Los Gatos City Council
January 30, 2023

HCD Draft Initial Review 2023-2031 Housing Element
E-6 Appendix E October 2022
No.

Programs
(The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element)
Achievements/Effectiveness Continue/Modify/
Delete
Policy
HOU-4.2
Continue to provide assistance to service providers who support special needs households such as seniors, persons with disabilities (including developmental challenges), and the homeless, such as Project Sentinel, Santa Clara County Housing Authority, and Santa Clara County Office of Supportive Housing.

Modify
Policy
HOU-4.3 Continue to encourage Los Gatos households to participate in financial assistance programs provided in the County of Santa Clara. Continue Actions

4.1 Continue to provide a guide to developments that include affordable housing units as part of the Housing Resources Guide posted on the Town’s website.

Town Housing Resources Guide is updated when
necessary. Modify

4.2 Continue the administration of the Rental Dispute Resolution Program and consider revisions as necessary to make the program as effective as possible in protecting both tenants and landlords’ rights.

The Town continues to use Project Sentinel to
administer a Rental Dispute Resolution Program. Continue

4.3 Continue to allow for an emergency shelter as a by-right permitted use in the Controlled Manufacturing (CM) zoning district, subject to appropriate development standards.

Town Code has been amended to address this. Delete

4.4 Continue to provide support for community and non-profit organizations providing supportive services for homeless persons in Los Gatos.

The Town continues to support organizations that
provide supportive services for homeless persons. Continue

4.5 Support the efforts of the Santa Clara County Fair Housing Consortium. Continue to make referrals through Project Sentinel and provide updated fair housing information on the Town’s website and at public locations through the Town, such as the Adult Recreation Center and public kiosks.

Project Sentinel is a member of the Santa Clara
County Fair Housing Consortium and administers
the Town's Rental Dispute Resolution Program. Modify

4.6 Support the efforts of non-profit affordable housing organizations that provide housing services in Los Gatos.

The Town has met with affordable housing
organizations regarding potential development in
Town.

Modify

4.7 Continue to support the County of Santa Clara’s Continuum of Care plan, as well as the “Housing 1000” campaign by Destination: Home.

The Town continues to support Santa Clara
County's Continuum of Care Plan. Continue

4.8 The Town shall amend the Town Code within one year of the Housing Element adoption to be consistent with the Employee Housing Act.

The Town will comply with State Law if a project is
proposed, or an issue comes up before the Town
Code is amended.

Delete

Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-7
No.

Programs
(The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element)
Achievements/Effectiveness Continue/Modify/
Delete
Goal
HOU-5 Retain and expand affordable housing opportunities for seniors. Modify Policy
HOU-5.1 Promote the Town’s Housing Conservation Program to assist low-income seniors with basic home repairs and maintenance. Modify Policy
HOU-5.2
Allow and encourage small-scale living facilities of two to six seniors that may include nursing care services that can be integrated into existing neighborhoods as infill development. Delete
Policy
HOU-5.3
Work with existing senior lifestyle living and assisted living facilities in Los Gatos, and support the development of new senior housing that includes continuum of care facilities within the Town. Modify Actions

5.1 Provide regularly updated senior housing resource materials at the Adult Recreation Center.

Senior resource materials are updated when
necessary. Modify
Goal
HOU-6 Mitigate Town governmental constraints to affordable and special needs housing development. Modify Policy
HOU-6.1 Continue expediting the permit processing system for affordable residential development applications. Modify Policy
HOU-6.2 Encourage universal design features in all new residential developments, to supplement the Title 24 requirements. Modify Policy
HOU-6.3 Support the rehabilitation and modification of housing to allow accessible to people of all abilities. Modify Policy
HOU-6.4
Support the provision of permanent, affordable, and accessible housing that allows persons with special needs to live independent lives. For the purposes of this Housing Element “persons with special needs” include extremely low-income households, the elderly, overcrowded and large-family households, the homeless population, those in need of emergency shelter, youth aging out of foster care, female-headed or single-parent households, and persons with disabilities, including developmental challenges.

Continue
Policy
HOU-6.5 Support efforts to provide coordinated services for persons with special needs in the Town. Modify Actions

6.1 Regularly review Town planning and zoning regulations and remove affordable housing development constraints as appropriate.

The Town's Housing Element contains a number
of items that limit or remove constraints. Modify

HCD Draft Initial Review 2023-2031 Housing Element
E-8 Appendix E October 2022
No.

Programs
(The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element)
Achievements/Effectiveness Continue/Modify/
Delete

6.2 Continue to enforce Section 29.10.505–530 of the Town Code to ensure equal access to housing for persons with disabilities under the Fair Housing Act and provide specific procedures for requesting and granting reasonable accommodations.

This has not yet been completed. Continue

6.3 Remove constraints to housing for persons with disabilities and encourage accessible housing in new residential developments.

Removal of constraints is considered when
necessary. Modify

6.4 Give priority to special needs housing by allowing for reduced processing time and streamlined procedures for such appropriate zoning/land use applications.

If a project of this nature is submitted it will be
given priority. Modify

6.5 Include preferential handling of special needs populations in management plans and regulatory agreements of funded projects.

Will be considered when plans are adopted, and
projects are funded. Modify

6.6 Explore opportunities to work with local and/or regional partners to provide rental assistance for persons with developmental challenges.

The Town will explore opportunities with local
and/or regional partners during the Housing
Element update process.

Modify

6.7 Consider development of universal design enhancements to existing design guidelines and standards to encourage the inclusion of universal design features in new construction. Periodically study every two years and adopt as appropriate specific revisions or amendments to the Town’s development documents as part of the Town Building Code.

The Town considers enhancements to universal
design and the Town requires universal design
features in new construction consistent with
Building Code requirements.

Delete

6.8 Increase awareness of universal design principles by periodically educating the Town Council, Commissions, and Boards about universal design and making information available to residents and builders at the Community Development Counter.

The Town takes appropriate actions to increase
awareness of universal design principles. Delete

6.9 Continue to work with the local California Department of Developmental Services Regional Center to continue to inform families within Los Gatos on housing and services available for persons with developmental challenges.

The Town works with the California Department
of Developmental Services to inform citizens of
available services.

Modify

6.10 On a biannual basis, continue to review, evaluate, update, and streamline as necessary, the development process for housing developments that will guarantee affordable units on a long-term basis for very low-, low-, and moderate-income households.

The Town considers improvements to the
development review process for affordable
housing projects when they are proposed.

Delete

Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-9
No.

Programs
(The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element)
Achievements/Effectiveness Continue/Modify/
Delete
Goal
HOU-7 Encourage residential construction that promotes green building and energy conservation practices. Modify Policy
HOU-7.1
Encourage sustainable housing development throughout the Town using the Town’s voluntary green building program by continuing to require that all residential development applications complete the Build It Green GreenPoint Rated Checklist as part of the development application package.

Modify
Policy
HOU-7.2 Promote the construction of energy efficient new homes utilizing the Energy Star Homes Program. Delete

7.1 Continue to enforce State of California Title 24 requirements for energy conservation. The Town enforces Title 24 requirements. Continue Goal
HOU-8 Ensure that the Town has sufficient resources and takes appropriate measures to implement the Housing Element. Modify Policy
HOU-8.1
All approvals of residential developments of three or more units shall include a finding that the proposed development is consistent with the Town’s Housing Element and addresses the Town’s housing needs as identified in the Housing Element. Delete Policy
HOU-8.2 Provide adequate management and staffing of affordable housing funds and programs. Continue

8.1 Prepare an annual housing report for the review of the Town Council including information on progress made towards achieving new construction need, affordable housing conserved/developed, effectiveness of existing programs and recommendations for improvement.

The Town prepares an annual housing report. Continue

8.2 Continue to fund staff for the management and planning of housing programs and funding for the Town.

The Town has contracted with HouseKeys to
administer our affordable housing program and
has staff that dedicate time to the Town’s
affordable housing program.

Delete

8.3 Deliver the adopted Housing Element to the San Jose Water Company and the West Valley Sanitation District.

Town staff regularly work with the San Jose Water
Company and West Valley Sanitation District on
upgrades to their infrastructure and they are
involved in development applications and
environmental review.

Modify

HCD Draft Initial Review 2023-2031 Housing Element
E-10 Appendix E October 2022
Production of Housing
The 2015 Housing Element identified a Regional Housing Needs Allocation (RHNA) of 619 housing units in Los Gatos between January 1, 2015, and June 30, 2023. The RHNA was divided into the following income categories:
 100 units affordable to extremely low-income households.  101 units affordable to very low-income households.
 112 units affordable to low-income households.
 132 units affordable to moderate-income households.
 174 units affordable to above moderate-income households.

As shown in Table A5-2, during the 2015–2023 planning period, 511 new units were added to the Town’s housing stock, achieving approximately 83 percent of the Town’s RHNA. Units affordable to moderate- and lower-income households that were created during the planning period include density bonus senior rental units (North Forty Phase I), an attached condominium (Union Avenue) and detached townhomes (Knowles Avenue) produced through the BMP program and accessory dwelling units.

Table E-2 Housing Units Produced, January 1, 2015, to June 30, 2023 Affordability
New Construction
Need
Housing Units
Produced Percent Achieved
Extremely Low 100 0 *
Very Low 101 49 24.4%
Low 112 3 2.7%
Moderate 132 120 90.9%
Above Moderate 174 339 194.8%
Total 619 511 82.5%
Source: HCD Annual Progress Report Dashboard (as of August 5, 2022).

Note: This table and text will be updated prior to finalization to account for units through January 1, 2023.

Preservation of “At Risk” Units
According to the 2015 Housing Element, there were no affordable units at risk of converting to market rate within 10 years from the beginning of the 2015 to 2023 planning period.

Rehabilitation of Existing Units
The Town did not rehabilitate any housing units between 2015 and 2023.

Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-11
E.4 Appropriateness of Goals, Objectives, and Policies
The goals, objectives, and policies identified in the 2015 Housing Element were appropriate for the 2015 to 2023 timeframe because they directly relate to the program requirements listed by the California Department of Housing and Community Development.

As for new construction, the greatest progress was made in producing housing in the moderate income and above moderate-income categories, where the Town permitted approximately 62 percent and 80 percent of the needed units, respectively. The Town permitted only about a quarter of its needed very low-income units and less than three percent of its low-income units. As was the case in the in prior years, the cost of housing continued to be high in Los Gatos, making affordable housing difficult to develop in the Los Gatos market. The Town successfully provided the governmental framework to encourage and facilitate affordable housing through a continuation of its BMP program and enhanced Accessory Dwelling Unit Ordinance.

E.5 Summary
Like many communities, the Town of Los Gatos experienced less development than expected in its 2015–2023 planning period. Of the 630 units it identified in its table of quantified housing objectives (Table H-3 on page 47 of the 2015 Housing Element), the Town permitted 511 units (approximately 81 percent), most of them for above moderate-income households.

Nonetheless, the goals, objectives, policies, and actions in the 2015 to 2023 Housing Element complied with State housing law that was in effect at the time and provided proper guidance for housing development in the Town. In the 2023 to 2031 Housing Element update, objectives for each of the goals will be modified as appropriate to more specifically respond to the current housing environment in Los Gatos. Policies will also be modified as needed to respond to current Housing Element law and existing and anticipated residential development conditions.

List of Organizations Contacted

APPENDIX
F

Appendix F. List of Organizations Contacted
October 2022 Appendix F F-1
F.1 List of Organizations Contacted
1 Native American Heritage Commission Tribal Consultation List Santa Clara County 07/22/2020
1 Amah Mutsun Tribal Band
Valentin Lopez, Chairperson
P.O. Box 5272
Galt, CA 95632
Phone number (916) 743-5833
[email protected]
2 Amah Mutsun Tribal Band of Mission San Juan Bautista
Irenne Zwierlein, Chairperson
789 Canada Road
Woodside, CA 94062
Phone: (650) 851-7489
Fax: (650) 332-1526
[email protected]
3 Indian Canyon Mutsun Band of Costanoan
Ann Marie Sayers, Chairperson
P.O. Box 28
Hollister, CA 95024
Phone number (831) 637-4238
[email protected]
4 Muwekma Ohlone Indian Tribe of the SF Bay Area
Charlene Mijmeh, Chairperson
20885 Redwood Road, Suite 232
Castro Valley, CA 94546
Phone: (408) 464-2892
[email protected]
5 Muwekma Ohlone Indian Tribe of the SF Bay Area
Monica Arellano
20885 Redwood Road, Suite 232
Castro Valley, CA 94546
[email protected]
6 North Valley Yokuts Tribe
Timothy Perez, MLD Contact
P.O. Box 717
Linden, CA 95236
Phone: (209) 662-2788
[email protected]

HCD Draft Initial Review 2023-2031 Housing Element
F-2 Appendix F October 2022
7 North Valley Yokuts Tribe
Katherine Perez, Chairperson
P.O. Box 717
Linden, CA 95236
Phone: (209) 887-3415
[email protected]
8 The Ohlone Indian Tribe
Andres Galvan
P.O. Box 3388
Fremont, CA 94539
Phone: (510) 882-0527
Fax: (510) 687-9393
[email protected]
9 The Confederated Villages of Lisjan
Corrina Gould, Chairperson
10926 Edes Avenue
Oakland, CA 94603
Phone: (510) 882-027
[email protected]
2 Additional List of Contacted Organizations
1 2
3 Santa Clara County Social Services Agency
353 West Julian Street
San Jose, CA 95110
[email protected]
(408) 755-7100
Pancho Guevara
Executive Director
Sacred Heart Community Service
1381 South First Street
San Jose, CA 95110
(408) 278-2160
United Way Bay Area
1400 Parkmoor Avenue San Jose, Ca 95126
(408) 345-4300

Appendix F. List of Organizations Contacted
October 2022 Appendix F F-3
3 Engage Los Gatos Housing

HCD Draft Initial Review 2023-2031 Housing Element

Appendix F. List of Organizations Contacted

HCD Draft Initial Review 2023-2031 Housing Element

Appendix F. List of Organizations Contacted

HCD Draft Initial Review 2023-2031 Housing Element

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AFFH Segregation Report Los Gatos G

APPENDIX

1 AFFH SEGREGATION REPORT: LOS
GATOS
UC Merced Urban Policy Lab and ABAG/MTC Staff
Version of Record: March 06, 15:57:57

2 0.1 Table of content

0.1 Table of content .................................................................................................... 2

0.2 List of figures ....................................................................................................... 3

0.3 List of tables ........................................................................................................ 3 1 Introduction .............................................................................................................. 4

1.1 Purpose of this Report ............................................................................................. 4

1.2 Defining Segregation ............................................................................................... 5

1.3 Segregation Patterns in the Bay Area ........................................................................... 5

1.4 Segregation and Land Use ......................................................................................... 6 2 Racial Segregation in Town of Los Gatos ........................................................................... 8

2.1 Neighborhood Level Racial Segregation (within Town of Los Gatos) ...................................... 8

2.2 Regional Racial Segregation (between Los Gatos and other jurisdictions) .............................. 16 3 Income Segregation in Town of Los Gatos ........................................................................ 21

3.1 Neighborhood Level Income Segregation (within Los Gatos) ............................................... 21

3.2 Regional Income Segregation (between Los Gatos and other jurisdictions) ............................. 27 4 Appendix 1: Summary of Findings ................................................................................. 31

4.1 Segregation in Town of Los Gatos .............................................................................. 31

4.2 Segregation Between Town of Los Gatos and Other jurisdictions in the Bay Area Region ............ 31 5 Appendix 2: Segregation Data ...................................................................................... 33 6 References .............................................................................................................. 37

3 0.2 List of figures
Figure 1: Racial Dot Map of Los Gatos (2020) .............................................................................. 9 Figure 2: Racial Isolation Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2020) ....... 11 Figure 3: Racial Dissimilarity Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2020) .. 14 Figure 4: Theil’s H Index Values for Racial Segregation in Los Gatos Compared to Other Bay Area Jurisdictions (2020) ........................................................................................................................... 15 Figure 5: Racial Dot Map of Los Gatos and Surrounding Areas (2020) ................................................ 16 Figure 6: Racial Demographics of Los Gatos Compared to All Bay Area Jurisdictions (2020) ..................... 18 Figure 7: Comparing the Share of People of Color in Los Gatos and Vicinity to the Bay Area (2020) ........... 19 Figure 8: Income Dot Map of Los Gatos (2015) ........................................................................... 22 Figure 9: Income Group Isolation Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2015) ................................................................................................................................... 24 Figure 10: Income Group Dissimilarity Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2015) ........................................................................................................................... 26 Figure 11: Income Group Theil’s H Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2015) ........................................................................................................................... 27 Figure 12: Income Dot Map of Los Gatos and Surrounding Areas (2015) .............................................. 28 Figure 13: Income Demographics of Los Gatos Compared to Other Bay Area Jurisdictions (2015) ............... 29

0.3 List of tables
Table 1: Racial Isolation Index Values for Segregation within Los Gatos ............................................. 10 Table 2: Racial Dissimilarity Index Values for Segregation within Los Gatos ........................................ 13 Table 3: Theil’s H Index Values for Racial Segregation within Los Gatos ............................................ 15 Table 4: Population by Racial Group, Los Gatos and the Region ...................................................... 17 Table 5: Regional Racial Segregation Measures .......................................................................... 20 Table 6: Income Group Isolation Index Values for Segregation within Los Gatos ................................... 23 Table 7: Income Group Dissimilarity Index Values for Segregation within Los Gatos .............................. 25 Table 8: Theil’s H Index Values for Income Segregation within Los Gatos ........................................... 26 Table 9: Population by Income Group, Los Gatos and the Region ..................................................... 28 Table 10: Regional Income Segregation Measures ....................................................................... 30 Table 11: Neighborhood Racial Segregation Levels in Los Gatos ...................................................... 33 Table 12: Neighborhood Income Segregation Levels in Los Gatos ..................................................... 34 Table 13: Regional Racial Segregation Measures ......................................................................... 35 Table 14: Regional Income Segregation Measures ....................................................................... 35 Table 15: Population by Racial Group, Los Gatos and the Region ..................................................... 36 Table 16: Population by Income Group, Los Gatos and the Region ................................................... 36

4 1 INTRODUCTION
The requirement to Affirmatively Further Fair Housing (AFFH) is derived from The Fair Housing Act of 1968, which prohibited discrimination concerning the sale, rental, and financing of housing based on race, color, religion, national origin, or sex—and was later amended to include familial status and disability.1
The 2015 U.S. Department of Housing and Urban Development (HUD) Rule to Affirmatively Further Fair Housing and California Assembly Bill 686 (2018) mandate that each jurisdiction takes meaningful action to address significant disparities in housing needs and access to opportunity.23 AB 686 requires that jurisdictions incorporate AFFH into their Housing Elements, which includes inclusive community participation, an assessment of fair housing, a site inventory reflective of AFFH, and the development of goals, policies, and programs to meaningfully address local fair housing issues. ABAG and UC Merced have prepared this report to assist Bay Area jurisdictions with the Assessment of Fair Housing section of the Housing Element.

Assessment of Fair Housing Components
The Assessment of Fair Housing includes five components, which are discussed in detail on pages 22-43 of HCD’s AFFH Guidance Memo:

A: Summary of fair housing enforcement and outreach capacity B: Integration and segregation patterns, and trends related to people with protected characteristics
C: Racially or ethnically concentrated areas of poverty D: Disparities in access to opportunity
E: Disproportionate housing needs, including displacement risk

1.1 Purpose of this Report
This report describes racial and income segregation in Bay Area jurisdictions. Local jurisdiction staff can use the information in this report to help fulfill a portion of the second component of the Assessment of Fair Housing, which requires analysis of integration and segregation patterns and trends related to people with protected characteristics and lower incomes. Jurisdictions will still need to perform a similar analysis for familial status and populations with disability.

This report provides segregation measures for both the local jurisdiction and the region using several indices. For segregation between neighborhoods within a city (intra-city segregation), this report includes isolation indices, dissimilarity indices, and Theil’s-H index. The isolation index measures

1 https://www.justice.gov/crt/fair-housing-act-2 2 HCD AFFH Guidance Memo 3 The 2015 HUD rule was reversed in 2020 and partially reinstated in 2021.

5 segregation for a single group, while the dissimilarity index measures segregation between two groups.

The Theil’s H-Index can be used to measure segregation between all racial or income groups across the city at once. HCD’s AFFH guidelines require local jurisdictions to include isolation indices and dissimilarity indices in the Housing Element. Theil’s H index is provided in addition to these required measures. For segregation between cities within the Bay Area (inter-city segregation), this report includes dissimilarity indices at the regional level as required by HCD’s AFFH guidelines. HCD’s AFFH guidelines also require jurisdictions to compare conditions at the local level to the rest of the region; and this report presents the difference in the racial and income composition of a jurisdiction relative to the region as a whole to satisfy the comparison requirement.

1.2 Defining Segregation
Segregation is the separation of different demographic groups into different geographic locations or communities, meaning that groups are unevenly distributed across geographic space. This report examines two spatial forms of segregation: neighborhood level segregation within a local jurisdiction and city level segregation between jurisdictions in the Bay Area.

Neighborhood level segregation (within a jurisdiction, or intra-city): Segregation of race and income groups can occur from neighborhood to neighborhood within a city. For example, if a local jurisdiction has a population that is 20% Latinx, but some neighborhoods are 80% Latinx while others have nearly no Latinx residents, that jurisdiction would have segregated neighborhoods.

City level segregation (between jurisdictions in a region, or inter-city): Race and income divides also occur between jurisdictions in a region. A region could be very diverse with equal numbers of white, Asian, Black, and Latinx residents, but the region could also be highly segregated with each city comprised solely of one racial group.

There are many factors that have contributed to the generation and maintenance of segregation.

Historically, racial segregation stemmed from explicit discrimination against people of color, such as restrictive covenants, redlining, and discrimination in mortgage lending. This history includes many overtly discriminatory policies made by federal, state, and local governments (Rothstein 2017).

Segregation patterns are also affected by policies that appear race-neutral, such as land use decisions and the regulation of housing development.

Segregation has resulted in vastly unequal access to public goods such as quality schools, neighborhood services and amenities, parks and playgrounds, clean air and water, and public safety (Trounstine 2015). This generational lack of access for many communities, particularly people of color and lower income residents, has often resulted in poor life outcomes, including lower educational attainment, higher morbidity rates, and higher mortality rates (Chetty and Hendren 2018, Ananat 2011, Burch 2014, Cutler and Glaeser 1997, Sampson 2012, Sharkey 2013).

1.3 Segregation Patterns in the Bay Area
Across the San Francisco Bay Area, white residents and above moderate-income residents are significantly more segregated from other racial and income groups (see Appendix 2). The highest levels of racial segregation occur between the Black and white populations. The analysis completed for this report indicates that the amount of racial segregation both within Bay Area cities and across jurisdictions in the region has decreased since the year 2000. This finding is consistent with recent research from the Othering and Belonging Institute at UC Berkeley, which concluded that “[a]lthough 7

6 of the 9 Bay Area counties were more segregated in 2020 than they were in either 1980 or 1990, racial residential segregation in the region appears to have peaked around the year 2000 and has generally declined since.”4
However, compared to cities in other parts of California, Bay Area jurisdictions have more neighborhood level segregation between residents from different racial groups. Additionally, there is also more racial segregation between Bay Area cities compared to other regions in the state.

1.4 Segregation and Land Use
It is difficult to address segregation patterns without an analysis of both historical and existing land use policies that impact segregation patterns. Land use regulations influence what kind of housing is built in a city or neighborhood (Lens and Monkkonen 2016, Pendall 2000). These land use regulations in turn impact demographics: they can be used to affect the number of houses in a community, the number of people who live in the community, the wealth of the people who live in the community, and where within the community they reside (Trounstine 2018). Given disparities in wealth by race and ethnicity, the ability to afford housing in different neighborhoods, as influenced by land use regulations, is highly differentiated across racial and ethnic groups (Bayer, McMillan, and Reuben 2004).5 ABAG/MTC plans to
issue a separate report detailing the existing land use policies that influence segregation patterns in the Bay Area.

4 For more information, see https://belonging.berkeley.edu/most-segregated-cities-bay-area-2020. 5 Using a household-weighted median of Bay Area county median household incomes, regional values were $61,050 for Black residents, $122,174 for Asian/Pacific Islander residents, $121,794 for white residents, and $76,306 for Latinx residents. For the source data, see U.S. Census Bureau, American Community Survey 5-Year Data (2015- 2019), Table B19013B, Table B19013D, B19013H, and B19013I.

7 Definition of Terms - Geographies
Neighborhood: In this report, “neighborhoods” are approximated by tracts.6 Tracts are statistical geographic units defined by the U.S. Census Bureau for the purposes of disseminating data. In the Bay Area, tracts contain on average 4,500 residents. Nearly all Bay Area jurisdictions contain at least two census tracts, with larger jurisdictions containing dozens of tracts.

Jurisdiction: Jurisdiction is used to refer to the 109 cities, towns, and unincorporated county areas that are members of ABAG. Though not all ABAG jurisdictions are cities, this report also uses the term “city” interchangeably with “jurisdiction” in some places.

Region: The region is the nine-county San Francisco Bay Area, which is comprised of Alameda County, Contra Costa County, Marin County, Napa County, San Francisco County, San Mateo County, Santa Clara County, Solano County, and Sonoma County.

6 Throughout this report, neighborhood level segregation measures are calculated using census tract data.

However, the racial dot maps in Figure 1 and Figure 5 use data from census blocks, while the income group dot maps in Figure 8 and Figure 12 use data from census block groups. These maps use data derived from a smaller geographic scale to better show spatial differences in where different groups live. Census block groups are subdivisions of census tracts, and census blocks are subdivisions of block groups. In the Bay Area, block groups contain on average 1,500 people, while census blocks contain on average 95 people.

8 2 RACIAL SEGREGATION IN TOWN OF LOS GATOS
Definition of Terms - Racial/Ethnic Groups
The U.S. Census Bureau classifies racial groups (e.g. white or Black/African American) separately from Hispanic/Latino ethnicity.7 This report combines U.S. Census Bureau definitions for race and ethnicity into the following racial groups:

White: Non-Hispanic white
Latinx: Hispanic or Latino of any race8
Black: Non-Hispanic Black/African American
Asian/Pacific Islander: Non-Hispanic Asian or Non-Hispanic Pacific Islander People of Color: All who are not non-Hispanic white (including people who identify as “some other race” or “two or more races”)9

2.1 Neighborhood Level Racial Segregation (within Town of Los Gatos) Racial dot maps are useful for visualizing how multiple racial groups are distributed within a specific geography. The racial dot map of Los Gatos in Figure 1 below offers a visual representation of the spatial distribution of racial groups within the jurisdiction. Generally, when the distribution of dots does not suggest patterns or clustering, segregation measures tend to be lower. Conversely, when clusters of certain groups are apparent on a racial dot map, segregation measures may be higher.

7 More information about the Census Bureau’s definitions of racial groups is available here:
https://www.census.gov/topics/population/race/about.html. 8 The term Hispanic has historically been used to describe people from numerous Central American, South American, and Caribbean countries. In recent years, the term Latino or Latinx has become preferred. This report generally uses Latinx to refer to this racial/ethnic group. 9 Given the uncertainty in the data for population size estimates for racial and ethnic groups not included in the Latinx, Black, or Asian/Pacific Islander categories, this report only analyzes these racial groups in the aggregate People of Color category.

9 Figure 1: Racial Dot Map of Los Gatos (2020)
Universe: Population. Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: The plot shows the racial distribution at the census block level for Town of Los Gatos and vicinity. Dots in each census block are randomly placed and should not be construed as actual placement of people.

There are many ways to quantitatively measure segregation. Each measure captures a different aspect of the ways in which groups are divided within a community. One way to measure segregation is by using an isolation index:
• The isolation index compares each neighborhood’s composition to the jurisdiction’s demographics as a whole.
• This index ranges from 0 to 1. Higher values indicate that a particular group is more isolated from other groups.
• Isolation indices indicate the potential for contact between different groups. The index can be interpreted as the experience of the average member of that group. For example, if the isolation index is .65 for Latinx residents in a city, then the average Latinx resident in that city lives in a neighborhood that is 65% Latinx.

Within Town of Los Gatos the most isolated racial group is white residents. Los Gatos’s isolation index of 0.663 for white residents means that the average white resident lives in a neighborhood that is

66.3% white. Other racial groups are less isolated, meaning they may be more likely to encounter other racial groups in their neighborhoods. The isolation index values for all racial groups in Los Gatos for the years 2000, 2010, and 2020 can be found in Table 1 below. Among all racial groups in this jurisdiction, the white population’s isolation index has changed the most over time, becoming less segregated from other racial groups between 2000 and 2020.

10 The “Bay Area Average” column in this table provides the average isolation index value across Bay Area jurisdictions for different racial groups in 2020.10 The data in this column can be used as a comparison to provide context for the levels of segregation experienced by racial groups in this jurisdiction. For example, Table 1 indicates the average isolation index value for white residents across all Bay Area jurisdictions is 0.491, meaning that in the average Bay Area jurisdiction a white resident lives in a neighborhood that is 49.1% white.

Table 1: Racial Isolation Index Values for Segregation within Los Gatos Los Gatos Bay Area
Average
Race 2000 2010 2020 2020
Asian/Pacific Islander 0.079 0.118 0.197 0.245
Black/African American 0.009 0.012 0.022 0.053
Latinx 0.059 0.082 0.104 0.251
White 0.838 0.774 0.663 0.491
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Figure 2 below shows how racial isolation index values in Los Gatos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each racial group, the spread of dots represents the range of isolation index values among Bay Area jurisdictions.

Additionally, the black line within each racial group notes the isolation index value for that group in Town of Los Gatos, and each dashed red line represents the Bay Area average for the isolation index for that group. Local staff can use this chart to contextualize how segregation levels for racial groups in their jurisdiction compare to other jurisdictions in the region.

10 This average only includes the 104 jurisdictions that have more than one census tract, which is true for all comparisons of Bay Area jurisdictions’ segregation measures in this report. The segregation measures in this report are calculated by comparing the demographics of a jurisdiction’s census tracts to the jurisdiction’s demographics, and such calculations cannot be made for the five jurisdictions with only one census tract (Brisbane, Calistoga, Portola Valley, Rio Vista, and Yountville).

11 Figure 2: Racial Isolation Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Another way to measure segregation is by using a dissimilarity index:
• This index measures how evenly any two groups are distributed across neighborhoods relative to their representation in a city overall. The dissimilarity index at the jurisdiction level can be interpreted as the share of one group that would have to move neighborhoods to create perfect integration for these two groups.
• The dissimilarity index ranges from 0 to 1. Higher values indicate that groups are more unevenly distributed (e.g. they tend to live in different neighborhoods).

12 Dissimilarity Index Guidance for Cities with Small Racial Group Populations The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if that group represents approximately less than 5% of the jurisdiction’s total population.

HCD’s AFFH guidance requires the Housing Element to include the dissimilarity index values for racial groups, but also offers flexibility in emphasizing the importance of various measures. ABAG/MTC recommends that when cities have population groups that are less than 5% of the jurisdiction’s population (see Table 4), jurisdiction staff use the isolation index or Thiel’s H-Index to gain a more accurate understanding of their jurisdiction’s neighborhood-level segregation patterns (intra-city segregation).

If a jurisdiction has a very small population of a racial group, this indicates that segregation between the jurisdiction and the region (inter-city segregation) is likely to be an important feature of the jurisdiction’s segregation patterns.

In Town of Los Gatos, the Black/African American group is 0.9 percent of the population - so staff should be aware of this small population size when evaluating dissimilarity index values involving this group.

Table 2 below provides the dissimilarity index values indicating the level of segregation in Los Gatos between white residents and residents who are Black, Latinx, or Asian/Pacific Islander. The table also provides the dissimilarity index between white residents and all residents of color in the jurisdiction, and all dissimilarity index values are shown across three time periods (2000, 2010, and 2020).

In Los Gatos the highest segregation is between Black and white residents (see Table 2). Los Gatos’s Black /white dissimilarity index of 0.369 means that 36.9% of Black (or white) residents would need to move to a different neighborhood to create perfect integration between Black residents and white residents. However, local jurisdiction staff should note that this dissimilarity index value is not a reliable data point due to small population size. See callout box above for more information.

The “Bay Area Average” column in this table provides the average dissimilarity index values for these racial group pairings across Bay Area jurisdictions in 2020. The data in this column can be used as a comparison to provide context for the levels of segregation between communities of color are from white residents in this jurisdiction.

13 For example, Table 2 indicates that the average Latinx/white dissimilarity index for a Bay Area jurisdiction is 0.207, so on average 20.7% of Latinx (or white residents) in a Bay Area jurisdiction would need to move to a different neighborhood within the jurisdiction to create perfect integration between Latinx and white residents in that jurisdiction.

Table 2: Racial Dissimilarity Index Values for Segregation within Los Gatos Los Gatos Bay Area
Average
Race 2000 2010 2020 2020
Asian/Pacific Islander vs. White 0.106 0.145 0.182 0.185 Black/African American vs. White 0.223* 0.246* 0.369* 0.244 Latinx vs. White 0.119 0.143 0.179 0.207
People of Color vs. White 0.093 0.124 0.157 0.168
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Note: If a number is marked with an asterisk (*), it indicates that the index is based on a racial group making up less than 5 percent of the jurisdiction population, leading to unreliable numbers.

Figure 3 below shows how dissimilarity index values in Town of Los Gatos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each racial group pairing, the spread of dots represents the range of dissimilarity index values among Bay Area jurisdictions. Additionally, the black line within each racial group pairing notes the dissimilarity index value in Los Gatos, and each dashed red line represents the Bay Area average for the dissimilarity index for that pairing. Similar to Figure 2, local staff can use this chart to contextualize how segregation levels between white residents and communities of color in their jurisdiction compare to the rest of the region. However, staff should be mindful of whether a racial group in their jurisdiction has a small population (approximately less than 5% of the jurisdiction’s population), as the dissimilarity index value is less reliable for small populations.

14 Figure 3: Racial Dissimilarity Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if that group represents approximately less than 5% of the jurisdiction’s total population. ABAG/MTC recommends that when cities have population groups that are less than 5% of the jurisdiction’s population (see Table 4), jurisdiction staff could focus on the isolation index or Thiel’s H-Index to gain a more accurate understanding of neighborhood-level racial segregation in their jurisdiction.

The Theil’s H Index can be used to measure segregation between all groups within a jurisdiction:
• This index measures how diverse each neighborhood is compared to the diversity of the whole city. Neighborhoods are weighted by their size, so that larger neighborhoods play a more significant role in determining the total measure of segregation. • The index ranges from 0 to 1. A Theil’s H Index value of 0 would mean all neighborhoods within a city have the same demographics as the whole city. A value of 1 would mean each group lives exclusively in their own, separate neighborhood.
• For jurisdictions with a high degree of diversity (multiple racial groups comprise more than 10% of the population), Theil’s H offers the clearest summary of overall segregation.

The Theil’s H Index values for neighborhood racial segregation in Los Gatos for the years 2000, 2010, and 2020 can be found in Table 3 below. The “Bay Area Average” column in the table provides the average Theil’s H Index across Bay Area jurisdictions in 2020. Between 2010 and 2020, the Theil’s H Index for racial segregation in Los Gatos increased, suggesting that there is now more neighborhood level racial segregation within the jurisdiction. In 2020, the Theil’s H Index for racial segregation in Los

15 Gatos was lower than the average value for Bay Area jurisdictions, indicating that neighborhood level racial segregation in Los Gatos is less than in the average Bay Area city.

Table 3: Theil’s H Index Values for Racial Segregation within Los Gatos Los Gatos Bay Area
Average
Index 2000 2010 2020 2020
Theil's H Multi-racial 0.011 0.015 0.023 0.042
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Figure 4 below shows how Theil’s H index values for racial segregation in Los Gatos compare to values in other Bay Area jurisdictions in 2020. In this chart, each dot represents a Bay Area jurisdiction.

Additionally, the black line notes the Theil’s H index value for neighborhood racial segregation in Los Gatos, and the dashed red line represents the average Theil’s H index value across Bay Area jurisdictions. Local staff can use this chart to compare how neighborhood racial segregation levels in their jurisdiction compare to other jurisdictions in the region.

Figure 4: Theil’s H Index Values for Racial Segregation in Los Gatos Compared to Other Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

16 2.2 Regional Racial Segregation (between Los Gatos and other jurisdictions)
At the regional level, segregation is measured between cities instead of between neighborhoods. Racial dot maps are not only useful for examining neighborhood racial segregation within a jurisdiction, but these maps can also be used to explore the racial demographic differences between different jurisdictions in the region. Figure 5 below presents a racial dot map showing the spatial distribution of racial groups in Los Gatos as well as in nearby Bay Area cities.

Figure 5: Racial Dot Map of Los Gatos and Surrounding Areas (2020) Universe: Population.

Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: The plot shows the racial distribution at the census block level for Town of Los Gatos and vicinity. Dots in each census block are randomly placed and should not be construed as actual placement of people.

To understand how each city contributes to the total segregation of the Bay Area, one can look at the difference in the racial composition of a jurisdiction compared to the racial composition of the region as a whole. The racial demographics in Los Gatos for the years 2000, 2010, and 2020 can be found in Table 4 below. The table also provides the racial composition of the nine-county Bay Area. As of 2020, Los Gatos has a higher share of white residents than the Bay Area as a whole, a lower share of Latinx residents, a lower share of Black residents, and a lower share of Asian/Pacific Islander residents.

17 Table 4: Population by Racial Group, Los Gatos and the Region Los Gatos Bay Area
Race 2000 2010 2020 2020
Asian/Pacific Islander 7.6% 10.9% 18.3% 28.2%
Black/African American 0.8% 0.9% 0.9% 5.6%
Latinx 5.2% 7.2% 9.0% 24.4%
Other or Multiple Races 3.2% 4.0% 6.5% 5.9%
White 83.3% 77.0% 65.3% 35.8%
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Figure 6 below compares the racial demographics in Los Gatos to those of all 109 Bay Area jurisdictions.11 In this chart, each dot represents a Bay Area jurisdiction. For each racial group, the spread of dots represents the range of that group’s representation among Bay Area jurisdictions.

Additionally, the black line within each racial group notes the percentage of the population of Town of Los Gatos represented by that group and how that percentage ranks among all 109 jurisdictions. Local staff can use this chart to compare the representation of different racial groups in their jurisdiction to those groups’ representation in other jurisdictions in the region, which can indicate the extent of segregation between this jurisdiction and the region.

11 While comparisons of segregation measures are made only using the 104 jurisdictions with more than one census tract, this comparison of jurisdiction level demographic data can be made using all 109 jurisdictions.

18 Figure 6: Racial Demographics of Los Gatos Compared to All Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.

Source U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

The map in Figure 7 below also illustrates regional racial segregation between Los Gatos and other jurisdictions. This map demonstrates how the percentage of people of color in Los Gatos and surrounding jurisdictions compares to the Bay Area as a whole:
• Jurisdictions shaded orange have a share of people of color that is less than the Bay Area as a whole, and the degree of difference is greater than five percentage points. • Jurisdictions shaded white have a share of people of color comparable to the regional percentage of people of color (within five percentage points). • Jurisdictions shaded grey have a share of people of color that is more than five percentage points greater than the regional percentage of people of color.

19 Figure 7: Comparing the Share of People of Color in Los Gatos and Vicinity to the Bay Area (2020)
Universe: Population.

Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.

Note: People of color refer to persons not identifying as non-Hispanic white. The nine-county Bay Area is the reference region for this map.

Segregation between jurisdictions in the region can also be analyzed by calculating regional values for the segregation indices discussed previously. Table 5 presents dissimilarity index, isolation index, and Theil’s H index values for racial segregation for the entire nine-county Bay Area in 2010 and 2020. In the previous section of this report focused on neighborhood level racial segregation, these indices were calculated by comparing the racial demographics of the census tracts within a jurisdiction to the demographics of the jurisdiction as a whole. In Table 5, these measures are calculated by comparing the racial demographics of local jurisdictions to the region’s racial makeup. For example, looking at the 2020 data, Table 5 shows the white isolation index value for the region is 0.429, meaning that on average white Bay Area residents live in a jurisdiction that is 42.9% white in 2020. An example of regional dissimilarity index values in Table 5 is the Black/white dissimilarity index value of 0.459, which means that across the region 45.9% of Black (or white) residents would need to move to a different jurisdiction to evenly distribute Black and white residents across Bay Area jurisdictions. The dissimilarity index values in Table 5 reflect recommendations made in HCD’s AFFH guidance for calculating dissimilarity at the region level.12 The regional value for the Theil’s H index measures how

12 For more information on HCD’s recommendations regarding data considerations for analyzing integration and segregation patterns, see page 31 of the AFFH Guidance Memo.

20 diverse each Bay Area jurisdiction is compared to the racial diversity of the whole region. A Theil’s H Index value of 0 would mean all jurisdictions within the Bay Area have the same racial demographics as the entire region, while a value of 1 would mean each racial group lives exclusively in their own separate jurisdiction. The regional Theil’s H index value for racial segregation decreased slightly between 2010 and 2020, meaning that racial groups in the Bay Area are now slightly less separated by the borders between jurisdictions.

Table 5: Regional Racial Segregation Measures
Index Group 2010 2020
Isolation Index Regional Level
Asian/Pacific Islander 0.317 0.378
Black/African American 0.144 0.118
Latinx 0.283 0.291
White 0.496 0.429
People of Color 0.629 0.682
Dissimilarity Index Regional Level
Asian/Pacific Islander vs. White 0.384 0.369
Black/African American vs. White 0.475 0.459
Latinx vs. White 0.301 0.297
People of Color vs. White 0.296 0.293
Theil's H Multi-racial All Racial Groups 0.103 0.097
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4.

21 3 INCOME SEGREGATION IN TOWN OF LOS GATOS
Definition of Terms - Income Groups
When analyzing segregation by income, this report uses income group designations consistent with the Regional Housing Needs Allocation and the Housing Element:

Very low-income: individuals earning less than 50% of Area Median Income (AMI)
Low-income: individuals earning 50%-80% of AMI
Moderate-income: individuals earning 80%-120% of AMI
Above moderate-income: individuals earning 120% or more of AMI Additionally, this report uses the term “lower-income” to refer to all people who earn less than 80% of AMI, which includes both low-income and very low-income individuals.

The income groups described above are based on U.S. Department of Housing and Urban Development (HUD) calculations for AMI. HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and VallejoFairfield Metro Area (Solano County).

The income categories used in this report are based on the AMI for the HUD metro area where this jurisdiction is located.

3.1 Neighborhood Level Income Segregation (within Los Gatos) Income segregation can be measured using similar indices as racial segregation. Income dot maps, similar to the racial dot maps shown in Figures 1 and 5, are useful for visualizing segregation between multiple income groups at the same time. The income dot map of Los Gatos in Figure 8 below offers a visual representation of the spatial distribution of income groups within the jurisdiction. As with the racial dot maps, when the dots show lack of a pattern or clustering, income segregation measures tend to be lower, and conversely, when clusters are apparent, the segregation measures may be higher as well.

22 Figure 8: Income Dot Map of Los Gatos (2015)
Universe: Population.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

Note: The plot shows the income group distribution at the census block group level for Town of Los Gatos and vicinity. Dots in each block group are randomly placed and should not be construed as actual placement of individuals.

The isolation index values for all income groups in Los Gatos for the years 2010 and 2015 can be found in Table 6 below.13 Above Moderate-income residents are the most isolated income group in Los Gatos.

Los Gatos’s isolation index of 0.619 for these residents means that the average Above Moderate-income resident in Los Gatos lives in a neighborhood that is 61.9% Above Moderate-income. Among all income groups, the Above Moderate-income population’s isolation index has changed the most over time, becoming less segregated from other income groups between 2010 and 2015.

Similar to the tables presented earlier for neighborhood racial segregation, the “Bay Area Average” column in Table 6 provides the average isolation index value across Bay Area jurisdictions for different income groups in 2015. The data in this column can be used as a comparison to provide context for the levels of segregation experienced by income groups in this jurisdiction. For example, Table 6 indicates the average isolation index value for very low-income residents across Bay Area jurisdictions is 0.269,

13 This report presents data for income segregation for the years 2010 and 2015, which is different than the time periods used for racial segregation. This deviation stems from the data source recommended for income segregation calculations in HCD’s AFFH Guidelines. This data source most recently updated with data from the 2011-2015 American Community Survey 5-year estimates. For more information on HCD’s recommendations for calculating income segregation, see page 32 of HCD’s AFFH Guidelines.

23 meaning that in the average Bay Area jurisdiction a very low-income resident lives in a neighborhood that is 26.9% very low-income.

Table 6: Income Group Isolation Index Values for Segregation within Los Gatos Los Gatos Bay Area
Average
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 0.125 0.162 0.269
Low-Income (50%-80% AMI) 0.067 0.115 0.145
Moderate-Income (80%-120% AMI) 0.135 0.166 0.183
Above Moderate-Income (>120% AMI) 0.728 0.619 0.507
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

Figure 9 below shows how income group isolation index values in Los Gatos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each income group, the spread of dots represents the range of isolation index values among Bay Area jurisdictions.

Additionally, the black line within each income group notes the isolation index value for that group in Los Gatos, and each dashed red line represents the Bay Area average for the isolation index for that group. Local staff can use this chart to contextualize how segregation levels for income groups in their jurisdiction compare to the rest of the region.

24 Figure 9: Income Group Isolation Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

Table 7 below provides the dissimilarity index values indicating the level of segregation in Los Gatos between residents who are lower-income (earning less than 80% of AMI) and those who are not lowerincome (earning above 80% of AMI). This data aligns with the requirements described in HCD’s AFFH Guidance Memo for identifying dissimilarity for lower-income households.14 Segregation in Los Gatos between lower-income residents and residents who are not lower-income increased between 2010 and 2015. Additionally, Table 7 shows dissimilarity index values for the level of segregation in Albany between residents who are very low-income (earning less than 50% of AMI) and those who are above moderate-income (earning above 120% of AMI). This supplementary data point provides additional nuance to an analysis of income segregation, as this index value indicates the extent to which a jurisdiction’s lowest and highest income residents live in separate neighborhoods.

Similar to other tables in this report, the “Bay Area Average” column shows the average dissimilarity index values for these income group pairings across Bay Area jurisdictions in 2015. For example, Table 7 indicates that the average dissimilarity index between lower-income residents and other residents in a Bay Area jurisdiction is 0.198, so on average 19.8% of lower-income residents in a Bay Area jurisdiction would need to move to a different neighborhood within the jurisdiction to create perfect income group integration in that jurisdiction.
14 For more information, see page 32 of HCD’s AFFH Guidance Memo.

25 In 2015, the income segregation in Los Gatos between lower-income residents and other residents was higher than the average value for Bay Area jurisdictions (See Table 7). This means that the lowerincome residents are more segregated from other residents within Los Gatos compared to other Jurisdictions in the region.

Table 7: Income Group Dissimilarity Index Values for Segregation within Los Gatos
Los Gatos Bay Area
Average
Income Group 2010 2015 2015
Below 80% AMI vs. Above 80% AMI 0.142 0.226 0.198
Below 50% AMI vs. Above 120% AMI 0.194 0.234 0.253
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

Figure 10 below shows how dissimilarity index values for income segregation in Los Gatos compare to values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each income group pairing, the spread of dots represents the range of dissimilarity index values among Bay Area jurisdictions. Additionally, the black line within each income group pairing notes the dissimilarity index value in Los Gatos, and each dashed red line represents the Bay Area average for the dissimilarity index for that pairing. Local staff can use this chart to contextualize how segregation levels between lower-income residents and wealthier residents in their jurisdiction compared to the rest of the region.

26 Figure 10: Income Group Dissimilarity Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

The Theil’s H Index values for neighborhood income group segregation in Los Gatos for the years 2010 and 2015 can be found in Table 8 below. The “Bay Area Average” column in this table provides the average Theil’s H Index value across Bay Area jurisdictions for different income groups in 2015. By 2015, the Theil’s H Index value for income segregation in Los Gatos was about the same amount as it had been in 2010. In 2015, the Theil’s H Index value for income group segregation in Los Gatos was lower than the average value for Bay Area jurisdictions, indicating there is less neighborhood level income segregation in Los Gatos than in the average Bay Area city.

Table 8: Theil’s H Index Values for Income Segregation within Los Gatos Los Gatos Bay Area
Average
Index 2010 2015 2015
Theil's H Multi-income 0.030 0.028 0.043
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

27 Figure 11 below shows how Theil’s H index values for income group segregation in Los Gatos compare to values in other Bay Area jurisdictions in 2015. In this chart, each dot represents a Bay Area jurisdiction. Additionally, the black line notes the Theil’s H index value for income group segregation in Los Gatos, and the dashed red line represents the average Theil’s H index value across Bay Area jurisdictions. Local staff can use this chart to compare how neighborhood income group segregation levels in their jurisdiction compare to other jurisdictions in the region.

Figure 11: Income Group Theil’s H Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

3.2 Regional Income Segregation (between Los Gatos and other jurisdictions)
At the regional level, segregation is measured between jurisdictions instead of between neighborhoods.

Income dot maps are not only useful for examining neighborhood income segregation within a jurisdiction, but these maps can also be used to explore income demographic differences between jurisdictions in the region. Figure 12 below presents an income dot map showing the spatial distribution of income groups in Los Gatos as well as in nearby Bay Area jurisdictions.

28 Figure 12: Income Dot Map of Los Gatos and Surrounding Areas (2015) Universe: Population.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

Note: The plot shows the income group distribution at the census block group level for Town of Los Gatos and vicinity. Dots in each block group are randomly placed and should not be construed as actual placement of individuals.

When looking at income segregation between jurisdictions in the Bay Area, one can examine how Los Gatos differs from the region. The income demographics in Los Gatos for the years 2010 and 2015 can be found in Table 9 below. The table also provides the income composition of the nine-county Bay Area in 2015. As of that year, Los Gatos had a lower share of very low-income residents than the Bay Area as a whole, a lower share of low-income residents, a lower share of moderate-income residents, and a higher share of above moderate-income residents.

Table 9: Population by Income Group, Los Gatos and the Region Los Gatos Bay Area
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 10.83% 14.29% 28.7%
Low-Income (50%-80% AMI) 6.56% 10.57% 14.3%
Moderate-Income (80%-120% AMI) 11% 16.34% 17.6%
Above Moderate-Income (>120% AMI) 71.62% 58.8% 39.4%

29 Universe: Population.

Source: Data for 2015 is from Housing U.S. Department of and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

Figure 13 below compares the income demographics in Los Gatos to other Bay Area jurisdictions.15 Like the chart in Figure 3, each dot represents a Bay Area jurisdiction. For each income group, the spread of dots represents the range of that group’s representation among Bay Area jurisdictions. The smallest range is among jurisdictions’ moderate-income populations, while Bay Area jurisdictions vary the most in the share of their population that is above moderate-income. Additionally, the black lines within each income group note the percentage of Los Gatos population represented by that group and how that percentage ranks among other jurisdictions. Local staff can use this chart to compare the representation of different income groups in their jurisdiction to those groups’ representation in other jurisdictions in the region, which can indicate the extent of segregation between this jurisdiction and the region.

Figure 13: Income Demographics of Los Gatos Compared to Other Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.

Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and ModerateIncome Summary Data.

15 While comparisons of segregation measures are made only using the 104 jurisdictions with more than one census tract, this comparison of jurisdiction level demographic data can be made using all 109 jurisdictions.

30 Income segregation between jurisdictions in the region can also be analyzed by calculating regional values for the segregation indices discussed previously. Similar to the regional racial segregation measures shown in Table 5, Table 10 presents dissimilarity index, isolation index, and Theil’s H index values for income segregation for the entire nine-county Bay Area in 2010 and 2015. In the previous section of this report focused on neighborhood level income segregation, segregation indices were calculated by comparing the income demographics of the census tracts within a jurisdiction to the demographics of the jurisdiction as a whole. In Table 10, these measures are calculated by comparing the income demographics of local jurisdictions to the region’s income group makeup. For example, looking at 2015 data, Table 10 shows the regional isolation index value for very low-income residents is

0.315 for 2015, meaning that on average very low-income Bay Area residents live in a jurisdiction that is 31.5% very low-income. The regional dissimilarity index for lower-income residents and other residents is 0.194 in 2015, which means that across the region 19.4% of lower-income residents would need to move to a different jurisdiction to create perfect income group integration in the Bay Area as a whole. The regional value for the Theil’s H index measures how diverse each Bay Area jurisdiction is compared to the income group diversity of the whole region. A Theil’s H Index value of 0 would mean all jurisdictions within the Bay Area have the same income demographics as the entire region, while a value of 1 would mean each income group lives exclusively in their own separate jurisdiction. The regional Theil’s H index value for income segregation decreased slightly between 2010 and 2015, meaning that income groups in the Bay Area are now slightly less separated by the borders between jurisdictions.

Table 10: Regional Income Segregation Measures
Index Group 2010 2015
Isolation Index Regional Level
Very Low-Income (<50% AMI) 0.277 0.315
Low-Income (50%-80% AMI) 0.157 0.154
Moderate-Income (80%-120% AMI) 0.185 0.180
Above Moderate-Income (>120% AMI) 0.467 0.435
Dissimilarity Index Regional Level
Below 80% AMI vs. Above 80% AMI 0.186 0.194
Below 50% AMI vs. Above 120% AMI 0.238 0.248
Theil's H Multi-income All Income Groups 0.034 0.032
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

31 4 APPENDIX 1: SUMMARY OF FINDINGS

4.1 Segregation in Town of Los Gatos
• The isolation index measures the segregation of a single group, and the dissimilarity index measures segregation between two different groups. The Theil’s H-Index can be used to measure segregation between all racial or income groups across the city at once. • As of 2020, white residents are the most segregated compared to other racial groups in Los Gatos, as measured by the isolation index. White residents live in neighborhoods where they are less likely to come into contact with other racial groups. • Among all racial groups, the white population’s isolation index value has changed the most over time, becoming less segregated from other racial groups between 2000 and 2020. • According to the dissimilarity index, within Los Gatos the highest level of racial segregation is between Black and white residents.16 However, local jurisdiction staff should note that this dissimilarity index value is not a reliable data point due to small population size. • According to the Theil’s H-Index, neighborhood racial segregation in Los Gatos increased between 2010 and 2020. Neighborhood income segregation stayed about the same between 2010 and 2015.
• Above Moderate-income residents are the most segregated compared to other income groups in Los Gatos. Above Moderate-income residents live in neighborhoods where they are less likely to encounter residents of other income groups.
• Among all income groups, the Above Moderate-income population’s segregation measure has changed the most over time, becoming less segregated from other income groups between 2010 and 2015.
• According to the dissimilarity index, segregation between lower-income residents and residents who are not lower-income has increased between 2010 and 2015. In 2015, the income segregation in Los Gatos between lower-income residents and other residents was higher than the average value for Bay Area jurisdictions.

4.2 Segregation Between Town of Los Gatos and Other jurisdictions in the Bay Area Region
• Los Gatos has a higher share of white residents than other jurisdictions in the Bay Area as a whole, a lower share of Latinx residents, a lower share of Black residents, and a lower share of Asian/Pacific Islander residents.

16 The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if that group represents approximately less than 5% of the jurisdiction’s total population. ABAG/MTC recommends that when cities have population groups that are less than 5% of the jurisdiction’s population (see Table 15 in Appendix 2), jurisdiction staff could focus on the isolation index or Thiel’s H-Index to gain a more accurate understanding of neighborhood-level racial segregation in their jurisdiction.

32 • Regarding income groups, Los Gatos has a lower share of very low-income residents than other jurisdictions in the Bay Area as a whole, a lower share of low-income residents, a lower share of moderate-income residents, and a higher share of above moderate-income residents.

33 5 APPENDIX 2: SEGREGATION DATA
Appendix 2 combines tabular data presented throughout this report into a more condensed format. This data compilation is intended to enable local jurisdiction staff and their consultants to easily reference this data and re-use the data in the Housing Element or other relevant documents/analyses.

Table 11 in this appendix combines data from Table 1, Table 2, and Table 3 in the body of the report.

Table 12 in this appendix combines data from Table 6, Table 7, and Table 8 in the body of the report.

Table 13 represents a duplication of Table 5 in the body of the report; Table 14 represents a duplication of Table 10 in the body of the report; Table 15 in this appendix represents a duplication of Table 4 in the body of the report, while Table 16 represents a duplication of Table 9 in the body of the report.

Table 11: Neighborhood Racial Segregation Levels in Los Gatos Los Gatos Bay Area
Average
Index Race 2000 2010 2020 2020
Isolation
Asian/Pacific Islander 0.079 0.118 0.197 0.245
Black/African American 0.009 0.012 0.022 0.053
Latinx 0.059 0.082 0.104 0.251
White 0.838 0.774 0.663 0.491
Dissimilarity
Asian/Pacific Islander vs. White 0.106 0.145 0.182 0.185 Black/African American vs. White 0.223* 0.246* 0.369* 0.244 Latinx vs. White 0.119 0.143 0.179 0.207
People of Color vs. White 0.093 0.124 0.157 0.168
Theil's H Multi-racial All 0.011 0.015 0.023 0.042
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Note: If a number is marked with an asterisk (*), it indicates that the index is based on a racial group making up less than 5 percent of the jurisdiction population, leading to unreliable numbers.

34 Table 12: Neighborhood Income Segregation Levels in Los Gatos Los Gatos Bay Area
Average
Index Income Group 2010 2015 2015
Isolation
Very Low-Income (<50% AMI) 0.125 0.162 0.269
Low-Income (50%-80% AMI) 0.067 0.115 0.145
Moderate-Income (80%-120% AMI) 0.135 0.166 0.183
Above Moderate-Income (>120% AMI) 0.728 0.619 0.507
Dissimilarity
Below 80% AMI vs. Above 80% AMI 0.142 0.226 0.198
Below 50% AMI vs. Above 120% AMI 0.194 0.234 0.253
Theil's H Multi-racial All 0.030 0.028 0.043
Universe: Population.

Source: Income data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

35 Table 13: Regional Racial Segregation Measures
Index Group 2010 2020
Isolation Index Regional Level
Asian/Pacific Islander 0.317 0.378
Black/African American 0.144 0.118
Latinx 0.283 0.291
White 0.496 0.429
People of Color 0.629 0.682
Dissimilarity Index Regional Level
Asian/Pacific Islander vs. White 0.384 0.369
Black/African American vs. White 0.475 0.459
Latinx vs. White 0.301 0.297
People of Color vs. White 0.296 0.293
Theil's H Multi-racial All Racial Groups 0.103 0.097
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4.

Table 14: Regional Income Segregation Measures
Index Group 2010 2015
Isolation Index Regional Level
Very Low-Income (<50% AMI) 0.277 0.315
Low-Income (50%-80% AMI) 0.157 0.154
Moderate-Income (80%-120% AMI) 0.185 0.180
Above Moderate-Income (>120% AMI) 0.467 0.435
Dissimilarity Index Regional Level
Below 80% AMI vs. Above 80% AMI 0.186 0.194
Below 50% AMI vs. Above 120% AMI 0.238 0.248
Theil's H Multi-income All Income Groups 0.034 0.032
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

36 Table 15: Population by Racial Group, Los Gatos and the Region Los Gatos Bay Area
Race 2000 2010 2020 2020
Asian/Pacific Islander 7.55% 10.95% 18.28% 35.8%
Black/African American 0.76% 0.86% 0.89% 5.6%
Latinx 5.21% 7.21% 9% 28.2%
Other or Multiple Races 3.16% 3.95% 6.55% 24.4%
White 83.31% 77.03% 65.29% 5.9%
Universe: Population.

Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census Bureau, 2010 Census of Population and Housing, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau, Census 2000, Table P004.

Table 16: Population by Income Group, Los Gatos and the Region Los Gatos Bay Area
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 10.83% 14.29% 28.7%
Low-Income (50%-80% AMI) 6.56% 10.57% 14.3%
Moderate-Income (80%-120% AMI) 11% 16.34% 17.6%
Above Moderate-Income (>120% AMI) 71.62% 58.8% 39.4%
Universe: Population.

Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011- 2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.

37 6 REFERENCES
Ananat, Elizabeth Oltmans. 2011. “The wrong side(s) of the tracks: The causal effects of racial segregation on urban poverty and inequality,” American Economic Journal: Applied Economics 3: 34-

66. Bayer, Patrick, Robert McMillan, and Kim S. Rueben. 2004. “What Drives Racial Segregation? New Evidence using Census Microdata,” Journal of Urban Economics 56(3): 514-535.

Burch, Traci. 2014. “The Old Jim Crow: Racial Residential Segregation and Imprisonment,” Law and Policy 36(3): 223-255.

Chetty, Raj and Nathanial Hendren. 2018. “The Impacts of Neighborhoods on Intergenerational Mobility I: Childhood Exposure Effects,” The Quarterly Journal of Economics 133(3):1107-1162 Cutler, David M., and Edward L. Glaeser. 1997. “Are ghettos good or bad?,” The Quarterly Journal of Economics 112(3): 827-72.

Lens, Michael and Paavo Monkkonen. 2016. “Do Strict Land Use Regulations Make Metropolitan Areas More Segregated by Income?,” Journal of the American Planning Association 82(1): 6–21.

Pendall, Rolf. 2000. “Local Land-Use Regulation and the Chain of Exclusion,” Journal of the American Planning Association 66(2): 125-142.

Rothstein, Richard. 2017. The Color of Law: A Forgotten History of how our Government Segregated America. New York: Liveright Publishing.

Sampson, Robert J. 2012. Great American city: Chicago and the enduring neighborhood effect.

Chicago: University of Chicago Press.

Sharkey, Patrick. 2013. Stuck in place: Urban neighborhoods and the end of progress toward racial equality. Chicago: University of Chicago Press.

Trounstine, Jessica. 2015. “Segregation and Inequality in Public Goods,” American Journal of Political Science 60(3): 709-725.

Trounstine, Jessica. 2018. Segregation by Design: Local Politics and Inequality in American Cities. New York: Cambridge University Press.

Sites Inventory Form H

APPENDIX

Please Start Here, Instructions in Cell A2, Table in
A3:B17 Form Fields
Site Inventory Forms must be submitted to HCD for a
housing element or amendment adopted on or after
January 1, 2021. The following form is to be used for
satisfying this requirement. To submit the form,
complete the Excel spreadsheet and submit to HCD
at [email protected]. Please send the Excel
workbook, not a scanned or PDF copy of the tables.

General Information
Jurisidiction Name LOS GATOS
Housing Element Cycle 6th
Contact Information
First Name Joel
Last Name Paulson
Title Community Development Director
Email [email protected]
Phone 4083546879
Mailing Address
Street Address 110 East Main Street
City Los Gatos
Zip Code 94538
Website
https://www.losgatosca.gov/897/Planning

Table A: Housing Element Sites Inventory, Table Starts in Cell A2 For Santa Clara County jurisdictions, please format the APNs as follows: 999-99-999 Jurisdiction Name Site Address/Intersection 5 Digit
ZIP Code
Assessor
Parcel Number
Consolidated
Sites
General Plan Designation
(Current)
Zoning Designation
(Current)
Minimum
Density
Allowed
(units/acre)
Maximum
Density
Allowed
(units/acre)
Parcel
Size
(Acres)
Existing
Use/Vacancy Infrastructure Publicly-Owned Site Status Identified in Last/Last Two Planning Cycle(s) Lower
Income
Capacity
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacity Optional Information1 Optional Information2 Optional Information3 LOS GATOS 50 Park Avenue 95030 529-01-040 A Medium Density Residential R-1D 5 12 0.18 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 1 1 Site A-1 consolidated parcels Property Owner Interest Form Submitted LOS GATOS 61 Montebello Way 95030 529-01-041 A Medium Density Residential R-1D 5 12 0.69 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 4 4 Site A-1 consolidated parcels Property Owner Interest Form Submitted LOS GATOS 101 South Santa Cruz Avenue 95030 529-01-022 Central Business District C-2 20 30 0.8 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 16 16 Site A-2 Property Owner Interest Form Submitted LOS GATOS 165 Los Gatos Saratoga Road 95030 529-04-083 Central Business District C-2 20 30 0.37 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 7 7 Site A-3 Property Owner Interest Form Submitted LOS GATOS 50 Los Gatos Saratoga Road 95030 529-24-032 B Mixed Use Commercial CH:PD 30 40 7.04 Hotel/motel YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 151 51 9 211 Site B-1 consolidated parcels Property Owner Interest Form Submitted LOS GATOS Los Gatos Saratoga Road 95030 529-24-001 B Mixed Use Commercial CH:PD 30 40 1.49 Hotel/motel YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 18 9 18 45 Site B-1 consolidated parcels Property Owner Interest Form Submitted LOS GATOS Los Gatos Saratoga Road 95030 529-24-003 B Mixed Use Commercial CH:PD 30 40 0.28 Hotel/motel YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 3 2 3 8 Site B-1 consolidated parcels Property Owner Interest Form Submitted LOS GATOS 15300 Los Gatos Bouelvard 95032 424-17-036 Mixed Use Commercial C-1 30 40 1.6 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 33 9 6 48 Site C-1 Property Owner Interest Form Submitted LOS GATOS 15349 Los Gatos Bouelvard 95032 424-19-049 C Mixed Use Commercial CH 30 40 0.34 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 7 2 1 10 Site C-2 consolidated parcels Property Owner Interest Form Submitted LOS GATOS Los Gatos Bouelvard 95032 424-19-048 C Mixed Use Commercial CH 30 40 1.2 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 26 8 2 36 Site C-2 consolidated parcels Property Owner Interest Form Submitted LOS GATOS Los Gatos Bouelvard 95032 424-19-069 C Mixed Use Commercial CH 30 40 1.34 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 28 8 4 40 Site C-2 consolidated parcels Property Owner Interest Form Submitted LOS GATOS 15425 Los Gatos Bouelvard 95032 424-19-067 Mixed Use Commercial CH 30 40 1.09 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 23 7 3 33 Site C-3 Property Owner Interest Form Submitted LOS GATOS 15975 Los Gatos Boulevard 95032 529-15-059 Mixed Use Commercial CH 30 40 0.64 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 13 4 2 19 Site C-4 Property Owner Interest Form Submitted LOS GATOS 16203 Los Gatos Bouelvard 95032 529-16-069 Mixed Use Commercial CH 30 40 0.79 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 17 5 2 24 Site C-5 Conceptual Development Advisory Committee application for a mixed-use development submitted on 11/17/2020 anticipating for increased density per the General Plan update LOS GATOS 16492 Los Gatos Bouelvard 95032 532-07-086 D Low Density Residential C-1 10 20 0.23 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 2 2 Site C-6 consolidated parcels Property Owner Interest Form Submitted LOS GATOS Los Gatos Bouelvard 95032 532-07-085 D Low Density Residential C-1 10 20 0.38 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 4 4 Site C-6 consolidated parcels Property Owner Interest Form Submitted LOS GATOS 15495 Los Gatos Bouelvard 95032 424-22-030 Mixed Use Commercial CH 30 40 3.85 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 81 23 12 116 Site C-7 Property Owner contacted staff with inquiry on residential development LOS GATOS 15445 Los Gatos Bouelvard 95032 424-19-068 Mixed Use Commercial CH 30 40 1.53 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 32 9 5 46 Site C-8 Adjacent to sites within the Site Inventory LOS GATOS 14859 Los Gatos Boulevard 95032 424-07-094 E North Forty Specific Plan North Forty Specific Plan 30 30 2.9 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 57 13 17 87 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site LOS GATOS 16392 Los Gatos Boulevard 95032 424-07-095 E North Forty Specific Plan North Forty Specific Plan 30 30 0.78 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 15 3 5 23 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site LOS GATOS 16260 Burton Road 95032 424-07-053 E North Forty Specific Plan North Forty Specific Plan 30 30 0.44 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 8 2 3 13 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site LOS GATOS 16250 Burton Road 95032 424-07-009 E North Forty Specific Plan North Forty Specific Plan 30 30 0.44 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 8 2 3 13 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site LOS GATOS 14917 Los Gatos Boulevard 95032 424-07-081 E North Forty Specific Plan North Forty Specific Plan 30 30 3.74 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 73 17 22 112 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site LOS GATOS 14925 Los Gatos Boulevard 95032 424-07-115 E North Forty Specific Plan North Forty Specific Plan 30 30 6.07 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 118 27 37 182 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site LOS GATOS Los Gatos Boulevard 95032 424-07-116 E North Forty Specific Plan North Forty Specific Plan 30 30 1.02 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 20 5 6 31 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site LOS GATOS 16245 Burton Road 95032 424-06-115 North Forty Specific Plan North Forty Specific Plan 30 30 1.17 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 23 5 7 35 Site D-2 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS Burton Road 95032 424-06-116 North Forty Specific Plan North Forty Specific Plan 30 30 0.11 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 2 0 1 3 Site D-2 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS 16240 Burton Road 95032 424-07-010 North Forty Specific Plan North Forty Specific Plan 30 30 0.26 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 5 1 2 8 Site D-3 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS 16270 Burton Road 95032 424-07-052 North Forty Specific Plan North Forty Specific Plan 30 30 0.43 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 8 2 3 13 Site D-4 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS 16210 Burton Road 95032 424-07-054 North Forty Specific Plan North Forty Specific Plan 30 30 0.26 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 5 1 2 8 Site D-5 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS 14831 Los Gatos Boulevard 95032 424-07-063 North Forty Specific Plan North Forty Specific Plan 30 30 0.56 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 11 3 3 17 Site D-5 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS 14849 Los Gatos Boulevard 95032 424-07-064 North Forty Specific Plan North Forty Specific Plan 30 30 0.93 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 18 4 6 28 Site D-6 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS 14823 Los Gatos Boulevard 95032 424-07-065 North Forty Specific Plan North Forty Specific Plan 30 30 0.37 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 6 1 4 11 Site D-7 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway LOS GATOS 14800 Oka Road 95032 424-08-057 Low Density Residential R-1:8 0 5 2.97 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 0 1 11 12 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS Oka Lane 95032 424-08-029 Low Density Residential R-1:8 0 5 0.31 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 1 1 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS Oka Lane 95032 424-08-059 Low Density Residential R-1:8 0 5 1.01 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 4 4 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS Oka Lane 95032 424-08-060 Low Density Residential R-1:8 0 5 1.29 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 5 5 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS 14800 Oka Road 95032 424-08-058 Low Density Residential R-1:8 0 5 1.41 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 6 6 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS 16603 Lark Avenue 95032 424-08-017 Medium Density Residential R-M:5-12 14 22 2.48 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 3 3 29 35 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS 14840 Oka Road 95032 424-08-021 Medium Density Residential R-M:5-12 14 22 4.32 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 6 6 49 61 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS Oka Lane 95032 424-08-074 Low Density Residential R-1:8 0 5 6.41 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 2 1 23 26 Site E-2 No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.

LOS GATOS Oka Road (Cal Trans ROW) 95032 000-00-000 Medium Density Residential R-1:8 14 22 4.9 Vacant YES - Current YES - State-Owned Available Not Used in Prior Housing Element 7 7 55 69 Site E-3 LOS GATOS 110 Knowles Drive 95032 424-32-077 High Density Residential CM:AHOZ 30 40 7.34 Commercial YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 106 79 35 220 Site F-1 No; however the site is located within the Affordable Housing Overlay Zone.

LOS GATOS 206 Knowles Drive 95032 424-32-076 High Density Residential CM 30 40 2.41 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 35 26 11 72 Site F-2 No; however, the site is located immediately adjacent to 110 Knowles Drive (Site F-1), which has an Affordable Housing Overlay Zone.

LOS GATOS 440 Los Gatos Almaden Road 95032 527-49-048 Neighborhood Commercial C-1 10 20 0.52 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 5 5 Site G-1 consolidated parcels Property Owner Interest Form Submitted LOS GATOS 445 Leigh Avenue 95032 527-49-049 Neighborhood Commercial C-1 10 20 0.29 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 3 3 Site G-1 consolidated parcels Property Owner Interest Form Submitted LOS GATOS 14000 Blossom Hill Road 95032 527-32-028 Neighborhood Commercial C-1 10 20 0.69 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 7 7 Site H-1 Property Owner Interest Form Submitted LOS GATOS 401-409 Alberto Road 95032 529-23-018 Mixed Use Commercial CH 30 40 2.19 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 4 4 52 60 Site I-1 Property Owner Interest Form Submitted; Development application submitted on 12/6/2022 for a mixed-use project with 27 du/ac

Table B: Candidate Sites Identified to be Rezoned to Accommodate Shortfall Housing Need, Table Starts in Cell A2 For Santa Clara County jurisdictions, please format the APNs as follows: 999-99-999 Jurisdiction Name Site Address/Intersection 5 Digit ZIP Code
Assessor Parcel
Number
Very LowIncome Low-Income ModerateIncome
Above
ModerateIncome
Type of Shortfall Parcel Size
(Acres)
Current General
Plan Designation Current Zoning
Proposed General
Plan (GP)
Designation
Proposed Zoning
Minimum
Density
Allowed
Maximum
Density
Allowed
Total Capacity Vacant/
Nonvacant
Description of
Existing Uses Infrastructure Optional Information1 Optional Information2 Optional Information3 LOS GATOS 50 Park Avenue 95030 529-01-040 0 0 0 1 Shortfall of Sites 0.18 Medium Density Resid R-1D Medium Density Resid R-1D 5 12 1 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 61 Montebello Way 95030 529-01-041 0 0 0 4 Shortfall of Sites 0.69 Medium Density Resid R-1D Medium Density Resid R-1D 5 12 4 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 101 S. Santa Cruz Avenue 95030 529-01-022 0 0 0 16 Shortfall of Sites 0.8 Central Business Dist C-2 Central Business Dist C-2 20 30 16 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 165 Los Gatos-Saratoga Road 95030 529-04-083 0 0 0 7 Shortfall of Sites 0.37 Central Business Dist C-2 Central Business Dist C-2 20 30 7 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 50 Los Gatos-Saratoga Road 95030 529-24-032 76 75 51 9 Shortfall of Sites 7.04 Mixed Use Commerci CH:PD Mixed Use Commerci CH:PD 30 40 211 Non-Vacant Hotel/motel YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Los Gatos-Saratoga Road 95030 529-24-001 9 9 9 18 Shortfall of Sites 1.49 Mixed Use Commerci CH:PD Mixed Use Commerci CH:PD 30 40 45 Non-Vacant Hotel/motel YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Los Gatos-Saratoga Road 95030 529-24-003 1 2 2 3 Shortfall of Sites 0.28 Mixed Use Commerci CH:PD Mixed Use Commerci CH:PD 30 40 8 Non-Vacant Hotel/motel YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15300 Los Gatos Boulevard 95032 424-17-036 24 9 9 6 Shortfall of Sites 1.6 Mixed Use Commerci C-1 Mixed Use Commerci C-1 30 40 48 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15349 Los Gatos Boulevard 95032 424-19-049 5 2 2 1 Shortfall of Sites 0.34 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 10 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15367 Los Gatos Boulevard 95032 424-19-048 18 8 8 2 Shortfall of Sites 1.2 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 36 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15405 Los Gatos Boulevard 95032 424-19-069 20 8 8 4 Shortfall of Sites 1.34 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 40 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15425 Los Gatos Boulevard 95032 424-19-067 16 7 7 3 Shortfall of Sites 1.09 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 33 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15795 Los Gatos Boulevard 95032 529-15-059 9 4 4 2 Shortfall of Sites 0.64 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 19 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16203 Los Gatos Boulevard 95032 529-16-069 12 5 5 2 Shortfall of Sites 0.79 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 24 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16492 Los Gatos Boulevard 95032 532-07-086 0 0 0 2 Shortfall of Sites 0.23 Low Density Resident C-1 Low Density Resident C-1 10 20 2 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Los Gatos Boulevard 95032 532-07-085 0 0 0 4 Shortfall of Sites 0.38 Neighborhood Comm C-1 Neighborhood Comm C-1 10 20 4 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15495 Los Gatos Bouelvard 95032 424-22-030 58 23 23 12 Shortfall of Sites 3.85 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 116 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15445 Los Gatos Bouelvard 95032 424-19-068 23 9 9 5 Shortfall of Sites 1.53 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 46 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14859 Los Gatos Boulevard 95032 424-07-094 44 13 13 17 Shortfall of Sites 2.9 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 87 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16392 Los Gatos Boulevard 95032 424-07-095 12 3 3 5 Shortfall of Sites 0.78 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 23 Non-Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16260 Burton Road 95032 424-07-053 6 2 2 3 Shortfall of Sites 0.44 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 13 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16250 Burton Road 95032 424-07-009 6 2 2 3 Shortfall of Sites 0.44 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 13 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14917 Los Gatos Boulevard 95032 424-07-081 56 17 17 22 Shortfall of Sites 3.74 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 112 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14925 Los Gatos Boulevard 95032 424-07-115 91 27 27 37 Shortfall of Sites 6.07 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 182 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Los Gatos Boulevard 95032 424-07-116 15 5 5 6 Shortfall of Sites 1.02 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 31 Non-Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16245 Burton Road 95032 424-06-115 18 5 5 7 Shortfall of Sites 1.17 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 35 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Burton Road 95032 424-06-116 2 0 0 1 Shortfall of Sites 0.11 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 3 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16240 Burton Road 95032 424-07-010 4 1 1 2 Shortfall of Sites 0.26 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 8 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16270 Burton Road 95032 424-07-052 6 2 2 3 Shortfall of Sites 0.43 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 13 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16210 Burton Road 95032 424-07-054 4 1 1 2 Shortfall of Sites 0.26 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 8 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14831 Los Gatos Boulevard 95032 424-07-063 8 3 3 3 Shortfall of Sites 0.56 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 17 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14849 Los Gatos Boulevard 95032 424-07-064 14 4 4 6 Shortfall of Sites 0.93 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 28 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14823 Los Gatos Boulevard 95032 424-07-065 5 1 1 4 Shortfall of Sites 0.37 North Forty Specific P North Forty Specific P North Forty Specific P North Forty Specific P 30 30 11 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14800 Oka Road 95032 424-08-057 0 0 1 11 Shortfall of Sites 2.97 Low Density Resident R-1:8 Low Density Resident R-1:8 0 5 12 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Oka Lane 95032 424-08-029 0 0 0 1 Shortfall of Sites 0.31 Low Density Resident R-1:8 Low Density Resident R-1:8 0 5 1 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Oka Lane 95032 424-08-059 0 0 0 4 Shortfall of Sites 1.01 Low Density Resident R-1:8 Low Density Resident R-1:8 0 5 4 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Oka Lane 95032 424-08-060 0 0 0 5 Shortfall of Sites 1.29 Low Density Resident R-1:8 Low Density Resident R-1:8 0 5 5 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14800 Oka Road 95032 424-08-058 0 0 0 6 Shortfall of Sites 1.41 Low Density Resident R-1:8 Low Density Resident R-1:8 0 5 6 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16603 Lark Avenue 95032 424-08-017 0 3 3 29 Shortfall of Sites 2.48 Medium Density ResidR-M:5-12 Medium Density ResidR-M:5-12 14 22 35 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14840 Oka Road 95032 424-08-021 0 6 6 49 Shortfall of Sites 4.32 Medium Density ResidR-M:5-12 Medium Density ResidR-M:5-12 14 22 61 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Oka Lane 95032 424-08-074 0 2 1 23 Shortfall of Sites 6.41 Low Density Resident R-1:8 Low Density Resident R-1:8 0 5 26 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Oka Road (Cal Trans ROW) 95032 000-00-000 0 7 7 55 Shortfall of Sites 4.9 Medium Density ResidR-1:8 Medium Density ResidR-1:8 14 22 69 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 110 Knowles Drive 95032 424-32-077 66 40 79 35 Shortfall of Sites 7.34 High Density Residen CM:AHOZ High Density Residen CM:AHOZ 30 40 220 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 206 Knowles Drive 95032 424-32-076 22 13 26 11 Shortfall of Sites 2.41 High Density Residen CM High Density Residen CM 30 40 72 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 440 Los Gatos Almaden Road 95032 527-49-048 0 0 0 5 Shortfall of Sites 0.52 Neighborhood Comm C-1 Neighborhood Comm C-1 10 20 5 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 445 Leigh Avenue 95032 527-49-049 0 0 0 3 Shortfall of Sites 0.29 Neighborhood Comm C-1 Neighborhood Comm C-1 10 20 3 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14000 Blossom Hill Road 95032 527-32-028 0 0 0 7 Shortfall of Sites 0.69 Neighborhood Comm C-1 Neighborhood Comm C-1 10 20 7 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 401-409 Alberto Way 95032 529-23-018 0 4 4 52 Shortfall of Sites 2.19 Mixed Use Commerci CH Mixed Use Commerci CH 30 40 60 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program 3

Table C: Land Use, Table Starts in A2
Zoning Designation
From Table A, Column G
and Table B, Columns L and N (e.g.,
"R-1")
General Land Uses Allowed (e.g., "Low-density residential") R-1D Single-family dwelling, provided that there is not more than one principal residential structure on a lot, two-family dwelling, provided that there is not more than one principal residential structure on a lot, family daycare home, and residential care facility, small family home.

C-1
Retailing, including formula retail up to six thousand (6,000) square feet, Personal service businesses and service businesses necessary for the conduct of households, Office activities, Limited manufacturing activities when a majority of sales are made, on site, to the ultimate consumer, Activities permitted in the LM zone which were approved on or before February 1, 1993, provided any change of use must be a conforming use in the C-1 zone, and Group classes, and single-family, two-family, and multi-family in a mixed-use project through a CUP.

C-2
Retailing, including formula retail up to six thousand square feet, Office activities subject to subsection (c), Limited manufacturing activities when a majority of sales are made, on site, to the ultimate consumer, Wholesaling without warehousing on the premises, Single-family and two-family uses, in conjunction with the other uses permitted in this section and multi-family in a mixed-use project through a CUP CH
Retailing, including formula retail up to six thousand square feet, Personal service businesses and service businesses necessary for the conduct of households, Office activities, Limited manufacturing activities when a majority of sales are made on site to the ultimate consumer, Group classes, and singlefamily, two-family, and multi-family in a mixed-use project through a CUP CH:PD Hotel up to 300 rooms, a conference facility containing approximately 10,000 square feet, and an underground parking facility North Forty Specific Plan Retail, Restaurant, Personal Service, Office, Hotel, Townhomes, Rowhouses, Multi-Family, Condominiums, Live/Work Lofts, Park, Public Transpiration and Parking Facilities, Small Family Daycare, Alternating Use/Shared Parking, and Botanical Nursery R-1:8
Single-family dwelling, provided that there is not more than one principal residential structure on a lot, raising of trees, vegetables and horticultural specialties, but not including commercial greenhouses, retail nurseries, or storage of landscaping equipment, products or supplies for commercial uses, family daycare home, and residential care facility, small family home.

R-M:5-12 Single-family dwelling, two-family dwelling, family daycare home, residential care facility, small family home, multi-family dwelling, and a transitional Housing facility as defined by Health and Safety Code section 50675.2 CM
Activities involving controlled manufacturing, research and development, wholesaling, warehousing, and other light industrial uses, Sales to the ultimate consumer of articles manufactured on the premises to the customer's order, Professional and administrative offices, Emergency shelters as defined by Health and Safety Code section 50801
CM:AHOZ Multifamily dwellings, Two-family dwellings, and Single-family dwellings.

HEOZ Housing Element Overlay Zone Implementation Program BF to apply to the sites included in the Site Inventory to modify the development standards (i.e., density, lot coverage, FAR, height) on those sites

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Environmental Analysis
Los Gatos 6th Cycle Housing Element
2023-2031 Planning Period
December 22, 2022
Prepared by
EMC Planning Group
EXHIBIT 2 Page 963

ENVIRONMENTAL ANALYSIS
LOS GATOS 6TH CYCLE HOUSING ELEMENT
2023-2031 PLANNING PERIOD

PREPARED FOR
Town of Los Gatos
Joel Paulson, Community Development Director
110 E. Main Street
Los Gatos, CA 95030
Tel 408.354.6879
[email protected]

PREPARED BY
EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Tel 831.649.1799
Fax 831.649.8399
Teri Wissler Adam, Senior Principal
[email protected]
www.emcplanning.com
December 22, 2022
This document was produced on recycled paper.

EMC Planning Group Inc.

TABLE OF CONTENTS
A. BACKGROUND ..................................................................................................................... 1 B. DETERMINATION ................................................................................................................ 9 C. EVALUATION OF ENVIRONMENTAL IMPACTS ............................................................. 10

1. Aesthetics .............................................................................................................................. 11

2. Agriculture and Forest Resources ...................................................................................... 15

3. Air Quality ............................................................................................................................. 17

4. Biological Resources ............................................................................................................ 23

5. Cultural Resources ............................................................................................................... 30

6. Energy .................................................................................................................................... 33

7. Geology and Soils ................................................................................................................ 37

8. Greenhouse Gas Emissions ............................................................................................... 44

9. Hazards and Hazardous Materials ..................................................................................... 51

10. Hydrology and Water Quality ............................................................................................ 57

11. Land Use and Planning ....................................................................................................... 64

12. Mineral Resources ................................................................................................................ 67

13. Noise ...................................................................................................................................... 68

14. Population and Housing ..................................................................................................... 72

15. Public Services ...................................................................................................................... 74

16. Recreation ............................................................................................................................. 79

17. Transportation ...................................................................................................................... 80

18. Tribal Cultural Resources ................................................................................................... 89

19. Utilities and Services Systems ............................................................................................. 90

20. Wildfire .................................................................................................................................. 98

21. Mandatory Findings of Significance ................................................................................ 104 D. SOURCES ........................................................................................................................... 106

EMC Planning Group Inc.

Figures
Figure 1 Location Map .................................................................................................................... 5 Figure 2 Site Inventory Location Areas ........................................................................................ 7 Figure 3 Downtown Area Sites’ Fire Hazards ........................................................................... 99

Section A Background 1 EMC Planning Group
Los Gatos 6th Cycle Housing Element December 22, 2022
A. BACKGROUND
Setting
The Town of Los Gatos is located within Santa Clara County, south of the San Francisco Bay.

It’s surrounded by the City of Campbell to the north, the cities of Saratoga and Monte Sereno to the west, the City of San Jose to the east, and unincorporated land (i.e., the Santa Cruz Mountains) to the south. The incorporated area of Los Gatos covers approximately 11.5 square miles and is almost entirely built-out, with its sphere of influence encompassing approximately 18 square miles. Primary access is provided by State Route 17 from the north and south, which is the main roadway linking the Bay Area to Santa Cruz and the northern Monterey Bay region, and from State Route 85 from the west and east. Los Gatos can also be accessed from the west by State Route 9, also known as Los Gatos-Saratoga Road. Figure 1, Location Map, presents the relationship between the Town of Los Gatos and nearby cities, as well as the state highway system.

Background
The Town of Los Gatos (Town) has prepared a draft 6th cycle Housing Element that covers the planning period 2023 through 2031 consistent with the requirements under California state law.

Part of the Housing Element Update requires that the Town identify adequate housing sites to accommodate the Regional Housing Needs Allocation (RHNA) assigned to the Town by the California Department of Housing and Development (HCD) and the Association of Bay Area Governments/Metropolitan Transportation Commission (ABAG/MTC). The RHNA identified for the Town’s 6th cycle Housing Element is 1,993 units.

Project Title Los Gatos 6th Cycle Housing Element
Lead Agency Contact Person
and Phone Number
Joel Paulson,
Community Development Director
408-354-6879
Date Prepared December 22, 2022
Study Prepared by EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Project Location Town of Los Gatos
Project Sponsor Name and Address Town of Los Gatos
110 E. Main Street
Los Gatos CA 95030
General Plan Designation Various
Zoning Various

Section A Background 2 EMC Planning Group
Los Gatos 6th Cycle Housing Element December 22, 2022
Methodology
The Town received a referendum to repeal the Land Use and Community Design Elements of the adopted Town of Los Gatos California 2040 General Plan (General Plan). In October 2022, the Town Council adopted a resolution to provide that the Town of Los Gatos 2020 General Plan’s Land Use and Community Design Elements will govern during the period of suspension. Therefore, when the term “General Plan” is used in this environmental analysis, it is the General Plan in effect that is being referenced (i.e., the Town of Los Gatos California 2040 General Plan with the Town of Los Gatos 2020 General Plan’s Land Use and Community Design Elements).

The Town’s 2040 General Plan Final Environmental Impact Report SCH#2020070175 (General Plan Final EIR) (Town of Los Gatos June 2022a) (chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://losgatos2040.com/images/docs/5_LG _2040_GP_FEIR_RTC_June_2022.pdf) was certified in June 2022, with the following documents making up the entirety of the General Plan Final EIR:
 2040 General Plan Final Environmental Impact Report Addenda and Errata for Town Council SCH#2020070175 dated June 2022 (chrome-extension://efaidnbmnnnibpcajpcglcle findmkaj/https://losgatos2040.com/images/docs/6_LG_2040_GP_FEIR_RTC_ Addenda_Errata_for_Town_Council.pdf);
 2040 General Plan Revised Sections of Draft Environmental Impact Report dated November 2021 (chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https:// www.losgatosca.gov/DocumentCenter/View/29410/Revised-Sections-of-Draft-EIR); and
 2040 General Plan Draft Environmental Impact Report (General Plan EIR) dated July 2021 (chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://losgatos2040.com/ images/docs/2040-General-Plan-DEIR-with-Appendices.pdf).

Some of the timing of preparation of the 6th cycle Housing Element Update overlapped with the preparation of the General Plan EIR, allowing for the two documents to work together on topics such as allowable density, floor area ratio, and height to assist in meeting the Town’s RHNA requirement. The General Plan EIR evaluated the potential growth for up to 3,738 dwelling units, has already evaluated the housing and population growth projections identified within the 6th cycle Housing Element Update.

This environmental analysis relies on the earlier analyses in the General Plan Program EIR (against which no timely lawsuit challenging its adequacy under CEQA was filed), pursuant to CEQA Guidelines section 15168(c). Section 15168(c) provides that “later activities [here, the Housing Element Update] in the program [here, the General Plan] must be examined in light of the program EIR to determine whether an additional environmental document must be prepared.” Section 15168(c)(2) provides: “If the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required.” The section further explains that the “within the scope” inquiry is a factual question that the agency determines based on substantial evidence. While no specific format is required to document the agency’s determination, an initial study checklist provides a useful, familiar format

Section A Background 3 EMC Planning Group
Los Gatos 6th Cycle Housing Element December 22, 2022
to explain the agency’s reasoning and evidence. As explained in detail for each environmental resource area herein, there is no evidence that development under the Housing Element Update would result in any new or more severe significant environmental impacts than previously determined in the General Plan EIR. Therefore, this analysis supports a determination under CEQA Guidelines section 15162 that no subsequent or supplemental EIR is necessary for the Housing Element Update.

The analysis in this initial study contains a brief discussion identifying the following:
a. “Earlier Analysis Used” identifies and states where the General Plan EIR is available for review (see above).
b. “Impact Adequately Addressed” identifies which effects from the checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and states whether such effects were addressed by mitigation measures based on the earlier analysis.
c. “Mitigation Measures”—For effects that are “Less-Than-Significant Impact with Mitigation Measures Incorporated,” mitigation measures are described which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project. This mitigation generally takes the form of General Plan policies.

Description of Proposal
The proposal includes the update and preparation of the Town’s 6th Cycle 2023-2031 Housing Element in order to comply with the state’s housing goals set forth in the Government Code, and adopting this element as an amendment to the Town’s General Plan. The Town is currently proposing a total of 2,312 housing units. Appendix H of the Town’s 2023-2031 Housing Element provides details and capacity estimates for each of the parcels that comprise the Town’s housing Sites Inventory. Figure 2, Site Inventory Location Areas, shows an overview of the proposed sites inventory map with the sites combined into various areas of the Town. The total number of housing units in the Draft Site Inventory is subject to change; however, the total number of units will not exceed the maximum of 3,738 units that were considered under the 2040 General Plan Environmental Impact Report (EIR). Development of these housing units would result in a population increase of approximately 5,780 (California Department of Finance 2022). The Housing Element Update may require the demolition of existing commercial structures on some of the individual sites, but would not result in a net increase in commercial square footage to the Town of Los Gatos compared to existing conditions. The assumption in the General Plan was that there would not be any additional commercial beyond what would already be allowed by the previous, Town of Los Gatos 2020 General Plan.

Other Public Agencies Whose Approval is Required
 California Department of Housing and Community Development

Section A Background 4 EMC Planning Group
Los Gatos 6th Cycle Housing Element December 22, 2022
Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
The Town did not receive any requests from California Native American tribes requesting consultation under Assembly Bill 52 for the Housing Element Update or for the General Plan EIR.

Note: Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See Public Resources Code section 21080.3.2.) Information may also be available from the California Native American Heritage Commission’s Sacred Lands File per Public Resources Code section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that Public Resources Code section 21082.3(c) contains provisions specific to confidentiality.

Source: ESRI 2014
Figure 1
Location Map
Los Gatos 6th Cycle Housing Element Environmental Analysis 0 6500 feet
Project
Location
£¤101
UV1 £¤101
k
Salinas
UV152 Gilroy
Los Gatos
San Jose
San Francisco
Santa Cruz
Monterey
Seaside
§¨¦580
§¨¦5
§¨¦280
§¨¦680
UV1
UV1
Regional Location
Los Gatos
San Jose
Campbell
Saratoga
Cupertino
§¨¦ §¨¦280 280
UV85
UV85
UV85
UV17
UV17
UV17
Los Gatos Town Limits
Santa Cruz Mountains
Not to Scale
Santa Cruz Mountains
Santa Clara

Section A Background 6 EMC Planning Group
Los Gatos 6th Cycle Housing Element December 22, 2022
This side intentionally left blank.

Source: Santa Clara County GIS 2022,
Google Earth 2022
Figure 2
Site Inventory Location Areas
Los Gatos 6th Cycle Housing Element Environmental Analysis 0 4000 ft
Downtown Area
Parcels
Alberto Way
Area Parcels
Los Gatos Lodge
Area Parcels
Los Gatos Blvd.

Area Parcels
North Forty
Area Parcels
Lark Ave.

Area Parcels
Winchester Blvd.

Area Parcels
Union Ave.

Area Parcels
Harwood Rd.

Area Parcels
Los Gatos
Town Limits

Section A Background 8 EMC Planning Group
Los Gatos 6th Cycle Housing Element December 22, 2022
This side intentionally left blank.

Section B Determination 9 EMC Planning Group
Los Gatos 6th Cycle Housing Element December 22, 2022
B. DETERMINATION
On the basis of this initial evaluation:
☐ I find that the Housing Element Update COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. ☐ I find that although the Housing Element Update could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the Housing Element Update have been made by or agreed to by its proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
☐ I find that the Housing Element Update MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
☐ I find that the Housing Element Update MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. ☒ I find that although the Housing Element Update could have a significant effect on the environment, because all potentially significant effects have been analyzed adequately in Town of Los Gatos General Plan EIR pursuant to applicable standards including CEQA Guidelines section 15168(c)2, and the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR, nothing further is required. ____
Joel Paulson, Community Development Director Date
01/17/2023

Section C Evaluation of Environmental Impacts 10 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
C. EVALUATION OF ENVIRONMENTAL IMPACTS
Notes

1. All answers take account of the whole action involved, including off-site as well as onsite, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

2. Once it has been determined that a particular physical impact may occur, then the checklist answers indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required.

3. “Negative Declaration: Less-Than-Significant Impact with Mitigation Measures Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less-Than-Significant Impact.” The lead agency must describe the mitigation measures and briefly explain how they reduce the effect to a less-than-significant level (mitigation measures from section XVII, “Earlier Analyses,” may be cross-referenced).

4. Earlier analyses are used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. [Section 15063(c)(3)(D)] In this case, a brief discussion would identify the following:
a. “Earlier Analysis Used” identifies and states where such document is available for review.
b. “Impact Adequately Addressed” identifies which effects from the checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and states whether such effects were addressed by mitigation measures based on the earlier analysis.
c. “Mitigation Measures”—For effects that are “Less-Than-Significant Impact with Mitigation Measures Incorporated,” mitigation measures are described which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

5. Checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances, etc.) are incorporated. Each reference to a previously prepared or outside document, where appropriate, includes a reference to the page or pages where the statement is substantiated.

6. “Supporting Information Sources”—A source list is attached, and other sources used or individuals contacted are cited in the discussion.

7. The explanation of each issue identifies:
a. The significance criteria or threshold, if any, used to evaluate each question; and b. The mitigation measure identified, if any to reduce the impact to less than significant.

Section C Evaluation of Environmental Impacts 11 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

1. AESTHETICS
Except as provided in Public Resources Code Section 21099 (Modernization of Transportation Analysis for Transit-Oriented Infill Projects), would the project:

Comments:
a. As identified in the General Plan EIR (Section 4.1, Aesthetics), scenic vistas in Los Gatos include the hillside area of the Santa Cruz Mountains and open space areas on the edges of the Town. New development facilitated by the Town, including the housing units proposed by the Housing Element Update, would be in the existing urbanized area and generally would not affect views of the hillside areas or other scenic vistas. The General Plan EIR states that new development in the urbanized area may be visible from ridges in the hillside area or from isolated locations in other open space areas of the Town, but would appear similar to existing surrounding urban development. However, new structures could be oriented or scaled in such a way that views of the hillside area are blocked from isolated locations in the Town.

The General Plan’s Community Design Element contains goals and policies to minimize potential visual impacts on scenic vistas from future development such as Goal CD-16 and its associated policies, which promote and protect scenic resources through design of new structures or remodels that allow scenic views to all affected properties.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Have a substantial adverse effect on a scenic vista? ☐ ☐ ☒ ☐ b. Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic
buildings within a state scenic highway?
☐ ☐ ☐ ☒
c. In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are those
that are experienced from publicly accessible vantage
points.) If the project is in an urbanized area, would
the project conflict with applicable zoning and other
regulations governing scenic quality?
☐ ☐ ☐ ☒
d. Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the
area?
☐ ☐ ☒ ☐

Section C Evaluation of Environmental Impacts 12 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The General Plan EIR concludes (p. 4.1-16) that the General Plan’s goals and policies would minimize visual intrusion and assist in reducing obstructions of view of the scenic vistas associated with the open space areas of the Town. Because development facilitated by the General Plan would occur in existing urbanized areas of the Town, and implementation of these policies would encourage vistas and visibility of scenic open space, impacts of the General Plan would be less than significant.

The Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR. Therefore, development consistent with the Housing Element Update would be required to implement the General Plan’s applicable goals and policies to reduce impacts on scenic vistas thereby ensuring its impact would be less than significant.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on scenic vistas.
b. According to the General Plan EIR (Section 4.1, Aesthetics), there are no state designated scenic highways within the Town limits and there would be no impacts on scenic resources within a state scenic highway (Town of Los Gatos 2021, p. 4.1-17) The sites nearest to the officially designated portion of State Route 9, associated with the Housing Element Update, are located approximately 0.60 miles east. Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would not facilitate new development adjacent to the officially designated portion of State Route 9. The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on scenic resources within a state scenic highway.
c. As discussed in the General Plan EIR (Section 4.1, Aesthetics), the General Plan would facilitate incremental change in the visual character of the Town through development and redevelopment of land. Implementation of the Housing Element Update, consistent with the growth projections evaluated in the General Plan EIR, would include the reuse of existing urbanized lands and infill development on vacant parcels to meet the housing needs of the growing community.

New development would not substantially degrade the visual character or quality of the Town by complying with existing design guidelines as well as with General Plan policies.

Impacts would be less than significant (Town of Los Gatos 2021, p. 4.1-24).

Some applicable General Plan policies from the Town of Los Gatos 2020 General Plan’s Land Use Element are presented below:
 Policy LU-7.2 - To ensure compatibility with surrounding neighborhoods, infill projects shall demonstrate that the development meets the criteria contained in the Development Policy for In-Fill Projects and the deciding body shall make findings consistent with this policy.;
 Policy LU-7.3 - Infill projects shall contribute to the further development of the surrounding neighborhood (e.g., improve circulation, contribute to or provide

Section C Evaluation of Environmental Impacts 13 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
neighborhood unity, eliminate a blighted area) and shall not detract from the existing quality of life.
 Policy LU-7.4 - Infill projects shall be designed in context with the neighborhood and surrounding zoning with respect to the existing scale and character of surrounding structures, and should blend rather than compete with the established character of the area; and
 Policy LU-1.4 - Infill projects shall be designed in context with the neighborhood and surrounding zoning with respect to the existing scale and character of surrounding structures, and should blend rather than compete with the established character of the area.

The Housing Element Update would adhere to the applicable General Plan policies and the Town’s existing design guidelines to ensure that development facilitated by the Housing Element Update does not substantially degrade visual character and quality of Los Gatos. As previously stated, the General Plan EIR concluded that new development would result in less than significant impacts associated with degrading the visual character or quality of the Town. Given that the Housing Element Update is consistent with the growth evaluated in the General Plan EIR, the Housing Element Update would result in less than significant impacts on scenic quality.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on scenic quality.
d. As identified in the General Plan EIR (Section 4.1, Aesthetics), new development facilitated under the General Plan would increase the development intensity throughout the Town, thereby introducing new sources of light. Potential sources of new nighttime light from new development include light spillover from the windows of residences and businesses, outdoor security lighting, lighted signs, and streetlights. New development could also produce glare from sunlight reflecting off windows, reflective surfaces, etc.

The development that would be facilitated by the General Plan, such as the housing sites associated with the Housing Element Update, would occur in already-urbanized areas of the Town, where existing lights and surfaces with glare are common. As a result, the General Plan EIR concluded that additional light and glare created under the General Plan, which includes the Housing Element Update, would not illuminate or contribute to light pollution in currently dark or unlit areas without reflective or glaring surfaces (p. 4.1- 25).

The Housing Element Update would also be required to comply with General Plan Policy CD-3.2, which requires that street and structure lighting minimize its visual impacts by preventing glare, limiting the amount of light that falls on neighboring properties, and avoiding light pollution of the night sky. In addition, safety lighting that may be implemented with the Housing Element Update would be required to conform to Townprescribed lighting regulations provided in Section 29.10.09015, Residential Outdoor Lighting, of the Los Gatos Municipal Code.

Section C Evaluation of Environmental Impacts 14 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
According to the General Plan EIR, new sources would not substantially increase the amount of nighttime lighting or glare in the already urbanized Town. The General Plan has an overall intent to improve the visual quality of Los Gatos and considers light and glare impacts from new development in the Town; therefore, the General Plan EIR concludes that impacts associated with light and glare would be less than significant (p. 4.1-25). The Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, would result in be less than significant impacts associated with light and glare. The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on light and glare.

Section C Evaluation of Environmental Impacts 15 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

2. AGRICULTURE AND FOREST RESOURCES
In determining whether impacts on agricultural resources are significant environmental effects and in assessing impacts on agriculture and farmland, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

Comments:
a. According to the General Plan EIR (Section 4.2, Agriculture and Forest Resources), the General Plan does not propose new or expanded conversion of Important Farmland or forestland to new uses and the Town prioritizes infill development and maximizing the underutilized parcels in the Town while maintaining existing community character.

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and the housing sites associated with the Housing Element Update would occur as infill development or on underutilized parcels in the Town.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to nonagricultural use?
☐ ☐ ☒ ☐
b. Conflict with existing zoning for agricultural use, or a Williamson Act contract?
☐ ☐ ☐ ☒
c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
☐ ☐ ☐ ☒
d. Result in the loss of forest land or conversion of
forest land to non-forest use?
☐ ☐ ☐ ☒
e. Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or
conversion of forest land to non-forest use?
☐ ☐ ☐ ☒

Section C Evaluation of Environmental Impacts 16 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Some of the sites associated with the Housing Element Update’s Lark Avenue Area are identified as Prime and Unique Farmland by the Farmland Mapping and Monitoring Program (California Department of Conservation 2018). Conversion of Important Farmland-designated lands to non-agricultural uses is considered an environmental impact. However, the Lark Avenue Area sites have been anticipated for residential uses since the previous general plan in 2011 (Town of Los Gatos 2011, Figure LU-3), are zoned for residential uses (Town of Los Gatos 2019), and are surrounded by urban uses (Google Earth 2022). Therefore, development associated with the Housing Element Update would result in less than significant impacts related to the conversion of Important Farmlands to non-agricultural uses and would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use.
b. None of the housing sites are zoned for agricultural use or are in a Williamson Act contract. See General Plan EIR Figure 4.2-2, Important Farmlands and Williamson Act Contracts in Los Gatos and SOI, within Section 4.2, Agriculture and Forest Resources.

Therefore, the Housing Element Update would not conflict with land currently zoned for agricultural use or with a Williamson Act contract.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on Williamson Act contracted land and conversion of land zoned for agricultural use.
c-e. The Town does not contain forest lands (Section 4.18, Effects Found Not to be Significant, Town of Los Gatos 2021, p. 4.18-1); therefore, development consistent with the growth projections evaluated in the General Plan EIR, such as the Housing Element Update, would not facilitate new or additional development that would conflict with existing zoning of or result in the loss of forest land to non-forest uses. In addition, the land throughout the southern and eastern portions of Los Gatos are no longer used as a source of timber for logging (Section 4.2, Agriculture and Forest Resources, p. 4.2-9). No impact would occur associated with the availability of forestry resources within the Town (Town of Los Gatos 2021, p. 4.18-1), or involve other changes in the existing environment which, due to their location or nature, could result in conversion of forest land to non-forest use.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on forest lands.

Section C Evaluation of Environmental Impacts 17 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

3. AIR QUALITY
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project:

Comments:
a. The most recently adopted air quality plan applicable to the Town of Los Gatos is the Bay Area Air Quality Management District’s Final 2017 Clean Air Plan, which describes how the San Francisco Bay Area will achieve compliance with the state’s one-hour ozone standard as expeditiously as practicable, and how the region will reduce transport of ozone and ozone precursors to neighboring air basins. As discussed in the General Plan EIR (Section 4.3, Air Quality), some of the General Plan policies within the Environment and Sustainability Element and the Mobility Element are aimed at reducing vehicle emissions and energy use, which are two major drivers of criteria air pollutant emissions.

General Plan Policy ENV-11.2 requires the increase in energy efficiency in municipal facilities; Policy ENV-11.4 promotes the use of efficient energy in new residences, businesses, and municipal buildings; and Policies ENV-11.5 and ENV-11.6 support the use of solar and organic waste recycling. Development projected by the General Plan would also be designed to promote active transportation and reduce vehicle miles traveled (VMT) in the Town, further reducing vehicle emissions through Policies ENV-8.3, MOB-1.1, MOB-1.2, MOB-2.2, MOB-2.3, and MOB-2.11.

Implementation of these General Plan policies would ensure that development under the General Plan would not result in significant criteria pollutant emissions or other significant air quality impacts. Therefore, the General Plan would be consistent with the goals of the Final 2017 Clean Air Plan (Town of Los Gatos 2021, p. 4.3-9). The General Plan EIR also concluded that the General Plan would be consistent with applicable Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Conflict with or obstruct implementation of the
applicable air quality plan?
☐ ☐ ☐ ☒
b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
nonattainment under an applicable federal or state
ambient air quality standard?
☐ ☒ ☐ ☐
c. Expose sensitive receptors to substantial pollutant
concentrations?
☐ ☐ ☒ ☐
d. Result in other emissions, such as those leading to
odors adversely affecting a substantial number of
people?
☐ ☒ ☐ ☐

Section C Evaluation of Environmental Impacts 18 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
control measures identified within the Final 2017 Clean Air Plan because it would implement similar measures through specific goals and policies that would reduce criteria pollutant emissions (p. 4.3-14). Additionally, it was concluded that buildout of the General Plan would not preclude planned transit or bike pathways and would not otherwise disrupt regional planning efforts to reduce VMT and meet federal and state air quality standards (Town of Los Gatos 2021, p. 4.3-14).

The Bay Area Air Quality Management District’s 2017 CEQA Air Quality Guidelines threshold for criteria air pollutants and precursors includes an assessment of the rate of increase of VMT and population. According to the General Plan EIR, because of the Town’s geographic and socioeconomic context, the rate of increase of service population is a more appropriate indicator than typical population as to whether the increase in VMT would be considered significant. It was determined that because VMT associated with buildout of the General Plan would increase by approximately 25 percent (General Plan’s 507,845 daily VMT/existing conditions 2,044,937 daily VMT), it would not exceed the rate of increase from the forecast population of approximately 29 percent (General Plan’s population increase of 8,971/Town’s population of 30,832). Therefore, impacts concerning criteria pollutants would be less than significant (Town of Los Gatos 2021, p. 4.3-14).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would be required to implement the applicable goals and policies of the Environment and Sustainability Element and the Mobility Element mentioned previously to ensure that development of the individual sites would not result in significant criteria pollutant emissions or other significant air quality impacts. Additionally, because many of the General Plan goals and policies are similar to the control measures outlined in the Final 2017 Clean Air Plan, implementation of them by the Housing Element Update would reduce criteria pollutant emissions. The Housing Element Update would also be required to promote active transportation through implementation of the applicable policies identified in the Mobility Element and stated above, reducing vehicle emissions.

The proposed population increase under the Housing Element Update is less than what was considered under the General Plan’s total buildout population and was evaluated by the General Plan EIR. Therefore, development associated with the Housing Element Update would not involve a VMT increase that exceeds the rate of the forecasted population.

For these reasons, the Housing Element Update, consistent with the growth projections evaluated in the General Plan EIR, would not conflict with or obstruct implementation of the applicable air quality plan. The General Plan EIR adequately addressed the Housing Element Update’s potential impact related to the conflict with an applicable air quality plan.
b. Development under the General Plan would involve construction activities that may result in air pollutant emissions such as demolition, grading, construction worker travel,

Section C Evaluation of Environmental Impacts 19 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
delivery hauling of construction supplies and debris, and fuel combustion by onsite construction equipment. Construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants during site preparation and grading, but the extent of daily emissions is unknown as it depends on the quantity of equipment and the hours of operation for each project.

The Bay Area Air Quality Management District’s 2017 CEQA Air Quality Guidelines do not have plan-level significance thresholds for construction air pollutant emissions that would apply to the General Plan. However, there are project-level thresholds for construction emissions that determine if a project’s construction emissions would be individually and cumulatively less than significant (i.e., if the construction emissions fall below the project-level thresholds). The Bay Area Air Quality Management District also identifies feasible fugitive dust control measures for construction activities that are recommended for all projects. Additionally, the Bay Area Air Quality Management District and California Air Resources Board have regulations that address the handling of hazardous air pollutants such as lead and asbestos, which could be aerially disbursed during demolition activities.

Section 4.3, Air Quality, of the General Plan EIR determined that construction associated with development under the General Plan would temporarily increase air pollutant emissions and possibly create localized areas of unhealthy air pollution concentrations or air quality nuisances. The General Plan’s goals and policies do not include implementation of feasible measures to reduce construction emissions associated with development and, therefore, the following mitigation would be required by all development under the General Plan to reduce temporary construction air quality impacts to a less-than-significant level (Town of Los Gatos 2021, p. 4.3-16 and -17).

Mitigation Measure
AQ-1 New discretionary projects in the General Plan Area that exceed the construction screening criteria of the Bay Area Air Quality Management District shall be conditioned to reduce construction emissions of reactive organic gases, nitrogen oxides, and particulate matter (PM10 and PM2.5) by implementing the Bay Area Air Quality Management District’s Basic Construction Mitigation Measures (described below) or equivalent, expanded, or modified measures based on project and site-specific conditions.

Basic Construction Mitigation Measures:

1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day, with priority given to the use of recycled water for this activity when feasible.

2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.

Section C Evaluation of Environmental Impacts 20 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping shall be prohibited.

4. All vehicle speeds on unpaved roads shall be limited to 15 mph.

5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.

6. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations). Clear signage shall be provided for construction workers at all access points.

7. All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified visible emissions evaluator.

8. A publicly visible sign shall be posted with the telephone number and person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Bay Area Air Quality Management District’s phone number shall also be visible to ensure compliance with applicable regulations.

Implementation of the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and may result in the generation of air pollutant emissions during construction activities. As discussed above, there are no thresholds for construction-related air pollutant emissions that would apply to the Housing Element Update because specific developments are unknown at this time.

Therefore, individual development associated with the Housing Element Update would be required to implement Mitigation Measure AQ-1 in order to reduce temporary construction air quality impacts and ensure that the Housing Element Update’s potential increase of criteria pollutants, for which the region is in nonattainment, would be less than cumulatively considerable.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts related to the increase of any criteria pollutant for which the region is nonattainment under an applicable federal or state ambient air quality standard. c. Sensitive receptors include residences, schools, and hospitals and are located throughout the Town. Pursuant to the Bay Area Air Quality Management District’s 2017 CEQA Air Quality Guidelines when assessing community risk and hazards for siting a new receptor, sources such as freeways or high-volume roadways within a 1,000-foot radius of a project

Section C Evaluation of Environmental Impacts 21 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
site are typically considered. As discussed in the General Plan EIR (Section 4.3, Air Quality), development projected by the General Plan could result in additional sources of toxic air contaminants through its commercial uses and, therefore, could increase the number of stationary or permitted sources that emit toxic air contaminants in the Town of Los Gatos. There are also several high-volume roadways within and around Los Gatos, such as State Routes 17 and 85, Los Gatos Boulevard, and Winchester Boulevard.

Areas of high traffic volumes typically result in elevated concentrations of carbon monoxide as the major source is automobile traffic.

The Bay Area Air Quality Management District’s 2017 CEQA Air Quality Guidelines have established preliminary screening criteria in determining whether a project would have a significant impact to localized carbon monoxide concentrations. It is noted that the screening criteria is not a threshold of significance, but is designed to provide the Town and project applicants with a conservative indication of whether a project would result in potentially significant air quality impacts. Using the screening criteria, the General Plan EIR determined that the highest traveled intersection in the Town (Los Gatos Boulevard at Lark Avenue) does not exceed traffic volumes for intersections affected by carbon monoxide and the General Plan would not substantially contribute to or result in the creation of carbon monoxide hotspots.

However, development under the General Plan may result in sensitive receptors placed in the proximity to high-volume roadways and freeways, which could expose sensitive receptors to pollutant concentrations. Development under the General Plan would be required to comply with General Plan Policy ENV-8.7, which requires that developments incorporate site planning techniques that reduce exposure of people to the impacts of high air pollutants from adjacent high-volume roadways. The General Plan EIR, therefore, concluded that impacts related to exposing sensitive receptors to pollutant concentrations would be less than significant (p. 4.3-18).

Development associated with the Housing Element Update could place sensitive receptors (i.e., residences) adjacent to high-volume roadways. The Housing Element Update does not, however, involve the increase in commercial development over existing conditions. Therefore, the Housing Element Update would not result in additional sources of toxic air contaminants through commercial uses increasing the number of stationary or permitted sources that emit toxic air contaminants in the Town. The Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, would be required to comply with General Plan Policy ENV-8.7.

Because the Housing Element Update was evaluated in the General Plan EIR and anticipated by the General Plan, development associated with the Housing Element Update would result in less than significant impacts related to exposing sensitive receptors to pollutant concentrations.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts related to sensitive receptors.

Section C Evaluation of Environmental Impacts 22 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
d. The Bay Area Air Quality Management District’s CEQA Air Quality Guidelines state that the land uses that typically produce objectionable odors include agricultural uses, wastewater treatment plants, food manufacturing plants, chemical plants, composting, refineries, landfills, and confined animal facilities. The General Plan would intermix industrial land uses with residential areas, which could have the potential to expose sensitive receptors (such as residents) to odors. Therefore, according to the General Plan EIR’s Section 4.3, Air Quality, the General Plan’s anticipated industrial development in these areas may result in objectionable odors that may affect a substantial number of people.

Construction associated with implementation of the General Plan could also emit odors from the construction vehicles and engine exhaust and idling, which may affect nearby receptors. Mitigation Measure AQ-1 would reduce construction air quality impacts to a less-than-significant level by reducing idling times and making sure that construction equipment is in proper working order (Town of Los Gatos 2021, p. 4.3-18).

The Housing Element Update does not involve the increase in any use other than residential, which the Bay Area Air Quality Management District determines as not typically producing objectionable odors. Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR. Therefore, the Housing Element Update would not result in the development of land uses that may expose sensitive receptors to objectionable odors. However, development associated with the Housing Element Update would involve construction activities, the equipment of which could emit odors that are objectionable to nearby sensitive receptors. Therefore, the Housing Element Update would be required to implement Mitigation Measure AQ-1 to reduce construction air quality impacts and their effect on nearby sensitive receptors.

The General Plan EIR adequately addressed the Housing Element Update’s potential to impact sensitive receptors with the creation of objectionable odors.

Section C Evaluation of Environmental Impacts 23 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

4. BIOLOGICAL RESOURCES
Would the project:

Comments:
a. Table 4.4-1 of the General Plan EIR (within Section 4.4, Biological Resources) illustrates that almost half of the Town is developed or an urban land use and does not provide habitat for the special-status species reported or known to occur in or near the Town of Los Gatos. Areas that may provide habitat for special-status species are primarily located in the open space and undeveloped hillside areas of the planning area and the waterways and wetlands adjacent to the waterways in the planning area, such as Los Gatos Creek and Ross Creek (Town of Los Gatos 2021, p. 4.4-12). As discussed throughout the Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife
or US Fish and Wildlife Service?
☐ ☐ ☒ ☐
b. Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or US
Fish and Wildlife Service?
☐ ☐ ☒ ☐
c. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to,
marsh, vernal pool, coastal, etc.), through direct
removal, filing, hydrological interruption, or other
means?
☐ ☐ ☒ ☐
d. Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
☐ ☐ ☒ ☐
e. Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☐ ☒
f. Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan?
☐ ☐ ☒ ☐

Section C Evaluation of Environmental Impacts 24 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
General Plan EIR, the General Plan focuses on infill development and redevelopment within the Town limits, which do not provide habitat suitable for special-status species.

Urban development is not allowed in areas of open space and the General Plan would not change these existing land use designations in order to prevent substantial development of the Town’s chaparral and scrubland habitats. The General Plan would also not facilitate permanent development in the riparian vegetation along the Town’s creeks and adjoining riparian areas.

Although development under the General Plan would occur in urban areas where infrastructure is already in place, the General Plan facilitates the increase in allowable density that could occur on some of the infill and redevelopment sites within the Town, which could require the upgrading of infrastructure facilities within riparian vegetation along creeks and waterways. Additionally, development within proximity to vegetation cover could result in new sources of light that affect nesting patterns or wildlife behavior.

This would result in potential temporary riparian and aquatic habitat impacts that support special-status species. Further, development facilitated by the General Plan could impact isolated trees and pockets of vegetation in the urbanized areas of Los Gatos. These trees and isolated pockets could provide habitat for special-status species, including migratory nesting birds, the disturbance or potential loss of which would be considered a significant, adverse impact.

Development under the General Plan would be subject to the provisions of various federal and state natural resources regulations and their respective permitting processes and would be required to implement the list of various goals and policies of the General Plan to help prevent loss of special-status species habitat in the Town. Specifically General Plan Policies ENV-5.2 and ENV-7.1, which would protect special-status plants and wildlife species and their habitats from adverse impacts of public and private projects, and Policies ENV-6.1 and ENV-16.2, which would protect aquatic habitat and adjacent riparian habitat. General Plan Policy ENV-7.11 would also be applicable and require implementation by development as it reduces indirect impacts to wildlife from light spill or light trespass from nearby development. Policy ENV-7.5 and ENV-7.10 would also prevent direct impacts to migratory nesting birds. Implementation of the General Plan’s applicable goals and policies, as well as compliance with state and federal regulations related to special-status species and their habitats, would ensure that impacts to special-status species and their habitats would be less than significant (Town of Los Gatos 2021, p. 4.4-16).

Development associated with the Housing Element Update would involve infill or the redevelopment of sites. No sites under the Housing Element Update are located within the Town’s hillside or open space areas that could contain habitats for special-status species. However, some of the sites associated with the Housing Element Update (within the Winchester Boulevard Area and Lark Avenue Area) are adjacent to the Los Gatos Creek. Development at these sites could result in indirect impacts on potential specialstatus species that are present in this riparian area through the creation of new light

Section C Evaluation of Environmental Impacts 25 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
sources that may affect the nesting patterns or behavior. Other impacts that could occur by development include the removal of or disturbance to isolated trees and pockets of vegetation that could provide habitat to nesting birds.

Development associated with the Housing Element Update would be required to comply with applicable policies of the General Plan such as Policy CD-3.2 and the Townprescribed lighting regulations provided in Town Code Section 29.10.09015, which are described further in Section 1.0, Aesthetics, checklist question “d;” Policy LU-1.3, which promotes high quality, well-designed, environmental sensitive, and diverse landscaping in new and existing developments and the preservation of existing trees, natural vegetation, natural topography, riparian corridors and wildlife habitats; Policy ENV-5.1, which requires that all development use native plants or appropriate non-invasive plants that are indigenous to Los Gatos and Santa Clara County to reduce disturbance of adjacent natural habitat; Policies ENV-5.2, -5.3, and -5.4, which all require that development protect special-status native plant species by way of prohibiting development that depletes or damages existing native plant species and prohibiting the use of invasive plant species; and Policies ENV-6.1, ENV-7.1, and ENV-16.2 mentioned previously.

Implementation of the General Plan’s applicable goals and policies, as well as compliance with state and federal regulations related to special-status species and their habitats, would ensure that impacts to special-status species and their habitats by development associated with the Housing Element Update would be less than significant.

The General Plan EIR adequately addressed the Housing Element Update’s potential to impact special-status species and their habitats.
b. The General Plan would facilitate infill development and redevelopment within existing urbanized areas of the Town and, therefore, is unlikely to contain surface waters and associated riparian vegetation zones. However, Section 4.4, Biological Resources, of the General Plan EIR explains that it is possible that the infill development facilitated by the General Plan would increase density in some areas, which could require upgraded utilities or stormwater drainage in areas of riparian habitat and streams, the construction of which could cause adverse, environmental impacts.

The General Plan’s applicable goals and policies would require conservation of existing creeks and avoidance of disturbing creeks as well as requiring setbacks and measures to protect riparian areas. Implementation of the General Plan’s goals and policies would ensure that development under the General Plan would result in less than significant impacts on riparian habitats (Town of Los Gatos 2021, p. 4.4-17).

Some of the sites associated with the Housing Element Update’s Winchester Boulevard Area and Lark Avenue Area are located adjacent to the Los Gatos Creek. Development of these sites could result in ground disturbance that adversely impacts the adjacent riparian habitat. However, the Housing Element Update would be required to comply with General Plan Policy ENV-6.1, preventing development from damaging riparian areas; ENV-6.2, requiring that riparian corridors, among other water courses, be retained

Section C Evaluation of Environmental Impacts 26 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
in their natural condition; ENV-6.3, which requires that setbacks and measures are implemented to protect riparian corridors; ENV-6.4, promoting the planting of local naïve trees and shrubs where development occurs on land surrounding streams; and ENV-16.4, which requires the conservation of existing creeks and the avoidance of disturbances to these areas.

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and the sites were evaluated with residential land uses in the General Plan EIR. Therefore, implementation of the applicable General Plan policies identified above would ensure that impacts on riparian habitats by development under the Housing Element Update would be reduced to a lessthan-significant level.

The General Plan EIR adequately addressed the Housing Element Update’s potential to impact on riparian habitats or other sensitive natural communities. c. The General Plan would facilitate infill development and redevelopment within existing urbanized areas of the Town and, therefore, is unlikely to contain jurisdictional wetlands.

However, Section 4.4, Biological Resources, of the General Plan EIR explains that it is possible that the infill development facilitated by the General Plan would increase density in some areas, which could require upgraded utilities or stormwater drainage in areas of jurisdictional wetlands and streams, the construction of which could cause adverse, environmental impacts
Detailed wetland delineations would be needed to determine the extent of any jurisdictional wetlands and other waters at specific locations and the U.S. Army Corps of Engineers is responsible for making a final determination for a particular site.

Compliance with the requirements of the Clean Water Act would be required for any project proposed under the General Plan as well as compliance with the goals and policies from the Environment and Sustainability Element and the Open Space, Parks, and Recreation Element of the General Plan; specifically General Plan Policy ENV-6.1, which would prevent development within wetlands. Implementation and compliance with state and federal regulations and the General Plan’s goals and policies promoting restoration of wetland and riparian habitat, impacts from development under the General Plan on wetlands would be less than significant (Town of Los Gatos 2021, p. 4.4-17).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR; therefore, the Housing Element Update would not propose residences on land with jurisdictional wetlands. The Housing Element Update would be required to comply with the requirements of the Clean Water Act and implement all applicable General Plan policies whose purpose is to protect wetlands within the Town (e.g., the policies associated with General Plan Goals ENV-6 and ENV-16). Compliance with state and federal regulations and implementation of applicable General Plan goals and policies would ensure that the Housing Element Update’s potential impact on wetlands would be less than significant.

Section C Evaluation of Environmental Impacts 27 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on wetlands.
d. The General Plan promotes redevelopment and infill development, which would occur in the developed portions of the Town. The developed areas of Los Gatos would not provide for wildlife movement corridors because the areas are developed with buildings and roads. Wildlife movements in the Town are generally limited to the hillside areas to the south and east, and the creeks, such as the Los Gatos Creek. However, Section 4.4, Biological Resources, of the General Plan EIR states that infill development under the General Plan could require construction of upgraded utilities and infrastructure that are near stream corridors (such as stormwater outfalls that are typically near riparian areas adjacent to creeks), which may result in significant environmental effects.

Development under the General Plan would be required to implement applicable General Plan goals and policies that would encourage wildlife movements and migration, such as Policy ENV-7.3, which directs the Town to maintain wildlife habitat and movement corridors for native wildlife species. Because the General Plan would not facilitate development in open space areas, including stream corridors, and contains policies to reduce impacts to stream corridors and protect wildlife movement corridors, the General Plan EIR concluded that impacts would be less than significant (Town of Los Gatos 2021, p. 4.4-20).

Some of the sites associated with the Housing Element Update (within the Winchester Boulevard Area and Lark Avenue Area) are located adjacent to the Los Gatos Creek.

However, development at these sites, among the others associated with the Housing Element Update, would be required to implement General Plan Policy ENV-6.1, requiring that developments do not damage riparian areas, wetlands, and intermittent or ethereal [sic] streams; Policy ENV-6.2, which requires that creek beds, riparian corridors, water courses, and associated vegetation are retained in their natural state; and Policy ENV-6.3, which requires that setbacks and measures are implemented to protect riparian corridors.

Consistent with the General Plan, the Housing Element Update would not facilitate development in open space areas, including stream corridors, and would implement all applicable General Plan policies to reduce impacts to stream corridors and protect wildlife movement corridors and open space. The sites associated with the Housing Element Update are not likely to facilitate major wildlife movement due to current active disturbance. As such, the Housing Element Update would have a less than significant impact on wildlife movement.

The General Plan EIR adequately addresses the Housing Element Update’s potential to interfere with the movement of migratory species.
e. Development under the General Plan could remove trees or substantially prune trees for construction. As discussed in the General Plan EIR (Section 4.4, Biological Resources),

Section C Evaluation of Environmental Impacts 28 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
development would be subject to all applicable local policies and regulations related to the protection of important biological resources such as the Town Municipal Code Chapter 29, Division 2 – Tree Protection. In addition to the Town Municipal Code, development under the General Plan would be required to comply with the policies associated with General Plan Goal ENV-2, such as Policy ENV-2.1, which requires that tree removal and replacement during development is consistent with the latest in tree conservation standards. Adherence to the tree protection requirements in the Town Municipal Code and implementation of the applicable General Plan policies would ensure that development under the General Plan would result in less than significant impacts related to local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance (Town of Los Gatos 2021, p. 4.4-21).

Most of the sites associated with the Housing Element Update contain trees and development may result in their removal or substantial pruning. However, the Housing Element Update would be required to comply with the Town Municipal Code’s Tree Protection standards for the preservation, protection, and maintenance of protected trees, including Section 29.10.1000 of the Town Municipal Code, which requires that a tree preservation report be prepared prior to construction on parcels with protected trees.

The Housing Element Update would also comply with all applicable General Plan policies related to the protection of biological resources. Compliance with the Town Municipal Code’s Tree Protection standards and applicable General Plan policies would ensure that development associated with the Housing Element Update would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

The General Plan EIR adequately addressed the Housing Element Update’s potential to conflict with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
f. The Final Santa Clara Valley Habitat Plan (habitat plan) (Santa Clara Valley Habitat Agency 2012) covers approximately 62 percent of Santa Clara County and only a small portion of this total involves the Town of Los Gatos. The Vasona Lake County Park and the riparian area on either side of Los Gatos Creek make up the portions of Los Gatos that are under the habitat plan’s coverage. The General Plan maintains a designation of Open Space for these areas and would not conflict with the habitat plan. There are no other adopted Habitat Conservation Plans or Natural Community Conservation Plans applicable to the planning area and, therefore, the General Plan EIR concluded that the General Plan would have no impact (Section 4.4, Biological Resources, p. 4.4-21).

Some of the sites associated with the Housing Element Update (the Winchester Boulevard Area and Lark Avenue Area) are adjacent to the Los Gatos Creek, which is within the habitat plan’s coverage area. Some portions of these sites are also themselves located within coverage of the habitat plan (Santa Clara Valley Habitat Agency 2022).

Therefore, pursuant to the provisions of the habitat plan, development within these areas

Section C Evaluation of Environmental Impacts 29 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
would be required to prepare and submit a habitat plan screening form. Development may also be required to apply for an exemption.

Because the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR, development at the Winchester Boulevard Area and Lark Avenue Area would prepare and submit habitat screening forms reducing its potential to result in conflict with the provisions of the habitat plan to a less-than-significant level.

The General Plan EIR adequately addresses the Housing Element Update’s potential to conflict with the provisions of the habitat plan.

Section C Evaluation of Environmental Impacts 30 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

5. CULTURAL RESOURCES
Would the project:

Comments:
a, b. According to the General Plan EIR (Section 4.5, Cultural and Tribal Cultural Resources), effects on cultural resources are only knowable once a specific project has been proposed because the effects are dependent on the individual project site conditions, project activities that may alter the character of an environment’s resources, and/or the characteristics of the proposed ground-disturbing activity (p. 4.5-10). Ground-disturbing activities associated with development under the General Plan have the potential to damage or destroy previously unknown historic or prehistoric archaeological resources that may be present on or below the ground surface. In addition to compliance with applicable General Plan policies, development consistent with the General Plan would be required to complete a Phase I Cultural Resources Inventory of the site, as discussed under Mitigation Measure CR-1 below (Town of Los Gatos 2021, p. 4.5-12).

None of the sites associated with the Housing Element Update are located within the Town’s Historic Districts (Town of Los Gatos 2022d); however, because development at each of the individual sites has not yet been proposed, construction activities could occur in areas that have not been previously developed with urban uses, have not been studied through a cultural resources investigation, or the excavation activities could reach depths that exceed those previously attained. Therefore, in order to ensure that development within the Town does not have detrimental effects on cultural resources, each individual project would need to be assessed as it is proposed.

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, would be required to comply with General Plan Policy ENV-12.1, which requires that archaeological and/or cultural resources are evaluated early in the development review process through consultation and use of contemporary professional techniques and Policy ENV-12.5, requiring that if cultural resource, including archaeological or paleontological resources, are uncovered during ground-disturbing activities, construction will stop until appropriate Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Cause a substantial adverse change in the significance of a historical resource pursuant to section 15064.5?
☐ ☒ ☐ ☐
b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to section
15064.5?
☐ ☒ ☐ ☐
c. Disturb any human remains, including those interred
outside of dedicated cemeteries?
☐ ☐ ☒ ☐

Section C Evaluation of Environmental Impacts 31 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
mitigation is implemented. In addition to compliance with General Plan policies, the Housing Element Update would be required to implement Mitigation Measure CR-1 in order to reduce impacts to a less-than-significant level.

Mitigation Measure
CR-1 If a project requires activities that have the potential to impact cultural resources, the Town shall require the project applicant or proponent to retain a qualified archaeologist meeting the Secretary of the Interior’s (SOI) Professional Qualification Standards (PQS) in archaeology and/or an architectural historian meeting the SOI PQS standards in architectural history to complete a Phase 1 cultural resources inventory of the project site (NPS 1983). A Phase 1 cultural resources inventory shall include a pedestrian survey of the project site and sufficient background archival research and field sampling to determine whether subsurface prehistoric or historic remains may be present. Archival research shall include a records search conducted at the Northwest Information Center (NWIC) and a Sacred Lands File (SLF) search conducted with the Native American Heritage Commission (NAHC). The technical report documenting the Phase 1 cultural resources inventory shall include recommendations to avoid or reduce impacts to cultural resources. These recommendations shall be implemented and incorporated in the project.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on historic and archaeological resources.
c. As discussed in the General Plan EIR (Section 4.5, Cultural and Tribal Cultural Resources), the potential to discover human burials within the Town exists even though much of the Town is built out. Excavation during construction activities would have the potential to disturb these resources. Therefore, development associated with the Housing Element Update, which is consistent with the growth projections evaluated in the General Plan EIR, has the potential to disturb these unknown Native American burials.

The General Plan EIR determined that development under the General Plan (inclusive of the Housing Element Update) would be required to comply with existing regulations relating to the treatment of human remains in General Plan Goal ENV-12: Protect the Town’s archaeological and cultural resources to maintain and enhance a unique sense of place.

Development associated with the Housing Element Update would also be required to comply with General Plan Policy 12.4, which states that any human remains discovered during implementation of public or private projects within the Town shall be treated with respect and dignity, and Policy ENV-12.6, which encourages development to avoid impacts to burial sites by designing or clustering development to avoid archaeological deposits that may contain human remains.

Section C Evaluation of Environmental Impacts 32 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
As concluded in the General Plan EIR, implementation of these General Plan policies would help ensure that development carried out under the General Plan (including the Housing Element Update) would have a less than significant impact from potential disturbance of human remains, including those interred outside of formal cemeteries (p. 4.5-13).

The General Plan EIR adequately addressed the Housing Element Update’s potential to disturb human remains, including those interred outside of formal cemeteries.

Section C Evaluation of Environmental Impacts 33 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

6. ENERGY
Would the project:

Comments:
a. Construction Energy Demand. The General Plan EIR (Section 4.6, Energy) discusses the energy use during construction activities associated with implementation of the General Plan. It notes that construction would be temporary in nature and the construction equipment used would be typical of similar-sized construction projects in the region. Construction contractors would be required to comply with the provisions of the California Code of Regulations Title 13 Sections 2449 and 2485, which prohibit diesel-fueled commercial motor vehicles and off-road diesel vehicles from idling for more than five minutes and would minimize unnecessary fuel consumption. Development under the General Plan would also be required to comply with construction waste management practices to divert a minimum of 65 percent of construction debris, pursuant to the applicable regulatory requirements found in the California Green Building Standards Code. Compliance with these practices would result in efficient use of energy necessary to construct development under the General Plan. Therefore, the General Plan EIR concluded that the General Plan would not involve the inefficient, wasteful, and unnecessary use of energy during construction, and construction impacts related to energy consumption would be less than significant (p. 4.6-14).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, developers would be required to comply with the provisions of the California Code of Regulations Title 13 Sections 2449 and 2485 and the applicable regulatory requirements related to diversion of construction debris associated with the California Green Building Standards Code in order reduce unnecessary fuel consumption. The Housing Element Update would result in the development of residential uses. The Housing Element Update’s energy demand would not be excessive relative to total Santa Clara County-wide demand or relative to other land use projects and would not inherently be a source of wasteful energy demand.

Development associated with the Housing Element Update would consume energy, but it would not be inefficient, wasteful, or unnecessary. Therefore, the impact would be less than significant.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Result in a potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
☐ ☐ ☒ ☐
b. Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
☐ ☐ ☐ ☒

Section C Evaluation of Environmental Impacts 34 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Operational Energy Demand. Transportation Fuel Consumption - As discussed in the General Plan EIR (Section 4.6, Energy), operation of the development under the General Plan would contribute to regional energy demand by consuming electricity, natural gas, and gasoline and diesel fuels. The General Plan EIR states that fuel consumption is closely associated with vehicle miles traveled (VMT); the more miles a vehicle travels, the more fuel that is required and consumed by that vehicle. However, the General Plan EIR discusses how the VMT generated by the General Plan would not increase boundary VMT per capita (the VMT within a specific geographic region) in Santa Clara County and, therefore, the effects from VMT would be localized and not have regional impacts.

This is related to energy because it suggests that fuel consumption resulting from the General Plan would be consistent with regional trends and would not be wasteful or inefficient. In addition, this encourages high-density and mixed-use infill developments with project design that support multi-modal transportation, which improve energy efficiency because it places residents closer to places of employment. These factors would help minimize the potential for the General Plan to result in the wasteful, inefficient, or unnecessary consumption of vehicle fuels.

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, its VMT generation would not increase boundary VMT per capita in Santa Clara County suggesting that its fuel consumption, like the General Plan’s consumption, would be consistent with regional trends and would not be wasteful or inefficient. Implementation of the Housing Element Update would also involve high-density and mixed-use infill developments thereby improving energy efficiency.

Natural Gas and Electricity - Development under the General Plan would consume natural gas and electricity for building heating and power, lighting, and water conveyance, among other operational requirements. Implementation of the policies associated with General Plan Goal PFS-6, encouraging development that reduces the use of non-renewable energy resources and expands the use of renewable resources and alternative fuels, and those associated with General Plan Goal PFS-7, which promotes green buildings that minimizes consumption of energy and natural resources, would offset some of the overall energy demand facilitated by buildout under the General Plan. In addition, developments under the General Plan would be subject to the energy conservation requirements of the California Energy Code and the California Green Building Standards Code. In 2018, the California Building Standards Commission began to require that solar photovoltaic panels be installed on new low-rise residential buildings (i.e., single-family homes and multifamily buildings of three stories or less). Because this requirement would involve applicable new residential development under the General Plan, the operational energy demand would be supplemented with renewable energy sources to a greater degree.

Therefore, residential development facilitated by the General Plan would, in general, be less dependent on fossil fuels than previous development.

In addition, the General Plan EIR indicated that a greater proportion of electricity supplied for operational power needs in Los Gatos through 2040 would be sourced from

Section C Evaluation of Environmental Impacts 35 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
renewables. Renewable energy sources generally result in reduced long-term environmental impacts compared to non-renewables because renewable sources do not require combustion of coal or natural gas to generate electricity, which avoids environmental impacts associated with air pollution and greenhouse gas emissions.

The General Plan EIR concluded that development under the General Plan would not result in potentially significant environmental effects from wasteful, inefficient, or unnecessary consumption of energy and this impact would be less than significant (p. 4.6-14).

Development associated with the Housing Element Update would be required to comply with the above-mentioned goals and policies located with the Public Facilities, Services, and Infrastructure Element of the General Plan in order to reduce energy consumption by development. The Housing Element Update would also be subject to the energy conservation requirements of the California Energy Code and the California Green Building Standards Code, which would help offset some of the overall energy demand by the Housing Element Update. Development associated with the Housing Element Update would involve new single-family and multi-family structures three stories or less (i.e., low-rise residential buildings) and, therefore, would be required to install solar photovoltaic panels pursuant to the adopted 2018 modifications to Title 24 of the California Energy Code. Therefore, residential development facilitated by the Housing Element Update, which is consistent with the growth projections evaluated in the General Plan EIR, would be less dependent on fossil fuels than existing development.

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, would result in less than significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during construction or operation. The General Plan EIR adequately addressed the Housing Element Update’s potential impacts related to energy demand during construction and operation.
b. Section 4.6, Energy, of the General Plan EIR discussed the General Plan’s consistency with state plans (California Green Building Standards Code and Title 24 of the California Energy Code) and a local plan (Los Gatos Sustainability Plan) for renewable energy or energy efficiency.

State. Any newly constructed buildings under the General Plan would be required to comply with all building design standards set in the California Building Code’s Title 24 (the California Green Building Standards Code is Part 11 of Title 24). Title 24 requires the implementation of energy efficient light fixtures and building materials into the design of new construction projects. The standards identified in Title 24 are updated every three years and each iteration is more energy efficient than the previous standards.

Development under the General Plan would also be required to comply with Senate Bill 100, which mandates 100 percent clean electricity for California by 2045. Impacts related to consistency of the General Plan with applicable state plans for increased energy efficiency and renewable energy use would be less than significant (p. 4.6-15).

Section C Evaluation of Environmental Impacts 36 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, would also be required to comply with all applicable building design standards identified above and within Title 24.

Compliance with these standards would allow development under the Housing Element Update to result in more efficient consumption of energy through design features such as efficient light fixtures and building materials. Additionally, because development associated with the Housing Element Update would be powered by the existing electricity grid, it would be powered by renewable energy mandated by Senate Bill 100. The Housing Element Update, therefore, would not conflict with or obstruct a state plan for renewable energy or energy efficiency.

Local. The Los Gatos Sustainability Plan was adopted as a long-term strategy to reduce greenhouse gas emissions in the Town and further implement sustainability measures from the previous general plan. The document focuses on five sectors, providing specific measures to reduce greenhouse gas emissions from each sector in order to achieve the Town’s reduction target of reducing greenhouse gas emissions 15 percent below baseline emissions (2008 or earlier) by 2020. The sectors covered in this plan are Transportation and Land Use, Energy, Water, Solid Waste, and Open Space.

The General Plan EIR evaluates the General Plan’s consistency against the Los Gatos Sustainability Plan in Table 4.6-5, and concludes that the General Plan would be consistent with the plan and the energy efficiency strategies contained therein. Impacts related to consistency of the General Plan with applicable local plans for increased energy efficiency and renewable energy use would be less than significant (p. 4.6-21).

Development associated with the Housing Element Update would be consistent with the growth projections evaluated in the General Plan EIR and, therefore, would implement those applicable General Plan goals and policies identified in the consistency analysis (Table 4.6-5 of the General Plan EIR) in order to comply with the sustainability measures of the Los Gatos Sustainability Plan. For these reasons, the Housing Element Update would not conflict with applicable local plans for increased energy efficiency and renewable energy use.

The General Plan EIR adequately addresses the Housing Element Update’s potential to conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Section C Evaluation of Environmental Impacts 37 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

7. GEOLOGY AND SOILS
Would the project:

Comments:
a. Earthquake Rupture. No known fault crosses any one of the sites associated with the Housing Element Update and the sites are not located in an Alquist-Priolo Earthquake Zone; the nearest Alquist-Priolo Earthquake Zone is approximately three miles southwest of the southernmost site associated with the Housing Element Update (California Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:

(1) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42?
☐ ☐ ☐ ☒
(2) Strong seismic ground shaking? ☐ ☐ ☒ ☐
(3) Seismic-related ground failure, including
liquefaction?
☐ ☐ ☒ ☐
(4) Landslides? ☐ ☐ ☐ ☒
b. Result in substantial soil erosion or the loss of topsoil? ☐ ☐ ☒ ☐ c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction, or collapse?
☐ ☐ ☒ ☐
d. Be located on expansive soil, creating substantial
direct or indirect risks to life or property?
☐ ☐ ☒ ☐
e. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal
systems where sewers are not available for the disposal of wastewater?
☐ ☐ ☐ ☒
f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
☐ ☒ ☐ ☐

Section C Evaluation of Environmental Impacts 38 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Department of Conservation 2022). Further, Section 4.7, Geology and Soils, of the General Plan EIR states that fault rupture is unlikely to affect new or existing structures in the Town because the only Alquist-Priolo Earthquake Zone is located west of the Town’s western limits (p. 4.7-19). Therefore, development associated with the Housing Element Update would also not exacerbate impacts related to earthquake rupture for faults in an Alquist-Priolo Earthquake Zone.

The General Plan EIR adequately addressed the Housing Element Update’s potential to directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault.

Seismic Ground-Shaking. The Town is located in an active seismic region with three faults running through it (Blossom Hill Fault, Shannon Fault, and Berrocal Fault), which would subject the Town to very strong ground shaking. According to the General Plan EIR (Section 4.7, Geology and Soils), ground shaking risk would be primarily in the northern portion of the Town.

Development under the General Plan would result in additional residential and nonresidential development within the Town, which would potentially expose people and structures to the effects of seismic ground shaking events. However, the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would involve infill development, which would in many cases replace older structures subject to seismic damage with newer structures built to current seismic standards that could better withstand the adverse effects of strong ground shaking (p. 4.7- 19). Potential structural damage and the exposure of people to the risk of injury or death from structural failure would be minimized by compliance with the California Building Code engineering design and construction measures. Foundations and other structural support features for development consistent with the General Plan would be designed to resist or absorb damaging forces from strong ground shaking.

The Housing Element Update would be required to comply with General Plan Policy HAZ-4.1, which requires new development to be sited away from high risk geologic and seismic hazard zones or, if located in a high-risk zone, incorporate construction techniques to reduce risk; Policy HAZ-4.2, which requires a geotechnical report to be prepared for new development proposed in hazard zones mapped by the state or the Town; Policies HAZ-4.3 and HAZ-4.4, which both require, respectively, that a geotechnical report is prepared for development with significant grading, potential erosion, and sedimentation hazards and for developments proposed in areas with identified geologic hazards; and Policy HAZ-4.8, which requires that a licensed geologic/geotechnical engineer complete the Town Geologic Hazards Checklist to demonstrate that potential hazards have been identified and that proposed structures will be designed to resist potential earthquake effects (Town of Los Gatos June 2022a). The General Plan EIR concludes that implementation of the mandatory California Building Code requirements and the General Plan’s goals and policies would reduce the potential for loss, injury, or death following a seismic event to a less-than-significant level.

Section C Evaluation of Environmental Impacts 39 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The housing sites associated with the Housing Element Update are located in areas of medium to high ground-shaking intensity, according to the General Plan EIR’s Figure

4.7-4. However, development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would not exacerbate seismic hazards associated with seismic ground shaking. The Housing Element Update would be required to implement the requirements of the California Building Code and applicable General Plan policies to ensure that impacts related to seismic ground-shaking are less than significant.

The General Plan EIR adequately addressed the Housing Element Update’s potential to directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic ground-shaking.

Liquefaction. According to the California Department of Conservation’s mapping, the Town includes areas susceptible to liquefaction located generally in the center of the Town and along State Route 17 (California Department of Conservation 2022). Most, if not all, of the sites associated with the Housing Element Update are in areas of liquefaction susceptibility. According to the General Plan EIR (Section 4.7, Geology and Soils), foundations and other structural support features for development under the General Plan, including the Housing Element Update, would be designed to resist or absorb damaging forces from liquefaction (p. 4.7-20). The Housing Element Update would be required to comply with General Plan policies identified under the discussion for Seismic Ground-Shaking, above.

Implementation of General Plan policies, in addition to compliance with applicable laws and regulations, would minimize the potential for loss, injury, or death following a seismic event and would reduce impacts to a less-than-significant level (Town of Los Gatos 2021, p. 4.7-21). Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would comply with the General Plan policies listed above and applicable laws and regulations of the California Building Code to ensure impacts are reduced to a less-than-significant level.

The General Plan EIR adequately addressed the Housing Element Update’s potential to directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving liquefaction.

Landslides. According to the California Department of Conservation’s mapping, the Town has areas susceptible to landslides throughout much of the southern and eastern portions of the Town and extending as far north as Blossom Hill Road (California Department of Conservation 2022). Outside of the hillside areas of the Town, there is potential for landslides and slope instability along the steep banks of drainages, and steep graded slopes associated with excavations. However, according to Section 4.7, Geology and Soils, of the General Plan EIR, landslide potential is minimal in the gently sloping west central and northernmost portions of the Town (Town of Los Gatos 2021,

Section C Evaluation of Environmental Impacts 40 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
p. 4.7-19). None of the sites associated with the Housing Element Update are located within these landslide hazard zones and, therefore, development of these sites would not exacerbate landslide hazards through grading or other site modification activities that reduce slope stability.

The General Plan EIR adequately addressed the Housing Element Update’s potential to directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides.
b. Wind and water are the main forces that cause soil erosion. Depending on how well exposed soil surfaces are protected from these forces, the erosion process can be very slow or rapid. Removal of natural or manufactured protection can result in substantial soil erosion and excessive sedimentation. Construction activities that would occur on individual sites associated with the Housing Element Update represent the greatest potential cause of erosion.

According to the General Plan EIR (Section 4.7, Geology and Soils), new development under the General Plan would involve construction activities that may result in loose or disturbed soils in the Town, which can increase the potential for erosion and loss of topsoil.

Construction activities that disturb one or more acres of soil and, therefore, would be subject to the National Pollutant Discharge Elimination System General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities adopted by the State Water Resources Control Board under the Clean Water Act. The Town’s Municipal Code Chapter 22, Article III enforces compliance with the Construction General Permit. Development of any site that disturbs more than one acre of soil will also be required to file a Notice of Intent with the State Water Resources Control Board and prepare a Storm Water Pollution Prevention Plan describing erosion and sediment control best management practices. Chapter 12 of the Town’s Municipal Code also provides regulatory standards to ensure grading, erosion, and sediment associated with development are minimized.

Many of the sites associated with the Housing Element Update would involve construction activities that disturb one or more acres of soil and, therefore, would be subject to the General Permit and be required to prepare a Storm Water Pollution Prevention Plan. Compliance is also required with the Town’s Municipal Code Chapter 12 that provides regulatory standards to ensure grading, erosion, and sediment associated with development are minimized. Development under the General Plan would be required to implement applicable General Plan policies and goals that would ensure that construction projects minimize their potential impacts related to erosion. Compliance with applicable laws and regulation, as well as implementation of applicable General Plan policies, would reduce impacts to a less-than-significant level (Town of Los Gatos 2021, p. 4.7-23).

Section C Evaluation of Environmental Impacts 41 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
According to the General Plan EIR, potential for erosion in Los Gatos is highest in the eastern, southern, and southwestern areas of the Town, with its potential decreasing toward the center of the Town and minimal in the flat areas just east of State Route 17.

The sites associated with the Housing Element Update are centrally located in the Town, along and east of State Route 17, with a few sites in the southwestern and northern ends of the Town. Therefore, there is potential for development associated with the Housing Element Update to result in soil erosion or loss of topsoil.

Development associated with the Housing Element Update would be required to comply with General Plan Policy ENV-15.1, which requires all new developments in areas subject to soil erosion to prepare erosion control plans to minimize soil erosion; Policy ENV15.2, which requires that grading permits be issued to ensure that the grading of slopes and sites proposed for development will be minimized; and Policy ENV-16.9, which requires that pollution in urban runoff be reduced from residential land use activities and other land uses.

Adherence to the state’s stormwater discharge permitting requirements, in addition to the above-mentioned General Plan policies, would ensure that potential impacts associated with soil erosion and loss of topsoil would be less than significant.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts associated with soil erosion and the loss of topsoil. c. According to the General Plan EIR (Section 4.7, Geology and Soils), development under the General Plan would result in additional residential and nonresidential development within the Town that would be potentially exposed to the effects of unstable soils.

However, potential structural damage and the exposure of people to the risks from unstable soils from structural failure would be minimized by compliance with the California Building Code engineering design and construction measures. Foundations and other structural support features would be designed to resist or absorb damaging forces from strong ground shaking and liquefaction. In addition to compliance with mandatory California Building Code requirements, implementation of applicable General Plan goals and policies, such as those listed previously in this section, would reduce the potential for development under the General Plan to exacerbate unstable soil conditions and ensure impacts are less than significant (p. 4.7-20 to 4.7-21).

Structures constructed on soils which are prone to liquefaction are subject to damage and possible collapse as a result of settlement and lateral spreading due to liquefaction (Town of Los Gatos 2021, p. 4.7-13). As discussed previously, most of the housing sites associated with the Housing Element Update are located on land that is susceptible to liquefaction. Development on the sites associated with the Housing Element Update could also result in soil erosion or loss of topsoil.

Construction activities on the individual housing sites associated with the Housing Element Update could risk exacerbating unstable soil conditions during grading and/or other site development/excavation activities. Developers are required to comply with the

Section C Evaluation of Environmental Impacts 42 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
General Plan policies identified in checklist questions “a” and “b” as well as the applicable requirements of the California Building Code. A detailed review of design and construction plans and incorporation of additional structural safety features would be required on a project-by-project basis, as necessary, for structures that would be located in areas subject to soil that is unstable, or that would become unstable as a result of the Housing Element Update.

Implementation of the applicable General Plan policies and the California Building Code would reduce the adverse effects of unstable geologic units and reduce the potential to exacerbate soil instability hazards to a less-than-significant level.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts associated with unstable soils.
d. According to the General Plan EIR (Section 4.7, Geology and Soils), the clay minerals in the Town’s clay and clay loam soils are prone to expansion and have moderate to high shrink-swell potential (p. 4.7-23). The California Building Code includes requirements to address soil-related hazards such as the removal, proper fill selection, and compaction of soil. In cases where soil remediation is not feasible, the California Building Code requires structural reinforcement of foundations to resist the forces of expansive soils. According to the General Plan EIR, compliance with the requirements of the California Building Code would reduce impacts related to expansive soils to a less-than-significant level (p.

4.7-23).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would be required to comply with the applicable requirements of the California Building Code. Therefore, impacts related to expansive soils on the individual sites associated with the Housing Element Update would be less than significant.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts associated with expansive soils.
e. Development under the General Plan encourages infill development and redevelopment within the Town of Los Gatos limits and would minimize encroachment into open space areas where wastewater infrastructure does not currently exist. Therefore, Section 4.7, Geology and Soils, of the General Plan EIR concludes that the General Plan would result in less than significant impacts related to soils that are incapable of supporting septic tanks or alternative wastewater disposal systems (p. 4.7-24).

All proposed sites associated with the Housing Element Update would connect into the Town’s existing sanitary sewer system and, therefore, no impacts associated with soils supporting the use of septic tanks would occur.

The General Plan EIR adequately addressed the Housing Element Update’s potential to have soils onsite that are incapable of adequately supporting the use of septic tanks.

Section C Evaluation of Environmental Impacts 43 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
f. According to the General Plan EIR (Section 4.7, Geology and Soils), the geologic units exposed at ground surface in the Town and the vicinity include Mesozoic rocks of the Franciscan Assemblage, the Miocene Temblor Sandstone, the Miocene Monterey Formation, the Pliocene-Pleistocene Santa Clara Formation, and Quaternary Alluvium.

The Miocene to Pleistocene sedimentary deposits in the Town have a high potential to yield paleontological resources (Town of Los Gatos 2021, p. 4.7-24). Therefore, paleontological resources may be encountered during any ground-disturbing activities associated with implementation of the General Plan. Directly or indirectly destroying a unique paleontological site is considered a significant environmental impact and, therefore, the General Plan would be required to comply with General Plan Policy ENV-12.5, requiring that if cultural resources, including paleontological resources, are uncovered during grading or other onsite excavation activities, construction shall stop until appropriate mitigation is implemented. Additionally, implementation of the following mitigation measure would ensure this potential impact would be less than significant (p. 4.7-25).

Mitigation Measure
GEO-1 The Town shall require paleontological resource studies for projects that involve ground disturbance in project areas mapped as high paleontological sensitivity at the surface or subsurface determined through environmental review. Additionally, in the event that a paleontological resource is disclosed, construction activities in the area shall be suspended, a qualified paleontologist shall be retained to examine the site, and protective measures shall be implemented to protect the paleontological resource.

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and may encounter unknown paleontological resources during construction activities. The Housing Element Update would be required to implement Mitigation Measure GEO-1 in order to ensure impacts would be less than significant.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts associated with paleontological resources.

Section C Evaluation of Environmental Impacts 44 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

8. GREENHOUSE GAS EMISSIONS
Would the project:

Comments:
a. According to the General Plan EIR (Section 4.8, Greenhouse Gas Emissions), development facilitated by the General Plan would involve activities, such as construction demolition and grading, that would result in greenhouse gas (GHG) emissions. The Bay Area Air Quality Management District does not have plan-level significance thresholds for construction GHG emissions that would apply to the General Plan. Therefore, the General Plan EIR determined that no significance conclusion would be made with regard to General Plan programmatic construction-related GHG emissions alone; rather operational and total (construction plus operational) programmatic GHG emissions are assessed with regard to significance level (Town of Los Gatos 2021, p. 4.8-25).

Los Gatos GHG emissions are based on the Los Gatos communitywide 2008 emissions inventory and communitywide GHG emissions anticipated related to ongoing activities within the community and buildout of the General Plan. Projected GHG emissions for 2030, 2040, and 2045 include implementation of the General Plan as well as several state and local GHG reduction actions that are assumed to be implemented (p. 4.8-25). The General Plan EIR determined that the GHG emissions generated by the General Plan would exceed the 2030 efficiency threshold of 3.31 metric tons of carbon dioxide equivalents (CO2e) per service person per year as well as exceed the 2040 efficiency threshold of 1.02 metric tons of CO2e per service person per year.

The General Plan EIR explains that while various goals, policies, and implementation programs contained in the General Plan would implementation some GHG emission reduction strategies related to energy use and vehicle miles traveled reduction, development under the General Plan would not achieve GHG reductions to reach less than significant levels (represented by equal to or less than 3.31 per capita metric tons CO2e per service person per year and by 2030 and 1.02 per capita metric tons CO2e per service person per year by 2040). The General Plan EIR indicates that the exceedance is primarily due to on-road vehicle miles traveled, which accounts for approximately 81 percent of the total emissions, and the main barrier to reducing vehicle miles traveled is the lack of public transit options in the Town.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
☒ ☐ ☐ ☐
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
☒ ☐ ☐ ☐

Section C Evaluation of Environmental Impacts 45 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
As discussed in Section 17.0, Transportation, the greatest reduction in vehicle miles traveled would be from the regional level reduction strategies outlined in Mitigation Measure T-1, which is explained as not possible since the Town cannot guarantee that other agencies and municipalities would participate in the regional strategies. Because of these limitations, development under the General Plan would be required to implement Mitigation Measure GHG-1.

Mitigation Measure
GHG-1 Los Gatos shall implement the following GHG emissions reduction measures by sector:

Energy (EN)
 Measure EN1: Adopt an ordinance requiring new commercial construction to be all electric or otherwise operationally carbon neutral by 2025: Adopt a new building ordinance which bans the installation of natural gas in new commercial construction by 2025 and requires new commercial buildings to install all-electric equipment or otherwise be operationally carbon neutral. Support this action by conducting outreach and education to local developers about the benefits and resources associated with building carbon neutral buildings.
 Measure EN2: Identify and partner with stakeholders to conduct electrification outreach, promotion, and education: Leverage partnerships with stakeholders to conduct outreach, promotion, and education around new and existing building electrification.  Measure EN3: Develop a Community wide Existing Residential Building Electrification Plan (EBEP): Support community-wide existing building electrification through the development of an EBEP that addresses the feasibility, timeline, equity concerns, local stakeholder involvement, costs, funding pathways, and
implementation for electrifying existing residential buildings in Los Gatos.
 Measure EN4: Electrify existing residential buildings beginning in 2023: Adopt an electrification ordinance for existing residential buildings to transition natural gas to electric in two phases, to be implemented through the building permit process:
 Phase I: Limit expansion of natural gas lines in existing buildings by 2023.
 Phase II: Require HVAC system replacements and hot water heaters replacements to be all-electric by 2023.

Section C Evaluation of Environmental Impacts 46 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
 Measure EN5: Identify and partner with stakeholders to develop resident-level funding pathways for implementing electrification ordinance: Leverage partnerships with stakeholders and establish funding pathways to ease community members’ costs when complying with the electrification ordinance, including:
 Pass a transfer tax ordinance and provide a rebate for electric panels and/or other upgrades.
 Partner with PG&E, SVCE, and/or other stakeholders to create or expand electrification/retrofit programs and incentives, especially for low-income residents. These could include the PACE program, PG&E’s low-income weatherization. program, tariffed on-bill financing, metered energy efficiency, or others.  Measure EN6: Decarbonize municipal buildings by 2040: Adopt a municipal building energy decarbonization plan to decarbonize municipal building energy operations by 2040. This plan would include a new building electrification policy as well as an existing building natural gas phase-out policy.
 Measure EN7: Coordinate with stakeholders to provide local energy generation support and incentives for the community: Partner with PG&E, SVCE, and/or other stakeholders to support and incentivize local on-site energy generation and storage resources within the community.
 Measure EN8: Develop an EV Readiness Plan to Support
Installation of 794 Chargers by 2030: Develop an EV Readiness Plan that supports the installation of 794 chargers (at least 160 of which would be public chargers) and a 30 percent EV share of registered passenger vehicles in Los Gatos by 2030. This plan should establish a path forward to increase EV for implementation of public charging infrastructure in key locations. In conjunction with an EV Readiness Plan, conduct a community EV Feasibility Study to assess infrastructure needs and challenges, particularly in frontline communities.
 Measure EN9: Increase privately owned EV charging infrastructure:

Amend the Town’s Building Code and Local Reach Code to require the following:
 EV capable attached private garages for new single-family and duplex residential development;
 20 percent EV capable charging spaces and panel capacity for new multi-family residential development;

Section C Evaluation of Environmental Impacts 47 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
 20 percent EV capable charging spaces for new commercial development; and
 At least 1 percent working chargers for all new development and major retrofits.
 Measure EN10: Increase Town-owned and publicly accessible EV charging infrastructure: Work with public and private partners to ensure there are sufficient publicly accessible DCFC and Level 2 EV chargers around the Town by 2030, with a focus on providing access to low-income households and affordable housing. Install new publicly accessible EV chargers at Town-owned facilities. Develop and implement a fee for use of Town-owned chargers to encourage efficient use and turnover, especially for those without home charging capability.
 Measure EN11: Identify and partner with stakeholders to develop EV-related rebates: Investigate partnerships with public and private partners for rebates on at-home electric circuits, panel upgrades, and Level 2 chargers, with a focus on supporting EV purchases for lowincome households in frontline communities.  Measure EN12: Encourage EV adoption and infrastructure improvements: Conduct outreach, promotion, and education to encourage EV adoption and infrastructure improvements. This would include the following:
 Providing education and outreach to the community on the benefits of ZEVs, availability of public charging, and relevant rebates and incentives available for businesses and residents.  Working with major employers to provide EV charging for employees and encourage EV adoption among employees.

Transportation (TR)
 Measure TR1: Implement Full Recommended Buildout of the Bicycle and Pedestrian Master Plan (BPMP): Fully implement the BPMP and add 23.2 new miles of bike network by 2035 to achieve 6 percent bicycle mode share by 2035.
 Measure TR2: Identify and partner with stakeholders to conduct outreach, promotion, and education: Leverage partnerships with stakeholders to conduct ongoing outreach, promotion, and education around active transportation in Los Gatos. This could include:

Section C Evaluation of Environmental Impacts 48 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
 Establishing Town-wide events or programs that promote active transportation in the community;
 Regularly updating the Town’s Bicycle and Pedestrian
Network Map and sharing through Town and stakeholder
partnership platforms;
 Supporting local bike groups in hosting workshops and classes on bike riding, safety, and maintenance by certified instructors;  Instituting car-free days downtown, potentially coupled with other large and regular events; or
 Consolidating a list of local employer-provided bicycle parking, lockers, showers, and incentives as a demonstration tool for other interested employers.
 Measure TR3: Facilitate a bike share program: Conduct a bike share pilot program and facilitate full implementation of a bike share program within the Town.
 Measure TR4: Establish parking meter rates and invest in transportation improvements: Establish parking meter rates, considering dynamic parking pricing in the downtown area.

Allocate a designated portion of paid parking revenue to investing in TDM strategies that will ensure cost-effective downtown access by improving transit, bicycle facilities, and create incentives for people to avoid driving.
 Measure TR5: Improve curbside management: Improve curbside management, including updating the municipal code to require active loading only, prohibit double parking, define locations for additional loading zones, and design loading zone signage.  Measure TR6: Require transportation system management for new construction: Draft and implement a Transportation System Management Plan (TSMP) ordinance for new construction to allow the Town to shift travel behavior away from singleoccupancy vehicles. Ensure telecommuting is an optional trip reduction strategy.
 Measure TR7: Eliminate parking minimums for developments:

Remove parking minimums and establish parking maximums.

Section C Evaluation of Environmental Impacts 49 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Waste (WS)
 Measure WS1: Require residential and commercial organic waste collection consistent with SB 1383 requirements: Work with local waste haulers and other community partners to expand organic waste collection capacity. Pass an ordinance by 2022 requiring residential and commercial organics generators to subscribe to organics collection programs or alternatively report organics selfhauling and/or backhauling. Allow limited waivers and exemptions to generators for de minimis volumes and physical space constraints and maintain records for waivers/exemptions.  Measure WS2: Require edible food recovery consistent with SB 1383 requirements: Adopt an edible food recovery ordinance or similarly enforceable mechanism to ensure edible food generators, food recovery services, and food recovery organizations comply with requirements to increase recovery rates.

As discussed in the General Plan EIR, even with implementation of Mitigation Measure GHG-1 requiring community GHG reduction measures, the General Plan would result in emissions that exceed GHG efficiency thresholds and, therefore, state targets. As a result, impacts related to the generation of GHG emissions under the General Plan would be significant and unavoidable with mitigation incorporated (p. 4.8-31).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would generate GHG emissions.

Development associated with the Housing Element Update is part of the significant and unavoidable cumulative GHG emissions impacts associated with the General Plan and, therefore, development associated with the Housing Element Update, which is consistent with the growth projections evaluated in the General Plan EIR, would result in significant and unavoidable GHG emissions impacts even after implementation of Mitigation Measure GHG-1.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts related to GHG emissions.
b. Development under the General Plan would result in additional GHG emissions due to construction, an increase in mobile sources, more building space requiring more heating and cooling, etc. Section 4.8, Greenhouse Gas Emissions, of the General Plan EIR evaluated the General Plan’s consistency with the California Air Resources Board 2017 Scoping Plan (which provides the framework for achieving the 2030 target related to GHG emissions), Senate Bill 32 (which codifies the statewide goal of reducing GHG emissions to 1990 levels by 2020), and Executive Order B-55-18 (an executive order mandating the state to achieve carbon neutrality by no later than 2045). The General Plan EIR determined that the General Plan would conflict with the reduction targets of all three state plans identified above and would contribute to climate change. Therefore, implementation of Mitigation Measure GHG-1 would be required.

Section C Evaluation of Environmental Impacts 50 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
However, even with implementation of Mitigation Measure GHG-1, total and per capita Los Gatos GHG emissions would not be reduced to a level below state targets by 2030 and 2040. Additionally, the General Plan was determined to impede “substantial progress” toward meeting the California Air Resources Board 2017 Scoping Plan, Senate Bill 32, and Executive Order B-55-18 targets. Therefore, impacts would be significant and unavoidable even with mitigation incorporated (p. 4.8-32).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and has been evaluated by the General Plan EIR. Development associated with the Housing Element Update is part of the significant and unavoidable cumulative GHG emissions impacts associated with the General Plan and, therefore, development associated with the Housing Element Update, which is consistent with the growth projections evaluated in the General Plan EIR, would result in significant and unavoidable impacts related to consistency with applicable state plans, even after implementation of Mitigation Measure GHG-1.

The General Plan EIR adequately addressed the Housing Element Update’s potential to conflict with an applicable state plan related to GHG emissions and targets.

The Town adopted its Statement of Overriding Conditions on June 30, 2022 and determined that specific economic, legal, social, technological, mobility, or other considerations, make infeasible the mitigation measures or project alternatives identified in the General Plan Final EIR related to GHG emissions.

Section C Evaluation of Environmental Impacts 51 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

9. HAZARDS AND HAZARDOUS MATERIALS
Would the project:

Comments:
a. According to the General Plan EIR (Section 4.9, Hazards and Hazardous Materials), development facilitated by the General Plan would result in approximately 156,400 square feet of manufacturing development, which would increase the overall routine transport, use, and disposal of hazardous materials in Los Gatos.

Documentation of compliance with hazardous materials regulations codified in the California Code of Regulations titles 8, 22, and 26 is required for all hazardous materials and hazardous waste transport. Individual contractors and property owners must comply with all applicable federal and state laws and regulations pertaining to the transport, use, Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
☐ ☐ ☐ ☒
b. Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
☐ ☐ ☒ ☐
c. Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
☐ ☐ ☐ ☒
d. Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code section 65962.5 and, as a result,
create a significant hazard to the public or the
environment?
☐ ☐ ☒ ☐
e. For a project located within an airport land-use plan or, where such a plan has not been adopted, within
two miles of a public airport or a public-use airport,
result in a safety hazard or excessive noise for people residing or working in the project area?
☐ ☐ ☐ ☒
f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
☐ ☐ ☐ ☒
g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?
☐ ☐ ☒ ☐

Section C Evaluation of Environmental Impacts 52 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
disposal, handling, and storage of hazardous waste, including but not limited to, Title 49 of the Code of Federal Regulations. Adherence to applicable regulations and laws would reduce accidental release of hazardous materials during transport. In addition to mandatory adherence to laws and regulations, the General Plan contains goals and policies that would apply to routine transport, use, or disposal of hazardous materials such as those policies associated with General Plan Goals HAZ-7 and MOB-15 (Town of Los Gatos 2021, p. 4.9-17).

The overall quantity of hazardous materials used and requiring disposal in Los Gatos could incrementally increase as a result of development under the General Plan.

However, all new development would be required to comply with existing applicable regulations, programs, and standards as well as implementation of applicable General Plan goals and policies, which would minimize risks from routine transport, use, and disposal of hazardous materials and result in less than significant impacts (p. 4.9-19).

Development associated with the Housing Element Update involves only residential development and would not involve industrial or commercial development that more commonly involve the storing, using, transporting and/or disposing of hazardous materials. Therefore, the Housing Element Update would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous material.

The General Plan EIR adequately addressed the Housing Element Update’s potential impact related to the routine transport, use, or disposal of hazardous materials. b. The General Plan facilitates and encourages infill development throughout the Town, which could require the demolition of existing uses to facilitate future development. If such buildings identified for demolition were constructed prior to the 1970s. Section 4.9, Hazards and Hazardous Materials, of the General Plan EIR states that lead and asbestos could be present and released into the environment during demolition activities. The California Department of Public Health, the California Department of Industrial Relations, Division of Occupational Safety and Health Administration, and the Bay Area Air Quality Management District regulate lead and asbestos abatement necessary for construction and redevelopment projects. California Code of Regulations Section 1532.1 requires testing, monitoring, containment, and disposal of lead‐based materials such that exposure levels do not exceed California Department of Industrial Relations, Division of Occupational Safety and Health Administration standards. The control of asbestos during demolition or renovation of buildings is regulated under the Federal Clean Air Act. Compliance with the mandatory requirements of California Code of Regulations and the Federal Clean Air Act would reduce the potential hazards and risks associated with release of lead and asbestos. Oversight by the appropriate agencies would ensure that impacts related to the potential accident conditions involving the release of hazardous materials into the environment would be less than significant (Town of Los Gatos 2021, p. 4.9-19).

Section C Evaluation of Environmental Impacts 53 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development associated with the Housing Element Update would involve the demolition of existing structures as it focuses on infill development and redevelopment. It is unknown at this time if any of the existing structures were constructed prior to the 1970s and whether or not hazardous materials are present on each site. As individual development associated with the Housing Element Update are proposed, a Phase I Environmental Site Assessment would be required for new development on proposed land that may be contaminated with hazardous materials or waste, pursuant to General Plan Policy HAZ-7.2. Should lead and asbestos be detected on any one of the sites associated with the Housing Element Update, the development would be required to comply with the mandatory requirements of the California Code of Regulations and the Federal Clean Air Act to reduce the potential hazards and risks related to the release of lead and asbestos.

Development under the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR. Therefore, impacts related to the potential for accident conditions involving the release of hazardous materials into the environment would be less than significant.

The General Plan EIR adequately addressed the Housing Element Update’s potential impact related to the accidental release of hazardous materials into the environment. c. Schools are located throughout Los Gatos. The General Plan would facilitate various types of development throughout the Town of Los Gatos; residential and office uses do not typically emit hazardous materials, and it is not possible to know the quantity of hazardous materials proposed for use at the future commercial and industrial development sites. Although the quantities of hazardous material used at the future commercial and industrial development cannot be known, Section 4.9, Hazards and Hazardous Materials, of the General Plan EIR determines that this type of development could occur within one-quarter mile of existing public or private schools in Los Gatos.

However, development under the General Plan would be required to comply with the provisions of the California Fire Code adopted by the Town (Chapter 12, Article II) and the Santa Clara County Fire Department Certified Unified Program Agency requirements that comply with provisions set forth in the California Health and Safety Code, Division 20, Chapter 6.95, Articles 1 and 2. Impacts would be less than significant (Town of Los Gatos 2021, p. 4.9-20).

The Housing Element Update, which is consistent with the growth projections evaluated in the General Plan EIR, would result in development within one-quarter mile of existing schools. However, the Housing Element Update involves only residential development, which does not typically generate or emit hazardous materials. Therefore, the Housing Element Update would not result in hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts related to hazardous emissions within one-quarter mile of a school.

Section C Evaluation of Environmental Impacts 54 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
d. Existing sites in Los Gatos that may contain hazardous land uses or contamination from land uses that were on the sites previously generators of hazardous waste, such as gas stations, dry cleaners, and industrial uses. According to the General Plan EIR (Section

4.9, Hazards and Hazardous Materials), there are active or open sites containing or potentially containing hazardous materials contamination within the Town limits.

Development facilitated by the General Plan on these sites could expose construction workers and future occupants of the new uses to hazardous materials (p. 4.9-21). It is also possible that unknown underground storage tanks may be present within the Town; if one is uncovered or disturbed during construction activities, it would be removed under permit from the Santa Clara County Fire Department; tank removal activities could also pose health and safety risks.

Development at any one of these known sites would be subject to investigation, remediation, and cleanup under the supervision of the Regional Water Quality Control Board, the Santa Clara Valley Water District (Valley Water), or the California Department of Toxic Substances and Control before construction activities could begin. In addition, development would be required to comply with General Plan Goal HAZ-7 (reduce the potential for injuries, damage to property, economic and social displacement, and loss of life resulting from hazardous materials is eliminated) and its associated policies, reducing the potential for release of hazardous substances through inter-organization cooperation, site assessments, and hazardous material storage monitoring. Risks posed by underground storage tanks would be minimized by managing the tank according to existing standards contained in Division 20, Chapters 6.7 and 6.75 (Underground Storage Tank Program) of the California Health and Safety Code as enforced and monitored by the Environmental Programs Division. Compliance with existing state and local regulations, in addition to implementation of applicable General Plan policies, would reduce risks related to hazardous material sites to a less-than-significant level (Town of Los Gatos 2021, p. 4.9-22).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and would not occur on sites identified by the Town as active or open sites containing or potentially containing hazardous materials contamination. However, it is possible that unknown underground storage tanks may be present within those sites associated with the Housing Element Update. Disturbance or removal activities related to underground storage tanks could pose health and safety risks.

As previously stated, risks posed by underground storage tanks would be minimized by managing the tank according to existing standards contained in Division 20, Chapters 6.7 and 6.75 (Underground Storage Tank Program) of the California Health and Safety Code as enforced and monitored by the Environmental Programs Division. Implementation of applicable General Plan policies such as Policy HAZ-7.2, which requires a Phase I Site Assessment for new development proposed on land that may be contaminated with hazardous materials or waste, would reduce risks posed by the underground storage tanks.

Section C Evaluation of Environmental Impacts 55 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Compliance with existing state and local regulations, in addition to implementation of applicable General Plan policies, would reduce the Housing Element Update’s potential risks of disturbing unknown underground storage tanks during construction activities to a less-than-significant level.

The General Plan EIR adequately addresses the Housing Element Update’s potential impacts related to hazardous material sites.
e. According to the General Plan EIR (Section 4.9, Hazards and Hazardous Materials), there are no public or private airports within or adjacent to the Town and the Town of Los Gatos is entirely outside the area of influence for the airport (Town of Los Gatos 2021, p. 4.9-22). Therefore, development of the Housing Element Update would have no impact related to airports or their influence areas.

The General Plan EIR adequately addressed the Housing Element Update’s potential impact related to airports and airport land use plans.
f. Development facilitated by the General Plan would accommodate future population growth and would increase vehicle miles in the Town, which could lead to increased congestion during emergency evacuations. Section 4.9, Hazards and Hazardous Materials, of the General Plan EIR explains that the Town adopted an Emergency Operations Plan, which provides guidance on effective emergency response approaches, and the Santa Clara County Office of Emergency Services developed an Operational Area Hazard Mitigation Plan, which details target programs for improving emergency preparedness and response in cooperation with local jurisdictions, including the Town of Los Gatos. Additionally, the General Plan includes policies that address emergency response, all of which are designed to align with programs set forth in the Santa Clara County-wide Hazard Mitigation Plan.

Development under the General Plan would be required to implement all applicable General Plan policies and programs outlined in the local emergency plans associated with emergency planning and response. Implementation of which would result in less than significant impacts (Town of Los Gatos 2021, p. 4.9-23).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR. Individual development under the Housing Element Update would implement the programs of the local emergency response plans as well as applicable General Plan policies, as appropriate. Because development associated with the Housing Element Update would involve infill development and redevelopment of sites, it would not impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan.

The General Plan EIR adequately addressed the Housing Element Update’s potential interference with an adopted emergency response plan or evacuation plan.

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g. Development associated with the Housing Element Update would result in the exposure of people or structures to risks involving wildfires. Refer to Section 20.0, Wildfire, for the analysis of risk of exposure involving wildland fires.

Section C Evaluation of Environmental Impacts 57 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022

10. HYDROLOGY AND WATER QUALITY
Would the project:

Comments:
a. According to the General Plan EIR (Section 4.10, Hydrology and Water Quality), construction activities facilitated by the General Plan could include road improvements and realignments, installation and realignment of utilities, demolition of existing structures for replacement, new development, and the potential replacement and/or improvements of drainage facilities. Construction activity could result in the alteration of existing drainage patterns and soil erosion due to earth-moving activities. Disturbed soils Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade
surface or ground water quality?
☐ ☐ ☐ ☒
b. Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?
☐ ☐ ☒ ☐
c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
(1) Result in substantial erosion or siltation on- or offsite; ☐ ☐ ☒ ☐
(2) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding onor off-site; ☐ ☐ ☒ ☐
(3) Create or contribute runoff water that would exceed the capacity of existing or planned storm water
drainage systems or provide substantial additional
sources of polluted runoff; or
☐ ☐ ☒ ☐
(4) Impede or redirect flood flows? ☐ ☐ ☒ ☐
d. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
☐ ☐ ☐ ☒
e. Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
☐ ☐ ☒ ☐

Section C Evaluation of Environmental Impacts 58 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
would be susceptible to erosion from wind and rain, resulting in sediment transport via stormwater runoff from the construction sites, ultimately into collecting waterways contributing to the degradation of water quality.

Individual construction activities that disturb one or more acres would be subject to the National Pollutant Discharge Elimination System General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities, Order No. 2012-0006-DWQ (general permit). Permit conditions require development of a stormwater pollution prevention plan, which, among others, describes the site’s erosion and sediment control measures, runoff water quality monitoring. Compliance with the general permit is reinforced through the Town Municipal Code (Chapter 22), the Town’s Storm Drain Master Plan, and adherence to the San Francisco Bay Regional Water Quality Control Board’s Basin Plan; whose water quality objectives are incorporated into individual National Pollutant Discharge Elimination System permits (Town of Los Gatos 2021, p. 4.10-10). The Town is also required, as part of the general permit, to incorporate construction site storm water runoff control elements into a stormwater management program as a means to control polluted discharges.

Development associated with the General Plan would be required to implement appropriate best management practices as measures for post-construction stormwater and submit a maintenance plan or manufacturers maintenance guide for those measures as part of the Housing Element Update’s submittal. Compliance with the regulations and policies abovementioned would reduce the risk of water degradation within the Town from construction activities to a less-than-significant level (p. 4.10-13).

Long-term alternations to drainage patterns during operation of development under the General Plan would also occur. If uncontrolled, this could result in the addition of contaminants into the Town’s stormwater drainage system and ultimately untreated discharge into nearby waterways. To ensure compliance with the general permit’s requirements and conditions, the Town’s Municipal Code Chapter 22 outlines regulations related to stormwater management control that projects would be required to comply with. Compliance with the Town’s applicable Municipal Code sections would minimize erosion and siltation that could adversely affect water quality within the Town.

Development under the General Plan would also be required to comply with the applicable General Plan policies associated with Goal ENV-16 (protect and conserve watersheds and water quality) as well as General Plan Policy ENV-17.8, which encourages new development to implement low-impact development measures to limit the amount of impervious surfaces. Compliance with regional and local requirements listed previously, in addition to implementation of applicable General Plan goals and policies, would ensure that the impacts related to development under the General Plan and its effects to water quality during operation would remain less than significant.

Development associated with the Housing Element Update would result in the increase in impervious surfaces in the Town, which could result in sediment transport via stormwater runoff from the sites into collecting waterways contributing to the

Section C Evaluation of Environmental Impacts 59 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
degradation of water quality. However, the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, its potential to degrade water quality in the Town has been evaluated by the General Plan EIR.

Development associated with the Housing Element Update would be required to comply with the regulations and policies mentioned above related to construction and operational activities such as the general permit, the San Francisco Bay Regional Water Quality Control Board, and the Town’s Municipal Code sections related to water quality control.

The Housing Element Update would also be required to comply with applicable General Plan policies such as Policy ENV-16.1, which requires that all applicants demonstrate that new development would not contaminate surface water and/or groundwater; Policy ENV-16.5, which requires that the approval of a development adjacent to a designated creek includes a condition that the creek be dedicated to the Town in fee with a maintenance easement granted to Santa Clara Valley Water District; Policy ENV-16.7, which encourages the implementation of bioswales and other innovations so runoff from parking lots drain into landscaped areas and rainwater percolates into the ground; and Policy ENV-17.8, which encourages low-impact development measures to limit the amount of impervious surface in new development and to increase the retention, treatment, and infiltration of urban stormwater runoff. The Housing Element Update would also comply with General Plan PFS-3.1, which requires that CEQA review analysis for all development projects consisting of single and cumulative impacts on water drainage (runoff) and contamination (water quality) in all areas, but particularly in or adjacent to hillsides, riparian corridors, and important undeveloped watersheds.

Adherence to these regulations and standards, as well as the policies within the General Plan, would ensure that development associated with the Housing Element Update does not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality during construction and operation.

The General Plan EIR adequately addressed the Housing Element Update’s potential to violate water quality standards.
b. Water demand and services is addressed in Section 19.0, Utilities and Service Systems.

Nearly half of the water used in Santa Clara County is pumped from the Santa Clara and Llagas Subbasins, with some communities relying solely on groundwater. Local sources include natural groundwater and surface water supplies. The Santa Clara Valley Subbasin is the groundwater basin for the Town of Los Gatos.

Groundwater Supply. Development associated with the General Plan would increase the demand for water from the Santa Clara Valley Subbasin. However, as stated in the General Plan EIR (Section 4.10, Hydrology and Water Quality), growth in the Town of Los Gatos that would be facilitated by the General Plan has been incorporated into the 2015 Urban Water Management Plan and it was determined that the future water demand in Los Gatos is projected to be met by the current water supply. Therefore, projected growth under the General Plan would not result in a depletion of groundwater supplies in the Santa Clara Valley Subbasin (Town of Los Gatos 2021, p. 4.10-14).

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The Housing Element Update would comply with General Plan Policy PFS-1.2, which requires that all new home construction and remodeled homes comply with the BayFriendly Landscaping Guidelines in addition to the landscaping standards in the GreenPoint Rated Building Guidelines and Policy PFS-1.4, which requires that all new development install water-efficient irrigation management systems and devices, such as evapotranspiration or soil moisture-based irrigation controls. Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, its impacts on the Santa Clara Valley Subbasin were evaluated in the General Plan EIR. Therefore, the Housing Element Update would not substantially decrease groundwater supplies such that the Housing Element Update may impede sustainable groundwater management of the basin.

Groundwater Recharge. Development associated with the General Plan could potentially interfere with groundwater recharge; however, the General Plan contains goals and policies that would encourage groundwater infiltration and promote the use of recycled water and other conservation efforts. Implementation of General Plan Policy ENV-17.6, which encourages the Town to participate in the regulation of groundwater use to protect it as a natural resource and conserve it for potential use during extended drought, and those applicable policies under General Plan Goal PFS-4, minimize the amount of stormwater runoff, as well as protect and improve the water quality of runoff, would maximize groundwater infiltration and increase water use efficiency within the Town to the maximum extent practicable. The General Plan EIR concludes that the amount of new impervious surfaces from new development and redevelopment under the General Plan would be reduced through low impact development-related General Plan goals and policies and would not substantially interfere with groundwater recharge.

Therefore, the General Plan EIR determined that the development under the General Plan would result in less than significant impacts related to groundwater recharge (p. 4.10-14).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, its impacts on the Santa Clara Valley Subbasin were evaluated in the General Plan EIR. Consistent with the General Plan EIR conclusion, the amount of new impervious surfaces from new development and redevelopment under the Housing Element Update would be reduced through low impact development-related General Plan goals and policies. Therefore, the Housing Element Update would not interfere substantially with groundwater recharge such that the Housing Element Update may impede sustainable groundwater management of the basin.
2020 Urban Water Management Plan. Since certification of the General Plan EIR and adoption of the General Plan, the San Jose Water Company updated and adopted its 2020 Urban Water Management Plan. The 2020 Urban Water Management Plan concluded that San Jose Water Company anticipates adequate supplies to meet system demand, even during prolonged drought conditions, through 2045 (San Jose Water Company 2021, p. 7-11).

The Santa Clara Subbasin has not been identified by the California Department of Water Resources as being critically overdraft. San Jose Water Company also plans to continue following all state and federal drinking water requirements and will work with Santa Clara

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Valley Water District (Valley Water), the California Division of Drinking Water, other groundwater basin stakeholders, and the public to ensure that groundwater remains safe and a reliable source of supply (San Jose Water Company 2021, p. 6-5).

The General Plan EIR adequately addressed the Housing Element Update’s potential to deplete or interfere with groundwater supply and recharge. c. According to the General Plan EIR (Section 4.10, Hydrology and Water Quality), most of the Town is within the 500-year flood zone with a few portions, such as those areas west of State Route 17 and adjacent to creeks, in the 100-year flood zone. Development in these areas could be subject to flood hazard and/or could impede or redirect flood flows to adjacent areas. Development within these areas, as facilitated by the General Plan, are required to comply with applicable provisions of the Town Municipal Code, which would minimize the risk and exposure to flood hazards. Chapter 29, Article IX includes requirements and provisions for reducing losses from flooding and for construction in flood-prone areas. Development in flood-prone areas would also be required to obtain a development permit before constriction or development begins per Municipal Code Section 29.90.070. Compliance with applicable sections of the Town Municipal Code would ensure that new structures proposed under the General Plan would not impede or redirect flows within a 100-year flood hazard area. Development under the General Plan is also required to implement those applicable General Plan policies associated with General Plan Goal HAZ-3. As concluded in the General Plan EIR, implementation of these goals and policies and compliance with applicable laws and regulations of the Town’s Municipal Code, would reduce impacts such that risk of loss, injury or death involving flooding in the planning area is not exacerbated by the General Plan.

Therefore, impacts related to flooding and flood hazards would be less than significant (Town of Los Gatos 2021, p. 4.10-17).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and could result in development within flood-prone zones adjacent to the Los Gatos Creek. Development associated with the Housing Element Update is required to implement General Plan Policy HAZ-3.3, requiring site planning and building design to mitigate identified flood and inundation hazards; Policy HAZ-3.4, requiring new development and substantial improvements to meet federal standards when within Federal Emergency Management Agency designated 100-year flood zones in the Los Gatos area; and Policy HAZ-3.6, which requires major new development and redevelopment to provide mitigation to ensure that the cumulative rate of peak stormwater run-off is maintained at pre-development levels. The Housing Element Update’s impacts associated with flood hazard has already been evaluated in the General Plan EIR, but would require implementation of General Plan policies and compliance with applicable laws and regulations in order to ensure that risks of loss, injury, or death involving flooding would not be exacerbated by implementation of the Housing Element Update and would result in less than significant impacts.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts related to flooding and flood hazards.

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d. The Town of Los Gatos is not located in a tsunami or seiche zone. Therefore, development of the Housing Element Update would not risk release of pollutants due to tsunami or seiche inundation of the Town. As determined in the General Plan EIR (Section 4.10, Hydrology and Water Quality), there would be no impact related to flood flows or project inundation (Town of Los Gatos 2021, p. 4.10-18).

The General Plan EIR adequately addressed impacts related to the risk release of pollutants due to tsunami or seiche inundation as a result of the Housing Element Update.
e. Refer to the discussion under checklist question “a.” According to the General Plan EIR (Section 4.10, Hydrology and Water Quality ), development under the General Plan would comply with the general permit, the Town’s Storm Drain Master Plan, applicable General Plan policies, and adhere to the San Francisco Bay Regional Water Quality Control Board’s Basin Plan, whose water quality objectives are incorporated into individual permits authorized by the San Francisco Bay Regional Water Quality Control Board. Therefore, development facilitated by the Housing Element Update would not conflict with or obstruct implementation of a water quality control plan.

The Sustainable Groundwater Management Act lists the Valley Water as the exclusive groundwater management agency for Santa Clara County. The Sustainable Groundwater Management Act requires that groundwater management agencies prepare a groundwater sustainability plan or an alternative to achieve sustainability. Pursuant to the Sustainable Groundwater Management Act, the Valley Water prepared its 2016 Groundwater Management Plan for the Santa Clara and Llagas Subbains as an alternative. Since the preparation of the General Plan EIR, the Valley Water has prepared an updated evaluation of its approved alternatives (i.e., the 2016 Groundwater Management Plan) titled the 2021 Groundwater Management Plan for the Santa Clara and Llagas Subbains, which was adopted by its Board of Directors in November 2021. However, the General Plan EIR utilized the most recent documentation at that time, which was the 2016 Groundwater Management Plan.

As discussed under checklist question “b” above, growth in the Town facilitated by the General Plan would implement applicable General Plan policies and goals encouraging groundwater infiltration, promoting the use of recycled water, and other water conservation efforts to reduce the potential for depletion of groundwater resources resulting in less than significant impacts on the Santa Clara Subbasin. According to the General Plan EIR, compliance with the Sustainable Groundwater Management Act requirements and adherence to the applicable General Plan goals and policies would ensure that impacts from development under the General Plan related to obstruction of a sustainable groundwater management plan would be less than significant (p. 4.10-15).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and its impacts on the Santa Clara Subbasin, and subsequently on the 2016 Groundwater Management Plan, has already been evaluated in the General Plan EIR. The Housing Element Update would be required to

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comply with the Sustainable Groundwater Management Act requirements and adhere to the applicable General Plan goals and policies to ensure that impacts from development associated with the Housing Element Update related to obstruction of a sustainable groundwater management plan would be less than significant.

Since the certification of the General Plan EIR and adoption of the General Plan, the 2021 Groundwater Management Plan for the Santa Clara and Llagas Subbasins was adopted by the Valley Water. The projected demands in the Santa Clara and Llagas subbasins for the 2021 Groundwater Management Plan for the Santa Clara and Llagas Subbasins are based on data used to develop the Valley Water’s 2020 Urban Water Management Plan. Valley Water maintains diverse water supply sources to meet countywide demands, including local surface water and groundwater, imported water, and recycled water. The Valley Water developed a Water Shortage Contingency Plan as part of its 2020 Urban Water Management Plan to establish actions and procedures for managing water supplies and demands during water shortages due to droughts and other emergencies. As stated within the 2021 Groundwater Management Plan for the Santa Clara and Llagas Subbasins, Valley Water will be able to meet countywide demands through 2045 under normal, a single dry, and five consecutive dry year conditions. If a five-year drought were to occur in the next five years, Valley Water would employ a range of response actions, including water conservation and calling for short-term water use reduction (Santa Clara Valley Water District 2021, p. 4-21).

The General Plan EIR adequately addressed the Housing Element Update’s potential to conflict with a sustainable groundwater management plan.

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11. LAND USE AND PLANNING
Would the project:

Comments:
a. As discussed in the General Plan EIR (Section 4.11, Land Use and Planning), the Town has limited land available for new development; therefore, due to the built-out nature of the Town, the General Plan encourages strategic growth. The Town would see a higher percentage of change through redevelopment of lands that have development potential rather than on vacant land. Many of the General Plan’s Land Use Element goals are promoting growth through infill development, development variety, and a mix of uses within the Town (Town of Los Gatos 2021, p. 4.11-12). Compliance with the General Plan goals and policies would ensure that future development under the General Plan does not disrupt or divide established communities and impacts would be less than significant (Town of Los Gatos 2021, p. 4.11-14).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and, therefore, would be required to comply with General Plan’s goals that promote growth through infill development and development variety. Each site associated with the Housing Element Update involves infill development or the redevelopment of property with existing uses; the Housing Element Update does not involve the development of any sites that would physically divide an established community.

The General Plan EIR adequately addressed the Housing Element Update’s potential impacts on physically dividing an established community. b. Section 4.11, Land Use and Planning, of the General Plan EIR identifies three regionally and locally adopted land use plans that apply to development under the General Plan:

Plan Bay Area 2040 (ABAG 2017), Final 2017 Clean Air Plan (Bay Area Air Quality Management District 2017), and Los Gatos Sustainability Plan (Town of Los Gatos 2012).

Plan Bay Area 2040 is a long-range land use and transportation plan for the San Francisco Bay Area region that promotes healthy and safe communities by reducing impacts from air pollution, protecting open space and agriculture, and increasing active transportation.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Physically divide an established community? ☐ ☐ ☐ ☒
b. Cause any significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
☐ ☐ ☐ ☒

Section C Evaluation of Environmental Impacts 65 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The General Plan EIR provides a breakdown of the General Plan’s consistency against the Plan Bay Area 2040’s goals in relation to climate protection, adequate housing, health and safe communities, open space and agricultural preservation, equitable access economic vitality, and transportation system effectiveness (refer to Table 4.11-4 of the General Plan EIR). As discussed in the General Plan EIR, the General Plan would be consistent with the goals contained in the Plan Bay Area 2040 (Town of Los Gatos 2021, p. 4.11-18).

As discussed in Section 3.0, Air Quality, the General Plan (and, therefore, the Housing Element Update) would be consistent with the Final 2017 Clean Air Plan through implementation of the applicable goals and policies located within the Environmental and Sustainability Element and the Mobility Element.

The General Plan EIR provides a breakdown of the General Plan’s consistency with the Los Gatos Sustainability Plan’s sustainability measures associated with transportation, land use, energy, water, solid waste, and open space (refer to Table 4.6-5 of the General Plan).

The General Plan EIR also discusses consistency with the California Green Building Standards Code and Title 24 of the California Energy Code. As discussed in Section 6.0, Energy, the General Plan is consistent with the Los Gatos Sustainability Plan and the energy efficiency strategies contained therein as well as with Title 24 of the California Energy Code.

The Town also has two specific plans (Albright and North Forty) and four overlay zones (Affordable Housing, Landmark and Historic Preservation, Planned Development, and Public School), which are key implementation mechanisms for the General Plan and its provisions must be consistent with the General Plan. There are also eight community place districts throughout the Town that have been identified as having the capacity to accommodate additional mixed-use developments and have existing infrastructure necessary to suppose the land uses.

The two specific plans address existing and future development within the Town to ensure that any development would maintain the existing residential setting while continuing to meet the needs of its residents. The overlay zones ensure that development facilitated by the General Plan is consistent with the development goals of the Town and the goals found within the General Plan provide guidance on the use of overlay zones in the community.

Therefore, the General Plan does not conflict with any applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect and impacts would be less than significant (Town of Los Gatos 2021, p. 4.11-20).

Development associated with the Housing Element Update is consistent with the growth projections evaluated in the General Plan EIR and therefore, would also be consistent with all of the above-mentioned plans (i.e., Plan Bay Area 2040, Final 2017 Clean Air Plan, Los Gatos Sustainability Plan, the state’s Title 24 of the Energy Code, and the Town’s specific plans, overlay zones, and community place districts). Development associated