Los Altos Hills City Council
August 20, 2026

TOWN OF LOS ALTOS HILLS
26379 Fremont Road
Los Altos Hills, CA 94022
Phone: (650) 941-7222
Fax: (650) 941-3160
www.losaltoshills.ca.gov
Internal Purchasing Policy
Approved by City Council: August xx, 2026
I. CODE SECTIONS
II. POLICY INTENT
III. SCOPE
IV. CODE OF CONDUCT
V. EXCLUSIONS/EXCEPTIONS
VI. DEFINITIONS
VII. BUSINESS LICENSE
VIII. REQUEST FOR PROPOSALS/QUALIFICATIONS
IX. PUBLIC WORKS PROJECTS
X. TYPE OF PURCHASES
XI. PROCUREMENT OF GOODS, SERVICES, AND PUBLIC WORKS PROJECTS XII. EMERGENCY PURCHASES
XIII. CONTRACTS/AGREEMENTS
XIV. SOLE SOURCE/SINGLE SOURCE VENDORS
XV. PROFESSIONAL SERVICES RULES
XVI. VENDOR DEBARMENT/NON-RESPONSIBILITY
XVII. ADDITIONAL PURCHASING GUIDELINES
I. CODE SECTIONS
Internal Purchasing Policy shall reference and supplement the Municipal Code Title 2 Administration, Chapter 4 Purchasing System (Purchasing System Ordinance; Municipal Code Sections 2-4.01 et seq.).

The Internal Purchasing Policy provides practices and procedures to be followed specific to the following Municipal Code Sections 2-4.03 and 2-4.04:
2-4.03 Open market orders for purchases and procurements of $60,000.00 or less.

All purchases or procurements of professional and facility services, public projects, supplies, materials, equipment, or other personal property, the cost of which is $60,000.00 or less, may be made in the open market without newspaper advertisement. When deemed appropriate by the City Manager, open market purchases shall be based on at least three competitive bids or quotes and shall be awarded on the basis of the bid most advantageous to the Town. The City Manager may solicit bids directly from prospective vendors by mail, email, or by telephone. The City Manager shall keep a record of all open market orders and bids submitted thereon which ITEM 7C Attachment 2

shall be open to public inspection. Public projects of $60,000.00 or less may be performed by the employees of the Town by force account or may be performed by negotiated contract.

Notwithstanding the provisions of this section, procurement of public projects as defined in the California Public Contracts Code shall comply with all applicable provisions of the Public Contracts Code. (§ 1, Ord. 252; § 1, Ord. 505, eff. October 12, 2006; § 1, Ord. 580, eff. March 23, 2019; § 1, Ord. 609, eff. May 20, 2023)
2-4.04 Formal and informal procedures for the purchase and procurement of goods, services, and public projects in excess of $60,000.00.

All purchases or procurements of goods, services (including professional, special, and personal), and public projects, the cost of which is in excess of $60,000.00 shall be made through either informal or formal procedures as provided for in this section. All purchases or procurements of goods, services, and public projects, the cost of which is more than $200,000.00, shall be based upon specifications or a scope of work approved by the City Council.

II. POLICY INTENT
The purpose of this policy is to define the Town’s internal uniform processes for the procurement of all professional and facility services, public projects, supplies, materials, equipment, or other personal property to ensure proper, efficient, and objective purchasing practice.

III. SCOPE
The provisions of this policy shall apply to elected and appointed officials, Town employees, volunteers, and vendors seeking to do business with the Town. It identifies those with the authority and responsibility to procure on behalf of the Town, and addresses policies on matters including, but not limited to, the purchase of goods and services, public works projects, emergency purchases, Town agreements for services, and the disposition of surplus property.

IV. CODE OF CONDUCT
All Town employees are responsible for impartially assuring fair and competitive access to Town procurement opportunities by responsible vendors. In addition, all employees shall conduct themselves in a manner that avoids any impropriety and that fosters the highest level of public confidence in the integrity of the Town's purchasing system.

1. Conflict of Interest: No employee shall participate in a procurement when the employee knows that their spouse, domestic partner, child, stepchild, parent, stepparent or other close family member or friend will either benefit from the procurement and/or has an employment arrangement contingent on or will be affected by the procurement.

2. No Gifts or Gratuities: No Town employee shall solicit, demand, accept or agree to accept a gift of goods or services, payment, loan, advance, deposit of money, or employment offer presented, promised in return for, or in anticipation of favorable consideration in a Town procurement.

3. Conduct with Vendors: Conduct with vendors who provide goods or services to the Town shall be fair, open, and transparent. Town employees shall refrain from showing favoritism to vendors

or being unduly influenced, safeguard confidentiality when required to do so, and select vendors on the basis of meeting appropriate and fair criteria.

4. Accountability: Town employees shall abide by and be accountable for the codes of conduct established in this policy. Policy violations may result in disciplinary action and/or termination of employment.

V. EXCLUSIONS/EXCEPTIONS
The following purchases are exempt from the competitive solicitation requirements of this policy unless otherwise required by law. These purchases remain subject to applicable approval authority, budget availability, contracting, documentation, and internal controls.

1. Employee benefits

2. Bond and trust account payments

3. Employee reimbursements

4. Escrow payments

5. Fuel (gasoline/diesel)

6. Building materials and tools

7. Field safety gear

8. Vehicles and specialized equipment

9. Insurance

10. Membership/dues

11. Media advertisements

12. Offsite training expenses

13. Pass-through payments

14. Postage

15. Refunds

16. Travel expenses

17. Utility payments

18. Contracts governed by any State or Federal law which prescribes a different procedure.

19. Goods or services accepted in compliance with the terms and conditions of a grant, gift, or bequest to the Town.

20. Piggybacking (cooperative agreement): an assignment of existing contract rights negotiated by another agency to purchase supplies, equipment, or services. Piggybacking is permissible when the solicitation document and resultant contract contain approval for other public entities to utilize the contract. Such agreements may include an assignability clause that assigns all or a portion of the specified deliverables as initially advertised, completed, evaluated, and awarded.

VI. DEFINITIONS
For purposes of this policy, the following words and phrases shall be interpreted as follows:

Awarding Authority - The governing body or staff person authorized to approve the purchase of goods and services on behalf of the Town based on level of review and/or predetermined monetary amounts established by this policy.

Bid - Formal written offer, in response to a solicitation, to furnish goods including supplies, equipment, and vehicles, and/or services in conformity with the specifications, delivery terms, and conditions required at a guaranteed maximum cost.

Change Order - A document signed and approved by an authorized Town employee that modifies the terms of the original approved purchase order and/or agreement in scope, cost, schedule, account coding, and/or other similar factor. Such document for professional services agreement is referred to as additional services.

Emergency - An emergency is a sudden, unexpected occurrence that poses a clear and imminent danger and requires immediate action to prevent or mitigate the loss or impairment of life, health, property, or essential public services, as declared by the Director of Emergency Services/City Manager.

Employee - An individual who performs services for the Town as an elected or appointed official or as a compensated employee of the Town or of a temporary services agency retained by the Town.

Goods - Includes supplies, materials, and equipment to be furnished or used by any Town Department, including items purchased by the Town and furnished to contractors for use in public works projects.

Independent Contractor -An individual or business with whom the Town contracts to provide services. An independent contractor differs from an employee in that the Town specifies the deliverable that is to result from the contracted work but does not have the right to direct or control the manner in which the work is performed.

Maintenance Work - As defined in Section 22002 of the Public Contract Code, and means duties that include any or all of the following: (a) routine, recurring and usual work for the preservation or protection of any publicly owned or publicly operated facility for its intended purposes, (b) minor repainting, (c) resurfacing of streets and highways at less than one inch, (d) landscape maintenance, including mowing, watering, trimming, pruning, planting, replacement of plants, and servicing of irrigation and sprinkler systems, or (e) work performed to keep, operate, and maintain publicly owned water, power, or waste disposal systems, including, but not limited to, dams, reservoirs, powerplants, and electrical transmission lines of 230,000 volts and higher.

Paper Products - Include, but are not limited to: paper janitorial supplies, cartons, wrapping, packaging, file folders, hanging folders, corrugated boxes, tissue, and toweling, or as otherwise defined in 14 CCR Section 18982(a)(5l).

Printing and Writing Papers - Include, but are not limited to: copy, xerographic, watermark, cotton fiber, offset, forms, computer printout paper, white wove envelopes, manila envelopes, book paper, note pads, writing tablets, newsprint, and other uncoated writing papers, posters, index cards, calendars, brochures, reports, magazines, and publications, or as otherwise defined in 14 CCR Section 18982(a)(54).

Professional Services - Services which require the exercise of professional discretion and independent judgment, based on an advanced or specialized knowledge, expertise or training gained by formal studies or experience. Examples of professional service providers include appraisers, architects, attorneys, engineers, instructors, land surveyors, physicians, information technology services, graphic designers, construction inspectors, etc.

Public Works Project (or public projects) - As defined in Section 22002 of the Public Contract Code, and means any of the following, but does not include "maintenance work":

1. Construction, reconstruction, erection, alteration, renovation, improvement, demolition, installation, and repair work involving any publicly owned, leased, or operated facility; or

2. Painting or repainting of any publicly owned, leased, or operated facility.

Quote - A written quotation from a vendor identifying the price for specified goods or services.

Recovered Organic Waste Products - Products made in California, landfill-diverted recovered organic waste processed at a permitted or otherwise authorized operation or facility, or as otherwise defined in 14 CCR Section 18982(a)(60).

Recycled-Content Paper - Paper products and printing and writing paper that consists of at least 30 percent, by fiber weight, postconsumer fiber, or as otherwise defined in 14 CCR Section 18982(a)(61).

Request for Proposal/Qualifications (RFP/Q) - An RFP/Q outlines the specific requirements, objectives, scope of services, and evaluation criteria (including grounds for disqualification and subsequent reinstatement) for a project or contract. RFP/Qs are used in procurement processes to solicit proposals or qualifications from potential vendors, suppliers, or service providers. The RFP/Q allows potential vendors to understand the organization's needs and submit detailed proposals that outline how they would fulfill those needs, or qualifications on how the vendor is best suited and qualified for the work. RFP/Qs are commonly used for complex projects or services where there are various factors to consider beyond just the cost. A Request for Qualifications (RFQ) is used when the selection of a vendor is largely based on qualifications matching the scope of services and scope objectives.

Request for Quotation - A Request for Quotation is a document that is used when an organization is seeking price quotes for specific goods or services. Unlike an RFP/Q, a Request for Quotation focuses primarily on the pricing aspect of the procurement process. It provides a description of the required products or services and asks potential suppliers to provide quotations or estimates for providing those items. Request for Quotations are often used for straightforward procurement needs where the decision is primarily based on cost.

Senate Bill 1383 of 2016 (SB 1383) - Senate Bill approved by the Governor on September 19, 2016, which added Sections 39730.5, 39730.6, 39730.7, and 39730.8 to the Health and Safety Code, and added Chapter 13.1 (commencing with Section 42652) to Part 3 of Division 30 of the Public Resources Code, establishing methane emissions reduction targets in a Statewide effort to reduce emissions of short-lived climate pollutants as amended, supplemented, superseded, and replaced from time to time.

Senate Bill 1383 of 2016 Regulations (SB 1383 Regulations) - The Short-Lived Climate Pollutants:

Organic Waste Reduction regulations developed by CalRecycle that created 14 CCR, Division 7, Chapter 12 and amended portions of the regulations of 14 CCR and 27 CCR.

Services (General) - Work performed or labor, time and effort expended by an independent contractor, including professional services and excluding agreements for public works projects.

Examples include custodial services and building and equipment maintenance.

Surplus Property - Any Town property that is no longer needed or useable by the holding Department.

VII.BUSINESS LICENSE
Pursuant to Municipal Code Title 3 Finance, Chapter 1 Business Licenses, a Town business license is required for vendors located within Town limits, or if an agent of the business comes into Town to conduct business. Before an agreement or purchase order can be issued, a vendor shall be required to obtain a Town business license. Refer to Municipal Code Sections 3-1.109 to 3-1.113 for exemptions to business license requirement.

VIII. REQUEST FOR PROPOSALS/QUALIFICATIONS
Request for Proposals/Qualifications (RFP/Qs) are issued to solicit proposals from vendors for specific or general scope of services often professional and complex in nature. RFP/Qs should outline the specific requirements, objectives, scope of work, and evaluation criteria for a project or contract. Request for Qualifications (RFQs) are issued when the scope of services is general and not yet well defined, which necessitates a need for a certain vendor with specific qualifications to assist in defining the scope of services or approach required for the project in the best interest of the Town.

In RFP/Qs, vendors are asked to submit detailed proposals or qualifications that outline their approach and methods to fulfill the necessary scope or contractual obligations specified. RFP/Qs are commonly used for complex projects or services where there are multiple factors to consider beyond just cost.

Proposals from RFP/Qs are more than just quotations of price; therefore, selection criteria of the vendor should not be solely based on cost.

RFP/Qs are not for public works projects, which require following informal or formal bid processes outlined in the Public Contract Code to be awarded to the lowest responsible bidder.

The vendor evaluation and selection criteria must be clearly outlined in the RFP/Q. Selection criteria can include various factors such as the proposal, firm qualifications, experience of the project team, fit for the project, references, etc. and not be solely based on price.

At minimum, RFP/Q documents should include the following information:

1. Project goal or intent

2. Project Background

3. Minimum qualifications of the vendor

4. Scope of Services

5. Anticipated or desired project schedule

6. Anticipated timeline for selection process, including interviews if applicable

7. Specific proposal requirements including references

8. Vendor selection criteria (be as specific as possible)

9. Town contact person

10. Town contract template
As applicable, RFP/Qs should be sent directly to vendors and specific trade journals, advertised on professional publications or newsletters, and posted on the Town’s website to reach out to a wider or specific pool of potential vendors. Any interested vendors shall be treated fairly and given identical information and an equal opportunity to compete.

Once responses are received, the proposals will be confidentially evaluated and scored in accordance with the established criteria. The Town can also require interviews and presentations from vendors to further assess their qualifications and aptitudes before making a vendor selection for the project.

When a top-rated proposer is identified, good faith negotiations will commence. If an agreement cannot be reached in consideration of cost and/or scope, the next highest-rated proposer will be engaged and so on, until a mutually acceptable agreement is reached.

The Town may utilize other accepted forms of requests for procurement such as a Request for Quotation, Request for Information, and Request for Statement of Interest as deemed appropriate.

IX. PUBLIC WORKS PROJECTS
For public works (or public) projects, the Town has adopted the California Uniform Public Construction Cost Accounting Act (the Act; Public Contract Code Section 22000 et seq.). The Town opted into the Act in 1995 through Council Resolution No. 76-95. These procedures are intended to provide uniformity of cost accounting standards for construction work performed or contracted by public entities in the State and a method for the bidding of public works projects. The Act should be consulted for detailed information (see the California State Controller's website at:
https://www.sco.ca.gov/ard_cuccac.html and the Manual, currently at: https://www.sco.ca.gov/FilesARD-Local/cuccac_manual_2025_edition.pdf. All requirements of the Act, as amended from time to time, shall apply to this Policy. The Town has elected to apply thresholds lower than the maximums authorized by the Act. Where this Policy and the Purchasing System Ordinance specify a lower amount, that amount governs. Maintenance work, as defined in this policy and the Public Contract Code, is separate and distinct from public works projects and does not fall under the Act.

Public Works Project in general means:
• Construction, alteration, demolition, installation, or repair work done under contract and paid in whole or in part out of public funds.
• It can include preconstruction and post-construction activities related to a public works project. • For a full definition of public works refer to Labor Code section 1720.

Anyone working on a public works project must be paid prevailing wages as determined by the Department of Industrial Relations (DIR). Projects of $30,000 or more must meet DIR's apprenticeship requirements. Failure to comply with public works requirements can result in civil penalties, criminal prosecution, or both.

Contractors List: At least once per calendar year, the Town must establish a new list or update its existing list of qualified contractors by mailing, faxing, or emailing written notice to all construction trade journals designated for that Agency under Public Contract Code Section 22036. The notice must invite licensed contractors to submit the name of their firms to the Town for inclusion on the Town's list of qualified bidders for the following 12 months. The Town can choose a specific date in which to renew the list of qualified contractors and may add a contractor to the list at any time during the year pursuant to the Act.

1. Development of Plans and Specifications

a. For public works projects (especially for projects above $60,000 in cost), staff shall prepare plans and specifications that will permit the widest opportunity to prospective bidders to respond to the request for bids based on the Town’s standard specifications. For public works projects that are $60,000 in value or less, plans and specifications should be prepared whenever practical in a format as approved by the Public Works Director. b. Bid bonds, performance bonds, and payment bonds shall be required in amounts stated in the specifications.

2. Solicitation of Bids and Proposals
a. Informal Bids: A notice inviting informal bids shall be prepared describing the project in general terms, how to obtain more detailed information about the project, and the time and place for the submission of bids. The notice shall be mailed, not less than 10 calendar days before bids are due, either to all Contractors on the Contractors List for the category of work to be bid, or to all construction trade journals as specified by the Act Commission in accordance with Section 22036 of the Public Contract Code. Additional contractors and/or construction trade journals may be notified at the discretion of the Department soliciting bids, provided, however:
i. If there is no Contractors List maintained by the Town for the particular category or work to be performed, the notice shall be sent to the construction trade journals specified by the California Uniform Construction Cost Accounting Commission. ii. If the product or service is proprietary in nature such that it can only be obtained from a certain contractor or contractors, the notice may be sent exclusively to such contractor or contractors.
b. Formal Bids: Notices describing the project, stating where to obtain more information, the time and place for submitting sealed bids, and their opening shall be pursuant to Section 22037:
i. Published at least 14 calendar days before the date of opening the bids in a newspaper of general circulation in the Town's jurisdiction;
ii. Sent electronically, if available, by either facsimile or e-mail to all construction trade journals specified in Section 22036 at least 15 days before the date of opening of bids; and
iii. Other notice, if necessary or desired by the Town. c. Rejections of Bids: In its discretion, the Town may reject any bids presented after reevaluating its cost estimates of the project and furnishing written notice to an apparent low bidder. The Town shall have the option of either of the following:
i. Abandoning the project;
ii. Re-advertising for bids in the manner described above; or iii. The Council may override the requirement for bidding if it determines that the public project will be performed more economically by the Town without a contract, or that materials and supplies can be purchased at a lower price in the open market, or if no bids are received through the formal or informal procedure, the project may be performed by Town employees.

d. Award of Contract
i. Public Works projects shall use either the Minor Construction Contract or Bid Construction Contractor, unless otherwise approved by the Public Works Director. ii. Contracts valued over $60,000 shall be awarded by the City Council. iii. Contracts valued up to and including $60,000 may be awarded by the City Manager. See Municipal Code Section 2-4.04(d).
iv. If all bids received through an informal bidding process are in excess of the amount defined in the Act as requiring a formal bid process, the Town Council may, by adoption of a resolution by a four-fifths vote, award the contract at the amount defined in the Act or less, to the lowest responsible bidder, if it determines the cost estimate of the Town was reasonable pursuant to Section 22034. If the Council does not award the contract, but wants to proceed with the project, the specifications must be reviewed and formal bids solicited.
e. Monitoring and Administration
i. Public works projects must be bid in accordance with the California Uniform Public Construction Cost Accounting Act and the Town’s Purchasing System Ordinance. ii. Public works projects must be awarded to the lowest responsible bidder. iii. Contracts over $5,000 require a purchase order or a contract prior to purchase being made or work commencing unless otherwise authorized as an emergency purchase. iv. Anyone working on a public works project must be paid prevailing wages as determined by the California Department of Industrial Relations.
v. Contractors completing public works projects must be registered with the Department of Industrial Relations, follow the California labor requirements for working on Public Works projects, be properly licensed by the State of California, provide a Tax Identification Number, and carry the required liability and workers' compensation insurance.
vi. Public Works projects over $25,000 require payment and performance bonds. vii.Register Public Works projects with the California Department of Industrial Relations (DIR). Project registration must be completed within 30 days of awarding the contract, but no later than the first day on which a contractor has workers employed upon the public works.

X. TYPE OF PURCHASES
For the purpose of this policy, purchases fall into one of the following categories: purchase of goods and/or services, public works projects, and emergency purchases.

As a general rule, purchases shall be based on a competitive procurement process. The rigor of the procurement process increases with the dollar value of the purchase. Although formal bidding can result in lower purchase prices, there are costs associated with the process in terms of time and effort and smaller value procurements may not attract vendor interest in a rigorous process. For that reason, the smaller the purchase, the lesser the requirements in procurement process and vice versa.

XI. PROCUREMENT OF GOODS, SERVICES, AND PUBLIC WORKS PROJECTS Per the Purchasing System Ordinance, under no circumstances may any procurement or purchase contemplated be split or separated into smaller components to avoid procurement or purchasing procedures and/or determine the awarding authority. See Municipal Code Section 2-4.01(b).

The City Manager serves as the Town's Purchasing Agent and may delegate authority to Department Directors to approve purchases and procurements up to $5,000 on behalf of the City Manager and in accordance with the requirements of this Policy.

1. Procurement costing up to and including $5,000 (including tax, shipping, and handling):
a. May be approved at the staff level by Department Directors. b. For a service purchase, purchase order or contract, insurance, W-9, and business license may be required.
c. Public works project work in the amount up to $5,000 or less may be performed by force account using the Town's own staff resources, or by negotiated contract, or by purchase order with no bid requirement and per the Purchasing System Ordinance.

2. Goods and services costing over $5,000 and up to and including $60,000* (including tax, shipping, and handling):
a. City Manager must approve purchase.
b. Efforts shall be made to solicit at least three proposals or quotes from different vendors. When fewer than three quotes are obtained, the requesting department shall document the solicitation efforts and explain why additional quotes were unavailable or impracticable. c. For purchase of goods that are standardized or of uniform quality, the award will be given to the vendor with the lowest quote.
d. For a service purchase, contract or purchase order, insurance, W-9, and business license are required.
e. For purchase of services or goods that are not standardized or not of uniform quality, other factors in addition to cost must be taken into account. In such cases, award need not be made to the lowest-priced proposer. A Request for Proposal (RFP), Request for Qualifications (RFQ), or other competitive solicitation deemed appropriate by the City Manager may be utilized. The basis for vendor selection shall be documented and retained in the procurement file. This provision does not apply to public works projects, which shall be procured in accordance with applicable bidding requirements.
f. Public works project in the amount of $60,000 or less may be performed by force account using the Town's own staff resources, or by negotiated contract, or by purchase order with no bid requirement and per the Purchasing System Ordinance. g. For information regarding sole source or single source vendors, see Section XIV of this policy.

3. Goods and services costing over $60,000* and up to and including $200,000** (including tax, shipping, and handling):
a. City Council must approve purchase.

b. An appropriate competitive solicitation, such as a Request for Proposals, Request for Qualifications, or Request for Quotations, shall be issued in accordance with Section VIII of this policy. Efforts shall be made to solicit at least three proposals or quotes from different vendors. Provide documentation to support the solicitation efforts if fewer than three proposals or quotes are received. An explanation and any supporting documents for the award decision must be submitted to the City Manager.
c. Public works projects shall be solicited and awarded in accordance with the applicable informal or formal bidding procedures described in Section IX of this policy and the California Uniform Public Construction Cost Accounting Act (CUPCCAA). d. For purchase of goods through a bidding process that are standardized or of uniform quality, the award will be given to the vendor with the lowest quote. e. For a service purchase, contract and/or purchase order, insurance, W-9, and business license are required.
f. Public works project in the amount of $200,000 or less may use the formal or informal bidding procedures set forth in the Act and per the Purchasing System Ordinance. g. For information regarding sole source or single source vendors, see Section XIV of this policy.

4. Goods and services costing over $200,000**:
a. City Council must approve purchase.
b. An appropriate competitive solicitation, such as a Request for Proposals, Request for Qualifications, or Request for Quotations, shall be issued in accordance with Section VIII of this policy. Efforts shall be made to solicit at least three proposals or quotes from different vendors. Provide documentation to support the solicitation efforts if fewer than three proposals or quotes are received. An explanation and any supporting documents for the award decision must be submitted to the City Manager.
c. For public works projects, Plans and Specifications for Formal Bids are required and must be approved by the City Council with authorization to advertise for bids. d. Public works projects shall be solicited and awarded in accordance with the applicable informal or formal bidding procedures described in Section IX of this policy and the California Uniform Public Construction Cost Accounting Act (CUPCCAA). e. For purchase of goods through a bidding process that are standardized or of uniform quality, the award will be given to the vendor with the lowest quote. f. For a service purchase, contract and/or purchase order, insurance, W-9, and business license are required.
g. Public works project in the amount of more than $200,000 must use the formal bidding procedures set forth in the Act and per the Purchasing System Ordinance. h. For information regarding sole source or single source vendors, see Section XIV of this policy.

XII.EMERGENCY PURCHASES
In a declared emergency, essential goods and services may need to be obtained outside the processes and authorities established in this Policy. The Policy allows for the necessary flexibility during the immediate response phase of a disaster while still maintaining an effective purchasing process and complying with applicable local and state purchasing laws. Where the Town is included in a major disaster or emergency declared by the President of the United States, this Policy also assures that Town procurements comply

with Federal regulations applicable to Federal disaster grant reimbursement as defined in Title 2 of the Code of Federal Regulations, Part 200 (2 CFR Part 200).

In a non-declared emergency, when purchases are immediately necessary for the preservation of life, property, public health, or continued operation of a Department, the City Manager must approve the purchase. All requirements, including obtaining an executed contract, business license, and insurance should be completed after the fact by the Department. Failure to complete necessary procedures before the good/service were needed does not constitute an emergency.

Departments shall submit a written explanation within five business days describing the nature of the emergency, why standard procedures could not be followed, and the cost of the emergency procurement.

XIII. CONTRACTS/AGREEMENTS
Contracts or agreements are required for the purchase of services.

1. A contract may be entered into for any period of time deemed to be in the best interest of the Town, provided that the term of the contract and renewal provisions are included in the original solicitation process. Contracts committing the Town over five fiscal years are not recommended and should be reviewed and approved by the awarding authority on a case-by-case basis.

2. Contracts in excess of one year shall include a provision automatically terminating the contract in the event that the City Council does not budget funds to pay the contract in future years.

3. Insurance, as defined in this policy, is required for any vendor in connection with a contract that involves service performed on Town property.

4. Public Works projects over $25,000 require payment and performance bonds.

5. If a vendor is providing a good such as equipment, a contract may be required if the purchase also entails a service such as set-up, testing, and/or maintenance as part of the purchase or lease.

6. Departments will use Town standard template contracts. The master templates are created and edited by the Town Attorney. Any changes or exemptions to the standard template contracts must be approved as to form by the Town Attorney.

7. Public works projects involving construction activities shall use the Minor Construction Agreement or the Bid Contract, unless otherwise approved by the Public Works Director.

8. All contracts shall be reviewed by the Department Director prior to execution. The City Manager shall approve and execute all contracts on behalf of the Town.

9. Contracts may not be split or separated into smaller components.

XIV. SOLE SOURCE/SINGLE SOURCE VENDORS
Sole Source is defined as the selection of a good or service that can only be obtained from one vendor because of its specialized, proprietary, or unique character.

Single source is defined as the selection of a good or service that may be available from two or more vendors, but there is a compelling reason to select one particular vendor.

The requesting Department must submit a written Sole/Single Source Justification including:
• Explanation of unique or proprietary features
• Market research demonstrating no reasonable alternatives • Documentation of efforts to identify other vendors
• Risks to operations if another vendor were used

• Why competition is impracticable or not in the Town's best interest The justification must be approved by the Department Director and City Manager and retained in the procurement file.

XV. PROFESSIONAL SERVICES RULES
Professional services refer to needs that supplement existing capacity. Competitive procurement may be waived for the following categories when determined by the City Manager to be in the Town's best interest and documented in the procurement file.

1. Work from another Government Agency

2. Cooperative procurement (negotiated by another agency and piggybacked by the Town)

3. Emergency purchases

4. Sole source/single source vendors

5. Recurring or essential services (including payment of claims and settlements against the Town, utility services, insurance liability claims, necessary bonds, insurance premium renewal for authorized policies, and expenditures related to payroll and employee benefits)

6. Specialized services (in accordance with Government Code Section 37103) Procurement of the above-mentioned services may be conducted in a manner determined appropriate by the Town.

All other services will undergo a competitive procurement process in accordance with Sections VIII and XI of this policy. Public works projects shall be procured in accordance with Section IX.

Professional services requiring a competitive procurement process are those provided by a person or firm possessing specialized knowledge, expertise, or training, including, but not limited to, architectural, landscape architectural, environmental, engineering, land surveying, construction management, and other consulting services. Professional, consultant, or other vendor services (collectively, “Services”) may offer differing qualifications, experience, methodologies, resources, and approaches to meet the Town’s needs. Accordingly, the selection of such services should be based on a best-value determination, considering qualifications, experience, responsiveness, and other relevant factors, rather than solely on the basis of the lowest bid or proposal. See Municipal Code Section 2-4.04(c).

Before proceeding with requesting proposals from consultants, it is important to have an identified scope of work, deliverables, required qualifications and any other elements which outline expectations to meet the requested solution. It is important to note that negotiation with a selected consultant may be needed to reach the desired solution. Procurement processes based on contract amounts are outlined in Section XI. Procurement of Goods, Services, and Public Works Projects.

The following items shall also be addressed for competitive selections:

1. Request for Proposals Solicitation: Requests for proposals shall specify the deadline and place for submission, the nature of the services required, and the selection criteria to be used for awarding the contract. A Town Contact should be identified and accessible to address questions and clarifications. Responses to questions, changes to any details in the RFP shall be posted on the Town website to ensure all prospective proposers are notified or aware of these changes.

Significant document or detail changes in the original RFP shall be distributed as an Addendum.

Efforts shall be made to solicit at least three proposals for services. Contracts should be awarded based on the evaluation of the proposals received. The Town Contact shall maintain the procurement documentation and submit executed contracts and insurance documents to the City Clerk.

2. Selection of Service Provider: An evaluation committee shall independently evaluate the submitted proposals and convene to discuss the evaluative factors in selecting the highest ranked proposers. If further evaluation of the highest ranked proposers is necessary, a formal interview may be conducted or other means to collect information (i.e., reference checks, online research, etc.) may be important to make an informed decision of the highest ranked proposer.

3. Negotiation: At times, items related to the delivery of the project (i.e., scope of work, deliverables, schedule, price, etc.) require discussion and agreement in consideration of alternative solutions or additional and necessary details that are identified through the proposal process. As such, the Town can consider modifications to the scope of work, tasks and deliverables during negotiation with the selected proposer. The final statement of work should be inclusive of the Town’s scope of work and consideration of the consultant proposal.

4. Award: Except as otherwise provided herein, the awarding authority shall award a contract based on qualifications, experience, and responsiveness, in addition to any other criteria set forth in the RFP. The contract shall be awarded to the proposer determined to provide the best overall value to the Town based upon the evaluation criteria established in the solicitation and any resulting negotiations. A PO shall be requested through the financial software after contract award, including contracts for services not acquired through an RFP process. Contracts exceeding $60,000 shall be awarded by the City Council in accordance with the Purchasing System Ordinance. Contracts exceeding $200,000 shall additionally be based upon specifications or a scope of work approved by the City Council as required by Municipal Code Section 2-4.04. City Council may award a contract to the next highest ranked proposer when the highest ranked proposer fails or refuses to execute a contract within ten (10) days after they are provided notice of award, unless the Town is responsible for the delay. Procurement of services of any value shall be through a written contract using the Town's standard template contract, unless otherwise approved by the City Manager or provided through an approved purchase order. Service contracts must be signed by the vendor and City Manager.

5. Rejection of Proposals: All proposals may be rejected and/or the RFP reissued with adequate documentation of the results of the RFP process, in the event of one or more of the following occurs:
a. All responses exceed the budgeted amount, or the Town was unable to negotiate a fair and reasonable price with any of the qualified consultants. b. There are no responsive consultants.
c. The project is abandoned.
d. The specifications, scope, and/or terms and conditions are revised for a new RFP. If the Purchasing Authority determines that rejection of all proposals is necessary, clear written justification should be provided. The decision must be made objectively, not to favor or solicit select vendors. The City Council shall approve a rejection of any or all proposals for formal RFPs. If no proposals are received, the award authority may allow purchase without further competition.

6. Contract Payment: Refer to Section XVII. Additional Purchasing Guidelines for more information.

XVI. VENDOR DEBARMENT/NON-RESPONSIBILITY
The Town has the right to disqualify vendors for the following reasons:

1. Non-performance

2. Inaccurate Statement of Qualifications (SOQ)

3. Other documented reasons determined by the Town to materially affect the vendor's responsibility or ability to perform
XVII. ADDITIONAL PURCHASING GUIDELINES

1. Alternate Vendor
a. In the event that a vendor with the lowest quote is unable to provide the product(s), alternate vendors will be utilized in sequence of lowest responsible quote meeting requirements.

2. Standardization
a. Standardization is an organized process to adopt one product or group of products to be used by the Town, such as a particular computer hardware or software. Product standardization may be utilized to create efficiencies, enhance safety, increase productivity, promote brand consistency, or to foster interoperability.
b. Product standardization decisions shall be made by the City Manager or designee after careful consideration and review of recommendations from staff.

3. Purchase Requisitions
a. A purchase requisition is required to be submitted for a purchase order to be issued when necessary.
b. The requesting Department prepares the requisition using the Town's financial software for the entire amount of the purchase, including tax, shipping and handling, etc. and includes the appropriate account codes.
c. Prior to submitting the purchase requisition for approval, all documents verifying compliance with this policy must be attached. These documents may include:
i. Written quotes including product specifications and tabulation, if appropriate or required; ii. First page of the staff report, if Council approval required or received; iii. Executed contract or amendment to contract for services; iv. Insurance and endorsements if required by contract, or alternatively, waiver of these documents approved by Town Attorney;
v. Verification of valid business license if required; and/or vi. Sole or single source memorandum approved by the Department Director and City Manager. The Town Attorney shall review when legal issues are present. d. Upon receipt of a purchase requisition, the Finance Department reviews the document for accuracy and completeness. If the purchase requisition is not complete and/or accurate, a purchase order will not be issued, and the requesting Department will be notified of any necessary corrections. If the purchase requisition is complete and accurate, a purchase order will be issued in accordance with the guidelines of this policy. e. Approval of the purchase requisition represents that the Department has sufficient funds available to pay for the purchase, all necessary documents are attached and acceptable, and the guidelines of this policy have been followed.
f. A purchase order is required prior to the purchase being made or work commencing unless otherwise noted in this policy.
g. Purchases under $5,000 do not require a purchase order but must be authorized by the purchasing Department per Section XI of this policy.

4. Purchase Orders

a. A purchase order is the principal document used to obtain goods and services for the Town. b. Purchase orders are required for purchases over $5,000 unless otherwise provided in this policy.
c. A purchase order establishes an encumbrance against a program account. d. The Finance Department will issue a purchase order only after Town staff at all approval levels have first reviewed and approved the purchase requisition. Approval levels are as follows:
a. Department Director or designee
b. Insurance verification by the Clerk Department if applicable c. Business License verification by Finance Department staff if applicable d. Approval for compliance with this policy by Finance Department e. Confirmation that the appropriate awarding authority has approved the purchase by Finance Department (i.e., Town Council).

NOTE: No work can commence until contract and PO have been approved. Depending on the type of entity (i.e., LLC, corporation, etc.), staff must ensure that the contract is signed by the appropriate signatories for execution. To identify the type of entity, please search for the business on the California Secretary of State Business Search: https://bizfileonline.sos.ca.gov/search/business.

5. Insurance Requirements
a. For on-call professional service contracts:
i. Liability
ii. Workers’ Compensation**
iii. Automobile
b. For specialized services
i. All of the above in addition to design insurance
c. For IT services
i. All of the above in addition to cybersecurity insurance *NOTE: Umbrella insurance can provide additional coverage but needs to be evaluated on a caseby-case basis. Staff should meet and confer with Finance Department if questions arise. **Vendors staffed by one individual do not require this insurance but must furnish a letter for legal review that confirms they will get workers’ compensation if they employ additional staff.

6. Change Orders/Additional Services
a. Where the actual cost of services differs from the original purchase order amount specified in the service contract, a contract amendment must be submitted by the Department with the change order or additional services request.
b. Change orders or additional services that increase any purchase order of goods or services over $60,000 will require prior approval from the City Council.

7. Blanket Purchase Orders
a. Blanket purchase orders can be utilized for goods or services that are used by the Town for ongoing operations. For a blanket purchase order, vendors agree to honor a price for a given period of time, and the Town may not specifically know how much of the product will be consumed or where or when it will be consumed.
b. A blanket purchase order provides for obtaining pricing for anticipated but unidentified goods or services.

c. Blanket purchase orders have the same requirements for goods and services as outlined in this policy.

8. Vendor Protest Procedures
a. Any participating bidder may file an appeal/protest of a contract award or proposed contract award. The protest or appeal must be made in writing within 10 days of award notification and contain at least the following information:
i. The name, address, email, and phone number of the protester. ii. The signature of the protester.
iii. The bid number and date of bid closing.
iv. A statement of the legal grounds on which the appeal is based, including all information relevant to the bid.
b. Staff shall immediately forward the protest to the City Attorney and City Manager for review and response.

9. Supplier Diversity and Local Business Participation
a. The Town encourages participation by qualified small, local, minority-owned, womenowned, and disabled veteran-owned businesses in its procurement processes, consistent with applicable law.

10. Joint Purchase with Public Agencies
a. The City Manager may issue a joint purchase order, together with any other CA city, county, or state public agency for the purchase of supplies, materials, equipment, or other personal property. See Municipal Code Section 2-4.08 for more information.

A. UNAUTHORIZED PURCHASES
Unauthorized purchases are required to be ratified by the appropriate awarding authority.

The employee making the unauthorized purchase must provide a written explanation of why the purchase was made. The written explanation must be reviewed and approved by the appropriate awarding authority. Unauthorized purchases may result in disciplinary action and other remedies available under applicable law and Town policy.

B. RECYCLED PRODUCTS AND MATERIALS
It is the Town's intent to minimize negative environmental impacts of the Town's activities by ensuring the procurement of services and products that reduce toxicity, maximize recyclability and recycled content, and conserve natural resources, material, and energy.

In 2016, Governor Brown signed into law Senate Bill 1383 (SB 1383), in a state-wide effort to reduce emissions of short-lived climate pollutants (SLCP). Beginning January 1, 2022, SB 1383 requires cities and counties to procure annually a quantity of recovered organic waste products. As there is so much paper present in the solid waste disposal stream, the procurement of recycled content and recyclable paper will grow demand for these products and support recycling to help meet the organic waste diversion goals of SB 1383.

Town Departments and direct service providers to the Town, as applicable, must comply with the Town's Organic Waste Product Procurement Procedure for purchasing and mandatory recordkeeping for paper products, printing and writing paper, and disposable kitchen and office supplies.

Requirements for purchasing paper products, printing and writing paper, and disposable kitchen and office supplies are as follows:

1. All purchases must contain 30 percent postconsumer recycled content, when available at no greater cost than nonrecycled products.

2. Products must be recyclable as defined by FTC "Green Guides."

3. Departments must require vendors to certify postconsumer content and recyclability claims.

4. Departments/employees must provide records to the recordkeeping designee, as outlined in the Town Organic Waste Product Procurement Procedure, of all paper products, printing and writing paper, and disposable kitchen and office supplies purchased from a vendor within thirty days of the purchase (both recycled content and non-recycled content, if any is purchased). Records shall include a copy of the invoice or other documentation of purchase, written certifications for recycled-content purchases, purchaser name, quantity purchased, date purchased, and recycled content (including products that contain none), and if non-recycled content paper products and/or non-­recycled content printing and writing paper are provided, include a description of why recycled-content paper products and/or recycled content printing and writing paper were not provided.

Departments should meet the following guidelines for non-paper products, provided the goods are available within a reasonable timeframe, meet reasonable performance standards, and are available at a reasonable cost:

1. All computer products purchased by the Town should be in compliance with the Federal Energy Star program.

2. All pesticides purchased by the Town shall be of the least toxic available.

3. Whenever possible, goods and services procured by the Town shall be from businesses that are certified green businesses by the Bay Area Green Business Program.

C. SURPLUS GOODS AND EQUIPMENT
Each Department shall periodically review its inventory and promptly notify the City Manager of any surplus property. Proceeds from the sale or trade-in of surplus property shall be returned to the appropriate fund.

1. Surplus Disposal: The declaring authority shall determine or approve one of the following methods of disposition that is most appropriate and in the best interest of the Town:
a. Trade-In: Surplus property may be offered as a trade-in credit toward the acquisition of new property.
b. Disposal: The surplus property may be offered for sale. All surplus property is for sale "as is," with no warranty, guarantee, or representation of any kind, expressed or implied, as to the condition, utility, or usability of the property offered for sale.

2. Methods of Disposal:

a. Public Auction: Surplus property may be sold at public auction. Town staff may conduct public auctions, use online auction sites, or the Town may contract with a professional auctioneer.
b. Selling for Scrap: Surplus property may be sold as scrap if the declaring authority deems that the value of the raw material exceeds the value of the property as a whole. c. Negotiated Sale: Surplus property may be sold outright if the declaring authority determines that only one known buyer is available or interested in acquiring the property. d. Donation: Surplus property unlikely to generate significant revenue may be donated to other public agencies or to non-profit organizations. Any non-profit must be qualified under Section 501(c)(3) of the Internal Revenue Code in order to receive a donation. e. No Value Item: Where the City Manager determines that specific supplies or equipment are surplus and of minimal value to the Town due to spoilage, obsolescence, or other cause; or where the City Manager determines that cost of disposal of such supplies or equipment would exceed the recovery value, the Town shall dispose of the supplies in such manner deems appropriate and in the best interest of the Town.

APPROVED AS TO FORM:

Steven Mattas, City Attorney

PURCHASING POLICIES AND PROCEDURES
(Effective August XX, 2026)
Purchase
Type
Dollar
Amount
Procurement Method Awarding
Authority
Goods &
Services
Up to $5,000 No competitive solicitation Department
Director
Over $5,000 –
$60,000
Open market purchase; efforts shall be made to obtain at least three quotes or proposals
City Manager
Over $60,000 –
$200,000
Competitive solicitation (Request for Proposals, Request for Qualifications, or Request for Quotations); efforts shall be made to solicit at least three proposals or quotes.

City Council
Over $200,000 Competitive solicitation (Request for Proposals, Request for Qualifications, or Request for Quotations); efforts shall be made to solicit at least three proposals or quotes.

City Council
Public
Works
Projects
Up to $60,000 Force account, negotiated contract, or purchase order City Manager Over $60,000 –
$200,000*
Informal bidding City Council
Over
$200,000**
Formal bidding City Council
Notes:
• Public works projects are subject to the California Uniform Public Construction Cost Accounting Act (CUPCCAA).
• See Sections IX, XI, and XV of this policy for detailed procurement requirements and exceptions.

Proposed Purchasing Policy
Purchasing Thresholds & Approval Flowchart
START: Determine the total anticipated purchase or contract amount. Use the full cost, including tax, shipping and handling. Purchases may not be split to avoid a threshold.

GOODS & SERVICES
Including professional and contractual services

PUBLIC WORKS PROJECTS
Subject to Town policy and CUPCCAA requirements
$5,000 or less
Department Director Approval
No competitive quotation requirement specified.

Purchase order generally not required.

Over $5,000 - $60,000
City Manager Approval
Make efforts to obtain at least 3 proposals or quotes.

Document why fewer than 3 were obtained.

Purchase order / contract requirements apply.

Over $60,000 - $200,000
City Council Approval
Competitive solicitation required (RFP, RFQ, or quotation).

Make efforts to solicit at least 3 proposals or quotes.

Document the basis for vendor selection.

Over $200,000
City Council Approval
Council-approved specifications or scope of work required.

Competitive solicitation required.

Make efforts to solicit at least 3 proposals or quotes. $5,000 or less
Department Director Approval
May use force account, negotiated contract, or PO.

No bid requirement.

Over $5,000 - $60,000
City Manager Approval
May use force account, negotiated contract, or PO.

No bid requirement under Town threshold.

Applicable public works rules still apply.

Over $60,000 - $200,000
City Council Approval
Use applicable informal or formal bidding under CUPCCAA.

Award to the lowest responsible bidder.

Follow Town and state public works procedures.

Over $200,000
City Council Approval
Council-approved plans and specifications required.

Formal bidding required. Award to lowest responsible bidder.

Advertise in accordance with applicable requirements.

STAFF AUTHORITY
$5,000
Department Director

CITY MANAGER AUTHORITY
$60,000
Up to and including

CITY COUNCIL AUTHORITY
Over $60,000
Additional requirements over $200,000
Quick reference: POs are generally required over $5,000; written contracts are generally required for services. Emergency, sole/single-source, cooperative purchasing, and other policy exceptions may follow different procedures.

Source: Draft Internal Purchasing Policy (August 2026), Sections IX, XI, XIII-XV and XVII. This summary is for quick reference; the adopted policy controls in the event of a conflict.

ITEM 7C Attachment 3

Finance & Investment Committee (FIC) – Draft Minutes
Meeting Date: July 27, 2026
Location: Council Chambers / Zoom Hybrid
Committee: Full committee present
Guests: Dana Stalder; Emily (Finance Intern); Justin Resuello (PFMAM) Call to Order
Chair Epstein called the meeting to order. All committee members were present. Dana Stalder attended as a guest; his appointment is expected to be considered by the Council in August.

Emily, the Town’s finance intern, was introduced.

Approval of Minutes
The committee reviewed minutes from three prior meetings (May 4, May 11, and June 1). • May 4 Minutes: Approved unanimously.
• May 11 Minutes: Approved unanimously.
• June 1 Minutes: Approved unanimously.

Public Comment
No public presentations.

Quarterly Investment Report – PFM Asset Management, Justin Resuello, PFMAM Justin presented the quarterly investment report for the period ending June 30, 2026, covering macroeconomic conditions, Federal Reserve posture, and portfolio performance.

Market & Economic Overview
• AI-related capital expenditure is now a significant contributor to U.S. GDP growth, offsetting softening consumer spending.
• Inflation rose in May due to energy volatility tied to Middle East conflict; oil recently around $103/barrel.
• Labor market stable at ~4.2% unemployment, though real wage growth remains modest. • Federal Reserve:
o New Chair Kevin Warsh signaling a more hawkish stance. o June meeting held rates at 3.50–3.75%.
o Fed may reduce forward-guidance tools (e.g., dot plot). o CME FedWatch shows no expected July rate change; ~50% probability of a September hike.

Portfolio Performance
• FY performance: ~3%, outperforming the Town’s 1–5 year benchmark. • Inflation remains above portfolio returns;
• Market value declined $128,000 during the quarter due to rising rates (unrealized). • Yield at cost: 4.22%
ITEM 7C Attachment 4

• Yield at market: 4.40%
• Duration: 2.55 years (benchmark 2.46 years)
• Corporate allocation increased to ~27%, within the 30% state limit. • Recent purchases:
o Salesforce (4.25%, 2028)
o NVIDIA (4.50%, 2031)
o U.S. Treasury (4.125%, 2031) NVIDIA provided ~40 bps pickup over Treasuries. • Total purchases this quarter: $2.1M.
• Quarterly interest earnings: $215,000; annualized accrual earnings approach $1M.

Committee Questions
• Corporate allocation limits clarified (Town follows state’s 30% cap). • Discussion of inflation vs. portfolio returns.
• Chair Epstein emphasized mark-to-market impacts and strong accrual earnings.

Conclusion: Committee thanked Justin for the report.

Development Fee Schedule Implementation Update
Presenter: Jay Bradford**
Jay provided a detailed update on implementation of the Council-approved fee schedule changes.

Public Notification
Approximately 40–50 communications issued between March and July 2026, including:
• Community Development Weekly and City Manager’s Weekly updates • Notices to Builders Exchange and Building Industry Association • Town Crier advertisement (July 1)
• Email to ~1,800 permit system users
Council Direction & Implementation
Council directed staff to implement:
• 90% cost recovery for Planning, Engineering, and Building fees • 80% cost recovery for ADUs and certain small projects • Maintain no fee for seismic gas shutoff valves
• Update formatting, notes, and valuation tables
Jay displayed side-by-side comparisons (Attachment 4 vs. updated schedule).

Hourly Rate Discussion
A significant discussion occurred regarding whether the hourly blended rate should also be discounted:
• Staff initially did not reduce hourly rates to 90%.
• Several committee members noted this may be inconsistent with Council intent. • After discussion, consensus direction:
o Hourly rates will be reduced to 90%,
o ADU hourly rates will be reduced to 80%,

o Staff will maintain separate hourly rates by project type.

Tiering for Small Projects
Committee revisited Council’s discussion regarding small-project relief:
• Council intended 80% cost recovery for ADUs and certain small projects. • Jay confirmed the valuation table already reflects reduced tiers for projects under $50,000 and under $250,000.
• Committee requested clearer presentation:
o Three separate tables showing 90% tier, 80% ADU tier, and small-project tier.

Jay agreed to revise the schedule accordingly.

Budget Impact
Chair Leung and Jay confirmed:
• The fee schedule changes reduced projected revenue by ~$400,000, • Operating surplus decreased from ~$700,000 to ~$268,000, • The Town remains in surplus.

Clarifications
• Flat fees are fixed values derived from the fee study; hourly rate changes do not retro-feed into flat fees.
• Excessive inspections still billed hourly.
• ADU projects will use the 80% hourly rate.
• Staff will send the final updated fee schedule to FIC and update the website.

Future Work
• Consider CPI escalators in next cycle.
• Benchmarking may occur sooner than five years.
• Staff preparing an RFP to evaluate plan-check costs, especially for smaller projects where current methodology may overstate costs.

Committee thanked Jay and staff for extensive work.

Draft Purchasing Policy
Presenter: Varsha (with contributions from Emily)**
Varsha presented the draft Purchasing Policy intended for Council adoption in August.

Purpose
• Document and standardize procurement procedures
• Improve transparency
• Clarify distinctions between goods/services procurement and public works procurement • Align with municipal code and state requirements
Key Elements
• Authority thresholds:
o Department Directors: up to $5,000
o City Manager: $5,000–$60,000

o Council: above $60,000
• Public Works thresholds:
o Town will retain current municipal code thresholds ($60,000 force account; $200,000 informal bidding)
o State CUPCCA thresholds recently increased to $75,000 and $225,000, but Town will not adopt them at this time
• Three-quote standard:
o Staff attempts to obtain three quotes; if not possible, documentation of outreach is required
• Professional services:
o Contract required; rules detailed in Section 13
• Purchase orders:
o Required for all services not acquired via RFP
o Finance verifies contracts, insurance, business license, vendor setup • Budget compliance:
o Departments may not exceed budgets; may reallocate within their fund • Exemptions:
o Insurance, utilities, employee benefits, and similar items • Contract duration:
o Multi-year contracts discouraged unless necessary
• Public works bonds:
o Required for projects over $25,000
Visual Aids
Emily prepared visual matrices summarizing thresholds and workflows.

Committee asked clarifying questions regarding budget authority, exceptions, and alignment with state law.

Adjournment
Chair Epstein adjourned the meeting.

TOWN OF LOS ALTOS HILLS August 20, 2026
Staff Report to City Council
_____________________________________________________________________________ SUBJECT: CODE ENFORCEMENT PROGRAM IMPLEMENTATION UPDATE FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, City Manager
_____________________________________________________________________________ RECOMMENDATION:

Staff recommends that the City Council receive the implementation update and confirm that staff should proceed with development of the full administrative enforcement framework described in this report, including:

1. An administrative citation program with escalating penalties;

2. Administrative compliance orders for complex, continuing, or repeated violations;

3. A comprehensive code enforcement cost-recovery and collection process;

4. Procedures addressing unpermitted work, repeat violations, and failure to meet compliance deadlines; and

5. Related due-process, hearing, software, training, and public-information procedures.

If the Council does not support one or more of these elements, staff requests direction identifying the elements to be modified or excluded from the ordinance and implementation work.

BACKGROUND:

At its June 18, 2026, meeting, the City Council reviewed the Town’s existing code enforcement program and potential options to modernize the administrative enforcement framework. The June 18, 2026 staff report recommended evaluating Municipal Code amendments addressing a comprehensive code enforcement administrative cost-recovery program; a standalone administrative citation and penalty process; consequences for work performed without required permits; and due-process protections, including notice, cure periods where applicable, hearing rights, and hardship procedures. The report also identified potential expansion of mediation and arbitration resources for recurring neighborhood disputes.

The June review concluded that the Town already possesses substantial nuisance abatement authority and that the principal opportunities for modernization involve administrative enforcement, broader cost recovery, clearer treatment of unpermitted work, and refinement of enforcement procedures. This approach would add practical intermediate tools between voluntary compliance and more resource-intensive nuisance, civil, or criminal remedies.

ITEM 8A

Following the Council’s discussion, the general direction was for staff to move forward with strengthening the code enforcement framework and return with a more developed proposal. Staff understood that direction to include enforcement tools that can be used without waiting for a property owner to seek a permit; charges and cost-recovery mechanisms so that repeated or prolonged enforcement costs can be shifted from the General Fund to the responsible property owner; clearer consequences for work performed before required approvals and later brought forward for legalization; more consistent tools for long-running cases and failure to comply with notices or deadlines; and further development of the overall code enforcement program and procedures rather than relying primarily on increased permit penalties. In practical terms, the direction was to return with a proposal addressing “fines, charges and program changes.” Consistent with that direction, staff has focused the current implementation work on the administrative enforcement and cost-recovery components that require Municipal Code amendments, hearing and appeal procedures, administrative systems, staff training, and public information. As that work has progressed, staff has refined how the proposed tools could operate together as a progressive enforcement framework.

The Town’s current code enforcement program places a strong emphasis on education and voluntary compliance. Staff typically begins with informal communication, notices of violation, correction deadlines, and follow-up inspections. Depending on the circumstances, the Town may also use stop work orders, permit enforcement, nuisance abatement, or referral to the City Attorney.

This approach has generally been effective, but there are cases where the Town would benefit from an intermediate administrative remedy that is more formal than a notice of violation but less burdensome than court action.

Following the Council’s direction, staff reviewed administrative enforcement programs used by other California jurisdictions, including Palo Alto, East Palo Alto, and Rohnert Park. The review focused on how peer agencies structure intermediate administrative enforcement, due process, cost recovery and collection, and escalation to more formal remedies. These programs are intended to encourage prompt correction of violations while preserving a fair opportunity to contest an enforcement action and maintaining other civil and criminal remedies when necessary.

The review also confirmed that implementing the broader administrative enforcement program requires significantly more work than adopting a penalty schedule. The Town must first amend its Municipal Code to establish clear authority for administrative penalties, cost recovery and collection, compliance procedures, hearings, appeals, and related remedies. Once that authority is established, staff must develop policies, forms, hearing procedures, recordkeeping systems, software functions, staff training, and public information materials. Because the Municipal Code amendments establish the legal foundation for the program, they will determine the overall implementation timeline.

DISCUSSION:

Existing Enforcement Approach
The Town’s current enforcement process is primarily compliance-oriented. Staff generally seeks to resolve violations by explaining the applicable requirements, identifying the corrective work needed, and providing a reasonable opportunity to comply. This approach is appropriate for many cases, particularly where a violation is unintentional or the responsible party is actively working toward correction.

However, some violations continue for extended periods despite repeated notices and inspections.

In other cases, the Town’s current options may be either too limited or too severe. A notice of violation may not create sufficient incentive for timely compliance, while criminal prosecution or civil litigation may require substantial staff and legal resources. Administrative citations and compliance orders would provide an additional enforcement step between those options.

An administrative citation would allow an authorized enforcement officer to document a violation, identify the responsible party, establish a correction period, and impose a monetary penalty when compliance is not achieved. A more structured administrative compliance order could be used for complex, continuing, or multi-step violations by identifying the corrective actions required, establishing a compliance schedule, and explaining the consequences of continued noncompliance.

These tools would supplement rather than replace the Town’s existing enforcement authority.

Unpermitted Work and Long-Running Cases
A specific objective of the proposed framework is to provide clearer and more consistent consequences for work performed without required approvals and for cases that remain unresolved after repeated notices or deadlines. Under the proposed approach, a later application to legalize unpermitted work would not, by itself, resolve the enforcement case or eliminate otherwise applicable administrative penalties or recoverable enforcement costs. The property owner would still be required to correct or remove the violation and obtain all approvals necessary to legalize the work.

Administrative citations, cost recovery, and compliance orders would allow the Town to address an active violation while the case is pending rather than waiting for a property owner to initiate a permit process. Staff will develop procedures to coordinate enforcement consequences with any after-the-fact permit process, avoid duplicative charges, maintain proportionality, and preserve notice and appeal rights.

Comparison with Other Jurisdictions
The programs reviewed by staff demonstrate several common elements that would be relevant to Los Altos Hills. The following table summarizes the principal features identified in the code excerpts reviewed for this implementation update.

Jurisdiction Core Administrative
Tools Due Process / Review Implementation Feature
Palo Alto
(see attachment 1)
Administrative citations
within a broader
enforcement system
Notice, appeal procedures,
independent hearing officers,
and written decisions
Collection mechanisms;
preserves authority to use
other remedies
East Palo Alto
(see attachment 2)
Administrative citations
and administrative
orders
Notice, opportunity to
correct, and administrative
review
Progressive enforcement;
recovery of penalties and
enforcement costs
Rohnert Park
(see attachment 3)
Citations and
compliance orders
within a unified system
Service requirements,
hearings, and final
administrative decisions
Comprehensive procedural
structure; civil and
criminal remedies retained
These examples demonstrate that an effective administrative enforcement program must balance efficiency with due process. The Town will require procedures that allow staff to respond to violations promptly while ensuring that property owners and other responsible parties receive clear notice, an opportunity to correct, and a fair process to challenge a citation or order.

How the Proposed Tools Would Work Together
The proposed framework is intended to operate progressively while preserving staff discretion to use the remedy appropriate to the seriousness, duration, and circumstances of a violation. A typical case could move from voluntary compliance to an administrative citation when a correction deadline is missed, and then to an administrative compliance order when a violation is complex, continuing, repeated, or requires a structured correction schedule. Existing nuisance abatement, civil, criminal, and other remedies would remain available and could be used earlier when warranted. An administrative order would not be required to follow every citation, and serious or time-sensitive cases would not be required to begin at the lowest step.

Figure 1. Illustrative Progressive Enforcement Path

1. Voluntary Compliance 2. Administrative Citation 3. Compliance Order 4. Existing Formal Remedies Education, notice of violation, and
correction deadline
Monetary consequence when a
deadline is missed or a violation
repeats
Structured corrective actions and
schedule for complex or
continuing cases
Nuisance abatement, civil,
criminal, or other enforcement
actions when warranted
The sequence above is illustrative rather than mandatory; the Town would retain discretion to select or escalate remedies based on the facts of each case.

Municipal Code Amendments
[You may wish to insert here:] In the 1990’s, the California Legislature amended the Government Code to permit local public agencies to enact administrative penalties provisions for violations of local codes. The legislation requires the agency to provide a reasonable time to correct violations

of building codes and provides for a new trial in superior court if the violator chooses to appeal.

As a result of the state legislation, most California cities and towns have amended their municipal codes to provide for administrative remedies to supplement other means of enforcing their codes.

The Municipal Code amendments will be the most important and time-sensitive component of implementation. The Town currently does not have a complete administrative framework comparable to the programs reviewed. The proposed amendments will need to define who may issue administrative enforcement actions, what violations are subject to those procedures, how notices must be served, how penalties and recoverable costs are calculated, how continuing and repeat violations are treated, how collection may occur, and how hearings and appeals are handled.

The amendments will also need to establish the authority to issue administrative compliance orders.

These orders may be particularly useful in complex cases where compliance requires several corrective actions over time. The ordinance will need to clarify when an order may be issued, what information it must contain, how deadlines are established, and what consequences apply if the order is not followed.

The code should also address cost recovery and collection as an integrated part of the program.

This includes recovery of administrative and enforcement costs, reinspection costs, hearing expenses where legally appropriate, unpaid penalties, and other documented expenses authorized by the ordinance. The amendments should also clarify how administrative enforcement applies to unpermitted work and continuing violations so that the Town is not dependent on a future permit application as its primary means of obtaining compliance. Any collection process must be consistent with applicable law and coordinated with the Finance Department and City Attorney.

Because these amendments create the legal foundation for every other part of the program, the ordinance development and adoption process will control the implementation schedule.

Administrative Cost Recovery
Cost recovery is a separate but complementary component of the proposed program.

Administrative fines are intended to create an incentive for timely compliance, while cost recovery is intended to reimburse the Town for reasonable enforcement expenses attributable to a confirmed violation. A future ordinance could authorize recovery of documented staff and consultant time, investigation and inspection costs, reinspection costs, and other costs where legally authorized.

Implementation will require clear rules and policies regarding when cost recovery begins, which costs are recoverable, how charges are documented and noticed, how a responsible party may contest them, and whether caps, hardship provisions, payment plans, or other limitations should apply in appropriate cases. These issues will be developed with the Finance Department and City Attorney as part of the ordinance and administrative procedures.

Issuance and Maintenance of Citations

Staff will need to establish clear procedures governing how citations are issued and maintained.

These procedures should identify when a citation is appropriate, how much time should be allowed for correction, how repeat violations are handled, and when escalating penalties may be imposed.

The process must also ensure consistency. Similar violations should be treated in a similar manner, while still allowing staff to consider factors such as the seriousness of the violation, its duration, its effect on health and safety, the responsible party’s compliance history, and the level of cooperation shown during the enforcement process.

Each citation will need to be supported by a complete administrative record. That record may include photographs, inspection notes, correspondence, permit history, applicable code provisions, proof of service, and documentation of prior attempts to obtain compliance. The Town’s code enforcement software will need to support this recordkeeping so that the history of each case can be accurately maintained and produced for a hearing or legal review.

Staff will also need procedures for tracking correction deadlines, scheduling reinspection, confirming compliance, assessing additional penalties, and closing cases. These administrative functions will require coordination between Community Development, Finance, the City Attorney, and the Town’s software vendor.

Administrative Orders
Administrative compliance orders would generally be used when a citation or ordinary notice process is not sufficient to achieve compliance, or when the nature of the violation requires a more structured corrective plan. An order could identify all outstanding violations, specify the required corrective actions, establish a compliance schedule, and explain the consequences of failing to comply. Depending on the seriousness and complexity of a case, the ordinance could also allow an order to be used directly without requiring a prior citation. Typically, when a party fails to comply with a compliance order, a hearing date is scheduled. At that hearing, the hearing officer or body may provide exended deadlines to obtain compliance and may impose daily penalties and enforcement costs.

This approach may be especially useful for long-running cases and matters involving unpermitted construction, grading, drainage, property maintenance, or multiple related violations. Rather than relying on repeated notices or separate citations for each inspection or condition, the Town would establish a comprehensive path to compliance through a single written order while retaining the ability to impose penalties and recover enforcement costs as authorized.

The order process must be carefully structured to ensure that the responsible party receives adequate clear notice and has an opportunity to appeal.

Hearing Officer Process
A fair and independent hearing process is essential to the program. Any person receiving an administrative citation or compliance order must have an opportunity to challenge the determination before an impartial hearing officer.

Staff anticipates that the Town would retain independent hearing officers rather than assigning appeals to Town employees who are involved in enforcement. The hearing officer would review the administrative record, consider testimony and evidence, determine whether the violation occurred, and issue a written decision. The officer may also need authority to affirm, modify, or rescind a citation or order, depending on the final ordinance, and may be provided with continuing jurisdiction to follow-up on their decision.

The Town will need to establish minimum qualifications, conflict-of-interest requirements, compensation, scheduling procedures, and written hearing rules. Staff will also need to determine whether hearing officers should be retained individually, through an on-call contract, or through a regional service used by multiple jurisdictions.

Hearing timelines will need to be clear. The Municipal Code should specify how long a person has in order to request a hearing, when the hearing must be scheduled, what information must be submitted in advance, and when a written decision must be issued. These timelines will be important both for due process and for efficient case management.

Software and Administrative Systems
Staff has confirmed that the Town’s existing TRAKiT permitting and code enforcement platform can be configured and augmented to support the core functions anticipated for the new program.

Configuration will be needed to generate citations and orders, calculate and track penalties and recoverable costs, track service and compliance dates, schedule hearings, maintain the administrative record, and coordinate payment information with Finance.

The software must also preserve the complete history of each enforcement action. This is important because administrative decisions may later be subject to judicial review. A clear and reliable record will help demonstrate that the Town followed its procedures and based its decision on documented evidence.

Software configuration and testing are expected to occur concurrently with ordinance development.

Final workflows and forms cannot be completed until the legal framework and specific procedural requirements are known. If a particular function requires custom development beyond standard configuration, staff will identify that need during implementation and return to the Council if it materially affects cost or schedule.

Staff Training and Implementation
Before the program begins, staff will need training on the new authority, due process requirements, evidence collection, report writing, hearing preparation, and testimony. Consistent training will be necessary to ensure that citations and orders are issued fairly and uniformly.

The Town should also provide public information before implementation. Residents, property owners, contractors, and design professionals should understand the purpose of the program, the steps in the enforcement process, and the right to appeal. Public information should make clear that the primary goal remains compliance rather than punishment.

Updated information should be placed on the Town’s website and incorporated into notices, citation forms, and appeal materials. Early public education may also reduce confusion and improve voluntary compliance once the program is launched.

Implementation of the proposed framework would occur concurrently across the ordinance, administrative, hearing, and software workstreams. Staff anticipates that approximately six months will be required to establish and launch the complete program. During the first two to three months, staff and the City Attorney would prepare the Municipal Code amendments addressing administrative penalties, compliance procedures, cost recovery, hearings and appeals, collection, and treatment of continuing and unpermitted-work violations. Internal review, hearing officer research, TRAKiT configuration planning, and development of forms could proceed at the same time.

As the ordinance moves through introduction and adoption, staff would continue developing the supporting procedures and systems so implementation can proceed without unnecessary delay.

Following adoption, staff would finalize citation procedures, hearing rules, administrative order templates, penalty schedules, software configuration, and public information materials. Staff training and hearing officer contracting would be completed before program launch.

The Municipal Code amendments remain the primary critical path because they establish the legal authority and procedural requirements that the remaining program elements must follow. Software development, legal review, or hearing officer procurement could also affect the timing. Staff will return to the Council if any of those items are expected to materially delay implementation.

FISCAL IMPACT:

Implementation will require staff time, City Attorney support, software configuration, hearing officer services, and development of forms and public information materials. There may also be costs associated with staff training and financial collection procedures.

The ongoing program will create administrative costs related to citation and order processing, hearings, inspection, recordkeeping, and collections. The ordinance may authorize recovery of eligible enforcement costs from responsible parties. Administrative penalties would serve a compliance and deterrence function, while cost-recovery charges would be intended to reimburse

documented Town expenses. The program should not be viewed primarily as a revenue source; its purpose is to improve compliance, reduce avoidable General Fund subsidies associated with prolonged enforcement, and provide an efficient alternative to more costly proceedings.

Staff will return with a more detailed estimate when the draft ordinance and implementation structure are presented for Council consideration.

ENVIRONMENTAL REVIEW:

This item is not a project under the California Environmental Quality Act pursuant to CEQA Guidelines Section 15378 because it involves organizational and administrative activities that will not result in a direct or reasonably foreseeable indirect physical change in the environment.

ATTACHMENTS:

1. Palo Alto Code Excerpts
CHAPTER 1.12 ADMINISTRATIVE PENALTIES - CITATIONS*
CHAPTER 1.16 ADMINISTRATIVE COMPLIANCE ORDERS*

2. East Palo Alto Code Excerpts
TITLE 1 - GENERAL PROVISIONS | CODE OF ORDINANCES | EAST PALO ALTO, CA | MUNICODE LIBRARY

3. Rohnert Park Code Excerpts
TITLE 1 - GENERAL PROVISIONS | CODE OF ORDINANCES | ROHNERT PARK, CA | MUNICODE LIBRARY

TOWN OF LOS ALTOS HILLS August 20, 2026
Staff Report to the City Council
SUBJECT: RECEIVE AN INFORMATIONAL REPORT ON THE TOWN’S RULE 20A PROJECT AND PROVIDE DIRECTION ON THE REMAINING RULE 20A

CREDITS
FROM: WooJae Kim, Public Works Director/City Engineer
APPROVED: Cody Einfalt, City Manager
RECOMMENDATION: That the City Council:

Staff recommend that the City Council receive an informational report on the Town’s Rule 20A project and provide direction on the remaining Rule 20A credits.

BACKGROUND:

In 1967, the California Public Utilities Commission (CPUC) established the overhead utility conversion program known as Electric Rule 20 to support utility undergrounding projects initiated by local communities. Under Rule 20A, cities and counties may utilize Rule 20A work credits, funded by PG&E ratepayers, to finance the conversion of overhead utility facilities to underground facilities within locally established Underground Utility Districts (UUDs).

Since the program’s inception, the Town has utilized Rule 20A to complete utility undergrounding projects at Byrne Preserve, Purissima Park, and, most recently, along El Monte Road, Elena Road, and Moody Road as part of the El Monte Fire Station Utility Undergrounding (Rule 20A) Project.

On June 20, 2019, the City Council adopted Resolution No. 40-19 (Attachment 1), approving the formation of a UUD in the vicinity of the El Monte Fire Station along El Monte Road, Elena Road, and Moody Road. These roadways serve as emergency evacuation routes for the Town.

As of February 28, 2021, the Town had accrued $304,871 in Rule 20A work credits. On April 28, 2021, the City Council authorized the purchase and transfer of $4,323,712 in Rule 20A credits from the County of Mariposa, County of Trinity, and City of Willows to support the Town’s Rule 20A UUD projects. The credits were acquired for a negotiated purchase price of $2,012,240, allowing the Town to obtain approximately $1.00 of Rule 20A credit for $0.45 to $0.50.

In CPUC Decision 21-06-013, CPUC directed utility companies to discontinue allocating new Rule 20A work credits effective December 31, 2022, and prohibited the borrowing of future credits. Local governments were permitted to retain and utilize previously accrued credits.

Subsequently, in June 2023, CPUC issued Decision 23-06-008, establishing a sunset date of December 31, 2033, as the expiration date for all unused Rule 20A credits.

ITEM 8B
REVISED and DISTRIBUTED 08.19.2026

Staff Report to City Council Page 2
Remaining Rule 20A Work Credits
August 20, 2026
As of December 31, 2022, the Town had accumulated a total of $4,656,261 in Rule 20A work credits.

On April 15, 2024, the City Council approved the Plans and Specifications for the El Monte Fire Station Utility Undergrounding (Rule 20A) Project and authorized staff to advertise the project for public bidding. Following the formal bidding process, Phoenix Electric Company was selected as the lowest responsible bidder and awarded the construction contract. Construction began on June 26, 2024. Construction management and inspection services were provided by Sanbell and S.R.

Rose Engineering (SREI), in coordination with Town Public Works staff.

On December 9, 2025, the City Council adopted Resolution No. 86-25 (Attachment 2), accepting the El Monte Fire Station Utility Undergrounding (Rule 20A) Project, constructed by Phoenix Electric Company, as complete. In January 2026, AT&T and Comcast completed the removal of utility poles within the project area, marking the completion of the Rule 20A undergrounding work.

DISCUSSION:

The El Monte Rule 20A Project installed approximately 3,000 linear feet of joint utility trench along Moody Road, Elena Road, and El Monte Road and facilitated the removal of 18 utility poles.

The following cost breakdown summarizes the costs associated with the undergrounding work, including design and construction, project management, construction inspection, PG&E’s undergrounding costs, and separate undergrounding costs incurred by AT&T and Comcast.

Funded By
Cost Breakdown
Descriptions
PG&E
(Rule
20A)
AT&T Comcast Town Total
Joint Trench Construction by
the Town's contractor $1,718,892 $1,312,259 $1,087,318 $1,020* $4,119,489 COSTS REIMBURSED TO TOWN Joint Trench Design by the Town's design team $84,154 $84,154 $84,154 $252,462
Town's Project/Construction
Management $190,510 $190,510 $190,510 $571,530
PG&E Cost for Pulling
Wires and Service
Conversion
$1,869,291 $1,869,291 COSTS TO UTILITIES Estimated AT&T Cost (borne by AT&T)
$413,076 $413,076
Estimated Comcast Cost
(borne by Comcast)
$173,480 $173,480
Total Cost $3,862,847 $1,999,999 $1,535,462 $1,020* $7,399,328 Centerline Length of Road
Undergrounded 3,000 Linear Feet

Staff Report to City Council Page 3
Remaining Rule 20A Work Credits
August 20, 2026
Avg. Cost per Length of
Road Undergrounded $2,466 per Linear Feet
Notes:
*Town cost of $1,020 was for Contract Change Order #5 to change the retaining wall system color, which was not covered by Rule 20A credits.

Based on project cost data, the total cost of undergrounding the project area within the UUD was approximately $2,466 per linear foot of roadway, including costs incurred separately by AT&T and Comcast in addition to the costs funded through Rule 20A work credits. Had the El Monte Fire Station Utility Undergrounding Project not been implemented as a Rule 20A project, the Town would have been responsible for funding the full cost of the undergrounding work.

Per the Rule 20A program requirements, eligible joint-trench and other approved Town undergrounding costs are reimbursed through the Town’s Rule 20A work credits, while costs associated with utility relocations are funded by Comcast and AT&T through their respective utility relocation programs.

The Town incurred approximately $4,942,461 in consultant and contractor costs for the Rule 20A Project. PG&E, AT&T, and Comcast have reimbursed the Town a total of $5,050,738 toward the project costs. As part of the final invoice submitted to PG&E prior to project closeout, PG&E authorized the Town to include additional amounts for potential contingencies.

The following table provides a breakdown of the estimated final project costs and the amounts allocated to each utility:

Project Reimbursements to Town by Utilities
Reimbursements PG&E AT&T Comcast Total
Amount Billed/Paid $2,101,833 $1,586,923 $1,361,982 $5,050,738 Town’s Remaining Rule 20A Credits
Prior to implementation of the Town’s Rule 20A Project, the Town had a Rule 20A work credit balance of $4,656,261. The project utilized $3,971,124 in Rule 20A credits, resulting in a remaining credit balance of $685,137. The Rule 20A account summary is provided below:

CIP/General Fund Rule 20A Credits
Available Project Funding $300,000 $4,656,261
Amount Billed by Town $1,020 $2,101,833
Amount Billed by PG&E for work
performed by PG&E $1,869,291
Balance $298,979 $685,137
The Town’s Rule 20A work credit balance prior to the purchase of $4,323,712 in credits from other jurisdictions was $332,549. Accordingly, of the remaining $685,137 in Rule 20A credits,

Staff Report to City Council Page 4
Remaining Rule 20A Work Credits
August 20, 2026
approximately $352,588 represents credits acquired through the Town’s purchase from other jurisdictions.

Because the Town purchased these credits at approximately 47 cents per dollar of credit, the Town’s actual cost for the $352,588 in purchased credits was approximately $165,716. If the Town does not utilize the remaining Rule 20A work credits before they expire, the Town would forfeit the full $685,137 in credits, including the approximately $165,716 in funds previously spent to acquire the purchased portion of the credits.

Rule 20A
Credit
Rule 20A
Credit Town Cost Rule 20A Remaining Town Cost
Accrued $332,549 $0 $332,549 $0
Purchased $4,323,712 $2,032,145 $352,588 $165,716
Options for Remaining Rule 20A Credits
Rule 20A work credits are not funded by PG&E ratepayers in advance. Instead, PG&E ratepayers are assessed for eligible undergrounding costs after Rule 20A credits are utilized. Therefore, PG&E ratepayers would not be responsible for any Rule 20A work credits that remain unspent when the program sunsets.

Staff have been communicating with PG&E’s Rule 20A program staff to explore options for using the Town’s remaining $685,137 in Rule 20A work credits. Based on these discussions, staff has identified the following three options for Council consideration and direction.

Option 1 – Pursue Additional Utility Undergrounding Project The Town could use its remaining Rule 20A credits to remove three utility poles and underground approximately 300 linear feet of overhead utilities along Elena Road near the Becky Lane intersection. A conceptual design is included as Attachment 3.

PG&E prioritizes Rule 20A undergrounding projects based generally on the chronological order of the applicable UUD formation resolutions. There are currently approximately 165 undergrounding projects in PG&E’s project queue. Because the proposed project is located within the existing UUD established by the Council in 2019, it could potentially be placed in the queue based on the 2019 UUD resolution date rather than being placed at the end of the queue.

The estimated cost of the proposed project is approximately $650,000, which is within the Town’s remaining $685,137 Rule 20A work credit balance. The conceptual cost estimate is included as Attachment 4.

However, the proposed 300-foot undergrounding segment does not meet PG&E’s current minimum project length requirement of 600 feet and therefore may not qualify as a standalone Rule 20A project. The Town could evaluate extending the proposed undergrounding to at least 600 feet to meet the minimum project length requirement. Extending the project would increase

Staff Report to City Council Page 5
Remaining Rule 20A Work Credits
August 20, 2026
the overall project cost, and the Town could be responsible for costs exceeding the remaining $685,137 Rule 20A credit balance. Based on the El Monte Rule 20A Project cost of approximately $2,466 per linear foot, each additional 100 linear feet could add approximately $246,600 to the project cost, although actual costs would depend on project-specific conditions.

Even if PG&E agrees to place the project in its work plan queue, there is no guarantee that the project would be constructed and completed before the Rule 20A program sunset date of December 31, 2033.

In addition, any costs incurred before construction, such as design and project management, would be the responsibility of the agency incurring those costs, if the Rule 20A undergrounding project is not approved for construction. If the Town elects to pursue an additional project, it may therefore be advantageous for PG&E to serve as the trench lead and be responsible for project design and implementation. For the El Monte Fire Station Utility Undergrounding Project, the Town elected to serve as the trench lead to maintain greater control over the project scope and schedule.

Option 2 – Donate Credits to Santa Clara County
The Rule 20A program allows local agencies to donate their remaining work credits to an undergrounding project within their home county. If the Town does not pursue an additional undergrounding project, it could elect to transfer its remaining credits to Santa Clara County for use on an eligible undergrounding project.

If the Town does not specifically designate the credits for use within Santa Clara County, the credits may otherwise be transferred to another eligible project within PG&E’s service territory, subject to the applicable Rule 20A program requirements.

Since the CPUC established the Rule 20A program sunset, some local agencies have elected to transfer their remaining credits rather than pursue new undergrounding projects. For example, in May 2024, the Town of Woodside elected to transfer its remaining $663,748 in Rule 20A work credits to San Mateo County to support an active undergrounding project.

This option would allow the Town to provide a local benefit by directing its remaining credits to an undergrounding project within Santa Clara County without undertaking a new project itself.

Option 3 – Take No Action at This Time
Under this option, the Town would retain the remaining Rule 20A work credits and take no immediate action while awaiting further direction from PG&E regarding the disposition of unused credits before the December 31, 2033 sunset date.

Based on discussions with PG&E staff, unused credits may ultimately be forfeited or potentially transferred to another agency or eligible project, depending on the final disposition established by CPUC.

Staff Report to City Council Page 6
Remaining Rule 20A Work Credits
August 20, 2026
Because a portion of the Town’s remaining credits was acquired through the purchase of credits from other jurisdictions, the Town could potentially consider pursuing a legal claim with the CPUC to recover the cost associated with those purchased credits if they are ultimately forfeited. Such a claim could involve additional legal costs, an extended process, and no guarantee of recovery.

Under this option, the Town would preserve its existing credits while continuing to monitor developments regarding the Rule 20A program and the final disposition of unused credits ENVIRONMENTAL REVIEW:

Rule 20A projects generally fall under Class 1 categorical exemption per Article 19 (Categorical Exemptions) section 15301(b) Existing Facilities of the California Environmental Quality ACT (CEQA) guidelines for private and public owned utilities used to provide electric power or other public utility services.
2026-27 CITY COUNCIL WORK PLAN:

This action is identified on the 2026-27 City Council Work Plan under Public Works Department for “Underground Utilities – Rule 20A (Phase 2)” to determine the scoping for the phase 2 project to use the remaining Rule 20A credits.

FISCAL IMPACT:

As discussed above, the Town has $685,137 in remaining Rule 20A work credits. If the Town wishes to utilize these credits for a local undergrounding project, one potential option is to further underground along Elena Road. However, to qualify as a new Rule 20A project, up to 600 linear feet of segment would need to be undergrounded, and the Town may be responsible for any costs over the remaining Rule 20A balance, which can be approximately $740,000.

Alternatively, the Town decides to transfer or forfeit the remaining Rule 20A credits, that would result in the Town foregoing approximately $165,716 in funds previously spent to acquire the remaining purchased credits.

ATTACHMENTS

1. Resolution No. 40-19

2. Resolution No. 86-25

3. Potential Undergrounding Project Option

4. Probable Cost Estimate of the Project Option

RESOLUTION 40- 19
RESOLUTION OF THE CITY COUNCIL OF :THE TOWN OF LOS ALTOS HILLS

FOR THE FORMATION OF AN UNDERGROUND UTILITY DISTRICT IN THE

AREA AROUND THE EL MONTL FIDE STATION
WHEREAS, the California Public Utilities Commission ( CPUC) has authorized electric and telecommunication utilities to convert overhead utility lines and facilities to underground pursuant to Electric Rule 20 and Telecommunication Rule 32; and WHEREAS, pursuant to certain criteria, CPUC rules allow participating cities and counties to establish legislation authorizing the creation' of underground utility districts within which existing overhead electric distribution and telecommunication distribution and service facilities will be converted to underground; and
WHEREAS, the Town of Los Altos Hills, has adopted an ordinance, codified as Chapter 3 UNDERGROUND UTILITY DISTRICTS under Title 7 Public Works in the Town of Los Altos Hills Municipal Code, authorizing the City Council to designate -areas within which all existing overhead. poles, overhead wires and overhead equipment associated with the distribution of electric power, telecommunication services and cable television should be removed and replaced with underground wires and facilities; and WHEREAS, the Town in consultation with the Los Altos Hills County Fire District ( Fire District) has determined that the public necessity, health, safety, or welfare requires undergrounding the existing overhead utilities and removal of the utility poles in the area around the El Monte Fire Station. would allow the Town to maintain an unobstructed emergency route that would otherwise be blocked if the roadways were blocked by fallen utility poles; and
WHEREAS, the Director ofPublic Works for the Town, -of Los Altos Hills has consulted with the affected public utilities and such utilities have agreed that the proposed underground conversion district, designated an Underground Utility District in the area around the El Monte Fire Station and more particularly described in Exhibit A attached hereto and incorporated herein by reference, meets the criteria established by the rules of the CPUC, to wit, That the street or road or right- of-way is extensively used by the general public and carries a heavy volume of pedestrian or vehicular traffic, and That the street or road or right-of-way is considered an arterial street or major collector as - defined in the Governor' s Office of Planning and Research General Plan Guidelines, and
WHEREAS, each year the Town. of Los Altos Hills is notified by PG& E regarding the allocation of work credits for conversion of overhead electric distribution lines and facilities to underground, known as Rule 20A allocations; and
Resolution 40- 19 Page 1
ITEM 8B Attachment 1

WHEREAS, the Director of Public Works for Town of Los Altos Hills has consulted with PG& E and determined that the City has accumulated Rule 20A work credits and PG& E has agreed that the City may borrow against future credits as part of the funding required for the proposed overhead to underground conversion project; and .

WHEREAS, the Town of Los Altos Hills and the affected utilities have agreed that each utility shall complete the engineering of their respective portion of the Overhead to Underground Utility Conversion Project in the area around the El Monte Fire Station; and WHEREAS, the Town of Los Altos Hills and the affected utilities have agreed that PG& E shall be responsible for preparation of the trench profile and composite drawings and that PG& E shall be designated as " trench lead" to manage trenching, installation of substructures, and pavement restoration and such other work; and
WHEREAS, the City Council of the Town of Los Altos Hills has now received the report from the Director ofPublic Works recommending that the area identified in Exhibit A should. be designated as an underground utility district within which all existing overhead poles, overhead wires and overhead equipment associated with the distribution of electric power, telecommunication services and cable television should be removed and replaced with underground wires and facilities; and
WHEREAS, upon the recommendation of the Director of Public Works, the City Council of the Town of Los Altos Hills has determined that the proposed Underground Utility District in the area around the El Monte Fire Station is categorically exempt from environmental review pursuant to the California Environmental Quality Act; and WHEREAS, the Town of Los Altos Hills has notified all affected property owners within the proposed Underground Utility District in the area around the El Monte Fire Station and inviting same to attend a public hearing to discuss formation of the proposed district; and WHEREAS, the City Council of the Town of Los Altos Hills held public hearings at which time the Council did receive and consider the recommendation of the Director of Public Works and did hear any and- all objections or protests that were raised by the owners of property Within the. above described district pertaining to designating this area an underground utility district;
NOW, THEREFORE, the City Council of the Town of Los Altos Hills does RESOLVE as follows:

SECTION 1. The public interest requires the removal of all existing utility poles, excepting those poles supporting streetlights or traffic signals, if applicable, overhead wires and associated overhead structures and installation of underground wires and facilities for supplying electric power, communication, or similar associated services within the areas as shown in Exhibit A, attached hereto, with such area being designated as the Underground Utility District in the area around the El Monte Fire Station; and Resolution 40- 19 Page . 2

SECTION 2. That the utility companies, cable television services and other affected services shall commence work on installation of underground facility installation in Underground Utility District in the area around the El Monte Fire Station and that as each phase ofthe project is complete and ready for conversion from overhead to underground utility facilities, all fronting property owners shall be notified, of the schedule for conversion of utility service lines; and
SECTION 3. The electric utility shall use the underground conversion allocation computed pursuant to decisions of the California Public Utilities Commission for the purpose of providing to each premises requiring it in an Underground Utility District in the area around the El Monte Fire Station a maximum of one hundred feet of individual electric service trenching and conductor ( as well as backfill, paving and conduit, if required) and each other serving utility shall provide service trenching and conductor in accordance with its rules and tariffs on file with the California Public Utilities Commission or as. required by its Franchise Agreement with the Town of Los Altos Hills, and
SECTION 4. The electric utility shall use said underground conversion allowance allocation, up to a maximum amount of $1500 per service entrance excluding permit fees, for the conversion of electric service panels to accept underground service in the Underground Utility District in the area around the El Monte Fire Station, and each property owner shall be financially responsible for any and all costs not covered by the electric utility for the installation and maintenance of the conduit and termination box located on, under or within any structure on the premises served pursuant to Section 7- 3. 09 of the Los Altos Hills Municipal Code; and
SECTION 5. That upon notification as specified in Section 2, all property owners in an Underground Utility District in the area around the E1 Monte Fire Station shall have underground electrical entrance facilities installed and inspected pursuant to the Town of Los Altos Hills Electrical Code and Chapter 3 UNDERGROUND UTILITY DISTRICTS under Title 7 Public Works in the Town of Los Altos Hills Municipal Code; and SECTION 6. That upon completion of the underground distribution system, the electrical utility is authorized to discontinue overhead electric service in the Underground Utility District; and
SECTION 7. That once all services have been converted from overhead to underground, the utility companies, cable television services and other affected services shall remove all poles ( except as specified above) and associated overhead facilities in an Underground Utility District in the area around the El Monte Fire Station, by approximately December 31, 2027.

The above and foregoing Resolution was passed and adopted by the City Council ofthe Town of Los Altos Hills at a regular meeting held on the 20th day of June 2019 by the following vote:

Resolution 40- 19 Page 3

AYES: Spreen, Wu, Corrigan, Tankha, Tyson
NOES: None
ABSTAIN: None
ABSENT: None
BY:
ger Spr en, Mayor
ATTEST:

Deborah Padovan, City Clerk
Resolution 40- 19 Page 4

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Resolution 40- 19 Page 5

RESOLUTION 8625

RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS

ACCEPTING THE EL MONTE FIRE STATION UTILITY UNDERGROUNDING ( RULE 20A) PROJECT PERFORMED BY PHOENIX ELECTRIC COMPANY AS COMPLETE; AUTHORIZING_,THE RELEASE OF FINAL RETENTION TO THE CONTRACTOR; AND

DIRECTING THE CITY CLERK TO FILE A NOTICE OF COMPLETION WHEREAS, Rule 20A underground program allows cities and counties to utilize Rule 20A work credits to fund utility undergrounding projects at locally identified underground districts; and WHEREAS, the City Council adopted Resolution No. 4049 on June 20, 2019, approving the formation of an Underground Utility District ( UUD) around the El Monte Fire Station; and WHEREAS, the El Monte Fire Station Undergrounding ( Rule 20A) Project was added to the Five - Year Capital Budget on June 20, 2020, and Town hired Sanbell ( formerly known as Bellecci and Associates) in October 2020 to prepare the undergrounding composite plans and to assist with the coordination with PG& E and other utility companies; and WHEREAS, on April 15, 2024, the Town Council approved the Plans and Specifications for the project, authorized staff to advertise the project for a formal bid, and authorized the City Manager to award a construction contract to the lowest responsible bidder not to exceed $ 4,200,000, including a contingency fund for potential change orders; and
WHEREAS, after a formal bid process for construction of the project, Phoenix Electric Company Phoenix) was determined to be the lowest responsible bidder, and the construction agreement with Phoenix was executed on June 3, 2024, for $ 3, 868, 742. 50; and WHEREAS, construction started on June 26, 2024, and the work was completed under the terms of the contract on November 4, 2025; and
WHEREAS, the total project expenditure for the contracted work by Phoenix Electric Company is 4, 119, 489, which is below $4,200, 000, the amount authorized by the Town Council; and WHEREAS, staff recommend that the City Council accept the El Monte Fire Station Undergrounding Rule 20A) Project performed by Phoenix Electric Company as complete and allow the remittance of the five percent retention to the contractor 35 days following the project acceptance.

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

1. The El Monte Fire Station Utility Undergrounding ( Rule 20A) Project by Phoenix Electric Company is accepted as complete; and

2. - Staff- is -authorized - to -make -the -final -retention payment- concerning theabove- described- - work; and

3. The City Cleric is hereby directed to file the notice of the completion of said project with the County Recorder of the County of Santa Clara, within ten ( 10) days from the date of this Resolution,•
RESOLUTION 86- 25 11 P a g e
ITEM 8B Attachment 2

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the 9th day of December 2025 by the following vote:

AYES: TANKHA, BHATEJA, MOK, SWAN, TYSON
NOES: NONE
ABSTAIN: NONE
ABSENT: NONE
ATTEST:
1 ika Birdsong -Miller, Gi Clerk
BY:/ A" L.4-
Kavita Tankha, Mayor
RESOLUTION 86- 25 2 1 P a g e

This Document is Recorded for the
Benefit of the Town , cif Los Altos Hills
and is Exempt from fee per Government
Code Sections 6103 and. 27383
When Recorded, Mail to:

Attention: City Clerk y
Town of Los Altos Hills
26379 Fremont Road .

Los Altos Hills. CA 94022.

NO' T' ICE OF COMPLETION
NOTICE IS HEREBY GIVEN that Phoenix Electric Company on June 3, 2024, entered into a contract for the El Monte Fire Station Utility Undergrounding ( Rule 20A) Project, in Los Altos Hills, situated in Santa Clara County, with the Town of Los Altos Hills. Said improvements were completed in accordance with the Plans and Specifications adopted by the City Council and upon the terms and conditions set forth and identified by the written contract.

On the 9th day of December 2025, the work provided to be done under the contract was accepted as fully completed within the terms of the contract.

NOTICE IS FURTHER GIVEN that the public board for whom the above- described work was done is the City Council of the Town of Los Altos Hills, a municipal corporation of the State of California, and that the name and address of the political subdivision for which the above- described work was done is the Town of Los Altos Hills, State of California, Town Hall, 26379 Fremont Road, Los Altos Hills, California 94022.

NOTICE IS FURTHER GIVEN that the name of the contractor by whom the above- described work was done is as follows:

CONTRACTOR: Phoenix Construction
WooJae Kim
Public Works Director/Town Engineer
Town of Los Altos Hills
DATE

f
I, Arika Birdsong -Miller, duly appointed City Cleric for the Town of Los Altos Hills, do hereby certify under PENALTY OF PERJURY under the laws ofthe State of California that the foregoing is true and correct. r
WITNESS my hand and official seal.

Arika Birdsong - Miller, City Clerk
Date:

Place: Town Hall
Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022

No. Bid Item Description Qty Unit Unit Cost Total Cost PG&E Allocated Cost
AT&T Allocated
Cost
Comcast
Allocated Cost
1 $ 584,190 $ 244,797 $ 181,697 $ 157,697

1.1 Mobilization 1 LS $ 22,840 $ 22,840 $ 7,613 $ 7,613 $ 7,613

1.2 Traffic Control System 1 LS $ 30,000 $ 30,000 $ 10,000 $ 10,000 $ 10,000

1.3 Stormwater Pollution Prevention 1 LS $ 8,250 $ 8,250 $ 2,750 $ 2,750 $ 2,750

1.4 PG&E Conduits 960 LF $ 20 $ 19,200 $ 19,200 $ - $ -

1.5 AT&T Conduits 1,250 LF $ 18 $ 22,500 $ - $ 22,500 $ -

1.6 Comcast Conduits 950 LF $ 18 $ 17,100 $ - $ - $ 17,100

1.7 PG&E Vaults 4 EA $ 25,000 $ 100,000 $ 100,000 $ - $ -

1.8 AT&T Vaults 4 EA $ 8,400 $ 33,600 $ - $ 33,600 $ -

1.9 Comcast Vaults 6 EA $ 2,500 $ 15,000 $ - $ - $ 15,000

1.1 Joint Trench with Surface Restoration 700 LF $ 370 $ 259,000 $ 86,333 $ 86,333 $ 86,333

1.11 Service Conversion 1 EA $ 12,500 $ 12,500 $ 4,167 $ 4,167 $ 4,167

1.12 Microsurfacing 1 LS $ 15,100 $ 15,100 $ 5,033 $ 5,033 $ 5,033

1.13 Signing and Striping 1 LS $ 9,100 $ 9,100 $ 3,033 $ 3,033 $ 3,033

1.14 Miscellaneous 1 LS $ 20,000 $ 20,000 $ 6,667 $ 6,667 $ 6,667 2 $ 97,000 $ 32,333 $ 32,333 $ 32,333
3 $ 150,000 $ 50,000 $ 50,000 $ 50,000
4 $ 238,000 $ 238,000 $ - $ -
5 $ 52,420 $ - $ 52,420 $ -
6 $ 22,020 $ - $ - $ 22,020
$ 171,545 $ 84,770 $ 47,468 $ 39,308
$ 1,315,200 $ 650,000 $ 363,918 $ 301,358
$ 685,137
15% Contingency
2026 Estimated Project Total
Rule 20A Work Credit Balance as of March 2026

TOWN OF LOS ALTOS HILLS

POTENTIAL OPTION

CONCEPT LEVEL OPINION OF PROBABLE COST ESTIMATE
April 10, 2026
Joint Trench Construction
Joint Trench Design
Construction Management and Inspection
Estimated Cost for AT&T's Work
Estimated Cost for PG&E's Work
Estimated Cost for Comcast's Work
ITEM 8B Attachment 4

2 These internal costs represent a significant component of the true fiscal impact of the El Monte Station Rule 20A undergrounding project.

Importantly, the roughly $500,000 to $800,000 in internal expenses were not reimbursed by Rule 20A credits and should be recognized in addition to the $2,032,145 the Town spent to purchase the credits used to partially fund the project.

The Fiscal Impact section of the staff report contains a typo: it refers to “6,000 feet” when it should state “600 feet.”
“As discussed above, the Town has $685,137 in remaining Rule 20A work credits. If the Town wishes to utilize these credits for a local undergrounding project, one potential option is to further underground along Elena Road. However, to qualify as a new Rule 20A project, up to 6,000 linear feet of segment would need to be undergrounded, and the Town may be responsible for any costs over the remaining Rule 20A balance, which can be approximately $740,000.” When internal personnel and overhead costs are included, the Town’s total cost exposure for a new 600-foot undergrounding segment would likely approach $1 million. Given the limited incremental safety benefit of extending undergrounding along Elena or Moody Road by two or three power poles, it is unlikely that the time and expense and many year staff effort required for a new Rule 20A project would be justified.

For context, the original project scope was 4,500 linear feet but was reduced during the process to 3,000 feet due to concerns about insufficient Rule 20A funding.

Thank you.

Best,
Allan

ITEM 8C
TOWN OF LOS ALTOS HILLS August 20, 2026
Staff Report to the City Council
SUBJECT: RESOLUTION AUTHORIZING THE ISSUANCE OF A REQUEST

FOR PROPOSALS FOR CITY ATTORNEY LEGAL SERVICES
FROM: Cody Einfalt, City Manager
RECOMMENDATION: That the City Council Should:

Adopt a resolution (Attachment 1) authorizing the City Manager to issue and advertise the Request for Proposals (RFP) for Town Attorney Legal Services.

BACKGROUND:

The Town of Los Altos Hills has historically contracted with outside law firms to provide City Attorney services. The City Attorney is appointed by, reports to, and serves at the pleasure of the City Council and functions as the Town’s chief legal advisor. The City Attorney works closely with the City Council, City Manager, and Town staff on the broad range of legal issues associated with municipal operations.

In preparation for a competitive solicitation of legal services, staff prepared a draft RFP using the Town’s established procurement format and reviewing recent legal-services solicitations from comparable California municipalities. Staff has also been working with the Council Ad Hoc Committee to review the proposed scope of services, qualifications, fee structure, and selection process. The proposed RFP is included as Attachment 2.

The purpose of the August 20 action is to authorize release of the RFP and begin the competitive process. Approval of the resolution would not select a law firm or approve a Legal Services Agreement. The City Council would retain responsibility for interviewing finalists, selecting the preferred firm and designated City Attorney, and considering the final agreement at a subsequent meeting.

DISCUSSION:

The proposed RFP is intended to provide the Town with a structured process to evaluate qualified municipal law firms based on experience, responsiveness, approach, staffing, availability, cost, and overall fit with Los Altos Hills. Key provisions of the proposed solicitation are summarized below.

Scope of Services and Service Expectations
The RFP seeks a full-service California municipal law firm capable of designating an experienced attorney to serve as the City Attorney. The proposed City Attorney would serve as the primary legal advisor to the City Council and work closely with the City Manager and Town departments.

The requested scope includes, among other things:

Staff Report to City Council
Authorize RFP for Town Attorney Legal Services
August 20, 2026
2 • General municipal law, the Brown Act, Public Records Act, conflicts of interest, ethics, elections, contracts, ordinances and resolutions.
• Land use, planning, housing law, CEQA, code enforcement, grading and hillside development, geotechnical issues, easements, pathways, rights-of-way, and real property matters.
• Public works contracting, procurement, taxes, fees, assessments, Proposition 218, employment and labor matters, risk management, claims and litigation coordination. • Attendance at City Council meetings and Planning Commission meetings as requested, regular on-site availability at Town Hall, timely response to Council and staff, and reliable backup coverage when the designated Town Attorney is unavailable. • Monitoring significant changes in state and federal law and proactively advising the Town regarding legal risks, compliance requirements, and available options.

The RFP also recognizes that the Town may continue to use separate or specialized counsel for particular matters, including conflicts, litigation, labor and employment, code enforcement, or other specialized areas. The selected City Attorney would be expected to coordinate with such counsel and help avoid duplication of effort and cost.

Proposal Requirements and Pricing
Proposers would be required to identify the attorney proposed to serve as City Attorney, a primary backup attorney, and the supporting legal team. The RFP requests information regarding municipal experience, current public-agency commitments, workload capacity, potential conflicts of interest, references, prior municipal engagements, transition approach, and the firm’s methods for controlling legal costs.

The RFP is designed to allow the Town to evaluate both qualifications and cost on a comparable basis. Firms may propose a monthly retainer/hybrid structure, an hourly model, or another clearly described alternative; however, each proposer is asked to provide sufficient detail regarding retainer services, hourly rates, specialized or litigation rates, billing increments, reimbursable expenses, proposed annual rate adjustments, and services that would be excluded from the base fee. The RFP also requests a 30/60/90-day transition plan to demonstrate how the firm would assume responsibility for ongoing legal matters while preserving institutional knowledge and continuity of service.

Evaluation and Selection
The proposed evaluation process emphasizes demonstrated municipal law qualifications and fit with the Town rather than price alone. The anticipated evaluation criteria are:

Evaluation Criterion Weight
Municipal law qualifications and relevant experience 25% Understanding of the Town and proposed approach to service 20% Proposed City Attorney/team, responsiveness, availability, and continuity 15% Fee structure, cost-control approach, and overall value 15%

Staff Report to City Council
Authorize RFP for Town Attorney Legal Services
August 20, 2026
3 Evaluation Criterion Weight
References, professional reputation, integrity, and conflict considerations 10% Interview / presentation 15%
Following an initial responsiveness review and evaluation of written proposals, the Town anticipates inviting a short list of the most qualified firms to interview with the City Council. The City Council would make the final selection and direct staff to negotiate the proposed Legal Services Agreement. If satisfactory terms cannot be reached with the preferred proposer, the Town may discontinue negotiations and proceed to another qualified proposer.

Proposed Schedule
The RFP provides a full five-week advertisement period for firms to prepare proposals. Following the proposal deadline, the revised schedule intentionally provides additional time for preliminary review, Town Council interviews, background and reference checks, due diligence, and agreement discussions before the anticipated November 19, 2026 consideration of appointment and agreement. The proposed schedule is as follows:

RFP Event Date
City Council authorization to issue RFP Thursday, August 20, 2026 Town issues RFP Friday, August 21, 2026
Optional Notice of Intent / deadline for written questions Intent: Friday, September 4, 2026;
Questions: Friday, September 11, 2026,
4:00 p.m.

Town issues responses / addenda Wednesday, September 16, 2026 Deadline for receipt of proposals Friday, September 25, 2026, 4:00 p.m.

Preliminary evaluation / initial background and reference checks September 28-October 9, 2026 Town Council finalist interviews October 12-23, 2026
Additional background/reference checks, due diligence, and contract discussions October 26-November 13, 2026
Council consideration of appointment and agreement Thursday, November 19, 2026 Transition / commencement of services To be negotiated
The proposed resolution authorizes the City Manager to make minor, non-substantive adjustments to the RFP schedule if necessary to administer the solicitation. The extended post-submittal review period is intended to give the City Council adequate time to evaluate finalists and complete appropriate background, reference, conflict, and professional-history due diligence before a final appointment is considered. Any material change to the scope of services or selection authority would remain with the City Council.

Staff Report to City Council
Authorize RFP for Town Attorney Legal Services
August 20, 2026
4 ANALYSIS
Staff recommends proceeding with the RFP because a competitive process will allow the City Council to evaluate the market for municipal legal services and directly compare the qualifications, proposed staffing, availability, service model, and pricing of interested firms. The process is also structured to focus on the individual attorney proposed to serve Los Altos Hills, rather than the reputation of the firm alone.

Issuance of the RFP does not obligate the Town to select any proposer or to accept the lowest-cost proposal. The Town reserves the right to reject any or all proposals, seek clarification, modify the schedule, and negotiate with the proposer the Council determines best meets the Town’s needs.

The final appointment and Legal Services Agreement would return to the City Council for consideration before any new engagement is established.

ENVIRONMENTAL REVIEW:

Authorization to issue the RFP is an organizational and administrative activity of the Town that will not result in direct or indirect physical changes to the environment and therefore is not a project under the California Environmental Quality Act (CEQA) Guidelines Section 15378(b)(5).

CITY COUNCIL WORKPLAN:

This action supports effective municipal governance and fiscal responsibility by conducting a competitive process for a core professional service and establishing clear expectations for legal service quality, responsiveness, accountability, and cost control.

FISCAL IMPACT:

There is no significant direct fiscal impact associated with authorizing and issuing the RFP beyond staff time and routine solicitation costs, which can be absorbed within the existing operating budget. The cost of future City Attorney legal services will depend on the proposals received and the final negotiated agreement. Staff will identify the anticipated fiscal impact when the proposed Legal Services Agreement returns to the City Council for consideration.

ATTACHMENTS:

1. Resolution Authorizing Issuance of a Request for Proposals for City Attorney Legal Services

2. Request for Proposals for City Attorney Legal Services

ITEM 8C Attachment 1
RESOLUTION __ -26

RESOLUTION AUTHORIZING ISSUANCE OF A REQUEST FOR PROPOSALS FOR

CITY ATTORNEY LEGAL SERVICES
WHEREAS, the Town of Los Altos Hills is a California general law municipality, and the City Attorney is appointed by and serves at the pleasure of the City Council; and WHEREAS, the Town has historically contracted with outside law firms to provide City Attorney and municipal legal services; and
WHEREAS, the City Council desires a competitive solicitation to evaluate qualified California municipal law firms based on experience, proposed staffing, responsiveness, availability, cost, and overall value to the Town; and
WHEREAS, Town staff has prepared a Request for Proposals for City Attorney Legal Services, substantially in the form presented on August 20, 2026, with advertisement proposed from August 21 through September 25, 2026; and
WHEREAS, the proposed process provides time for proposal evaluation, finalist interviews, reference and background checks, and anticipated City Council consideration of a City Attorney appointment and Legal Services Agreement on November 19, 2026.

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

1. Approves and authorizes issuance and advertisement of the Request for Proposals for City Attorney Legal Services, substantially in the form presented on August 20, 2026; and authorizes the City Manager to administer the solicitation and make minor, nonsubstantive revisions as necessary. Final appointment of the City Attorney and approval of any Legal Services Agreement shall return to the City Council.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a Regular meeting held on 20th of August 2026 by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

By:

Rajiv Bhateja, Mayor
ATTEST:
_____
Arika Miller, City Clerk

Town of Los Altos Hills - Town Attorney Legal Services ITEM 8C Attachment 2 Town of Los Altos Hills
Request for Proposals (RFP) for
Town Attorney Legal Services
ISSUE DATE:

August 21, 2026
Deadline for Proposal Submittal:

September 25, 2026, by 4:00 p.m. Pacific Time
Cody Einfalt, City Manager
[email protected]

Town of Los Altos Hills - Town Attorney Legal Services
2 Table of Contents

1. RFP Overview 3

2. Town Background and Current Legal Services Model 4

3. Scope of Services 5

4. Minimum Qualifications 6

5. Proposal Submission Requirements 7

6. Fee Proposal and Billing Requirements 9

7. Transition and Service Expectations 10

8. Proposal Evaluation and Selection 10

9. RFP Terms and Conditions 11

10. Insurance and Contract Requirements 12
Appendix A - Fee Proposal Form 13
Appendix B - Proposal Submission Checklist 15
Attachments / Appendices:

1. Appendix A - Fee Proposal Form

2. Appendix B - Proposal Submission Checklist

Town of Los Altos Hills - Town Attorney Legal Services
3 1. RFP Overview
1A. Introduction and Purpose
1A1. The Town of Los Altos Hills ("Town") is soliciting proposals from qualified California law firms to provide comprehensive municipal legal services and to serve as the Town Attorney. The Town seeks a responsive, practical, and trusted legal partner with substantial experience advising California general law cities and towns.
1A2. The selected firm will designate a principal attorney to serve as Town Attorney. The Town Attorney is appointed by, reports to, and serves at the pleasure of the Town Council, and will work closely with the City Manager and Town staff in the day-to-day conduct of Town business. The Town Attorney and other attorneys providing services under the agreement will be independent contractors and not Town employees.
1A3. The Town anticipates entering into an initial three-year Legal Services Agreement, with options to extend by mutual agreement. Notwithstanding any stated term, the Town Attorney will continue to serve at the pleasure of the Town Council and the agreement will contain termination provisions acceptable to the Town.
1B. Town Objectives
• Obtain high-quality, practical, and timely municipal legal advice that supports informed decisionmaking by the Town Council and staff. • Maintain a strong working relationship between the Town Attorney, Town Council, City Manager, department heads, and staff while preserving the Town Attorney's independent professional judgment.
• Receive proactive advice regarding changes in law, emerging legal risks, and options for achieving Town objectives within acceptable levels of legal risk. • Control legal costs through efficient staffing, transparent billing, matter management, and appropriate use of specialized counsel.
• Ensure continuity of service through adequate firm depth, backup coverage, and an orderly transition from the incumbent legal services provider.
1C. Selection Process
1C1. Town staff and/or designated evaluators will conduct a preliminary review of proposals for responsiveness, qualifications, references, conflicts, and proposed fees. The Town may request written clarifications or additional information.
1C2. The Town Council expects to interview a short list of the most qualified proposers. Interview format and location will be communicated to finalists. The Town Council will make the final selection in its sole discretion and may direct staff to negotiate a Legal Services Agreement with the selected proposer.
1C3. If the Town is unable to reach satisfactory agreement terms with the highest-ranked proposer, the Town may discontinue negotiations and negotiate with another proposer. 1D. RFP Schedule
RFP Event Date
Town issues RFP Friday, August 21, 2026
Optional Notice of Intent to Propose Friday, September 4, 2026 Deadline to submit written questions Friday, September 11, 2026, 4:00 p.m.

Town issues responses / addenda Wednesday, September 16, 2026 Deadline for receipt of proposals Friday, September 25, 2026, 4:00 p.m.

Preliminary evaluation / initial background and reference checks September 28-October 9, 2026 Town Council finalist interviews October 12-23, 2026
Additional background/reference checks, due diligence, and contract discussions October 26-November 13, 2026
Tentative Town Council consideration of appointment and agreement Thursday, November 19, 2026

Town of Los Altos Hills - Town Attorney Legal Services
4 Following the proposal deadline, the Town anticipates a multi-week evaluation and due diligence period to allow for preliminary review, Town Council finalist interviews, background and reference checks, conflict and professional-history review, and agreement discussions before final Council consideration. The Town reserves the right, at its sole discretion, to revise this schedule. Any material changes will be communicated by addendum.
1E. RFP Coordinator and Communications
All communications, questions, requests for clarification, and proposal submissions concerning this RFP shall be directed only to:

Cody Einfalt, City Manager / RFP Coordinator
Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
Email: [email protected]
From the issue date through completion of the selection process, proposers shall not contact Town Councilmembers, other Town officials, employees, consultants, or advisors regarding this solicitation except through the RFP Coordinator or as expressly authorized by the Town. Unauthorized communications may be grounds for disqualification.
1F. Questions, Addenda, and Notice of Intent
Prospective proposers are encouraged, but not required, to submit a Notice of Intent to Propose by the date shown in Section 1D. The notice should identify the firm, the principal contact, contact information, and a brief statement of intent to submit a proposal. The Town may post addenda and written responses to questions on its website and may also distribute them to firms that submitted a Notice of Intent. Proposers are responsible for reviewing all addenda before submitting a proposal.

2. Town Background and Current Legal Services Model
2A. About the Town
The Town of Los Altos Hills is a California general law municipality incorporated in 1956 and operates under the Council-Manager form of government. Five Town Councilmembers are elected to four-year terms. The Town Council annually selects a Mayor and Vice Mayor from among its members and appoints the City Manager and Town Attorney.

Los Altos Hills is an exclusively residential, semi-rural community of approximately nine square miles in northwestern Santa Clara County, with approximately five additional square miles of adjacent unincorporated territory within or near the Town's sphere of influence. The community has approximately 8,500 residents and no traditional commercial or industrial base. Town services and infrastructure include land use planning and building regulation, engineering and public works, pathways and trails, open space, sewer infrastructure, finance, human resources, parks and recreation, code compliance, and general administration. Several major services are provided through contracts or other public agencies.

The Town's small organizational structure requires outside legal counsel to operate as an extension of the Town's executive and departmental team. The selected Town Attorney should be comfortable advising on high-visibility residential land use matters, hillside development, grading and geotechnical issues, easements and rights-of-way, pathways and trails, state housing mandates, public contracting, intergovernmental agreements, and other matters common to a highly engaged residential community. 2B. Town Council and Meeting Expectations
Regular Town Council meetings are generally held on the third Thursday of each month, with a summer recess typically occurring in July. The selected Town Attorney should anticipate attendance at all regular Town Council meetings, closed sessions, special meetings, and study sessions as requested. Attendance at Planning Commission meetings and other committees, commissions, or ad hoc bodies will be required as described in the Scope of Services or as requested by the Town.

Town of Los Altos Hills - Town Attorney Legal Services
5 2C. Current Legal Services Model
The Town has historically contracted with outside law firms for Town Attorney services. The Town may also retain separate or specialized counsel for particular matters, including conflicts, litigation, labor and employment, code enforcement, or other areas requiring specialized expertise. The selected Town Attorney will be expected to coordinate effectively with any such counsel and to protect the Town from duplicative effort and unnecessary legal expense.

3. Scope of Services
The following scope describes the Town's expected core legal services. The Town may add, delete, or modify assignments based on operational needs. Proposers should clearly identify any service they believe should be treated as specialized or outside the proposed base retainer. 3A. General Counsel and Governance
• Provide clear, concise, practical, and timely legal advice to the Town Council, City Manager, department heads, staff, and authorized boards, commissions, and committees. • Attend regular and special Town Council meetings, study sessions, and closed sessions; advise on agenda items, parliamentary procedure, procedural requirements, and legal issues that arise during meetings.
• Attend Planning Commission meetings as requested and provide legal support for land use hearings, appeals, findings, conditions of approval, and related procedural matters. • Provide guidance regarding the Ralph M. Brown Act, California Public Records Act, Political Reform Act, Government Code Section 1090, AB 1234 ethics requirements, elections law, due process, conflicts of interest, and other open-government and public integrity requirements. • Review agendas and staff reports for legal issues when requested and help staff identify legal risks early enough to permit practical solutions.
• Prepare or review ordinances, resolutions, policies, contracts, agreements, memoranda, notices, forms, leases, deeds, easements, and other legal documents; approve documents as to form when appropriate.
• Research and provide written or oral legal opinions as requested by the Town Council or City Manager.
• Provide training to Councilmembers, commissioners, committee members, and staff on municipal law topics as requested.
3B. Land Use, Housing, Environmental, and Code Matters
• Advise on general plans, zoning, subdivisions, development review, conditional use permits, variances, appeals, enforcement procedures, vested rights, exactions, takings, and other land use matters.
• Provide counsel on the California Environmental Quality Act (CEQA) and related environmental review requirements.
• Advise on state and federal housing laws, Housing Element implementation, density bonus law, accessory dwelling units, ministerial approval requirements, and other evolving housing mandates. • Provide legal review involving the Town's distinctive development standards, including hillside development, grading, geotechnical constraints, private road and trail easements, pathways, dedications, rights-of-way, and open-space issues.
• Assist with drafting and updating the Town Municipal Code, Zoning Code, and implementing regulations.
• Coordinate with specialized code enforcement counsel when retained by the Town and provide general municipal-law support for code compliance matters. 3C. Public Works, Real Property, Contracts, and Finance • Advise on public works contracting, procurement, prevailing wage requirements, bidding, construction claims, professional services agreements, and contract administration. • Provide legal services concerning property acquisition and disposition, easements, dedications, encroachments, rights-of-way, leases, licenses, and public improvements.

Town of Los Altos Hills - Town Attorney Legal Services
6 • Advise on interagency agreements, joint powers agreements, franchises, service contracts, and relationships with other public agencies and service providers. • Advise regarding taxes, assessments, rates, fees, Proposition 218, cost recovery, debt or financing matters, and other municipal finance issues as requested. 3D. Employment, Labor, Risk, Claims, and Litigation
• Provide general advice regarding public employment, personnel policies, discipline, workplace investigations, leave, wage and hour issues, pensions, and labor relations, including the MeyersMilias-Brown Act. • Advise on tort liability, risk management, claims, indemnity, insurance, and strategies to reduce municipal exposure.
• Represent, coordinate, or advise the Town in litigation and administrative proceedings not handled by the Town's risk pool or separately retained counsel, as directed by the Town Council. • Oversee and coordinate outside or special counsel, including litigation counsel, to ensure consistent strategy, effective communication, and cost control.
• Keep the Town Council and City Manager informed of significant developments in litigation and other material legal matters.
3E. Legislative Monitoring and Proactive Advice
• Monitor significant state and federal legislation, regulations, and court decisions affecting California municipalities and advise the Town of material changes. • Provide practical recommendations for policy, code, contract, or operational changes needed for compliance or risk reduction.
• Proactively identify emerging legal issues and, when appropriate, present reasonable options with an explanation of relative legal risk, cost, timing, and operational implications. 3F. Availability and Office Hours
• Provide a designated Town Attorney who will serve as the primary point of contact and who has authority within the firm to manage the Town's work and staffing. • Provide prompt responses to routine telephone and email requests, generally the same or next business day, and immediate attention to urgent matters. • Maintain regular in-person office hours at Town Hall. For proposal pricing purposes, proposers should assume approximately four to six hours of on-site availability per week, subject to final negotiation and operational needs.
• Provide reliable backup coverage when the designated Town Attorney is unavailable and an afterhours contact for urgent legal matters.

4. Minimum Qualifications
Proposals should demonstrate that the firm and proposed attorneys satisfy the following minimum or preferred qualifications. The Town may determine that equivalent experience satisfies a stated preference. • All attorneys who will provide legal advice to the Town must be active members in good standing of the State Bar of California throughout the term of the agreement. • The firm should have at least five years of substantial experience representing California municipalities. The proposed Town Attorney should preferably have at least ten years of California municipal law experience and meaningful current or recent experience serving as a city or town attorney, assistant city attorney, or equivalent municipal counsel. • Demonstrated expertise in general municipal law, open government, ethics, public records, land use and housing, CEQA, public contracting, public works, real property, employment and labor, municipal finance, risk management, and litigation oversight.
• Demonstrated ability to provide clear, concise, practical advice and to communicate effectively in public meetings with elected officials, staff, applicants, residents, and other stakeholders. • Adequate staffing depth and subject-matter resources to provide continuity, timely response, and specialized support without excessive duplication or unnecessary handoffs.

Town of Los Altos Hills - Town Attorney Legal Services
7 • Demonstrated sound judgment, integrity, professionalism, and an ability to work collaboratively while maintaining independent professional advice.
• Ability to identify and manage actual and potential conflicts of interest, including a process for prompt conflicts checks and use of conflict counsel when necessary. • Sufficient workload capacity and geographic availability to satisfy meeting, office-hour, responsiveness, and transition requirements.

5. Proposal Submission Requirements
5A. Submittal Instructions
5A1. Proposals must be received by the Town no later than 4:00 p.m. Pacific Time on Friday, September 25, 2026. Late proposals may be rejected.
5A2. Submit one electronic proposal in searchable PDF format by email to [email protected] with the subject line: "Town Attorney Legal Services RFP." If file size requires a secure file-transfer link, the proposer must coordinate delivery with the RFP Coordinator before the deadline. 5A3. Proposals should be concise and focused on the information requested. Marketing brochures and extraneous materials are discouraged. The Town recommends a proposal length of no more than 30 pages, excluding resumes, the fee proposal form, and requested attachments. 5A4. Submission of a proposal constitutes the proposer's acknowledgment that it has reviewed this RFP and all addenda and has developed an informed understanding of the requested services. Any material assumptions, exceptions, or requested contract modifications must be clearly identified. 5B. Required Proposal Format
Proposals should be organized in the following order and labeled accordingly:

1. Cover Letter

2. Table of Contents

3. Executive Summary and Service Philosophy

4. Firm Information and Background

5. Proposed Town Attorney and Legal Team

6. Relevant Municipal Experience and Qualifications

7. Approach to Service Delivery, Responsiveness, and Cost Control

8. Current Clients, Conflicts, and Professional Responsibility Disclosures

9. Transition Plan

10. Training and Legislative Support

11. References

12. Fee Proposal

13. Contract / RFP Exceptions

14. Additional Information
5C. Cover Letter
• Signed by an individual authorized to bind the firm.
• Identify the proposed Town Attorney and the principal contact for the proposal. • Provide a high-level statement of the firm's qualifications and interest in serving the Town. • Confirm that the proposal will remain valid for at least 120 days after the proposal deadline. • Confirm the firm has completed a preliminary conflict review and identify any known actual or potential conflicts requiring further analysis or waiver.
• Confirm the ability to meet the insurance requirements in Section 10 or clearly identify any requested exception.
5D. Executive Summary and Service Philosophy
Provide a concise overview of the firm's proposed approach and respond to the following:

1. Describe your view of the role of a contract Town Attorney in a small, highly engaged community.

Town of Los Altos Hills - Town Attorney Legal Services
8 2. Describe how you provide pragmatic legal advice when multiple legally permissible options carry different levels of risk.

3. Describe how you keep the Town Council and City Manager informed about significant legal matters without overwhelming the organization with unnecessary detail.

4. Describe how your firm controls legal costs, avoids duplication, staffs matters efficiently, and alerts clients when a matter is likely to exceed expected cost or scope.

5. Describe how you proactively identify legal developments or risks that may affect a municipal client.

6. Describe your approach to maintaining productive relationships with elected officials and staff while preserving independent professional judgment.
5E. Firm Information and Background
• Legal entity name, form of organization, Federal Employer Identification Number, headquarters, and office(s) that will serve the Town.
• Number of years the firm has provided municipal legal services in California and a brief organizational history.
• Number of attorneys and non-attorney support staff available to serve the Town, including municipallaw subject matter resources. • Normal business hours and the geographic location from which routine Town services will be provided.
• Any ownership, affiliate, or subsidiary relationships relevant to the proposal. 5F. Proposed Town Attorney and Legal Team
• Identify the attorney proposed to serve as Town Attorney and the attorney who will serve as primary backup.
• Provide resumes for the proposed Town Attorney, backup attorney, and other key attorneys likely to provide regular service, including education, State Bar admission, municipal appointments, years of experience, and relevant practice areas.
• Describe the expected roles of partners/shareholders, associates, paralegals, and other personnel, and how assignments will be made to control costs.
• Describe how the firm cross-trains and provides continuity during vacations, illness, emergencies, turnover, or competing client demands.
• List the current public-agency meeting commitments of the proposed Town Attorney that could affect availability for Los Altos Hills meetings.
5G. Relevant Experience and Qualifications
Describe representative experience in the areas listed below, emphasizing work for California general law municipalities and communities with characteristics or legal issues comparable to Los Altos Hills:
• General municipal governance, Brown Act, Public Records Act, ethics, conflicts, and elections. • Residential land use, zoning, planning, CEQA, housing legislation, ADUs, subdivisions, and code compliance.
• Hillside development, grading, geotechnical issues, easements, dedications, pathways/trails, rightsof-way, and real property. • Public works, procurement, contracts, franchises, and interagency agreements. • Public employment, personnel, labor relations, investigations, and pensions. • Municipal finance, fees, assessments, Proposition 218, and risk management. • Litigation, administrative proceedings, claims, and management of specialized outside counsel. 5H. Current Clients, Conflicts, and Professional Responsibility Disclosures • List all California public agencies for which the proposed Town Attorney currently serves as city/town attorney, assistant city/town attorney, general counsel, or in a comparable recurring role. • Identify any current representation that creates or could reasonably create a conflict of interest with the Town, and describe the proposed approach to resolving or managing the conflict.

Town of Los Altos Hills - Town Attorney Legal Services
9 • Identify material matters during the last five years in which the firm has been adverse to the Town of Los Altos Hills or, if relevant to anticipated Town work, the County of Santa Clara or another agency with which the Town has a significant contractual relationship. • Disclose any public State Bar discipline during the last ten years involving the proposed Town Attorney or primary backup attorney.
• Describe any termination or non-renewal of a municipal general-counsel relationship involving the proposed Town Attorney during the last five years, if material to the Town's evaluation. The Town recognizes that attorney-client confidentiality may limit the detail that can be provided. 5I. Transition Plan
Provide a practical 30/60/90-day transition plan describing how the firm would assume responsibility with minimal disruption. Address file transfer, matter inventories, deadlines, conflicts, relationships with existing special counsel, document and knowledge transfer, pending litigation or claims, and initial meetings with the Town Council, City Manager, and key staff. Identify any information or assistance the firm would need from the Town or incumbent counsel.
5J. Training and Legislative Support
Describe the types of training and legal updates the firm provides to municipal clients, including open government, ethics, conflicts, public records, land use and housing, personnel, and other new laws. Identify whether routine alerts, briefings, or client trainings are included in the proposed retainer or otherwise billed. 5K. References
Provide three to five references for comparable California municipal legal services, including at least two current or recent city/town attorney clients. The Town prefers references from smaller or similarly situated municipalities where feasible. For each reference provide: entity name; contact name and title; phone and email; scope of services; dates/duration of service; and the identity of the attorney(s) who performed the work. By submitting a proposal, the proposer authorizes the Town to contact listed references and other public clients as part of due diligence.
5L. Contract and RFP Exceptions
Clearly identify any exceptions to this RFP, requested changes to anticipated contractual terms, assumptions affecting scope or price, or inability to meet a requirement. Failure to identify an exception may be considered acceptance of the requirement for purposes of negotiation.

6. Fee Proposal and Billing Requirements
6A. Pricing Structure
The Town is seeking a fee structure that is transparent, predictable, and easy to administer. Proposers shall complete Appendix A and may propose a monthly retainer / hybrid model, an hourly model, or another clearly described alternative. For comparison purposes, each proposal must identify a monthly retainer option for core Town Attorney services, even if the proposer recommends an alternative structure.

The monthly retainer proposal should address regular Town Council meeting attendance, routine closed sessions and special meetings, Planning Commission support as proposed, regular on-site office hours, routine telephone and email consultation, agenda/staff document review, basic drafting and legal research, and other general-counsel work. Proposers shall clearly identify any exclusions, hour caps, or assumptions. 6B. Required Fee Information
• Monthly retainer amount and a detailed description of included services, assumptions, and any included hour limits.
• Hourly rates for the proposed Town Attorney, backup Town Attorney, partners/shareholders, of counsel, associates, paralegals, and other billable personnel for work outside the retainer. • Hourly rates or alternative pricing for litigation and other specialized services, with a description of the work treated as specialized.
• Billing increment used by the firm (for example, 0.1 hour) and any minimum charge policies.

Town of Los Altos Hills - Town Attorney Legal Services
10 • All reimbursable expenses, markups, travel charges, administrative charges, technology charges, or other pass-through costs. Routine local travel and ordinary office overhead should be included in the proposed fees unless clearly disclosed otherwise.
• Rate-guarantee period and any proposed annual escalation methodology. • Any alternative fee arrangement the proposer believes would provide better value to the Town. 6C. Billing and Cost Management
• Invoices should be submitted monthly and itemized by matter, date, timekeeper, task description, time, rate, and amount, except to the extent a fixed retainer covers the service. • The selected firm will be expected to use the lowest-cost qualified professional appropriate for each task and to avoid unnecessary multiple-attorney attendance, internal conferences, duplicative review, or excessive research.
• The Town expects advance communication when a matter is likely to require significant unbudgeted work or when the firm recommends use of specialized or outside counsel. • Proposers should describe matter-budgeting, reporting, alternative fee, or other practices used to control municipal legal spending.

7. Transition and Service Expectations
7A. Transition
The selected firm will be expected to coordinate a professional transition with the incumbent counsel, Town staff, and existing special counsel. The transition should protect attorney-client privilege, preserve deadlines and records, minimize duplicate billing, and maintain continuity on pending matters. Any significant transition costs should be disclosed in the fee proposal. 7B. Relationship Management and Reporting
• Establish a clear primary contact and escalation process for Town staff. • Provide the City Manager with periodic updates on significant matters, expected deadlines, and material budget issues.
• Maintain organized matter files and return or transfer Town records promptly upon request or termination of the agreement, subject to applicable ethical obligations. • Coordinate with the Town's risk pool, insurers, consultants, and other legal counsel when authorized. • Participate in periodic performance and service discussions with the Town Council and City Manager as requested.
7C. Confidentiality and Cybersecurity
The selected firm must maintain attorney-client confidences and Town records in accordance with applicable law and professional obligations. The firm should maintain reasonable administrative, technical, and physical safeguards for confidential electronic information and promptly notify the Town of any security incident materially affecting Town information.

8. Proposal Evaluation and Selection
8A. Evaluation Criteria
The Town will evaluate proposals based on overall qualifications, demonstrated fit with the Town's needs, and best value rather than price alone. The anticipated evaluation criteria are:

Evaluation Criterion Weight
Municipal law qualifications and relevant experience 25% Understanding of the Town and proposed approach to service 20% Proposed Town Attorney / team, responsiveness, availability, and continuity 15% Fee structure, cost-control approach, and overall value 15% References, professional reputation, integrity, and conflict considerations 10% Interview / presentation 15%

Town of Los Altos Hills - Town Attorney Legal Services
11 8B. Evaluation Process
8B1. Responsiveness Review. The Town may reject proposals that are incomplete, materially nonresponsive, or fail to satisfy mandatory requirements. 8B2. Written Proposal Evaluation. Responsive proposals will be evaluated against the criteria above. The Town may conduct reference checks, review public information, and request clarifications. 8B3. Finalist Interviews. The Town may invite a short list of proposers to interview with the Town Council and/or designated evaluators. Finalists may be asked to address hypothetical municipal-law scenarios, staffing and availability, transition, conflicts, and fee structure. 8B4. Selection and Negotiation. The Town Council will determine the proposer it believes best meets the Town's needs. The Town may negotiate scope, staffing, fees, contract terms, and other matters with the selected proposer. If negotiations are unsuccessful, the Town may negotiate with another proposer.
8B5. No Award Obligation. This RFP does not obligate the Town to award a contract, reimburse proposal costs, or select the lowest-cost proposal.

9. RFP Terms and Conditions
9A. Town Rights
The Town reserves the right, in its sole discretion, to:
• Reject any or all proposals, waive informalities or minor irregularities, or cancel and reissue this RFP. • Amend the RFP or schedule by written addendum.
• Request clarification, supplemental information, interviews, or best-and-final proposals. • Conduct independent reference checks and due diligence concerning proposers and proposed attorneys.
• Negotiate with one or more proposers and accept other than the lowest-priced proposal. • Modify the scope of services before or during contract negotiations. • Retain separate or special counsel for any matter, including conflicts or specialized legal services. • Select no proposer if the Town determines that doing so is in its best interest. 9B. Proposal Costs and Ownership
All costs of preparing, submitting, and presenting a proposal are the sole responsibility of the proposer.

Proposals and related materials submitted to the Town become Town records and will not be returned. 9C. Public Records and Confidential Information
Proposals are subject to disclosure under the California Public Records Act (Government Code section 7920.000 et seq.) and other applicable law. A proposer claiming that specific information is exempt from disclosure must clearly identify the information and the legal basis for the claimed exemption. Designating an entire proposal as confidential or proprietary is not acceptable. The Town will make disclosure determinations in accordance with law and does not guarantee that material marked confidential will be withheld. Proposers should not submit information that they are prohibited from disclosing. 9D. Proposal Validity, Withdrawal, and Errors
• Proposals shall remain valid for at least 120 days after the proposal deadline and, if selected for negotiation, through completion of negotiations unless otherwise agreed. • A proposer may withdraw its proposal by written notice received by the RFP Coordinator before the proposal deadline.
• Proposers are responsible for errors or omissions in their proposals. After the deadline, changes may be made only at the Town's request or with the Town's written approval. 9E. Collusion, Gratuities, and Nondiscrimination
By submitting a proposal, the proposer represents that the proposal is genuine, was prepared independently, and is not the result of collusion intended to restrict competition. No proposer shall offer any gratuity, gift, discount, employment, or other improper benefit to a Town official, employee, or

Town of Los Altos Hills - Town Attorney Legal Services
12 representative in connection with this procurement. The selected firm must comply with applicable nondiscrimination laws.
9F. Licensure and Conflicts
Each attorney providing legal services must maintain all licenses and professional qualifications required by law. Proposers must disclose known actual or potential conflicts and cooperate with additional conflicts checks requested by the Town. The Town may disqualify a proposer if a conflict cannot be resolved to the Town's satisfaction.
9G. No Attorney-Client Relationship During Procurement
Submission of a proposal, participation in an interview, or other communication during this procurement does not by itself create an attorney-client relationship with the Town. Proposers should not request confidential Town information except as authorized by the RFP Coordinator. Any confidential information shared by the Town during the procurement shall be handled in accordance with instructions provided by the Town and applicable law.
9H. RFP and Proposal in Final Agreement
The Town may incorporate this RFP, the selected proposal, written clarifications, and negotiated modifications into the final Legal Services Agreement. The final agreement will control in the event of a conflict among documents.

10. Insurance and Contract Requirements
10A. Insurance
The selected firm will be required to maintain insurance acceptable to the Town. Anticipated minimum limits are shown below and may be modified during contract negotiations based on the Town's standard requirements and risk review.

Insurance Category Anticipated Minimum Limit
Professional Liability / Errors & Omissions $2,000,000 per claim Commercial General Liability $1,000,000 per occurrence / $2,000,000 aggregate Automobile Liability $1,000,000 per accident
Workers' Compensation Statutory requirements
Employer's Liability $1,000,000 per accident
10B. Indemnification and Professional Obligations
The final agreement will contain indemnification, defense, insurance, confidentiality, records, termination, and other provisions appropriate for professional legal services. Proposers should identify any material exception to the anticipated requirement that the firm be responsible for claims, damages, or losses arising from the firm's negligent acts, errors, omissions, or other wrongful conduct, subject to the final negotiated agreement and applicable law.
10C. Contract Term and Termination
The Town anticipates an initial three-year agreement, with possible extensions. The Town Attorney serves at the pleasure of the Town Council. The final agreement is expected to permit the Town to terminate services upon written notice and to require the firm to cooperate in an orderly transfer of files and matters upon termination.
10D. Business License and Other Requirements
The selected firm will be responsible for obtaining any business license or other authorization required to perform services for the Town and for complying with all applicable federal, state, and local laws and professional rules.

Town of Los Altos Hills - Town Attorney Legal Services
13 Appendix A. Fee Proposal Form
Proposer Name: ________________________________________________ Proposers may attach supplemental pricing detail, but this form should be completed to facilitate comparison. All fees should be stated in U.S. dollars.

A1. Monthly Retainer Option
Monthly retainer amount $
Included on-site office hours per week
Included Council / special meeting assumptions
Included Planning Commission assumptions
Any monthly hour cap or other limitation
Describe services included in the monthly retainer and all exclusions:
________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ A2. Hourly Rates for Work Outside the Retainer
Timekeeper / Classification Name (if applicable) Hourly Rate Proposed Town Attorney $
Primary Backup Town Attorney $
Partner / Shareholder $
Of Counsel $
Senior Associate $
Associate $
Paralegal / Law Clerk $
Other $
A3. Specialized Services / Litigation
Describe services considered specialized or outside the base retainer and provide applicable rates or alternative pricing:
________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ A4. Expenses, Billing Practices, and Rate Adjustments
Billing increment: _________________________________________________________________ Routine local travel charges:
_________________________________________________________________ Other reimbursable expenses / markups:
_________________________________________________________________ Rate guarantee period: _________________________________________________________________ Proposed annual rate adjustment after guarantee period:
_________________________________________________________________ Transition / onboarding charges, if any:
_________________________________________________________________

Town of Los Altos Hills - Town Attorney Legal Services
14 A5. Alternative Fee Proposal (Optional)
Describe any alternative fee arrangement the proposer believes will provide superior value or predictability to the Town:
________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________

Town of Los Altos Hills - Town Attorney Legal Services
15 Appendix B. Proposal Submission Checklist
This checklist is provided for convenience. Proposers remain responsible for all requirements in the RFP. ☐ Proposal submitted by 4:00 p.m. Pacific Time on September 25, 2026. ☐ Searchable PDF submitted to the RFP Coordinator with the required subject line. ☐ Cover Letter signed by an authorized representative.
☐ Proposal valid for at least 120 days.
☐ Executive Summary and Service Philosophy included.
☐ Firm Information and Background included.
☐ Proposed Town Attorney and backup attorney identified; resumes included. ☐ Relevant municipal experience and qualifications addressed. ☐ Current clients, conflicts, and requested professional responsibility disclosures addressed. ☐ 30/60/90-day transition plan included.
☐ Training and legislative support described.
☐ Three to five municipal references provided.
☐ Appendix A Fee Proposal Form completed.
☐ All RFP / anticipated contract exceptions clearly identified. ☐ Ability to meet insurance requirements confirmed or exceptions identified. ☐ All addenda reviewed and acknowledged.

END OF REQUEST FOR PROPOSALS

1 Keren Brunner
From: Arika Miller
Sent: Wednesday, August 19, 2026 2:38 PM
To: Keren Brunner
Subject: FW: City Attorney RFP Feedback
Follow Up Flag: Follow up
Flag Status: Flagged
From: Cody Einfalt <[email protected]>
Sent: Wednesday, August 19, 2026 8:54 AM
To: Arika Miller <[email protected]>
Subject: FW: City Attorney RFP Feedback
Arika, please add email below to item 8C as a supplemental public comment From: Jim Waschura <[email protected]>
Sent: Wednesday, August 19, 2026 8:29 AM
To: Cody Einfalt <[email protected]>; BCC - Rajiv Bhateja; Kavita Tankha <[email protected]>
Subject: Re: City Attorney RFP Feedback
Bonus points for:
 Experience working with affordable housing developers, or with/for cities that have been successful engaging with such developers.
 Experience with Builder's Remedy responses.
 Direct experience negotiating with HCD on Housing Element-related issues.  Alliance with other attorneys, potentially at the same firm, to handle special considerations like litigation, labor law, code enforcement. Achieve synergy.

Consideration of allowance/restrictions on use of AI and privacy of information fed to AI Consideration of remote attendance versus in-person attendance. Less important for internal meetings, but for public meetings residents appreciate seeing/appreciating their champions. If paying for travel, maybe adjust this for economy.

Possibly consider retainer pricing to guarantee a certain amount of hours per month (baseline) at lower contracted rate, with overages billed at their nominal rate. No overtime unless we request a particular person and our request is for greater than standard time. Use of lower-paid associates/staff as much as possible.

ITEM 8C Supplemental 1

2 For breakdown of importances: I suggest experience and qualifications gets bumped up, and understanding the town gets bumped down.I don't think you need to mention References, reputation - that's table stakes.

Who is evaluating the candidates beyond sitting city council members and Cody? Perhaps there are citizen volunteers qualified to evaluate, but I'm not sure. Engaging with former council members/mayors might be a good idea - both to get ideas about characteristics/practices that are important, but also potentially to interview.

From: Cody Einfalt <[email protected]>
Sent: Wednesday, August 19, 2026 7:34 AM
Subject: City Attorney RFP Feedback
Good Morning Planning Commissioners,
As some of you may be aware, Steve Mattas announced his retirement earlier this year as the Town’s Attorney (after 24 years) and the City Council has asked staff to assemble an RFP for legal services in search of firms to consider as a replacement.

Tomorrow evening at the City Council meeting, the Council will consider a draft RFP for city attorney services Staff report: https://losaltoshillsca.portal.civicclerk.com/event/4576/files/attachment/14573 Draft RFP: https://losaltoshillsca.portal.civicclerk.com/event/4576/files/attachment/14575 The City Council Ad Hoc Committee tasked to this topic (Rajiv and Kavita) have asked me to pass along this draft RFP and ask if the Planning Commission has any feedback on the proposed RFP.

Please respond to me directly, or participate in the public meeting tomorrow. Your comments will be included in the public packet.

Thank you

3 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]

ITEM 8D

TOWN OF LOS ALTOS HILLS

MEMORANDUM
DATE: August 20, 2026
TO: Vice Mayor Linda Swan, Council Members Stanley Mok, Kavita Tankha, and George Tyson
FROM: Mayor Rajiv Bhateja
RE: Consideration of Revisions to the Mayoral Rotation Policy Earlier this year, the City Council approved an updated policy on mayoral rotation. This policy change had the goal of clarifying the considerations for mayoral and vice mayoral selection by the City Council in an orderly manner. Another goal was to maintain a balance between the values of having experience relevant to these roles and the desire to create the opportunity for new leadership.

Since then, the Council has had the experience of a split year for vice mayor, an innovative approach that provides the opportunity for earlier service of a new councilmember as vice mayor, while still providing some council experience before being elevated to that role. This approach also increases the opportunity for a councilmember elected during a three-person cycle to serve as mayor during that first term.

The proposed update is as follows:

The Council may also consider selecting a vice mayor for a six-month term, with the dual benefits of elevating a newly elected councilmember to vice mayor in the second half of the year (and thus be prepared to serve as mayor in the following year) and also providing continuity when a termed-out councilmember is unable to serve as mayor the following year.

Attachment:

1. Mayoral Rotation Policy - April 2026

Selection of Vice Mayor and Mayor – Los Altos Hills
Drafted by Ad hoc subcommittee: Kavita Tankha and George Tyson, 29Jan2026 This policy is written to provide an orderly process for Vice Mayor and Mayor selection that balances the need for experience and continuity with the desire to have a rotation that gives councilmembers a chance to hold these positions.

Each city council has the ability and right to suspend this policy at any time if it determines that extraordinary conditions apply.

Policy conditions:

1. Minimum time on council to serve as Vice Mayor is one year and for Mayor two years

2. The Vice Mayor is promoted to Mayor at the transition time a. Exception – if the Vice Mayor is no longer a member of the council b. In this case, the Mayor is the eligible councilmember who has served the longest since serving as Mayor

3. Candidates for Vice Mayor are selected from eligible councilmembers based on the following hierarchy of qualifications:
a. Has never been Vice Mayor or Mayor before*, or if there are no such candidates:
b. Has served as Mayor just once already

4. In the event that there are multiple candidates who qualify in section 3 above, then the hierarchy is as follows:
a. Has served the longest on the council
b. Received the largest number of votes in the last election c. In the event that the previous election was not held (due to number of candidates equaling the number of open seats), then councilmembers will vote based on their judgment of who is best qualified to serve the Town

5. In the event a vacancy for Mayor occurs mid-year, the Vice Mayor is elevated to Mayor, and a new Vice Mayor is selected based on the criteria in sections 3 and 4 above *Any member re-elected to the Council after a break in service will be treated in the normal sequence for appointment as Vice Mayor and Mayor, without regard to such person’s service prior to the break in service.

ITEM 8D, Attachment 1

ITEM 8E

TOWN OF LOS ALTOS HILLS
Staff Report to the City Council
August 20, 2026
_________________________________________________________________________________________________ ________ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ _ SUBJECT: RESOLUTION APPROVING AMENDMENTS TO THE

PROCLAMATIONS, COMMENDATIONS, AND COMMEMORATIONS

POLICY AND PROCEDURES
FROM: Arika Birdsong-Miller, City Clerk
APPROVED: Cody Einfalt, City Manager
________________________________________________________________________________ RECOMMENDATION:

That the City Council approve the attached Resolution (Attachment 1) Amending the Proclamations, Commendations, and Commemorations Policy and Procedures (Attachment 2).

BACKGROUND
The Town's Guidelines for Proclamations, Commendations and Commemorations were originally adopted by the City Council on May 1, 2003. The City Council subsequently discussed amendments to the guidelines at a special meeting on January 24, 2013, with proposed amendments returning to the City Council for consideration on February 28, 2013 (Attachment 3). The guidelines, as amended, have continued to serve as the Town's policy governing the issuance of proclamations, commendations, and commemorations.

The existing guidelines establish criteria for the types of recognition that may be issued, including extraordinary achievements and community service, charitable and nonprofit organizations, significant milestones and retirements, local arts and cultural celebrations, and public awareness campaigns. The guidelines also identify categories of requests that are not appropriate for Town recognition.

Most recently, at its June 18, 2026, meeting, the City Council discussed the Town's practices related to proclamations and ceremonial recognitions and provided direction regarding updates to the existing guidelines. Based on that direction, staff reviewed the existing policy and procedures and prepared the proposed amendments for City Council consideration

DISCUSSION
To improve consistency, transparency, and administrative efficiency, staff reviewed the existing guidelines and reorganized the policy to establish clearer standards and procedures. The proposed amended policy is structured similarly to the Town's existing Flag Display Policy and Procedures (Attachment 4), which establishes that ceremonial and commemorative displays constitute an expression of the Town's official sentiments and provides a defined process for City Council consideration and approval.

For reference, a list of proclamations issued by the Town over the past five years is provided below.

Staff Report to City Council
Resolution Amending Proclamation Policy
August 20, 2026
Historical
Proclamation
Under Proposed
Policy Reason
American Red Cross
Month KEEP / Eligible Health, safety, emergency preparedness/nonprofit service Emergency
Preparedness / National
Preparedness Month
KEEP / Eligible Expressly fits emergency preparedness
Water Conservation
Month KEEP / Eligible Environmental stewardship/community-wide purpose Challenge Team Youth
Champions
Eligible, but not
recurring Achievement/community recognition
Internet Digital Bill of
Rights REMOVE Policy/ideological advocacy rather than ceremonial recognition 50th Anniversary of
Title IX Not recurring
One-time 50th anniversary; any future Title IX
recognition should be separately reviewed for
policy/advocacy content
Steve Padovan
Retirement
Eligible, but not
recurring Retirement recognition
Compassion Week KEEP / Eligible
Community-wide/community service purpose,
assuming the proclamation itself remains nonideological Cultural Significance
of Diwali REMOVE Expressly prohibited by race/ethnicity/ancestry/national-origin restriction Local Emergency –
Severe Winter Storms
Not part of this
ceremonial
calendar
Emergency governmental action rather than
ordinary ceremonial recognition
AAPI Heritage Month REMOVE Expressly prohibited by
race/ethnicity/ancestry/national-origin restriction
National Service Dog
Month KEEP / Eligible Public awareness/community-wide purpose Hidden Villa 100th
Anniversary
Eligible, but not
recurring One-time organizational milestone
Mental Health Month KEEP / Eligible Health/public awareness International Dark Sky
Week KEEP / Eligible Environmental stewardship and strong local connection Bike Month KEEP / Eligible Health, safety, transportation/community awareness
Foster Care/Resource
Parent Awareness
Month
KEEP / Eligible Public awareness/education/community purpose National Public Works
Week KEEP / Eligible Civic engagement/municipal service Childhood Cancer
Awareness Month KEEP / Eligible Health/public awareness

Staff Report to City Council
Resolution Amending Proclamation Policy
August 20, 2026
Historical
Proclamation
Under Proposed
Policy Reason
Community
Foundation Week KEEP/ Eligible Nonprofit/community service recognition Zero-Emission
Building Appliance
Rules
REMOVE Express support for specific regulatory
rules/policy position
Building Safety Month KEEP / Eligible Public health/safety and municipal function Affordable Housing
Month
Potentially
eligible
Housing awareness may qualify, but wording must
avoid advocating legislation/policy positions
Public Works Week KEEP / Eligible Municipal service/public awareness The proposed amendments establish an annual ceremonial calendar for recurring proclamations, clarify the eligibility and content standards applicable to all requests, establish procedures for requests that are not included on the annual calendar (Attachment 5), and provide direction regarding the scheduling and presentation of ceremonial recognitions. The amendments are intended to provide staff, the City Council, and members of the public with a clear and consistent framework for determining when and how the Town will issue proclamations, commendations, and commemorations.
2025-26 CITY COUNCIL WORK PLAN
This action is not included in the FY 2026–27 City Council Work Plan and is considered part of the Town’s routine day-to-day operations.

FISCAL IMPACT
There is no anticipated fiscal impact associated with the recommended action.

ATTACHMENTS

1. Proposed Resolution Approving the Proclamations, Commendations, and Commemorations Policy and Procedures

2. Proposed Proclamations, Commendations, and Commemorations Policy and Procedures

3. Current Proclamation, Commendations, and Commemorations Policy and Procedures

4. Town's existing Flag Display Policy and Procedures

5. 2027 Proposed Proclamation Calendar

ITEM 8E, Attachment 1
RESOLUTION NO. -26

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS

APPROVING AN AMENDED PROCLAMATIONS, COMMENDATIONS AND

COMMEMORATIONS POLICY & PROCEDURES
WHEREAS, the Town of Los Altos Hills ("Town") issues proclamations, commendations, commemorations, certificates, plaques, meeting dedications, and other ceremonial recognitions to acknowledge qualifying events, achievements, milestones, public awareness efforts, and individuals and organizations that have made significant contributions to the Town and community; and
WHEREAS, ceremonial recognitions issued or presented by the Town are expressions of the Town's official sentiments and constitute Town speech and are not intended to create a public forum or forum for private expression; and
WHEREAS, the City Council desires to establish clear and uniform standards governing the issuance and presentation of ceremonial recognitions to promote consistency, transparency, administrative efficiency, and the appropriate use of Town resources; and WHEREAS, the Town's Guidelines for Proclamations, Commendations and Commemorations were originally adopted by the City Council on May 1, 2003, and were subsequently reviewed and amended in 2013; and
WHEREAS, the City Council desires to amend and reorganize the existing guidelines into a comprehensive Proclamations, Commendations and Commemorations Policy & Procedures that establishes clear eligibility criteria, content restrictions, procedures for review and approval, and standards for scheduling and presenting ceremonial recognitions; and WHEREAS, the amended policy establishes an Annual Ceremonial Calendar through which the City Council will annually identify recurring ceremonial recognitions that may be prepared, scheduled, and administered by Town staff without separate City Council action, provided that each recognition remains consistent with the policy; and WHEREAS, requests for proclamations, commendations, or commemorations that are not included on the Annual Ceremonial Calendar will require sponsorship by at least one City Council Member before being presented to the City Council for consideration, and Council Member sponsorship does not constitute approval of the requested recognition; and WHEREAS, the amended policy establishes content restrictions to ensure that ceremonial recognitions issued by the Town are consistent with the Town's official speech and are administered consistently regardless of the viewpoint, identity, affiliation, or popularity of the requester or proposed recipient; and

WHEREAS, the City Council finds that adoption of the amended Proclamations, Commendations and Commemorations Policy & Procedures will provide clear and consistent direction to Town staff, the City Council, and members of the public regarding the issuance and administration of Town ceremonial recognitions.

NOW, THEREFORE, BE IT RESOLVED, that the City Council of the Town of Los Altos Hills hereby approves the amended Proclamations, Commendations and Commemorations Policy & Procedures, attached hereto as Exhibit A and incorporated herein by reference.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on , 2026, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY:

Rajiv Bhateja, Mayor
ATTEST:

Arika Birdsong- Miller, City Clerk

ITEM 8E, Attachment 2

TOWN OF LOS ALTOS HILLS
26379 Fremont Road
Los Altos Hills, CA 94022
Phone: (650) 941-7222 | www.losaltoshills.ca.gov
Proclamations, Commendations and Commemorations Policy & Procedures
Approved by City Council: __________________

1. Purpose
The purpose of this document is to establish clear, uniform policy and procedures governing proclamations, commendations, commemorations, certificates, plaques, meeting dedications, and other ceremonial recognitions issued or presented by the Town of Los Altos Hills. The policy is intended to promote consistency, transparency, administrative efficiency, and appropriate use of ceremonial recognitions as expressions of the Town’s official sentiments.

2. Policy
Ceremonial recognitions issued by the Town are expressions of the Town’s official sentiments and constitute Town speech. They are not intended to create a public forum or a forum for private expression. No person or organization is entitled to a Town proclamation, commendation, commemoration, certificate, plaque, meeting dedication, or other ceremonial recognition merely by submitting a request.

The City Council shall establish the list of recurring proclamations, commendations, and commemorations for the upcoming calendar year when it approves the annual City Council meeting calendar during the fourth quarter of the preceding year. Once approved, these recurring recognitions shall constitute the Town’s Annual Ceremonial Calendar and may be scheduled and administered by staff throughout the year.

All requests shall be reviewed for consistency with this policy. The City Clerk is authorized to determine whether a request clearly satisfies the adopted eligibility criteria and may be processed administratively. Requests that are not included on the Annual Ceremonial Calendar, or for which eligibility is uncertain, shall be handled in accordance with Section 3(C) of this policy.

To preserve the efficient conduct of City Council meetings, the Town’s general practice shall be to schedule no more than three (3) ceremonial presentations during any single regular City Council meeting. This limit applies to the combined number of proclamations, commendations, commemorations, certificates, and other ceremonial recognitions presented during the meeting.

A. Content Restrictions
The Town will not issue a proclamation, commendation, commemoration, or other ceremonial recognition that:
• Advocates for or against a political candidate, political party, ballot measure, pending legislation, or legislative position, or otherwise suggests an official Town endorsement of a partisan political position.
• Promotes or endorses an ideological or religious belief, doctrine, or individual conviction.

This restriction does not prohibit recognition of a specific cultural event or holiday that is independently eligible under this policy and is not presented as Town endorsement of a religious belief or doctrine.

Proclamations, Commendations and Commemorations Policy & Procedures | Page 2 • Recognizes, commemorates, promotes, or designates a race, ethnicity, ancestry, or national-origin group, or a heritage or identity month, week, day, campaign, or cause organized around race, ethnicity, ancestry, or national origin. • Recognizes an individual or organization whose stated policies, objectives, or activities advocate violence, hatred, unlawful discrimination, or conduct contrary to the health, safety, or well-being of the Town community.
• Is primarily commercial in nature, advertises or promotes a for-profit business, product, service, or commercial transaction, or could reasonably be interpreted as a Town endorsement of a commercial enterprise.
• Is defamatory, obscene, threatening, or otherwise inconsistent with law or Town policy.

The restrictions above shall be applied consistently regardless of the viewpoint, identity, affiliation, or popularity of the requester or proposed recipient. A request that falls within a prohibited category shall not be administratively approved or added to the Annual Ceremonial Calendar.

3. Procedures
A. Annual Ceremonial Calendar

1. During the fourth quarter of each year, staff shall prepare a proposed list of recurring ceremonial recognitions for the following calendar year for consideration by the City Council in conjunction with adoption of the annual City Council meeting calendar.

2. The City Council may add, remove, or modify recurring recognitions before adopting the Annual Ceremonial Calendar.

3. Once adopted, staff may prepare, schedule, and distribute recognitions listed on the Annual Ceremonial Calendar without separate City Council action, provided the recognition remains consistent with this policy.

4. Placement of an item on the Annual Ceremonial Calendar does not guarantee presentation at a particular City Council meeting. Staff may adjust presentation dates based on agenda workload, recipient availability, and operational needs.

B. Submission and Staff Review

1. Requests should be submitted to the City Clerk with sufficient information to evaluate the request, including the proposed subject of recognition, recipient or sponsoring organization, requested date, reason for recognition, and any relevant supporting information.

2. The City Clerk shall review each request for consistency with the eligibility criteria and content restrictions in this policy.

3. A request that is already included on the Annual Ceremonial Calendar and otherwise complies with this policy may be processed and scheduled administratively.

4. The City Clerk may request additional information when necessary to determine whether a request satisfies this policy. Incomplete requests may be held until sufficient information is provided.

5. The City Clerk may determine the appropriate form of recognition based on the nature and significance of the request, subject to City Council direction and the provisions of this policy.

C. Requests Outside the Annual Ceremonial Calendar

1. A request for a proclamation, commendation, or commemoration that is not included on the Annual Ceremonial Calendar shall not automatically be scheduled for presentation.

Proclamations, Commendations and Commemorations Policy & Procedures | Page 3

2. If the requester believes the request satisfies this policy, the City Clerk shall circulate the request to the full City Council to determine whether a Council Member wishes to sponsor the proposed recognition for City Council consideration.

3. If no Council Member elects to sponsor the request, no further action shall be taken and the request shall not be placed on the City Council agenda.

4. If a Council Member elects to sponsor the request, the item shall be placed on a future City Council agenda under the Council-Initiated Items section.

5. Council Member sponsorship permits the request to be considered by the City Council; sponsorship does not constitute approval of the recognition. If the City Council approves the request, the proclamation, commendation, or commemoration shall be scheduled for presentation at the next regular City Council meeting, subject to the ceremonial presentation limits established by this Policy.

D. City Council Consideration

1. The City Council may approve, modify, decline, or provide other direction regarding a proposed recognition presented for its consideration.

2. A recognition requiring City Council consideration shall be approved only by the affirmative action required for the applicable agenda item under Town procedures and law.

3. City Council approval of a one-time recognition does not automatically add that recognition to the Annual Ceremonial Calendar for future years unless the City Council expressly directs otherwise.

E. Scheduling and Presentation

1. Staff shall schedule approved ceremonial recognitions based on available agenda capacity, the three-recognition guideline, recipient availability, and other operational considerations.

2. When the number of approved recognitions exceeds the general meeting guideline, staff may schedule the recognition for a future City Council meeting, arrange presentation at another appropriate Town event, or transmit the recognition directly to the recipient when appropriate.

3. The Mayor, Vice Mayor, or another Council Member may present an approved recognition. Staff may coordinate with recipients regarding attendance, presentation logistics, and photographs.

4. The City Clerk may make non-substantive edits to ceremonial documents for grammar, formatting, factual accuracy, consistency, and Town style, provided the edits do not materially change the recognition approved by the City Council.

4. Eligibility Criteria
Subject to the content restrictions in Section 2(A), the following may be eligible for Town recognition:

1. Extraordinary achievement or outstanding community service that has a meaningful connection to the Town of Los Altos Hills or its residents.

2. Charitable fundraising events or nonprofit organizations that serve the Los Altos Hills community, including a Los Altos Hills nonprofit or a local branch of a state or national nonprofit organization.

3. Significant milestones for an individual or organization, such as major birthdays, anniversaries, or other noteworthy achievements, when there is a substantial connection to the Town.

Proclamations, Commendations and Commemorations Policy & Procedures | Page 4

4. Retirement of individuals who have made significant contributions to the Town or community.

5. Local arts or cultural events and celebrations that have a meaningful connection to the Town and do not fall within a prohibited category in Section 2(A).

6. Public awareness campaigns that address health, safety, education, civic engagement, environmental stewardship, emergency preparedness, or another community-wide public purpose and do not advocate a prohibited political, ideological, religious, racial, ethnic, ancestry, or national-origin cause.

7. Regional events or requests from other public agencies when recognition is appropriate and consistent with this policy.

5. Forms of Recognition
A. Proclamations
A proclamation is an official ceremonial document used to proclaim or recognize a qualifying event, awareness campaign, milestone, achievement, or other occasion consistent with this policy. Proclamations are generally reserved for matters of broad community significance or occasions for which a formal statement of Town recognition is appropriate.

B. Resolutions
A resolution is a formal action of the City Council and shall be used for ceremonial recognition only in the most significant cases. Adoption of a ceremonial resolution requires placement on a City Council agenda and supporting materials sufficient to explain the basis for the proposed recognition.

C. Certificates of Commendation, Recognition, or Appreciation Certificates may be issued to recognize individual or organizational service, achievement, milestones, athletic or academic accomplishments, acts of heroism, or other qualifying accomplishments. The title of the certificate shall be selected based on the nature of the recognition.

D. Plaques
Plaques may be used to recognize significant service to the Town, including service by outgoing Council Members, Commissioners, and, when appropriate, outgoing Mayors or other individuals whose service warrants this form of recognition.

E. Meeting Dedications
The Mayor may recommend that a City Council meeting be dedicated in memory of an individual with a significant connection to the Town. When approved or otherwise authorized under Town procedures, the dedication may be noted on the agenda and announced during the meeting.

6. Specific Recognition Guidelines
A. Community Events
In determining whether a community event is appropriate for recognition, consideration shall be given to the event’s significance to the Los Altos Hills community, its public or charitable purpose, and whether recognition would be consistent with the content restrictions in this policy.

Proclamations, Commendations and Commemorations Policy & Procedures | Page 5 B. Athletic and Academic Accomplishments
Recognition may be provided when a Town resident or a team with a substantial Town connection reaches a significant level of competition or achievement. Recognition should generally occur after the highest relevant level of competition has concluded.

C. Acts of Heroism
Recognition may be provided to Town residents or others with a substantial connection to the Town who perform heroic acts when the significance of the act warrants public recognition.

D. Eagle and Golden Arrow Scouts
Town residents achieving Eagle Scout or Golden Arrow Scout status may receive a Certificate of Commendation or other appropriate certificate.

E. Commissioner and Committee Member Service
A framed Certificate of Appreciation may be presented to a Commissioner or Committee Member who resigns before completion of a term. A member completing a full term may receive a plaque or other recognition consistent with Town practice.

F. Regional Events and Other Public Agencies
Appropriate certificates or proclamations may be prepared for qualifying regional events or in response to requests from other public agencies, subject to this policy and City Council direction when required.

7. Administration and Exceptions

1. The City Clerk is responsible for administering this policy and coordinating the preparation, scheduling, and presentation of Town ceremonial recognitions.

2. The City Manager or designee may resolve administrative questions concerning scheduling, logistics, and implementation that do not alter the substantive eligibility standards or content restrictions established by this policy.

3. Any exception to the substantive provisions of this policy must be expressly approved or directed by the City Council. No exception may be granted administratively.

4. If a request is inconsistent with a mandatory content restriction in Section 2(A), staff shall not process the request as an administratively approved recognition. Any proposed departure from that restriction must be referred to the City Attorney before the item is placed before the City Council.

5. Nothing in this policy limits the City Council’s authority, subject to applicable law, to determine the content of its own official speech or to amend this policy by formal action.

8. Policy Review
Staff may periodically review this policy and recommend amendments to improve clarity, consistency, legal compliance, or administrative efficiency. Substantive amendments shall be presented to the City Council for approval.

Adopted 5/1/03
Revised February 28, 2013
3 Town of Los Altos Hills
Guidelines for Proclamations,
Commendations and Commemorations
The basic premise when considering recognitions is that the Mayor provides direction to Staff to initiate recognition. In providing that direction, the Mayor takes into account the following guidelines in determining if the City Council wishes to consider recognition. If a Council member wishes to initiate recognition, he/she should contact the Mayor.

FORMS IN WHICH THE RECOGNITION CAN BE PREPARED:

Proclamations
Proclamations are a form of a Certificate, but with a Proclamation, something is being proclaimed. These are typically used for Fire Prevention Week, United Way Week, etc.

The Mayor should determine, at a meeting of the City Council, if the City Council is in favor of presenting the Proclamation and if they want it presented on the agenda. The Mayor will then provide direction to staff. If the recipient cannot be present at a meeting, the Proclamation will be mailed. In some instances, a Proclamation is presented at an event by the Mayor.

Proclamations are not issued for religious observances, ethnic celebrations or events that are not local or regional in nature.

Resolutions
Many cities use the “Resolution” as a means of recognizing groups or individuals. A Resolution is a formal, written action of the City Council and must be agendized for a vote. All Resolutions adopted by the City Council are numbered and placed in the official book of Resolutions. The Resolution that is presented contains the same basic wording. It will be signed by the Mayor on behalf of the Council. If a Resolution is used to provide recognition, it is only used in the most significant cases.

Adoption of a Resolution requires a staff report with a recommendation and justification for issuing the Resolution.

Certificates
Certificates are prepared in response to the type of recognition desired. These include Certificates of Commendation, Certificates of Recognition and Certificates of Appreciation.

The Mayor should determine if the City Council is in favor of presenting the Certificate and if they want it presented on agenda. The Mayor then provides direction to staff.

Presentations will not be agendized if the recipient cannot be present at the meeting to ITEM 8E, Attachment 3

Adopted 5/1/03
Revised February 28, 2013
3 receive the Certificate. In some instances, a Certificate is presented at an event by the Mayor.

Certificates are not issued for religious observations, ethnic celebrations or recognition that is not local or regional in nature.

Plaques
Plaques are an appropriate means of recognition for significant service to the Town.

Plaques are presented to outgoing Councilmembers and Commissioners who complete their terms of office. If a Commissioner applies and is reappointed, the recognition is given when he/she leaves the Commission. A plaque can be presented as a recognition for the outgoing Mayor.

Meeting Dedication
There are times when a meeting is dedicated to the memory of an individual. The Mayor would initiate this action. When a meeting is dedicated, a notation appears on the agenda and the Mayor announces that the meeting is in memory of an individual.

TYPES OF REQUESTS FOR RECOGNITION
The following are guidelines regarding when recognition should occur.

Community Events
There are many events that may occur in the community. The Mayor, after determining if the City Council is in favor of issuing the Proclamation or Certificate, will provide direction to staff regarding if and how the recognition should occur. In making that determination, the City Council should consider the significance of the event to the entire community.

Athletic/Academic Accomplishments
Recognition may be provided when an individual or a team reaches a significant level of competition. Recognition can be given for a local or regional Championship level. If the competitor continues to compete at the State and/or National level, recognition should be given when the individual or team has completed the highest level of competition.

Athletic accomplishments should be limited to those made by children residing in Los Altos Hills competing in school-related or publicly conducted and sanctioned competitions. Adults residing in the community may also be recognized for their athletic achievements in well-recognized sporting events.

The determination of when recognition is appropriate is the responsibility of the City Council and/or the coaches, teachers, or administrators at the school.

Adopted 5/1/03
Revised February 28, 2013
3 Acts of Heroism
Recognition may be given to those individuals who are residents of Los Altos Hills who perform heroic acts. The significance and frequency of these acts should indicate whether this type of Commendation should be presented at a City Council meeting.

Eagle and Golden Arrow Scouts
Young men and women who are residents of the Town of Los Altos Hills and become Eagle Scouts or Golden Arrow Scouts may be recognized by the Town. A Certificate of Commendation will be prepared and presented by the Mayor to the recipient at a City Council meeting.

Commissioner and Committee Member Resignations
If a Commissioner or Committee Member finds it necessary to resign prior to completion of his/her term, a framed Certificate of Appreciation will be presented at a City Council meeting. If a Commissioner or Committee Member completes the term of office, a plaque will be presented at a City Council meeting.

Regional Events and Recognition for Other Cities
Appropriate Certificates or Proclamations will be prepared for regional events or in response to requests from other cities. The Mayor will determine if the City Council is in favor of preparing the recognition and provide appropriate direction to staff.

TOWN OF LOS ALTOS HILLS
26379 Fremont Road
Los Altos Hills, CA 94022
Phone: (650) 941-7222
www.losaltoshills.ca.gov
Display Flag Poles Policy & Procedures
Approved by City Council: October 20, 2022

1. Purpose
The purpose of this document is to establish the policy and procedures to be followed by all Town employees regarding the display of ceremonial or commemorative flags on the flag poles throughout the Town (“Display Flag Poles”).

2. Policy
All flags shall be displayed in accordance with federal and state regulations, including Title 4, Chapter 1 of the United States Code, and Sections 430 through 439 of the California Government Code. Display Flag Poles are not intended to be a forum for free expression by the public.

Ceremonial or commemorative flags shall be displayed as an expression of the Town’s official sentiments. Ceremonial and commemorative flags elected for display will reflect the Town’s speech, not that of an individual community member or group, and therefore must be approved by City Council resolution.

The display of ceremonial or commemorative flags other than the flags of the United States of America, State of California, and Town of Los Altos Hills must be supported by at least one Council member for Council consideration. The Council will not review proposals for the display of ceremonial or commemorative flags from third parties directly, nor will the Town use its Display Flag Poles to sponsor the expression of a third party. Flag raising ceremonies shall be conducted in accordance with all applicable provisions of federal and state laws.

3. Procedures
The Town will authorize the display of ceremonial or commemorative flags on Display Flag Poles as an expression of the Town’s official sentiments upon adoption of City Council resolution:

A. A councilmember who wishes to propose the display of ceremonial or commemorative flags will contact the City Manager to request a draft resolution be presented to City Council.

B. Town staff will draft and present a resolution to City Council including a proposed date of flag-raising, the length of flag display, and expression of the Town’s official sentiments regarding the proposed flag.

ITEM8E, Attachment 4

Draft Flag Display Policy and Procedures

C. The resolution must be approved by a majority of City Council members to be adopted.

B. Upon adoption of the City Council Resolution to display a ceremonial or commemorative flag, Town staff will follow the following guidelines:
a. The procurement of the flags for each Display Flag Pole shall be the responsibility of the Town.
b. Any flag-raising ceremony will not be allowed to take place in the street or in any other way block the public right of way.
c. Speakers may be permitted to speak on the Town’s behalf to present background information on the flag display.

C. Any exceptions to these guidelines must be approved by resolution of City Council.

D. If any of these guidelines are not followed, the Office of the City Manager has the right to suspend or cancel a flag-raising ceremony.
5171557.2

ITEM 8E, Attachment 5
2027 Town of Los Altos Hills Proposed
Proclamations
Month Proclamation Recommendation / Reason
March
American Red Cross
Month
Public safety/emergency preparedness
connection.

April International Dark Sky
Week
Strong connection to the Town's rural character
and dark-sky interests.

April National Cities, Towns,
and Villages Month Directly related to municipal government.

May
Mental Health Awareness
Month General public-awareness campaign.

May
Foster Care/Resource
Parent Awareness Month
Qualifies as a public-awareness recognition,
although it has only appeared once in the history
you provided.

May Public Works Week
Direct connection to Town employees and
municipal services; appeared in both 2024 and
2025.

September
Childhood Cancer
Awareness Month
Permissible public-awareness campaign, but
only one occurrence in the history provided.

September National Preparedness
Month
Strong connection to emergency preparedness
and appeared multiple times under slightly
different names.

October Compassion Week Appeared in both 2022 and 2025 and is community-oriented.

1 Keren Brunner
From: Arika Miller
Sent: Monday, August 17, 2026 1:40 PM
To: Keren Brunner
Subject: FW: Supplement to Agenda Item 11A
Follow Up Flag: Follow up
Flag Status: Flagged
From: Jim Waschura
Sent: Monday, August 17, 2026 8:09 AM
To: Arika Miller <[email protected]>
Subject: Supplement to Agenda Item 11A
Hello, please add the following as a supplement to this month's City Council meeting agenda item 11A. Thanks,
=======
Supplement to Agenda Item 11A
I support seating the standing committee on housing and suggest the following topics for its first meeting.

The committee's first order of business should be to consider and fine-tune its charter so the committee members, the Council, and residents are clear and unified on objectives and priorities.

I recommend early work should stay at the 10,000 foot level of criteria, partnerships with affordable housing developers and landowners, and funding approaches, and discussion of specific properties or areas should wait until clearer strategies have been developed and explained to residents.

One early priority should be developing criteria for where multifamily housing may be appropriate in town. Suitable sites should be near major commute corridors rather than interior residential streets, should have existing or feasibly extended infrastructure, and should be separated from single-family homes by adequate transition margins and landscape screening. They must not create traffic problems on narrow rural roads or burden emergency evacuation routes, which rules out locations up in the hills reached only by small streets.

I recommend the committee ground its vision and strategy in the observation that the town wants and needs affordable housing and that the amounts required are not a threat to our semi-rural character. It would be a great benefit if local teachers, firefighters, police officers, and town staff could live here in town. The threat is the huge increase in density that comes with the state's Density Bonus incentives, under which obtaining 80 affordable homes would require an additional 900 market-rate homes in a ITEM 11A Supplemental 1

2 town of only about 3,200 homes today. Construction on that scale goes far beyond what the RHNA quotas suggest, so obtaining the affordable units by other means is how the town protects itself from overdevelopment and protects its semi-rural character.

I further recommend that, once the criteria work has brought residents together around a common vision, the committee work with City Council to prioritize relationships with nonprofit affordable developers that finance projects through state tax credits, county housing funds, and grants rather than market-rate cross-subsidy, which lets the town control the ratio of affordable to market-rate units. The committee can identify the nonprofit developers active in Santa Clara County, catalog the funding programs they rely on, and open conversations with City Council members to consider how to approach these companies as partners.

I appreciate the Council bringing this committee forward and look forward to its work. 28-Year Resident,
Jim Waschura

ITEM 11A, Supplement 2
Multi-Family Housing on Town-Owned Property
I had another idea…
An alternative approach using an “indirect” strategy
Introduction
This is the second of two documents, each outlining “an idea” towards successfully meeting the Towns needs to meet or exceed RHNA requirements for “Low Income Housing”. The first document focused on using the town-owned property located at the intersection of Purissima and Elena.

This second document outlines a completely different idea and should be considered purely on its own merits, It is not dependent on the first.

The case has been made that in order for Los Altos Hills to reach its RHNA numbers – in particular for “low income” units, extraordinary measures will have to be taken to force it to happen. This is because meeting our overall quota for Multi-Family units is going to require special measures as it is – but relying on the overall total to include a sufficient proportion of “Low Income” would require a huge total number of Multi-Family units - such that the overall population of our town would have to explode to sustain such a demand.

One way to solve this might be to “have it built it on Town-owned property” and have the “low income requirement” built into the “deed” for the property.

Or (!) perhaps there is a clever alternative that has the same effective outcome, which “uses” the Town-owned property to achieve the same end – without actually building any housing on Town-owned land.

This document outlines such an approach. Again it is not intended as a concrete proposal at this time, but rather as food for further thought and discussion on the hope that it will lead to further ideas on how to reach the Town’s RHNA goals.

Multi-Family Housing on Town-Owned Property
Some General Considerations to Make It Work
Like chess, a planned set of moves is needed to achieve the objective This alternative approach involves following a sequence of steps- each of which needs to be accomplished in sequence to achieve the final goal. These are described individually as in the sequence presented further below in this document.

The downside to this is that achieving certain steps may become dependent on reaching negotiated agreement with third parties. We are not complete masters of our own destiny as we were in the first idea presented in a previous document.

If agreement with the third party fails, we are stuck.

Not only “Town-Owned Land” but also “Not Adjacent”
The idea expounded in this document (as well as the predecessor idea involving the property at Purissima and Elena) were stimulated by the generally perceived requirement that we will have to build on town-owned land (or at least having town-owned land play a role) in order to succeed in building enough low-cost housing to meet RHNA numbers.

But there is another unstated but “de facto” stringent requirement. Any site that is going to have any significant amount of “MF Housing” built on it, cannot share a border (be adjacent to) parcels zoned RA for conventional single-family residences. Ignoring this requirement seems guaranteed to invite litigation from neighboring land-owners claiming effective confiscation through loss of property values.

Both of the ideas presented here and in the previous document meet both criteria (Town-Owned Property involved, and “Not immediately adjacent to single-family homes)

First of all, to understand this approach, we need to be familiar with the geography of the area in town around the Little League Fields and the neighbor across the road – namely the Fremont Hills Country Club.

Note the four ball fields and the Town Ring on the south side of Purissima Road and the Fremont Hills Country Club roughly opposite on the other side of Purissima.

Step 1 Negotiate with Little League organization to give up the southernmost of their four fields – so they still have the original 3 as initially envisaged in 1969 – including small, medium and large sizes (i.e. Minor, Major, and Senior Leagues)

The area shaded in pink below shows the current location of this 4th ball field and the area to the south of it
If you have questions about the relationship between Little League and the “ownership” of the property, historical info may be found on this web page
http://www.couperus.org/Scrapbooks/LittleLeague

Step 2 Move the Town ring from its current position, northwards adjacent to 3rd ball field, thus freeing up a large chunk of contiguous open space at the southern end (pink area in following image)
The left-over pink area south of the Town Ring now becomes available for other purposes – as long as they fit the restriction of “Recreational” as stipulated in the 2002 Open Space Initiative.

The resulting open space is available to accommodate another ring (or two) and associated equine facilities (holding paddocks etc) that might be moved over from the Country Club equine facilities

Now let us take a look at the part of the Fremont Hills Country Club across the road – annotated here in pink
Note we apparently have here a Barn and some adjacent buildings as well as two Horse Rings tucked in the bottom right-hand corner. These two rings play an important role in what follows -

Step 3 Negotiate with Fremont Hills to move part of their horse facilities across the road
If the Country Club were to do something like this, the resulting vacated space on the Country Club property would now be available to build Multi-Family Housing

Step 4 Negotiate with the Club to implement a Multi-Family Housing structure in the area freed up by moving the rings from the Club property.

Mutually beneficial business plan worked out between Town of LAH and Fremont Hills Country Club, allowing LAH to stipulate conditions in deed for the MF housing – further details of business model (MF Housing owned by Town and land lease paid by Town to Country Club or MF Housing built and owned by Club in exchange for considerations - or variations thereof)
Shown here is the outline of a building that could support around 128 or 192 units depending on whether it has 2 or 3 Residential levels.

Could start with 2 and add a 3rd level (or start with 2 wings and add a 3rd

wing) in a subsequent Housing Cycle when RHNA numbers for lowincome housing will very likely grow.

Concluding Notes
a) Just as Westwind can operate as a non-profit on Town–owned property under the “Recreation” heading, so too Fremont Country Club can operate equestrian recreational facilities on this piece of town-owned land – both properties are listed in the Open Space initiative of 2002 under the “Public Recreation” designation.
b) For history on details on Little League occupancy of Town land – see http://www.couperus.org/Scrapbooks/LittleLeague/index.htm in particular note diagram in 4th image with ID# 0500, showing 3 fields.
c) This particular “quid pro quo” negotiation (involving 2 rings) is just one flavor chosen as a particular example. The Club might prefer to just move one ring and instead use some of the space across the road to increase availability for other recreational offerings (Pickleboard is growing in popularity, while Badminton is in increasing demand by the local South Asian community)
d) We have no insights into the popularity or activity level of the equine facilities at the club. A quick google led us to this website
https://windyhillequestrians.com/
This might mean that the club has farmed out the operation of their equestrian operation to a 3rd party that is primarily interested in training of horses and riders, not necessarily housing (boarding) more than a few horses. Obviously they need a ring to operate, but do they need two – and maybe there is enough space to still let Little League retain all four ball fields. Or how serious is the Club about maintaining their commitment to Equine offerings? Maybe they see a better ROI and steady source of income to support the club’s operation from starting a new venture for their club membership – e.g. inexpensive living accommodations for elderly members who would like a modicum of facilities and assistance in their old age.

All of these topics are open to examination and discussion in figuring out a business plan that is mutually beneficial to The Town of Los Altos Hills and The Fremont Hills Country Club.

Multi-Family Housing on Town-Owned Property
Today’s meeting of the of the LAH Sub-division committee (Aug 10 discussing 2 proposals related to the former “Fenwick” property) brought home to me the urgency of emphasizing a point which is apparently understood by some, but not yet fully realized by others – specifically as outlined in the following paragraph.

The case has been made that in order for Los Altos Hills to reach its RHNA numbers – in particular for “low income” units, extraordinary measures will have to be taken to force it to happen. This is because meeting our overall quota for Multi-Family units is going to require special measures as it is – but relying on the overall total to include a sufficient proportion of “Low Income” would require a huge total number of Multi-Family units - such that the overall population of our town would have to explode to sustain such a demand.

One way to solve this might be to “have it built it on Town-owned property” and have the “low income requirement” built into the “deed” for the property – which could in fact be dedicated entirely to “Low” and “Very Low” income units. Maybe a home for retirees, or a facility for “assisted living”, or even accommodations made available to certain classes of public servants (First Responders, School Teachers, Foothill College staff, etc…)
The purpose of this document is not to argue the merits of this claim that it has to occur on town-owned property for it to work. For purposes of this document, we will stipulate that such is the case – the purpose of this document is to suggest a possible solution scenario by means of showing a rough “back of the envelope” design and thus hopefully stimulate further discussion and proposals for alternate approaches or ideas for refinement.

If we can assume for a moment that such a solution can be made to “pencil out” financially, what/where and how might this be physically manifested? Following is a sequence of diagrams with accompanying text, which outline the approach and (assuming it is not perfect) maybe stimulate further thought and creation of other ideas or improvements.

The following is a rough outline - offered in the spirit of a “Brain Storming” basic idea. Not all details are worked out, but it is hoped there is sufficient detail to get the idea across and stimulate further open discussion.

ITEM 11A, Supplement 3

I had hoped to wait for the birth of the new Housing Element Implementation Committee before floating this idea, but tonight’s discussion convinced me to send it out sooner rather than later.

Here goes -
We need first to identify a suitable chunk of town-owned property – an inventory of which may be seen here
http://www.couperus.org/Scrapbooks/Town-Properties/index.htm The Town in fact owns many chunks of real estate (both restricted under provisions of the “Open Space Initiative” of 2002 and otherwise)

but not many that are both unrestricted and large enough to be a candidate to locate a large building. One such candidate is the sister of the land commonly referred to as “Little League Fields – but located immediately north of the latter as denoted by the blue markup in the above diagram (Little League fields are denoted in Red) Looked at in greater detail, we can see that it is a long narrow property which may be a challenge because of its narrow profile.

In the diagram above, we have placed a measuring scale across the narrowest point, and it looks like it may be around 60 ft from lot line to lot line.

(Bear in mind – the level of accuracy of measurement in these diagrams is a factor of the “quick-and-dirty” tools we have at our disposal for this “back of the envelope” investigation. If this approach is to be further investigated, more accurate numbers need to be obtained) Is 60 ft front-to-back sufficient to make this property a feasible candidate?
If we switch our map to one that also shows a satellite view, we see that on-the-spot reality is a little different to the engineering drawing of the previous diagram. The latter gives a completely erroneous impression as to the actual location and width of Purissima Road at this location. With the inclusion of satellite imagery, we can see that

Purissima Road (as manifested in physical paving) is much narrower than we thought and there is a (roughly) 20 ft space between the property’s lot line and the edge of the road.

So we are talking 80 ft (as opposed to 60 ft) available width of which this extra 20 can serve as a useful “set-back” from the main thoroughfare.

So what might it look like if we were to put a building in this space designed purely for “Low and very low income” multi-family housing Imagine a single row of 5 apartments (each 20 by 20 ft) all fronting onto a 8ft corridor- resulting in an approx footprint of 100 ft by 30 ft. (upper narrower section of footprint shown above) Then another adjacent footprint of slightly smaller apartments 20 ft by 15ft, but two

rows of 4 apartments separated by an 8 ft corridor – the southern portion of the yellow footprint shown in the above diagram Given a ground floor (Lobby, Parking, Launderette, Garbage, etc) and three stories each of (5 + 4 + 4) apartments = 39 total units, maybe we have a viable idea?
Just for clarity, below is a schematic of the footprint, consisting of two rectangles, the first is a single row of units fronting onto a common corridor, the other is two rows of units sharing a corridor between them. (Not drawn to scale)