy for establishing and maintaining fund reserve targets for each of the Town’s governmental funds. Fiscal reserves provide working capital for operations and maintenance activities, funding for IT, vehicle, and equipment needs, fulfillment of legal, regulatory, and contractual obligations and mitigation of risk and liability exposures.
The Town is required to reclassify fund balances into the following five categories to comply with the Governmental Accounting Standards Board Statement (GASB) No. 54, Fund Balance, and Governmental Fund Types.
Non-Spendable: This is a portion of fund balance not available for appropriations by its nature or external restriction.
Examples are inventories, prepaid expenses and loans to other agencies.
Restricted: The restricted portion of the fund balance is subject to externally enforceable legal restrictions. Examples are Gas Tax revenues and grant proceeds.
Committed: The committed portion of the fund balance is constrained by the limitations imposed through formal City Council action. Only formal City Council action can remove or modify a previously committed amount.
Unassigned: The Unassigned portion of fund balance is that remaining after the non-spendable, the restricted, the committed, and the assigned fund balances are identified and recorded. The general fund is the only fund that reports a positive unassigned fund balance.
Assigned: The assigned portion of the fund balance is established for intended use by either the City Council or its designee, such as the City Manager. No formal City Council action is needed to remove the intended use. GAAP required reserves, such as the Other Post-Employment Benefits (OPEB) reserve, belong to this category.
Order of Utilization
The Town will use GASB’s definitions of fund balance for the annual financial reports (audits) and for all other financial reporting. For all financial planning purposes, the term Budgetary Fund Balance will be used and will include
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any portion of the fund balance that is available for appropriation. Portions of the fund balance not available for appropriations will be identified as follows.
The Town shall strive to use the most restricted fund balances prior to utilizing those that are less restricted. This policy establishes the order of use of unrestricted resources as follows:
> Nonspendable (if funds become spendable)
> Restricted
> Committed
> Assigned
> Unassigned
Finance Reporting
A system of effective internal controls will be maintained that ensures only properly authorized expenditures, recordings of financial transactions, and accounting entries are executed. Along with providing management information and meeting reporting requirements.
Accounting and Finance Responsibilities
Management’s discussion and analysis (MD&A). MD&A should introduce the basic financial statements and provide an analytical overview of the government’s financial activities. Each basic financial statement should include:
1. Government-wide financial statements, consisting of a statement of net assets and a statement of activities.
2. A series of statements that focus on information about the government’s major governmental and enterprise funds, including its blended component units.
Annual Audit
The Town aims to maintain its accounting records, processes, and procedures in a manner that supports the issuance of an unmodified (clean) audit opinion. Responsibility for the accuracy of financial information and the completeness and fairness of its presentation—including all required disclosures—rests with Town management.
Each year, an independent public accounting firm with expertise in municipal finance conducts the Town’s financial audit. The resulting audit opinion is included in the Town’s Annual Comprehensive Financial Report (ACFR), which is organized into three primary sections: introductory, financial, and statistical. The independent auditor’s report appears first within the financial section.
Following the auditor’s report, the Management’s Discussion and Analysis (MD&A) provides a narrative overview of the Town’s financial performance. It includes a comparative analysis of current and prior year results, highlights significant financial trends, and discloses key events or decisions affecting the Town’s fiscal position. The MD&A serves to enhance readers’ understanding of the Town’s financial statements by offering context and analysis.
Accounting During a Disaster
The Finance and Administrative Services Department is responsible for the Town’s participation in disaster assistance funding. Breaking down responsibilities into four main sections, (1) Compensation and Claims Unit, (2) Cost and Purchasing Unit, (3) Time Keeping Unit, and the (4) Recovery Unit. Ensuring that the Finance and Administrative Services Department continues to assist staff, elected officials, and the Town in saving time and energy when making financial decisions, promoting public confidence, and the development emergency management.
Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 183 Town Policies
In the case of an emergency all reimbursements that are based on disaster related expenses should be recorded by each department. Each department is responsible for keeping thorough, accurate and complete records regarding all expenses that are incurred as a latter result of a declared disaster. Without proper documentation, requests for reimbursement will be denied.
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Investment Policy
Adopted by the City Council on February 20, 2025
1.0 Philosophy
It is the policy of the Town of Los Altos Hills to invest public funds in a manner that will provide a reasonable rate of investment return while minimizing exposure to loss of capital and thereby maintaining a consistent source of revenues for the Town. This policy establishes the parameters for the Town’s investment strategies.
2.0 Delegation of Authority
Authority to manage the Town of Los Altos Hills’ investment program is derived from the California Government Code Section 53600 et seq. The City Council shall approve all modifications to the investment strategy and the selection or dismissal of an investment advisor. Administration of the Council-approved investment strategy is hereby delegated to the City Manager, who shall be responsible for supervising all treasury activities of the Town’s Finance Director and who shall establish written procedures for the operation of the investment program consistent with this investment policy. Procedures should include reference to: safekeeping, delivery vs. payment, investment accounting, wire transfer agreements, banking service contracts and collateral/ depository agreements. Such procedures shall include explicit delegations of authority to persons responsible for investment transactions. No person may engage in any investment transactions except as provided under the terms of this policy and the procedures established by the City Manager or her/his designee. The City Manager or her/his designee shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials.
3.0 Scope
This investment policy applies to all financial assets of the Town of Los Altos Hills. These funds are accounted for in the Town of Los Altos Hills’ Annual Comprehensive Financial Report (ACFR) and include:
3.1 Funds
General Fund Enterprise Funds
Special Revenue Funds Capital Projects Funds
Trust and Agency Funds
Any new fund, unless specifically exempted
3.2 The following financial assets are excluded:
Deferred Compensation Plans – Investments are directed by the individual plan participants.
Debt Service Funds Held by Trustees – Investments are placed in accordance with bond indenture provisions.
Notes and Loans – Investments are authorized by separate agreements approved by City Council.
Retiree and Retiree Medical Plans
Except as noted, the Town of Los Altos Hills will consolidate cash balances from all funds to maximize investment earnings. Investment income will be allocated to the various funds based on their respective participation and in accordance with generally accepted accounting principles.
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4.0 Prudence
Investments shall be made with judgment and care – under circumstances then prevailing – which persons of prudence, discretion and intelligence exercise in the management of their own affairs, not for speculation, but for investments, considering the probable safety of their capital as well as the probable income to be derived.
4.1 Standard of prudence:
The standard of prudence to be used by investment officials shall be the “prudent investor” standard and shall be applied in the context of managing an overall portfolio. When investing, reinvesting, purchasing, acquiring, exchanging, selling, or managing public funds, a trustee shall act with care, skill, prudence, and diligence under the circumstances then prevailing, including, but not limited to, the general economic conditions and the anticipated needs of the agency, that a prudent person acting in a like capacity and familiarity with those matters would use in the conduct of funds of a like character and with like aims, to safeguard the principal and maintain the liquidity needs of the agency.
5.0 Objective
The primary objectives, in priority order, of the Town of Los Altos Hills’ investment activities shall be:
5.1 Safety:
Safety of principal is the foremost objective of the investment program. Investments of the Town of Los Altos Hills shall be undertaken in a manner that seeks to ensure the preservation of capital in the overall portfolio. The objective is to minimize (1) credit risk, through diversifying the portfolio among the authorized investment types with pre-qualifying financial institutions and broker dealers, and (2) interest rate risk, by structuring portfolio maturities to match cash requirements and investing operating funds in shorter-term securities.
5.2 Liquidity:
The Town of Los Altos Hills’ investment portfolio will remain sufficiently liquid to enable the Town of Los Altos Hills to meet all operating requirements which might be reasonably anticipated. In addition to structuring the portfolio so that securities mature concurrent with cash needs, suitable investments (Section 6.0) consist largely of securities with active secondary or resale markets.
5.3 Return on Investments:
The Town of Los Altos Hills’ investment portfolio shall be designed with the objective of attaining a market rate of return throughout budgetary and economic cycles, commensurate with the Town of Los Altos Hills’ investment risk constraints and the cash flow characteristics of the portfolio.
6.0 Authorized and Suitable Investments
Where this section specifies a percentage limitation for a particular security type, that percentage is applicable only on the date of purchase. Credit criteria listed in this section refers to the credit rating at the time the security is purchased. Where credit requirements in this section refer to a minimum credit rating, this minimum is regardless of any category modifiers such as “+” or “-”. If an investment’s credit rating falls below the minimum rating required at the time of purchase, the City Manager will perform a timely review and decide whether to sell or hold the investment.
The Town of Los Altos Hills is empowered by Government Code Section 53601, 53601.6, 53601.8, 53635, 53635.2, 53638, and 53684 which includes a number of requirements on how and where public money may be invested. Within the context of limitations, the following investments are authorized, as further
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limited herein. A security purchased in accordance with this section shall not have a forward settlement date exceeding 45 days from the time of investment. The Town is empowered by statute to invest in the following type of securities:
1. United States Treasury notes, bonds, bills, or certificates of indebtedness, or those for which the faith and credit of the United States are pledged for the payment of principal and interest.
2. Federal agency or United States government-sponsored enterprise obligations, participations, or other instruments, including those issued by or fully guaranteed as to principal and interest by federal agencies or United States government-sponsored enterprises.
3. Obligations of the State of California or any local agency within the state, including bonds payable solely out of revenues from a revenue-producing property owned, controlled or operated by the state or any local agency or by a department, Commission, agency or authority of the state or any local agency; provided that the obligations are rated in one of the three highest categories by a nationally recognized statistical rating organization (NRSRO). Purchases of municipal obligations in sections 3 and 4 combined may not exceed 30 percent of the Town’s investment portfolio.
4. Registered treasury notes or bonds of any of the other 49 states in addition to California, including bonds payable solely out of the revenues from a revenue-producing property owned, controlled, or operated by a state, or by a department, board, agency, or authority of any of these states; provided that the obligations are rated in one of the three highest categories by a NRSRO. Purchases of municipal obligations in sections 3 and 4 combined may not exceed 30 percent of the Town’s investment portfolio.
5. Bankers’ Acceptances with a rating of the highest ranking or highest letter and number rating as provided for by a NRSRO. Purchases of bankers’ acceptances may not exceed 180 days. No more than 40% of the Town’s investment portfolio may be invested in bankers’ acceptances and no more than 30% of the Town’s investment portfolio may be invested in the bankers’ acceptances of any one commercial bank.
6. Commercial paper of “prime” quality of the highest ranking or of the highest letter and number rating as provided for by a NRSRO. The entity that issues the commercial paper shall meet all of the following conditions in either paragraph (1) or (2):
(1) The entity meets the following criteria:
(A) Is organized and operating in the United States as a general corporation. (B) Has total assets in excess of five hundred million dollars ($500,000,000). (C) Has debt other than commercial paper, if any, that is rated in a rating category of “A” or its equivalent or higher by a NRSRO.
(2) The entity meets the following criteria:
(A) Is organized within the United States as a special purpose corporation, trust, or limited liability company.
(B) Has program-wide credit enhancements including, but not limited to, overcollateralization, letters of credit, or a surety bond.
(C) Has commercial paper that is rated “A-1” or higher, or the equivalent, by an NRSRO. Eligible commercial paper shall have a maximum maturity of 270 days or less. Local agencies, other than counties or a city and county, may invest no more than 25% of their moneys in eligible commercial paper.
Eligible commercial paper associated with less than $100,000,000 of investments shall have a maximum maturity of 270 days or less. Local agencies, other than counties or a city and
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county, may invest no more than 25% of their moneys and no more than 5% per issuer in eligible commercial paper. Eligible commercial paper associated with more than or equal to $100,000,000 of investments and Pooled Funds shall have a maximum maturity of 270 days or less. Local Agencies other than counties or a city and county, may invest no more than 40% of their moneys and no more than 5% per issuer in eligible commercial paper.
7. FDIC insured or fully collateralized time certificates of deposit in financial institutions located in California, including U.S. branches of foreign banks licensed to do business in California. All time deposits must be collateralized in accordance with California Government Code section 53651. Purchase of FDIC insured or fully collateralized time certificates of deposit may not exceed 50% of the Town’s investment portfolio.
8. Negotiable Certificates of Deposit (CD) issued by a nationally or state-chartered bank, a savings association or a federal association (as defined by Section 5102 of the Financial Code), a state or federal credit union, or by a federally- or statelicensed branch of a foreign bank. No more than 30% of the Town’s portfolio may be invested in negotiable CDs and eligible CDs must be rated in one of the three highest categories by a NRSRO.
9. Local Agency Investment Fund (LAIF). Investments in LAIF shall not exceed $75 million.
10. Insured savings account or bank money market account. In accordance with California Government Code Section 53635.2 to be eligible to receive local agency deposits a financial institution must have received a minimum overall “satisfactory” rating for meeting the credit needs of California communities in its most recent evaluation.
11. Shares of beneficial interest issued by diversified management companies that are money market funds registered with the Securities and Exchange Commission under the Investment Company Act of 1940 (15 U.S.C. Sec. 80a1, et seq.). To be eligible for investment pursuant to this subdivision these companies shall either: (1) attain the highest ranking letter or numerical rating provided by not less than two of the three largest nationally recognized rating services or (2) have an investment advisor registered or exempt from registration with the Securities and Exchange Commission with not less than five years’ experience managing money market mutual funds and with assets under management in excess of $500,000,000. The purchase price of shares shall not exceed 20% of the investment portfolio and 10% per money market fund.
12. California Asset Management Program. (CAMP), as long as the portfolio is rated among the top two rating categories by a NRSRO. There is no limit on the percentage of CAMP that may be held in the Town’s portfolio.
13. Medium-term notes, defined as all corporate and depository institution debt securities with a maximum remaining maturity of five years or less, issued by corporations organized and operating within the United States or by depository institutions licensed by the United States or any state and operating within the United States. Notes eligible for investment under this subdivision shall be rated in a rating category of “A” or its equivalent or better by a NRSRO. Purchases of medium-term notes shall not include other instruments authorized by this section and may not exceed 30% of the agency’s money and 5% per issuer that may be invested pursuant to this section.
14. United States dollar denominated senior unsecured unsubordinated obligations issued or unconditionally guaranteed by the International Bank for Reconstruction and Development, International Finance Corporation, or Inter American Development Bank, with a maximum remaining maturity of five years or less, and eligible for purchase and sale within the United States. Investments under this subdivision shall be rated in a rating category of “AA” or its equivalent or better by a NRSRO and shall not exceed 30% of the agency’s moneys that may be invested pursuant to this section. (Supranationals).
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15. Mortgage Pass-Through and Asset-Backed Securities including equipment lease-backed certificates, consumer receivable passthrough certificates, or consumer receivable-backed bonds of a maximum remaining maturity of five year. Securities eligible for investment under this subdivision shall be rated in a rating category of “AA,” its equivalent or better by at least one NRSRO. Purchase of securities authorized by this subdivision may not exceed 20 percent of the Town’s total portfolio.
Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 189 Town Policies
Summary Table of Permitted Investments
Investment Instruments
Calif. Code Limitation (Maturity, % of
Portfolio, Rating)
Town Policy Limitation (Maturity, % of
Portfolio, Rating)
U.S. Treasury 5 years
100% of portfolio
5 years
100% of portfolio
Federal Agency
(including mortgagebacked securities and
callable securities)
5 years
100% of portfolio
5 years
100% of portfolio
Municipal Obligations
(including notes issued by the State of
California, California local agencies, and the
other 49 states)
5 years
100% of portfolio
5 years
30% of portfolio Credit rating category of
“A” or its equivalent or higher by a NRSRO
Bankers’ Acceptances 180 days 40% of portfolio 40% per issuer 180 days 40% of portfolio 30% per issuer Commercial Paper (under $100,000,000 of
investments)
270 days
25% of portfolio
10% per issuer
Long term credit rating category of “A” and
short term rating of “A-1” or its equivalent
or higher by a NRSRO
270 days
25% of portfolio
5% per issuer
Long term credit rating category of “A” and
short term rating of “A-1” or its equivalent
or higher by a NRSRO
Commercial Paper (min. $100,000,000 of
investments) and Pooled Funds
270 days
40% of portfolio
10% per issuer
Long term credit rating category of “A” and
short term rating of “A-1” or its equivalent
or higher by a NRSRO
270 days
40% of portfolio
5% per issuer
Long term credit rating category of “A” and
short term rating of “A-1” or its equivalent
or higher by a NRSRO
Deposits
(Collateralized/FDIC) 100%1
of portfolio 5 years
50% of portfolio
Negotiable CDs 5 years
30% of portfolio
5 years
30% of portfolio
5% per issuer
Credit rating category of “A” or its
equivalent or higher by a NRSRO
LAIF $75 million $75 million
Money Market Funds 20% of portfolio
10% per fund
20% of portfolio
10% per fund
JPA
(CAMP) 100% of portfolio 100% of portfolio
Medium-Term Notes
5 years
30% of portfolio
10% per issuer
Credit rating category of “A” or its
equivalent or higher by a NRSRO
5 years
30% of portfolio
5% per issuer
Credit rating category of “A” or its
equivalent or higher by a NRSRO
Supranationals
5 years
30% of portfolio
Credit rating category of “AA” or its
equivalent or higher by a NRSRO
5 years
30% of portfolio
Credit rating category of “AA” or its
equivalent or higher by a NRSRO
Mortgage Pass-through and Asset-Backed
Securities
5 years or less
20% of portfolio
Credit rating category of “AA” or its
equivalent or higher by a NRSRO
5 years or less
20% of portfolio
Credit rating category of “AA” or its
equivalent or higher by a NRSRO
1For deposit placement services.
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7.0 Authorized Financial Dealers and Institutions
To provide for the optimum yield in the Town’s portfolio, the Town’s procedures shall be designed to encourage competitive bidding on transactions from an approved list of broker/dealers. The Town may engage the services of an external investment advisor to assist in the management of the Town’s investment portfolio in a manner consistent with this investment policy. If the Town hires an investment adviser to provide investment management services, the adviser is authorized to transact with its direct dealer relationships on behalf of the Town. Approved investment adviser firms must provide their services to the Town on a fiduciary capacity and be registered with the Securities and Exchange Commission (SEC) under the Investment Advisor’s Act of 1940. The advisor shall have more than five years’ experience in managing public funds and shall have at minimum $1 billion under management. The City Manager, or the Town’s investment advisor, shall maintain a list of authorized broker/dealers and financial institutions that are approved for investment purposes. This list will be developed after a comprehensive credit and capitalization analysis indicates the firm is adequately financed to conduct business with public entities. It shall be the policy of the Town to purchase securities only from those authorized institutions or firms.
8.0 Safekeeping and Custody
To protect against potential fraud and embezzlement, or losses caused by a collapse of an individual securities dealer all security transactions entered into by the Town of Los Altos Hills shall be conducted on a deliveryversus-payment (DVP) basis. Securities will be held by a third-party custodian, in the Town of Los Altos Hills’ name and control, designated by the City Manager or her/his designee and evidenced by safekeeping receipts.
9.0 Collateralization
Collateralization will be required on certificates of deposit as specified under Government Code Section 63630 et seq in order to anticipate market changes and provide a level of security for all funds. All time deposits must be collateralized in accordance with California Government Code section 53651.
The Town of Los Altos Hills chooses to limit collateral to the following:
Collateral will always be held by an independent third party. A clearly marked evidence of ownership (safekeeping receipt) must be supplied to the Town of Los Altos Hills and retained.
The right of collateral substitution is granted.
10.0 Internal Control
The Town of Los Altos Hills is responsible for establishing and maintaining an internal control structure designed to ensure that the assets of the Town are protected from loss, theft or misuses. The internal control structure shall be designed to provide reasonable assurance that these objectives are met. The concept of reasonable assurance recognizes that (1) the cost of a control should not exceed the benefits likely to be derived and (2) the valuation of costs and benefits requires estimates and judgments by the City Manager and staff.
The City Manager or designee shall arrange for an annual audit by an external CPA firm in compliance with the requirements of state law and generally accepted accounting principles as pronounced by the Government Accounting Standards Board (GASB). As a part of the audit, investment transactions will be tested. The annual audit will be an integral part, but not the sole part of management’s program of monitoring internal controls.
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The internal controls shall address the following points:
• Control of collusion
• Separation of transaction authority from accounting and recordkeeping • Custodial safekeeping
• Avoidance of physical delivery securities
• Clear delegation of authority to subordinate staff members • Written confirmation of transactions for investments and wire transfers • Development of a wire transfer agreement with the lead bank and third-party custodian
11.0 Ethics and Conflicts of Interest
Officers and employees involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. These officers and employees involved in the investment process shall disclose to the City Manager any material financial interest in financial institutions that conduct business with this jurisdiction, and they shall further disclose any large personal financial/investment positions that could be related to the performance of the Town of Los Altos Hills, particularly with regard to the time of purchases and sales. Employees and investment officials shall refrain from undertaking personal investment transactions with the same individual with whom business is conducted on behalf of the Town of Los Altos Hills.
12.0 Diversification
The Town of Los Altos Hills will diversify its investments by security type and institution. Limits are provided for in Section 6.0. With the exception of U.S. Treasury and Federal Agency securities, municipal bonds, supranational bonds, and authorized pools such as CAMP or LAIF, no more than 5% of the Town of Los Altos Hills’ total investment portfolio will be invested in a single issuer.
13.0 Maximum Maturities
To the extent possible, the Town of Los Altos Hills will attempt to match its investments with anticipated cash flow requirements. The Town of Los Altos Hills will not directly invest in securities maturing more than five (5) years from the settlement date unless City Council has provided approval for a specific purpose at least three (3) months before the investment is made. The calculation of an investment’s remaining maturity/term is to be measured from the settlement date to final maturity.
Debt reserve funds may be invested in securities exceeding five (5) years if the maturities of such investments are made to coincide as nearly as practicable with the expected use of the funds.
The Town of Los Altos Hills will retain operating reserves as adopted by the City Council. The amount of active deposits and inactive investments with a maturity of one year or less shall always be equal to greater than any draw on these reserves required by the annual operating budget.
Securities may be sold prior to maturity to accommodate the Town’s cash flow requirements, to reposition the portfolio to perform well in the current market, or to take advantage of market opportunities to increase the Town’s rate of return.
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14.0 Performance Standards
The investment portfolio shall be designed with the objective of obtaining a market rate of return throughout budgetary and economic cycles, commensurate with the Town’s investment risk constraints and cash flow needs.
14.1 Market Yield (Benchmark):
Suitability should be the standard for evaluating the success of the Town’s investment portfolio. Given this strategy and the active investment management utilized by the Town, the basis used to determine whether market yields are adequate shall be the ICE BofAML 1-5 year U.S. Treasury Index. 15.0 Reporting The City Manager is charged with the responsibility of including a market report on investment activity and returns in the Town of Los Altos Hills’ Cash and Investment Report. The Report will be in compliance with California Government Code Section 53646. 16.0 Investment Policy Adoption The Town of Los Altos Hills’ investment policy shall be adopted by the City Council. The policy shall be reviewed annually by the Finance and Investment Committee and any modifications made thereto must be approved by the City Council.
15.0 Reporting
The City Manager is charged with the responsibility of including a market report on investment activity and returns in the Town of Los Altos Hills’ Cash and Investment Report. The Report will be in compliance with California Government Code Section 53607 and will include:
• The monthly report shall include an accounting of all receipts, disbursements, and fund balances. • The quarterly reports shall include the book and market value of the cash investment, the classification of the investment, the name of the institution or entity, the rate of interest, and the maturity dates for all securities.
• The quarterly report will include a statement of compliance of the portfolio with the investment policy or an explanation as to why the portfolio is not in compliance per Government Code 53646(b) (2).
• The quarterly report will include a statement on availability of funds to meet its obligations within the next six months per Government Code 53646(b)(3).
As a good reporting practice, the Report will be submitted on a quarterly basis and provided to the Council within 45 days following the end of the month.
16.0 Investment Policy Adoption
The Town of Los Altos Hill’s’ investment policy shall be adopted by the City Council. The policy shall be reviewed annually by the Finance and Investment Committee and any modifications made thereto must be approved by the City Council.
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Glossary of Terms - Financial Policy
Bankers’ Acceptances
Short-term credit arrangements that enable businesses to obtain funds to finance commercial transactions. They are time drafts drawn on a bank by an exporter or importer to obtain funds to pay for specific merchandise. By its acceptance, the bank becomes primarily liable for the payment of the draft at maturity. An acceptance is a highgrade negotiable instrument.
Benchmark
A comparative base for measuring the performance or risk tolerance of the investment portfolio. A benchmark should represent a close correlation to the level of risk the average duration of the portfolio’s investments.
Broker
Someone who brings buyers and sellers together and is compensated for her/his service.
California Asset Management Program (CAMP)
CAMP is a joint powers authority which provides investment services to local governments through its investment pool. The pool is AAAm-rated by Standard and Poor’s, and provides same-day availability to funds up to 11:00AM Pacific. The pool strives to maintain stable asset value.
Certificates of Deposit
1. Negotiable Certificates of Deposit are large-denomination CDs. They are issued at face value and typically pay interest at maturity, if maturing in less than 12 months. CDs that mature beyond this range pay interest semi-annually. Negotiable CDs are issued by U.S. banks (domestic CDs), U.S. branches of foreign banks (Yankee CDs), and thrifts. There is an active secondary market for negotiable domestic and Yankee CDs. However, the negotiable thrift CD secondary market is limited. Yields on CDs exceed those on U.S. treasuries and agencies of similar maturities. This higher yield compensates the investor for accepting the risk of reduced liquidity and the risk that the issuing bank might fail. State law does not require the collateralization of negotiable CDs.
2. Non-negotiable Certificates of Deposit are time deposits with financial institutions that earn interest at a specified rate for a specified term. Liquidation of the CD prior to maturity incurs a penalty. There is no secondary market for these instruments; therefore, they are not liquid. They are classified as public deposits, and financial institutions are required to collateralize them. Collateral may be waived for the portion of the deposits that are covered by FDIC insurance.
Collateral
Securities, evidence of deposit or other property, which a borrower pledges to secure repayment of a loan. Also refers to securities pledged by a bank to secure deposits of public monies.
Collateralization
Process by which a borrower pledges securities, property or other deposits for the purpose of securing the repayment of a loan and/or security. Also refers to securities pledged by a bank to secure deposits of public moneys.
Dealer
Someone who acts as a principal in all transactions, including buying and selling from her/his own account.
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Delivery v. payment
The preferred method of delivering securities, with an exchange of money for the securities.
Demand deposits
A deposit of monies which are payable by the bank upon demand of the depositor.
Derivative
Securities that are based on, or derived from, some underlying asset, reference date, or index.
Diversification
Dividing investment funds among a variety of securities offering independent returns.
Federal Depository Insurance Corporation (FDIC)
A federal agency that insures bank deposits, currently up to $250,000 per deposit.
Federal Home Loan Bank (FHLB)
A federal agency that provides credit and liquidity in the housing market. FHLB issues discount notes and semiannual pay coupon securities.
Federal Home Loan Mortgage Corporation (FHLMC)
A federal agency that provides credit and liquidity in the housing market. FHLMC, also called “Freddie Mac,” issues discount notes, semi-annual pay coupon securities and mortgage-backed securities.
Federal National Mortgage Association (FNMA)
A federal agency that provides credit and liquidity in the housing market. FHLMC, also called “Fannie Mae,” issues discount notes, semi-annual pay coupon securities and mortgage-backed securities Liquidity
An asset that can easily and rapidly be converted into cash without significant loss of value.
Local Agency Investment Fund (LAIF)
The LAIF was established by the State of California to enable treasurers to place funds in a pool for investments.
There is a limitation of $50 million per agency subject to a maximum of fifteen total transactions per month. The Town uses this fund when market interest rates are declining as well as for short-term investments and liquidity.
Town funds in LAIF are limited to $40 million.
Maturity
The date upon which the principal or stated value of an investment becomes due and payable.
Mortgage-Backed Security
Debt obligations that represent claims to the cash flows from pools of mortgage loans, most commonly on residential property.
Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 195 Town Policies
Portfolio
Combined holding of more than one stock, bond, commodity, cash equivalent or other asset. The purpose of a portfolio is to reduce risk through diversification.
Repurchase Agreement
A form of collateralized loan involving the sale of a security with a simultaneous agreement by the seller to buy the same security back from the purchaser at an agreed-on price and future date. The party who sells the security at the inception of the repurchase agreement and buys it back at maturity is borrowing money from the other party, and the security sold and subsequently repurchased represents the collateral.
Safekeeping
Offers storage and protection of assets provided by an institution serving as an agent.
Supranational Bonds
A bond issued by a supranational agency such as the World Bank.
U.S. Treasury Bills
Commonly referred to as T-Bills, these are short-term marketable securities sold as obligations of the U.S.
Government. They are offered in three-month, six-month and one year maturities. T-Bills do not accrue interest but are sold at a discount to pay face value at maturity.
U.S. Treasury Notes
These are marketable, medium-term interest-bearing securities sold as obligations of the U.S. Government with original maturities of one to ten years. Interest is paid semiannually.
U.S. Government Agency
Issues Issues which are unconditionally backed by the full faith and credit of the United States.
Yield
The rate of annual income return on an investment, expressed as a percentage. Income yield is obtained by dividing the current dollar income by the current market price for the security. Net yield or yield to maturity is the current income yield minus any premium above par or plus any discount from par in purchase price, with the adjustment spread over the period from the date of purchase to the date of maturity of the bond.
196 Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan Town Policies
Reserve Policy
Proposed for City Council Adoption on June 26, 2025
Resolution XX-XX
Purpose
This policy establishes reserve targets for the Town’s governmental funds to ensure financial stability, operational continuity, and long-term planning. Reserves provide:
> Working capital for operations and maintenance
> Funding for equipment, technology, and capital needs
> Resources to meet legal, regulatory, and contractual obligations > A buffer against revenue shortfalls and unforeseen emergencies Maintaining adequate reserves enhances transparency, supports credit ratings, and helps manage risk through economic or operational disruptions.
Policy
This policy ensures that the Town maintains sufficient cash flow to meet current and future obligations while providing transparency to the public. By establishing targeted reserve levels for each of the Town’s governmental funds, the policy supports financial stability, risk mitigation, and long-term planning.
Reserves are essential to address both planned and unplanned needs:
> Planned needs may include:
• Funding operating requirements
• Meeting debt service obligations (if any)
• Addressing pension and other post-employment benefit (OPEB) liabilities > Unplanned needs may include:
• Offsetting revenue shortfalls
• Covering unanticipated expenses
• Responding to emergencies or disasters
Establishing formal reserve targets helps the Town:
> Maintain adequate working capital
> Prepare for financial contingencies and emergencies
> Support strong credit ratings and reduce borrowing costs This policy defines specific reserve accounts by outlining their purpose, target thresholds, allowable uses, and replenishment procedures. It distinguishes between committed reserves, which are formally designated by City Council for specific purposes, and assigned reserves, which offer greater flexibility and may be used for a range of Town-identified needs. Both committed and assigned reserves may be established, modified, applied, or eliminated by City Council resolution. Committed reserves are restricted to the purposes explicitly stated at the time of designation. In contrast, assigned reserves may support multiple related activities, provided they align with the stated intent of the reserve.
Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 197 Town Policies
Policy Review and Monitoring
This policy will be reviewed annually during the budget process to ensure alignment with the Town’s financial goals and compliance with applicable regulations. As part of the annual review, the Administrative Services Director/ Finance Director will:
> Recalculate reserve thresholds based on the most recent financial data > Evaluate reserve usage and replenishment
> Recommend any policy or funding adjustments for inclusion in the budget In addition to the annual review, reserve balances will be monitored mid-year and presented to the City Council as part of the mid-year financial update to promote transparency and timely decision-making.
Committed Reserves
1. Pension Contribution Reserve
Purpose of the Reserve:
The Pension Contribution Reserve is to set aside funds for the Town’s estimated unfunded liability. CalPERS prepares an annual Actuarial Report for each of the Town’s three pension plans. This reserve is for amounts not included in the Accrued Liability and represents the difference between the currently applied Discount Rate and the lowest Discount Rate measured by CalPERS in its most recent actuarial report. This difference is updated to the most recent past fiscal year end as reported in the related ACFR Pension Footnote.
Threshold of the Reserve:
The Pension Contribution Reserve shall maintain a maximum threshold based on the CalPERS annual actuarial report for each of the Town’s three pension plans. The reserve threshold amount is calculated by the following:
the difference between the accrued liability at the current discount rate and the accrued liability calculated using the discount rate that is one percentage point lower than the current rate, as shown in the most recent ACFR pension footnote.
The balance of the Town’s Section 115 Pension Trust shall be included in the calculation of the Pension Contribution Reserve. The sum of the Pension Contribution Reserve and the Pension Trust balance shall be used to evaluate compliance with the policy threshold.
Usage of the Reserve:
Adjustments to the reserve will result from the discount rate changes in succeeding years per the CalPERS annual report per the Analysis of Discount Rate Sensitivity as updated in the most recent ACFR Pension footnote.
Replenishment of the Reserve:
During the annual budget cycle, the Pension Contribution Reserve will be adjusted to reflect the new threshold amount as described in the preceding Threshold of the Reserve section. These adjustments will be approved by the City Council as part of the annual budget cycle.
2. Technology Reserve
198 Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan Town Policies
Purpose of the Reserve:
The Technology Reserve is to set aside funds for the Town’s future Audio and Visual equipment and software replacement needs.
Threshold of the Reserve:
The threshold will be calculated based on $460K, the budgeted amount of the AV system, and will be $46K for the following 10 years for upgrades and replacement of the equipment.
Usage of the Reserve:
Eligible expenditures will be for AV System and software to be upgraded or replaced throughout the fiscal year. These expenditures will be determined on an annual basis.
Replenishment of the Reserve:
The Technology Reserve will be adjusted up or down, as necessary, to equal the threshold. These expenditures will be determined on an annual basis.
3. Vehicle and Equipment Replacement Reserves
Purpose of the Reserve:
The Vehicle and Equipment Replacement Reserve is to set aside funds for the Town’s current and future vehicle and equipment replacement needs. The Town maintains a vehicle and equipment replacement schedule for all Town vehicles and equipment. This schedule is updated as equipment is added or removed from service.
Threshold of the Reserve:
The threshold of the Vehicle and Equipment Replacement Reserve will be calculated each year during the annual budget cycle. This threshold will be the sum of the amount determined for each piece of equipment on the Vehicle and Equipment replacement schedule based on future replacement costs of the item divided by its useful life and multiplied by the number of years in service, but in no event greater than the future replacement cost.
Usage of the Reserve:
Eligible expenditures include vehicles and/or equipment replacements purchased throughout the fiscal year.
These expenditures will be determined on an annual basis.
Replenishment of the Reserve:
During the annual budget cycle, the Vehicle and Equipment Replacement Reserve will be adjusted up or down, as necessary, to equal the threshold. Any adjustments will be approved by the City Council as part of the annual budget cycle.
4. Facilities Replacement Reserves
Purpose of the Reserve:
The Facilities Replacement Reserve is to set aside funds for the Town’s current and future facility improvement and replacement needs. The Town maintains a facility schedule for all Town facilities. Additions to the facilities schedule occur when Town facilities are either improved or new Town facilities are added. Deletions occur as Town facilities are demolished and removed from service.
Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 199 Town Policies
Threshold of the Reserve:
The threshold of the Facilities Replacement Reserve will be calculated each year during the annual budget cycle.
This threshold will be comprised of two parts. For existing buildings, it will be the cumulative depreciation of the buildings listed in the fixed asset schedule as reported in the most recent ACFR Capital Asset Footnote.
Added to this amount is any remaining unspent funds appropriated to construct additions or improvements to facilities.
Usage of the Reserve:
Eligible expenditures include facilities improvements, renovations, or demolitions that occur throughout the fiscal year. These expenditures will be determined on an annual basis.
Replenishment of the Reserve:
During the annual budget cycle, the Facilities Replacement Reserve will be adjusted up or down, as necessary, to equal the threshold. Any adjustments will be approved by the City Council as part of the annual budget cycle.
5. Disaster Contingency Reserve:
The Disaster Contingency Reserve is to set aside funds for emergencies that may arise within the Town that have not been federally and or state declared disasters. To constitute a Town emergency, the disaster or emergency would be natural disasters (i.e. earthquakes, landslides, flooding) or temporary service outages of Town facilities and infrastructure (i.e. extensive debris cleanup from wind events that prohibits travel on Town roads). To be declared a Town Emergency, the Emergency Operations Center and team would be activated for any length of time. Town emergencies are smaller in nature than presidentially declared federal disasters and governor declared state disasters and are typically contained within the Town boundaries.
Threshold of the Reserve:
The Disaster Contingency Reserve shall maintain a balance not less than $1,250,000. This amount shall be adjusted up or down, as necessary, each year. Adjustments will be based on the risk assessment performed by the Town’s emergency services personnel.
Usage of the Reserve:
The City Manager is the Director of Emergency Services. In the event of a Town emergency, the City Manager would determine eligible expenditures allowable for use of the reserve on a case-by-case basis. If expenditures are incurred, use of the reserve will be considered on an annual basis.
Replenishment of the Reserve:
During the annual budget cycle, the Disaster Contingency Reserve will be adjusted as necessary to equal the threshold. Any adjustments will be approved by the City Council as part of the annual budget cycle.
6. Capital Projects Reserve
Purpose of the Reserve:
The Capital Projects Reserve is to set aside funds to start or complete projects for which the Council has previously appropriated funds, but the projects have not been started or completed.
200 Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan Town Policies
Threshold of the Reserve:
The Capital Projects Reserve shall maintain a balance equal to the unused prior appropriated funds as shown in the list of capital projects prepared as part of the annual budget process. This amount shall be adjusted up or down, as necessary, each year.
Usage of the Reserve:
The Capital Projects Reserve will be used to fund the completion of the prior appropriated projects as shown in the list of capital projects in the budget.
Replenishment of the Reserve:
During the annual budget cycle, the Capital Projects Reserve will be adjusted as necessary to equal the threshold. Any adjustments will be approved by the City Council as part of the annual budget cycle.
Assigned Reserves
1. General Fund Stabilization Reserve
Purpose of the Reserve:
The General Fund Stabilization Reserve is to establish a minimum unassigned fund balance and to set aside funds for the Town’s current and future operational needs in the event of economic downtowns or unexpected expenditures.
Threshold of the Reserve:
The General Fund Stabilization Reserve shall maintain a maximum threshold that is equivalent to three months of average operating expenditures in the general fund. Operating expenditures are defined as those expenditures before transfers to other funds and exclude capital expenditures (less that portion of Community Development costs that are recovered through charges for services). The figures from the most recent ACFR shall be used for calculating the threshold amount.
Usage of the Reserve:
Allowable expenditures for use in this reserve shall be determined on a case-by-case basis. Examples of allowable expenditures include, but are not limited to, significant economic downturn that result in diminished property taxes revenues, thus resulting in a need for use of the reserve to balance the annual general fund budget. These expenditures will be recommended by the City Manager and approved by the City Council.
If expenditures are recommended and approved, use of this reserve will be considered on an annual basis.
Replenishment of the Reserve:
During the annual budget cycle, the General Fund Stabilization Reserve will be reviewed and updated based on the most recent audited and issued Annual Comprehensive Financial Report. Any adjustments will be approved by the City Council as part of the annual budget cycle.
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Appendix
Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 203 Appendix
Glossary of Terms in Budget
Accounting System: The methods and records
established to identify, assemble, analyze, classify,
record and report a government’s transactions and
to maintain accountability for the related assets and
liabilities.
ACFR: abbreviation. Annual Comprehensive Financial
Report. This is the Town’s financial statement,
which includes auditor’s opinion and other financial
information pertinent in evaluating the Town’s financial health.
Adopted Budget: The official budget as approved by
the City Council at the start of each fiscal year.
Agency Fund: A fund normally used to account for
assets held by a government as an agent for individuals, private organizations or other governments and/or
other funds.
Amended Budget: The official budget as adopted and
as amended by the City Council through the course of
a fiscal year.
Annual Budget: A budget applicable to a single fiscal
year.
Annual Financial Report: A financial report applicable
to a single fiscal year.
Appropriated Budget: The expenditure authority
created by the appropriation bills or ordinances, which are signed into law, and the related estimated revenues.
The appropriated budget would include all reserves,
transfers, allocations, supplemental appropriations
and other legally authorized legislative and executive
changes.
Appropriation: A legal authorization granted by a
legislative body for a given period to make expenditures and to incur obligations for specific purposes. An
appropriation usually is limited in amount and time it
may be expended.
ASD: abbreviation. Administrative Services Department
Assessed Valuation: The estimated value placed upon
real and personal property by the County Assessor as
the basis for levying property taxes.
Audit: Prepared by an independent Certified Public
Accountant , the primary objective of an audit is to
determine if the City’s financial statements present
fairly the City’s financial position and results of
operations in conformity with generally accepted
accounting principles.
Authority: A government or public agency created to
perform a single function or restricted group of related activities.
Balanced Budget: A balanced budget exists when total
revenues are equal to, or greater than, total expenses.
Bond Covenant: A legally enforceable promise made
by an issuer of bonds to the bondholders, normally
contained in the bond resolution or indenture.
Budget: A plan of financial operation embodying an
estimate of the proposed expenditures for a given
period and the proposed means of financing them.
Capital Budget: A plan or proposed capital outlays and
the means of financing them.
Capital Improvement Program: A plan for capital
improvements to be implemented each year over a
fixed period of years to meet capital needs arising from the assessment of long‐term needs. It sets forth each
project in which the government is to have a part and
specifies the full resources estimated to be available
to finance the projected expenditures.
Capitalized Expenditures: Expenditures resulting in the acquisition and/or construction of fixed assets.
Contracted Services: Services rendered in support of
City operations and activities by external parties. These may be based upon either formal contracts or ad hoc
charges.
Contingency: A budgetary reserve set‐aside for
emergencies or unforeseen expenditures not otherwise
budgeted.
Cost Accounting: The method of accounting that
provides for assembling and recording of all the
elements of cost incurred to accomplish a purpose, to
204 Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan Appendix
carry on an activity or operation, or to complete a unit of work or a specific job.
Cost Allocation Plan: A comprehensive analysis of
the appropriate distribution of overhead costs from
the Town’s General Government Departments to
the various service departments – Public Works,
Community Development and Parks & Recreation.
Cost of Services: Payments made by customers
for publicly provided services that benefit specific
individuals and exhibit “public good” characteristics.
They include such fees as recreational fees, building
permit fees, etc.
Debt Service Fund: A fund established for the payment
of interest and principal on all debt other than payable exclusively from special assessments.
Department: A major organizational group of the City
with overall management responsibility for an operation or a group of related operations within a functional area.
Depreciation: (1) Expiration in the service life of capital assets attributable to wear and tear, deterioration,
action of the physical elements, inadequacy or
obsolescence. (2) That portion of the cost of a capital asset which is charged as an expense during a particular period.
Division: An organizational subgroup of a department.
Employee Services: Salaries plus fringe benefits earned by employees of the organization for work performed.
Encumbrance: The commitment of appropriated funds
to purchase goods that have not yet been received, or
services that have yet to be rendered.
Enterprise Fund: A fund established to account for
operations financed and operated in a manner similar to private business enterprises. In this case, the governing body intends that costs of providing goods or services
to the general public on a continuing basis be financed or recovered primarily through user charges.
Entitlement: The amount of payment to which a state
or local government is entitled pursuant to an allocation formula contained in applicable statutes.
EOC: abbreviation. Emergency Operation Center. This
is only activated during an emergency situation by
authorized Town personnel.
ERAF: abbreviation. Educational Revenue
Augmentation Fund. A shift of property tax revenues
from cities, counties and other local agencies to the
State in support of schools.
Expenditure: Decreases in net financial resources.
Expenditures include current operating expenses, which
require the current or future use of net current assets, debt service, and capital outlays.
FIC: abbreviation. Finance and Investment Committee.
Fiscal Year: A 12‐month period (usually July 1st through June 30th) to which the annual operating budget applies and at the end of which a government determines its
financial position and the results of its operations.
Fixed Assets: Equipment costing $5,000 or more,
including tax, and not qualifying as a capital
improvement project.
Full‐Time Equivalent (FTE): The conversion of full‐time and part‐time employee hours to an equivalent of a
full-time position. For example: one person working
half‐time would count as 0.5 FTE.
Fund: A fiscal and accounting entity with a self‐
balancing set of accounts in which cash and other
financial resources, all related liabilities and residual equities, or balances, and changes therein, are
recorded and segregated to carry on specific activities or attain certain objectives in accordance with special regulations, restrictions, or limitations.
Fund Balance: The difference between fund assets and
fund liabilities of governmental and similar trust funds.
General Fund: The fund used to account for all financial resources, except those required to be accounted for
in another fund.
Generally Accepted Accounting Principles (GAAP):
Uniform minimum standards of/ and guidelines for
financial accounting and reporting. They govern the
form and content of the basic financial statements of
an entity. GAAP encompasses the conventions, rules
and procedures necessary to define accepted
Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan 205 Appendix
accounting practices at a particular time. They include not only broad guidelines of general application, but
also detailed practices and procedures. GAAP provides a standard by which to measure financial presentations.
Governmental Funds: Funds general used to account
for tax‐supported activities. There are five different
types of governmental funds: the general fund, special
revenue funds, debt service funds, capital projects
funds, and permanent funds.
Grants: Contributions of cash or other assets from
another governmental agency (usually) to be expended
or used for a specified purpose, activity or facility.
Infrastructure: All City owned facilities supporting
the operation of the governmental unit. It includes:
streets, roads, bridges, curbs and gutters, parks, water and sewer lines, storm drains, water pump stations
and reservoirs, water wells, sewer lift stations, all
government buildings and related facilities.
Internal Service Fund: A fund used to account
for the financing of goods or services provided by
one department to other departments on a costreimbursement basis.
Investment: Securities and real estate purchased and
held for the production of income in the form of interest, dividends, rentals or base payments.
Long Term Debt: Debt with a maturity of more than
one year after the date of the issues.
Materials & Services: Expenses which are charged
directly as a part of the cost of a service.
Modified Accrual Basis: The accrual basis of accounting where revenues are recognized when they become both
“measurable” and “available” to finance expenditures of the current period. All governmental funds and agency
funds are accounted for using the modified accrual basis of accounting.
Net Income (Loss): Proprietary fund excess (deficit) of operating revenues and operating transfers-in over
operating expenses, non-operating expenses and
operating transfers-out.
Non‐Operating Expenses: Proprietary fund expenses
not directly related to the fund’s primary activities (e.g. interest).
Non‐Operating Revenues: Proprietary fund revenues
incidental to, or by‐products of, the fund’s primary
activities.
Operating Expenses: Proprietary fund expenses related
directly to the fund’s primary activities.
Operating Income: The excess of proprietary fund
operating revenues over operating expenses.
Operating Revenues: Proprietary funds revenues
directly related to the fund’s primary activities. They consist primarily of user charges for goods and services.
Operating Transfers: Legally authorized transfers from
a fund receiving revenue to the fund through which
the resources are to be expended, such as transfers
from the General Fund to a Special Revenue or Capital
Projects Fund.
Ordinance: A formal legislative enactment by the City
Council. If it is not in conflict with any higher form of law, it has the full force and effect of law within the boundaries of the City.
PCI: abbreviation. Pavement Condition Index.
Preliminary Budget: A budget in its preliminary
preparation stage prior to review and formulation by
the City Council. In the preliminary stage, a budget
forecasts current costs into the future and new or
modified spending proposals for the future.
Program: Group activities, operations, or organization
units directed to attaining specific purposes or
objectives.
Program Purpose: A general statement explaining the
reason a particular program or division exists.
Proprietary Fund: The classification used to account
for a government’s ongoing organizations and activities that are similar to those often found in the private
sector (i.e., enterprise and internal service funds). All assets, liabilities, equities, revenues, expenses and
transfers relating to the government’s business and
206 Town of Los Altos Hills | FY 2026-2027 & 2027-2028 Operating Budget and FY 2027-2031 Five Year Capital Improvement Plan Appendix
quasi-business activities are accounted for through
proprietary funds.
Reserved Fund Balance: Those portions of fund balance
that have not been appropriated for expenditure or that are legally segregated for a specific future use.
Resolution: A special or temporary order of the City
Council requiring less formality than an ordinance.
Retained Earnings: An equity account reflecting the
accumulated earning of an enterprise or internal service fund.
Revenues: (1) Increases in net current assets of a
governmental fund type from other than expenditure
refunds and residual equity transfer. (2) Increases in
the net total assets of a proprietary fund type from
other than expense refunds, capital contributions and
residual equity transfers.
Risk Management: All the ways and means used to
avoid accidental loss or to reduce its consequences if
it does occur.
Self‐Insurance: A term often used to describe the
retention by an entity of a risk of loss arising out of the ownership of property or from some other cause,
instead of transferring that risk to an independent third party through the purchase of an insurance policy. It is sometimes accompanied by the setting aside of assets
to fund any related losses. Because no insurance is
involved, the term self‐insurance is a misnomer.
Service Reimbursements: Transactions that constitute
reimbursements to a department/division for
expenditures or expenses initially made from it but
that properly apply to another department/division.
Service Level Measure: A statement describing an
activity conducted or performed by the program/
division. A program will usually have many Service Level Measures. Service Level Measures provide quantifiable
and qualifiable information as to the level of service to be provided in relation to the level of fund indicated in the budget.
Special Revenue Fund: A fund used to account for the
proceeds of specific revenue sources that are legally
restricted to expenditures for specified purposes.
Specific Program Objectives: An “action” statement
indicating the new or special activities proposed for a program.
Taxes: Compulsory charges levied by a government for
the purpose of financing services performed for the
common benefit. This term does not include specific
charges made against particular persons or property
for current or permanent benefits such as special
assessments. Neither does the term include charges
for services rendered only to those paying such charges as, for example, user charges.
Transfers: Payments from one fund to another ideally
for work or services provided, or to cover operating
expense shortfalls.
Triple Flip: Backfill of the confiscated local sales tax reimbursed through a series of revenue swapping
procedures to guarantee repayment for the California
Economic Recovery Bond.
Trust Fund: Funds used to account for assets held by a
government in a trustee capacity for individuals, private organizations, other governments and/or funds.
The Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
Budget Document Changes
May 8, 2026 version:
• Revenues (Page 10)
o Updated Fee Study narrative
• Community Development (Page 12)
o Updated expenditures narrative
• City Clerk (Page 79)
o Updated budget summary narrative
May 13, 2026 version:
• Sewer Fund Narrative (Page 13)
o Sewer Operating budget decrease updated
• Town-Wide Fund Summary (Page 43)
o Capital Funds and Sewer Fund expenditures and fund balances updated • Town-Wide Financial Summary (Page 44)
o Non-departmental expenditures and fund balances updated • Sewer Fund (Page 48)
o Capital Outlay expenditures and fund balances updated • Department Spending (Page 49)
o Updated
• Department Overview (Page 54-58)
o Updated
• City Council (Page 67)
o Updated table and budget summary narrative
June 1, 2026 version:
• Staffing Tables
o Updated to 2 decimal places
• General Fund Revenues Chart (Page 10)
o Updated scale
• City Manager’s Message (Page 15-16)
o Updated narrative
• Demographics (Page 31-32)
o Updated demographic figures
• General Fund Revenues and Expenditures (Page 46)
o Updated transfers
ITEM 7C, Attachment 4
• Department Overview (Page 54)
o Updated
• City Attorney (Page 72)
o Updated City Attorney contract escalator in FY 2027-28 • Town Center (Page 91)
o Updated narrative
• Westwind Community Barn (Page 119)
o Updated Charges for Services revenue based on latest estimates • Westwind Barn Community Improvements (Page 166)
o Updated budget from $50,000 to $75,000 in out-years
June 12, 2026
• Allocations Out
o Updated Allocations In and Allocations Out to align Allocations In to the current budgets.
• Fee Revenues
o Updated fee revenues based on Finance and Investment Committee recommendations. The proposed budget now assumes a 90% cost recovery target for most development services fees and an 80% cost recovery target for ADU permits, water heater permits, HVAC permits, and heat pump permits.
ITEM 7D
THE TOWN OF LOS ALTOS HILLS June 18, 2026
Staff Report to the City Council
SUBJECT: CONSIDERATION OF A RESOLUTION SUBMITTING A MEASURE TO THE VOTERS OF LOS ALTOS HILLS FOR THE NOVEMBER 3, 2026, GENERAL
MUNICIPAL ELECTION REGARDING SPECIFIC MODIFICATIONS TO THE LAND USE ELEMENT PAGE LU-4 TO AMEND POLICY 1.2 RELATED TO
THE KEEPING OF HORSES AND DOMESTICATED ANIMALS ON
RESIDENTIAL PROPERTY AND ADD POLICY 1.4 PROHIBIITNG NEW
INDUSTRIAL, LARGE SCALE COMMERCIAL AND RETAIL USES ON
PRIVATE PROPERTY WITHIN THE TOWN CONSISTENT WITH THE
“GREEN SHEETS” LAND USE PRINCIPLES AND SPECIFYING
PROCEDURES AND PROCESSES RELATED TO THE BALLOT
ARGUMENTS
FROM: Steve Mattas, City Attorney
APPROVED: Cody Einfalt, City Manager
RECOMMENDATION:
That the City Council consider the comments from Town Committees, the Planning Commission and the public and consider adoption of a resolution submitting a measure to the voters of Los Altos Hills for the November 3, 2026, General Municipal Election to amend various elements of the General Plan to incorporate certain land use principles commonly referred to as the “Green Sheets of the Town of Los Altos Hills” through the amendment of Policies 1.2 and 1.4 of the Land Use Element on page LU-4 to authorize the keeping of animals on residential properties and to prohibit new industrial, large-scale commercial and retail uses on private property within the Town and further directing staff to work with a council sponsored ad hoc committee to prepare and sign a ballot argument in favor of the initiative measure and, if necessary, a rebuttal argument if an argument is filed against the initiative measure, and to direct the City Attorney to prepare an impartial analysis and to consolidate this initiative measure into the consolidated election to be held on November 3, 2026.
BACKGROUND
At its May 14, 2026, meeting, the City Council asked staff to present the proposed Green Sheets initiative to the Town’s Planning Commission and Committees and to solicit input on the initiative from these bodies. Over the last several weeks, staff presented the initiative to the Planning Commission and several Town Committees. A summary of the input solicited from the different bodies is included in this staff report. The item on tonight’s agenda is for the City Council to consider the input from the different Town bodies and to consider whether to place the initiative measure on the November 3, 2026 ballot.
DISCUSSION
As the Council is aware, the initiative covers amendments to the Land Use Element to add/amend new policies to (1) clarify the types of animals that are allowed to be kept on residential properties within the Town and (2) prohibit the introduction of new industrial, large-scale commercial, and retail uses on private property, while still allowing for existing lawfully permitted commercial uses within the Town..
A. Planning Commission
The Planning Commission discussed the initiative measure at its June 8, 2026, meeting to provide input to the Council and to comply with legal requirements for the amendment of General Plans.
Pursuant to Government Code Sections 65350 et seq., the Planning Commission shall review amendments of the General Plan, provide opportunity for involvement of the public through a public hearing, and provide a recommendation to the City Council of whether the proposed amendments would affect the internal consistency of the General Plan. The Planning Commission held a public hearing on the proposed General Plan amendments and found the initiative measure to be consistent with the Town’s General Plan.
The Planning Commission further offered comments on the substance of the initiative measure for the Council’s consideration. The Planning Commission believes that since this measure will go to the voters, it should include a more substantial change than what is currently proposed. However, the Commissioners did not come into agreement on what the substantial change would be. Some Commissioners requested the inclusion of a restriction on the vacation of pathway easements in the initiative measure, but the Commissioners understood that Council removed this portion from the measure before it was sent to the Commission and Town Committees and thus did not specifically request this specific change.
B. Town Committees
On June 4th, Town staff sent the following email to Pathways Committee, Open Space Committee, and Environmental Design and Protection Committee:
The Town Council is set to hold a public hearing on the draft ballot initiative designed to place into the Town’s General Plan Land Use Element two key elements first set forth in the Green Sheets. At the June 18, 2026, meeting the City Council will consider whether to place the initiative on the ballot for the November general election.
At the May 14th meeting, the Town Council requested input from the Town Land Use Committees and Planning Commission on the proposed initiative measure. Since the proposed initiative amends the General Plan Land Use Element, Government Code Section 65353 requires that the Planning Commission hold a public hearing and then make a recommendation to the City Council on the proposed amendments. Thus, the purpose of this request is to seek committee input and the Planning Commission’s recommendation on the proposed ballot initiative prior the Council considering action to place the measure on the ballot for residents to decide whether to approve the changes to the Land Use Element as set forth in the initiative measure.
Here is a copy of the proposed ballot initiative seeking comments:
https://losaltoshillsca.portal.civicclerk.com/event/4504/files/attachment/14022 For background, the Green Sheets, written in 1956, were the first statements of the type of community our founders wanted for Los Altos Hills and on the community pillars they saw as essential to preserve the rural character of the town. Some of the points listed in the Green Sheets are no longer applicable, but some are still pertinent.
The councilmembers who have expressed support for further consideration of this initiative measure believe there is urgency to consider this initiative measure as a way to preserve some aspects of the Green Sheets and character of the Town.
The ballot initiative would amend policy 1.2 of Goal 1 within the Land Use Element to clarify that the types of animals that are allowed within the Town include but are not limited to rabbits, birds, fowl, dogs, cats, sheep, cattle, pigs, goats, equines, llamas, alpacas, and the like. Additionally, the ballot measure would add policy 1.4 to Goal 1 within the Land Use Element which would prohibit the introduction of new industrial, large-scale commercial, and retail uses. Policy 1.4 would not apply to existing commercial development within the Town or to Town owned property. If the initiative measure is placed on the November ballot and approved by a majority of voters, the changes approved by in the initiative measure would require voter approval from the residents to changes these specific policies identified above.
The ballot initiative would make it harder for future Town Councils to make changes, as a vote of the people would be required for the change and some people consider this as a negative consequence. Some feel it is positive.
A public hearing regarding this proposed initiative measure was held by the City Council on April 16, 2026. At that meeting, the City Council provided direction to the City Attorney to modify the draft initiative measure to limit its focus to changes to the Land Use Element that would prohibit new industrial, large-scale commercial, or retail land uses and to allow for the keeping of animals on residential property including rabbits, birds, fowl, dogs, cats, sheep, cattle, pigs, goats, equines, llamas, alpacas, and the like in Town. At that time, the Council was not specific as to whether this would apply to only single-family residential lots or could potentially apply to the multi-family residential lots. The committees may desire to offer their input on this issue as they consider the draft initiative measure.
On Thursday, June 18, 2026, the Town Council will vote to determine whether to place this initiative measure on the November ballot. To insure a well-thought-out ballot imitative, the Town Council requested that the applicable land-use committees review the draft ballot initiative at one of their upcoming meetings and forward any committee recommendations to the City Manager for presentation to the City Council. Similarly, the City Council has requested that the Planning Commission, acting consistent with Government Code Section 65353, schedule and conduct a hearing and provide its recommendations regarding the proposed amendments to the Land Use Element set forth in the initiative measure. Please submit your committee’s opinions and comments to me (Cody Einfalt [email protected]) for input to the Town Council before June 8th.
Reponses from the Committees will be uploaded as supplemental documents to the Agenda packet for June 18th.
ENVIRONMENTAL REVIEW
The proposed initiative measure is exempt from CEQA pursuant to the CEQA Guidelines Section 15061.3 common sense exception in that CEQA applies only to projects which have the potential for causing a significant effect on the environment. The proposed amendments will not have any impact on the current Land Use Plan, which already has a policy related to keeping of horses and domesticated animals on residential property and this initiative measure clarifies that policy and the existing Land Use Element already does not allow industrial and large-scale commercial and retail uses within the Town.
2026-2027 CITY COUNCIL WORK PLAN:
City Council identified incorporating the Green Sheets into the Town’s General Plan as a City Council goal for 2026-2027.
FISCAL IMPACT:
There is an estimated fiscal impact of approximately $5,000 to $10,000 associated with adding the initiative measure to the November 3, 2026 Election ballot. This cost will be absorbed within the Town’s existing election budget.
ATTACHMENTS
Attachment 1 - Resolution
Attachment 2 - Draft Green Sheets Initiative Measure
ITEM 7D, Attachment 1
TOWN OF LOS ALTOS HILLS
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS
SUBMITTING A MEASURE TO THE VOTERS OF LOS ALTOS HILLS AT THE NOVEMBER 3, 2026 ELECTION REGARDING SPECIFIC MODIFICATIONS TO THE LAND USE ELEMENT PAGE LU-4 TO AMEND POLICY 1.2 RELATED TO THE
KEEPING OF HORSES AND DOMESTICATED ANIMALS ON RESIDENTIAL PROPERTY AND ADD POLICY 1.4 PROHIBIITNG NEW INDUSTRIAL, LARGE SCALE
COMMERCIAL AND RETAIL USES ON PRIVATE PROPERTY THAT ARE CONSISTENT WITH THE “GREEN SHEETS” LAND USE PRINCIPLES; REQUESTING
THAT THE SANTA CLARA COUNTY BOARD OF SUPERVISORS CONSENT TO THE
CONSOLIDATION OF THIS ELECTION WITH THE STATEWIDE GENERAL ELECTION TO BE HELD ON THE SAME DATE; DIRECTING THE CITY ATTORNEY TO PREPARE AN IMPARTIAL ANALYSIS; AND SPECIFYING PROCEDURES
RELATED TO SUBMISSION OF BALLOT ARGUMENTS
WHEREAS, the Town of Los Altos Hills (“Town”) was incorporated in 1956 based on local residents’ desire to preserve the rural atmosphere of the foothills and other related community interests;
WHEREAS, the reasons for incorporation were compiled in a set of documents commonly referred to as the “Green Sheets”, as they were originally printed on light green paper; WHEREAS, the Los Altos Hills City Council ("Council") desires that certain guiding principles set forth in the Green Sheets be incorporated into the Town’s General Plan; WHEREAS, California law permits municipalities to adopt or amend their general plans through the initiative process; and
WHEREAS, a General Municipal Election is scheduled to be held in the Town of Los Altos Hills on November 3, 2026.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the Town of Los Altos Hills as follows:
Section 1. Placing a Measure on the ballot for the Regular Municipal Election.
Pursuant to Elections Code Section 9222 the City Council hereby places on the ballot at the November 3, 2026 General Municipal Election in the Town of Los Altos Hills an ordinance, which if approved, would amend the Town’s General Plan Land Use Element by amendment Policy 1.2 on page LU-4 to clarify the types of animals that are allowed on residential properties within the Town and by adding Policy 1.4 on page LU-4 to prohibit new industrial, large-scale commercial, and retail uses on private property (“Ordinance”). This measure shall be designated by letter by the Santa Clara County Registrar of Voters. Pursuant to Election Code Section 10400 et.seq., the election for this measure shall be consolidated with the statewide general election to be held on the same date.
Los Altos Hills City Council Resolution No.
2 Section 2. Description of the Question Placed on the Ballot.
The Ordinance to be approved by the voters pursuant to Section 1 is set forth in Exhibit A hereto. The Board of Supervisors of the County of Santa Clara is requested to order the County Registrar of Voters to set forth in the voter information portion of all sample ballots to be mailed to the qualified electors of the Town the full text of the Ordinance and to mail with the sample ballots to the electors printed copies of the full text of the Ordinance, together with the primary arguments and rebuttal arguments (if any) for and against the measure, and to provide voter ballots for the election for use by qualified electors of the Town who are entitled thereto in the manner provided by law. The proposed Ordinance shall be submitted to the voters on the ballot in the form of the following question, which question shall require the approval of a majority of qualified electors casting votes:
Shall the measure to amend the Town of Los Altos Hills
General Plan Land Use Element Policy 1.4 to clarify the types of horses and domesticated animals that may be kept on residential properties to include but not be limited to rabbits, birds, fowl, dogs, cats, sheep, cattle, pigs, goats, equines, llamas, alpacas, and the like, and add Policy 1-4 to page LU-4 to prohibit new industrial, large-scale commercial, and retail uses on private property, be adopted?
YES
NO
Section 3. The City Clerk is authorized, instructed and directed to work with the Santa Clara County Registrar of Voters as needed in order to properly and lawfully conduct the election. The ballots to be used in the election shall be in form and content as required by law.
The Santa Clara County Registrar of Voters is authorized to canvass the returns of the general municipal election. In all particulars not recited in this Resolution, the election shall be held and conducted as provided by law for holding municipal elections.
Section 4. The Board of Supervisors is requested to instruct the Santa Clara County Registrar of Voters to provide such services as may be necessary for the holding of the consolidated election. The election shall be held in all respects as if there were only one election.
The Town of Los Altos Hills acknowledges that the consolidated election will be held and conducted in the manner prescribed in Elections Code Section 10418. The Town of Los Altos Hills recognizes that the County will incur additional costs because of this consolidation and agrees to reimburse the County for those costs. The City Manager is hereby authorized and directed to expend the necessary funds to pay for the City’s cost of placing the measure on the election ballot.
Section 5. The polls for the election shall be open at 7:00 a.m. on the day of the election and shall remain open continuously from that time until 8:00 p.m. that same day, when the polls shall be closed, except as provided in Section 14401 of the Elections Code of the State of California. The notice of the time and place of holding the election is hereby given, and the City Clerk is authorized to give further notice of the election, as required by law.
Section 6. Establishment of the Deadline for Argument Submission; Designation of
Los Altos Hills City Council Resolution No.
3 Preferences if Multiple Submissions.
Pursuant to Elections Code section 9286 the City Clerk has established August 11, 2026, 5:00 p.m. as the deadline for the submission of arguments in favor of and arguments against the question. If more than one argument for or more than one argument against the question is submitted, the priorities set forth in Elections Code section 9287 shall control. Primary arguments shall not exceed three hundred (300) words and shall be signed by not more than five persons.
Section 7. Provision for Rebuttal Arguments.
Pursuant to Elections Code section 9285(b) the City Council hereby adopts the provisions of Elections Code section 9285(a) allowing the filing of rebuttal arguments. The deadline for filing rebuttal arguments shall be 5:00 p.m., August 18, 2026. Rebuttal arguments shall not exceed two hundred fifty (250) words and shall be signed by not more than five persons; those persons may be different persons than the persons who signed the primary arguments.
Section 8. Pursuant to California Elections Code Section 9282, Councilmembers ____ and ______are hereby authorized to submit a written argument in favor of the proposed measure, not to exceed three hundred (300) words, on behalf of the City Council. At Councilmember ______ discretion, the argument may also be signed by other members of the City Council or bona fide associations or by individual voters who are eligible to vote on the measure. In the event that an argument is filed against the measure, Councilmembers ______ and _______ are also authorized to submit a rebuttal argument on behalf of the City Council, which may also be signed by members of the City Council or bona fide associations or by individual voters who are eligible to vote on the measure, which may be different from those who signed the primary argument.
Section 9. Impartial Analysis
Pursuant to California Elections Code Section 9280, the City Council hereby directs the City Clerk to transmit a certified copy of the measure to the City Attorney. The City Attorney shall prepare an impartial analysis of the measure, not to exceed five hundred (500) words in length, showing the effect of the measure on the existing law and the operation of the measure, and file the impartial analysis with the City Clerk by August 11, 2026.
Section 10. Pursuant to California Elections Code Section 9285, when the City Clerk has selected the arguments for and against the measure, which will be printed and distributed to the voters, the City Clerk shall send copies of the argument in favor of the measure to the authors of the argument against, and copies of the argument against to the authors of the argument in favor.
Rebuttal arguments shall be printed in the same manner as the primary arguments. Each rebuttal argument shall immediately follow the primary argument, which it seeks to rebut.
Section 11. The City Clerk is directed to file certified copies of this Resolution with the Board of Supervisors and the Registrar of Voters of the County of Santa Clara.
Section 12. The jurisdictional boundaries of the Town of Los Altos Hills have not changed since the last general municipal election.
Los Altos Hills City Council Resolution No.
4 Section 13. The proposed initiative measure is exempt from CEQA pursuant to the CEQA Guidelines Section 15061.3 common sense exception in that CEQA applies only to projects which have the potential for causing a significant effect on the environment. The proposed amendments will not have any impact on the current Land Use Plan, which already has a policy related to keeping of horses and domesticated animals on residential property and this initiative measure clarifies that policy and the existing Land Use Element already does not allow industrial and large-scale commercial and retail uses within the Town.
Section 14. This Resolution shall become effective immediately upon its passage and adoption.
ITEM 7D, Attachment 2
Initiative to Amend Various Elements of the General Plan to Incorporate Certain Land Use Principles to Preserve the Rural Atmosphere of the Foothills and the Community, Commonly Referred to as the “Green Sheets of the Town of Los Altos Hills” Consisting of:
Allow Various Animals; Prohibit Industrial, Retail, and Commercial Designations.
The City Council of the Town of Los Altos Hills hereby ordain as follows:
Section 1: Purpose
A. The Town of Los Altos Hills (“Town”) was incorporated in 1956 based on local residents’ desire to preserve the rural atmosphere of the foothills and other related community interests. The reasons for incorporation were compiled in a set of documents commonly referred to as the “Green Sheets”, as they were originally printed on light green paper.
Among other information, the Green Sheets set forth the arguments in favor of incorporation and the blueprint of the type of community that supporters sought to achieve.
B. The Green Sheets describe certain characteristics for the Town as desired by the incorporation advocates, which are summarized as follows:
1) A wide and not over-populated community of homes in the country, with only planning, controls, ordinances and services that are absolutely essential. 2) Sun, air, and quiet of a community; relaxed pace of country life and rural pursuits; and the space and right to keep animals.
3) No high speed roads, increased traffic, additional quarrying, trucks and resorts. 4) No additional industry and commerce.
C. California law permits municipalities to adopt or amend their general plans and/or zoning ordinances through the initiative process. An initiative measure proposing such an amendment may be placed on the ballot by formal action of the Council on its own volition.
D. To effectuate these purposes to memorialize provisions of the Green Sheets into the General Plan that have not previously been explicitly incorporated would require an amendment to the Land Use Element. This Initiative may only be amended or repealed by the voters of the Town of Los Altos Hills.
Section 2 General Plan Amendments
This Section of the Initiative enacts amendments to the Town of Los Altos Hills General Plan.
A. Amendments to the General Plan Land Use Element Text.
Amend subsection (a) of Policy 1.2 of Goal 1 on Page LU-4 of the General Plan Land Use Element, attached hereto as Exhibit B, as set forth below. Text to be inserted is shown in red underline and text to be deleted is presented in strikethrough type:
Those uses normally accessory to dwellings in a semi-rural area: vineyards and orchards, the keeping of horses and other domestic animals (including but not limited to rabbits, birds, fowl, dogs, cats, sheep, cattle, pigs, goats, equines, llamas, alpacas, and the like), and other agricultural pursuits that are compatible with residential uses. This subsection (a) of Policy 1.2 shall not be changed or rescinded without approval of the voters; Add Policy 1.4 on Page LU-4 of the General Plan Land Use Element, attached hereto as Exhibit B, as set forth below. Text to be inserted is shown in red underline and text to be deleted is presented in strikethrough type:
The Town shall not allow new industrial, large-scale commercial, or retail land uses as a part of its zoning code. Home-based small-scale businesses such as catering and internet businesses are not considered industrial, large-scale commercial, or retail uses for the purpose of this provision. This provision does not and is not intended to prohibit, alter or modify the status of any existing commercial development within the Town prior to the passage of this measure nor does this provision apply to Town owned property. This policy shall not be changed or rescinded without voter approval.
Section 3: Implementation
A. Effective Date. Upon the effective date of this Initiative, the Town of Los Altos Hills General Plan and Zoning Code are amended as shown in Sections 2 or 3 of this Initiative, except that if the four amendments of the General Plan permitted in a calendar year as prescribed under California Government Code section 65358 have been utilized prior to the effective date of this measure, this General Plan amendment shall be the first amendment added to the General Plan on January 1 of the following year. At such time as the General Plan amendments enacted by this Initiative are inserted into the General Plan, any provision of the Town's Zoning Code inconsistent with this Initiative shall not be enforced.
B. Amendments Internat Consistency. The Town of Los Altos Hills General Plan, as amended by this initiative, comprise an integrated, internally consistent and compatible statement of policies for the Town.
C. Other Town General Plan Provisions, Ordinances, and Policies. The Town is hereby authorized and directed to amend other provisions of the General Plan, Zoning Code, and other ordinances and policies affected by this Initiative as soon as possible and in the manner and time required by State Law to ensure consistency between Sections 2 or 3 of this Initiative and other provisions of the Town's General Plan, the Town Zoning Code, and other Town ordinances and policies.
Section 4: Severability and Interpretation
This Initiative shall be interpreted so as to be consistent with all federal and state laws, rules, and regulations. If any section, sub-section, sentence, clause, phrase, part, or portion of this Initiative is held to be invalid or unconstitutional by a final judgment of a court of competent jurisdiction, such decision(s) shall not affect the validity of the remaining portions of this Initiative. The voters
hereby declare that this Initiative, and each section, sub-section, sentence, clause, phrase, part, or portion thereof would have been adopted or passed even if one or more sections, sub-sections, sentences, clauses, phrases, parts, or portions are declared invalid or unconstitutional. If any provision of this Initiative is held invalid as applied to any person or circumstance, such invalidity shall not affect any application of this Initiative that can be given effect without the invalid application. This Initiative shall be broadly construed to achieve the purposes stated in this Initiative.
Section 5: Amendment or Repeal
Except as otherwise provided herein, this Initiative may be amended or repealed only by the voters of the Town of Los Altos Hills.
Overview of
“Green Sheets” Initiative
Measure
Steve Mattas, City Attorney | June 18, 2026
Changes to Land Use Element
• Defines the types of domestic animals that are permissible within the Town as including but not limited to rabbits, birds, fowl, dogs, cats, sheep, cattle, pigs, goats, equines, llamas, alpacas, and the like. • Prohibits new industrial, large-scale commercial, or retail land uses. 6/18/2026 5
Proposed Changes
Pathways Committee Feedback
• Nick moved that PWC recommend to council that the current Green Sheets ballot proposition (open space and commercial properties) move forward.
• Richard recommends that whenever possible, the pathways be included in the Green Sheets.
6/18/2026 3
Environmental Design and Protection
Committee
• On June 9, EDPC voted to add the previously proposed pathway language to the measure and recommended that the language “shall not be changed or rescinded without approval of the voters.” 6/18/2026 4
5/14/2026 5
Council Initiated Measure Timeline
Date Action Description
April 16, 2026 Council consideration of draft ballot measure language incorporating prior direction from City Council.
April 17, 2026 through
July 2, 2026
Time for review of draft initiative measure by Commissions and Committees if directed by City Council (this is not a legal required action).
July 16, 2026 Last regular City Council meeting prior to initiative measure submission date.
August 6, 2026 Last day that City Council may act to place a Council sponsored initiative measure on the November 3, 2026 ballot.
November 3, 2026* Initiative will be on the ballot at the November 3, 2026 general election.
• City Council may consider the comments from Town Committees, Planning Commission and the public and decide if any changes to the proposed language should be made.
• City Council may act on the resolution tonight.
• Council has until August 6th, 2026, to approve the initiative for the November ballot.
6/18/2026 6
Next Steps
6/18/2026 7
Questions?
1 Arika Miller
From: Cody Einfalt
Sent: Friday, June 5, 2026 8:42 AM
To: Arika Miller
Subject: FW: Council Request for Comments on the Greensheets The committee notes from 5/27 should be a supplemental item to upload for the greensheets for June 18th From: Mike Orlando
Sent: Thursday, June 4, 2026 7:57 PM
To: Cody Einfalt <[email protected]>
Cc: Nick Erndt
Subject: Re: Council Request for Comments on the Greensheets Hi AllHere's the Greensheets excerpt from the 5/27 PWC Special Meeting notes:
6. Recommendation/Vote for Green Sheet/Ballot Prop
PWC needs to recommend whether or not Green Sheets should be brought to the public through a ballot proposition. Nick moved that PWC recommend to council that the current Green Sheets ballot proposition (open space and commercial properties) move forward. Richard recommends that whenever possible, the pathways be included in the Green Sheets.
On Thu, Jun 4, 2026 at 7:31 PM Cody Einfalt <[email protected]> wrote:
Please and thank you! I’ll stand by Mike
Cody
From: Nick Erndt
Sent: Thursday, June 4, 2026 4:54 PM
To: Cody Einfalt <[email protected]>;
Subject: RE: Council Request for Comments on the Greensheets Mike - can you pass on the notes from the last meeting? For Cody, you could just pass on the Greensheets feedback.
ITEM 7D, Supplement 1
2 Yahoo Mail: Search, Organize, Conquer
On Thu, Jun 4, 2026 at 2:16 PM, Cody Einfalt
<[email protected]> wrote:
Hi,
I am following up to see if your committee was able to provide comments on the proposed Greensheet Ballot Initiative.
Cody Einfalt, MPA
City Manager
Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
P: 650-947-2508 | F: 650-941-3160
E: [email protected]
From: Cody Einfalt
Sent: Tuesday, May 19, 2026 7:47 AM
To:
Subject: Council Request for Comments on the Greensheets
Take care,
Nick
3 The Town Council is set to hold a public hearing on the draft ballot initiative designed to place into the Town’s General Plan Land Use Element two key elements first set forth in the Green Sheets. At the June 18, 2026, meeting the City Council will consider whether to place the initiative on the ballot for the November general election.
At the May 14th meeting, the Town Council requested input from the Town Land Use Committees and Planning Commission on the proposed initiative measure. Since the proposed initiative amends the General Plan Land Use Element, Government Code Section 65353 requires that the Planning Commission hold a public hearing and then make a recommendation to the City Council on the proposed amendments. Thus, the purpose of this request is to seek committee input and the Planning Commission’s recommendation on the proposed ballot initiative prior the Council considering action to place the measure on the ballot for residents to decide whether to approve the changes to the Land Use Element as set forth in the initiative measure.
Here is a copy of the proposed ballot initiative seeking comments:
https://losaltoshillsca.portal.civicclerk.com/event/4504/files/attachment/14022 For background, the Green Sheets, written in 1956, were the first statements of the type of community our founders wanted for Los Altos Hills and on the community pillars they saw as essential to preserve the rural character of the town. Some of the points listed in the Green Sheets are no longer applicable, but some are still pertinent.
The councilmembers who have expressed support for further consideration of this initiative measure believe there is urgency to consider this initiative measure as a way to preserve some aspects of the Green Sheets and character of the Town.
The ballot initiative would amend policy 1.2 of Goal 1 within the Land Use Element to clarify that the types of animals that are allowed within the Town include but are not limited to rabbits, birds, fowl, dogs, cats, sheep, cattle, pigs, goats, equines, llamas, alpacas, and the like. Additionally, the ballot measure would add policy 1.4 to Goal 1 within the Land Use Element which would prohibit the introduction of new industrial, large-scale commercial, and retail uses. Policy 1.4 would not apply to existing commercial development within the Town or to Town owned property. If the initiative measure is placed on the November ballot and approved by a majority of voters, the changes approved by in the initiative measure would require voter approval from the residents to changes these specific policies identified above.
Good Morning Pathways Committee Chair and Vice Chair,
4 A public hearing regarding this proposed initiative measure was held by the City Council on April 16, 2026. At that meeting, the City Council provided direction to the City Attorney to modify the draft initiative measure to limit its focus to changes to the Land Use Element that would prohibit new industrial, large-scale commercial, or retail land uses and to allow for the keeping of animals on residential property including rabbits, birds, fowl, dogs, cats, sheep, cattle, pigs, goats, equines, llamas, alpacas, and the like in Town. At that time, the Council was not specific as to whether this would apply to only single-family residential lots or could potentially apply to the multi-family residential lots. The committees may desire to offer their input on this issue as they consider the draft initiative measure.
On Thursday, June 18, 2026, the Town Council will vote to determine whether to place this initiative measure on the November ballot. To insure a well-thought-out ballot imitative, the Town Council requested that the applicable land-use committees review the draft ballot initiative at one of their upcoming meetings and forward any committee recommendations to the City Manager for presentation to the City Council. Similarly, the City Council has requested that the Planning Commission, acting consistent with Government Code Section 65353, schedule and conduct a hearing and provide its recommendations regarding the proposed amendments to the Land Use Element set forth in the initiative measure. Please submit your committee’s opinions and comments to me (Cody Einfalt [email protected]) for input to the Town Council before June 8th.
Cody Einfalt, MPA
City Manager
Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
P: 650-947-2508 | F: 650-941-3160
E: [email protected]
The ballot initiative would make it harder for future Town Councils to make changes, as a vote of the people would be required for the change and some people consider this as a negative consequence. Some feel it is positive.
1 Arika Miller
From: Gumapos, Melvina <[email protected]> Sent: Friday, June 12, 2026 4:02 PM
To: Arika Miller
Cc: ROV-fiscal; Candidate Services
Subject: RE: Inquiry Regarding Ballot Initiative Costs for November 2026 Election Hi Arika,
The total estimated cost to place a measure on the ballot is $45,842. This includes a processing fee of $11,253 to place the measure on the ballot and an estimated measure cost of $34,590. When estimating costs, we assume a six-page measure, which typically includes the text of the measure, an impartial analysis, arguments in favor and against, and rebuttals to both arguments. Please see the estimated measure cost details below. You may deduct the cost of any pages you choose not to include. We encourage you to consult with your legal counsel regarding your options as ROV cannot give legal advice.
Thank you.
Melvina
ROV-Fiscal
(408) 282-3087
From: Arika Miller <[email protected]>
Sent: Friday, June 12, 2026 9:35 AM
To: Gumapos, Melvina <[email protected]>
Cc: ROV-fiscal <[email protected]>; Candidate Services <[email protected]> Subject: [EXTERNAL] RE: Inquiry Regarding Ballot Initiative Costs for November 2026 Election Good morning Melvina,
Thank you for providing the election cost estimate for the Town of Los Altos Hills.
I have a follow-up question regarding the ballot measure cost estimate. The draft estimate appears to assume a six-page ballot measure; however, the actual proposed measure is only three pages in length, with a ballot question of 75 words or less.
Could you please confirm whether the reduced measure length would result in a lower estimated cost for the ballot measure portion of the election? We would appreciate an updated estimate, if applicable, so that we can accurately reflect the anticipated costs in our upcoming staff report and City Council presentation.
ITEM 7D, Supplement 3
2 Thank you for your assistance. I look forward to hearing from you.
Best regards,
Arika Miller
City Clerk
From: Gumapos, Melvina <[email protected]> Sent: Thursday, June 11, 2026 5:48 PM
To: Arika Miller <[email protected]>
Cc: ROV-fiscal <[email protected]>; Candidate Services <[email protected]> Subject: RE: Inquiry Regarding Ballot Initiative Costs for November 2026 Election Hi Arika,
Good evening.
Enclosed is the election cost estimate for the Town of Los Altos Hills.
Please note that this estimate is based on projected registration and currently available information. They are subject to change upon final billing of actual charges after the election.
Thank you.
Melvina
ROV-Fiscal
(408) 282-3087
From: Arika Miller <[email protected]>
Sent: Wednesday, May 6, 2026 1:46 PM
To: ROV-fiscal <[email protected]>; Candidate Services <[email protected]> Subject: [EXTERNAL] Inquiry Regarding Ballot Initiative Costs for November 2026 Election Good afternoon,
3 I am reaching out to inquire about the estimated cost associated with adding a ballot initiative measure to the November 2026 ballot for the Town of Los Altos Hills.
Specifically, we would like to understand the additional cost of placing a ballot initiative on the ballot in conjunction with our regular municipal election. If possible, could you please provide an estimate of the anticipated costs and any related considerations or deadlines we should be aware of?
Thank you in advance for your assistance. Please let me know if you need any additional information from the Town in order to provide an estimate.
Best,
Arika Miller
2
3 All this for what? A ballot initiative our own town founders (not ones to shrink from bold ideas on the ballot) chose not to undertake. Perhaps because they themselves would soon go against one of the injunctions on those selfsame sheets: the one regarding not wanting a city manager. Perhaps because they trusted future city councils to protect the ideas represented by the sheets while giving them the leeway they needed to reflect simultaneously the ethos and preferences of the town's residents rather than those of the people of a particular time and place.
While we're running to protect ourselves from an imaginary future council that wants to plonk a hypothetical Walmart in our town, are there not real, visible concerns on which we could be spending our money? Has anyone suggested that residents be banned from keeping animals? Has any retail establishment actually considered buying the most expensive land in our county to put up a superstore?
Please trust future city councils to do the right thing for our town and its residents just as past councils have! Thank you
Anand
TOWN OF LOS ALTOS HILLS June 18, 2026
Staff Report to the City Council
SUBJECT: INTRODUCTION OF AN ORDINANCE DESIGNATING THE
MARTHA LYNN TANK HOUSE AT 12889 VISCAINO PLACE AS A
HISTORICAL LANDMARK, FILE #SP24-0001.
PREPARED BY: Jonathan Fox, Senior Planner
FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, City Manager
RECOMMENDATION: That the City Council:
Introduce an Ordinance (Attachment 1) designating the Martha Lynn Tank House at 12889 Viscaino Place (Fremont Hills Country Club) as a historical landmark.
BACKGROUND:
Figure 1. FHCC Property Source. Town GIS
On October 22, 2024, the City Council approved FILE# CUP24-0002 for a new aquatic building at Fremont Hills Country Club. As a condition of approval, the applicant is required to apply for landmark designation of the water tower and obtain a City Council decision on that application.
This condition must be satisfied before final closeout of the building permit.
NOTICING / PUBIC COMMENTS
As required by LAHMC Section 11-1.04, The public was advised of this Public Hearing in the following ways:
ITEM 7E STAFF REPORT
City Council
Martha Lynn Tank House
June 18, 2026
• Mailing to owners of property within 300 feet of the subject property - May 29, 2026 • Public posting places - May 29, 2026
• Posted at the project site – May 29, 2026
• Town Website: www.losaltoshills.ca.gov – June 12, 2026 To date, staff has received one public comment and is included as Attachment 4.
CODE REQUIREMENTS
The following Municipal Code sections are applicable to this project:
Section 11-1.03 Designation by ordinance.
The City Council by ordinance may designate one or more individual structures or other natural features, sites, or areas having a special character or special historical, architectural, cultural or aesthetic interest or value or significance as landmarks, and shall designate a landmark site for each landmark.
Section 11-1.04 Public hearing.
The City Council shall hold a public hearing concerning each proposed designation. Notice of time and place of the hearing shall be given not less than ten (10) days prior to the hearing: (a) by posting copies of the Notice of Public Hearing in at least three (3) public places in the City of the Town of Los Altos Hills and in at least three (3) places along the streets upon which the property on which the structure, natural feature, site or area abuts; and (b) by United States mail to the owner of the property and to each other property owner within a distance of three hundred (300) feet of the property, using addresses from the last adopted tax roll.
DISCUSSION:
The applicant retained architectural preservation firm, Page & Turnbull, to prepare a landmark evaluation report (Attachment 2). The report finds that the Martha Lynn Tank House is historically significant to Los Altos Hills and Santa Clara County and qualifies for Landmark Designation under the Town's adopted criteria. Staff and the History Committee agree with these findings.
On February 17, 2026, the History Committee voted unanimously to recommend to the City Council that the Martha Lynn Tank House be designated as a historic landmark.
As part of the application, Fremont Hills Country Club provided a written narrative (Attachment 3) highlighting several items for the Town to consider as part of potential landmark designation.
A summary is provided below:
• FHCC is applying under mandate
• The tower’s public exposure is extremely limited
• The structure serves an active, functional purpose
• FHCC already intended and remains committed to renovating and beautifying the tower • Strict historic material requirements could create a financial burden
City Council
Martha Lynn Tank House
June 18, 2026
Staff has considered these comments and finds that they do not preclude approval of the landmark designation. The structure retains its historical, architectural, and visual significance, which form the basis for designation under the Town's landmark criteria. Furthermore, landmark designation would not prevent the continued use, maintenance, or improvement of the structure. While future alterations that materially affect the landmark's exterior appearance require City Council approval, ordinary maintenance and repair may continue without a Landmark Alteration Permit.
Accordingly, staff finds that the required findings for landmark designation can be made.
Pursuant to LAHMC Section 11-106, in considering the designation of landmarks, the City Council shall make the following findings:
1. That the proposed landmark has significant historical, architectural, cultural or aesthetics interest or value.
2. That the proposed landmark may be designated without imposing undue hardship on the property owner.
3. That approval or modified approval of the application is consistent with the purposes and criteria of this chapter.
Staff has prepared draft findings for the Council’s consideration which are included under Attachment 1.
If approved, the tank house may be added to the Inventory of Historic Sites and Structures (Appendix A) during the next review of the inventory.
ENVIRONMENTAL REVIEW:
The proposed ordinance is exempt from the California Environmental Quality Act (CEQA) pursuant to section 15331 which allows for preservation and conservation of historical resources. 2026 CITY COUNCIL STRATEGIC PRIORITIES:
This request was not part of the Council’s priorities for 2026.
FISCAL IMPACT:
There is no fiscal impact associated with the landmark designation request.
ATTACHMENTS
1. Resolution
2. Landmark Evaluation Report
3. Applicant Narrative
4. Public Comment
Ordinance XXX Page 1
ORDINANCE XXX
ORDINANCE OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS DESIGNATING THE MARTHA LYNN TANK HOUSE AT 12889 VISCAINO PLACE (FREMONT HILLS COUNTRY CLUB) AS A HISTORICAL LANDMARK
WHEREAS, Section 11-1.03 (Designation by ordinance) of Chapter 1 (Landmark Designation and Preservation) of Title 11 (Landmark Designation and Preservation) authorizes the City Council to designate by Ordinance one or more individual structures or other natural features, sites, or areas having a special character or special historical, architectural, cultural, or aesthetic interest or value or significance as landmarks.
WHEREAS, The City Council must make the findings listed in Section 11-1.06 to approve a LandMark Designation; and
WHEREAS, The architectural preservation firm, Page & Turnbull, has determined that the Martha Lynn Tank House is historically significant to Los Altos Hills and Santa Clara County and qualifies for Landmark Designation under the Town’s adopted criteria; and WHEREAS, On February 17, 2026, the History Committee voted unanimously to recommend to the City Council that the Martha Lynn Tank House be designated as a historic landmark; and WHEREAS, The City Council has held a noticed public hearing on June 18, 2026, in accordance with the provisions of 11-1.04 of the Los Altos Hills Municipal Code and accepted public comments regarding this matter; and
NOW, THEREFORE, the City Council of the Town of Los Altos Hills does ORDAIN as follows:
1. That the Martha Lynn Tank House at 12889 Viscaino Place, Los Altos Hills, California, is designated as Historical Landmark, making the Findings outlined in Exhibit A.
2. SEVERABILITY. If any provision of this Ordinance or the application thereof to any person or circumstance is held invalid or unconstitutional, the remainder of this Ordinance, including the application of such part or provision to other persons or circumstances shall not be affected thereby and shall continue in full force and effect. To this end, provisions of this Ordinance are severable. The City Council of the Town of Los Altos Hills hereby declares that it would have passed each section, subsection, subdivision, paragraph, sentence, clause, or phrase hereof irrespective of the fact that nay one or more sections, subsections, subdivisions, paragraphs, sentences, clauses, or phrases be held unconstitutional, invalid, or unenforceable.
3. EFFECTIVE DATE AND PUBLICATION. This ordinance shall become effective thirty (30) days from the date of its adoption. Within 15 days after the passage of this ordinance, the Town Clerk shall cause the Ordinance or a summary thereof to be published once with the names of those Town Councilmembers voting for or against it in a newspaper or general circulation in the Town of Los Altos Hills, as required by the law.
ITEM 7E ATTACHMENT 1
Ordinance XXX Page 2
INTRODUCED:
PASSED:
AYES:
NOES:
ABSTAIN:
ABSENT:
By: ___________________________________
Rajiv Bhateja, Mayor
ATTEST:
______________________________________________
Arika Miller, City Clerk
APPROVED AS TO FORM:
______________________________________________
Steve Mattas, City Attorney
Ordinance XXX Page 3
EXHIBIT “A”
FINDINGS FOR LANDMARK DESIGNATION
MARTHA LYNN TANK HOUSE – 12889 VISCAINO PLACE
FILE #SP24-0001
1. That the proposed landmark has significant historical, architectural, cultural or aesthetics interest or value.
The proposed landmark has significant historical, architectural, and aesthetic value. Constructed in 1906 on the Martha Lynn homestead and later incorporated into the Shumate Ranch, the structure is directly associated with the area's early twentieth-century agricultural and equestrian history.
Architecturally, it is significant as one of the few remaining water tanks of its type in Santa Clara County. Aesthetically, its prominent hilltop location within the Fremont Hills Country Club equestrian grounds makes it a distinctive and well-recognized visual landmark in the surrounding area.
2. That the proposed landmark may be designated without imposing undue hardship on the property owner.
The proposed landmark may be designated without imposing undue hardship on the property owner. Designation would recognize and protect the structure's historic significance while allowing for its continued use and maintenance. There is no evidence that landmark designation would deprive the owner of reasonable use of the property or impose an unreasonable economic burden.
Pursuant to LAHMC Section 11-1.09, a Landmark Alteration Permit approved by the City Council would be required for alterations, construction, relocation, exterior painting, or demolition that would result in a material change to the landmark's exterior appearance. However, ordinary maintenance and repair activities that do not materially alter the landmark's appearance may be undertaken without a Landmark Alteration Permit.
3. That approval or modified approval of the application is consistent with the purposes and criteria of this chapter.
The approval of the request would designate the Martha Lynn Tank House as having special architectural, historical, cultural, and aesthetic significance as a landmark pursuant to Section 11-
1.05 of the Municipal Code.
MARTHA LYNN TANK HOUSE
LANDMARK EVALUATION REPORT
12889 VISCAINO PLACE
LOS ALTOS HILLS, CALIFORNIA
[24391]
PREPARED FOR
FREMONT HILLS COUNTRY CLUB
October 30, 2025
FINAL
ITEM 7E ATTACHMENT 2
Landmark Evaluation Report Martha Lynn Tank House
[24391] 12889 Viscaino Place, Los Altos Hills, CA
PAGE & TURNBULL i October 30, 2025
TABLE OF CONTENTS
INTRODUCTION .................................................................................................................................... 1 Methodology ...................................................................................................................................................3 Summary of Findings .....................................................................................................................................3 PHYSICAL DESCRIPTION....................................................................................................................... 5 Site....................................................................................................................................................................5 Exterior.............................................................................................................................................................6 Interior ...........................................................................................................................................................10 Surrounding Area .........................................................................................................................................11 HISTORIC CONTEXT ............................................................................................................................ 13 Los Altos Hills History...................................................................................................................................13 Tank Houses & Water Towers.....................................................................................................................16 SITE HISTORY....................................................................................................................................... 22 Site Development.........................................................................................................................................22 Martha Lynn Tank House Construction Chronology ...........................................................................29 Ownership History........................................................................................................................................31 Select Biographies ....................................................................................................................................32 TOWN OF LOS ALTOS HILLS LANDMARK DESIGNATION EVALUATION..........................................35 Character-Defining Features and Non-Contributing Features...............................................................37 CONCLUSION ...................................................................................................................................... 39 REFERENCES ........................................................................................................................................ 40 APPENDICES ........................................................................................................................................ 43 Appendix A – Preparer Qualifications........................................................................................................43
Landmark Evaluation Report Martha Lynn Tank House
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INTRODUCTION
This Landmark Evaluation Report has been prepared at the request of the Fremont Hills Country Club for the structure known as the Martha Lynn Tank House located within the bounds of the Fremont Hills Country Club at 12889 Viscaino Place (APN 175-55-049) in the Fremont Hills neighborhood of Los Altos Hills. Originally situated within a homestead owned by Martha Lynn following the Rancho era (circa 1776- circa 1854), the tank house was constructed during her ownership in 1906 following the San Francisco earthquake. San Francisco-based pharmacist Dr.
Thomas Shumate acquired the property shortly thereafter in circa 1910 and built a summer estate consisting of a residence and stables. From the time of the tank house’s construction through the mid-1950s, the property containing the tank house retained its agricultural use, even as the Shumates amassed the surrounding 400 acres to serve as a walnut orchard and a horse ranch. The parcel was subsequently acquired in 1956 by the Fremont Hills Development Company for the purpose of establishing the Fremont Hills subdivision, inclusive of a 15-acre country club site, the Fremont Hills Country Club (Figure 1). The Fremont Hills Country Club has continuously used several of the Lynn and Shumate estate-era buildings for their recreational operations, including Shumate’s stables for the club’s equestrian program (Figure 2). The country club has also retained and converted the Martha Lynn Tank House into restrooms associated with the equestrian facilities.
The Martha Lynn Tank House (also referred to as “Martha Lynn Water Tower”) is listed in the Town of Los Altos Hills Inventory of Historic Sites and Structures, dated June 6, 2018, and is therefore considered a historic resource by the Town of Los Altos Hills.1 The structure, however, has not been formally designated as a Town of Los Altos Hills Landmark. The purpose of this report is to evaluate the structure under the landmark criteria for Los Altos Hills. 1 The Martha Lynn Tank House has continued to be listed by the town as a historical resource, per the more recent Town of Los Altos Hills Historical Resources List, dated 2024 and available online at:
https://www.losaltoshills.ca.gov/DocumentCenter/View/6785/Town-of-LAH-Historical-Resources-2024-List.
Landmark Evaluation Report Martha Lynn Tank House
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Figure 1. Fremont Hills Country Club parcel at 12889 Viscaino Place (APN 175-55-049), shaded red. The approximate location of the Martha Lynn Tank House within the property bounds is indicated with a red star.
Source: Santa Clara County Assessor’s Office. Edited by Page & Turnbull.
Figure 2. Aerial view of the Fremont Hills Country Club with approximate property boundary outlined in red, 2025. The white arrow indicates the Martha Lynn Tank House. Source: Google Earth. Edited by Page & Turnbull.
Landmark Evaluation Report Martha Lynn Tank House
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Methodology
This report follows a standard outline for evaluating local historic resources and provides a summary of the current local historic status, a building description, and historic context for the Martha Lynn Tank House located within the bounds of the Fremont Hills Country Club. Page & Turnbull prepared this report using research collected at local repositories, including the Santa Clara County Office of the Assessor-Recorder, the Town of Los Altos Hills Planning and Community Development Department, and the Los Altos Library, as well as online sources including Ancestry.com, the California Digital Newspaper Collection, and Newspapers.com. Key primary sources consulted and cited in this report include Historic American Building Survey (HABS) documentation and historical newspapers.
Page & Turnbull staff conducted a site visit to 12889 Viscaino Place on August 5, 2025 to photograph the structure and its existing conditions. All photographs within this report were taken at that time, unless otherwise noted.
Summary of Findings
In Page & Turnbull’s professional opinion, the Martha Lynn Tank House located on the Fremont Hills Country Club property at 12889 Viscaino Place is a rare surviving example of an early twentiethcentury tapered-tower overhang type, a once-common but now scarce form of domestic water infrastructure in Santa Clara County. Constructed in 1906 on the Martha Lynn homestead and later incorporated into the Shumate Ranch, the structure is directly associated with the region’s early twentieth-century agricultural and equestrian heritage and the development patterns that shaped Los Altos Hills. The tank house continues to convey its historical significance despite the passage of time and the deterioration of some original materials. Its preserved form, materials, and craftsmanship embody the functional ingenuity of vernacular builders, while its enduring presence within an equestrian setting reinforces its contextual link to the rural character of the Town. As such, the tank house appears to meet the following Town of Los Altos Hills’ criteria for Landmark designation:
Criterion A: Its character, interest, or value as part of the development of Los Altos Hills, and/or exemplification of the cultural, educational, economic, agricultural, social or historical heritage of Los Altos Hills;
Criterion C: Its embodiment of distinguishing characteristics or an architectural type of specimen; and
Criterion D: Its unique location or singular physical characteristics, whether manmade or natural, representing an established or familiar visual feature of a neighborhood,
Landmark Evaluation Report Martha Lynn Tank House
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community, or the Town of Los Altos Hills, or its relationship to any other landmark if its preservation is essential to the integrity of that landmark.
The structure’s period of significance spans from its date of construction, 1906, to the date the property was acquired for the purposes of a subdivision in 1956. The Martha Lynn Tank House remains a unique and important physical reminder of the community’s agricultural past.
Landmark Evaluation Report Martha Lynn Tank House
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PHYSICAL DESCRIPTION
The Martha Lynn Tank House is a three-story, wood-frame, tapered-tower overhang tank house. It features a hipped roof clad in wood shingles with exposed rafter tails; its tapered-tower base is also clad in wood shingles. The overhanging belvedere contains a round wood-panel water tank and features simple wood railing and decorative lattice sections below the roof eave.2 A surfacemounted wood ladder on the southwest elevation provides access to the elevated belvedere via a hatch in the floor. The interior at the ground floor is currently divided into two rooms, which serve as a men’s and women’s restroom.
Site
The Martha Lynn Tank House is situated within the Fremont Hills Country Club property located at 12889 Viscaino Place in Los Altos Hills. The 17-acre property lies east of Interstate 280 between Purissima Road and the Fremont Hills subdivision and features hilly terrain. It contains a Midcentury Modern clubhouse constructed in 1961; an Olympic-sized swimming pool and associated swim facilities; 13 tennis and pickleball courts; the Windy Hill Equestrian Center facilities with stables of varying ages, two riding arenas, and associated outbuildings and paddocks; and a surface parking lot (Figure 3). The tank house is located atop a hill within the equestrian area of the property, east of the stables and north of the riding arenas.
Figure 3. Bird's eye view of the Fremont Hills Country Club property at 12889 VIscaino Place, looking north. The tank house is identified with a white arrow. Source: Google Earth. Edited by Page & Turnbull. 2 A belvedere, when associated with a water tank (especially a water tower), refers to an architectural feature, typically at the top, designed to accommodate a person and provide a scenic viewpoint of the surrounding area.
TENNIS POOL
RIDING
ARENAS
STABLES
Landmark Evaluation Report Martha Lynn Tank House
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Exterior
The Martha Lynn Tank House is approximately three stories tall with a rectangular footprint (Figure 4). The wood-framed structure sits upon a concrete foundation. It is comprised of two sections: the tapered tower base and the upper overhanging belvedere with a hipped roof clad in wood shingles.
The tapered tower base is clad in painted wood shingles, creating an interior area at the ground floor (currently utilized as men’s and women’s restrooms). The overhanging platform of the belvedere is supported by three large wood beams as this housing contains the wood-panel water tank (Figure 5). The platform itself is comprised of a wood-board floor with an access hatch on the southwest side. The platform is enclosed by a simple wood railing and ornamented with flared sections of wood lattice between the roof support posts below the eave, which features exposed rafter tails.
Figure 4. Northeast facade
illustrating the tapered tower
base and belvedere sections.
Figure 5. Upper belvedere section.
The four exterior facades of the tank house are similar with few openings and little to no ornamentation. The southwest façade includes a single wood door near the south corner and a surface-mounted wood ladder near the center, which provides access to the upper belvedere volume (Figure 6 and Figure 7). Several vertical boards are mounted to the lower rungs of the ladder. The concrete foundation extends at the south corner to create a paved landing at the door.
This landing area features an L-shaped raised curb that extends southwest from the structure and then turns northwest (Figure 8).
Landmark Evaluation Report Martha Lynn Tank House
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Figure 6. Southwest facade, looking northeast. Figure 7. Door detail on southwest facade, looking north.
Landmark Evaluation Report Martha Lynn Tank House
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Figure 8. Door landing along base of southwest facade, looking southeast.
The southeast façade features a single wood door near the east corner, while the northeast façade lacks openings (Figure 9). The concrete foundation is raised above ground at the east corner and along the base of the northeast façade (Figure 11). The northwest façade has one centered window at the ground level, which is a wood-frame divided-lite fixed window (Figure 10 and Figure 12). The window is topped with a shallow shed roof clad in wood shingles and features a simple sill along its bottom edge. The glazed portions are covered by a galvanized wire mesh screen.
Landmark Evaluation Report Martha Lynn Tank House
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Figure 9. Oblique view of southeast (left) and
northeast (right) facades, looking west.
Figure 10. Northwest facade, looking southeast.
Figure 11. Concrete foundation detail. Figure 12. Window on northwest façade.
Landmark Evaluation Report Martha Lynn Tank House
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Interior
The interior at the ground floor is currently evenly divided into two rooms by a wood-frame wall clad in painted plywood panels. These interior spaces serve as a men’s and women’s restroom (Figure 13 and Figure 14). The floor of both restrooms is poured concrete and a short concrete knee wall is visible along the northeast and northwest interior elevations (Figure 15 and Figure 16). Larger wood beams rest upon this knee wall, which appears to be exposed structural framing of the tapered-tower base. Other large vertical beams of the tapered-tower base’s structural framing are exposed, giving the appearance that the exterior walls are angled inward. Both restrooms are outfitted with composite-board stalls and contemporary toilet furnishings (toilets and sinks) and contemporary lighting and plumbing fixtures.
Figure 13. Interior of women's restroom. Figure 14. Interior of men's restroom.
Figure 15. Exposed wood framing and
concrete knee wall in women's restroom
Figure 16. Non-historic door to men's
restroom.
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[24391] 12889 Viscaino Place, Los Altos Hills, CA
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Surrounding Area
The area surrounding the Martha Lynn Tank House consists of the Fremont Hills Country Club’s equestrian area (known as Windy Hill Equestrian), which includes several one-story stables and outbuildings, two riding arenas, a round pen, wood-fenced paddocks, and a surface parking lot accessed via Roble Ladera Road (Figure 17 through Figure 19). Based on historic aerial photographs, the two extant stables with monitor roofs appear to have been constructed by 1930, while the northern riding arena appears by 1958 and the southern arena by 1963. Between these features are natural areas, usually planted with grass and a scattering of mature trees. This southern portion of the country club parcel is bounded by Roble Ladera Road on the east and Purissima Road on the south and west. Large residential lots comprise the majority of properties along these boundary roads.
Figure 17. Windy Hill Equestrian area, looking southwest towards stables.
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Figure 18. Riding arenas to the south of the tank house, looking south.
Figure 19. Windy Hill Equestrian parking area, looking east from stables.
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HISTORIC CONTEXT
Los Altos Hills History
OHLONE, SPANISH, AND MEXICAN/RANCHO ERA PERIODS (1776-1854) Originally inhabited by Ohlone peoples before European contact in approximately 1775, the area’s earliest human presence was documented through archaeological excavations conducted in 1955, 1964, and 1970, which revealed burial sites and cultural artifacts throughout what would become Los Altos Hills.3 During the Spanish and Mexican periods, the land fell within two major Mexican land grants. In 1840, Governor Juan B. Alvarado granted Rancho La Purísima Concepción, encompassing 4,436 acres, to Jose Gorgonio and his son Jose Ramon, both Indigenous laborers from Mission Santa Clara. Juana Briones de Miranda, a prominent landowner and early settler of San Francisco, purchased the grant in 1844 for $300.4 The site of her adobe is a California Historical Landmark (No. 524).5 Adjacent to the Briones land was Rancho San Antonio, a similarly sized tract granted to Juan Prado Mesa. Adobe Creek, still a recognizable feature today, served as the boundary between the two ranchos. These grants and their associated families formed the basis for the region’s early EuroAmerican land tenure and development patterns.
AMERICAN AGRICULTURAL PERIOD (1855-1910)
The American period brought intensified agricultural and horticultural development. In 1855, Briones sold approximately 3,000 acres of her rancho to Martin Murphy, founder of Sunnyvale (Figure 20). Murphy later gifted the majority of the tract to his daughter Elizabeth Yuba and her husband William Taaffe, who established a country estate on land that now comprises the Foothill College campus.6 In the late nineteenth and early twentieth centuries, the area’s agricultural productivity shifted from viticulture (mainly Zinfandel grapes) to orchard crops, including apricots, prunes, and plums, after a grape blight devastated local wine production. This change aligned Los Altos Hills with the broader identity of the Santa Clara Valley as the "Valley of Heart's Delight," known nationally for its abundant fruit harvests.7 It was during this period that Martha Lynn moved her family to a homestead in the area (by 1906), where they endured the 1906 earthquake and built the existing tank house with the assistance of their neighbor, Harold L. Brubaker. 3 Town of Los Altos Hills, “Town History.” Accessed online, https://www.losaltoshills.ca.gov/218/Town-History. 4 Town of Los Altos Hills, “Town History.” 5 California Office of Historic Preservation, Landmarks by County: Santa Clara, accessed online, https://ohp.parks.ca.gov/?page_id=21522. 6 Town of Los Altos Hills, “Town History.” 7 Town of Los Altos Hills, “Town History.”
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Figure 20. Portion of the 1876 map of Fremont Township, drawn by Sherman Day. The black star marks the approximate location of the future site of the tank house. The portion of Arastradero Road shown here forms part of the northern limit of the Town of Los Altos Hills today. Source: David Rumsey Map Collection. Edited by Page & Turnbull.
ESTATE ERA (1911-1945)
The estate era began in earnest in the early twentieth century as affluent San Franciscans sought country retreats in the Peninsula’s hill regions south of the city, following the 1906 earthquake.
Large homes such as the Shumate House (Figure 21), Morgan Manor, and the Griffin House (Figure 22), some of which remain today as designated Los Altos Hills Historic Landmarks, were constructed as seasonal or year-round residences.8 These estates often occupied hilltop locations and maintained expansive grounds, reinforcing a low-density, rural aesthetic that contrasted with the growing urban fabric of the surrounding valley.
8 Town of Los Altos Hills, “Town History.”
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Figure 21. Shumate House, circa 1915. Source: Los
Altos Hills: A Colorful Story.
Figure 22. Willard Griffin House, circa 1901. Source: Los Altos Hills Historical Society.
POST-WORLD WAR II ERA (1946-1956)
By the postwar period, however, the pressures of suburban development began to threaten the established rural character of the Los Altos Hills. By 1950, roughly 500 families lived in the area.
Developers began proposing residential subdivisions with densities of four to six homes per acre, which alarmed local residents who favored preservation of the one-house-per-acre character of the community.9 In response, neighborhood associations formed in various parts of the area, including along Page Mill Road, Moody Road, and Robleda Avenue. These associations later consolidated their efforts through the formation of a formal Incorporation Committee in 1954. Led by William Simrell Jr., the committee developed a set of guiding documents known as the “Green Sheets,” which articulated the community's zoning preferences, desired municipal boundaries, fiscal estimates, and land-use goals.10
As nearby towns like Atherton, Hillsborough, Menlo Park, and Los Altos began banning horses as their once-widespread equestrian estates began to undergo subdivision, the horsemen of Los Altos Hills rode on horseback to gather signatures for incorporation of a town that would protect the rural character and equestrian history of their rolling hills.11 After considerable debate and public outreach, residents voted on incorporation on January 10, 1956, the same year Shumate Ranch was sold to the Fremont Hills Development Company. With a turnout of 65 percent, the measure passed narrowly and the Town of Los Altos Hills was officially incorporated on January 27, 1956, as the fourteenth municipality in Santa Clara County.12 Opponents of incorporation soon initiated efforts to 9 Los Altos Hills Historical Society, Fifteenth Anniversary Booklet, 1971, https://lahhistory.org/DigitalArchive/FifteenthAnniversaryBooklet. 10 Los Altos Hills Historical Society, Fifteenth Anniversary Booklet. 11 Los Altos Hills History Committee, “History of Horses & Pathways: Their Influence on Making Los Altos Hills A Connected Community,” accessed online, https://vimeo.com/1053555543. 12 Los Altos Hills Historical Society, Fifteenth Anniversary Booklet.
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reverse the vote, but these failed. Under the leadership of first mayor Sidney W. Treat, early town officials emphasized inclusive governance and consensus-building to stabilize the new civic framework.
MODERN LOS ALTOS HILLS (1957-PRESENT)
From its inception, Los Altos Hills pursued a planning model centered on rural preservation. The town implemented zoning regulations mandating a minimum one-acre lot size and prohibiting commercial development. These policies, aimed at limiting growth and maintaining open space, were upheld in the courts in the 1970s following a series of legal challenges. A central component of the town's planning approach has been its expansive network of pedestrian, equestrian, and bicycle pathways that traverse private lands via public easements and underscore the town’s rural identity and community ethos.13 The first pathways master plan was created in 1966 and today there are 85 miles of trails/paths.14
Today, the Town of Los Altos Hills remains one of the few communities in Santa Clara County to have maintained strict zoning ordinances, resisted commercial development, and retained a semirural character, reflecting the foundational priorities established during its mid-twentieth-century incorporation.
Tank Houses & Water Towers
In the history of rural California, tank houses and water towers were essential structures for providing pressurized water before the advent of electricity and municipal water systems. These structures, common throughout the agricultural landscape of Santa Clara County and the broader Bay Area, served as a means for rural residents and farmers to achieve a modern domestic water supply through gravity and the power of wind.
Tank houses and their predecessors, water towers, became widespread in the latter half of the nineteenth century, following the popularization of the self-regulating American windmill.15 The core components of a typical system included a hand-dug well, a windmill, and a large tank elevated on a platform. The windmill would pump water from the well into the tank, and the elevation of the tank would then create sufficient pressure for water to flow by gravity down to a farmhouse, field or garden, and/or livestock trough. The tank house was an evolution of the simpler water tower, which was just an elevated tank on an open tower. The enclosed structure housing the tank and its 13 Town of Los Altos Hills, “Town History.”
14 Los Altos Hills History Committee, “History of Horses & Pathways: Their Influence on Making Los Altos Hills A Connected Community,” accessed online, https://vimeo.com/1053555543. 15 Leon S. Pitman, “Domestic Tankhouses of Rural California,” Pioneer America, Vol. 8, No. 2 (July 1976): 84-97.
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supporting tower was known as a tank house. Tank houses were often located adjacent to the kitchen or service yard to reduce the run of pipes necessary to supply water to laundry areas or indoor washrooms. By enclosing the tank, farmers created a useful, multi-story space for purposes like storage or living quarters below the tank (Figure 23). Owning a water tank and tank house was a sign of prosperity, as it was a significant investment for a farm owner.16 The specific design of tank house varied, and six California domestic tank house subtypes ultimately developed.
The subtype expressed by the Martha Lynn Tank House is the “tapered tower with overhang” tank subtype. This design is characterized by a tapered vertical tower, the walls of which incline inward as they rise, and an overhanging tank enclosure that projects outward from the narrower top of the tower. This unique silhouette gave the structure improved stability and increased the capacity of the water tank without expanding the ground footprint.
This type of tank house was particularly well-suited for Santa Clara County’s agricultural conditions, where its tapered design provided enhanced wind resistance and stability in the wide, open terrain of the Santa Clara Valley. The overhanging tank enclosure allowed for a larger water tank (increased weight) on a smaller base, a practical consideration for smaller homesteads or properties on hillsides. These tank houses often utilized local redwood lumber for most of its components, including the tank itself as well as clapboard siding, for its rot-resistant properties. 16 Ellen Bowen and Lee Anne Wentz. "Tankhouses & Water Towers." YouTube video, 1:15:00. Presented by the Historical Society of Santa Rosa, July 20, 2023. https://www.youtube.com/watch?v=thaUBrH_q4s.
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Figure 23. Six common California domestic tank house type as determined by tower and tank room construction. “F” represents the tapered tower overhang type. Source: Pitman.
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California is notable for the sheer number of tank houses that were built, with one source estimating that over 90 percent of all existing enclosed water towers in the nation are in the state. 17 Another source estimated that “hundreds—perhaps thousands—once dotted the Santa Clara Valley landscape.”18 These structures were a defining feature of Santa Clara Valley’s rural landscape from the 1850s to the 1930s. The decline of tank houses and water towers began with the introduction of modern deep-drilled wells and electric pumps, which eliminated the need for gravity-fed systems.
Today, there are few remaining known water tank house structures, especially those exhibiting the tapered tower with overhang subtype and fewer that have been formally designated at the local, state or national level. For instance, in a review of the California Built Environment Resource Directory (BERD), 12 water tanks or tank houses in Santa Clara County appear to have been formally evaluated for state and/or federal listing.
19 Designated water tanks in Santa Clara County include the water tank at 201 Alma Street in Palo Alto (Figure 24), a reinforced concrete cylinder constructed in 1910. Another cylindrical water tank (1925), albeit of redwood, is that of the National Register-listed Messina Orchard in San José (Figure 25). A limited number of water tanks appear to reflect the tapered tower with overhang subtype. The tank house (1910) of the National Register-listed property Miller/Melone Ranch (Figure 26) in Saratoga appears to be a straight-box subtype. In nearby Los Altos, the tank house at 10 Yerba Buena Avenue (1912, Figure 27) is a Los Altos Landmark, but it is unclear from public view whether it is a tapered or straight-box subtype.
Figure 24. Fred Eyerly Water Tank/Tower Well
at 10 Alma Street, Palo Alto. Source:
PaloAlto.gov
Figure 25. Water Tank at Messina Orchard. Source:
Messina Orchard National Register Nomination.
17 Thomas Cooper, Tankhouse: California’s Redwood Water Towers from a Bygone Era. Santa Rosa, CA: Barn Owl Press, 2011. 18 Historic American Building Survey (HABS). “John Krohn Tank House, 13000 Foothill Avenue, San Martin, Santa Clara County, CA.” Accessed online, https://www.loc.gov/item/ca0977/. 19 https://ohp.parks.ca.gov/pages/1068/files/Santa%20Clara.csv
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Other known tapered tower with overhang subtype examples in Santa Clara County have been moved from their original locations and thereby have lost both their historic locations and historic settings. For example, the Spagnoli Tank House (1915) was moved from Pine Lane in Los Altos to the Figure 26. Tank House of the Miller-Melone Ranch,
Saratoga, CA. Source: Miller/Melone National Register
Nomination, 1993.
Figure 27. Tank House (background), 10 Yerba
Buena Avenue residence, Los Altos. Source:
Google Streetview, 2025.
Los Altos History Museum’s property in the 1990s (Figure 28). 20 Similarly, the Califaro Tank House
(ca. 1880s) was moved from near downtown San José to History Park in San José in 1987 (Figure 29).21 Another formally documented tapered tower with overhang tank house is the 1912-era John Krohn Tank House in San Martin. This tank house was documented for the Historic American Building Survey in 1980 but does not appear to have ever been formally designated. It is unclear from current aerial imagery if the tank house remains extant.22 Tank houses, particularly those of the tapered tower with overhang subtype, are an endangered structure type in Santa Clara County. 20 Los Altos History Museum, “Tank House Makeover,” December 20, 2019, accessed online, https://www.losaltoshistory.org/2019/12/tank-house-makeover/. 21 https://www.facebook.com/groups/sanjosevalleyorchards/posts/2638316002962693/ 22 Historic American Building Survey (HABS), “John Krohn Tank House, 13000 Foothill Avenue, San Martin, Santa Clara County, CA,” accessed online, https://www.loc.gov/item/ca0977/.
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Figure 28. Spagnoli Tank House in Los Altos, ca. 2020.
Source: Los Altos History Museum.
Figure 29. Califaro Tank House at History San José,
date unknown. Source: https://www.facebook.com/
Figure 30. John Krohn Tank House in San Martin, 1980.
Source: Historic American Building Survey, CA-2111.
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SITE HISTORY
Site Development
The land containing the Martha Lynn Tank House at 12889 Viscaino Place was originally part of Rancho La Purísima Concepción, a 4,436-acre Mexican land grant issued in 1840 by Governor Juan Bautista Alvarado to José Gorgonio and his son José Ramón, both Ohlone people associated with Mission Santa Clara. In 1844, the rancho was sold to Juana Briones de Miranda, a pioneering ranchera and businesswoman. Briones retained ownership until 1855, when she sold approximately 3,000 acres to Martin Murphy, a prominent early settler and founder of Sunnyvale. Murphy subsequently conveyed a large portion of this tract to his daughter, Elizabeth Yuba (Murphy) Taaffe, and her husband, William Taaffe. The Taaffe family operated the land as part of a large rural estate, measuring approximately 735 acres, which became known as the Taaffe Ranch.23 By 1904, the property was largely subdivided among family members, and the parcel containing the future tank house site was eventually sold out of Taaffe ownership (Figure 31). By 1906, the land was in the possession of a widowed homesteader, Martha Lynn, who constructed the tank house following the San Francisco earthquake with help from volunteers, in particular her neighbor, Harold L. Brubaker. With the exception of the tank house, available archival sources do not clarify what additional buildings were extant, constructed, or otherwise associated with Martha Lynn’s homestead. Within several years (by 1910), Martha and her three sons moved to Palo Alto and the property became part of Dr. Thomas E. Shumate’s approximately 400-acre ranch, where it served agricultural (walnut orchard) and equestrian functions until the estate’s subdivision in 1956 for the creation of the Fremont Hills neighborhood and Country Club (Figure 32 and Figure 33).24 23 Fava, Los Altos Hills: A Colorful History, 91, available online: https://archive.org/details/losaltoshillscol00fava. 24 United States Federal Census, “Palo Alto City,” 1910. Accessed online, www.ancestry.com.
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Figure 31. Map of the Taaffe Partition within Rancho Purisima Concepcion, August 1904. Note the Brubaker and Shumate parcels in the north-central section of the map. Source: Los Altos Hills: A Colorful History.
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Figure 32. Aerial photograph with an arrow indicating the tank house, 1930. The current Fremont Hills Country Club property boundary is outlined in red. Source: Fairchild Aerial Surveys, Flight C-1180, Frame 11, October 1930. Courtesy of UCSB Library Geospatial Collection.
Edited by Page & Turnbull.
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Figure 33. Aerial photograph with an arrow indicating the tank house, May 1953. The current Fremont Hills Country Club property boundary is outlined in red. Source: Google Earth.
Edited by Page & Turnbull.
In 1956, the Fremont Hills Development Company initiated the subdivision of its 400-acre purchase (previously the Shumate Ranch) with plans to include a 15-acre site for a country club with “swimming pool, three or more tennis courts and horseback riding facilities” with membership “open to residents of the 387-acre multimillion-dollar luxury subdivision being developed there as well as to other residents of the area.”25 The Los Altos Hills Planning Commission required riding trails as well as a network of pedestrian pathways through the Fremont Hills subdivision, which contributed to the town’s extensive pathway network. A pool and two riding rings were under construction in 1958 with the equestrian programing utilizing “an existing barn on the site…for boarding horses of members” (Figure 34 and Figure 35).26 More broadly, Shumate’s extant “barns and stable area” were retained for the country club’s use, which also included the extant tank house.27 25 Peninsula Times Tribune, “Country club planned for hills subdivision,” December 19, 1956. 26 Peninsula Times Tribune, “Country club planned for hills subdivision,” December 19, 1956. 27 Peninsula Times Tribune, “Rustic Setting for New Club,” July 16, 1958.
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Figure 34. View of Shumate's stables and orchard land, looking southwest, 1958. The tank house is behind the tree canopy at far left marked with a white arrow. Source: Peninsula Times Tribune.
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Figure 35. New riding ring with tank house at back right, indicated with black arrow, 1958.
Source: Peninsula Times Tribune.
A 10,000 square-foot clubhouse was built by Tanklage Construction Company in 1961 with Palo Altobased landscape architect Thomas Sherlock responsible for the site planning and landscape design elements (Figure 36).
28 Two tennis courts were added by 1963 with additional tennis courts and landscape elements expanded through 1968 (Figure 37 and Figure 38). Despite this surrounding development, the Martha Lynn Tank House and two of Shumate’s stables remain extant.
Figure 36. Rendering of clubhouse, 1960. Source: Peninsula Times Tribune. 28 Peninsula Timbes Tribune, “Sherlock named to design Hills club landscaping,” January 21, 1958.
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Figure 37. Aerial photograph with an arrow indicating the tank house, 1963. The visible portion of the current Fremont Hills Country Club property boundary is outlined in red. Source: Cartwright Aerial Surveys, Flight CASSCL, Frame 15-23, January 1963. Courtesy of UCSB Library Geospatial Collection.
Edited by Page & Turnbull.
TENNIS
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Figure 38. Aerial photograph with an arrow indicating the tank house, 1968. The visible portion of the current Fremont Hills Country Club property boundary is outlined in red. Source: Cartwright Aerial Surveys, Flight CAS2310, Frame 1-37, May 1968. Courtesy of UCSB Library Geospatial Collection.
Edited by Page & Turnbull.
MARTHA LYNN TANK HOUSE CONSTRUCTION CHRONOLOGY
While research did not uncover any permit history specifically for the tank house, existing documentation states that it was constructed in 1906 following the earthquake on the Martha Lynn homestead by volunteer labor, led by neighbor Harold L. Brubaker.29 At some time after the Fremont Hills Country Club acquired the tank house but prior to the tank house being documented by the Historic American Building Survey (HABS) in 1979, the interior at the ground level was outfitted to serve as men’s and women’s restroom facilities (Figure 39). The function of the interior prior to the remodel is unknown, but the base of tank houses were often used for storage or utility rooms. Overall, it appears that otherwise little to no exterior alterations have occurred or that replacement materials have been used since the time of its construction in 1906 (Figure 40 and Figure 41).
29 Town of Los Altos Hills General Plan, Appendix A: Inventory of Historic Sites and Structures (Revision 6/26/2018): 3.
TENNIS
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Figure 39. HABS documentation of the tank house, 1979. Source: Library of Congress.
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Figure 40. “Martha R. Lynn Tower” on the Dr.
Thomas E. Shumate Ranch, date unknown. Source:
Los Altos Hills Historical Scrapbook Digital Archive.
Figure 41. Southwest façade in 2025, showing
minimal changes.
Ownership History
The following table provides a summary of the ownership history of the tank house, beginning with the year of construction, compiled from historic resources, including books, newspaper articles, city directories, and other public records.
TABLE 1. OWNERSHIP HISTORY FOR 12889 VISCAINO PLACE.
Date(s) Owner(s) Occupation
Circa 1906-1910 Martha Lynn Homesteader
1910-1952 Dr. Thomas Shumate Drug store operator
1952-1956 Freda Shumate None documented
1956-1958 Fremont Hills Development
Company Real estate developer
1958-Present Fremont Hills Country Club Recreational facility
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SELECT BIOGRAPHIES
Owner, Martha Lynn (ca. 1906-1910)
Research uncovered little about Martha R. Lynn, the owner of the land during the time of the tank house’s construction. Born in California in 1877, she married Fred Lynn, an electrical engineer from Pennsylvania, in 1898.
30 They had three sons, Leo, Joseph, and Harold, and lived in Alaska and Oakland, California, prior to Fred’s death sometime between 1900 and 1910 and Martha’s move to the Los Altos Hills area. Upon the sale of the land containing the tank house to Dr. Shumate by 1910, Martha moved to 181 Tasso Street in Palo Alto, remaining there until at least 1922. 31 Builder, Harold L. Brubaker (ca. 1906)
Harold “Harry” Lee Brubaker was an orchardist. Originally from Ohio, he resided in Santa Clara County for 55 years with his wife Maggie May (née Bearden) (1876-1971). 32 They married in Maggie’s
hometown of Springfield, Missouri in 1892.33 The Brubakers had three sons, Otto, Ernest, and Lester; a daughter Edith May died in infancy. The family moved to Alameda, California in 1900 and to the Mountain View area by 1908, though prior existing documentation associated with the Martha Lynn Tank House places this relocation prior to 1906.34 At the time of Harold Brubaker’s death, his family lived at 27591 Purissima Avenue, which is approximately a half mile from the Fremont Hills Country Club.
Owner, Dr, Thomas Shumate (1910-1956)
Dr. Thomas Edward Shumate was born on April 1, 1871, in St. Louis, Missouri, and came to California as a boy. He put himself through the University of California's Pharmacy School while working as a night drug clerk and eventually opened his own pharmacy. He received his Medical Degree in 1894 from Cooper Medical School, later known as Stanford Medical School.35 Shumate served as police surgeon in San Francisco from the time of his medical school graduation until 1900. He expanded his “Shumate’s Pharmacy” chain to include 32 locations in San Francisco by 1933. He married Frederica “Freda” (née Ortman) (1874-1958) in 1899 and they had three children, Frederick, Charles Albert (“Al”), and Virginia.36
30 United States Federal Census, “Palo Alto City,” 1900 and 1910. Accessed online, www.ancestry.com. 31 United States Federal Census, “Palo Alto City,” 1910. San Jose City Directory, 1922. Accessed online, www.ancestry.com. 32 Peninsula Times Tribune, “Mr. Brubaker of Altos Hills dies at 93,” February 26, 1960. 33 Missouri Marriage Records, 1891-1895, accessed online, www.ancestry.com. 34 United States Federal Census, 1900, accessed online, www.ancestry.com. 35 Peninsula Times Tribune, “Rites tomorrow for Los Altan, Dr. Shumate,” February 28, 1952. 36 FindAGrave, “Dr. Thomas Edward Shumate,” accessed online, https://www.findagrave.com/memorial/105012808/thomasedward-shumate.
Figure 42. Dr. Thomas Shumate,
1936. Source: Peninsula Times
Tribune, May 29, 1936.
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Around 1910–1912, Dr. Shumate acquired a tract of land at the corner of Fremont and Concepción roads in what is now the Town of Los Altos Hills. He initiated improvements on this property for the purpose of creating a summer estate, beginning with modest structures, including a stable and garage, followed by a gardener’s quarters, and culminating in the construction of a limestone Italianate residence between 1915 and 1916.37 The limestone was repurposed from San Francisco's Indiana Building at the 1915 Panama-Pacific International Exposition, and the house was designed by William S. Merchant, who had previously collaborated with Bernard Maybeck on the Palace of Fine Arts.
38 Located approximately a quarter-mile east of the Fremont Hills Country Club property, the house is addressed 12775 Viscaino Road and was designated Los Altos Hills Landmark in 1994. 39 In San Francisco, Dr. Shumate held numerous prominent roles, serving as police commissioner from 1912 to 1937 as well as director of St. Francis Hospital (until 1950), the Medico-Dental Building, the Old Liberty Bank (later absorbed into Bank of America), and the Philippine Telephone Company. 40 By the time of his death on February 29, 1952, Dr. Shumate had amassed a substantial Los Altos Hills estate totaling approximately 400 acres, which included ranchland and walnut orchards. This land spanned from Fremont and Concepcion Roads to Purissima Road. He also owned the Troy Stock Farm, which spanned another 400 acres on the Mountain View–Alviso Road near Sunnyvale, where he kept American Saddlebred horses.
41 Following Dr. Shumate's death, his widow Freda, along with their surviving children Al and Virginia, managed the estate until its sale in 1956. The property was transformed by the Fremont Hills Development Company into the sites of Fremont Hills Elementary School (acquired by the Palo Alto Unified School District in January 1957), the Fremont Hills Country Club (established in 1958 with clubhouse and pool constructed in 1961), and residential neighborhoods.42 Owner, Fremont Hills Country Club (1958-Present)
The Fremont Hills Country Club was established in 1958 as part of the Fremont Hills subdivision, a residential development carved from the former Shumate Ranch by the Fremont Hills Development 37 The equestrian facilities later became part of the Fremont Hills Riding Academy (now Windy Hill Equestrian), which includes stables, riding rings, and the tank house (as a restroom facility). 38 Los Altos History Committee, “Memo: Requested Maintenance for the Original Shumate Gate at the corner of Concepcion & Viscaino and the Shumate Pillar along Concepcion.” Accessed online, https://www.losaltoshills.ca.gov/DocumentCenter/View/7352/Memo-Regarding-SG-041325-V4. 39 Clyde Noel, “A classic Italian villa,” Los Altos Town Crier October 12, 2021. Accessed online, https://www.losaltosonline.com/archives/a-classic-italian-villa/article_10e61fa8-083b-5ead-a332-083707d6efe7.html. 40 Fava, Los Altos Hills: A Colorful History (1976), 85-86. 41 Fava, Los Altos Hills: A Colorful History (1976), 85. 42 Peninsula Timbes Tribune, “Sherlock named to design Hills club landscaping,” January 21, 1958.
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Company. Conceived as the neighborhood’s social and recreational hub, the club was formed as a non-profit corporation with original members of the board of directors including E.W. Van Buskrik, president; Frank William Courneed, secretary; William D. Coldiron, treasurer; Harry Fitzpatrick; and L.H. Price; the original stable master was Chidley Dunlap.43 The first facilities were constructed between 1958 and 1961, including two riding arenas, a swimming pool, and a clubhouse. The planning of these facilities and their future programing was overseen by an advisory committee, consisting of George T. Hayes, chairman; Mrs. Frederick T. Adams; Rudolph J. Domenie; Mrs. G.W.
Sugden; Dr. Richard S. Wilbur; William H. Williams; and James B. Zischke.44 A 1958 photograph from the Peninsula Times Tribunes shows several committee members in front of the property’s stable (Figure 43). Bob Murphy served as the first club manager.45 Over the next decade, the club expanded its tennis program, adding multiple courts, while maintaining its equestrian center on the southern portion of the property, now known as Windy Hill Equestrian. Today, Fremont Hills Country Club continues to serve both members and the broader Los Altos Hills community with its swim, tennis, and equestrian programs.
Figure 43. "[Fremont Hills Country Club] Social events planned by feminine members, Mrs. Grant Minick, Mrs.
George Hayes, and Mrs. Rudolph Domenie,” 1958. Source: Peninsula Times Tribune 43 Peninsula Times Tribune, “New country club taking shape,” July 16, 1958. 44 Peninsula Times Tribune, “New country club taking shape,” July 16, 1958. 45 Peninsula Times Tribune, “Fremont Hills Country Club Project Rapidly Nearing Completion,” May 5, 1959.
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TOWN OF LOS ALTOS HILLS LANDMARK DESIGNATION
EVALUATION
The Town of Los Altos Hills’ Landmark designation is an inventory of local structures, natural features, sites, and areas that exhibit historical, architectural, cultural, and/or aesthetic significance within city limits. Resources can be listed as a local Landmark through a number of methods. State Historical Landmarks and National Register-listed properties are automatically designated as a Los Altos Hills Landmark. Properties can be nominated as Landmarks by the resolution of the City Council or upon the request of the Los Altos Hills Standing History Committee, the property owner, or an authorized agent of the property to be designated.
In order for a property to be eligible for designation as a Los Altos Hills Landmark, it must be found significant under one or more of the following criteria:
a) Its character, interest, or value as part of the development, and/or its exemplification of the cultural, educational, economic, agricultural, social or historical heritage of the City. b) Its identification with a person, or persons, who significantly contributed to the culture, history, or development of the Town.
c) Its embodiment of distinguishing characteristics or an architectural type of specimen. d) Its unique location or singular physical characteristics, whether manmade or natural, representing an established or familiar visual feature of a neighborhood, community, or the Town of Los Altos Hills, or its relationship to any other landmark if its preservation is essential to the integrity of that landmark.
e) Its potential of yielding archaeological information. f) Any property which is listed on the National Register and is described in Section 470a of Title 16 of the United States Code and/or is a Registered State Landmark.46 The following section examines the eligibility of the Martha Lynn Tank House situated at the Fremont Hills Country Club, addressed at 12889 Viscaino Place, for individual listing as a Town of Los Altos Hills Landmark.
CRITERION A
The Martha Lynn Tank House is eligible under Los Altos Hills Criterion (a) for its association with significant events. The structure possesses character, interest, and value as part of the development of Los Altos Hills and exemplifies the agricultural and equestrian heritage of the Town. Built in 1906 as part of the Martha Lynn homestead and later incorporated into the Shumate Ranch, the structure 46 Los Altos Hills Municipal Code, §11-1.05 Designation criteria. Accessed online, https://ecode360.com/44000651#44000656.
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reflects the region’s reliance on self-sufficient water systems that supported orchard cultivation, livestock, and rural homesteads in the early twentieth century. Its continued presence serves as a tangible link to the area’s pre-incorporation agrarian economy and rural way of life. Therefore, the tank house is eligible under Criterion (a) with a period of significance of 1906, its date of construction to 1956, when the property was sold for the purpose of subdivision. This time period of significance reflects that which the property is most strongly associated with agrarian activities prior to town incorporation.
CRITERION B
The Martha Lynn Tank House is not eligible under Los Altos Hills Criterion (b) for its association with a person or persons. The structure appears to have been constructed when the property was owned by Martha Lynn. Research did not uncover any substantive biographical information about Martha Lynn beyond her identification as the original homesteader and owner of the property at the time the tank house was constructed. The property is better associated with Dr. Thomas E. Shumate, a prominent San Francisco physician, businessman, and civic leader who owned and operated approximately 400 acres of ranchland, including the tank house and several extant stables, from circa 1910 to 1956. Yet, Shumate does not appear to have ever been a full-time resident of his ranch, nor are any of his professional accomplishments directly associated with the tank house. The builder of the tank house, who appears to have been Harold “Harry” Lee Brubaker, was both a neighbor of Marth Lynn and an orchardist, and therefore possibly well-versed in the construction of necessary water tanks for the agrarian purposes. However, research did not uncover that he significantly contributed to the culture, history, or development of the Town.
CRITERION C
The Martha Lynn Tank House is eligible under Los Altos Hills Criterion (c) for its association with architecture. The structure specifically embodies the distinguishing characteristics of the tapered tower with overhang subtype of tank houses that once numbered in the hundreds, if not thousands, throughout the Santa Clara Valley. The subtype appears to have been regionally notable variation of early California tank houses accommodating both the winds and terrain of the valley. Its design and workmanship, consisting of a tapered tower base, overhanging belvedere with wood-panel tank, hipped roof, and wood shingle cladding exemplify the carpentry and functional ingenuity of vernacular water tower and tank house designs of the early 1900s in the area. The Martha Lynn Tank House also continues to express its original materials, although deteriorated, including its wood framing, wood-shingle cladding, wood-panel tank, and wood-frame hipped roof with exposed rafter tails. These character-defining features continue to convey the structure’s architectural typology and significance. Therefore, the tank house is eligible under Los Altos Hills Criterion (c), with a period of significance of 1906, the date of its construction.
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CRITERION D
The Martha Lynn Tank House is eligible under Los Altos Hills Criterion (d) for its association with its unique location and setting. The structure occupies a unique location atop a hill within the Fremont Hills Country Club’s equestrian grounds, making it a prominent and familiar visual feature in the area. Its height, distinctive silhouette, and association with the surrounding open space contribute to its visual status. In combination with nearby historic resources, such as remnants of the Shumate Ranch stables, the Martha Lynn Tank House’s preservation is integral to maintaining the historic character and layered narrative of the Fremont Hills area.
Moreover, the structure has remained situated at its location of original construction since circa 1906. Its longtime and continued presence on the same parcel preserves the direct physical connection to its historic period of use as part of the Lynn homestead and later the Shumate Ranch.
Despite surrounding development, the structure’s feeling is that of a bygone era, as its scale, form, and vernacular character evoke the historic rural setting and functional role of tank houses in early twentieth-century Santa Clara County agriculture. While the Fremont Hills neighborhood has been built up since the mid-twentieth century, the Martha Lynn Tank House remains within an open, equestrian-oriented environment on the Fremont Hills Country Club grounds, reflecting its historical association with Los Altos Hills’ rural and agricultural history and uses. Therefore, the Martha Lynn Tank House is eligible under Criterion (d) with a period of significance of 1906 to 1956, during which time the property is most strongly associated with agrarian activities prior to the Town’s incorporation.
CRITERION E
The Martha Lynn Tank House is not eligible under Los Altos Hills Criterion (e). The “potential of yielding archaeological information” does not relate to above-ground built resources.
CRITERION F (NATIONAL REGISTER/LANDMARK LISTING)
The Martha Lynn Tank House is not eligible under Los Altos Hills Criterion (f). It is not currently listed on the National Register of Historic Places, nor is it listed as a Registered State Landmark.
Character-Defining Features and Non-Contributing Features Since the Martha Lynn Tank House appears to be eligible for listing as a Town of Los Altos Hills Landmark under several criteria for designation, a list of the structure’s character-defining elements or features is helpful. Character-defining features are the physical features that convey why a property is significant and when it was significant. Characteristics can be expressed in terms of form
Landmark Evaluation Report Martha Lynn Tank House
[24391] 12889 Viscaino Place, Los Altos Hills, CA
PAGE & TURNBULL 38 October 30, 2025
(shape), proportion (size), structure, plan, style, materials, craftsmanship, decorative details, spatial relationships, and aspects of its site and environment. Character-defining features in this instance are those that relate to the subject property’s indicated period of significance, 1906 to 1956.
The character-defining features of the Martha Lynn Tank House include, but are not limited to:
• Three-story height comprised of a two-story tapered tower base, narrowing toward the top, and a one-story overhanging belvedere/tank enclosure
• Wood framing with three large beams supporting the overhanging platform • Hipped roof clad in wood shingles with exposed rafter tails • Painted wood-shingle cladding on the tower base
• Flared wood lattice panels between roof support posts on the belvedere • Simple wood railing enclosing the belvedere platform
• Wood-panel water tank contained within the belvedere
• Minimal exterior openings, including one wood-frame divided-lite fixed window with a shallow shed roof clad in wood shingles and a simple sill • Surface-mounted wood ladder for belvedere access
• Wood-board platform floor with access hatch at top of ladder.
Non-contributing features or spaces are those that were constructed after the period of significance (post-1956), have been significantly altered, and/or do not contribute to the overall historic character or historic significance of the building or structure.
The noncontributing features of the Martha Lynn Tank House include, but are not limited to:
• Exterior paint color
• Single wood doors to the interior space(s)
• Electrical and plumbing conduit and fixtures (at exterior and interior) • Interior plan configuration, such as the interior wall that subdivides the interior space into two rooms (currently used as men’s and women’s restrooms) • Interior materials, finishes, and fixtures including bathroom stall components and furnishings (i.e. toilets, sinks, and mirrors).
Landmark Evaluation Report Martha Lynn Tank House
[24391] 12889 Viscaino Place, Los Altos Hills, CA
PAGE & TURNBULL 39 October 30, 2025
CONCLUSION
The Martha Lynn Tank House located on the Fremont Hills Country Club property at 12889 Viscaino Place is a rare surviving example of an early twentieth-century tapered-tower with overhang subtype, a once-common but now scarce form of domestic water infrastructure throughout the Santa Clara Valley and what is defined today as Santa Clara County. Constructed in 1906 on the Martha Lynn homestead and later incorporated into the Shumate Ranch, the structure is directly associated with the region’s early twentieth-century agricultural and equestrian heritage and the development patterns that shaped Los Altos Hills. The tank house continues to convey its historical significance despite the passage of time and the deterioration of some original materials. Its preserved form, materials, and workmanship embody the functional ingenuity of vernacular builders, while its enduring location, setting and hence, presence within an equestrian backdrop reinforces its contextual link to the rural character of the Town. As such, the Martha Lynn Tank House meets the Town of Los Altos Hills’ criteria for Landmark designation under Criteria (a), (c), and (d), with a period of significance of 1906 to 1956. It remains a unique and important physical reminder of the community’s agricultural past.
Landmark Evaluation Report Martha Lynn Tank House
[24391] 12889 Viscaino Place, Los Altos Hills, CA
PAGE & TURNBULL 40 October 30, 2025
REFERENCES
Published Works & Reports
California Office of Historic Preservation. Technical Assistance Bulletin No. 7: How to Nominate a Resource to the California Register of Historical Resources. Sacramento: California Office of State Publishing, September 4, 2001.
California Office of Historic Preservation. Technical Assistance Bulletin No. 8: User’s Guide to the California Historical Resource Status Codes & Historic Resources Inventory Directory. Sacramento:
California Office of State Publishing. November 2004.
Cooper, Thomas. Tankhouse: California’s Redwood Water Towers from a Bygone Era. Santa Rosa, CA:
Barn Owl Press, 2011.
Fava, Florence. Los Altos Hills: A Colorful History (1976).
Los Altos History Committee. “Memo: Requested Maintenance for the Original Shumate Gate at the corner of Concepcion & Viscaino and the Shumate Pillar along Concepcion.” Accessed online, https://www.losaltoshills.ca.gov/DocumentCenter/View/7352/Memo-Regarding-SG-041325- V4.
National Park Service. National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. Washington, D.C.: U.S. Department of the Interior, National Park Service, 1995. “Messina Orchard,” National Register of Historic Places Nomination, listed 2018, available online at:
https://npgallery.nps.gov/NRHP/GetAsset/863aa278-7497-4c2e-a129-2ef775fd7aff. “Miller/Melone Ranch,” National Register of Historic Places Nomination, listed 1993, available online at: https://catalog.archives.gov/id/123861740.
Pitman, Leon S. “Domestic Tankhouses of Rural California,” Pioneer America, Vol. 8, No. 2 (July 1976).
San Jose State University, Sourisseu Academy. “Windmills, Water Towers & Tank Houses of Santa Clara County,” Volume 3 (1975-1977). Accessed online,
https://www.californiarevealed.org/do/d85907c8-1174-41f4-8208-a5885b989cd5.
Landmark Evaluation Report Martha Lynn Tank House
[24391] 12889 Viscaino Place, Los Altos Hills, CA
PAGE & TURNBULL 41 October 30, 2025
Newspapers & Periodicals
Noel, Clyde. “A classic Italian villa,” Los Altos Town Crier October 12, 2021. Accessed online, https://www.losaltosonline.com/archives/a-classic-italian-villa/article_10e61fa8-083b-5eada332-083707d6efe7.html.
Peninsula Times Tribune, “Rites tomorrow for Los Altan, Dr. Shumate,” February 28, 1952. --- “Country club planned for hills subdivision,” December 19, 1956. --- “Sherlock named to design Hills club landscaping,” January 21, 1958.
Public Records
California State Office of Historic Preservation, Built Environment Resource Directory (BERD), Santa Clara County, updated September 2022.
City of San Jose. City Directory, multiple years. Accessed online, www.ancestry.com.
Historic American Building Survey (HABS). “Martha Lynn Tank House” (1979).
Historic American Building Survey (HABS). “John Krohn Tank House, 13000 Foothill Avenue, San Martin, Santa Clara County, CA.” Accessed online, https://www.loc.gov/item/ca0977/.
Town of Los Altos Hills. “General Plan, Appendix A: Inventory of Historic Sites and Structures.” Accessed online, https://www.losaltoshills.ca.gov/DocumentCenter/View/152/General-Plan--- 4a-Conservation-Appendix---Historic-Sites-PDF.
Town of Los Altos Hills Municipal Code. §11-1.05 Designation criteria. Accessed online, https://ecode360.com/44000651#44000656.
United States Federal Census. Multiple years. Accessed online, www.ancestry.com.
Internet Sources
Bowen, Ellen and Lee Anne Wentz. "Tankhouses & Water Towers." Presented by the Historical Society of Santa Rosa, July 20, 2023. https://www.youtube.com/watch?v=thaUBrH_q4s.
California Office of Historic Preservation. “Landmarks by County: Santa Clara.” Accessed online, https://ohp.parks.ca.gov/?page_id=21522.
Landmark Evaluation Report Martha Lynn Tank House
[24391] 12889 Viscaino Place, Los Altos Hills, CA
PAGE & TURNBULL 42 October 30, 2025
FindAGrave. “Dr. Thomas Edward Shumate.” Accessed online, https://www.findagrave.com/memorial/105012808/thomas-edward-shumate.
Los Altos Hills Historical Society. Fifteenth Anniversary Booklet, 1971, https://lahhistory.org/DigitalArchive/FifteenthAnniversaryBooklet.
Los Altos Hills Historical Scrapbook Digital Archive.
Los Altos Hills History Committee. “History of Horses & Pathways: Their Influence on Making Los Altos Hills A Connected Community.” Accessed online, https://vimeo.com/1053555543.
Los Altos History Museum, “Tank House Makeover,” December 20, 2019, accessed online, https://www.losaltoshistory.org/2019/12/tank-house-makeover/.
Town of Los Altos Hills. “Town History.” Accessed online, https://www.losaltoshills.ca.gov/218/TownHistory.
University of California, Santa Barbara Library Geospatial Collection. “FrameFinder,” various dates.
Landmark Evaluation Report Martha Lynn Tank House
[24391] 12889 Viscaino Place, Los Altos Hills, CA
PAGE & TURNBULL 43 October 30, 2025
APPENDICES
Appendix A – Preparer Qualifications
This Preliminary Landmark Evaluation was prepared by Page & Turnbull of San Francisco, California.
Page & Turnbull staff responsible for this report include Christina Dikas, Principal-in-charge; Jen Hembree, Cultural Resources Planner, project manager; and Maggie Nicholson, Cultural Resources Planner, primary author, all of whom meet or exceed the Secretary of the Interior’s Professional Qualification Standards for Historic Architecture, Architectural History, or History.
ITEM 7E ATTACHMENT 3
From:
Sent: Thursday, October 3, 2024 12:20 PM
To: Keren Brunner <[email protected]>
Subject: Referred by Carol Gottleib
Hello!
Carol suggested I email "and ask that be added as supplemental material in care of Keren Brunner."
I am supporting her efforts around the Martha Lynn water tank with FHCC (I am a former member and I ride at Windy Hill Equestrian). Should FHCC move forward with the landmark designation, I'd love to support fund raising efforts.
Cheers,
lisa
ITEM 7E ATTACHMENT 4
1 TOWN OF LOS ALTOS HILLS June 18, 2026
Staff Report to City Council
_____________________________________________________________________________ SUBJECT: WAIVE FIRST READING AND ADOPT INTRODUCTION OF AN ORDINANCE ADDING ARTICLE 17 TO CHAPTER ONE OF TITLE 10 OF
THE LOS ALTOS HILLS MUNICIPAL CODE TO ESTABLISH LOCAL
PROCEDURES FOR ADMINISTERING DENSITY BONUS
APPLICATIONS CONSISTENT WITH CALIFORNIA STATE DENSITY
BONUS LAW AND HOUSING ELEMENT PROGRAM B-3
FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, City Manager
_____________________________________________________________________________ RECOMMENDATION:
Staff recommends that the City Council adopt waive the first reading and introduce the proposed ordinance adding Article 17 to Chapter 1 of Title 10 of the Los Altos Hills Municipal Code to establish local procedures for administering Density Bonus applications consistent with California State Density Bonus Law (Government Code Sections 65915–65918). Adoption of the ordinance will implement Housing Element Program B‑3, ensure consistency with current state housing requirements, and provide procedural clarity for applicants and decision‑makers.
BACKGROUND:
The Town’s adopted 2023–2031 Housing Element includes Program B-3, which requires the Town to update the Municipal Code to implement California State Density Bonus Law. State Density Bonus Law (Government Code Sections 65915 through 65918) requires local jurisdictions to provide density bonuses, concessions, incentives, waivers, and parking reductions for qualifying affordable housing developments and other eligible housing projects.
The proposed ordinance adds Article 17 to Chapter 1 of Title 10 of the Los Altos Hills Municipal Code to establish local procedures for administering Density Bonus applications consistent with State law. The ordinance is intended to implement State Density Bonus Law and ensure the Town’s Municipal Code remains consistent with changes enacted by the Legislature since adoption of the Housing Element.
State Density Bonus Law has undergone significant amendments in recent years. Housing Element Program B-3 specifically identified adoption of a local Density Bonus Ordinance as an implementation measure to codify state requirements, provide procedural clarity to applicants and decision-makers, and maintain consistency with evolving state housing law. While local agencies are required to comply with State Density Bonus Law regardless of whether a local ordinance has ITEM 7F
2 been adopted, jurisdictions are encouraged to establish local procedures to facilitate consistent administration of density bonus requests.
Program B-3 specifically calls for alignment with State Density Bonus Law, including Government Code Section 65915 et seq., and related legislation such as AB 2345, AB 1287, and SB 1227. These laws address different aspects of affordable housing development and provide incentives intended to encourage the inclusion of affordable units in residential projects. The following is a high-level summary of the referenced legislation:
• AB 2345 increased the maximum density bonus available under State Density Bonus Law from 35 percent to 50 percent for qualifying projects that provide specified levels of affordable housing.
• AB 1287 expanded State Density Bonus Law by allowing certain qualifying projects to receive an additional density bonus when additional affordable units are provided, potentially allowing total density bonuses of up to 100 percent of the otherwise permitted base density.
• SB 1227 made technical and procedural amendments to State Density Bonus Law and related housing provisions to improve consistency, administration, and implementation.
These legislative changes reflect the State’s continuing efforts to increase housing production and affordability by providing additional development incentives for projects that include affordable housing units. As a result, local inclusionary housing programs and affordable housing requirements should be evaluated for consistency with current State law and to ensure they do not inadvertently constrain the use of incentives available under State Density Bonus Law.
The proposed ordinance generally incorporates State Density Bonus Law by reference and establishes local procedures addressing application requirements, review procedures, affordability restrictions, density bonus agreements, and implementation of concessions, incentives, waivers, and parking reductions. The ordinance is intended to function as an "evergreen" ordinance that automatically incorporates future changes to State Density Bonus Law without requiring frequent amendments to the Municipal Code.
On June 9, 2026, the Planning Commission conducted a public hearing on the proposed ordinance.
Assistant City Attorney Claire Lai presented an overview of State Density Bonus Law, including eligibility requirements, density bonus calculations, concessions and incentives, waivers of development standards, parking reductions, affordability requirements, and the Town’s proposed implementation procedures.
The Planning Commission discussion focused on several implementation topics, including the distinction between concessions and incentives intended to reduce development costs and waivers intended to remove development standards that physically preclude construction of a qualifying project; the limited discretion available to local agencies when reviewing density bonus requests;
3 the interaction between Density Bonus Law and multifamily zoning regulations; potential application of density bonus provisions to SB 9 and other residential development scenarios; administration and monitoring of affordability restrictions; and the staffing resources that may be necessary to administer affordability agreements over time.
The Planning Commission also discussed the ordinance provision allowing applicants to request a Conditional Use Permit for density bonuses or incentives beyond those required by State law. The Commission generally viewed this provision as a voluntary local option that could provide flexibility for future policy objectives while preserving the Town’s discretion over benefits exceeding State requirements.
Following discussion and public testimony, the Planning Commission adopted a resolution recommending that the City Council adopt the ordinance implementing Housing Element Program B-3 and State Density Bonus Law. The Planning Commission did not recommend substantive modifications to the ordinance and supported forwarding the ordinance to the City Council for consideration.
DISCUSSION:
State Density Bonus Law is one of California’s primary tools for encouraging the production of affordable housing. The law requires local jurisdictions to grant specified density bonuses and related development incentives when applicants provide qualifying affordable housing units or develop other eligible housing types identified by State law. Eligible projects may receive increased residential density, concessions and incentives that reduce development costs, waivers of development standards that would physically preclude construction of a project, and reductions in parking requirements.
Although local agencies are required to comply with State Density Bonus Law regardless of whether a local ordinance exists, adoption of a local ordinance provides several benefits. First, it creates a clear procedural framework for applicants and decision-makers. Second, it consolidates applicable requirements in a single location within the Municipal Code. Third, it establishes local administrative procedures regarding application submittal requirements, affordability agreements, review processes, and monitoring responsibilities. Finally, it helps ensure ongoing consistency between the Municipal Code and State law.
The proposed ordinance has been drafted primarily as an implementation ordinance rather than a policy ordinance. The Town retains limited discretion under State Density Bonus Law. In most circumstances, qualifying applicants are entitled to density bonuses and related benefits established by statute. Local agencies may only deny requested concessions, incentives, or waivers when specific statutory findings can be made, including findings related to public health and safety, historic resources, or violations of State or federal law. As a result, the ordinance largely codifies existing legal obligations rather than establishing new local development standards.
4 The ordinance incorporates State Density Bonus Law through references to the applicable Government Code sections rather than reproducing detailed statutory provisions within the Municipal Code. Staff and the City Attorney's Office recommend this approach because State Density Bonus Law is amended frequently by the Legislature. By referencing State law directly, the ordinance will remain current as statutory requirements evolve, reducing the need for repeated Municipal Code amendments.
The ordinance also establishes procedures for affordability monitoring and enforcement. Projects receiving density bonus benefits must enter into a recorded density bonus agreement and affordability restriction consistent with State law. These agreements establish affordability terms, occupancy requirements, resale or rental restrictions, reporting obligations, and enforcement mechanisms necessary to maintain compliance throughout the affordability period required by State law.
During Planning Commission review, Commissioners expressed interest in the long-term administration of affordability restrictions and noted that future affordable housing projects may require additional monitoring and oversight by Town staff or third-party administrators. While the ordinance establishes the framework necessary to implement State requirements, staff will continue to evaluate the most effective methods for administering affordability programs should qualifying projects be approved in the future.
The ordinance also includes a local Conditional Use Permit process that would allow consideration of density bonuses, incentives, or affordability programs beyond those required by State law. This provision is entirely discretionary and would only apply when an applicant seeks benefits not otherwise mandated by State Density Bonus Law. Staff believes this provision provides flexibility for future affordable housing initiatives while preserving the Town’s authority over any discretionary local incentives.
The proposed ordinance implements Housing Element Program B-3, provides a clear administrative framework for processing density bonus requests, ensures consistency between the Municipal Code and State law, and positions the Town to efficiently administer future density bonus applications. Staff therefore recommends adoption of the ordinance.
The Planning Commission discussed the practical application of concessions, incentives, and waivers under State Density Bonus Law, including the limited ability of local agencies to require project redesigns to avoid waiver requests and the statutory findings required to deny a request.
Commissioners also discussed the distinction between cost-based concessions and incentives versus waivers necessary to avoid physically precluding construction of a qualifying project. While Commissioners raised numerous questions regarding implementation and administration of these provisions, the discussion did not result in proposed amendments to the ordinance. Following deliberation, the Planning Commission adopted a resolution recommending City Council approval of the ordinance as presented and forwarding the ordinance to the City Council for consideration.
5 Additionally, the requirements in Housing Element Program B-3, as reflected in the proposed ordinance, are mandated by state law and cannot be modified. The Town must comply with these provisions regardless of whether a local ordinance is in place. The ordinance also incorporates incentives consistent with Housing Element Programs E-5 and E-11; aside from such incentives, these standards represent the minimum necessary to meet state requirements.
NEXT STEPS:
If the City Council adopts the ordinance, staff will incorporate the new Density Bonus procedures into the Town's development review process and application materials. The ordinance will become part of the Town's implementation of Housing Element Program B-3 and will provide a formal framework for processing Density Bonus applications consistent with State law.
Following adoption, staff will update application forms, administrative procedures, and public information materials as necessary to reflect the new ordinance requirements. Staff will also continue monitoring changes to State Density Bonus Law and related housing legislation to ensure ongoing compliance.
Should the Town receive future Density Bonus applications, staff will implement the affordability agreement, monitoring, and reporting requirements established by the ordinance and evaluate whether additional administrative resources or third-party monitoring services may be appropriate as affordable housing units are developed and occupied.
Adoption of the ordinance will complete Housing Element Program B-3 and further align the Town's Municipal Code with current State housing law requirements.
ENVIRONMENTAL REVIEW:
The adoption of the proposed ordinance is exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3), the “common sense” exemption, because the ordinance establishes administrative procedures for processing Density Bonus applications and does not, in itself, authorize or approve any specific development project that could result in a physical change to the environment. Any future housing development requesting a density bonus will undergo project‑specific environmental review at the time an application is submitted, as required by CEQA. Additionally, the ordinance implements State Density Bonus Law, the requirements of which are mandated by statute, and therefore the adoption of local procedures to align with state law does not result in new environmental impacts.
FISCAL IMPACT:
Adoption of the ordinance is not expected to result in a significant fiscal impact to the Town. The proposed amendments primarily establish procedural clarity for administering Density Bonus applications in alignment with existing State requirements. Costs associated with reviewing
6 Density Bonus requests and processing qualifying housing applications will be covered through existing planning application fees. Any future increase in staff time associated with Density Bonus processing is anticipated to be minimal and can be accommodated within the Community Development Department’s current budget. No additional staffing or resources are required to implement the ordinance.
ATTACHMENTS:
1. Ordinance
2. May 7th, 2026, Planning Commission Meeting Item 4.2 Staff Report
Ordinance No. _____ Page 1 of 10
ORDINANCE NO. XXX
AN ORDINANCE OF THE TOWN OF LOS ALTOS HILLS AMENDING TITLE 10 (ZONING AND SITE DEVELOPMENT) OF THE LOS ALTOS HILLS MUNICIPAL
CODE TO ADOPT A DENSITY BONUS ORDINANCE IMPLEMENTING STATE LAW CONSISTENT WITH HOUSING ELEMENT PROGRAM B-3
WHEREAS, California Housing Element Law (Gov. Code §65580 et seq.) requires housing elements to assess housing needs, identify inventory of resources, and analyze potential constraints relevant to meeting a jurisdiction’s Regional Housing Need Allocation (RHNA) obligation and for preserving, improving, and developing housing. This includes an analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, and inclusion of goals, programs and policies to promote and incentivize housing opportunities; and
WHEREAS, Government Code sections 65915 – 65918 (“State Density Bonus Law”) allows housing development applicants to seek density bonuses for housing developments or land donations within a local jurisdiction by setting aside project units as affordable housing; and WHEREAS, State Density Bonus Law requires cities to adopt an ordinance to specify how compliance with the statutory density bonus requirements will be implemented; and WHEREAS, the adopted and state-certified 2023-2031 Housing Element (“Housing Element”) of the Town of Los Altos Hills (“Town”) contains numerous goals, policies and programs to meet its RHNA obligations, including an inventory of sites in the Town suitable to accommodate housing units at various income levels under RHNA, programs to rezone such sites to multi-family zoning districts to accommodate RHNA units and to ensure that parcels would be developed at appropriate minimum densities, and to streamline residential development projects and promote housing opportunities and mobility; and
WHEREAS, Policy 2.6 under Goal 2 of the Housing Element provides for incentivizing development of affordable housing through density bonuses. Program B-3 of the Housing Element provides for the Town to amend its Zoning Ordinance to update density bonus regulations to meet updated state Density Bonus Law requirements, including amendments introduced by Assembly Bill (AB) 2345, Senate Bill (SB) 1763, and SB 1227; and WHEREAS, the Town has prepared this Ordinance amending Title 10 of the Los Altos Hills Municipal Code to adopt a Density Bonus Ordinance that implements State Density Bonus Law (the “Ordinance”), consistent with the Housing Element and State Density Bonus Law; and WHEREAS, under the California Environmental Quality Act (“CEQA”), CEQA only applies to projects which have the potential for causing a significant effect on the environment.
CEQA Guidelines section 15061(b)(3) provides that CEQA does not apply to activities that would not have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA; and
WHEREAS, on _________, 2026, the Los Altos Hills Planning Commission held a public hearing to consider a recommendation to the Los Altos Hills City Council regarding the proposed ITEM 7F ATTACHMENT 1
Ordinance No. _____ Page 2 of 10
Ordinance. At the public hearing, the Planning Commission reviewed and carefully considered all testimony, comments, and evidence presented in the record and during the hearing; and WHEREAS, at its _________, 2026, meeting, the Planning Commission by Resolution XXXX recommended the City Council adopt the Ordinance; and WHEREAS, on __________, 2026, the Los Altos Hills City Council held a public hearing to consider proposed Ordinance and the Planning Commission recommendation. At the public hearing, the City Council reviewed and carefully considered the proposed Ordinance, and all related testimony and evidence presented in the record and during the hearing. All interested parties were provided with an opportunity to participate and be heard.
NOW, THEREFORE, the City Council of the Town of Los Altos Hills does hereby ordain as follows:
SECTION I. FINDINGS.
Based on the entirety of the record before it, which includes, without limitation, the California Environmental Quality Act, Public Resources Code §21000, et seq. and the CEQA Guidelines, 14 California Code of Regulations §15000, et seq. (collectively, “CEQA”); the Los Altos Hills General Plan and Housing Element; the Los Altos Hills Municipal Code; all reports, minutes, and public testimony submitted as part of the Planning Commission’s __________, 2026 public hearing and the City Council’s __________, 2026 public hearing, and any and all other evidence (within the meaning of Public Resources Code §21080(e) and §21082.2), the City Council of the Town of Los Altos Hills hereby finds as follows:
1. All recitals above are true, correct, incorporated herein and made a part hereof.
2. The documents and other material constituting the record for these proceedings are located at the Community Development Department for the Town of Los Altos Hills, 26379 Fremont Road, Los Altos Hills, and in the custody of the Community Development Director.
3. This Ordinance is exempt from CEQA pursuant CEQA Guidelines section 15061(b)(3) as CEQA only applies to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA. This Ordinance establishes a procedure for implementing State Density Bonus Law as required by statute and the Housing Element. However, it does not approve any projects, grant any entitlements, or make physical changes to the environment. As such, this Ordinance is a regulatory act taken by the Town and does not physically change the environment. Therefore, it is exempt from CEQA as it does not have the potential for causing a significant effect on the environment.
4. This Ordinance was prepared and adopted in accordance with the Planning and Zoning Law (Government Code, sections 65853-65860) and meets all of the requirements thereunder.
5. This Ordinance is consistent with and supports the General Plan by implementing housing goals, programs and strategies in the Housing Element, including but not limited to Program B-3. This Ordinance is consistent with Program B-3, and supports the Town’s goals, policies and programsto incentivize housing, promote affordability, and reduce potential constraints.
It also allows the Town to comply with relevant state housing laws.
Ordinance No. _____ Page 3 of 10
SECTION II. AMENDMENT.
1. Amendments to Article 2 “Definitions” of Chapter 1 “Zoning” of Title 10 “Zoning and Site Development” of the Municipal Code.
The following definitions are hereby added to Article 2 “Definitions” of Chapter 1 “Zoning” of Title 10 “Zoning and Site Development” of the Municipal Code and shall be incorporated in alphabetical order to existing definitions. Other definitions under Article 2 are not amended and shall continue in full force and effect.
Density Bonus
An increase over the otherwise maximum allowable residential density under the Town’s Zoning Ordinance, any applicable specific plan as may be adopted by the City Council, or the Land Use Element of the General Plan, as in effect on the date the application is submitted to the Town, as defined in Government Code Section 65915(g). "Density bonus" includes both a density bonus and any additional density bonus as provided in the State Density Bonus Law.
Density Bonus Housing Agreement
A legally binding agreement between the developer of a housing development and the Town that ensures the requirements of the State Density Bonus Law and the Density Bonus Ordinance are satisfied.
State Density Bonus Law
Sections 65915 through 65918 of the California Government Code, or successor provisions, as such law may change from time to time.
Non-Restricted Unit
Any dwelling unit within a housing development excluding restricted units.
Restricted Unit
A dwelling unit that will be offered for rent or sale exclusively to and which shall be affordable to the designated income group or qualified resident, as required by Article 10 of Part III of Chapter 2 of this title and the State Density Bonus Law.
2. Additions to Title 10 “Zoning and Site Development” of the Municipal Code.
A new Article 17, “Density Bonus Ordinance” is hereby added to Title 10 of the Municipal Code to read as follows. Other chapters, articles, sections, subsections, paragraphs and texts in Title 10 are not amended and shall continue in full force and effect.
ARTICLE 17
DENSITY BONUS ORDINANCE
§ 10-1.1701 Purpose and Intent
§ 10-1.1702 Density Bonus Entitlement and Incentives
§ 10-1.1703 Waiver and Reduction of Development Standards § 10-1.1704 Density Bonus for Child Care Facilities
§ 10-1.1705 Revised Parking Standards
§ 10-1.1706 Affordability Requirements
§ 10-1.1707 Development Standards and Limitations
§ 10-1.1708 Density Bonus Application Procedure
Ordinance No. _____ Page 4 of 10
§ 10-1.1709 Town Review of Density Bonus Application
§ 10-1.1710 Density Bonus Housing Agreement
§ 10-1.1711 Restricted Units Occupancy and Management
§ 10-1.1712 Severability
§ 10-1.1701 Purpose and Intent; Title.
The purpose of this article is to provide incentives for the production of housing for extremely low income, very low income, low income, and moderate income households, senior citizens, transitional foster youth, disabled veterans, homeless persons, and low income college students, in accordance with Government Code Sections 65915 through 65918 (State Density Bonus Law). In enacting this article, the Town’s intent is to facilitate the development of affordable housing and to implement the goals, policies, and actions of the Housing Element of the Town’s General Plan.
This article shall be known and cited as the "Density Bonus Ordinance of the Town of Los Altos Hills" or "Density Bonus Ordinance."
§ 10-1.1702 Density Bonus Entitlement and Incentives.
(a) The Town shall grant a density bonus and one or more incentives or concessions to any housing development consisting of five (5) or more dwelling units, as and to the extent required pursuant to Section 65915 of the State Density Bonus Law.
(b) The Town shall grant a density bonus or other incentives of equivalent financial value to applicants for approval to convert apartments to a condominium project, as and to the extent required pursuant to Section 65915.5 of the State Density Bonus Law. (c) With the exception of the additional density bonuses for a land donation, child care facility and qualifying affordable housing projects, as provided in this article or under the State Density Bonus Law, each housing development shall be entitled to only one (1) density bonus. (d) Any dwelling unit that would otherwise qualify and required to be maintained as a restricted unit pursuant to the Town’s Inclusionary Housing Ordinance shall also be considered a restricted unit for purposes of determining whether the housing development qualifies for a density bonus. (e) Any density bonus or incentive or concession awarded pursuant to this article shall generally apply only to the particular housing development for which the density bonus or incentive or concession is awarded. A density bonus or incentive or concession may be transferred, credited, or applied to a different housing development only if the Town and the developer agree pursuant to an approved density bonus housing agreement.
(f) The approval of a density bonus shall not, in and of itself, preclude a housing development from receiving other government subsidies for affordable housing. (g) The approval of a density bonus, incentive or concession, development standard waiver or modification, or parking modification as provided herein, shall not be interpreted, in and of itself, to require a general plan amendment, zoning change, or other discretionary approval. (h) Bonuses above or below those available under state law. i. A developer may seek approval of a conditional use permit for additional bonus units that exceed the maximum density bonus available under the State Density Bonus Law, subject to approval by the Town pursuant to Article 10, Chapter 1 of this title. If the
Ordinance No. _____ Page 5 of 10
Town grants and the developer accepts such additional bonus units, the additional bonus units shall be considered an incentive or concession. ii. If a developer agrees to construct a housing development that will contain less than the percentage of affordable units required to qualify for a density bonus pursuant to the State Density Bonus Law, the developer may seek approval of a conditional use permit for a density bonus that is proportionally lower than the minimum density bonus specified in the State Density Bonus Law, subject to approval by the Town pursuant to Article 10, Chapter 1 of this title.’
iii. If the Town grants and the developer accepts such additional bonus units pursuant to (i) or (ii) above, the additional bonus units shall be considered an incentive or concession.
§ 10-1.1703 Waiver and Reduction of Development Standards.
A developer may seek a waiver or reduction of development standards that will have the effect of physically precluding the construction of a housing development that qualifies for a density bonus at the densities or with the incentives or concessions permitted by this article, as and to the extent required pursuant to Section 65915 of the State Density Bonus Law. The developer must make such request in writing. If the Town determines that the requested waiver or reduction does not meet the criteria under Section 65915 of the State Density Bonus Law, and upon the request of a developer, the Town shall meet with the developer to discuss such deficiencies and compliance with said criteria in a requested waiver or reduction of Town development standards.
Notwithstanding the foregoing, the Town shall not be required to approve any request for a waiver or modification of development standards as permitted by Section 65915 of the State Density Bonus Law. § 10-1.1704 Density Bonus for Child Care Facilities.
When a developer proposes to construct a housing development that qualifies for a density bonus under Section 10-1.1702 and the qualifying housing development includes a child care facility that will be located on the premises of, as part of, or immediately adjacent to, the housing development, and the housing development otherwise meets the requirements under subdivisions (b) and (h) of Section 65915 of the State Density Bonus Law, the Town shall grant an additional density bonus and concession or incentive as provided under subdivision (h) of Section 65915 of the State Density Bonus Law and subject to the requirements therein.
§ 10-1.1705 Revised Parking Standards.
Upon the written request of the developer of a housing development that qualifies for a density bonus under Section 10-1.1702, the Town shall permit vehicle parking ratios, inclusive of handicapped and guest parking, which do not exceed the parking ratios established pursuant to Section 65915(p) of the State Density Bonus Law.
§ 10-1.1706 Affordability Requirements.
All restricted units shall remain affordable in accordance with the requirements of, and for the minimum period required by, the State Density Bonus Law. The required affordability time limit for
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each restricted unit shall commence upon the issuance of a certificate of occupancy for such restricted unit. The owner of rental restricted units shall provide all notices and rights to tenants required to be given prior to and upon the expiration of affordability covenants pursuant to Government Code Section 65863.10 or successor statutes.
§ 10-1.1707 Development Standards and Limitations.
(a) All housing developments subject to this article must satisfy all of the requirements of this article, notwithstanding the housing development's satisfaction of other program requirements, laws or regulations, including but not limited to the Town’s Inclusionary Housing Ordinance.
Those restricted units provided under this article which meet all of the requirements for inclusionary units in the Town’s Inclusionary Housing Ordinance shall also qualify as inclusionary units for purposes of that ordinance.
(b) Restricted units shall be constructed concurrently with non-restricted units as specified in the density bonus housing agreement, unless the Town and the developer otherwise agree pursuant to a schedule included in the density bonus housing agreement. (c) Unless the Town and developer otherwise agree pursuant to a density bonus housing agreement, restricted units:
i. Shall be built on site;
ii. Shall not be located in only one (1) portion of the housing development or be situated within only one (1) building of a housing development that contains multiple buildings; and
iii. Shall be of the same size and interior finishes and features as the nonrestricted units. (d) Residents of restricted units shall be entitled to use all of the same amenities within the housing development. The number of bedrooms of the restricted units shall be proportional to the number of bedrooms in the non-restricted units of the housing development. The exterior appearance of the restricted units shall be of the same design and appearance as the overall housing development by having the same building form (proportion of width to length and plate height with a variation of up to twenty-five percent (25%)), exterior construction materials, roof form, siding and trim, and window placement and type. Housing developments shall comply with all applicable development standards, except those that may be modified as provided by this article. In addition, all units in housing developments subject to this article must comply with all applicable California Building Standards Codes incorporated and as may be amended under Title 8 of this code, including but not limited to residential and fire code requirements. (e) Density bonus units may be located in geographic areas of the development site other than the areas where the restricted units are located, and shall be located only on parcels for which the density bonus was granted except as permitted pursuant to Section 10-1.1702. (f) No building permit shall be issued, nor any development approval granted, for any improvements within a housing development subject to this article which do not meet the requirements of this article. No restricted unit shall be rented or sold except in accordance with this article.
(g) The entry into and execution of a density bonus housing agreement shall be a condition of any application for a discretionary land use permit, including but not limited to subdivision maps, site plans, and conditional use permits, for a housing development proposed under this article.
Ordinance No. _____ Page 7 of 10
§ 10-1.1708 Density Bonus Application Procedure.
(a) An application for a density bonus, incentive, concession, waiver, modification, or revised parking standard pursuant to the density bonus ordinance shall, to the extent possible, be submitted with the first application for approval of a housing development, including a preliminary application submitted pursuant to Government Code Section 65941.1, and processed concurrently with all other applications required for the housing development. If any requested incentive, concession, waiver, modification, or revised parking standard requires a separate land use application, including but not limited to a variance or conditional use permit, the separate land use application shall, to the extent possible, be submitted with the housing development application for concurrent processing.
(b) The Community Development Director or his or her designee shall prepare and maintain a list of supplemental application materials for density bonus, incentive, concession, waiver, modification, or revised parking standard requests under this article, which materials shall be submitted together with and as part of the project application. (c) The application shall be submitted on a form prescribed by the Town and shall include at least the following information:
i. Site plan showing total number of dwelling units, including the number and location of non-restricted units, the number and location of restricted units, and the number and location of proposed density bonus units.
ii. Level of affordability of restricted units and plans for ensuring affordability. iii. Description of any requested incentive, concession, waiver or modifications of development standards, or modified parking standards. For any incentive and concession, the application shall include evidence that the requested incentive and concession results in identifiable and actual cost reductions. For waivers or modifications of development standards, the application shall show that the development standards will have the effect of physically precluding the construction of a housing development that qualifies for a density bonus at the densities or with the incentives or concessions permitted by this density bonus ordinance. iv. If a density bonus is requested for a donation of land, the application shall show the location of the land to be dedicated and provide evidence that all of the conditions required by Section 65915 of the State Density Bonus Law for donations of land are satisfied.
v. If a density bonus or incentive or concession is requested for a childcare facility, the application shall show the location and square footage of the childcare facility and provide evidence that each finding included in Section 10-1.1704 can be made. § 10-1.1709 Town Review of Density Bonus Application.
(a) Upon submittal of an application for a density bonus, incentive, concession, waiver, modification, or revised parking standard, the Community Development Director or his or her designee shall determine if the application is complete and conforms to the provisions of this article.
(b) An application for a density bonus, incentive, concession, waiver, modification, or revised parking standard pursuant to the density bonus ordinance shall be considered by and acted upon by the approval body with authority to approve the housing development. Any decision
Ordinance No. _____ Page 8 of 10
regarding a density bonus, incentive, concession, waiver, modification, or revised parking standard may be appealed to the Planning Commission and from the Planning Commission to the City Council.
(c) Public hearings shall be held pursuant to Section 10-1.1005 for any density bonus, incentive, concession, waiver, modification, or revised parking standard applied for under the provisions of this density bonus ordinance. Density bonuses and related incentives, concessions, reductions and waivers shall be approved by the highest approval body required to review and approve the requested application. Other reviewing bodies in advisory roles may provide comments and recommendations to the approving body.
§ 10-1.1710 Density Bonus Housing Agreement.
(a) Any developer receiving a density bonus, incentives and concessions, waivers or modifications of development standards, or reduced parking requirements pursuant to this article shall agree to enter into a density bonus housing agreement with the Town to ensure compliance with this article and the State Density Bonus Law, including that restricted units remain restricted and affordable in accordance with State Density Bonus Law requirements. The density bonus housing agreement shall be submitted to the Town by the developer, shall be made a condition of the discretionary planning permits for all housing developments pursuant to this article, and shall be recorded as a deed restriction on any parcels on which the restricted units will be constructed. Where an inclusionary housing agreement is required pursuant to the Town’s Inclusionary Housing Ordinance, both the density bonus housing agreement and inclusionary housing agreement shall, if feasible, be combined into a single agreement. (b) The density bonus housing agreement shall be recorded prior to the approval of any parcel map or final map or, where the housing development does not include a map, prior to issuance of a building permit for any structure in the housing development. The density bonus housing agreement shall run with the land and be binding upon all future owners and successors in interest.
(c) The density bonus housing agreement shall include, but not be limited to, the following terms:
i. The total number of units including restricted units approved for the housing development, the number of density bonus units granted, and the number, type, location, unit size (square footage), number of bedrooms, tenure of restrictions and affordability, and level of affordability of restricted units. ii. Standards for determining affordable rent or affordable ownership cost for the restricted units.
iii. A schedule for completion and occupancy of restricted units in relation to construction of non-restricted units.
iv. A description of any incentive, concession, waiver, modification, or revised parking standard being provided by the Town.
v. Provisions to ensure affordability of the restricted units, including but not limited to, and where applicable, tenure and conditions governing the initial sale of for-sale restricted units.
vi. Where applicable, tenure and conditions establishing rules and procedures for
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qualifying tenants and prospective purchasers, setting rental rates, filling vacancies, and operating and maintaining units for rental restricted units. vii. A description of remedies for breach of the agreement by either party. The Town may identify tenants or qualified purchasers as third-party beneficiaries under the agreement.
viii. Other provisions to ensure implementation and compliance with this article and the State Density Bonus Law.
§ 10-1.1711 Restricted Units Occupancy and Management.
(a) Density Bonus Resale Agreement. All buyers of for-sale restricted units shall enter into a density bonus resale agreement with the Town prior to purchasing the unit or property. The resale agreement shall be consistent with the density bonus housing agreement. (b) Eligibility Requirements. Only households meeting eligibility standards for the restricted units as set forth in the density bonus housing agreement shall be eligible to occupy restricted units. (c) Management and Monitoring. Rental restricted units shall be managed and operated by the owner or his or her agent. Each owner of rental restricted units shall submit an annual report to the Town in the form prescribed by the Town, identifying which units are restricted units, the monthly rent, vacancy information for each rental target dwelling unit for the prior year, monthly income for tenants of each rental target dwelling unit, and other information as required by the Town, while ensuring the privacy of the tenant.
§ 10-1.1712 Severability.
If any provision of this article or the application thereof to any person or circumstances is held invalid, the remainder of the article and the application of the provision to other persons not similarly situated or to other circumstances shall not be affected thereby. In the event of any conflict between this article and the State Density Bonus Law, the State Density Bonus Law shall prevail.
SECTION III. SEVERABILITY.
If any provision of this Ordinance or the application thereof to any person or circumstance is held invalid or unconstitutional the remainder of this Ordinance, including the application of such part or provision to other persons or circumstances shall not be affected thereby and shall continue in full force and effect. To this end, provisions of this Ordinance are severable. The City Council of the Town of Los Altos Hills hereby declares that it would have passed each section, subsection, subdivision, paragraph, sentence, clause, or phrase hereof irrespective of the fact that any one or more sections, subsections, subdivisions, paragraphs, sentences, clauses, or phrases be held unconstitutional, invalid, or unenforceable.
SECTION IV. EFFECTIVE DATE AND PUBLICATION.
Pursuant to the provisions of Government Code Section 36933, a summary of this Ordinance shall be prepared by the City Attorney. At least five (5) days prior to the Council meeting at which this Ordinance is scheduled to be adopted, the City Clerk shall (1) publish the Summary, and (2) post in the City Clerk’s Office a certified copy of this Ordinance. Within fifteen (15) days after the adoption of this Ordinance, the City Clerk shall (1) publish the summary, and (2) post in the City
Ordinance No. _____ Page 10 of 10
Clerk’s Office a certified copy of the full text of this Ordinance along with the names of those City Council members voting for and against this Ordinance or otherwise voting. This Ordinance shall become effective thirty (30) days from and after its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSTENTIONS:
ABSENT:
ATTEST:
BY:
Mayor
City Clerk
APPROVED AS TO FORM:
City Attorney
TOWN OF LOS ALTOS HILLS May 7, 2026
Staff Report to the Planning Commission
SUBJECT: Consideration of Recommendation on an Ordinance Adding Article 17 to Chapter 1 (Zoning) of Title 10 (Zoning and Site Development) of the Los Altos Hills Municipal Code to Implement State Density Bonus Law pursuant to Housing Element Program B-3.
FROM: Tim McBirney, Community Development Analyst
APPROVED: Jay Bradford, Community Development Director
RECOMMENDATION:
Review and adopt a resolution making a recommendation to the City Council on the proposed Ordinance (Attachment 1) making amendments to Title 10, Chapter 1 to adopt a density bonus ordinance implementing state law pursuant to Housing Element Program B-3.
BACKGROUND
The Town’s adopted Housing Element includes Program B-3, which requires implementation of density bonus regulations to align with recent changes in State Density Bonus Law (California Government Code §65915). These updates reflect legislation including AB 2345, SB 1763, and SB 1227, which expand incentives for affordable housing development and limit local discretion.
California’s Density Bonus Law is a state mandate that local jurisdictions must implement. It requires cities and towns to grant density bonuses and other incentives to qualifying housing developments that include affordable units.
Program B-3 provides for the Density Bonus Ordinance to be adopted by the 1st Quarter of 2026.
Staff has prepared the attached Ordinance adding Article 17 to the Zoning to implement state density bonus rules. The proposed Ordinance entirely tracks state law, with one exception where it provides for the potential for developers to seek a density bonus that is either more than the state law maximum or less than the state law minimum. This set of density bonus would be subject to approval of a conditional use permit by the Town because they are different from state law requirements. This additional bonus structure preserves Town discretion and also potentially provides for some opportunities for additional incentives for lower-income households, including extremely low-income households, consistent with Housing Element Programs E-5 and E-11.
STATE DENSITY BONUS LAW
A density bonus allows a developer to build more housing units than otherwise permitted by zoning in exchange for providing affordable housing. This allowance gives developers a percentage ITEM 7F ATTACHMENT 2
increase in allowable density above the base zoning in exchange for a portion of units being restricted as affordable (very low, low, or moderate income). This law creates incentivization for developments across the affordability spectrum when they may not otherwise be feasible with local market conditions. Consistent with this legislative intent, the Density Bonus statute provides that it “shall be interpreted liberally in favor of producing the maximum number of total housing units.” There are two important aspects of State Density Bonus Law: the ability for applicants to obtain additional density above zoning requirements, and the ability for applicants to receive reductions and waivers in local development and design standards. Cities have very limited discretion in reviewing these density bonus and waiver/reduction requests and generally must approve them.
The following sections provide a summary of these two aspects of the law.
Basics of Density Bonus Under State Law
State Density Bonus Law is set forth under Government Code section 65915 – 65918, with the most commonly utilized provision under Section 65915. This statute requires general law and charter cities to grant a density bonus and other incentives, concessions or waivers to projects setting aside certain percentages of affordable units to low, lower or moderate income households defined by the Health and Safety Code. This requirement extends to housing for transitional foster youth, disabled veterans, homeless persons, or low income college students.1 To qualify for density bonus through affordable units, the project must set aside a certain percentage of its “total units” as affordable to households at various income levels. Density Bonus Law specifies that “total units” includes all units designated as affordable to satisfy local inclusionary requirements.2
To qualify with affordable units, the project must offer for-sale or rental units to lower-income or very-low-income households, or for sale units to moderate-income households. The density bonus is then generally determined by a sliding scale proportional to the percentage of affordable units offered. Projects may also become eligible for density bonus through pathways other than offering affordable units, such as donating land to the city3 or proposing a senior housing or senior mobile home park project, including residential care facilities for the elderly.4 How is the applicable “density bonus” available under state law? The applicable “density bonus” is the additional units that the city must allow over the “base density”, or the “maximum allowable residential density”. This term is defined as the greatest number of units allowed under the zoning ordinance, specific plan, or land use element of the general plan, whichever is highest.5
1 Gov. Code section 65915(b)(1)(A)-(G).
2 Gov. Code section 65915(o)(9). See also Latinos Unidos del Valle de Napa y Solano v. County of Napa (“LUNA”) (2013) 217 CA4th 1160.
3 Gov. Code section 65915(g).
4 Gov. Code section 65915(b)(1)(C), (f)(3)(A).
5 Gov. Code section 65915(o)(6).
If there is no base density, then the maximum number of units allowed would be determined by estimating the realistic development capacity of the site based on the objective development standards applicable to the project. The developer may provide a base density study to the city for this purpose, and the city must accept the study as long as it includes all applicable objective development standards.6
All fractional numbers (in calculating the number of resulting bonus units, parking requirements, etc.) are rounded up for calculations pursuant to Gov. Code section 65915(q).
Incentives/Concessions and Waivers
A project that is eligible for Density Bonus Law (regardless of whether it seeks to build the additional units) is entitled to receive incentives/concession, development standard waivers, and parking reductions. The city cannot require a project to obtain legislative amendments (zoning amendment, general plan amendment) just because the project requests/is entitled to one or more of these reductions. Likewise, the city cannot require the project to be modified in order to eliminate the need for any of the reductions outlined above. • Incentives/Concessions. Incentives/concessions are reductions or elimination of standards that would lead to cost reductions for the density bonus project. Specifically, incentives and concessions are defined as (1) a reduction in site development standards or a modification of zoning code or architectural design requirements, such as a reduction in setback or minimum square footage requirements; (2) approval of mixed use zoning; or (3) other regulatory incentives or concessions, which actually result in identifiable and actual cost reductions. The specific number of incentive/concessions is determined based on the percentage of affordable units provided and the level of affordability.
Cities have limited discretion to deny concession and incentives requests. Specifically, the city must grant the request unless it finds that the proposed concession or incentive does not result in identifiable and actual cost reductions to provide for affordable housing costs or rents, would cause a “specific, adverse impact” on public health or safety or historical property, or would be contrary to state or federal law. These are high thresholds to meet, and the city cannot require developers to provide financial proformas or to demonstrate that the incentive or concession is necessary to make the project financially feasible. 7 • Waivers. These are eliminations of local standards that would physically preclude construction of the density bonus project. Specifically, cities are not permitted to apply any development standard which physically precludes the construction of the project at its permitted density and with the granted concessions/incentives. 8 Similar to the denial thresholds for concession and incentive requests, the city may only deny a waiver request if it finds that waiving the development standard at issue would cause a specific, adverse impact on public health or safety, or historical property, or would be contrary to state or federal law.9 Again, as noted above, this is a high threshold to meet. 6 Gov. Code section 65915(o)(6)(A).
7 Schreiber v. City of Los Angeles (2021) 69 Cal.App.5th 549. Cities can require reasonable documentation from the developer to support the concession/incentives request on a general level. 8 Gov. Code section 65915(e).
9 Id.
Waivers are in addition to the numbers of incentives/concession that a project may receive, and there is no limit on how many development standards a project may waive.10 Common examples of waivable development standards include setbacks, height, lot coverage, common open space, and external façade design requirements. • Parking Reductions. Separately from incentives/concessions and waivers, density bonus projects receive specific parking reductions. Under current law, these ratios are: 1 space for 0-1 bedroom, 1.5 spaces for 2-3 bedrooms, 2.5 for 4 or more bedrooms. Where parking is required, the developer may provide tandem or uncovered parking onsite, but not onstreet parking.11 Recent Legislative Changes to Density Bonus Law
Every legislative session since 2017 has seen some amendments to the State Density Bonus statute.
A few notable changes starting from 2023 are listed below. These include bills specifically identified in the Housing Element under Program B-3 to be incorporated. • AB 2345: Increases the maximum density bonus to 50 percent for projects with 15 percent very-low-income units, 24 percent low-income units, or 44 percent moderate-income units.
Reduces parking ratio for two- and three-bedroom units to 1.5 spaces per unit. Reduces the minimum affordability required to qualify for two or three incentives. Adds incentives for senior housing projects.
• SB 1763: Provides development incentives to encourage 100 percent affordable housing projects. This includes an 80 percent density bonus, height increases of up to three additional stories or 33 feet, and elimination of parking requirements. • SB 1227: adds bonus for eligible student housing developments in which at least 20 percent of units, or rental beds, are restricted to lower-income students for 55 years. • AB 323: Requires for-sale units that qualify a project for a density bonus to be sold to qualifying households and subject to an equity sharing agreement or sold to a qualified non-profit organization.
• SB 713: Specifies that a standard enacted by voter initiative (example: height limits) is subject to the same provisions for waivers or reductions as other development standards. • AB 1287: Specifies that where the zoning ordinance or general plan allows a density range, the “maximum allowable residential density” shall be the top of this range. Grants an additional “Stacking” density bonus for projects providing the maximum amount of very low-income, low-income or moderate-income units.
10 Id.
11 Gov. Code section 65915(p)4).
Consequences of Violating State Density Bonus Law
Density Bonus Law provides developers the ability to initiate litigation against a city if they refuse to grant a requested incentive, concession or waiver.12 If a court determines that the city’s refusal is in violation of Density Bonus Law, it is required to award attorney’s fees and cost of suit to the developer.13 Relatedly, denying a density bonus project in violation of the statute likely also triggers a violation of the Housing Accountability Act; that law also gives a broader cause of action for applicants, individuals eligible for residency in the project, and housing advocate organizations to initiate litigation against the city.14
PROPOSED DENSITY BONUS ORDINANCE (NEW ARTICLE 17)
State law requires cities to adopt local ordinances to implement the State Density Bonus Law. The proposed Ordinance (Attachment 1) implements state law and Program B-3 under the Housing Element. Because Density Bonus Law is constantly amended by the Legislature, it is recommended that local ordinance provide the structure for granting and reviewing density bonus applications and refer to state law on specific qualifications and other provisions. Thus, this proposed Ordinance essentially mirrors state law in order to capture all of the current provisions and potential future changes.
In summary, the proposed Ordinance adds a new Article 17 to Chapter 1 of Title 10 under Zoning and includes the following:
• Sections 10-1.1701 – 10-1.1703: provides for the granting of density bonus, waivers and incentives/concessions under state law. It also includes the additional ability for an applicant to seek more or less bonus offered by state law pursuant to a conditional use permit. This is intended to provide additional affordable housing incentives in line with Program E-11 of the Housing Element.
• Section 10-1.1704: provides for density bonus for projects with childcare facilities. This is required by state law and potentially relevant to Los Altos Hills. • Section 10-1.1705: provides for the parking reductions required by state law. • Sections 1706-1711: provides for the process for reviewing and granting density bonus applications, and enforcement of the affordability of density bonus projects. These provisions implement state law and also ensure the projects remain affordable as a condition of receiving the density bonus benefits.
In summary, the requirements in Housing Element Program B-3, as reflected in the proposed ordinance, are mandated by state law and cannot be modified. The Town must comply with these provisions regardless of whether a local ordinance is in place. The ordinance also incorporates incentives consistent with Housing Element Programs E-5 and E-11; aside from such incentives, these standards represent the minimum necessary to meet state requirements. 12 Gov. Code sections 65915(d)(3); (e)(1).
13 Id.
14 Gov. Code section 65589.5(k).
ENVIRONMENTAL REVIEW
This Ordinance is exempt from CEQA pursuant CEQA Guidelines section 15061(b)(3) as CEQA only applies to projects which have the potential for causing a significant effect on the environment.
Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA. This Ordinance establishes a procedure for implementing State Density Bonus Law as required by statute and the Housing Element. However, it does not approve any projects, grant any entitlements, or make physical changes to the environment. As such, this Ordinance is a regulatory act taken by the Town and does not physically change the environment. Therefore, it is exempt from CEQA as it does not have the potential for causing a significant effect on the environment.
NEXT STEPS
Following the Planning Commission consideration, the draft ordinance will proceed to the May 14, 2026 City Council regular meeting for introduction, and anticipated to be adopted at the June regular meeting. The Housing Element Program B-3 states the Ordinance must be adopted by Q1 2026.
ATTACHMENTS
1. Draft ordinance amending Title 10, Chapter 1 to add Article 17
2. Draft resolution- Planning Commission Recommendation
3. Government Code section 65915- statutory text
Ordinance Adding Article 17 to Title
10, Chapter 1 to Implement a Density
Bonus Ordinance
CITY COUNCIL REGULAR MEETING
JUNE 18, 2026
BACKGROUND
• Housing Element Program B-3:
➢ Amend the Zoning Ordinance to update density bonus regulations to meet updated state requirements (AB 2345, SB 1763, SB 1227)
➢ Timeline: By Q1, 2026; State Law Applies
• State Density Bonus Law (Gov. Code Section 65915 et seq.) (SDBL) ➢ Requires general law and charter cities to grant density bonuses, waivers, and incentives to qualifying affordable housing developments or other eligible projects (donation of land, residential care facilities for the elderly, etc). ➢ Cities must comply with SDBL and also adopt local ordinances to implement the state law requirements (GC 65915(a)(1))
2
BASICS OF STATE DENSITY BONUS LAW
• Ability for applicants to obtain additional density above zoning requirements ➢ Cities must grant a density bonus and other incentives, concessions or waivers for eligible projects. The main types of projects are as follows:
1. Projects that set aside affordable units to low, lower or moderate income households
2. Senior Housing, including RCFEs (no affordable units needed)
3. Housing for Transitional Foster Youth, homeless persons, disabled veterans, or lower income students
4. Projects that donate land to the city
➢ Density Bonus is awarded based on a sliding scale proportional to the percentage and type of affordable units being set aside
❑ Project types #2-3 receive a fixed percentage of density bonus (i.e. RCFEs get 20%) 3
BASICS OF STATE DENSITY BONUS LAW
➢ "Density Bonus" is calculated over the base density – the maximum allowed under zoning, specific plan, or land use element, whichever is highest. ➢ No base density = developer can submit a base density study ❖ The city must accept it, as long as the study includes all applicable objective development standards of the city's land use documents. ➢ All fractional numbers are rounded up to the next whole number ➢ Applicants may use the same set of affordable units to satisfy Density Bonus and local inclusionary requirements.
4
BASICS OF STATE DENSITY BONUS LAW
• Ability for applicants to receive incentives/concessions, waivers, and parking reductions
➢ Incentives/Concessions
▪ Reductions or elimination of standards that would lead to cost reductions for the density bonus project.
▪ Broadly defined by statute- includes modifications in development, design, and architectural standards
▪ Number of incentives/concessions is based on the percentage and level of affordable units (maximum is 5 for 100% affordable projects)
▪ Town cannot require pro forma to "prove" cost reduction, and must make specific findings to deny a request (specific adverse impact, historic property, violation of law) 5
BASICS OF STATE DENSITY BONUS LAW
➢ Waivers of Development Standards
▪ Eliminations of local standards that would physically preclude construction of the density bonus project
▪ Broadly defined by statute and density bonus projects get unlimited number of waivers ▪ Must grant waivers to allow for the project as designed by developer- cannot request the applicant to change the project to eliminate the need for a waiver ▪ Town also must make specific findings to deny a request (specific adverse impact, historic property, violation of law)
6
BASICS OF STATE DENSITY BONUS LAW
➢ Parking Reductions
▪ Density Bonus-eligible projects get specific parking reductions in addition to any requested concessions and waivers
o Studios and 1 bedroom: 1 parking space
o 2-3 bedrooms: 1.5 parking spaces
o 4+ bedrooms: 2.5 parking space
o 1 bedspace in student housing development: 0 parking spaces ▪ Additional reductions available for projects near major transit stops (Town does not have any currently), or for 100% affordable projects or certain supportive housing Projects eligible for density bonus will get the benefits of waivers, concessions, and parking reductions. They do not have to build the bonus units. 7
STATE LAW CHANGES
8 SDBL changes constantly. HE Program B-3 mentions 3 bills effective in 2023/2024:
• AB 2345: Increased maximum density bonus to 50%. lower affordability thresholds for incentives, reduced parking requirements, added incentives for senior housing
• SB 1763: Expanded benefits for 100% affordable projects, up to 80% density bonus, height increases allowed, eliminated parking requirements in some cases • SB 1227: Added incentives for qualifying student housing, consulting with developers and designers on common roadblocks in the process.
PROPOSED LOCAL ORDINANCE- NEW ARTICLE 17
9 Sections 10-1.1701–1703
• Implements state density bonus requirements and allows: density bonuses, incentives/concessions, waivers/reductions
• Includes optional Conditional Use Permit process for bonuses above state maximums and bonuses below state minimums
• Recommended approach is to reference state law so that ordinance absorbs subsequent state law changes
Section 10-1.1704
• Childcare facility density bonus provisions
Section 10-1.1705
• State-required parking reductions
REQUIRED LOCAL CHANGES AND ORDINANCE
UPDATES (CONT.)
10 Sections 1706–1711
• Application review procedures, affordability enforcement requirements • Long-term compliance provisions
Local Flexibility
• CUP option preserves Town discretion
• Supports Housing Element Programs E-5 and E-11 – potentially provides for opportunities to incentivize RCFEs and extremely-low income units • Encourages deeper affordability opportunities
ENVIRONMENTAL REVIEW & CONSEQUENCES OF
NON-COMPLIANCE
CEQA
• This ordinance update is exempt from CEQA as it does not directly review or approve projects and only functions as a regulatory measure
Risks of Non-Compliance
• State Density Bonus Law and Housing Accountability Act provide cause of actions to developers, Town has burden of proof to show it complied with statute
11
RECOMMENDATION
• Staff recommends that the City Council waive reading
and introduce the proposed ordinance to implement
Housing Element program B-3 and align with State
Density Bonus Law
• The item would proceed to the next City Council regular meeting for adoption of the ordinance.
12
Questions?
CITY COUNCIL REGULAR MEETING
JUNE 18, 2026
TOWN OF LOS ALTOS HILLS June 18, 2026
Staff Report to the City Council
SUBJECT: RESOLUTION APPROVING A 10-YEAR RENEWAL OF AN
EXISTING T-MOBILE AT&T OPERATED WIRELESS
COMMUNICATIONS FACILITY AT 26140 DUVAL WAY;
LANDS OF EPISCOPAL LAYMENS GROUP OF LOS ALTOS; FILE
#CUP24-0004
PREPARED BY: Jonathan Fox, Senior Planner
FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, City Manager
RECOMMENDATION:
That the City Council adopt a Resolution (Attachment 1) making a Categorical Exemption determination under CEQA pursuant to Sections 15301(b) and APPROVING the Conditional Use Permit Renewal, subject to conditions of approval.
BACKGROUND:
The subject property is a 1.12-acre parcel located at the top of a small knoll above Interstate 280.
St. Luke’s Chapel in the Hills occupies the property along with three wireless communication providers. The three wireless sites are as follows:
• AT&T utilizes a monopine at the westerly end of the property which is downslope of the chapel. A monopine is a wireless communications facility disguised as a pine tree; • The Sprint antennas are located within a 37-foot-tall flagpole which is located near the entry driveway and the equipment is located within a wood fence enclosure just below the flagpole.
• The T-Mobile antenna, a wireless telecommunication facility, are located within the church steeple. The T-Mobile antenna is the subject of this application; The City Council initially approved the T-Mobile-operated antenna structure through Conditional Use Permit #224-95-ZP-SD-CUP-ND on January 15, 1997. The conditions of approval required that the CUP be renewed after three (3) years. The Town approved renewals in 2002 and 2005.
The most recent renewal has an expiration date of 2007. The wireless facility has been in continuous operation since installation; however, the Town did not receive a renewal request until April 18, 2025, with the current application. The Use Permit is expired and the applicant, T-Mobile (represented by Crystal Shea), is requesting a 10-year extension. The Town most recently issued building permit #BLD25-0173 in 2025 for revisions and electrical upgrades to the T-Mobile wireless facility.
DISCUSSION:
ITEM 7G STAFF REPORT
City Council
26140 Duval Way
June 18, 2026
A Conditional Use Permit (CUP) renewal for a wireless facility may be approved if the City Council finds that the facility complies with the Town’s Wireless Communications Facilities Policy (Attachment 3) and the previously approved conditions for the site. The subject property meets the Policy’s siting and co-location criteria, and conditions related to landscaping, color, and structure are addressed in the CUP.
Staff inspected the property and found it to be well maintained, clean, and generally in compliance with the existing conditions of approval. To align the CUP with the Town’s Wireless Facilities Ordinance, staff recommends revising the renewal term from three years to ten years.
This change is reflected in the Resolution (Attachment 1).
On April 13, 2026, the Planning Commission reviewed the project, conducted a public hearing, and unanimously recommended that the City Council approve the project. The Commission supported staff's recommendation to revise the renewal term from three years to ten years.
Additionally, the Commission supported revising the requirement for annual radio frequency emissions reports so that reports are submitted at staff's discretion, but no more than once per year. These changes are redlined in Attachment 1.
NOTICING/PUBLIC OUTREACH
The public was advised of this Public Hearing in the following ways:
• Mailing to property owners within a 500 feet radius – June 5, 2026 • Posted at the project site – June 5, 2026
• Public Posting Places – June 5, 2026
• Town Website: www.losaltoshills.ca.gov – June 5, 2026 To date, staff has not received public comments regarding the proposed project. Public comments received after publication of the staff report but before June 18, 2026, City Council meeting will be forwarded to the City Council.
ENVIRONMENTAL REVIEW:
The proposed Conditional Use Permit renewal is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15301(b) of the CEQA guidelines – No modifications to an existing facility.
2026 CITY COUNCIL STRATEGIC PRIORITIES:
This is not part of the 2026 City Council Strategic Priorities as renewals are a standard part of the Conditional Use Permit Process.
FISCAL IMPACT:
City Council
26140 Duval Way
June 18, 2026
There is no fiscal impact to the Town for review of Conditional Use Permit Renewals as the Town requires payment of an application fee and deposit to cover staff time.
ATTACHMENTS
1. Resolution with Conditions of Approval
2. File No. #224-95-ZP-SD-CUP-ND – Existing Conditions of Approval
3. Wireless Communications Facilities Policy
4. Radio Frequency Site Compliance Report
5. Environmental Design & Protection Committee report, dated March 2026
6. As-Built Plans (no modifications proposed) – Planning Commission only
Resolution CC _-26 Page 1
RESOLUTION CC _-26
RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS
MAKING A CATEGORICAL EXEMPTION DETERMINATION UNDER CEQA AND
APPROVING A CONDITIONAL USE PERMIT RENEWAL FOR AN EXISTING WIRELESS COMMUNICATIONS FACILITY AT 26140 DUVAL WAY AND
IMPOSING CERTAIN CONDITIONS OF APPROVAL
WHEREAS, on January 15, 1997, the City Council approved Conditional Use Permit #224-95- ZP-SD-CUP-ND for a new wireless communications facility at 26140 Duval Way; and WHEREAS, on April 18, 2025, The Town of Los Altos Hills received an application for a Conditional Use Permit Renewal (CUP24-0004) from the wireless provider, T-Mobile, for an existing wireless communications facility at 26140 Duval Way (“Project”); and WHEREAS, based on the record presented before it, the project is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15301(b) as the project scope is a renewal of an existing wireless facility with no changes to the facility; and WHEREAS, the project application was processed in accordance with the applicable provisions of the California Government Code and the Los Altos Hills Municipal Code; and WHEREAS, on April 13, 2026, the Planning Commission held a duly noticed public hearing on the Project, considered all oral and written testimony, evidence, and public comments presented regarding the Project, and unanimously adopted a recommendation that the City Council approve the Project; and
NOW, THEREFORE, based on the entirety of the record before it, the City Council of the Town of Los Altos Hills hereby finds that the Project is exempt from CEQA pursuant to CEQA Guidelines Section 15301(b) and approves the Conditional Use Permit Renewal subject to the conditions contained in Exhibit “A” and incorporated herein by reference.
The above and foregoing Resolution was passed and adopted by the Planning Commission of the Town of Los Altos Hills at a regular meeting held on the 18th day of June 2026 by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
By: ___________________________________
Rajiv Bhateja, Mayor
ATTEST:
______________________________________________
Arika Miller, City Clerk
ITEM 7G ATTACHMENT 1
Resolution CC _-26 Page 2
EXHIBIT A
CONDITIONS OF APPROVAL
T-Mobile – 26140 Duval Way – File# CUP24-0004
PLANNING:
1. Any changes or revisions to the telecommunications facility or its use shall require an amendment to the applicable conditional use permit(s). Additionally, the Planning Director Community Development Director may, at any time, schedule a review or revocation hearing before the Planning Commission regarding the use permit, if any condition of approval is not met or the facility being used inconsistently with the approved use or in violation of Town development codes.
2. In accordance with the Town’s Wireless Communications Policy, the applicant shall permit the collocation of other carrier’s wireless communications equipment at this facility.
3. The permit shall expire three (3) ten (10) years from the date of approval. Renewal of the permit must be requested in writing, with appropriate fees, prior to the expiration date.
4. The equipment cabinet shall be painted a color, to be determined by the Planning Department, to blend with the surround environment, prior to final inspection of the facility.
5. Landscape screening of the equipment may be required by the Planning Department upon final inspection, if determined to be necessary.
6. The applicant shall submit a signed agreement to the Town, agreeing that, should the use be discontinued by the carrier, all facilities will be removed not later than ninety (90) days after discontinuance of the use or abandonment. The agreement shall be drafted by the City Attorney, and must be signed by the applicant and submitted to the Town prior to acceptance of plans for building plan check.
7. Not later than thirty (30) days after installation and initial operation of the antenna facility, and on or prior to January 1st of each year thereafter, testing of radio frequency emissions shall be conducted by qualified professionals and the reports of such testing shall be provided in writing to the Planning Department, with a comparison to applicable Federal emission standards. The facility shall comply with the Radio Frequency Site Compliance Report submitted with the renewal application. At staff’s discretion, and not more than once a year, the Town may request that the site operator retain the services of qualified professionals to conduct testing of the radio frequency electromagnetic field emissions and provide a report of such testing in writing to the Community Development Department. The report shall compare the results of the testing to the applicable federal emission standards. If at any time the emission levels are shown not to comply with Federal standards, the use permit shall be scheduled for a revocation hearing before the Planning Commission.
Resolution CC _-26 Page 3
ENGINEERING:
8. Any, and all, changes to the approved site plan shall first be approved by the Town Engineering Department. No grading shall take place during the grading moratorium (October 1 to April 30) except with prior approval from the City Engineer. No grading shall take place within ten feet of any property line.
9. Any, and all, areas on the project site that have the native material disturbed shall be protected for erosion control during the rainy season and shall be replanted prior to final inspection.
Please refer to the Conditions of Project Approval set forth herein. If you believe that these conditions impose any fees, dedications, reservation or other exactions under the California Government Code Section 66000, you are hereby notified that these Conditions constitute written notice of a statement of the amount of such fees, and/or a description of the dedications, reservations, and other exactions. You are hereby further notified that the 90-day approval period in which you may protest such fees, dedications, reservations, and other exactions, pursuant to Government Code Section 66020(a), has begun. If you fail to file a protest within this 90-day period complying with all requirements of Section 66020, you will be legally barred from later challenging such exactions.
ITEM 7G ATTACHMENT 2
Article 13
Wireless Telecommunications Facilities
§ 10-1.1301. Purpose.
The purpose and intent of this article is to provide a uniform and comprehensive set of regulations and standards for the permitting, development, siting, installation, design, operation and maintenance of wireless telecommunications facilities in the Town of Los Altos Hills. These regulations are intended to prescribe clear and reasonable criteria to assess and process applications in a consistent and expeditious manner, while reducing the impacts associated with wireless telecommunications facilities. This article provides standards necessary to: (1) preserve and promote harmonious land uses and the public right-of-way in the Town; (2) promote and protect public health and safety, community welfare, visual resources, and the aesthetic quality of the Town consistent with the goals, objectives and policies of the General Plan; (3) provide for the orderly, managed, and efficient development of wireless telecommunications facilities in accordance with the State and Federal laws, rules, and regulations; and (4) encourage new and more efficient technology in the provision of wireless telecommunications facilities.
This article is not intended to, nor shall it be interpreted or applied to: (1) prohibit or effectively prohibit any personal wireless service provider's ability to provide personal wireless services; (2) prohibit or effectively prohibit any entity's ability to provide any interstate or intrastate telecommunications service, subject to any competitively neutral and nondiscriminatory rules or regulation for rights-of-way management; (3) unreasonably discriminate among providers of functionally equivalent services; (4) deny any request for authorization to place, construct or modify personal wireless service facilities on the basis of environmental effects of radio frequency emissions to the extent that such wireless facilities comply with the FCC's regulations concerning such emissions; (5) prohibit any collocation or modification that the Town may not deny under Federal or State law; or (6) otherwise authorize the Town to preempt any applicable Federal or State law.
(§ 2, Ord. 587, eff. January 18, 2020)
§ 10-1.1302. Definitions.
For the purposes of this article, the following defined terms shall have the meaning set forth in this section unless the context clearly indicates or requires a different meaning.
Accessory equipment means any equipment associated with the installation of a wireless telecommunications facility, including, but not limited to, cabling, generators, air conditioning units, electrical panels, equipment shelters, equipment cabinets, equipment buildings, pedestals, meters, vaults, splice boxes, and surface location markers.
Antenna means that part of a wireless telecommunications facility designed to radiate or receive radio frequency signals or electromagnetic waves for the provision of services, including, but not limited to, cellular, paging, personal communications services (PCS) and microwave communications. Such devices include, but are not limited to, directional antennas, such as panel antenna, microwave dishes, and satellite dishes; omnidirectional Town of Los Altos Hills, CA
§ 10-1.1301 § 10-1.1302
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antennas; wireless access points (Wi-Fi); and strand-mounted wireless access points.
This definition does not apply to broadcast antennas, antennas designed for amateur radio use, or satellite dishes designed for residential or household purposes.
Base station means the same as defined by the FCC in 47 C.F.R. Section 1.6100(b)(1), as may be amended, which defines that term as a structure or equipment at a fixed location that enables FCC-licensed or authorized wireless communications between user equipment and a communications network. The term does not encompass a tower as defined in 47 C.F.R. Section 1.6100(b)(9) or any equipment associated with a tower. The term includes, but is not limited to, equipment associated with wireless communications services such as private, broadcast, and public safety services, as well as unlicensed wireless services and fixed wireless services such as microwave backhaul. The term includes, but is not limited to, radio transceivers, antennas, coaxial or fiber-optic cable, regular and backup power supplies, and comparable equipment, regardless of technological configuration (including distributed antenna systems and small-cell networks). The term includes any structure other than a tower that, at the time the relevant application is filed with the State or local government under this section, supports or houses equipment described in 47 C.F.R. Section 1.6100(b)(1)(i) and (ii) that has been reviewed and approved under the applicable zoning or siting process, or under another State or local regulatory review process, even if the structure was not built for the sole or primary purpose of providing such support. The term does not include any structure that, at the time the relevant application is filed with the State or local government under this section, does not support or house equipment described in 47 C.F.R. Section 1.6100(b)(1)(i) and (ii).
Building-mounted means mounted to the side or façade, but not the roof, of a building or another structure such as a water tank, pump station, church steeple, freestanding sign, or similar structure.
Cellular means an analog or digital wireless telecommunications technology that is based on a system of interconnected neighboring cell sites.
Co-location means the mounting or installation of new transmission equipment on an existing tower or structure with existing transmission equipment.
Collocation means the same as defined by the FCC in 47 C.F.R. Section 1.6100(b)(2), as may be amended, which defines that term as the mounting or installation of transmission equipment on an eligible support structure for the purpose of transmitting or receiving radio frequency signals for communications purposes.
Eligible facilities request means the same as defined by the FCC in 47 C.F.R. Section
1.6100(b)(3), as may be amended, which defines that term as any request for modification of an existing tower or base station that does not substantially change the physical dimensions of such tower or base station, involving: (1) collocation of new transmission equipment; (2) removal of transmission equipment; or (3) replacement of transmission equipment.
Eligible support structure means the same as defined by the FCC in 47 C.F.R. Section
1.6100(b)(4), as may be amended, which defines that term as any tower or base station as defined in this section, provided that it is existing at the time the relevant application Town of Los Altos Hills, CA
§ 10-1.1302 § 10-1.1302
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is filed with the State or local government under this section.
Existing means the same as defined by the FCC in 47 C.F.R. Section 1.6100(b)(4), as may be amended, which provides that a constructed tower or base station is existing for purposes of Section 6409(a) regulations if it has been reviewed and approved under the applicable zoning or siting process, or under another state or local regulatory review process, provided that a tower that has not been reviewed and approved because it was not in a zoned area when it was built, but was lawfully constructed, is existing for purposes of this definition.
FCC means the Federal Telecommunications Commission.
Habitable floor area means the heated and conditioned space in a single-family residence or accessory dwelling unit as defined by the California Building Code. For the purposes of this Article, existing habitable floor area includes unbuilt space meeting the above criteria that has an approved building permit that was issued prior to the submittal date of a wireless application.
Macro cell site means a facility within a cellular network that provides radio coverage to a large area of mobile network access. A macro cell differs from a microcell by offering a larger coverage area and high-efficiency output. Output power is usually in a range of tens of watts.
Micro/small cell site means a facility that provides a small range of coverage for a cellular network and is a radio access point with a low radio frequency (RF) power output footprint and range. Specifically, a "small cell wireless facility" means a facility that meets all of the following conditions as defined by the FCC:
Modification means any change to an existing wireless telecommunications facility that involves any of the following: collocation, expansion, modification, alteration, enlargement, intensification, reduction, augmentation, or aesthetics, including, but not The facility meets one of the following mounting height requirements:
(i) mounted on structures 50 feet or less in height, including antennas, or (ii) mounted on structures that are at most 10% taller than adjacent structures, or does not extend the height of the locating structures by more than 50 feet, or by more than 10%, whichever is greater;
(iii)
(1)
The volume of each antenna associated with the deployment is at most three cubic feet;
(2)
The volume of all other wireless equipment associated with the structure is at most 28 cubic feet;
(3)
(4) The facility does not require antenna registration under Federal regulations; (5) The facility is not located on tribal lands; and
The facility does not result in human exposure to radio frequency radiation in excess of the applicable Federal safety standards.
(6)
Town of Los Altos Hills, CA
§ 10-1.1302 § 10-1.1302
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limited to, a change in size, shape, color, visual design, noise or exterior material.
Modification does not include repair, replacement, or maintenance if those actions do not involve a change to the existing facility involving any of the following: collocation, expansion, modification, alteration, enlargement, intensification, reduction, or augmentation.
Monopole means a structure consisting of a single pole used to support antennas or related equipment and includes a monopine or similar monopoles camouflaged to resemble trees or other objects.
Personal wireless service facilities mean the same as defined in 47 U.S.C. Section 332(c)(7)(C)(i), as may be amended, which defines the term as facilities that provide personal wireless services.
Personal wireless services means the same as defined in 47 U.S.C. Section 332(c)(7)(C)(i), as may be amended, which defines the term as commercial mobile services, unlicensed wireless services and common carrier wireless exchange access services.
Pole means a single shaft of wood, steel, concrete, or other material capable of supporting the equipment mounted thereon in a safe and adequate manner and as required by provisions of the Los Altos Hills Municipal Code.
RF means radio frequency or electromagnetic waves between 30 kHz and 300 GHz in the electromagnetic spectrum range.
Right-of-way or public right-of-way means all public streets and utility easements, now and hereafter owned by the Town or other public entity, but only to the extent of the Town or public entity's right, title, interest or authority to grant a license to occupy and use such streets and easements for wireless communication facilities.
Roof-mounted means mounted directly on the roof of any building or structure, above the eave line of said building or structure.
Section 6409(a) means Section 6409(a) of the Middle Class Tax Relief and Job Creation Act of 2012, codified at 47 U.S.C. Section 1455.
Site means the same as defined by the FCC in 47 C.F.R. Section 1.6100(b)(6), as may be amended, which provides that for towers other than towers in the public rights-ofway, the current boundaries of the leased or owned property surrounding the tower and any access or utility easements currently related to the site, and, for other eligible support structures, further restricted to that area in proximity to the structure and to other transmission equipment already deployed on the ground.
Substantial change means the same as defined by the FCC in 47 C.F.R. Section
1.6100(b)(7), as may be amended, which defines that term differently based on the particular wireless facility type (tower or base station) and location (in or outside the public right-of-way). For clarity, this definition organizes the FCC's criteria and thresholds for a substantial change according to the wireless facility type and location.
For towers outside the public right-of-way, a substantial change occurs when:
(i) The proposed colocation or modification increases the overall height more (1)
Town of Los Altos Hills, CA
§ 10-1.1302 § 10-1.1302
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