Los Gatos City Council
September 16, 2025

ITEM NO. 13.

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 41 | Page
Town of Los Gatos
SECTION 5: INFORMATION COLLECTION, ANALYSIS, AND

DISSEMINATION
A primary objective of the Town of Los Gatos EOC is the timely gathering of accurate, accessible, and consistent information during an emergency and sharing vetted intelligence to ensure coordinated timely emergency response and the continuity of government operations. Status boards and other technologies for tracking emergency activities will be utilized. All Town EOC sections must maintain and display current status information so that other sections can quickly comprehend what actions have been taken, what resources are available, and to track damage status across the Town. Situation reports create a common operating picture and will be used to inform the operational objectives, priorities and strategies.

To ensure effective intelligence flow, emergency response agencies at all levels must establish communications systems and protocols to organize, integrate, and coordinate intelligence among the responding agencies.
• The flow of situation reports among the levels of government should occur as follows:
• Field level reports disseminated to local EOCs
• The Town EOC provides a jurisdictional situation report to the OA EOC based on field reports; DOC reports; and EOC activities and intelligence

5.1 Information Collection and Management Tool
An Information Collection and Management Tool is used in EOCs to accomplish the objective of timely gathering of accurate, accessible, and consistent information during an emergency. Every emergency event is unique, as such the Information Collection and Management Tool should be tailored to fit the circumstances and needs demanded by individual incidents.

At a minimum, every Information Collection and Management Tool should include the following information elements:

Essential Element of Information (e.g. boundaries of the disaster area, access points to the disaster area, jurisdictional boundaries).

Specific Information Requirement in support of an Essential Element of Information (e.g. traffic control points, safe routes, special permits required to access the disaster area).

Proposed Method or Source that could be used to obtain the Specific Information Requirement (e.g. field operation reports, GIS, reconnaissance).

Responsible Element, Section, or Agency identifies the responsible party tasked with collecting the specified information (e.g. EOC Operations Section, EOC Plans Section).

Deliverable Product specifies the mechanism the Responsible Element, Section, or Agency utilizes to relay a particular Specific Information Requirement (e.g. ICS Form 209, EOC Action Plan, incident map).

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 42 | Page
Town of Los Gatos
Collection Suspense or Schedule defines the reporting frequency for each Specific Information Requirement (e.g. daily, hourly, status change).

Distribution Requirement identifies the position, personnel, agency, or organization receiving the most up-to-date information in accordance with the Collection Suspense or Schedule (e.g. all EOC Section Chiefs, the REOC).

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 43 | Page
Town of Los Gatos
SECTION 6: CRISIS COMMUNICATIONS AND PUBLIC

INFORMATION
Per NIMS, public information is coordinated and integrated across jurisdictions and functional agencies; among Federal, State, local, and tribal partners; and with private-sector entities and nongovernmental organizations. In order to effectively ensure timely and accurate public information and alert and warning messages are disseminated systems, structures, plans, policies, and equipment must be developed and identified to accomplish these tasks.

6.1 Joint Information System (JIS)
The Joint Information System (JIS) provides the mechanism to organize, integrate, and coordinate information to ensure timely, accurate, accessible, and consistent messaging across multiple jurisdictions and/or disciplines with nongovernmental organizations and the private sector. It includes the plans, protocols, procedures, and structures used to provide public information.

The JIS structure is used for ensuring that:
• Public Information Officer (PIO) functions are coordinated and integrated. • A structure and system for developing and delivering coordinated interagency messages is provided.
• Public information plans and strategies on behalf of the incident management leadership can be developed, recommended, and executed.
• Leadership is effectively advised on public affairs issues that could affect a response effort, and rumors and inaccurate information that could undermine public confidence are controlled and managed.

Federal, State, tribal, territorial, regional, or local Public Information Officers and established Joint Information Centers (JICs) are critical supporting elements of the JIS. A robust and competent Town JIS is integral to an effective and comprehensive Town incident management capability.

6.2 Joint Information Center (JIC)
The Joint Information Center (JIC) is:
• A central location that facilitates operation of the Joint Information System. • A location where personnel with public information responsibilities perform critical emergency information functions, crisis communications, and public affairs functions.

JICs may be established at various levels of government or at incident sites, or can be components of Multiagency Coordination (MAC) Systems (e.g., MAC Groups or EOCs). A single JIC location is preferable, but the system is flexible and adaptable enough to accommodate virtual or multiple JIC locations, as required.

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 44 | Page
Town of Los Gatos

6.3 EOC Communication Systems
The Town of Los Gatos EOC is equipped with multiple redundant communication modalities allowing the sharing of situational awareness, resource status, raw intelligence and data, and alert and warning. The communication capabilities are routinely reviewed and updated as technology advances. Current communication resources in the Town EOC include, but are not limited to:
• EOC information management system for internal coordination, status boards, ICS forms, and situation reporting (e.g., VEOCI)
• Land-line based phones
• Satellite phone
• Fax machine
• Silicon Valley Interoperability Radio Authority (SVIRA) ECOMM phone • Internet enabled computers
• Radio systems
o ARES/RACES amateur radio
o Public safety frequencies (i.e., law, fire, EMS)
Public Alerting and Notifications
During an emergency, the Town of Los Gatos is responsible for the dissemination of information to the public. Public Information Officers (PIOs) disseminate emergency instructions and critical information to affected audiences—including governments, media, and the public—to provide messages that are accessible to all sectors of the community. Several county departments, as well as, PIOs from cities/towns, special districts, PNP organizations, and private companies share in the responsibility for disseminating complete, coordinated, and correct information to the public.

The Town has various systems in place for disseminating warnings and emergency information to the public which are describe below:

ALERT SCC AlertSCC is the county’s public alert and notification system which has been made available for use to each of the 15 cities/towns within the county. AlertSCC uses the 9-1-1 database to deliver messages to the public via landline-based telephones. Additionally, the public can register through a web portal to directly receive AlertSCC alerts and notifications on cell phones and via email and SMS. Town of Los Gatos representatives have been trained and authorized to create and send public alerts and notifications. OES and County Communications staff are available 24/7 to assist the Town representatives in creating and sending public messages, as needed.

Emergency Alert System The Emergency Alert System (EAS) is a national public warning system that may be used by local authorities to deliver important emergency information to the public via local broadcast media. The county’s primary station is KCBS (740 AM) and KSJO (92.3 FM) serves as the county’s backup station. OES and County Communications have the credentials to access EAS and script emergency messages to inform the public of a threat, the steps to be taken by them, and where additional information can be obtained.

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 45 | Page
Town of Los Gatos
Integrated Public Alert and Warning System The Integrated Public Alert and Warning System (IPAWS) is an internet-based capability Federal, State, and local authorities can use to issue critical public alerts and notifications. County OES has been provided a federal credential and maintains it on behalf of local jurisdictions. That credential is provided to those city’s/jurisdictions/individuals who have completed the applicable County mandatory training to be accessed through the AlertSCC system. IPAWS delivers alerts simultaneously through multiple communications devices reaching as many people as possible to save lives and protect property. These communication pathways include EAS (described above) and Wireless Emergency Alerts (WEA). The WEA system is capable of delivering alerts and notifications to cell phones within a geographic area without the cell phone being registered with the local alerting system. Best practice is to have the local Public Safety Access Point (PSAP/Dispatch) be the primary point of contact for dissemination of time sensitive alert and warning messages.

6.4 Public Awareness and Education
The public’s response to any emergency is based on their understanding of the nature of the emergency, the potential hazards, the likely response of emergency services, and knowledge of what individuals and groups with or without access and functional needs, should do to increase their chances of survival and recovery. Individuals caring for the elderly, children, or pets also need an increased understanding of their specific situation as it pertains to disaster preparedness.

The Town makes emergency preparedness information available to the residents of Los Gatos through social media and the Town website. Further, the Town Manager’s Office will provide special emphasis on specific hazards throughout the calendar year, aiding in the disaster preparation and education of the communities within the Town.

The Town utilizes various pathways to distribute incident management information; promote disaster preparedness; and disseminate warnings, alerts, and notifications. For complete information, consult the Town of Los Gatos Crisis Communications Annex to this Emergency Operations Plan. It provides best practices for crafting effective alert and warning messages, choosing appropriate alerting channels and spokespeople, and providing public education to ensure people understand how to obtain, use, and respond to information from the Town. The Town Manager’s Office and Police Department utilize the following mediums for distributing incident management and preparedness information to the public and partnering stakeholders:

Town Sites:
• Town Website: www.losgatosca.gov/2026/Emergency-Preparedness • Town Facebook: www.facebook.com/losgatosca
• Town Instagram: www.instagram.com/townoflosgatos/
• Town X: https://x.com/TownLG
• Town LinkedIn: www.linkedin.com/company/town-of-los-gatos • Town Nextdoor: https://nextdoor.com/agency-detail/ca/los-gatos/town-of-los-gatos/ • Notify Me Distribution Lists: Sign up at www.LosGatosCA.gov/NotifyMe Los Gatos-Monte Sereno Police Department Social Media Pages:

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 46 | Page
Town of Los Gatos
• Facebook: https://www.facebook.com/LGMSPolice/
• Twitter: https://twitter.com/lgmspolice?lang=en
• YouTube: https://www.youtube.com/channel/UC_ovaYpCkfNEtSR2oHrBMZw

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 47 | Page
Town of Los Gatos
SECTION 7: ADMINISTRATION, FINANCE, AND LOGISTICS

7.1 Finance Considerations
To enhance the capability of the Town of Los Gatos to respond to incidents by providing financial support and coordination to the Town's incident management operations and coordinating the recovery of costs as allowed by Federal and State law, the financial priorities during incident management operations are:
• Preserve life, property, and the environment
• Provide continuity of financial support to the Town, and OA when appropriate • Cooperate with the other sections of the Town EOC
• Document the Town’s costs and recovery of those costs as allowable • Maintain a positive image for the Town in its dealings with the public The Finance/Administration function will operate under the following policies during a qualifying incident/event as the situation dictates:
• The Standardized Emergency Management System (SEMS) and the National Incident Management System (NIMS) will be followed
• All existing Town and departmental fiscal operating procedures will be adhered to unless modified by Town Council or the EOC Director
• For incident/events that render the accounting systems either inaccessible or unusable for any period of time, appropriate personnel will be on an operational period, as determined by the EOC Director. This may be a period of 12 hours.

The Finance/Administration function’s primary responsibility is to maintain to the greatest extent possible the financial systems necessary to keep the Town of Los Gatos functioning during an incident or crisis of any size or type. These systems include but are not limited to:
• Payroll
• Payments
• Revenue collection
• Claim processing
• Cost recovery documentation
The function also supervises the negotiation and administration of vendor and supply contracts and procedures in collaboration with the incident management procurement functions.

Cost Recovery Documentation Requirements
To ensure eligibility for state and federal reimbursement, the Town of Los Gatos will follow FEMA and Cal OES requirements for cost documentation during disaster response and recovery. Departments and Town personnel must track expenses using the following categories and forms, as appropriate:
• Labor: Timesheets or FEMA Force Account Labor Summary (Form 90-123) with employee name, title, hours worked, and fringe benefits.

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 48 | Page
Town of Los Gatos
• Equipment: Equipment usage logs or FEMA Form 90-127 documenting hours, operator, type/classification, and rates.
• Materials and Supplies: Itemized receipts or inventory lists showing unit price and quantity used. • Contracted Services: Executed contracts, invoices, and scope of work documentation. • Administrative Costs: Time and expense records for finance staff or other disaster-specific administrative work.
• Damage Assessment: Photos, maps, and field inspection notes documenting incident damage with estimated costs.

Cost records should be compiled daily during activation and submitted to the Finance Section for centralized tracking. Final documentation must be compiled within 30 days of demobilization for federal assistance submission.

The extent and complexity of the incident or crisis will determine the extent to which the Finance/Administration function will mobilize. For some incidents/events, only part of the section may need to be engaged. In larger more complex incidents the entire function will likely engage.

The Finance/Administration function acts in a support role in all incidents/events to ensure that all required records are preserved for future use and Cal OES and FEMA filing requirements through maintenance of proper and accurate documentation of all actions taken.

To carry out its responsibilities, the Finance/Administration function will accomplish the following during a disaster/emergency:

For incidents/events where the Town of Los Gatos’ computer systems and bank are accessible and usable:
• Notify the other parts of the incident management organization and Town departments that incident management accounting procedures will be initiated and used for the event • Determine (in collaboration with technical staff) the extent to which the county's computer systems are accessible and/or usable
• Determine if the Town's banking institutions can continue handling financial transactions • Inform the incident management organization and Town departments that the payroll and payments processing will be handled on a "business-as-usual" basis except that incident management accounting procedures will be used for incident/event-related costs • Disseminate information about the incident management accounting procedures to other sections and departments as necessary
• Upon proclamation or declaration of a disaster by the State and/or Federal Governments, coordinate to initiate the recovery process of the Town’s costs • Coordinate with the other sections and departments on the collection and documentation of costs pertaining to the incident/event
• Coordinate with the State and Federal disaster assistance agencies for the required inspections, documentation, audits, and other necessary work in order to recover costs For incidents/events where the Town’s computer systems and/or banking institutions are either inaccessible or unusable

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 49 | Page
Town of Los Gatos
• Notify the other parts of the incident management organization and Town departments that incident management accounting procedures will be initiated and used for the event • Determine (in collaboration with technical staff) the extent to which the Town’s computer systems are accessible and/or usable
• Determine if the Town's banking institutions can continue handling financial transactions • Inform the incident management organization and Town departments that payroll and payments will be on hold for a short time and that processing will continue on a normal basis as of a specified date
• Activate other Finance/Administration functions as necessary • Maintain, as best possible, the financial continuity of the Town (payroll, payments and revenue collection)
• Disseminate information about the incident management accounting procedures to other sections and departments as necessary
• Upon proclamation or declaration of a disaster by the State and/or Federal Governments, coordinate with those agencies to initiate the recovery process of the Town costs • Coordinate with the other sections and departments on the collection and documentation of costs pertaining to the incident/event
• Coordinate with the State and Federal disaster assistance agencies for the required inspections, documentation, audits, and other necessary work in order to recover costs

7.2 Mutual Aid
The foundation of California's emergency planning and
response is a statewide mutual aid system which is designed to ensure adequate resources, facilities and other support is provided to jurisdictions whenever their own resources prove to be inadequate to cope with a given situation. The basis for the system is the California Disaster and Civil Defense Master Mutual Aid Agreement (MMAA).

The MMAA was developed in 1950 and has been adopted by
the state, all 58 counties, and most incorporated cities in the state. The agreement creates a formal structure wherein each jurisdiction retains control of its own facilities, personnel and resources, but may also receive or render assistance to other jurisdictions within the state. State government is obligated to provide available resources to assist local jurisdictions in emergencies. It is the responsibility of the local jurisdiction to negotiate, coordinate, and prepare mutual-aid agreements.

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 50 | Page
Town of Los Gatos
Mutual-aid agreements exist for:
• Law Enforcement
• Fire Services
• Emergency Medical Services
• Emergency Management
• Public Utilities
• Building Inspectors
• Coroner
• Transit Operators
Mutual Aid Systems
A statewide mutual-aid system, operating within the framework of the MMAA allows for the progressive mobilization of resources to and from emergency response agencies, local governments, OAs, and state regions with the intent to provide requesting agencies with adequate resources. Emergency mutual-aid response and recovery activities are generally conducted at the request and under the direction of the affected local government.

The statewide mutual-aid system includes several discipline-specific mutual aid systems, such as fire rescue and law. The adoption of SEMS/NIMS does not alter existing mutual-aid systems. These systems work through local government, OAs; regional and state levels consistent with SEMS/NIMS guidelines.

Fire agencies in Santa Clara County have signed onto a countywide mutual-aid agreement to ensure that firefighting resources and personnel will be available to combat wildland/urban interface fires. If these resources are not enough to meet the threat, fire resources from throughout the state can be requested under the MMAA. Requested mutual aid resources will be provided and utilized in accordance with the MMAA. During a proclaimed emergency, mutual aid will be coordinated at the local government, OA, or mutual aid regional level. The Town of Los Gatos must make mutual aid requests through the OA EOC for resources not covered under the MMAA.

During and following an incident, the coordination of resources is critical when there are multiple request for similar resource or when resources are scare. It is anticipated that, at the County level, Mutual Aid MAC Group will be established to coordinate mutual aid resources. The 2013 California Statewide MACS Guide provides the architecture to support coordination for incident prioritization, scarce resource allocation, communications systems integration, and information coordination.

Volunteer and Private Sector Agencies in Mutual Aid
Volunteer and private sector agencies may participate in the mutual aid system along with governmental agencies. For example, the disaster medical mutual aid system relies heavily on private sector involvement for medical/health resources. Some volunteer agencies such as the American Red Cross, Salvation Army, and others are an essential element of the statewide emergency response to meet the needs of disaster victims. Volunteer agencies mobilize volunteers and other resources through their own systems. They

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 51 | Page
Town of Los Gatos
may identify resource needs that are not met within their own systems that would be requested through the mutual aid system. Volunteer agencies with extensive involvement in the emergency response should be represented in the Town EOC.

Some private sector agencies have established mutual-aid arrangements to assist other private sector agencies within their functional area. For example, electric and gas utilities have mutual aid agreements within their industry and established procedures for coordinating with a governmental EOC. In some functional areas, services are provided by a mix of special district, municipal, and private sector agencies.

Mutual aid arrangements may include both governmental and private sector agencies. Liaison should be established between an activated EOC and private sector agencies involved in a response. Where there is a need for extensive coordination and information exchange, private sector agencies should be represented in an activated EOC at the appropriate SEMS level.

Special Mutual Aid Considerations For Terrorism Incidents Terrorism incidents require response by law enforcement at many levels and require crime scene management. As such, the information flow, command structure, and mutual aid processes can be different from those in the management of other emergency situations.

A terrorist activity emergency has its own unique threat and crisis characteristics and must be dealt with in accordance to its magnitude and with an appropriate level of response. Plans and procedures have been created, exercised and revised for both the most likely and worst-case scenarios.

Mutual Aid Authorities, Plans, and Guidance Documents
Mutual-aid assistance may be provided to Town departments or response organizations operating in the Town under one or more of the following authorities:
• California Master Mutual Aid Agreement (MMAA)
• California Law Enforcement Mutual Aid Plan
• California Fire Service and Rescue Mutual Aid Plan
• California Medical Mutual Aid Plan
• Emergency Managers Mutual Aid Plan
• San Francisco Bay Area Transit Operators Mutual Aid Agreement • Santa Clara County Law Enforcement Mutual Aid Protocol • California Statewide Multi-Agency Coordination System Guide

7.3 Resource Management
It is state policy that resource requests for emergency response and disaster repair and restoration be entered into by the lowest level of government. When Town resources are exhausted and additional resources are required, resource requests will follow an established process for ordering, tracking, mobilizing, and demobilizing.

Maintenance of resources is important throughout all aspects of resource management. Maintenance prior to deployment ensures their availability and capability. Maintenance during the deployment phase

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 52 | Page
Town of Los Gatos
ensures continued capabilities (e.g., ensuring adequate fuel supplies during use). Post-operational inspection and maintenance ensures future availability.

Integration of Mutual Aid Resources
In order to receive County, State, and federal resources, coordination needs to be done through the Los Gatos EOC, and field level command structures. The Logistics Section will be in charge of tracking requests for equipment, resources, and manpower under existing mutual aid protocols. The requesting agencies are responsible to report to OA EOC the number and status of resources deployed on a mission on a daily basis. Resources requested through the Town EOC will be done following the prescribed county resource requesting process below:

Resource typing of equipment will be handled by individual disciplines—law, fire, EMS, public works, and others—under the guidance issued by Cal OES regarding NIMS implementation.

Resource Tracking Procedures
The Town will implement NIMS-compliant resource tracking protocols for all major incidents. The following procedures will be used during EOC activation:
• Resource Typing: All requested or deployed resources will be typed using FEMA and Cal OES guidelines.
• Tracking Tools:
o ICS 211: Check-In List (for personnel and equipment)
o ICS 215A: Incident Action Plan Safety Analysis (risk-based assignments) o ICS 221: Demobilization Check-Out
• Logistics Section Responsibilities:
o Maintain an active inventory of deployed resources
o Assign tracking numbers for mutual aid assets
o Ensure accountability for return, demobilization, or replacement

ITEM NO. 13.

TOWN OF LOS GATOS
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Town of Los Gatos
• Systems Used: Resource status will be recorded in the current EOC System (VEOCI, Excel tracking tool, or another system). If systems are down, hard copy ICS forms will be used.

Resources provided under mutual aid will be coordinated through the Operational Area EOC as

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 54 | Page
Town of Los Gatos
SECTION 8: PLAN DEVELOPMENT AND MAINTENANCE

8.1 Plan Maintenance
The Town Manager’s Office will maintain this plan and record administrative updates, such as changes to references, terminology, contact information, and procedural clarifications, in the official Plan Revision Log. Major revisions will be brought forward to the Town Council for review and adoption.

8.2 Plan Concurrence
All departments, divisions, and supporting organizations identified in this Emergency Operations Plan are expected to review and acknowledge their assigned responsibilities. By receiving and reviewing this Plan, these entities concur with their roles and commit to integrating EOP guidance into their emergency procedures, training, and response activities. Concurrence with this Plan affirms a shared responsibility for coordinated preparedness and response across the Town of Los Gatos.

8.3 Plan Training and Exercise
Exercise Program Requirements
The Town of Los Gatos will maintain an regular exercise program aligned with the Homeland Security Exercise and Evaluation Program (HSEEP) to test and evaluate emergency response capabilities. • At least one interagency or EOC-level exercise every one or two years is recommended under California SEMS guidance and federal preparedness best practices. This may be a functional or full-scale exercise involving the Emergency Operations Center or similar multi-agency coordination.
• Acceptable substitutes for an exercise may include a real-world EOC activation, provided:
o The activation involves coordination of two or more Town departments or agencies o The Town completes an After Action Report (AAR) within 60 days o An Improvement Plan (IP) is developed within 90 days
Other recommended activities include:
• Semi-annual tabletop exercises for key EOC sections
• Quarterly training or drills focused on priority emergency management functions, such as alert and warning, communications, shelter coordination, or other core EOC capabilities. These exercises support readiness and provide an opportunity to validate plans, training, and procedures. Documentation of all exercises and improvement efforts will be retained by the Town Manager’s Office.

Below is a list of the different progressive exercise types:

Seminars: generally orient participants to, or provide an overview of, authorities, strategies, plans, policies, procedures, protocols, resources, concepts, and ideas. As a discussion-based exercise, seminars

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 55 | Page
Town of Los Gatos
can be valuable for entities that are developing or making major changes to existing plans or procedures.

Seminars can be similarly helpful when attempting to assess or gain awareness of the capabilities of interagency or inter-jurisdictional operations.

Workshop: Although similar to seminars, workshops differ in two important aspects: participant interaction is increased, and the focus is placed on achieving or building a product. Effective workshops entail the broadest attendance by relevant stakeholders. Products produced from a workshop can include new standard operating procedures (SOPs), emergency operations plans, continuity of operations plans, or mutual aid agreements. To be effective, workshops should have clearly defined objectives, products, or goals, and should focus on a specific issue.

Tabletop Exercise: A tabletop exercise (TTX) is intended to generate discussion of various issues regarding a hypothetical, simulated emergency. TTXs can be used to enhance general awareness, validate plans and procedures, rehearse concepts, and/or assess the types of systems needed to guide the prevention of, protection from, mitigation of, response to, and recovery from a defined incident.

Generally, TTXs are aimed at facilitating conceptual understanding, identifying strengths and areas for improvement, and/or achieving changes in perceptions.

During a TTX, participants are encouraged to discuss issues in depth, collaboratively examining areas of concern and solving problems. The effectiveness of a TTX is derived from the energetic involvement of participants and their assessment of recommended revisions to current policies, procedures, and plans.

TTXs can range from basic to complex. In a basic TTX (such as a facilitated discussion), the scenario is presented and remains constant—it describes an emergency and brings discussion participants up to the simulated present time. Participants apply their knowledge and skills to a list of problems presented by the facilitator; problems are discussed as a group; and resolution is reached and documented for later analysis.

In a more advanced TTX, play advances as participants receive pre-scripted messages that alter the original scenario. A facilitator usually introduces problems one at a time in the form of a written message, simulated telephone call, videotape, or other means. Participants discuss the issues raised by each problem, referencing established authorities, plans, and procedures for guidance. Participant decisions are incorporated as the scenario continues to unfold.

During a TTX, all participants should be encouraged to contribute to the discussion and be reminded that they are making decisions in a no-fault environment. Effective TTX facilitation is critical to keeping participants focused on exercise objectives and associated capability targets.

Games: A game is a simulation of operations that often involves two or more teams, usually in a competitive environment, using rules, data, and procedures designed to depict an actual or hypothetical situation. Games explore the consequences of player decisions and actions. They are useful tools for validating plans and procedures or evaluating resource requirements.

During game play, decision-making may be either slow and deliberate or rapid and more stressful, depending on the exercise design and objectives. The open, decision-based format of a game can incorporate “what if” questions that expand exercise benefits. Depending on the game’s design, the

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 56 | Page
Town of Los Gatos
consequences of player actions can be either pre-scripted or decided dynamically. Identifying critical decision-making points is a major factor in the success of evaluating a game.

Drill: A drill is a coordinated, supervised activity usually employed to validate a specific function or capability in a single agency or organization. Drills are commonly used to provide training on new equipment, validate procedures, or practice and maintain current skills. For example, drills may be appropriate for establishing a community-designated disaster receiving center or shelter. Drills can also be used to determine if plans can be executed as designed, to assess whether more training is required, or to reinforce best practices. A drill is useful as a stand-alone tool, but a series of drills can be used to prepare several organizations to collaborate in an FSE.

For every drill, clearly defined plans, procedures, and protocols need to be in place. Personnel need to be familiar with those plans and trained in the processes and procedures to be drilled.

Functional Exercise: Functional Exercises (FEs) are designed to validate and evaluate capabilities, multiple functions and/or sub-functions, or interdependent groups of functions. FEs are typically focused on exercising plans, policies, procedures, and staff members involved in management, direction, command, and control functions. In FEs, events are projected through an exercise scenario with event updates that drive activity typically at the management level. An FE is conducted in a realistic, real-time environment; however, movement of personnel and equipment is usually simulated.

FE controllers typically use a Master Scenario Events List (MSEL) to ensure participant activity remains within predefined boundaries and ensure exercise objectives are accomplished. Simulators in a Simulation Cell (SimCell) can inject scenario elements to simulate real events.

Full Scale Exercise: Full Scale Exercises (FSEs) are typically the most complex and resource-intensive type of exercise. They involve multiple agencies, organizations, and jurisdictions and validate many facets of preparedness. FSEs often include many participants operating under cooperative systems such as the ICS or Unified Command.

In an FSE, events are projected through an exercise scenario with event updates that drive activity at the operational level. FSEs are usually conducted in a real-time, stressful environment that is intended to mirror a real incident. Personnel and resources may be mobilized and deployed to the scene, where actions are performed as if a real incident had occurred. The FSE simulates reality by presenting complex and realistic problems that require critical thinking, rapid problem solving, and effective responses by trained personnel.

The level of support needed to conduct an FSE is greater than that needed for other types of exercises.

The exercise site for an FSE is usually large, and site logistics require close monitoring. Safety issues, particularly regarding the use of props and special effects, must be monitored. Throughout the duration of the exercise, many activities occur simultaneously.

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 57 | Page
Town of Los Gatos
SECTION 9: ACCESS AND FUNCTIONAL NEEDS

9.1 Purpose
This section ensures that all emergency planning, response, and recovery operations conducted by the Town of Los Gatos are inclusive of individuals with disabilities and others with access and functional needs (D/AFN).

9.2 Scope
This section applies to all Town departments, partners, and agencies involved in emergency management activities. It covers preparedness, response, recovery, and mitigation efforts, ensuring that D/AFN populations receive appropriate communications, transportation, sheltering, medical care, and other critical services during emergencies.

9.3 Situation Overview
• Approximately 20% of Los Gatos residents are 65 or older, and 30% speak a language other than English at home. Many residents may have disabilities, limited English proficiency, or other access and functional needs.
• Emergencies disproportionately impact D/AFN populations, who may require additional assistance with evacuation, communication, medical care, or sheltering.

9.4 Planning Assumptions
• D/AFN individuals reside and work throughout Los Gatos and may not be able to self-evacuate or access emergency information without assistance.
• Emergency shelters and programs must be accessible to all, including those with mobility, sensory, cognitive, mental health, or language needs.
• The Town will coordinate with community-based organizations, the Operational Area, and mutual aid partners to address D/AFN requirements.

9.5 Roles and Responsibilities
EOC Management Section
Management section is responsible for overall emergency policy and coordination. Elements include:
• Overall management and coordination of emergency response and recovery operations • Oversee and manage all sections in the EOC.
• Coordinate and liaison with appropriate federal, state, local government, private and volunteer entities
• Establish priorities and resolve demand conflicts
• The EOC Director ensures D/AFN considerations are integrated into all EOC functions and operations.
• The D/AFN Coordinator (or AFN Technical Specialist) is assigned under the Management Section as a Technical Specialist. This position advises the EOC Director and all Section Chiefs on D/AFN issues, ensuring compliance and best practices.

ITEM NO. 13.

TOWN OF LOS GATOS
TOWN MANAGER’S OFFICE 58 | Page
Town of Los Gatos
• Prepare and disseminate emergency public information, other essential information and data about impacts and damage
Operations Section
• Ensures that evacuation, sheltering, mass care, and field operations are accessible and inclusive. • Coordinates with the D/AFN Coordinator to address specific needs in real time.

Planning Section
• Tracks D/AFN-related resource requests, unmet needs, and maintains situational awareness of D/AFN issues.

Logistics Section
• Procures accessible transportation, communication aids, medical equipment, and supplies for D/AFN populations.

Finance/Administration Section
• Documents costs related to D/AFN accommodations for potential reimbursement.

D/AFN Coordinator
• Responsible for identifying and mitigating safety concerns for the D/AFN populations and maintaining awareness of potential Town liability during EOC response and recovery activities • Determine which D/AFN populations are impacted.
• Provide advice and assistance with other Sections as they manage resources and activities. • Monitor and assist with message development/translation, as needed, including alert and warning messages to ensure all D/AFN populations are reached.
• Participate in planning meetings and Incident Action Plan (IAP) development to ensure D/AFN considerations are operationalized.

9.6 Concept of Operations
Notification and Warning
• All public alerts and warnings will be provided in multiple formats (e.g., voice, text, visual, languages) to reach individuals with sensory or language barriers. • The Town will use AlertSCC and other accessible platforms to notify D/AFN populations.

Evacuation and Transportation
• Accessible transportation resource requests (e.g., wheelchair-accessible vehicles, paratransit) will be identified and coordinated through the Operational Area. • Assistance for individuals with mobility, cognitive, or medical needs will be prioritized.

Sheltering and Mass Care

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• General population shelters designated by the Town or coordinated through the OA will strive to meet ADA requirements or be modified to achieve accessibility upon activation. • Santa Clara County Functional Assessment Service Teams (FAST) may be deployed to assess and support D/AFN needs in shelters.
• Service animals, durable medical equipment, and personal assistance services will be accommodated.

Communication
• As needed, emergency public information will be provided in accessible formats, in accordance with CA SB160.
• The Public Information Officer (PIO) will coordinate with the D/AFN Coordinator to ensure messaging is accessible and culturally appropriate.

Medical and Health Services
• Coordination with public health and medical partners to ensure continuity of care for individuals with chronic conditions, medication needs, or life-sustaining equipment.

Recovery
• D/AFN considerations will continue through recovery, including accessible Disaster Recovery Centers and assistance programs.

9.7 Integration and Coordination
• The D/AFN Coordinator will work closely with all EOC sections, community-based organizations, and county/state partners.
• The Town will maintain updated resource lists for accessible transportation, sheltering, and communication aids.
• Regular training and exercises will include D/AFN scenarios and participation from DAFN-serving organizations.

Compliance
Los Gatos maintains compliance with California Government Code § 8593.3 by:
• Including D/AFN considerations in emergency alerting, evacuation, transportation, sheltering, and communications planning.
• Ensuring alerts and warnings utilize accessible communication methods. • Regularly integrating D/AFN considerations into Town trainings and exercises.

Partner Coordination
• Santa Clara County: Provides extensive public health, medical, and behavioral health support, as well as specialized AFN resources.

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• American Red Cross: Oversees and manages shelter accessibility and specialized shelter needs. • CADRE: Coordinates with voluntary and community-based organizations to provide localized D/AFN support.

9.8 EOC Checklist (D/AFN considerations)
• Confirm D/AFN Coordinator reporting within the Management Section and coordination across all EOC sections.
• Initiate immediate liaison with Santa Clara County, Red Cross, and CADRE. • Ensure accessible communication channels for public information dissemination. • Verify accessibility of evacuation, transportation, and sheltering resources. • Maintain documentation of all D/AFN-related activities, resource requests, and decisions.

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ABBREVIATIONS AND GLOSSARY

ACRONYMS
AAR/IP — After-Action Report/Improvement Plan
ADA — Americans with Disabilities Act
ADAAA — Americans with Disabilities Amendments Act
ADAAG — Americans with Disabilities Act Accessibility Guidelines AFN — Access and Functional Needs
ALERT — Automated Local Evaluation in Real Time
AlertSCC — Alert Santa Clara County
ARC — American Red Cross
ARES — Amateur Radio Emergency Services
ASC — Animal Services
BHS — Behavioral Health Services
CADRE — Collaborating Agencies’ Disaster Relief Effort
Cal FIRE — California Department of Forestry and Fire Protection Cal OES — California Governor’s Office of Emergency Services CBO — Community-Based Organization
CCO — Office of County Counsel
CDAA — California Disaster Assistance Act
CEO — Office of the County Executive
CERT — Community Emergency Response Team
CHP — California Highway Patrol
ConOps — Concept of Operations
COOP — Continuity of Operations Plan
CRC — Community Resource Center
CWS — Child Welfare Services
DEH — Department of Environmental Health
D/AFN — Disabilities/Access and Functional Needs
DOC — Department Operations Center

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DPEC — Disaster Preparedness Executive Committee
DSW — Disaster Service Worker
EAS — Emergency Alert System
EF — Emergency Function
EMPG — Emergency Management Performance Grant
EOAC — Santa Clara County Emergency Operational Area Council EMS — Emergency Medical Services
EOC — Emergency Operations Center
EOP — Emergency Operations Plan
ESF — Emergency Support Function
FAST — Functional Assessment and Support Team
FBO — Faith-Based Organization
FCC — Federal Communications Commission
FE — Functional Exercise
FEMA — Federal Emergency Management Agency
FIN — Finance Agency
FSE — Full-Scale Exercise
FSP — Food Safety Program
GIS — Geographic Information System
HSEEP — Homeland Security Exercise and Evaluation Program HSPD — Homeland Security Presidential Directive
IC — Incident Commander
ICP — Incident Command Post
ICS — Incident Command System
IHSS — In-Home Supportive Services
IPAWS — Integrated Public Alert and Warning System
JIC — Joint Information Center
JIS — Joint Information System
LAET — Large Animal Evacuation Team
MAC — Multi-Agency Coordination

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MAC Group — Multi-Agency Coordination Group
MACS — Multi-Agency Coordination System
MMAA — California Master Mutual Aid Agreement
MOA — Memorandum of Agreement
MOU — Memorandum of Understanding
MSEL — Master Scenario Events List
NGO — Non-Governmental Organization
NIMS — National Incident Management System
NRF — National Response Framework
NWS — National Weather Service
OA — Operational Area
OA EOC — Operational Area Emergency Operations Center
OAFN — Office of Access and Functional Needs (Cal OES)
OASIS — Operational Area Satellite Information System
OCC — Office of Cultural Competency
OE — Office of Education
OEM — Office of Emergency Management
OES — Office of Emergency Services
OIR — Office of Immigrant Relations
OPA — Office of Public Affairs
OSH — Office of Supportive Housing
PG&E — Pacific Gas and Electric Company
PHD — Public Health Department
PIO — Public Information Officer
PL — Public Law
PNP — Private Non-Profit
PPD — Presidential Policy Directive
RACES — Radio Amateur Civil Emergency Services
REOC — Regional Emergency Operations Center
SCCFD — Santa Clara County Fire Department

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SCVWD — Santa Clara Valley Water District
SEMS — Standardized Emergency Management System
SimCell — Simulation Cell
SMS — Short Message Service
SOC — State Operations Center
SOP — Standard Operating Procedures
SO — Sheriff’s Office
SSA — Social Services Agency
SVIRA — Silicon Valley Interoperability Radio Authority TDD/TTY — Telecommunication Device for the Deaf/Teletypewriter TSS — Technology Services and Solutions
TTX — Tabletop Exercise
VOAD — Voluntary Organizations Active in Disasters
VTA — Santa Clara Valley Transportation Authority
WEA — Wireless Emergency Alerts

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GLOSSARY
Accessible — A facility is accessible if it has the legally required features and/or qualities that ensure entrance, participation, and usability of places, programs, services, and activities by individuals with a wide variety of disabilities.

Access and Functional Needs (AFN) Population — Individuals who have developmental or intellectual disabilities; physical disabilities; chronic conditions or injuries; limited English proficiency; or who are non-English speaking, older adults, children, people living in institutionalized settings; those who are low income, homeless, or transportation disadvantaged (including those dependent on public transit); or those who are pregnant.

Affected Population — Persons who have been displaced, injured, or suffered some other loss due to an incident, event, or disaster.

American Red Cross (ARC/Red Cross) — A humanitarian organization, led by volunteers, that provides relief to victims of disasters and helps people prevent, prepare for, and respond to emergencies.

Americans with Disabilities Act (ADA) — Prohibits discrimination against people with disabilities in employment, transportation, public accommodation, communications, and governmental activities; also establishes requirements for telecommunications relay services.

Annex — A functional, support, hazard-, or incident-specific supplement to a basic emergency plan.

Appendix — An attachment to an emergency plan that provides referenced information, such as forms, SOPs, or guidance materials.

Catastrophe — A cascading set of human-caused or influenced events whose adverse consequences may be irreversible. A catastrophe may be caused by a disaster, or cause one, but is distinct from an “emergency” or “state of emergency.” Civil Unrest — A disruption of the social order such as a strike, protest, riot, or rebellion, which may be non-violent or violent.

Community-Based Organization (CBO) — Non-profit organizations operating within a single community; may be small and informal or formally incorporated.

Crisis — A phenomenon, event, or active threat that poses inevitable harm to life, property, environment, organizational performance, reputation, or way of life, requiring urgent intervention.

Dam Failure — Partial or complete collapse of a dam causing downstream flooding.

Disability and Access and Functional Needs (D/AFN) — Individuals with disabilities and/or AFN who may require additional assistance before, during, and after an incident (includes physical, sensory, cognitive, and intellectual disabilities; older adults; children; people with limited English proficiency; and those with limited access to transport, medical care, or services).

Disaster — Any natural event (e.g., hurricane, tornado, earthquake, wildfire, flood) or other emergency of such severity as to warrant federal disaster assistance.

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Disaster Service Worker (DSW) — A California program providing workers’ compensation benefits to government employees and affiliated volunteers performing authorized disaster activities.

Emergency — An incident or crisis that threatens safety or property and exceeds local response resources/capacity.

Emergency Medical Services (EMS) — Out-of-hospital acute medical care, patient transport, and related services.

Emergency Operations — Actions taken during an emergency to protect life and property, assist affected people, and restore essential services.

Emergency Operations Center (EOC) — The site from which officials coordinate, monitor, and support response activities.

Emergency Operations Plan (EOP) — Describes how people and property will be protected in disasters; identifies responsibilities, resources, and coordination methods.

Emergency Responder / First Responder — Individuals responsible for protecting life, property, environment, or evidence in the early stages of an incident (law enforcement, fire, EMS, etc.).

Emergency Response Providers — Federal, state, and local governmental and nongovernmental agencies involved in emergency response, including EMS and hospital emergency services.

Evacuation — Organized, supervised dispersal of people from dangerous areas.

Evacuee — Persons removed or self-relocating from areas threatened or affected by a disaster.

Federal Emergency Management Agency (FEMA) — The federal agency responsible for coordinating planning, preparedness, risk reduction, response, and recovery.

Flood — Temporary inundation of dry land by overflow of waters, rapid runoff, or mudflow.

Hazard — Any source of danger or element of risk to people or property.

Hazardous Material (HazMat) — Substances that pose a health, safety, or property risk when released in sufficient quantities.

Incident — An occurrence, natural or human-caused, requiring emergency action to protect life or property.

Incident Command System (ICS) — A standardized emergency management system that provides an integrated organizational structure for coordinated response.

Limited English Proficiency (LEP) — Persons whose primary language is not English and who have limited ability to read, speak, write, or understand it.

Local Government / Local Jurisdiction — Under SEMS, cities, counties, and special districts. For unincorporated areas, refers to the county.

Mass Care and Shelter — Feeding, housing, and providing essential services to affected populations (including during Public Safety Power Shutoffs).

Medical Baseline Program — Utility program offering discounted rates and advance PSPS notifications for customers with qualifying medical conditions.

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Mitigation — Actions taken before, during, or after an incident to lessen its impacts.

Mobilization — Procedures for activating, assembling, and deploying resources in response.

Multi-Agency Coordination (MAC) — Coordination across government and organizations to make joint emergency response decisions and allocate resources.

Multi-Jurisdiction Incident — An incident involving statutory responsibility across multiple jurisdictions, managed under Unified Command.

Mutual Aid — Voluntary provision of services and resources between jurisdictions when one’s own resources are insufficient.

Mutual Aid Agreement — A written agreement between agencies or jurisdictions to provide assistance upon request.

Natural Disaster — Any catastrophic natural event (hurricane, earthquake, wildfire, flood, etc.) causing significant damage or risk.

National Incident Management System (NIMS) — A national framework providing a standardized approach to incident management.

National Response Framework (NRF) — Federal framework outlining guiding principles, roles, and structures for coordinated national disaster response.

Non-Governmental Organization (NGO) — An entity not created by government but serving public purposes; may cooperate with governments (e.g., faith-based charities, Red Cross).

Office of Emergency Services (OES) — Lead agency under the California Emergency Services Act and Operational Area coordinator for Santa Clara County.

Operational Area (OA) — Encompasses all jurisdictions within a county; coordinates mutual aid and resource allocation between local and state.

Operational Area Emergency Operations Center (OA EOC) — Physical location for OA coordination of information and resources.

Person with a Disability — A person with a physical or mental impairment limiting major life activities, or a history/perception of such impairment.

Plan — A document describing the overall jurisdictional response to potential emergencies.

Preparedness — The ongoing process of building and improving capabilities through planning, training, exercises, and resources.

Recovery — Long-term activities to restore community systems and improve resilience after an incident.

Resources — Personnel, facilities, and equipment available for assignment.

Response — Immediate activities to address the direct effects of an incident, save lives, and protect property.

Shelter — Facilities providing safe, accessible, and secure temporary refuge (general, medical needs, or pet shelters).

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Situational Report (SitRep) — A status report summarizing the current situation for decisionmakers.

Special District — Local government unit (e.g., water district) with authority to own, operate, or maintain facilities/projects.

Standardized Emergency Management System (SEMS) — California’s system for managing emergency response across five levels: field, local, OA, regional, and state.

State of Emergency — A formal declaration of imminent or occurring incidents that exceed jurisdictional capacity.

Terrorism — Criminal violence against civilians or infrastructure to achieve political ends through fear and intimidation.

Threat — Intent or capability (communicated or inferred) to harm life, property, or the environment.

Volunteer Organizations Active in Disasters (VOAD) — Established disaster relief organizations, often faith-based, that provide housing repair, feeding, cleanup, supplies, childcare, animal sheltering, mental health support, and coordination (e.g., 2-1-1).

ITEM NO. 13.

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AUTHORITIES AND REFERENCES
Emergency response, like all governmental action, is based on legal authority. The Town of Los Gatos Emergency Operations Plan (EOP), follows federal, state, and local regulations and guidelines.

Additionally, best practices and lessons-learned have also been integrated in to this plan where possible; these were identified in the review of after-action reports from recent national large-scale disasters, incidents, and events (to include Stafford Act, non-Stafford Act, terrorist non-Stafford act, and off-shore non-Stafford act incidents and events).

Local
• Town of Los Gatos Municipal Code Chapter 8 - Civil Defense and Disaster • Town of Los Gatos 2040 General Plan, Chapter 9 – Hazards and Safety • Santa Clara County Office of Emergency Management Emergency Operations Plan, January 2022.

County of Santa Clara
• Santa Clara County Office of Emergency Management Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan, 2021
County
• County of Santa Clara Ordinance Code, Division A8: Civil Protection and Emergency Services • Santa Clara County Operational Area Disaster Response and Recovery Organization Interim Agreement 1995
State
• California Constitution (Article XI: Local Government) • California Coroners’ Mutual Aid Plan
• California Disaster and Civil Defense Master Mutual Aid Agreement • California Disaster Assistance Act (Title 19, Division 2, Chapter 6, California Code of Regulations) • California Education Code, §32282
• California Emergency Services Act (Gov. Code, Title 2, Division 1, Chapter 7) • California Fire Service and Rescue Emergency Mutual Aid Plan • California Government Code, §§11135, 8588.15, 8608
• California Health and Safety Code, §§101025 and 34070–34082 • California Law Enforcement Mutual Aid Plan
• Disaster Service Worker Program (Gov. Code, Title 1, Division 4, Chapter 8; Labor Code §3211.92) • Standardized Emergency Management System (SEMS) (Title 19, Division 2, Chapter 1, California Code of Regulations)
• Standardized Emergency Management System Guidelines
• State of California Emergency Plan
• Title 22, California Code of Regulations (CCR), §§72551 and 87223 • Title 24, California Code of Regulations (CCR), Accessibility Regulations Federal

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• ADA Amendments Act (ADAAA)
• ADA Checklist for Emergency Shelters
• Americans with Disabilities Act (ADA)
• Americans with Disabilities Act Accessibility Guidelines (ADAAG) • Americans with Disabilities Act of 1990 (PL 101-336), as amended • Civil Rights Act of 1964 (PL 88-352, Section VI)
• Communications Act of 1934, as amended
• Comprehensive Preparedness Guide (CPG-101): Developing and Maintaining Emergency Operations Plans (2021)
• Executive Order 13166 – Improving Access to Services for Persons with Limited English Proficiency • Executive Order 13347 – Individuals with Disabilities in Emergency Preparedness • Federal Civil Defense Act of 1950 (PL 920)
• Federal Communications Commission – Emergency Alert System Rules • H.R. 5441 (PL 109-295), Section 689: Individuals with Disabilities • Homeland Security Act of 2002 (PL 107-296)
• Homeland Security Presidential Directive-5 (HSPD-5): Management of Domestic Incidents • National Incident Management System (NIMS, 2017)
• National Response Framework (2019)
• Pets Evacuation and Transportation Standards Act of 2006 (PL 109-308) • Post-Katrina Emergency Management Reform Act of 2006 (PL 109-295) • Presidential Policy Directive 8 (PPD-8): National Preparedness • Rehabilitation Act of 1973 (PL 93-112, Section 504), as amended • Robert T. Stafford Disaster Relief and Emergency Assistance Act (PL 93-288), as amended • SARA Title III – Superfund Amendments and Reauthorization Act of 1986 • Section 508 of the Rehabilitation Act of 1973
• The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) Additional Sources
• https://maps.conservation.ca.gov/cgs/informationwarehouse/regulatorymaps/ • https://www.fire.ca.gov/incidents/
• U.S. Census Bureau, “Los Gatos town, California.”
https://data.census.gov/cedsci/profile?q=Los%20Gatos%20town,%20California&g=1600000US0 644112&table=DP05&tid=ACSDP5Y2017.DP05.

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APPENDEX

ITEM NO. 13.

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Appendix A: Local / State / Federal Crosswalk
The table below provides a crosswalk that approximates equivalent terms used by the Town of Los Gatos, the State of California, and the U.S. Federal Government.

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Appendix B: Emergency Operations Plan Document Descriptions

ITEM NO. 13.
1 of 2
Resolution 20 - September 16, 2025
ATTACHMENT 3
RESOLUTION 20 -xx

RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF LOS GATOS WHEREAS, the preservation of life and property is an inherent responsibility of local, state, and federal government; and
WHEREAS, while no plan can prevent death and destruction, good plans carried out by knowledgeable and well-trained personnel can and will minimize losses; and WHEREAS, the Town of Los Gatos has prepared an updated Emergency Operations Plan (EOP) to support effective and efficient allocation of resources for the protection of the community during times of emergency; and
WHEREAS, this plan establishes the emergency organization, assigns tasks, specifies policies and general procedures, and coordinates planning efforts of emergency staff and service elements utilizing the Standardized Emergency Management System (SEMS) and the National Incident Management System (NIMS); and
WHEREAS, this Emergency Operations Plan is an extension of the California Emergency Plan and will be reviewed and exercised periodically and revised as necessary to meet changing conditions.

NOW, THEREFORE, BE IT RESOLVED that the Town Council of the Town of Los Gatos hereby adopts the updated Emergency Operations Plan (September 2025) as the directive for establishing and operating the Town’s emergency management organization.

Section 2. The Town Clerk and Town Mayor shall certify to the adoption of this Resolution.

PASSED AND ADOPTED at a regular meeting of the Town Council of the Town of Los Gatos, California, held on the 16th day of September, 2025, by the following vote:

COUNCIL MEMBERS:

AYES:

NAYS:

ABSENT:

ABSTAIN:

SIGNED:

ITEM NO. 13.
2 of 2
Resolution 20 - September 16, 2025
ATTACHMENT 3
_______________________________

MAYOR OF THE TOWN OF LOS GATOS

LOS GATOS, CALIFORNIA
ATTEST:
___________________________________

TOWN CLERK OF THE TOWN OF LOS GATOS

LOS GATOS, CALIFORNIA

ITEM NO. 13.

PREPARED BY: Nicolle Burnham
Parks and Public Works Director
Reviewed by: Town Manager, Assistant Town Manager, Town Attorney, and Finance Director 110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6832 www.losgatosca.gov

TOWN OF LOS GATOS

COUNCIL AGENDA REPORT
MEETING DATE: 09/16/2025
ITEM NO: 14
DATE: September 11, 2025
TO: Mayor and Town Council
FROM: Chris Constantin, Town Manager
SUBJECT: Adopt a Resolution to Modify Town Council Policy 1-08: “Transportation Impact Policy” to Update the Project List, Modify Charges for Affordable Housing and Allow for Charges on Accessory Dwelling Units in Excess of 750 Square Feet
RECOMMENDATION: Adopt a Resolution (Attachment 1) to Modify Town Council Policy 1- 08: “Transportation Impact Policy” to Update the Project List, Modify Charges for Affordable Housing and Allow for Charges on Accessory Dwelling Units ADUs in Excess of 750 Square Feet.

FISCAL IMPACT:

The proposed changes will allow for the collection of Transportation Impact Fees on ADUs of 750 square feet or more, which may generate nominal additional revenue. Fees will be charged proportionately in relation to the ADU square footage to that of the primary dwelling unit.

Simultaneously, the Policy introduces a 50% reduction in Transportation Impact Fees for deedrestricted housing units serving extremely low- and very low-income households, which may result in a moderate reduction in total collected fees over time.

The net fiscal impact is expected to be minimal but directionally neutral to slightly positive, depending on development activity. These adjustments ensure ongoing policy alignment with State housing mandates while supporting Town infrastructure needs. Based on recent development trends over the past three years, the Town processes approximately 50 ADUs annually, several of which exceed 750 square feet. Applying Transportation Impact Fees to these units could result in nominal additional revenue of approximately $25,000 per year, depending on unit size and fee rates.

ITEM NO. 14.

PAGE 2 OF 3
SUBJECT: Adopt Resolution to Modify Town Council Policy 1-08 “Transportation Impact Policy”
DATE: September 11, 2025
STRATEGIC PRIORITY:

This item aligns with the strategic priority: Develop structure to ensure accountability of how funding resources move forward the Town’s core goals and priorities.

BACKGROUND:

On August 5, 1991, the Town of Los Gatos adopted Town Council Policy 1-08 to establish procedures for assessing Traffic Impact Mitigation Fees. The Policy has been revised periodically to reflect legislative changes and Town priorities, with updates in 2014, 2016, 2017, and most recently in 2021. These updates have addressed fee applicability, project eligibility, and alignment with state mandates such as SB 743 requiring Vehicle Miles Traveled (VMT) metrics.

This current update further aligns the Policy with current CEQA requirements, clarifies charges for Accessory Dwelling Units (ADUs), adjusts affordable housing incentives, and updates the project list.

In early 2024, the Town adopted an increase to its transportation impact fee, which was later rescinded due to concerns regarding the nexus study. Staff has reviewed the nexus study and is not recommending changes to the Town’s transportation impact fee until a Town-wide traffic model has been completed. At this time, Town staff is recommending only an update to the Town’s Transportation Impact Policy.

DISCUSSION:

The Town is proposing a policy-only update at this time to ensure consistency with recent changes in State law regarding Accessory Dwelling Units and to remove outdated projects from the Transportation Impact Policy’s project list. This interim update allows the Town to improve clarity and legal defensibility of the fee application while staff completes the Town-wide traffic model needed for a full nexus-based fee update. The Policy update does not include a change to the fee amount at this time.

Attachment 1 is a resolution to support the adoption of the changes, and the proposed Policy is attached to the resolution. Attachment 2 is a redline of the changes proposed to Town Policy 1-08. Specific proposed changes to the Policy include:

1. Allowing Transportation Impact Fees to be charged on Accessory Dwelling Units of 750 square feet or larger, as allowed per state law;

2. Reducing Transportation Impact Fees for deed restricted housing units, which may encourage production of affordable housing; and

3. Replacing the project list in Attachment 2.

ITEM NO. 14.

PAGE 3 OF 3
SUBJECT: Adopt Resolution to Modify Town Council Policy 1-08 “Transportation Impact Policy”
DATE: September 11, 2025
CONCLUSION:

The actions proposed herein will update the Town’s Transportation Impact Policy to better align with current state law and local development trends. While no changes to the Transportation Impact Fee amounts are being implemented at this time, the Policy revisions ensure clarity regarding eligibility for fee application and update the list of capital projects for which fees may be used. These actions pertain to Town Council Policy only and do not affect the Town Code.

Staff is not recommending changes to the Town’s Transportation Impact Fee until a Town-wide traffic model has been completed.

COORDINATION:

This agenda item was coordinated with the Town Manager, Town Attorney, and the Finance Director. If the Policy is adopted, staff will return to Council with a follow-up update to the Master Fee Schedule to reflect the new applicability of fees to ADUs larger than 750 square feet.

ENVIRONMENTAL ASSESSMENT:

In accordance with CEQA Guidelines Section 15378(b)(4), these actions are fiscal and administrative activities and do not constitute projects as defined in CEQA, and no further action is required.

Attachments:

1. Draft Resolution to Modify Town Council Policy 1-08, “Transportation Impact Policy”

2. Redline of Proposed Changes to Town Council Policy 1-08

ITEM NO. 14.
1 of 2
Resolution 2025- September 16, 2025
ATTACHMENT 1
RESOLUTION 2025-

RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF LOS GATOS ADOPTING AN

UPDATED TRAFFIC IMPACT POLICY
WHEREAS, Chapter 15, Article VI of the Town of Los Gatos Town Code provides for the establishment of Traffic Impact Mitigation Fees;
WHEREAS, on August 5, 1991, the Town of Los Gatos adopted Resolution 1991- 174 adopting a Traffic Impact Policy;
WHEREAS, the Policy has been updated from time to time including most recently on December 12, 2021;
WHEREAS, staff recommends updating the Policy to reduce the transportation impact fees charged for affordable housing and to provide that transportation impact fees will be collected for accessory dwelling units in excess of 750 square feet; and WHEREAS, Attachment 2, Project list, has not been modified since 2014 and many of the projects have been completed and therefore needs to be updated.

NOW, THEREFORE, BE IT RESOLVED, by the Town Council of the Town of Los Gatos that:

1. The Transportation Impact Policy attached as Exhibit A to this Resolution is hereby adopted and the previous Traffic Impact Policy is rescinded.

2. Adoption of this updated Policy is not a project subject to CEQA because it can be seen with certainty that it will not have a significant impact on the environment. (CEQA Guidelines Section 15378.)
PASSED AND ADOPTED at a regular meeting of the Town Council of the Town of Los Gatos, California, held on the 16th day of September, 2025, by the following vote:

COUNCIL MEMBERS:

AYES:

NAYS:

ABSENT:

ABSTAIN:

SIGNED:
_______________________________

ITEM NO. 14.
2 of 2
Resolution 2025- September 16, 2025
ATTACHMENT 1

MAYOR OF THE TOWN OF LOS GATOS

LOS GATOS, CALIFORNIA
DATE: __________________
ATTEST:
___________________________________

TOWN CLERK OF THE TOWN OF LOS GATOS

LOS GATOS, CALIFORNIA
DATE: __________________

ITEM NO. 14.

EXHIBIT A to ATTACHMENT 1

COUNCIL POLICY MANUAL
TITLE: Transportation Impact Policy POLICY NUMBER: 1-08 EFFECTIVE DATE: January 4, 1988 PAGES: 11
ENABLING ACTIONS: 1991-174; 2014-017,
2016-068; 2017-011
REVISED DATES: 8/5/91; 3/24/14; 12/6/16;
3/21/17; 12/07/2021; 09/16/2025
APPROVED:

PURPOSE
To provide guidance to Town staff and the development community in implementing the provisions of the Town Municipal Code, Chapter 15, Article VII, Traffic Impact Mitigation Fees, and evaluating and mitigating California Environmental Quality Act (CEQA) transportation impacts.

SCOPE
This Policy is applicable to all land use entitlements, land use projects, and transportation improvements Town-wide.

POLICY
I. GENERAL CONDITIONS AND APPLICABILITY

1. Projects that are determined by the Town to generate one or more new net Average Daily Trips (ADT) are subject to this Policy.

2. An Accessory Dwelling Unit (ADU) of less than 750 square feet shall be exempted from the requirements of Transportation Analysis and the Traffic Impact Fees. ADU’s of 750 square feet or greater shall be charged proportionately in relation to the square footage of the ADU to the square footage of the primary dwelling unit.

3. Attachment 1 - Transportation Analysis (TA) Guidelines establish a process to comprehensively and accurately analyze potential project effects (adverse and beneficial) on transportation facilities and services in the Town of Los Gatos and other jurisdictions. The TA Guidelines serve three primary purposes:

Small Town Service Community Stewardship Future Focus

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• Provide an evaluation for the California Environmental Quality Act (CEQA) significant impacts and mitigation as a part of the environmental analysis process. • Evaluate a project’s consistency with the Town’s General Plan. • Evaluate a project’s consistency with the Santa Clara County Congestion Management Program (CMP).

II. TRANSPORTATION IMPACT FEES

1. All Projects that generate one or more new Average Daily Trips (ADT) as calculated based on the ITE trip generation manual are required to pay Transportation Impact Fees, previously known as Traffic Impact Mitigation Fees.

2. All required Transportation Impact Fees shall be paid in full to the Town in association with and prior to issuance of a building permit, unless otherwise required by law. If no building permit is required, the fee shall be paid in full prior to issuance of a certificate of use and occupancy, or similar entitlement. Unless otherwise required by law, the amount due shall be calculated based on the fee in place as approved by the Town Council by resolution at the time the fee is paid.

3. The per trip amount of the fee shall be as set forth by the Town Council by resolution, pursuant to Town Municipal Code, Chapter 15, Article VII, Traffic Impact Mitigation Fees.

4. Fees shall be calculated by multiplying net new ADT by the per trip amount in place at the time the fees are paid.

5. Credit against Transportation Impact Fees due shall be granted for projects shown on the town of Los Gatos Transportation Improvements list (Attachment 2) up to the amount of the actual reasonable expenditure based on receipts submitted to the Town and as approved by the Town Engineer. Credit may be applied for any listed projects for which the developer, as a condition of approval, is required to either construct at the developer's sole cost or contribute a fixed or percentage amount of funding toward future construction of the listed improvement.

6. No credit shall be given for any public right-of-way dedication required for completion of projects not listed on Attachment 2.

7. Credit for existing development shall be determined by trips generated at the site within three years of entitlement application to the Community Development Department. Properties not generating trips within three years of application will not receive credit. All credits under this section shall be at the discretion of the Town

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Engineer.

8. Housing units deed restricted for extremely low- and very low-income categories shall pay a fee at 50% of the rate of the fee that would otherwise be required for the unit.

Extremely low- and very-low income categories will be as defined by the County of Santa Clara. The Community Development Director shall provide verification that the appropriate deed restrictions have been filed before permitting the project to pay the lower fee.

9. No credit shall be given for installation of Town-standard frontage improvements, Project access improvements, or internal circulation improvements.

10. Credit shall only be granted for payment of costs or construction of projects listed in Attachment 2, unless otherwise approved by the Town Council.

III. VEHICLE MILES TRAVELLED MITIGATION MEASURES

1. To mitigate VMT environmental impacts, the project shall be conditioned for implementation of mitigation measures in the following categories:
• Modify the project’s built environment characteristics to reduce VMT generated by the project;
• Implement transportation Demand Management (TDM) measures to reduce VMT generated by the project; and/or
• Participate in a VMT fee program and/or VMT mitigation exchange/banking program (if they exist) to reduce VMT from the project or other land uses to achieve acceptable levels.

2. The Town is taking a Townwide approach for VMT impact mitigation. Attachment 3, VMT Reduction Actions for the Town of Los Gatos, provides a framework for mitigating VMT in the Town.

APPROVED AS TO FORM:

Gabrielle Whelan, Town Attorney

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Town of Los Gatos
Transportation Analysis Guidelines
Table of Contents

1. Introduction............................................................................ Error! Bookmark not defined.

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2.3 Recommended Process and Documentation .................... Error! Bookmark not defined.

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1. Introduction
Transportation Analysis (TA) Guidelines are routinely established by jurisdictions to assess potential transportation effects of proposed projects on the local transportation system. These guidelines are intended to provide a clear and consistent technical approach to evaluating both land use and transportation infrastructure projects within Los Gatos.

These guidelines establish a process to comprehensively and accurately analyze potential project effects (adverse and beneficial) on transportation facilities and services in the Town of Los Gatos and other jurisdictions. This information is essential for decision-makers and the public when evaluating land use development and transportation infrastructure projects. These TA Guidelines serve three primary purposes:
• Provide an evaluation for the California Environmental Quality Act (CEQA) significant impacts and mitigation as a part of the environmental analysis process. • Guide the Local Transportation Analysis in evaluating a project’s consistency with the Town’s General Plan Mobility Goals.
• Evaluate a project’s consistency with the Santa Clara County Congestion Management Program (CMP).

1.1 Intent of TA Guidelines
The Town of Los Gatos General Plan 2040 seeks to “provide a well-connected transportation system that enables safe access for all transportation modes, including pedestrians, bicyclists, motorists, and transit riders of all ages and abilities.” The TA Guidelines support this goal by evaluating new projects against the policies of the latest General Plan.

For CEQA-based environmental analysis, these TA Guidelines incorporate the use of vehicle miles traveled (VMT) to disclose the effects of the project on the surrounding environment. Town staff completed an SB 7431 implementation process, which included the preparation of the SB 743 Implementation for the Town of Los Gatos (July 2020) document package. The document package provides detailed technical information pertaining to the options and data considered by the Town of Los Gatos to implement VMT as an impact criterion.

The TA Guidelines present the Town’s approach for determining the need for a transportation analysis, its content, and identifying acceptable transportation improvements for land use and transportation projects proposed within Los Gatos. The TA Guidelines establish a transportation analysis protocol for the following:
1 Senate Bill 743 (SB 743) changed some of the transportation significance criteria under the California Environmental Quality Act (CEQA) CEQA. Specifically, vehicle level of service (LOS) is no longer used as a determinant of significant environmental impacts, and a vehicle miles traveled (VMT) analysis is required.

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1 • Environmental analysis
• General Plan consistency
• Congestion Management Program (CMP) evaluation
• Mobility deficiency criteria and thresholds
• Guidance on acceptable transportation improvements
Town staff will review transportation studies and reports based on the process presented in the TA Guidelines. However, each project is unique, and the TA Guidelines are not intended to be prescriptive beyond practical limits. Not all criteria and analyses described in the TA Guidelines will apply to every project. Early and consistent communication with Town staff is encouraged to confirm the type and level of analysis required for each study.

1.2 Environmental Evaluation
The TA Guidelines outline the methods and thresholds with which to evaluate projects consistent with the latest CEQA Statue & Guidelines.

The latest CEQA Statue & Guidelines include revised Appendix G Checklist questions for transportation impact evaluation. The four questions are as follows:

Would the project:
a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? d) Result in inadequate emergency access?

1.3 Project Types
A TA is prepared for a project before a discretionary action is taken. The following types of projects, which involve development activity or infrastructure changes in and around the Town of Los Gatos and affect the adjacent transportation system, should be evaluated for TA requirements. • Land use entitlements or changes in use requiring discretionary approval by Los Gatos, which include General Plan amendments, specific plans (and related amendments), zoning changes, use permits, planned developments, and tentative subdivision maps; or any modifications of use that would generate 20 or more new Peak Hour (vehicle) Trips or at the discretion of the Town’s Traffic Engineer
• Land use activity advanced by agencies other than Los Gatos that is subject to jurisdictional review under state and federal law, such as school districts, Santa Clara Valley Transportation Authority (VTA) Board of Directors, and others; or advanced within Los Gatos by agencies other than the

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Town and inconsistent with the Town’s General Plan.
• Transportation infrastructure modification or expansion, including capital improvement projects on Town roads, county roads, and state highways that may impact Town facilities and services.

1.4 CEQA and Non-CEQA Terminology
To distinguish the CEQA analysis from the non-CEQA analysis (i.e., the local transportation analysis) the analyses apply different terminologies as summarized below in Table 1.

Table 1: Comparison of Select CEQA and Non-CEQA Terms
CEQA Term Non-CEQA Term
CEQA Transportation Analysis Local Transportation Analysis Significance criteria Threshold or performance standard Significant impact Deficiency
Mitigation measure Mitigation improvement
Baseline Conditions Existing Conditions and Background
Conditions
Future Year Cumulative Conditions Cumulative Conditions

2. Determining the Level of Transportation Analysis
Unless explicitly waived by the Town, a TA may be required when any one of the following conditions is met.
• A project has the potential to create a significant transportation environmental impact under CEQA.
• A project has the potential to generate daily vehicle miles traveled greater than the Town’s General Plan future year VMT projections.
• For local transportation analysis, a project has the potential to generate 20 or more new Peak Hour (vehicle) Trips.
• A project that is not consistent with the development density established by existing zoning, community plan, or general plan policies for which an environmental impact report (EIR) was certified, per CEQA Statue & Guidelines Section 15183.
• A project will alter physical or operational conditions on a Town pedestrian facility, bicycle facility, transit facility or service, or other transportation facility. • An Accessory Dwelling Unit (ADU) of 750 square feet or smaller shall be exempted from the requirements of Transportation Analysis and the Transportation Impact Fees.

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In general, a TA is applicable for two to five years. After two or more years of inactivity, a TA may need to be updated to reflect changes in the study environment, including traffic growth and other circulation issues.

Nothing in the Transportation Impact Policy shall prohibit or restrict a Project applicant from completing a local transportation study for a Project anticipated to generate less than 20 new Peak Hour trips.

2.1 CEQA Relief for Projects Consistent with General Plan or Zoning Per CEQA Statue & Guidelines Section 15183, projects consistent with a general plan, zoning action, specific plan, and certified environmental impact report (EIR) would not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects.

Additionally, projects consistent with a general plan, zoning action, or specific plan where cumulative impact(s) were adequately addressed in a prior EIR would not require further CEQA transportation analysis. As noted below, projects consistent with the Town’s General Plan, as determined by the Community Development Director, will not be required to do any VMT Analysis since the Town is taking a Townwide approach for VMT impact mitigation.

2.2 CMP Consistency Screening
Projects should reference the most recent VTA Transportation Impact Analysis (TIA) Guidelines to determine the need for a transportation impact analysis. In most cases, projects that generate fewer than 100 net new peak hour vehicle trips are not required to conduct VTA’s CMP transportation analysis.

2.3 Recommended Process and Documentation
In coordination with Town staff, the project applicant shall retain a transportation professional to conduct the TA. The transportation consultant should seek Town acceptance of the scope of work before initiating the analysis. In some cases, review by other affected jurisdictions will be required. Appendix A:

Transportation Analysis Report Format Outline contains a recommended outline for the TA document.

Each TA will begin by preparing a scope of work that describes the project description, site location, analysis methods, area-wide assumption, study elements, study time periods, and traffic data collection methods. To finalize a TA scope of work for the local transportation analysis, the project applicant will provide an estimate of the project trip generation and trip distribution . These estimates and scope of work should be shared with Town staff to finalize the scope of services. Overall, the TA report will address:
1) environmental analysis, 2) project site access and circulation, and 3) other transportation impacts and traffic deficiencies.

2.4 Contact with Appropriate Town Staff
To minimize the potential for delays in project processing, it is important for the TA to be prepared in coordination with Town staff. Timely coordination will also ensure that potential transportation improvements and environmental consequences are considered as early as possible in the planning process, as deficiencies and corresponding improvement costs can have a substantial effect on project costs. Coordination should include the following:

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• A pre-application meeting, which will include a discussion of the TA requirements. • Development of an approved scope of work, which includes trip generation, study area, analysis scenarios and parameters, data requirements, and provisions for pedestrians, bicyclists, and transit users.
• Approval of the project trip generation (person and vehicle) and trip distribution. • Review of all assumptions and the results of Existing Conditions analysis. • Review of the administrative draft report, with adequate time for comments. • Review of a draft report, with adequate time for comments.

If the TA report information will be incorporated into the transportation and circulation section of an environmental document (e.g., Initial Study, Mitigated Negative Declaration, or Environmental Impact Report), the format of this report may need to be discussed with the environmental consultant, a peer reviewer, and/or Town staff. Upon circulation of the draft environmental document, the format of the final TA report may need to be discussed with the environmental consultant.

2.5 Consultation with Other Jurisdictions
If the study area overlaps with other jurisdictions, staff from other jurisdictions must be consulted to verify study locations, the impact significance criteria, and to consider any current development applications. Section 15086 of the CEQA Statue & Guidelines22 shall be followed as the basis for satisfying consultation requirements. In most cases, overlap will occur for roadway system analysis, but may also include impact analysis of active transportation modes (bicycling and walking), as well as transit system facilities and services.

2.6 Project Trip Generation and Trip Reductions
Person and vehicle trip generation rates are a way to estimate the number of expected pedestrian, bicycle, transit, and vehicle trips that a proposed development will generate. These rates establish the basis of analysis for a proposed project and its effects on the transportation network. Person trip generation should be reported for walking, bicycle, and pedestrian trips, and vehicle trip generation should be reported for single-occupant, and carpool.

Methodologies to estimate project trip generation and trip reductions shall be prepared consistent with the latest VTA TIA Guidelines, with the exceptions described in this document. 2 California Environmental Quality Act Statute & Guidelines, 2020.

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2.6.1 Vehicle Trips
Consistent with the VTA TIA Guidelines, pass-by trips shall not be considered in calculating the 20 new Peak Hour Trip threshold that triggers the requirement for conducting a comprehensive local transportation analysis report.

The Institute of Traffic Engineers (ITE) Trip Generation Manual trip generation rates for Specialty Retail Center shall apply to all Specialty Retail.

Uses within the Central Business District (C-2 Zone} are expected to change periodically as part of the natural business cycle. For the purpose of Transportation Impact Fees, changes in use without changes in net building square footage within the C-2 Zone shall not be considered to create a traffic deficiency, shall be exempt from this policy, and no fees shall be charged for a change in use. Any increases in building square footage shall pay impact fees at the ITE Shopping Center rate or comparable equivalent rate for the expanded area, as determined by the Town Traffic Engineer.

The Town reserves the right to require the project sponsor to conduct local trip generation surveys for select projects, depending on land use and conditions in the field.

2.6.2 Person Trips
Person trip generation rates should be developed from empirical studies, person travel survey data, or conversion of vehicle trip rates to person trip rates using a vehicle occupancy factor. In addition, person trip generation by mode may be derived using an approved analysis tool that incorporates data from local trip generation surveys or published trip generation rate data.

2.6.3 Establishing Trip Generation Rates for an Unspecified Use For projects where the ultimate land use is not certain (for example, a large subdivision of flexible commercial-industrial parcels), there are two options for establishing the trip generation rates. • Option 1: Town staff will recommend the use of the highest traffic intensity among all permitted uses to establish traffic deficiencies.
• Option 2: Estimates can be made using a lower traffic intensity use if the Town and developer establish a maximum trip allowance. Once a proposed land use has been identified, then: 1) the subdivision trip generation allowance must be monitored by the Town as development occurs; and 2) the TA report may need to be updated.

2.6.4 Credit for Existing Trips – Local Analysis
The estimate of new trips generated by the proposed development project may include credit for trips associated with existing uses on the site. Uses are considered as existing if they are actively present on the project site at the time that data is gathered for the transportation impact analysis. Similarly, if a

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planned (but not constructed) use was already permitted for the site and an improvement(s) was identified and funded, the new TA only needs to assess the effects of additional trips above and beyond the trips for the permitted use. Additionally, certain commercial land uses attract vehicle traffic that currently exists on the roadway, rather than generating new trips.

Understanding there are permitted reductions that may be taken under the circumstances listed above, the Town requires that any reductions in project vehicle trip generation are applied according to the latest VTA TIA Guidelines.

In calculating new Peak Hour Trips for purposes of determining whether or not a TA report is required pursuant to this Policy, trip credit shall be granted for an existing use or the most recent former use.

In calculating new Average Daily Trips for purposes of determining the amount of the Transportation Impact Mitigation Fee due, trip credit shall be granted for an existing use or the most recent former use.

Where the property is vacant, the most recent former use shall be used.

Where a portion of the space is changing use, credit will apply to the proportionate square footage of the space under review.

Where the change in use results in fewer trips than the existing or former use, no credit or refund will be due the applicant.

2.6.4 Credit for Existing Trips – VMT Analysis
For the evaluation of vehicle miles of travel, VMT credit for the prior use depends on how the project changes the baseline condition, if the project sponsor had ownership and control of the previous land use, and the reason for stopping the previous land use. Baseline conditions are typically defined at the beginning of an environmental analysis and a CEQA analysis needs to isolate the effects of the project to clearly define the project’s effect on the baseline condition. To receive VMT credit, the project sponsor needs to demonstrate continuous ownership of site, with on-site occupancy paused only due to the redevelopment activity and not because of some economic or other condition outside the control of the project sponsor. However, this credit should only be applied to total project generated VMT and should not be included when calculating a VMT rate.

2.7 Vehicle Miles Traveled Methods
As noted, projects consistent with the Town’s General Plan, as determined by the Community Development Director, will not be required to do any VMT Analysis since the Town is taking a Townwide approach for VMT impact mitigation. Although the calculation of VMT is simply the number of cars multiplied by the distance traveled by each car, VMT performance measures can be reported differently.

At a minimum, the VMT analysis for Los Gatos will be prepared for two purposes:

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• Greenhouse gas and air quality analysis using project generated VMT on a VMT per service population basis (residents + employment).
• Environmental evaluation by land use and/or transportation project.

The project generated VMT from new population and employment growth and the boundary (total) VMT for a specific geographic area will be prepared using the latest Santa Clara Valley Transportation Authority (VTA)-City/County Association of Governments of San Mateo County (C/CAG) Bi-County Model (“VTA Travel Model”). Because emissions rates vary by vehicle speed, the project generated VMT and total VMT should be disaggregated by speed bin (typically in five mile an hour increments of speed from 0 to ~80 miles per hour) to allow different emissions factors to be applied at different speeds, which allows for the preparation of a more refined emissions analysis.

3. Transportation Analysis (CEQA) for Land Use Projects For an environmental analysis, these TA Guidelines incorporate the use of vehicle miles traveled (VMT) to disclose the effects of the project on the environment. Town staff completed an SB 743 implementation process, which included the preparation of the SB 743 Implementation for the Town of Los Gatos (July 2020) document package. The document package provides detailed technical information pertaining to the options and data considered by the Town of Los Gatos to implement VMT as an impact criterion.

At its November 17, 2020 meeting, the Town Council adopted Resolution 2020-045, Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743.

The CEQA Statue & Guidelines allow exemptions to projects meeting certain criteria. Project applicant may review the exemptions before preparing CEQA analysis for projects.

Based on the Town’s implementation of SB 743, the following methods should be used to determine VMT impact thresholds and mitigation requirements for land use projects.

3.1 VMT Analysis Methods
The Town elected to conduct a complete VMT analysis consistent with the General Plan future year VMT projections based on long-term expectations for air quality and GHG expectations as part of its General Plan EIR, so that it could make specific use of CEQA Statue & Guidelines Section 15183 to streamline project-specific CEQA analysis that is consistent with its General Plan and other Town documents. For the Town of Los Gatos, addressing transportation VMT impacts in the Town General Plan EIR is a useful way of understanding VMT impacts and how VMT reduction should be balanced against other community values related to the environment, social justice, and the community. By conducting a Town-wide VMT impact analysis, the Town is able to develop a program-based VMT mitigation approach. The concept of a ‘program’ approach to impact mitigation is commonly used in a variety of technical subjects, including

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transportation, air quality, GHG, and habitat. Absent a new program-level VMT mitigation approach, there are limited feasible mitigation options for project sites, and as a result limited ability to reduce VMT. Also, practically speaking, without feasible mitigation, significant VMT impacts would be significant and unavoidable (SAU). Under these circumstances, a project must prepare an EIR, thus adding time and cost to environmental review compared to an initial study/negative declaration (IS/ND) that relies on streamlining offered in the CEQA Statue & Guidelines.

Should a project not be consistent with the General Plan, as determined by the Community Development Director, or for some other reason unable to benefit from streamlined CEQA review under CEQA Statue & Guidelines Section 15183, the following sections provide details on how to conduct a complete VMT analysis for land use plans and projects in the Town of Los Gatos.

3.1.1 Regional Transportation Plan/Sustainable Communities Strategy and General Plan Consistency The first step in assessing project impacts is to determine if the project land use is contained within the Town of Los Gatos residential and non-residential land use allocations in the current Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), and if the project is consistent with the latest General Plan. If the project is not consistent with the RTP/SCS and/or the latest General Plan, amendments to those documents or the project would be needed prior to proceeding with the project review.

3.1.2 VMT Assessment
Projects not consistent with the current RTP/SCS or the latest General Plan are required to complete a VMT analysis using the VTA Travel Model to determine if there would be a significant VMT impact. The tools and methodology of the VMT analysis shall be approved by PPW Director (or Traffic Engineer). The impact analysis includes two types of VMT:

1. Total Project Generated VMT – Daily VMT of all vehicle trips, vehicle types, and trip purposes for all project land uses, presented as a total project generated VMT.

2. Project’s Effect on VMT within the Town of Los Gatos. VMT that occurs within the Town of Los Gatos by any type of vehicle. This captures all on-road vehicle travel on a roadway network for any purpose, and includes local trips as well as trips that pass through the area without stopping.

If the land use control totals increase between the without and with project conditions in the travel model, these VMT metrics will need to be expressed on a per service population (residents, employees, and other populations generating the VMT) basis to understand the effects of the project between scenarios.

The types of VMT analysis are evaluated for the following scenarios:

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• Baseline Conditions – Conditions in the baseline year for the CEQA analysis, which is most often chosen as the time of notice of preparation (NOP) of an environmental document, but may be chosen as the baseline year of the VTA Travel Model, if land use and transportation network conditions can be considered largely unchanged between the model baseline year and the date of the NOP. For compliance with the CEQA Statute & Guidelines Section 15125(a), the transportation impact analysis must include a description of the physical environmental conditions near the project, as they exist at the time the NOP is published, or if no NOP is published, at the time environmental analysis is commenced, from both a local and regional perspective. Baseline VMT estimates will be prepared using the most recent base year VTA Travel Model. • Baseline with Project Conditions – The project land use is added to the project Transportation Analysis Zone (TAZ), or a separate TAZ may be created to contain the project land uses. A full model run is performed and VMT changes (by metric of choice) are isolated for the project TAZ and across the full model network. The model output must include reasonableness checks of the production and attraction balancing to ensure the project effect is accurately captured. If this scenario results in a less-than- significant impact, then additional cumulative scenario analysis may not be required.
• Future Year Cumulative Conditions – Conditions requiring an RTP/SCS and/or General Plan amendment are also required to evaluate the project effect on VMT under Future Year Cumulative Conditions. This scenario buildout of the region’s land use and transportation system also provides the long-range view of future travel patterns. Future Year Cumulative Conditions VMT estimates should be based on the horizon year of the most recent VTA Travel Model, ensuring the model does not already contain the land uses or transportation improvements associated with the project.
• Future Year Cumulative with Project Conditions – The project land use is added to the project TAZ, or a separate TAZ is created to contain the project land uses. The addition of project land uses may be accompanied by a reallocation of a similar amount of land use from other TAZs throughout the model area (focusing on Santa Clara County), especially if the proposed project is significant in size such that it would potentially reduce the potential for development throughout the rest of the model area. Land use projects will generally not change the Future Year Cumulative Conditions control totals for population and employment growth within the model area. Instead, they will influence the land use supply through changes in General Plan land use designations and zoning. If project land uses are simply added to the Future Year Cumulative Conditions scenario, then the analysis should reflect this limitation in the methods and acknowledge that the analysis may overestimate the project’s effect on VMT. A full model run is performed and VMT changes (by metric of choice) would be isolated for the project TAZ and across the full model network. The model output must include reasonableness checks of the production and attraction balancing to ensure the project effect is accurately captured.

The model output should include the two VMT metrics listed earlier: 1) total project generated VMT, and 2) project’s effect on VMT using the total boundary VMT. Emissions vary by speed bin; disaggregating VMT by speed bin allows different emissions factors to be applied at different speeds, which allows for the preparation of a more refined emissions analysis. The total boundary VMT is needed as an input for air quality, greenhouse gas (GHG), and energy impact analysis, while the project generated VMT metrics are

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used for the transportation impact analysis.

Both “with project” scenarios noted above will summarize the two types of VMT and be compared to the without project condition.

Project generated VMT should be extracted from the VTA Travel Model by combining either the origindestination (for total VMT) or production-attraction (for the other metrics) trip matrices and congested skims (travel distances for each origin-destination pair in the travel mode) from final assignment. The VMT should be adjusted to reflect trips that extend beyond the model boundary. The project’s effect on VMT should be estimated using the Town limit boundary and extracting the total link-level VMT for both the without and with project conditions. Additional VMT metric specifications may be found in the SB 743 Implementation for the Town of Los Gatos (July 2020) document package.

If a project is mixed-use (i.e., composed of both residential and retail/office uses), project generated VMT should be extracted for both the total VMT and VMT per service population (residents and employees).

3.2 VMT Significance Thresholds
The Town Council adopted Resolution 2020-045, Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743. The thresholds balance the Town’s priorities with respect to competing objectives, including Los Gatos’s geographic and transportation context, greenhouse gas reduction goals, interest in achieving the state’s greenhouse gas reduction goals, and the latest General Plan goals and policies related to land use mix, economic development, and housing provision.

VMT analyses shall evaluate a project’s VMT impacts based on the thresholds established in the latest Council-adopted resolution.

3.3 VMT Mitigation Measures
To mitigate VMT impacts, the project shall be conditioned for implementation of mitigation measures in the following categories:

1. Modify the project’s built environment characteristics to reduce VMT generated by the project;

2. Implement transportation Demand Management (TDM) measures to reduce VMT generated by the project; and/or

3. Participate in a VMT fee program and/or VMT mitigation exchange/banking program (if they exist) to reduce VMT from the project or other land uses to achieve acceptable levels.

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The Town is in the process of updating the General Plan and the Draft Environmental Impact Report (DEIR) for the 2040 General Plan was released for public review in July 2021. The 2040 General Plan DEIR identifies significant but unavoidable transportation impacts and the mitigation measures. The Town is taking a Town-wide approach for VMT impact mitigation.

Attachment 3, VMT Reduction Actions for the Town of Los Gatos, provides a framework for mitigating VMT in the Town. Attachment 2, Transportation Mitigation Improvements Project List, has many improvements that are consistent with the VMT Reduction Strategies.

Evaluation of VMT reductions should be conducted using state-of-the-practice methods, recognizing that many of the TDM strategies are dependent on building occupant performance over time. As such, actual VMT reduction cannot be reliably predicted, and monitoring may be necessary to gauge performance related to mitigation expectations.

4. Transportation Analysis (CEQA) for Transportation Projects Transportation Analysis for transportation projects shall follow the latest CEQA Guidelines and related technical advisories from the Governor’s Office of Planning and Research (OPR).

The Thresholds of Significance for all transportation projects are established in the latest Council-adopted resolution.

Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact.

In 2020 Caltrans adopted its guidance under SB 743. The department’s Transportation Analysis Framework and Transportation Analysis for CEQA provide guidance for assessing induced travel impacts from prospective projects on the State Highway System. CEQA analysis for proposed transportation projects on the State Highway System should also follow Caltrans guidance.

5. Transportation Analysis per the Town’s Transportation Policies The contents and extent of a local transportation analysis per the Town’s General Plan depend on the location and size of the proposed development, the prevailing transportation conditions in the surrounding area, and questions from decision-makers and the public. The Town is committed to a wellconnected transportation system that enables safe access for all modes of travel. The methods presented in this chapter include robust data collection and analysis techniques for pedestrian, bicycle, and transit networks, in addition to vehicle circulation.

The local transportation analysis shall be prepared consistent with the latest VTA TIA Guidelines, with the exceptions described in this document.

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5.1 Study Area
The study area is determined by evaluating the project location and how it may affect all transportation modes and facilities. It is not simply a map showing where the project is located. Rather, the study area is the area of influence of a project. Each local transportation analysis will consider the adjacent transportation system for site access and circulation of land development projects and street modifications for transportation projects. To properly assess the site access, the Town may require offsite intersection analysis and/or other multimodal analysis.

The study area may include the nearest CMP facility to evaluate the proposed project’s conformity with the CMP facilities.

Applicants should consult with Town staff early regarding the need for a local transportation analysis based on local or site-specific issues, especially those related to pedestrians, bicyclists, and transit users.

5.2 Key Study Elements
The extent and complexity of a local transportation analysis will vary on the project attributes. Table 2 summarizes the basic requirements for a local transportation analysis for every project requiring a complete transportation analysis. Specific significance criteria for each of the listed elements are described in further detail in the Transportation Analysis (CEQA) for Land Use Projects and Transportation Analysis (CEQA) for Transportation Projects sections. To avoid substantial off-site improvements or changes to the project site plan/description after the transportation analysis is completed, a preliminary site plan shall be included for a “fatal flaw” evaluation.

Table 2: Local Transportation Analysis – Evaluation Criteria Study Element Evaluation Criteria
General Plan
Consistency
Evaluate the project against goals, policies, and actions set forth in the latest General Plan and other applicable Town plans.

Parking
Compare the project parking plan with Town and local specific plan standards and discuss how the proposed supply will affect demand for walking, bicycling, and transit modes. If a mix of land uses is proposed on site, or complements adjacent land uses, justify how the development will make use of shared on-site parking.

On-Site
Circulation
Review and evaluate site access locations, turning radii, truck loading areas, emergency access, and othersite characteristics with respect to operations and safety for all modes of transportation.

Pedestrian
Facilities
Identify any existing or planned pedestrian facilities that may be affected by the project. Document how the project will affect local pedestrian circulation (e.g., disclose how widening a road or adding a driveway will affect pedestrian safety and walking time).

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Table 2: Local Transportation Analysis – Evaluation Criteria Study Element Evaluation Criteria
Bicycle Facilities Identify any existing or planned facilities that may be affected by the project.

Transit
Identify any existing or planned transit facilities that may be affected by the project. If appropriate, document how the project improves access to or utilization of transit. For system planning, use crush load as capacity, not seated capacity.

Safety
Assessment
Evaluate project trips added to safety enhancement projects within the study area that are proposed as part of other future safety studies by the Town or other agencies.

Trucks (or Other
Large
Vehicles)
For relevant industrial projects, identify the number of truck trips that will be generated, and design facilities necessary to accommodate these trucks.

Automated
Vehicles or
Transportation
Network
Company Pickup/Drop-Off
For projects where automated vehicles and/or transportation network companies may have a large concentration of pick-up/drop-off, the project site circulation and pick-up/drop-off areas must be reviewed to identify opportunities and constraints of the project site. Modifications to the site circulation and/or pick-up/drop-off may be recommended.

Off-Site Traffic
Operations
All roadway facility analysis and Level of Service should be conducted using the latest version of the Highway Capacity Manual (HCM).

Intersection
Traffic Control
Evaluate unsignalized intersections located within the study area to determine appropriate traffic control. Analysis should include documentation of the appropriateness of a roundabout as an alternative or replacement to a traffic signal.

Other Issues
Consider other issues on a case-by-case basis (e.g., construction deficiencies, queuing between closely spaced intersections, emergency access, special event traffic)
Other
Jurisdictional
Requirements
In situations where several agencies must approve a development or are responsible for affected roadways, the applicant must contact lead and responsible agencies to determine issues to be addressed, scope of study, etc.

In general, the applicant will be responsible for analyzing project impacts against appropriate jurisdictional thresholds; however, the analysis method will be determined by the Town in compliance with CEQA, and the impacts will be mitigated consistent with Town standards.

5.3 Data Collection
Accurate data is essential to achieve a high level of confidence in local transportation analysis results.

Existing transportation data shall be collected using the requirements set forth below. Data should be presented on maps or figures where appropriate. To address the specific needs of each project, the extent of data collected shall be at the discretion of Town staff.

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• Pedestrian/Bicycle Facilities – Document the existing pedestrian and bicycle facilities serving the project site. Elements will include presence and width of sidewalks, curb ramps, crosswalks, or other pedestrian facilities providing access to the nearest attractors of the project site, such as transit stops, neighborhood attractors and/or complimentary land uses, and bicycle facilities (e.g., routes, lanes, or shared-use paths) within a two-mile bicycling distance of the project site.

Document barriers, deficiencies, and high pedestrian-demand land uses, including schools, parking, senior housing facilities, and transit stops or centers. The report will note any deficiencies or enhancements planned or recommended in the latest General Plan or future planning documents.
• Transit Facilities and Ridership – Document transit lines nearest to the project site, including stop locations, frequency of service, and any capacity issues. It will also describe transit stop amenities (e.g., benches, shelters, etc.).
• Multimodal Peak-Period Turning Movement Counts – Turning movement counts, including vehicles, bicycles, and pedestrians, will be collected for each study time period at all study intersections. The following parameters will be followed (fall and spring days while school is in session are preferred):
• Data collection will cover at least two hours to ensure the peak hour is observed. • As applicable, 48-hour machine counts will be used to identify the peak period before conducting other counts or analysis.
• Traffic volumes should not be influenced by a holiday, weather, construction, or other temporary change.
• The percent of traffic that consists of heavy trucks will be noted/estimated during data collection.
• Some projects may require vehicle classification or occupancy counts. Consult with Town staff on a case-by-case basis.
• Traffic counts that are older than two years at study initiation will not be used without consultation and approval by Town staff. These counts may need to be adjusted to reflect current year traffic volumes.
• Daily Traffic Counts – Collect data for all study roadway segments using the parameters described above for peak period turning movement counts, with the exception of bicycle and pedestrian volumes. Daily counts are used to size facilities (e.g., 2-lane vs. 4- lane) and to identify temporal changes in traffic.
• Roadway Geometry – Document existing roadway and intersection geometries and lane configurations. Information from aerial photography and street views should be verified based on a site visit(s).
• Intersection Controls and Signal Timings – For use in intersection analysis, intersection control types and signal timings and phasing should be based on signal timing sheets (available from Los Gatos or Caltrans) and verified during site visits.
• Five-Year Collision Data – Obtain Statewide Integrated Traffic Records System (SWITRS) through the local California Highway Patrol or through the following web site: www.chp.ca.gov/switrs.

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• Mode Split – Summarize daily and peak hour mode split for the study area land uses. Data could include U.S. Census journey-to-work data, empirical surveys, or any other available surveys.

5.4 Project Site Access and Circulation Review
A detailed site plan review is required for all projects. The local transportation analysis should include a review and summary of findings of the following qualitative and quantitative features. • Consideration of roundabouts are encouraged. Conduct roundabout analysis as required by Town staff.
• Existence of any current traffic problems in the local area, such as a high-collision location, nonstandard intersection or roadway, or an intersection in need of a traffic signal or a roundabout. • Applicability of context-sensitive design practices compatible with adjacent neighborhoods or other areas that may be impacted by the project traffic. • Proximity of proposed site driveway(s) to other driveways or intersections. • Adequacy of the project site design to convey all vehicle types. • Number and type of parking provided, including vehicle and bicycle parking. • On- and off-street loading requirements.
• Adequacy of on-site vehicle, bicycle, and pedestrian circulation and provision of direct pedestrian paths from residential areas to school sites, public streets to commercial and residential areas, and the project site to nearby transit facilities.

An important aspect of a TA is to provide sufficient information for the Town to determine that a project is consistent with the latest General Plan and other applicable Town policies, plans, and standards. As such, individual projects must be reviewed against relevant policies contained in the latest General Plan or other plans and policies. Applicants should review the full policy statements in the latest General Plan Mobility Element.

If the study area extends into an adjacent jurisdiction, the applicant may be responsible for analyzing project generated operational impacts in these jurisdictions. These include intersection or segment locations in any other jurisdiction, including Caltrans-maintained facilities. The applicant shall refer to current policies in the respective jurisdiction to identify the appropriate significance criteria.

5.5 Analysis Scenarios
The range of scenarios includes Existing Conditions, Background Conditions, and Cumulative Conditions.

Projects consistent with the latest General Plan will only be required to complete the Existing and Background conditions analysis; where Existing Conditions looks at the effect of the proposed project on the existing system within the next year or two, Background Conditions typically looks at a longer time frame of about three to five years. Inclusion of all three analysis conditions (e.g., Existing, Background, and Cumulative), would typically occur for large development projects, General Plan amendments, specific plans (and related amendments), with Cumulative Conditions having a time horizon of 10 to 20 years.

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The following analysis scenarios will document existing or future conditions, any deficiencies, and identify deficiencies that will result from the addition of the project. Each scenario will include a qualitative description of transportation facilities for all modes (and any planned enhancements), traffic volumes, and a quantitative analysis of intersection LOS. Key study elements are identified in the Multimodal Analysis Methods section of this chapter. Details regarding each local transportation analysis scenario are presented below.
• Existing Conditions – These conditions are based on recent field observations and recent traffic count data.
• Existing with Project Conditions – Traffic volume forecasts for roadway analysis reflecting Existing Conditions with traffic generated by the proposed project. For reuse or conversion projects, this may involve accounting for any existing use of the site that remains or will be removed. It should also qualitatively describe how the project will affect transportation for other modes, including compliance or relation to other Town documents.
• Background Conditions – Traffic volume forecasts for roadway segment and intersection analysis should reflect Existing Conditions with growth due to approved development that is expected to be operational before or concurrently with the proposed project. This scenario may not be needed if the study area has limited or no approved developments. • Background with Project Conditions – This scenario represents the Background Conditions with vehicle trips added by the proposed project. It provides decision-makers and the public with a view of conditions with all recently approved development and physical improvements, including the proposed project.
• Future Year Cumulative Conditions – This scenario represents transportation conditions for all travel modes in the study area reflecting all approved projects, pending projects, or expected development of other areas of Los Gatos designated for growth under the latest General Plan or specific plan. In most cases, the project site will likely be vacant under this scenario. In some cases, this scenario may need to account for any existing uses on the site that could continue, and potential increases in development allowed by ministerial approvals. • Cumulative with Project Conditions – This scenario represents the cumulative future transportation conditions with anticipated changes to the transportation system and the additions of project trips, and provides the long-range view of future traffic operations.

5.6 Analysis Time Periods
Based on the land use of the proposed project and upon consultation with Town staff, the study shall analyze traffic operations during the peak one hour of the following time periods:
• Weekday morning peak (7:00 – 10:00 AM)
• Weekday evening peak (4:00 – 7:00 PM)

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For some projects, the Town may substitute or require additional peak hour analysis for the following time periods as approved or requested by the Town’s Traffic Engineer:
• Weekday afternoon peak (2:00 – 4:00 PM)
• Friday evening peak (4:00 – 7:00 PM)
• Weekend midday peak (11:00 AM – 1:00 PM)
• Sunday or holiday evening peak (4:00 – 7:00 PM)
For example, retail commercial projects should evaluate operations for Saturday midday peak hour conditions, in addition to the standard weekday morning and evening peak periods. The determination of study time periods should be made separately for each proposed project, based upon the peaking characteristics of the project generated traffic and peaking characteristics of the adjacent street system and land uses.

5.7 Multimodal Analysis Methods
The report should provide a quantitative and/or qualitative evaluation of the project’s potential adverse or beneficial effects on transportation facilities and services related to pedestrians, bicyclists, and transit users.

For some projects, more detailed multimodal analysis may be required. Such analysis shall be decided upon in consultation with Town staff and consider new tools, methods, and performance measures, such as those listed below.
• Multimodal LOS – The latest Highway Capacity Manual (6th Edition) contains methods for multimodal LOS.
• Person Delay – Simulation models can be used to measure system performance in terms of overall person-delay for all modes within a transportation network. This method provides a better decision-making tool for developing improvements to promote efficient movement of people, rather than a particular type of vehicle.
• Safety Assessment – Evaluate whether the project adds vehicle trips to a safety improvement identified within the study area. (If a project may affect a Caltrans facility, a safety assessment may be needed for CEQA purposes as well.)
• Bicycle Level of Stress (LTS) – Evaluate LTS for all bicycle facilities within a two-mile bicycling distance of the project site. There are several methods for evaluating LTS for bicycle facilities, which generally rely on street widths/number of vehicle lanes, vehicle speeds, daily volumes, and type of bicycle facility to evaluate “low stress” bike networks. The Low-Stress Bicycling and Network Connectivity (2012) report and the National Association of City Transportation Officials (NACTO) Urban Bikeway Design Guide, Second Edition (2014) contains methods for LTS. • Pedestrian Level of Stress (LTS) – Evaluate LTS for all pedestrian facilities providing access to the nearest attractors (e.g., transit stops, neighborhood attractors and/or complimentary land uses) of the project site. Compared to bicycle LTS, there are parallel methods for calculating pedestrian comfort using best practiced from the NACTO Urban Street Design Guide (2013) and pedestrian

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safety research. As with bicycle comfort, pedestrian comfort is based on a variety of factors ranging from the quality and presence of sidewalks to the conditions of the adjacent roadway (speed, number of travel lanes, frequency of trucks).
• Activity Connectedness – Travel time for each mode (e.g., walking, bicycles, transit, and vehicles) between the project and surrounding land uses can be used to gauge the degree of accessibility for a project. The Town desires to minimize travel time to necessary destinations while minimizing unnecessary vehicle travel. Tools such as geographic information systems or online tools (e.g., Index and Walk Score) can be used to gauge this measure specifically for walking. The main idea is to evaluate activity centers and destinations around projects to ensure that walk times to necessary destinations are minimized and the walking experience is comfortable.

5.8 Traffic Operations Analysis
Traffic operational deficiencies shall be analyzed using standard or state-of-the-practice professional procedures. The main issues related to traffic operations analysis are the method, input data, and assumptions. These three items influence the level of confidence and the associated level of defensibility of the local transportation analysis. For traffic operations, this requires following the procedures and techniques published in the most recent Highway Capacity Manual (HCM).

Traffic Operations Analysis should be conducted according to the latest VTA Traffic Level of Service Guidelines.

5.9 Mobility Deficiency Criteria
The overall guiding principal of the General Plan 2040 Mobility Element is to, “[p]rovide a well- connected transportation system that enables safe access for all transportation modes, including pedestrians, bicyclists, motorists, and transit riders of all ages and abilities.” Los Gatos evaluates each transportation mode to identify deficiencies. Local transportation analyses evaluate intersection operations focused on specific traffic issues such as queuing and safety. A greater emphasis is placed on pedestrian, bicycle, and transit facilities and services, in part to reduce traffic congestion and air quality impacts associated with automobile use. Table 5 outlines deficiency criteria for each mode. The mobility deficiency criteria can be used to identify conflicts with existing or planned multimodal facilities.

Table 5: Mobility Deficiency Criteria
Study Element Deficiency Determination
Parking Project increases off-site parking demand above a level required by the Town Zoning Code and/or desirable by the Town.

On-Site Circulation
Project designs for on-street circulation, access, and parking fail to meet Town standards. Where Town standards are not defined, industry standards [Highway Design Manual, California Manual on Uniform Traffic Control Devices (MUTCD), etc.] should be referenced, as appropriate.

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Table 5: Mobility Deficiency Criteria
Study Element Deficiency Determination
Failure to provide adequate accessibility for service and delivery trucks on site, including access to loading areas. Project will result in a hazard or potentially unsafe conditions without improvements.

Pedestrian
Facilities
Project fails to provide safe and accessible pedestrian connections between project buildings and adjacent streets, trails, and transit facilities.

Bicycle Facilities
Project disrupts existing or planned bicycle facilities or is otherwise inconsistent with the latest General Plan, Bicycle and Pedestrian Master Plan, or other related plans. Project adds bicycle trips along project frontage to an existing facility that needs improvements per the latest BPMP.

Transit Project disrupts existing or planned transit facilities and services or conflicts with Town adopted plans, guidelines, policies, or standards.

Heavy Vehicles
(Trucks and
Buses)
A project fails to provide adequate accommodation of forecasted heavy traffic or temporary construction-related truck traffic consistent with Town or industry standards (Highway Design Manual, MUTCD, etc.).

Off-Site Traffic
Operations
95th percentile vehicle queues exceed the existing or planned length of a turn pocket. The proposed project introduces a design feature that substantially increases safety hazards.

Signalized
Intersection Traffic
Control
Addition of project traffic causes a signalized intersection to 1) drop more than one level overall or at the worst individual approach delay if it is at LOS A, B, or C or 2) drop at all overall or at the worst individual approach delay if it is at LOS D or below.

Unsignalized
Intersection
Traffic Control
Addition of project traffic causes an all-way stop-controlled or side street stop-controlled intersection to 1) operate at LOS E or F overall or the worst-case movement, and 2) meets the Caltrans signal warrant criteria.

General Plan
Consistency
Evaluate the project against mobility, safety, and other related goals, policies, and actions set forth in the latest General Plan.

Other Subject
Areas
Consider other areas on a case-by-case basis (e.g., construction impacts, queuing between closely spaced intersections, emergency access, special event traffic, etc.).

Requirements
for Other
Jurisdictions
The project exceeds established deficiency thresholdsfor transportation facilities and services under the jurisdiction of other agencies.

5.10 CMP Deficiency Criteria
To determine consistency with the CMP, off-site intersection analysis may be needed and should be applied according to the latest VTA TIA Guidelines.

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5.11 Mitigation Improvements
All project deficiencies should be addressed consistent with the policies of the latest General Plan Mobility Element. Under these circumstances, the applicant should meet with Town staff to identify transportation improvements that address the deficiencies. Table 6 shows example types of improvements to address transportation deficiencies.

Potential improvements may require a more detailed review, often including traffic operations, to demonstrate how they address a specific deficiency.

Selected improvements should be identified whether they will be implemented under Existing Conditions, Background Conditions, or Cumulative Conditions. Background Conditions generally reflect conditions at the time of full occupancy of a project.

If a transportation improvement is selected to address a deficiency, it should include a description of the benefit to traffic reduction generated by a proposed development and how the improvement contributes to the multimodal transportation system in Los Gatos. In addition, all transportation improvements need to consider whether they have secondary effects to VMT [i.e., whether the improvement is VMT inducing per guidance in the OPR Technical Advisory (December 2018, Pages 20-21)].

The improvement shall not unreasonably degrade bicycle, pedestrian or transit access, and circulation. If a project proposes improvements in response to auto LOS deficiency involving a change to existing roadway or intersection geometry, or changes to signal operations, the TA shall analyze and disclose secondary effects on other modes, i.e., whether the mitigation would affect pedestrian or bicycle conditions or increase transit vehicle delay, per the methodologies in 5.7.

Table 6: Example Improvements
Study Element Improvement
Project Modifications
and Transportation
Demand Management
• Alter density or diversity of project uses or integrate affordable housing
• Encourage telecommuting and alternative work schedules • Provide ride-sharing programs to encourage carpooling and vanpooling
• Provide local shuttle service
• Provide employer-sponsored vanpools or shuttles
• Provide pedestrian network improvements
• Provide traffic calming measures and low-stress bicycle network improvements
• Implement car-sharing (e.g., ZipCar) program
• Limit parking supply
• Unbundle parking costs from property costs
• Institute on-street market pricing for parking

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Pedestrian and Bicycle
Facilities
• Provide for access to, from, and through the development for pedestrians and bicyclists
• Construct Class I bicycle paths, Class II bicycle lanes, and other facilities
• Provide secure bicycle parking and shower amenities
• Reduce travel lanes on a street to install a two-way left-turn lane and Class II bicycle lanes
• Add corner bulbouts, reduce curb radii, add pedestrian refuges, or implement other walking-related improvements Transit Facilities
• Provide bus turnouts, bus shelters, additional busstops, and park-and-ride lots
• Fund increases in transit service
Parking Facilities
• Design parking facilities to allow free-flow accessto and from the street
• Provide off-street parking per Town standards or
recommendations
• Implement shared parking among complementary land uses Traffic Control
Modifications
• Provide for yield or stop control
• Evaluate unsignalized intersections with substandard LOS for conversion to roundabout intersection control or
for signalization
• Provide coordination/synchronization of traffic signals along a corridor
• Provide turn-lane channelization through raised islands • Restrict selected turning movements
StreetOperations
Modifications
• Optimize location of access driveway(s)
• Provide improvementsto traffic signal phasing, or lengthen existing turning pocket
• Provide additional through traffic lane(s), right-turn lane(s), and left-turn lane(s) if they do not adversely impact other modes or induce additional vehicle travel
• Reduce travel lanes on a street to install a two-way left-turn lane
• Address congestion pricing on roads or within a specific area

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Appendix A: Transportation Analysis Report FormatOutline Note: Not all sections are required for all projects. The project applicant shall consult with the Town Traffic Engineer to determine the required sections.

1. Introductory Items
• Front Cover/Title Page
• Table of Contents, List of Figures, and List of Tables • Executive Summary

2. Introduction
• Project description
• Project sponsor/contact info
• Type and size of development
• Site plan (include proposed driveways, roadways, traffic control, parking facilities, emergency vehicle access, and internal circulation for vehicles, bicyclists, and pedestrians)
• Location map (include major streets, study intersections, and neighboring zoning and land uses)
• Scope of transportation analysis

3. Current Conditions
• Description of existing street system within project site and surrounding area • Location and routes of nearest public transit system serving the project • Location and routes of nearest pedestrian and bicycle facilities serving the project • Vehicle Miles Traveled Assessment
o Description of baseline VMT estimates (may include site and regional VMT estimates)
• Intersection Analysis for Site Access and Circulation Evaluation and CMP Evaluation o Figure of study intersections with peak hour turning movement counts, lane geometries, and traffic control

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o Map of study area showing average daily traffic (ADT) of study roadways o Table of existing peak hour average vehicle delay and level of service (LOS)

4. Project Trip Generation
• Table of project generated trip estimate
• Figure/map of trip distribution (in percent)

5. Project Site Access and Circulation Evaluation
• Summary of a detailed site review for all modes of travel • Mobility deficiency analysis and summary to vehicle, transit, bicycle, and pedestrian facilities (under Project Conditions and Cumulative Conditions) • Summary of transportation improvements
CEQA Transportation Analysis Report Section

6. Vehicle Miles Traveled Assessment
• Summary of project generated VMT under Baseline Conditions • Summary of project’s effect on VMT under Future Year Cumulative Conditions • Identification of significant impacts
• Discussion of mitigation measures
• Evaluation of impacts of mitigation measures

7. Other CEQA Requirements
• Summary of conflicts with a plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian paths. Present mitigation measures, as needed.
• Evaluation of hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). Present mitigation measures, as needed.
• Emergency access evaluation. Present mitigation measures, as needed.

Local Transportation Analysis Report Section

8. Existing with Project Conditions

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• Maps of study area with applicable peak hour turning movements (Project Only and Existing with Project Conditions)
• Table of Existing Conditions and Existing with Project Conditions intersection peak hour average vehicle delay and LOS (or other multimodal performance measure)
• Traffic signal and other warrants
• Changes/Deficiencies to bike, pedestrian, and transit networks • Findings of project deficiencies
• Improvementsfor project deficiencies (include a map showing physical improvements)
• Scheduling and implementation responsibility of improvements • Deficiencies of proposed improvements

9. Background Conditions
• Table of trip generation for approved project(s)
• Figure and/or table of approved projects trip distribution (in percent) • Map of study area with applicable peak hour turning
movements (Background Conditions)
• Table of intersection peak hour average vehicle delay and LOS (or other multimodal performance measure) (including queue
lengths, etc)
• Changes/deficiencies to bike, pedestrian, and transit networks • Traffic signal and other warrants

10. Background with Project Conditions
• Similar content to Existing with Project Conditions

11. Cumulative Conditions and Cumulative with Project Conditions • Map of study area with Cumulative Conditions peak hour turning movements
• Map of study area with Cumulative with Project Conditions peak hour turning movements
• Table of Cumulative Conditions and Cumulative with Project Conditions intersection peak hour average vehicle delay and LOS (or other multimodal performance measure)
• Changes/Deficiencies to bike, pedestrian, and transit networks • Traffic signal and other warrants
• Findings of project deficiencies
• Improvementsfor project deficiencies (include a map showing physical improvements)
• Scheduling and implementation responsibility of improvements • Deficiencies of proposed improvements

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Additional Sections for Transportation Analysis Report

12. Construction Deficiencies
• Trips due to construction workers
• Truck trips and truck access routes

13. Phasing Deficiencies (For Large Projects Only)

14. Appendices
• List of references
• List of authors
• Pedestrian, bicycle, and vehicle counts
• Technical calculations for all analyses

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EXHIBIT A to ATTACHMENT 1
Attachment 2 - Transportation Mitigation Improvements Project List ID Project Name Category Description
Cost Estimate
($2024)
Estimated
Funding from
Other Sources
Unfunded Cost
or Town Share
1 State Route 17 Corridor Congestion Relief Project 1 Safety and Capacity Improvements Ÿ Modify the SR 17/SR 9 interchange’s on- and off-ramps Ÿ ŸImplement advance transportation technology
Ÿ Install traffic signals control system, traveler information system, and ramp meters $ 171,600,000 $ 154,440,000 $ 17,160,000 2 Shannon Rd Widening and Safety Improvements BPMP Priority Projects Add shoulders and retaining wall between Santa Rosa Drive and Diduca Way.
3 Union Avenue Widening and Sidewalks BPMP Priority Projects Add sidewalks and bike lanes between Blossom Hill Road to Lynne Ave $ 4,413,397 $ - $ 4,413,397
4 Traffic Signal Modernization Program Traffic Signal
Smart Signals Project will modernize and upgrade the Town’s traffic signals/communications equipment to provide realtime data for the advanced traffic management and adaptive traffic control systems $ 30,000,999 $ - $ 30,000,999
5 Highway 17 Bicycle & Pedestrian Overcrossing BPMP Priority Projects Overcrossing of SR-17 south of Blossom Hill Road $ 30,160,000 $ 4,457,880 $ 25,702,120 6 Kennedy Sidewalk & Bike Lanes BPMP Priority Projects
Add sidewalks and Class II bicycle lanes from Los Gatos Bld to Englewood Ave $ 3,389,360 $1,872,990 $ 1,516,370
7 Sidewalk Gap Filling Projects Other BPMP Projects - New Facilities Fill gaps in sidewalks, multiple locations on Town-wide circulation network $ 820,741 $ - $ 820,741
8 New and Expanded Bicycle and Pedestrian
Facilities (Non Priority Projects) Other BPMP Projects - New Facilities Construct new bicycle lanes, cycle tracks and multiuse paths $ 6,284,007 $ - $ 6,284,007 9 Los Gatos Almaden Road Complete Streets
Improvements Complete Streets (Carryover)
Fill gaps in sidewalks between Peach Blossom Lane and
Camino del Cerro $ 4,413,397 $ 4,413,397
10 Los Gatos Boulevard Multimodal Widening Complete Streets (Carryover) Add sidewalks and bicycle lanes between Samaritan Drive and Camino Del Sol $ 726,960 $ 726,960
11 Parking Program Implementation Lighting and Signage Add lighting, signage, and other project elements $ 416,000 $ 416,000 12 Bicyle and Pedestrian Improvements Program -
Safety Improvements
Other BPMP Projects - Bicyclist and
Pedestrian Safety
High visibility crosswalks, midblock crossings, pedestrian beacons, and other project elements on Town-wide
circulation network $ 1,060,123 $ - $ 1,060,123
13 Priority Projects from Bicycle and Pedestrian
Master Plan BPMP Priority Projects
Work towards implement priority projects from BPMP as
feasible $ 96,175,611 $ - $ 96,175,611
14 Blossom Hill Road/Belgatos Signal Traffic Signal New Signal $ 1,511,120 $ - $ 1,511,120 15 Los Gatos Blvd/Burton Traffic Signal Signal Upgrade $ 709,280 $ - $ 709,280 16 University/Andrews Signal Traffic Signal Signal Upgrade $ 1,349,920 $ - $ 1,349,920 $ 353,030,916 $ 160,770,870 $ 192,260,046

ITEM NO. 14.

TITLE: Transportation Impact Policy
Attachment 3 -VMT Reduction Strategies
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EXHIBIT A to ATTACHMENT 1
Attachment 3 - VMT REDUCTION STRATEGIES
For projects that would generate Vehicle Miles Traveled (VMT), one or more VMT reduction strategies shall be required to reduce VMT of the project. Examples of VMT reduction strategies are provided below. The VMT reduction strategies are organized by their relative scale for implementation (i.e., individual site level, Town-wide level, and regional level).

INDIVIDUAL SITE LEVEL
 Encourage Telecommuting and Alternative Work Schedules: This strategy relies on effective internet access and speeds to individual project sites/buildings to provide the opportunity for telecommuting. This strategy would reduce commute VMT but also result in a change in VMTfor other travel purposes; thus, this strategy should consider the net change in the Town’s project-generated VMT.
 Provide Ride-Sharing Programs: This strategy focuses on encouraging carpooling and vanpooling by project site/building tenants.
 Implement Car-Sharing Program: This strategy reduces the need to own a vehicle or reducesthe number of vehicles owned by a household by making it convenient to access a shared vehicle for those trips where vehicle use is essential. Examples include programs like ZipCar,Car2Go, and Gig.
 Provide Employer-Sponsored Vanpool/Shuttle: This strategy relies on employers purchasing orleasing vans or shuttles, and often subsidizing the cost of at least program administration, if notmore. Vanpools typically service employee’s commute to work, while shuttles service nearby transit stations and surrounding commercial centers.

Scheduling and rider charges, if any, are within the employer’s purview. A supplemental strategy may include facilitating or enhancing the service by improving the shuttle stops and biking/walking paths to the stops.

TOWN-WIDE LEVEL
 Provide Bicycle and Pedestrian Network Improvements: This strategy focuses on creating a comprehensive bicycle and pedestrian network within the project and connecting to nearby destinations. Projects in Los Gatos tend to be smaller so the emphasis of this strategy would likely be the construction of network improvements that connect the project site directly to nearby destinations. Alternatively, implementation could occur through an impact fee programor benefit/assessment district based on regional or local plans such as the Bicycle and Pedestrian Master Plan.  Provide Local Transit or Microtransit Solutions: This strategy focuses on providing transit solutions that serve the local circulation needs and connections to key regional destinations. The service would connect to transit hubs, schools, commercial centers, and residential areas to improve transit connectivity and address the “first/last mile”

ITEM NO. 14.

TITLE: Transportation Impact Policy
Attachment 3 – VMT Reduction Strategies
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problems. The service may be in the form of a local shuttle, microtransit service using dynamic routing and scheduling, fare subsidies to private transportation network companies (TNCs) or taxi companies, or other service delivery methods. The service may be open to all or target a special population, such as seniors, disabled or students. The implementation of this strategy may require regional or private partnership.  Provide Transit Signal Priority: This strategy would upgrade the Town’s traffic signals along transit corridors to provide transit signal priority to improve transit bus travel time.
 Improve Biking and Walking Paths to Bus Stops and Transit Amenities: This strategy improves the biking and walking paths to bus stops, enhances amenities at bus stops such as shelters, benches, and ADA accessible loading areas.  Provide Traffic Calming Measures: This strategy combines the California Air Pollution Control Officers Association (CAPCOA) research focused on traffic calming with new research on providing a low-stress bicycle network. Traffic calming creates networks with low vehicle speeds and volumes that are more conducive to walking and bicycling.

Building a low-stress bicycle network produces a similar outcome. One potential change in this strategy over time is that ebikes (and e-scooters) could extend the effective range of travel on the bicycle network,which could enhance the effectiveness of this strategy.
 Limit Parking Supply: When combined with companion TDM measures, reduced parking supplydiscourages driving by limiting easy and convenient parking options.

Implementation of this strategy may require reducing (or removing) minimum parking requirements and allowing developers to use shared parking strategies.  Unbundle Parking Costs from Property Cost: Unbundling separates parking costs from propertycost, for instance by not including a parking space in a residential unit’s rent, or by requiring employers to lease each parking space separately from the building owner.

This strategy ensures that the user understands that the cost of driving includes parking and can encourage people to use an alternative mode to save money.  Implement Market Price Public Parking (On-Street): This strategy focuses on implementing a pricing strategy for parking by pricing all on-street parking in central business districts, employment centers, and retail centers. Priced parking would encourage “park once” behaviorand may also result in area-wide mode shifts.

REGIONAL LEVEL
 Increase Density: This strategy focuses on increasing density of land uses, where allowed by the General Plan and/or Zoning Ordinance, to reduce distances people travel and provide more travel mode options. This strategy also provides a foundation for many other strategies. For example, densification increases transit ridership, which justifies enhanced transit service.
 Increase Diversity of Urban and Suburban Developments: This strategy focuses on

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Attachment 3 – VMT Reduction Strategies
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inclusion of mixed uses within projects or in consideration of the surrounding area to minimize vehicle travelin terms of both the number of trips and the length of those trips.  Increase Transit Accessibility: This strategy focuses on encouraging the use of transit by locating a project with high density near transit. A project with a residential/commercial center designed around a bus station is referred to as a transit-oriented development (TOD).
 Integrate Affordable and Below Market Rate Housing: This strategy provides greater opportunities for lower income families to live closer to job centers since income effectsprobability that a commute will take transit or walk to work.  Increase Transit Service Frequency/Speed: This strategy focuses on improving transit service convenience and travel time competitiveness with driving. Given existing land use density in LosGatos, this strategy may be limited to traditional commuter transit where trips can be pooled at the start and end locations, or it may require new forms of demand-responsive transit service. Note that implementation of this strategy would require regional or local agency implementation, substantial changes to current transit practices, and would not likely be applicable for individual development projects.  Implement Area or Cordon Pricing: This strategy focuses on implementing a cordon (i.e., boundary) pricing scheme, where a cordon is set around a specific area to charge a toll to enterthe area by vehicle. The cordon location is usually the boundary of an area with limited points of access. The cordon toll may be constant, applied during peak periods, or be variable, with higher prices during congestion peak periods. The toll can also be based on a fixed schedule or be dynamic, responding to real-time congestion levels. Note that implementation of this strategy requires alternative modes of travel that are available and reliable, such as high-qualitytransit infrastructure.

ITEM NO. 14.

TITLE: Transportation Impact Policy
Attachment 4 -Definitions
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EXHIBIT A to ATTACHMENT 1
Attachment 4 - DEFINITIONS
Land use entitlements shall mean entitlement changes in use requiring discretionary approval by Los Gatos, which include General Plan amendments, specific plans (and related amendments), zoning changes, use permits, planned developments, and tentative subdivision maps.

Land Use Projects or Development shall mean residential or nonresidential improvements on a site.

Existing development shall mean any already existing habitable residential or nonresidential building or projects which rebuild or remodel the existing development without increasing the trips generated. No fee shall be charged for development already existing.

Expansion of use, to determine traffic increases, shall include any increase in the number of living units, gross floor area in a nonresidential development and/or any intensification of use which increases trips generated.

Transportation improvements shall mean those improvements to the transportation facilities and related actions necessary to implement the transportation element of the Town's general plan and any applicable specific plan.

Site shall mean a plot of ground consisting of one (1) or more lots or parcels on which a common improvement is proposed or exists.

Trip generation rate shall mean the number of vehicle trips over a weekday twenty-four-hour period generated by a particular type of land use and shall be expressed in terms of the number of acres or square feet of land for each land use category. The Town Engineer may exercise reasonable discretion to establish recommended trip generation rates for land use categories consisting of groupings of land uses having similar use and functional characteristics. When the trip generation rate is multiplied by the amount of land, the number of trips, both incoming and outgoing, shall be estimated.

Average Daily Trips (ADT) shall mean the total number of trips, both in-bound and out-bound, within a 24-hour weekday period, generated by a particular use or development.

Pass-By Trip: Trips generated by the proposed Project that would be attracted from traffic passing the proposed project site on an adjacent street that contains direct access to the Project.

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TITLE: Transportation Impact Policy
Attachment 4 – Definitions
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Peak Hour Trips shall mean vehicle trips, both in-bound and out-bound, occurring during a 60- minute period either during the A.M. Peak (7 A.M. to 9 A.M.) or the P.M. Peak (4 P.M. to 6 P.M.), generated by a particular use or Project.

Specialty Retail. Specialty Retail uses are defined as walk-in and impulse businesses such as juice bars, yogurt shops, coffee shops, donut shops, and similar uses which do not generally serve meals and have limited or no seating. Specialty Retail uses are defined under this policy for purposes of establishing trip generation data and this definition does not provide any land use or zoning guidance.

Use shall mean the purpose for which a site or structure is arranged, designed, intended, constructed, erected, moved, altered or enlarged or for which either a site or a structure is or may be occupied or maintained.

Vehicle Trip End shall mean an incoming or outgoing trip going to or coming from anywhere within the Town or outside the Town.

CEQA shall mean the California Environmental Quality Act. These terms are reserved for definitions per the CEQA Guidelines: significance criteria, significant impact, and mitigation measures.

Local Transportation Analysis shall mean analysis to assess potential mobility deficiencies caused by new developments on the local roadway performance, following the Town’s transportation policies. These terms are reserved for Local Transportation Analysis: threshold or performance standard, deficiency, and mitigation improvement.

Vehicle Miles Traveled (VMT) is a metric that accounts for the number of vehicle trips generated times the length or distance of those trips. VMT is an accessibility performance metric that evaluates the changes in land use patterns, regional transportation systems, and other built environment characteristics.

Level of Service (LOS) is a metric that assigns a letter grade to network performance. The typical application is to measure the average amount of delay experienced by vehicle drivers at an intersection during the most congested time of day and assign a report card range from LOS A (fewer than 10 seconds of delay) to LOS F (more than 80 seconds of delay). Vehicle level of service is used to measure vehicle mobility.

ITEM NO. 14.

ATTACHMENT 2

COUNCIL POLICY MANUAL
TITLE: Transportation Impact Policy POLICY NUMBER: 1-08 EFFECTIVE DATE: January 4, 1988 PAGES: 11
ENABLING ACTIONS: 1991-174; 2014-017,
2016-068; 2017-011
REVISED DATES: 8/5/91; 3/24/14; 12/6/16;
3/21/17; 12/07/2021; 09/16/2025
APPROVED:

PURPOSE
To provide guidance to Town staff and the development community in implementing the provisions of the Town Municipal Code, Chapter 15, Article VII, Traffic Impact Mitigation Fees, and evaluating and mitigating California Environmental Quality Act (CEQA) transportation impacts.

SCOPE
This Policy is applicable to all land use entitlements, land use projects, and transportation improvements Town-wide.

POLICY
I. GENERAL CONDITIONS AND APPLICABILITY

1. Projects that are determined by the Town to generate one or more new net Average Daily Trips (ADT) are subject to this Policy.

2. An Accessory Dwelling Unit (ADU) of less than 750 square feet shall be exempted from the requirements of Transportation Analysis and the Traffic Impact Fees. ADU’s of 750 square feet or greater shall be charged proportionately in relation to the square footage of the ADU to the square footage of the primary dwelling unit. (

3. The Town Council may exempt housing developments for very low, low, and moderate income residents (as defined by Town Ordinance, General Plan, or statute) from all or a portion of the traffic impact mitigation fee upon making a finding that the development Small Town Service Community Stewardship Future Focus

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provides a significant community benefit by meeting current needs for affordable housing.

4.3. Attachment 1 - Transportation Analysis (TA) Guidelines establish a process to comprehensively and accurately analyze potential project effects (adverse and beneficial) on transportation facilities and services in the Town of Los Gatos and other jurisdictions. The TA Guidelines serve three primary purposes:
• Provide an evaluation for the California Environmental Quality Act (CEQA) significant impacts and mitigation as a part of the environmental analysis process. • Evaluate a project’s consistency with the Town’s General Plan. • Evaluate a project’s consistency with the Santa Clara County Congestion Management Program (CMP).

II. TRANSPORTATION IMPACT FEES

1. All Projects that generate one or more new Average Daily Trips (ADT) as calculated based on the ITE trip generation manual are required to pay Transportation Impact Fees, previously known as Traffic Impact Mitigation Fees.

2. All required Transportation Impact Fees shall be paid in full to the Town in association with and prior to issuance of a building permit, unless otherwise required by law. If no building permit is required, the fee shall be paid in full prior to issuance of a certificate of use and occupancy, or similar entitlement. Unless otherwise required by law, tThe amount due shall be calculated based on the fee in place as approved by the Town Council by resolution at the time the fee is paid.

3. The per trip amount of the fee shall be as set forth by the Town Council by resolution, pursuant to Town Municipal Code, Chapter 15, Article VII, Traffic Impact Mitigation Fees.

4. Fees shall be calculated by multiplying net new ADT by the per trip amount in place at the time the fees are paid.

5. Credit against Transportation Impact Fees due shall be granted for projects shown on the tTown of Los Gatos Transportation Improvements list (Attachment 2) up to the amount of the Estimated Project Cost shown on Attachment 2actual reasonable expenditure based on receipts submitted to the Town and as approved by the Town Engineer., Town of Los Gatos Traffic Mitigation Improvements Project List, Credit may be applied fofor any listed projects for which the developer, as a condition of approval, is required to either construct at the developer's sole cost or contribute a fixed or percentage amount of funding toward future construction of

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the listed improvement. Where construction is fully funded and completed by the developer, said credit shall be equal to the Project Cost as shown in Attachment 2.

Where payment is a fixed amount or a percentage of Project Cost, credit shall be equal to the actual amount due, whether the project is constructed by the developer or others.

6. No credit shall be given for any public right-of-way dedication required for completion of projects not listed on Attachment 2.

7. Credit for existing development shall be determined by trips generated at the site at the timewithin three years of entitlement application to the Community Development Department. Properties not generating trips at the timewithin 3three years of application will not receive credit. Underutilized property or properties not generating a typical amount of trips for the existing unit type may receive a reduced credit based on actual trips generated. All credits under this section shall be at the discretion of the Town Engineer.

8. A fifty percent (50%) credit will be issued for all hHousing units deed restricted for extremely low- and very low-income categories shall pay a fee at 50% of the rate of the fee that would otherwise be required for the unit. Extremely low- and very-low income categories will be as defined by the County of Santa Clara. Prior to issuing any credit on the fee tThe Community Development Director shall provide verification that the appropriate deed restrictions have been filed before permitting the project to pay the lower fee.

7.9.Credit will be given on a case-by-case basis and shall not exceed the impact fee payable. Any request for credit shall be made prior to the payment of the Transportation Impact Fees. No credit shall be given for installation of Townstandard frontage improvements, Project access improvements, or internal circulation improvements.

8.10. Credit shall only be granted for payment of costs or construction of projects listed in Attachment 2, unless otherwise approved by the Town Council.

III. VEHICLE MILES TRAVELLED (“VMT”) MITIGATION MEASURES

1. To mitigate VMT environmental impacts, the project shall be conditioned for implementation of mitigation measures in the following categories:
• Modify the project’s built environment characteristics to reduce VMT generated by the project;

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• Implement transportation Demand Management (TDM) measures to reduce VMT generated by the project; and/or
• Participate in a VMT fee program and/or VMT mitigation exchange/banking program (if they exist) to reduce VMT from the project or other land uses to achieve acceptable levels.

2. The Town is taking a Townwide approach for VMT impact mitigation. Attachment 3, VMT Reduction Actions for the Town of Los Gatos, provides a framework for mitigating VMT in the Town.

APPROVED AS TO FORM:

Robert SchultzGabrielle Whelan, Town Attorney

ITEM NO. 14.

TITLE: Transportation Impact Policy
Attachment 1 – Transportation Analysis Guidelines
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Town of Los Gatos
Transportation Analysis Guidelines
Table of Contents

1.Introduction.......................................................................................................................... 1

1.1 Intent of TA Guidelines.................................................................................................. 1

1.2 Environmental Evaluation.............................................................................................. 2

1.3 Project Types................................................................................................................... 2

1.4 CEQA and Non-CEQA Terminology ................................................................................. 3

2.Determining the Level of Transportation Analysis................................................................ 3

2.1 CEQA Relief for Projects Consistent with General Plan or Zoning ................................. 4

2.2 CMP Consistency Screening............................................................................................. 4

2.3 Recommended Process and Documentation ................................................................. 4

2.4 Contact with Appropriate Town Staff............................................................................. 4

2.5 Consultation with Other Jurisdictions ............................................................................ 5

2.6 Project Trip Generation and Trip Reductions................................................................. 5

2.6.1 Vehicle Trips............................................................................................................. 6

2.6.2 Person Trips ............................................................................................................. 6

2.6.3 Establishing Trip Generation Rates for an Unspecified Use................................... 6

2.6.4 Credit for Existing Trips – Local Analysis................................................................. 6

2.6.4 Credit for Existing Trips – VMT Analysis .................................................................. 7

2.7 Vehicle Miles Traveled Methods .................................................................................... 7

3.Transportation Analysis (CEQA) for Land Use Projects ........................................................ 8

3.1 VMT Analysis Methods .................................................................................................. 8

3.1.1 Regional Transportation Plan/Sustainable Communities Strategy and General Plan Consistency ...9

3.1.2 VMT Assessment.................................................................................................... 9

3.2 VMT Significance Thresholds...................................................................................... 11

3.3 VMT Mitigation Measures.......................................................................................... 11

4. Transportation Analysis (CEQA) for Transportation Projects........................................... 12

5. Transportation Analysis per the Town’s Transportation Policies .................................... 13

ITEM NO. 14.

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Attachment 1 – Transportation Analysis Guidelines
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5.1 Study Area...................................................................................................................... 13

5.2 Key Study Elements........................................................................................................ 13

5.3 Data Collection............................................................................................................... 14

5.4 Project Site Access and Circulation Review ................................................................... 16

5.5 Analysis Scenarios.......................................................................................................... 16

5.6 Analysis Time Periods .................................................................................................... 17

5.7 Multimodal Analysis Methods....................................................................................... 18

5.8 Traffic Operations Analysis............................................................................................ 19

5.9 Mobility Deficiency Criteria ........................................................................................... 19

5.10 CMP Deficiency Criteria ............................................................................................... 20

5.11 Mitigation Improvements............................................................................................ 21

ITEM NO. 14.

TITLE: Transportation Impact Policy
Attachment 1 – Transportation Analysis Guidelines
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1. Introduction
Transportation Analysis (TA) Guidelines are routinely established by jurisdictions to assess potential transportation effects of proposed projects on the local transportation system. These guidelines are intended to provide a clear and consistent technical approach to evaluating both land use and transportation infrastructure projects within Los Gatos.

These guidelines establish a process to comprehensively and accurately analyze potential project effects (adverse and beneficial) on transportation facilities and services in the Town of Los Gatos and other jurisdictions. This information is essential for decision-makers and the public when evaluating land use development and transportation infrastructure projects. These TA Guidelines serve three primary purposes:
• Provide an evaluation for the California Environmental Quality Act (CEQA) significant impacts and mitigation as a part of the environmental analysis process. • Guide the Local Transportation Analysis in evaluating a project’s consistency with the Town’s General Plan Mobility Goals.
• Evaluate a project’s consistency with the Santa Clara County Congestion Management Program (CMP).

1.1 Intent of TA Guidelines
The Town of Los Gatos General Plan 2040 seeks to “provide a well-connected transportation system that enables safe access for all transportation modes, including pedestrians, bicyclists, motorists, and transit riders of all ages and abilities.” The TA Guidelines support this goal by evaluating new projects against the policies of the latest General Plan.

For CEQA-based environmental analysis, these TA Guidelines incorporate the use of vehicle miles traveled (VMT) to disclose the effects of the project on the surrounding environment. Town staff completed an SB 7431 implementation process, which included the preparation of the SB 743 Implementation for the Town of Los Gatos (July 2020) document package. The document package provides detailed technical information pertaining to the options and data considered by the Town of Los Gatos to implement VMT as an impact criterion.

The TA Guidelines present the Town’s approach for determining the need for a transportation analysis, its content, and identifying acceptable transportation improvements for land use and transportation projects proposed within Los Gatos. The TA Guidelines establish a transportation analysis protocol for the following:
1 Senate Bill 743 (SB 743) changed some of the transportation significance criteria under the California Environmental Quality Act (CEQA) CEQA. Specifically, vehicle level of service (LOS) is no longer used as a determinant of significant environmental impacts, and a vehicle miles traveled (VMT) analysis is required.

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1 • Environmental analysis
• General Plan consistency
• Congestion Management Program (CMP) evaluation
• Mobility deficiency criteria and thresholds
• Guidance on acceptable transportation improvements
Town staff will review transportation studies and reports based on the process presented in the TA Guidelines. However, each project is unique, and the TA Guidelines are not intended to be prescriptive beyond practical limits. Not all criteria and analyses described in the TA Guidelines will apply to every project. Early and consistent communication with Town staff is encouraged to confirm the type and level of analysis required for each study.

1.2 Environmental Evaluation
The TA Guidelines outline the methods and thresholds with which to evaluate projects consistent with the latest CEQA Statue & Guidelines.

The latest CEQA Statue & Guidelines include revised Appendix G Checklist questions for transportation impact evaluation. The four questions are as follows:

Would the project:
a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? d) Result in inadequate emergency access?

1.3 Project Types
A TA is prepared for a project before a discretionary action is taken. The following types of projects, which involve development activity or infrastructure changes in and around the Town of Los Gatos and affect the adjacent transportation system, should be evaluated for TA requirements. • Land use entitlements or changes in use requiring discretionary approval by Los Gatos, which include General Plan amendments, specific plans (and related amendments), zoning changes, use permits, planned developments, and tentative subdivision maps; or any modifications of use that would generate 20 or more new Peak Hour (vehicle) Trips or at the discretion of the Town’s Traffic Engineer
• Land use activity advanced by agencies other than Los Gatos that is subject to jurisdictional review under state and federal law, such as school districts, Santa Clara Valley Transportation Authority (VTA) Board of Directors, and others; or advanced within Los Gatos by agencies other than the

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Town and inconsistent with the Town’s General Plan.
• Transportation infrastructure modification or expansion, including capital improvement projects on Town roads, county roads, and state highways that may impact Town facilities and services.

1.4 CEQA and Non-CEQA Terminology
To distinguish the CEQA analysis from the non-CEQA analysis (i.e., the local transportation analysis) the analyses apply different terminologies as summarized below in Table 1.

Table 1: Comparison of Select CEQA and Non-CEQA Terms
CEQA Term Non-CEQA Term
CEQA Transportation Analysis Local Transportation Analysis Significance criteria Threshold or performance standard Significant impact Deficiency
Mitigation measure Mitigation improvement
Baseline Conditions Existing Conditions and Background
Conditions
Future Year Cumulative Conditions Cumulative Conditions

2. Determining the Level of Transportation Analysis
Unless explicitly waived by the Town, a TA may be required when any one of the following conditions is met.
• A project has the potential to create a significant transportation environmental impact under CEQA.
• A project has the potential to generate daily vehicle miles traveled greater than the Town’s General Plan future year VMT projections.
• For local transportation analysis, a project has the potential to generate 20 or more new Peak Hour (vehicle) Trips.
• A project that is not consistent with the development density established by existing zoning, community plan, or general plan policies for which an environmental impact report (EIR) was certified, per CEQA Statue & Guidelines Section 15183.
• A project will alter physical or operational conditions on a Town pedestrian facility, bicycle facility, transit facility or service, or other transportation facility. • An Accessory Dwelling Unit (ADU) of 750 square feet or smaller shall be exempted from the requirements of Transportation Analysis and the Transportation Impact Fees.

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In general, a TA is applicable for two to five years. After two or more years of inactivity, a TA may need to be updated to reflect changes in the study environment, including traffic growth and other circulation issues.

Nothing in the Transportation Impact Policy shall prohibit or restrict a Project applicant from completing a local transportation study for a Project anticipated to generate less than 20 new Peak Hour trips.

2.1 CEQA Relief for Projects Consistent with General Plan or Zoning Per CEQA Statue & Guidelines Section 15183, projects consistent with a general plan, zoning action, specific plan, and certified environmental impact report (EIR) would not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects.

Additionally, projects consistent with a general plan, zoning action, or specific plan where cumulative impact(s) were adequately addressed in a prior EIR would not require further CEQA transportation analysis. As noted below, projects consistent with the Town’s General Plan, as determined by the Community Development Director, will not be required to do any VMT Analysis since the Town is taking a Townwide approach for VMT impact mitigation.

2.2 CMP Consistency Screening
Projects should reference the most recent VTA Transportation Impact Analysis (TIA) Guidelines to determine the need for a transportation impact analysis. In most cases, projects that generate fewer than 100 net new peak hour vehicle trips are not required to conduct VTA’s CMP transportation analysis.

2.3 Recommended Process and Documentation
In coordination with Town staff, the project applicant shall retain a transportation professional to conduct the TA. The transportation consultant should seek Town acceptance of the scope of work before initiating the analysis. In some cases, review by other affected jurisdictions will be required. Appendix A:

Transportation Analysis Report Format Outline contains a recommended outline for the TA document.

Each TA will begin by preparing a scope of work that describes the project description, site location, analysis methods, area-wide assumption, study elements, study time periods, and traffic data collection methods. To finalize a TA scope of work for the local transportation analysis, the project applicant will provide an estimate of the project trip generation and trip distribution . These estimates and scope of work should be shared with Town staff to finalize the scope of services. Overall, the TA report will address:
1) environmental analysis, 2) project site access and circulation, and 3) other transportation impacts and traffic deficiencies.

2.4 Contact with Appropriate Town Staff
To minimize the potential for delays in project processing, it is important for the TA to be prepared in coordination with Town staff. Timely coordination will also ensure that potential transportation improvements and environmental consequences are considered as early as possible in the planning process, as deficiencies and corresponding improvement costs can have a substantial effect on project costs. Coordination should include the following:

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• A pre-application meeting, which will include a discussion of the TA requirements. • Development of an approved scope of work, which includes trip generation, study area, analysis scenarios and parameters, data requirements, and provisions for pedestrians, bicyclists, and transit users.
• Approval of the project trip generation (person and vehicle) and trip distribution. • Review of all assumptions and the results of Existing Conditions analysis. • Review of the administrative draft report, with adequate time for comments. • Review of a draft report, with adequate time for comments.

If the TA report information will be incorporated into the transportation and circulation section of an environmental document (e.g., Initial Study, Mitigated Negative Declaration, or Environmental Impact Report), the format of this report may need to be discussed with the environmental consultant, a peer reviewer, and/or Town staff. Upon circulation of the draft environmental document, the format of the final TA report may need to be discussed with the environmental consultant.

2.5 Consultation with Other Jurisdictions
If the study area overlaps with other jurisdictions, staff from other jurisdictions must be consulted to verify study locations, the impact significance criteria, and to consider any current development applications. Section 15086 of the CEQA Statue & Guidelines22 shall be followed as the basis for satisfying consultation requirements. In most cases, overlap will occur for roadway system analysis, but may also include impact analysis of active transportation modes (bicycling and walking), as well as transit system facilities and services.

2.6 Project Trip Generation and Trip Reductions
Person and vehicle trip generation rates are a way to estimate the number of expected pedestrian, bicycle, transit, and vehicle trips that a proposed development will generate. These rates establish the basis of analysis for a proposed project and its effects on the transportation network. Person trip generation should be reported for walking, bicycle, and pedestrian trips, and vehicle trip generation should be reported for single-occupant, and carpool.

Methodologies to estimate project trip generation and trip reductions shall be prepared consistent with the latest VTA TIA Guidelines, with the exceptions described in this document. 2 California Environmental Quality Act Statute & Guidelines, 2020.

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2.6.1 Vehicle Trips
Consistent with the VTA TIA Guidelines, pass-by trips shall not be considered in calculating the 20 new Peak Hour Trip threshold that triggers the requirement for conducting a comprehensive local transportation analysis report.

The Institute of Traffic Engineers (ITE) Trip Generation Manual trip generation rates for Specialty Retail Center shall apply to all Specialty Retail.

Uses within the Central Business District (C-2 Zone} are expected to change periodically as part of the natural business cycle. For the purpose of Transportation Impact Fees, changes in use without changes in net building square footage within the C-2 Zone shall not be considered to create a traffic deficiency, shall be exempt from this policy, and no fees shall be charged for a change in use. Any increases in building square footage shall pay impact fees at the ITE Shopping Center rate or comparable equivalent rate for the expanded area, as determined by the Town Traffic Engineer.

The Town reserves the right to require the project sponsor to conduct local trip generation surveys for select projects, depending on land use and conditions in the field.

2.6.2 Person Trips
Person trip generation rates should be developed from empirical studies, person travel survey data, or conversion of vehicle trip rates to person trip rates using a vehicle occupancy factor. In addition, person trip generation by mode may be derived using an approved analysis tool that incorporates data from local trip generation surveys or published trip generation rate data.

2.6.3 Establishing Trip Generation Rates for an Unspecified Use For projects where the ultimate land use is not certain (for example, a large subdivision of flexible commercial-industrial parcels), there are two options for establishing the trip generation rates. • Option 1: Town staff will recommend the use of the highest traffic intensity among all permitted uses to establish traffic deficiencies.
• Option 2: Estimates can be made using a lower traffic intensity use if the Town and developer establish a maximum trip allowance. Once a proposed land use has been identified, then: 1) the subdivision trip generation allowance must be monitored by the Town as development occurs; and 2) the TA report may need to be updated.

2.6.4 Credit for Existing Trips – Local Analysis
The estimate of new trips generated by the proposed development project may include credit for trips associated with existing uses on the site. Uses are considered as existing if they are actively present on the project site at the time that data is gathered for the transportation impact analysis. Similarly, if a

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planned (but not constructed) use was already permitted for the site and an improvement(s) was identified and funded, the new TA only needs to assess the effects of additional trips above and beyond the trips for the permitted use. Additionally, certain commercial land uses attract vehicle traffic that currently exists on the roadway, rather than generating new trips.

Understanding there are permitted reductions that may be taken under the circumstances listed above, the Town requires that any reductions in project vehicle trip generation are applied according to the latest VTA TIA Guidelines.

In calculating new Peak Hour Trips for purposes of determining whether or not a TA report is required pursuant to this Policy, trip credit shall be granted for an existing use or the most recent former use.

In calculating new Average Daily Trips for purposes of determining the amount of the Transportation Impact Mitigation Fee due, trip credit shall be granted for an existing use or the most recent former use.

Where the property is vacant, the most recent former use shall be used.

Where a portion of the space is changing use, credit will apply to the proportionate square footage of the space under review.

Where the change in use results in fewer trips than the existing or former use, no credit or refund will be due the applicant.

2.6.4 Credit for Existing Trips – VMT Analysis
For the evaluation of vehicle miles of travel, VMT credit for the prior use depends on how the project changes the baseline condition, if the project sponsor had ownership and control of the previous land use, and the reason for stopping the previous land use. Baseline conditions are typically defined at the beginning of an environmental analysis and a CEQA analysis needs to isolate the effects of the project to clearly define the project’s effect on the baseline condition. To receive VMT credit, the project sponsor needs to demonstrate continuous ownership of site, with on-site occupancy paused only due to the redevelopment activity and not because of some economic or other condition outside the control of the project sponsor. However, this credit should only be applied to total project generated VMT and should not be included when calculating a VMT rate.

2.7 Vehicle Miles Traveled Methods
As noted, projects consistent with the Town’s General Plan, as determined by the Community Development Director, will not be required to do any VMT Analysis since the Town is taking a Townwide approach for VMT impact mitigation. Although the calculation of VMT is simply the number of cars multiplied by the distance traveled by each car, VMT performance measures can be reported differently.

At a minimum, the VMT analysis for Los Gatos will be prepared for two purposes:

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• Greenhouse gas and air quality analysis using project generated VMT on a VMT per service population basis (residents + employment).
• Environmental evaluation by land use and/or transportation project.

The project generated VMT from new population and employment growth and the boundary (total) VMT for a specific geographic area will be prepared using the latest Santa Clara Valley Transportation Authority (VTA)-City/County Association of Governments of San Mateo County (C/CAG) Bi-County Model (“VTA Travel Model”). Because emissions rates vary by vehicle speed, the project generated VMT and total VMT should be disaggregated by speed bin (typically in five mile an hour increments of speed from 0 to ~80 miles per hour) to allow different emissions factors to be applied at different speeds, which allows for the preparation of a more refined emissions analysis.

3. Transportation Analysis (CEQA) for Land Use Projects For an environmental analysis, these TA Guidelines incorporate the use of vehicle miles traveled (VMT) to disclose the effects of the project on the environment. Town staff completed an SB 743 implementation process, which included the preparation of the SB 743 Implementation for the Town of Los Gatos (July 2020) document package. The document package provides detailed technical information pertaining to the options and data considered by the Town of Los Gatos to implement VMT as an impact criterion.

At its November 17, 2020 meeting, the Town Council adopted Resolution 2020-045, Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743.

The CEQA Statue & Guidelines allow exemptions to projects meeting certain criteria. Project applicant may review the exemptions before preparing CEQA analysis for projects.

Based on the Town’s implementation of SB 743, the following methods should be used to determine VMT impact thresholds and mitigation requirements for land use projects.

3.1 VMT Analysis Methods
The Town elected to conduct a complete VMT analysis consistent with the General Plan future year VMT projections based on long-term expectations for air quality and GHG expectations as part of its General Plan EIR, so that it could make specific use of CEQA Statue & Guidelines Section 15183 to streamline project-specific CEQA analysis that is consistent with its General Plan and other Town documents. For the Town of Los Gatos, addressing transportation VMT impacts in the Town General Plan EIR is a useful way of understanding VMT impacts and how VMT reduction should be balanced against other community values related to the environment, social justice, and the community. By conducting a Town-wide VMT impact analysis, the Town is able to develop a program-based VMT mitigation approach. The concept of a ‘program’ approach to impact mitigation is commonly used in a variety of technical subjects, including

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transportation, air quality, GHG, and habitat. Absent a new program-level VMT mitigation approach, there are limited feasible mitigation options for project sites, and as a result limited ability to reduce VMT. Also, practically speaking, without feasible mitigation, significant VMT impacts would be significant and unavoidable (SAU). Under these circumstances, a project must prepare an EIR, thus adding time and cost to environmental review compared to an initial study/negative declaration (IS/ND) that relies on streamlining offered in the CEQA Statue & Guidelines.

Should a project not be consistent with the General Plan, as determined by the Community Development Director, or for some other reason unable to benefit from streamlined CEQA review under CEQA Statue & Guidelines Section 15183, the following sections provide details on how to conduct a complete VMT analysis for land use plans and projects in the Town of Los Gatos.

3.1.1 Regional Transportation Plan/Sustainable Communities Strategy and General Plan Consistency The first step in assessing project impacts is to determine if the project land use is contained within the Town of Los Gatos residential and non-residential land use allocations in the current Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), and if the project is consistent with the latest General Plan. If the project is not consistent with the RTP/SCS and/or the latest General Plan, amendments to those documents or the project would be needed prior to proceeding with the project review.

3.1.2 VMT Assessment
Projects not consistent with the current RTP/SCS or the latest General Plan are required to complete a VMT analysis using the VTA Travel Model to determine if there would be a significant VMT impact. The tools and methodology of the VMT analysis shall be approved by PPW Director (or Traffic Engineer). The impact analysis includes two types of VMT:

1. Total Project Generated VMT – Daily VMT of all vehicle trips, vehicle types, and trip purposes for all project land uses, presented as a total project generated VMT.

2. Project’s Effect on VMT within the Town of Los Gatos. VMT that occurs within the Town of Los Gatos by any type of vehicle. This captures all on-road vehicle travel on a roadway network for any purpose, and includes local trips as well as trips that pass through the area without stopping.

If the land use control totals increase between the without and with project conditions in the travel model, these VMT metrics will need to be expressed on a per service population (residents, employees, and other populations generating the VMT) basis to understand the effects of the project between scenarios.

The types of VMT analysis are evaluated for the following scenarios:

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• Baseline Conditions – Conditions in the baseline year for the CEQA analysis, which is most often chosen as the time of notice of preparation (NOP) of an environmental document, but may be chosen as the baseline year of the VTA Travel Model, if land use and transportation network conditions can be considered largely unchanged between the model baseline year and the date of the NOP. For compliance with the CEQA Statute & Guidelines Section 15125(a), the transportation impact analysis must include a description of the physical environmental conditions near the project, as they exist at the time the NOP is published, or if no NOP is published, at the time environmental analysis is commenced, from both a local and regional perspective. Baseline VMT estimates will be prepared using the most recent base year VTA Travel Model. • Baseline with Project Conditions – The project land use is added to the project Transportation Analysis Zone (TAZ), or a separate TAZ may be created to contain the project land uses. A full model run is performed and VMT changes (by metric of choice) are isolated for the project TAZ and across the full model network. The model output must include reasonableness checks of the production and attraction balancing to ensure the project effect is accurately captured. If this scenario results in a less-than- significant impact, then additional cumulative scenario analysis may not be required.
• Future Year Cumulative Conditions – Conditions requiring an RTP/SCS and/or General Plan amendment are also required to evaluate the project effect on VMT under Future Year Cumulative Conditions. This scenario buildout of the region’s land use and transportation system also provides the long-range view of future travel patterns. Future Year Cumulative Conditions VMT estimates should be based on the horizon year of the most recent VTA Travel Model, ensuring the model does not already contain the land uses or transportation improvements associated with the project.
• Future Year Cumulative with Project Conditions – The project land use is added to the project TAZ, or a separate TAZ is created to contain the project land uses. The addition of project land uses may be accompanied by a reallocation of a similar amount of land use from other TAZs throughout the model area (focusing on Santa Clara County), especially if the proposed project is significant in size such that it would potentially reduce the potential for development throughout the rest of the model area. Land use projects will generally not change the Future Year Cumulative Conditions control totals for population and employment growth within the model area. Instead, they will influence the land use supply through changes in General Plan land use designations and zoning. If project land uses are simply added to the Future Year Cumulative Conditions scenario, then the analysis should reflect this limitation in the methods and acknowledge that the analysis may overestimate the project’s effect on VMT. A full model run is performed and VMT changes (by metric of choice) would be isolated for the project TAZ and across the full model network. The model output must include reasonableness checks of the production and attraction balancing to ensure the project effect is accurately captured.

The model output should include the two VMT metrics listed earlier: 1) total project generated VMT, and 2) project’s effect on VMT using the total boundary VMT. Emissions vary by speed bin; disaggregating VMT by speed bin allows different emissions factors to be applied at different speeds, which allows for the preparation of a more refined emissions analysis. The total boundary VMT is needed as an input for air quality, greenhouse gas (GHG), and energy impact analysis, while the project generated VMT metrics are

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used for the transportation impact analysis.

Both “with project” scenarios noted above will summarize the two types of VMT and be compared to the without project condition.

Project generated VMT should be extracted from the VTA Travel Model by combining either the origindestination (for total VMT) or production-attraction (for the other metrics) trip matrices and congested skims (travel distances for each origin-destination pair in the travel mode) from final assignment. The VMT should be adjusted to reflect trips that extend beyond the model boundary. The project’s effect on VMT should be estimated using the Town limit boundary and extracting the total link-level VMT for both the without and with project conditions. Additional VMT metric specifications may be found in the SB 743 Implementation for the Town of Los Gatos (July 2020) document package.

If a project is mixed-use (i.e., composed of both residential and retail/office uses), project generated VMT should be extracted for both the total VMT and VMT per service population (residents and employees).

3.2 VMT Significance Thresholds
The Town Council adopted Resolution 2020-045, Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743. The thresholds balance the Town’s priorities with respect to competing objectives, including Los Gatos’s geographic and transportation context, greenhouse gas reduction goals, interest in achieving the state’s greenhouse gas reduction goals, and the latest General Plan goals and policies related to land use mix, economic development, and housing provision.

VMT analyses shall evaluate a project’s VMT impacts based on the thresholds established in the latest Council-adopted resolution.

3.3 VMT Mitigation Measures
To mitigate VMT impacts, the project shall be conditioned for implementation of mitigation measures in the following categories:

1. Modify the project’s built environment characteristics to reduce VMT generated by the project;

2. Implement transportation Demand Management (TDM) measures to reduce VMT generated by the project; and/or

3. Participate in a VMT fee program and/or VMT mitigation exchange/banking program (if they exist) to reduce VMT from the project or other land uses to achieve acceptable levels.

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The Town is in the process of updating the General Plan and the Draft Environmental Impact Report (DEIR) for the 2040 General Plan was released for public review in July 2021. The 2040 General Plan DEIR identifies significant but unavoidable transportation impacts and the mitigation measures. The Town is taking a Town-wide approach for VMT impact mitigation.

Attachment 3, VMT Reduction Actions for the Town of Los Gatos, provides a framework for mitigating VMT in the Town. Attachment 2, Transportation Mitigation Improvements Project List, has many improvements that are consistent with the VMT Reduction Strategies.

Evaluation of VMT reductions should be conducted using state-of-the-practice methods, recognizing that many of the TDM strategies are dependent on building occupant performance over time. As such, actual VMT reduction cannot be reliably predicted, and monitoring may be necessary to gauge performance related to mitigation expectations.

4. Transportation Analysis (CEQA) for Transportation Projects Transportation Analysis for transportation projects shall follow the latest CEQA Guidelines and related technical advisories from the Governor’s Office of Planning and Research (OPR).

The Thresholds of Significance for all transportation projects are established in the latest Council-adopted resolution.

Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact.

In 2020 Caltrans adopted its guidance under SB 743. The department’s Transportation Analysis Framework and Transportation Analysis for CEQA provide guidance for assessing induced travel impacts from prospective projects on the State Highway System. CEQA analysis for proposed transportation projects on the State Highway System should also follow Caltrans guidance.

5. Transportation Analysis per the Town’s Transportation Policies The contents and extent of a local transportation analysis per the Town’s General Plan depend on the location and size of the proposed development, the prevailing transportation conditions in the surrounding area, and questions from decision-makers and the public. The Town is committed to a wellconnected transportation system that enables safe access for all modes of travel. The methods presented in this chapter include robust data collection and analysis techniques for pedestrian, bicycle, and transit networks, in addition to vehicle circulation.

The local transportation analysis shall be prepared consistent with the latest VTA TIA Guidelines, with the exceptions described in this document.

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5.1 Study Area
The study area is determined by evaluating the project location and how it may affect all transportation modes and facilities. It is not simply a map showing where the project is located. Rather, the study area is the area of influence of a project. Each local transportation analysis will consider the adjacent transportation system for site access and circulation of land development projects and street modifications for transportation projects. To properly assess the site access, the Town may require offsite intersection analysis and/or other multimodal analysis.

The study area may include the nearest CMP facility to evaluate the proposed project’s conformity with the CMP facilities.

Applicants should consult with Town staff early regarding the need for a local transportation analysis based on local or site-specific issues, especially those related to pedestrians, bicyclists, and transit users.

5.2 Key Study Elements
The extent and complexity of a local transportation analysis will vary on the project attributes. Table 2 summarizes the basic requirements for a local transportation analysis for every project requiring a complete transportation analysis. Specific significance criteria for each of the listed elements are described in further detail in the Transportation Analysis (CEQA) for Land Use Projects and Transportation Analysis (CEQA) for Transportation Projects sections. To avoid substantial off-site improvements or changes to the project site plan/description after the transportation analysis is completed, a preliminary site plan shall be included for a “fatal flaw” evaluation.

Table 2: Local Transportation Analysis – Evaluation Criteria Study Element Evaluation Criteria
General Plan
Consistency
Evaluate the project against goals, policies, and actions set forth in the latest General Plan and other applicable Town plans.

Parking
Compare the project parking plan with Town and local specific plan standards and discuss how the proposed supply will affect demand for walking, bicycling, and transit modes. If a mix of land uses is proposed on site, or complements adjacent land uses, justify how the development will make use of shared on-site parking.

On-Site
Circulation
Review and evaluate site access locations, turning radii, truck loading areas, emergency access, and othersite characteristics with respect to operations and safety for all modes of transportation.

Pedestrian
Facilities
Identify any existing or planned pedestrian facilities that may be affected by the project. Document how the project will affect local pedestrian circulation (e.g., disclose how widening a road or adding a driveway will affect pedestrian safety and walking time).

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Table 2: Local Transportation Analysis – Evaluation Criteria Study Element Evaluation Criteria
Bicycle Facilities Identify any existing or planned facilities that may be affected by the project.

Transit
Identify any existing or planned transit facilities that may be affected by the project. If appropriate, document how the project improves access to or utilization of transit. For system planning, use crush load as capacity, not seated capacity.

Safety
Assessment
Evaluate project trips added to safety enhancement projects within the study area that are proposed as part of other future safety studies by the Town or other agencies.

Trucks (or Other
Large
Vehicles)
For relevant industrial projects, identify the number of truck trips that will be generated, and design facilities necessary to accommodate these trucks.

Automated
Vehicles or
Transportation
Network
Company Pickup/Drop-Off
For projects where automated vehicles and/or transportation network companies may have a large concentration of pick-up/drop-off, the project site circulation and pick-up/drop-off areas must be reviewed to identify opportunities and constraints of the project site. Modifications to the site circulation and/or pick-up/drop-off may be recommended.

Off-Site Traffic
Operations
All roadway facility analysis and Level of Service should be conducted using the latest version of the Highway Capacity Manual (HCM).

Intersection
Traffic Control
Evaluate unsignalized intersections located within the study area to determine appropriate traffic control. Analysis should include documentation of the appropriateness of a roundabout as an alternative or replacement to a traffic signal.

Other Issues
Consider other issues on a case-by-case basis (e.g., construction deficiencies, queuing between closely spaced intersections, emergency access, special event traffic)
Other
Jurisdictional
Requirements
In situations where several agencies must approve a development or are responsible for affected roadways, the applicant must contact lead and responsible agencies to determine issues to be addressed, scope of study, etc.

In general, the applicant will be responsible for analyzing project impacts against appropriate jurisdictional thresholds; however, the analysis method will be determined by the Town in compliance with CEQA, and the impacts will be mitigated consistent with Town standards.

5.3 Data Collection
Accurate data is essential to achieve a high level of confidence in local transportation analysis results.

Existing transportation data shall be collected using the requirements set forth below. Data should be presented on maps or figures where appropriate. To address the specific needs of each project, the extent of data collected shall be at the discretion of Town staff.

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• Pedestrian/Bicycle Facilities – Document the existing pedestrian and bicycle facilities serving the project site. Elements will include presence and width of sidewalks, curb ramps, crosswalks, or other pedestrian facilities providing access to the nearest attractors of the project site, such as transit stops, neighborhood attractors and/or complimentary land uses, and bicycle facilities (e.g., routes, lanes, or shared-use paths) within a two-mile bicycling distance of the project site.

Document barriers, deficiencies, and high pedestrian-demand land uses, including schools, parking, senior housing facilities, and transit stops or centers. The report will note any deficiencies or enhancements planned or recommended in the latest General Plan or future planning documents.
• Transit Facilities and Ridership – Document transit lines nearest to the project site, including stop locations, frequency of service, and any capacity issues. It will also describe transit stop amenities (e.g., benches, shelters, etc.).
• Multimodal Peak-Period Turning Movement Counts – Turning movement counts, including vehicles, bicycles, and pedestrians, will be collected for each study time period at all study intersections. The following parameters will be followed (fall and spring days while school is in session are preferred):
• Data collection will cover at least two hours to ensure the peak hour is observed. • As applicable, 48-hour machine counts will be used to identify the peak period before conducting other counts or analysis.
• Traffic volumes should not be influenced by a holiday, weather, construction, or other temporary change.
• The percent of traffic that consists of heavy trucks will be noted/estimated during data collection.
• Some projects may require vehicle classification or occupancy counts. Consult with Town staff on a case-by-case basis.
• Traffic counts that are older than two years at study initiation will not be used without consultation and approval by Town staff. These counts may need to be adjusted to reflect current year traffic volumes.
• Daily Traffic Counts – Collect data for all study roadway segments using the parameters described above for peak period turning movement counts, with the exception of bicycle and pedestrian volumes. Daily counts are used to size facilities (e.g., 2-lane vs. 4- lane) and to identify temporal changes in traffic.
• Roadway Geometry – Document existing roadway and intersection geometries and lane configurations. Information from aerial photography and street views should be verified based on a site visit(s).
• Intersection Controls and Signal Timings – For use in intersection analysis, intersection control types and signal timings and phasing should be based on signal timing sheets (available from Los Gatos or Caltrans) and verified during site visits.
• Five-Year Collision Data – Obtain Statewide Integrated Traffic Records System (SWITRS) through the local California Highway Patrol or through the following web site: www.chp.ca.gov/switrs.

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• Mode Split – Summarize daily and peak hour mode split for the study area land uses. Data could include U.S. Census journey-to-work data, empirical surveys, or any other available surveys.

5.4 Project Site Access and Circulation Review
A detailed site plan review is required for all projects. The local transportation analysis should include a review and summary of findings of the following qualitative and quantitative features. • Consideration of roundabouts are encouraged. Conduct roundabout analysis as required by Town staff.
• Existence of any current traffic problems in the local area, such as a high-collision location, nonstandard intersection or roadway, or an intersection in need of a traffic signal or a roundabout. • Applicability of context-sensitive design practices compatible with adjacent neighborhoods or other areas that may be impacted by the project traffic. • Proximity of proposed site driveway(s) to other driveways or intersections. • Adequacy of the project site design to convey all vehicle types. • Number and type of parking provided, including vehicle and bicycle parking. • On- and off-street loading requirements.
• Adequacy of on-site vehicle, bicycle, and pedestrian circulation and provision of direct pedestrian paths from residential areas to school sites, public streets to commercial and residential areas, and the project site to nearby transit facilities.

An important aspect of a TA is to provide sufficient information for the Town to determine that a project is consistent with the latest General Plan and other applicable Town policies, plans, and standards. As such, individual projects must be reviewed against relevant policies contained in the latest General Plan or other plans and policies. Applicants should review the full policy statements in the latest General Plan Mobility Element.

If the study area extends into an adjacent jurisdiction, the applicant may be responsible for analyzing project generated operational impacts in these jurisdictions. These include intersection or segment locations in any other jurisdiction, including Caltrans-maintained facilities. The applicant shall refer to current policies in the respective jurisdiction to identify the appropriate significance criteria.

5.5 Analysis Scenarios
The range of scenarios includes Existing Conditions, Background Conditions, and Cumulative Conditions.

Projects consistent with the latest General Plan will only be required to complete the Existing and Background conditions analysis; where Existing Conditions looks at the effect of the proposed project on the existing system within the next year or two, Background Conditions typically looks at a longer time frame of about three to five years. Inclusion of all three analysis conditions (e.g., Existing, Background, and Cumulative), would typically occur for large development projects, General Plan amendments, specific plans (and related amendments), with Cumulative Conditions having a time horizon of 10 to 20 years.

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The following analysis scenarios will document existing or future conditions, any deficiencies, and identify deficiencies that will result from the addition of the project. Each scenario will include a qualitative description of transportation facilities for all modes (and any planned enhancements), traffic volumes, and a quantitative analysis of intersection LOS. Key study elements are identified in the Multimodal Analysis Methods section of this chapter. Details regarding each local transportation analysis scenario are presented below.
• Existing Conditions – These conditions are based on recent field observations and recent traffic count data.
• Existing with Project Conditions – Traffic volume forecasts for roadway analysis reflecting Existing Conditions with traffic generated by the proposed project. For reuse or conversion projects, this may involve accounting for any existing use of the site that remains or will be removed. It should also qualitatively describe how the project will affect transportation for other modes, including compliance or relation to other Town documents.
• Background Conditions – Traffic volume forecasts for roadway segment and intersection analysis should reflect Existing Conditions with growth due to approved development that is expected to be operational before or concurrently with the proposed project. This scenario may not be needed if the study area has limited or no approved developments. • Background with Project Conditions – This scenario represents the Background Conditions with vehicle trips added by the proposed project. It provides decision-makers and the public with a view of conditions with all recently approved development and physical improvements, including the proposed project.
• Future Year Cumulative Conditions – This scenario represents transportation conditions for all travel modes in the study area reflecting all approved projects, pending projects, or expected development of other areas of Los Gatos designated for growth under the latest General Plan or specific plan. In most cases, the project site will likely be vacant under this scenario. In some cases, this scenario may need to account for any existing uses on the site that could continue, and potential increases in development allowed by ministerial approvals. • Cumulative with Project Conditions – This scenario represents the cumulative future transportation conditions with anticipated changes to the transportation system and the additions of project trips, and provides the long-range view of future traffic operations.

5.6 Analysis Time Periods
Based on the land use of the proposed project and upon consultation with Town staff, the study shall analyze traffic operations during the peak one hour of the following time periods:
• Weekday morning peak (7:00 – 10:00 AM)
• Weekday evening peak (4:00 – 7:00 PM)

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For some projects, the Town may substitute or require additional peak hour analysis for the following time periods as approved or requested by the Town’s Traffic Engineer:
• Weekday afternoon peak (2:00 – 4:00 PM)
• Friday evening peak (4:00 – 7:00 PM)
• Weekend midday peak (11:00 AM – 1:00 PM)
• Sunday or holiday evening peak (4:00 – 7:00 PM)
For example, retail commercial projects should evaluate operations for Saturday midday peak hour conditions, in addition to the standard weekday morning and evening peak periods. The determination of study time periods should be made separately for each proposed project, based upon the peaking characteristics of the project generated traffic and peaking characteristics of the adjacent street system and land uses.

5.7 Multimodal Analysis Methods
The report should provide a quantitative and/or qualitative evaluation of the project’s potential adverse or beneficial effects on transportation facilities and services related to pedestrians, bicyclists, and transit users.

For some projects, more detailed multimodal analysis may be required. Such analysis shall be decided upon in consultation with Town staff and consider new tools, methods, and performance measures, such as those listed below.
• Multimodal LOS – The latest Highway Capacity Manual (6th Edition) contains methods for multimodal LOS.
• Person Delay – Simulation models can be used to measure system performance in terms of overall person-delay for all modes within a transportation network. This method provides a better decision-making tool for developing improvements to promote efficient movement of people, rather than a particular type of vehicle.
• Safety Assessment – Evaluate whether the project adds vehicle trips to a safety improvement identified within the study area. (If a project may affect a Caltrans facility, a safety assessment may be needed for CEQA purposes as well.)
• Bicycle Level of Stress (LTS) – Evaluate LTS for all bicycle facilities within a two-mile bicycling distance of the project site. There are several methods for evaluating LTS for bicycle facilities, which generally rely on street widths/number of vehicle lanes, vehicle speeds, daily volumes, and type of bicycle facility to evaluate “low stress” bike networks. The Low-Stress Bicycling and Network Connectivity (2012) report and the National Association of City Transportation Officials (NACTO) Urban Bikeway Design Guide, Second Edition (2014) contains methods for LTS. • Pedestrian Level of Stress (LTS) – Evaluate LTS for all pedestrian facilities providing access to the nearest attractors (e.g., transit stops, neighborhood attractors and/or complimentary land uses) of the project site. Compared to bicycle LTS, there are parallel methods for calculating pedestrian comfort using best practiced from the NACTO Urban Street Design Guide (2013) and pedestrian

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safety research. As with bicycle comfort, pedestrian comfort is based on a variety of factors ranging from the quality and presence of sidewalks to the conditions of the adjacent roadway (speed, number of travel lanes, frequency of trucks).
• Activity Connectedness – Travel time for each mode (e.g., walking, bicycles, transit, and vehicles) between the project and surrounding land uses can be used to gauge the degree of accessibility for a project. The Town desires to minimize travel time to necessary destinations while minimizing unnecessary vehicle travel. Tools such as geographic information systems or online tools (e.g., Index and Walk Score) can be used to gauge this measure specifically for walking. The main idea is to evaluate activity centers and destinations around projects to ensure that walk times to necessary destinations are minimized and the walking experience is comfortable.

5.8 Traffic Operations Analysis
Traffic operational deficiencies shall be analyzed using standard or state-of-the-practice professional procedures. The main issues related to traffic operations analysis are the method, input data, and assumptions. These three items influence the level of confidence and the associated level of defensibility of the local transportation analysis. For traffic operations, this requires following the procedures and techniques published in the most recent Highway Capacity Manual (HCM).

Traffic Operations Analysis should be conducted according to the latest VTA Traffic Level of Service Guidelines.

5.9 Mobility Deficiency Criteria
The overall guiding principal of the General Plan 2040 Mobility Element is to, “[p]rovide a well- connected transportation system that enables safe access for all transportation modes, including pedestrians, bicyclists, motorists, and transit riders of all ages and abilities.” Los Gatos evaluates each transportation mode to identify deficiencies. Local transportation analyses evaluate intersection operations focused on specific traffic issues such as queuing and safety. A greater emphasis is placed on pedestrian, bicycle, and transit facilities and services, in part to reduce traffic congestion and air quality impacts associated with automobile use. Table 5 outlines deficiency criteria for each mode. The mobility deficiency criteria can be used to identify conflicts with existing or planned multimodal facilities.

Table 5: Mobility Deficiency Criteria
Study Element Deficiency Determination
Parking Project increases off-site parking demand above a level required by the Town Zoning Code and/or desirable by the Town.

On-Site Circulation
Project designs for on-street circulation, access, and parking fail to meet Town standards. Where Town standards are not defined, industry standards [Highway Design Manual, California Manual on Uniform Traffic Control Devices (MUTCD), etc.] should be referenced, as appropriate.

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Table 5: Mobility Deficiency Criteria
Study Element Deficiency Determination
Failure to provide adequate accessibility for service and delivery trucks on site, including access to loading areas. Project will result in a hazard or potentially unsafe conditions without improvements.

Pedestrian
Facilities
Project fails to provide safe and accessible pedestrian connections between project buildings and adjacent streets, trails, and transit facilities.

Bicycle Facilities
Project disrupts existing or planned bicycle facilities or is otherwise inconsistent with the latest General Plan, Bicycle and Pedestrian Master Plan, or other related plans. Project adds bicycle trips along project frontage to an existing facility that needs improvements per the latest BPMP.

Transit Project disrupts existing or planned transit facilities and services or conflicts with Town adopted plans, guidelines, policies, or standards.

Heavy Vehicles
(Trucks and
Buses)
A project failsto provide adequate accommodation of forecasted heavy traffic or temporary construction-related truck traffic consistent with Town or industry standards (Highway Design Manual, MUTCD, etc.).

Off-Site Traffic
Operations
95th percentile vehicle queues exceed the existing or planned length of a turn pocket. The proposed project introduces a design feature that substantially increases safety hazards.

Signalized
Intersection Traffic
Control
Addition of project traffic causes a signalized intersection to 1) drop more than one level overall or at the worst individual approach delay if it is at LOS A, B, or C or 2) drop at all overall or at the worst individual approach delay if it is at LOS D or below.

Unsignalized
Intersection
Traffic Control
Addition of project traffic causes an all-way stop-controlled or side street stop-controlled intersection to 1) operate at LOS E or F overall or the worst-case movement, and 2) meets the Caltrans signal warrant criteria.

General Plan
Consistency
Evaluate the project against mobility, safety, and other related goals, policies, and actions set forth in the latest General Plan.

Other Subject
Areas
Consider other areas on a case-by-case basis (e.g., construction impacts, queuing between closely spaced intersections, emergency access, special event traffic, etc.).

Requirements
for Other
Jurisdictions
The project exceeds established deficiency thresholds for transportation facilities and services under the jurisdiction of other agencies.

5.10 CMP Deficiency Criteria
To determine consistency with the CMP, off-site intersection analysis may be needed and should be applied according to the latest VTA TIA Guidelines.

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5.11 Mitigation Improvements
All project deficiencies should be addressed consistent with the policies of the latest General Plan Mobility Element. Under these circumstances, the applicant should meet with Town staff to identify transportation improvements that address the deficiencies. Table 6 shows example types of improvements to address transportation deficiencies.

Potential improvements may require a more detailed review, often including traffic operations, to demonstrate how they address a specific deficiency.

Selected improvements should be identified whether they will be implemented under Existing Conditions, Background Conditions, or Cumulative Conditions. Background Conditions generally reflect conditions at the time of full occupancy of a project.

If a transportation improvement is selected to address a deficiency, it should include a description of the benefit to traffic reduction generated by a proposed development and how the improvement contributes to the multimodal transportation system in Los Gatos. In addition, all transportation improvements need to consider whether they have secondary effects to VMT [i.e., whether the improvement is VMT inducing per guidance in the OPR Technical Advisory (December 2018, Pages 20-21)].

The improvement shall not unreasonably degrade bicycle, pedestrian or transit access, and circulation. If a project proposes improvements in response to auto LOS deficiency involving a change to existing roadway or intersection geometry, or changes to signal operations, the TA shall analyze and disclose secondary effects on other modes, i.e., whether the mitigation would affect pedestrian or bicycle conditions or increase transit vehicle delay, per the methodologies in 5.7.

Table 6: Example Improvements
Study Element Improvement
Project Modifications
and Transportation
Demand Management
• Alter density or diversity of project uses or integrate affordable housing
• Encourage telecommuting and alternative work schedules • Provide ride-sharing programs to encourage carpooling and vanpooling
• Provide local shuttle service
• Provide employer-sponsored vanpools or shuttles
• Provide pedestrian network improvements
• Provide traffic calming measures and low-stress bicycle network improvements
• Implement car-sharing (e.g., ZipCar) program
• Limit parking supply
• Unbundle parking costs from property costs
• Institute on-street market pricing for parking

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Pedestrian and Bicycle
Facilities
• Provide for access to, from, and through the development for pedestrians and bicyclists
• Construct Class I bicycle paths, Class II bicycle lanes, and other facilities
• Provide secure bicycle parking and shower amenities
• Reduce travel lanes on a street to install a two-way left-turn lane and Class II bicycle lanes
• Add corner bulbouts, reduce curb radii, add pedestrian refuges, or implement other walking-related improvements Transit Facilities
• Provide bus turnouts, bus shelters, additional busstops, and park-and-ride lots
• Fund increases in transit service
Parking Facilities
• Design parking facilities to allow free-flow accessto and from the street
• Provide off-street parking per Town standards or
recommendations
• Implement shared parking among complementary land uses Traffic Control
Modifications
• Provide for yield or stop control
• Evaluate unsignalized intersections with substandard LOS for conversion to roundabout intersection control or
for signalization
• Provide coordination/synchronization of traffic signals along a corridor
• Provide turn-lane channelization through raised islands • Restrict selected turning movements
Street Operations
Modifications
• Optimize location of access driveway(s)
• Provide improvements to traffic signal phasing, or lengthen existing turning pocket
• Provide additional through traffic lane(s), right-turn lane(s), and left-turn lane(s) if they do not adversely impact other modes or induce additional vehicle travel
• Reduce travel lanes on a street to install a two-way left-turn lane
• Address congestion pricing on roads or within a specific area

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Appendix A: Transportation Analysis Report FormatOutline Note: Not all sections are required for all projects. The project applicant shall consult with the Town Traffic Engineer to determine the required sections.

1. Introductory Items
• Front Cover/Title Page
• Table of Contents, List of Figures, and List of Tables • Executive Summary

2. Introduction
• Project description
• Project sponsor/contact info
• Type and size of development
• Site plan (include proposed driveways, roadways, traffic control, parking facilities, emergency vehicle access, and internal circulation for vehicles, bicyclists, and pedestrians)
• Location map (include major streets, study intersections, and neighboring zoning and land uses)
• Scope of transportation analysis

3. Current Conditions
• Description of existing street system within project site and surrounding area • Location and routes of nearest public transit system serving the project • Location and routes of nearest pedestrian and bicycle facilities serving the project • Vehicle Miles Traveled Assessment
o Description of baseline VMT estimates (may include site and regional VMT estimates)
• Intersection Analysis for Site Access and Circulation Evaluation and CMP Evaluation o Figure of study intersections with peak hour turning movement counts, lane geometries, and traffic control

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o Map of study area showing average daily traffic (ADT) of study roadways o Table of existing peak hour average vehicle delay and level of service (LOS)

4. Project Trip Generation
• Table of project generated trip estimate
• Figure/map of trip distribution (in percent)

5. Project Site Access and Circulation Evaluation
• Summary of a detailed site review for all modes of travel • Mobility deficiency analysis and summary to vehicle, transit, bicycle, and pedestrian facilities (under Project Conditions and Cumulative Conditions) • Summary of transportation improvements
CEQA Transportation Analysis Report Section

6. Vehicle Miles Traveled Assessment
• Summary of project generated VMT under Baseline Conditions • Summary of project’s effect on VMT under Future Year Cumulative Conditions • Identification of significant impacts
• Discussion of mitigation measures
• Evaluation of impacts of mitigation measures

7. Other CEQA Requirements
• Summary of conflicts with a plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian paths. Present mitigation measures, as needed.
• Evaluation of hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). Present mitigation measures, as needed.
• Emergency access evaluation. Present mitigation measures, as needed.

Local Transportation Analysis Report Section

8. Existing with Project Conditions

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• Maps of study area with applicable peak hour turning movements (Project Only and Existing with Project Conditions)
• Table of Existing Conditions and Existing with Project Conditions intersection peak hour average vehicle delay and LOS (or other multimodal performance measure)
• Traffic signal and other warrants
• Changes/Deficiencies to bike, pedestrian, and transit networks • Findings of project deficiencies
• Improvementsfor project deficiencies (include a map showing physical improvements)
• Scheduling and implementation responsibility of improvements • Deficiencies of proposed improvements

9. Background Conditions
• Table of trip generation for approved project(s)
• Figure and/or table of approved projects trip distribution (in percent) • Map of study area with applicable peak hour turning
movements (Background Conditions)
• Table of intersection peak hour average vehicle delay and LOS (or other multimodal performance measure) (including queue
lengths, etc)
• Changes/deficiencies to bike, pedestrian, and transit networks • Traffic signal and other warrants

10. Background with Project Conditions
• Similar content to Existing with Project Conditions

11. Cumulative Conditions and Cumulative with Project Conditions • Map of study area with Cumulative Conditions peak hour turning movements
• Map of study area with Cumulative with Project Conditions peak hour turning movements
• Table of Cumulative Conditions and Cumulative with Project Conditions intersection peak hour average vehicle delay and LOS (or other multimodal performance measure)
• Changes/Deficiencies to bike, pedestrian, and transit networks • Traffic signal and other warrants
• Findings of project deficiencies
• Improvementsfor project deficiencies (include a map showing physical improvements)
• Scheduling and implementation responsibility of improvements • Deficiencies of proposed improvements

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Additional Sections for Transportation Analysis Report

12. Construction Deficiencies
• Trips due to construction workers
• Truck trips and truck access routes

13. Phasing Deficiencies (For Large Projects Only)

14. Appendices
• List of references
• List of authors
• Pedestrian, bicycle, and vehicle counts
• Technical calculations for all analyses

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ATTACHMENT 2
Attachment 2 - Traffic Transportation Mitigation Improvements Project List Source Description
Estimated
Project Cost
(2014 $)
Growth
Related
Project Cost
Share
Mitigation
Impact Fee
Eligible Cost
GP/VTP 2035 Blossom Hill Rd and Union Ave Intersection Improvements $ 1,200,000 90.00% $ 1,080,000 GP/VTP 2035 Los Gatos - Almaden Rd Improvements $ 3,000,000 50.00% $ 1,500,000 GP/VTP 2035 Los Gatos Blvd Widening - Samaritan Dr to Camino Del Sol - Road widening, new sidewalks and bike lanes $ 4,000,000 50.00% $ 2,000,000 GP/VTP 2035 Union Ave Widening and Sidewalks - complete ped and bike routes $ 3,000,000 50.00% $ 1,500,000 GP/VTP 2035 Wood Rd Gateway on Santa Cruz Ave - roundabout $ 1,200,000 50.00% $ 600,000 GP/VTP 2035 Central Traffic Signal Control System $ 750,000 9.68% $ 72,600 GP/VTP 2035 Hwy 9 Los Gatos Creek Trail connector - new path and bridge for ped/bike $ 1,000,000 50.00% $ 500,000 GP/VTP 2035 Hwy 9/N. Santa Cruz Ave Intersection Improvements $ 1,400,000 90.00% $ 1,260,000 CIP Roberts Road Improvements from bridge to University $ 600,000 50.00% $ 300,000 CIP Pollard Road Widening from Knowles to York Avenue $ 2,500,000 50.00% $ 1,250,000 CIP Sidewalks infill- Van Meter, Fischer and Blossom Hill Schools $ 1,000,000 50.00% $ 500,000 CIP Winchester Blvd/Lark Avenue Intersection Improvements $ 850,000 90.00% $ 765,000 CIP Westbound Lark to Hwy 17 northbound ramps - add two right-turn lanes $ 3,750,000 90.00% $ 3,375,000 CIP Unfunded Deferred Street Maintenance (Annual PMS Survey) $ 10,500,000 9.68% $ 1,016,400 Project Name Category Description
Cost Estimate
($2024)
Estimated
Funding from
Other Sources
Unfunded Cost
or Town Share
State Route 17 Corridor Congestion Relief Project 1 Safety and Capacity Improvements Ÿ Modify the SR 17/SR 9 interchange’s on- and off-ramps Ÿ ŸImplement advance transportation technology
Ÿ Install traffic signals control system, traveler information system, and ramp meters $ 171,600,000 $ 154,440,000 $ 17,160,000 Shannon Rd Widening and Safety Improvements BPMP Priority Projects Add shoulders and retaining wall between Santa Rosa Drive and Diduca Way.

Union Avenue Widening and Sidewalks BPMP Priority Projects Add sidewalks and bike lanes between Blossom Hill Road to Lynne Ave $ 4,413,397 $ - $ 4,413,397
Traffic Signal Modernization Program Traffic Signal
Smart Signals Project will modernize and upgrade the Town’s traffic signals/communications equipment to provide real-time data for the advanced traffic management and adaptive traffic control systems $ 30,000,999 $ - $ 30,000,999
Highway 17 Bicycle & Pedestrian Overcrossing BPMP Priority Projects Overcrossing of SR-17 south of Blossom Hill Road $ 30,160,000 $ 4,457,880 $ 25,702,120 Kennedy Sidewalk & Bike Lanes BPMP Priority Projects
Add sidewalks and Class II bicycle lanes from Los Gatos Bld to Englewood Ave $ 3,389,360 $1,872,990 $ 1,516,370
Sidewalk Gap Filling Projects Other BPMP Projects - New Facilities Fill gaps in sidewalks, multiple locations on Town-wide circulation network $ 820,741 $ - $ 820,741
New and Expanded Bicycle and Pedestrian Facilities
(Non Priority Projects) Other BPMP Projects - New Facilities Construct new bicycle lanes, cycle tracks and multiuse paths $ 6,284,007 $ - $ 6,284,007 Los Gatos Almaden Road Complete Streets
Improvements Complete Streets (Carryover)
Fill gaps in sidewalks between Peach Blossom Lane and Camino del Cerro $ 4,413,397 $ 4,413,397
Los Gatos Boulevard Multimodal Widening Complete Streets (Carryover) Add sidewalks and bicycle lanes between Samaritan Drive and Camino Del Sol $ 726,960 $ 726,960
Parking Program Implementation Lighting and Signage Add lighting, signage, and other project elements $ 416,000 $ 416,000 Bicyle and Pedestrian Improvements Program -Safety
Improvements
Other BPMP Projects - Bicyclist and
Pedestrian Safety
High visibility crosswalks, midblock crossings, pedestrian beacons, and other project elements on Town-wide circulation network $ 1,060,123 $ - $ 1,060,123
Priority Projects from Bicycle and Pedestrian Master
Plan BPMP Priority Projects
Work towards implement priority projects from BPMP as
feasible $ 96,175,611 $ - $ 96,175,611
Blossom Hill Road/Belgatos Signal Traffic Signal New Signal $ 1,511,120 $ - $ 1,511,120 Los Gatos Blvd/Burton Traffic Signal Signal Upgrade $ 709,280 $ - $ 709,280 University/Andrews Signal Traffic Signal Signal Upgrade $ 1,349,920 $ - $ 1,349,920 $ 353,030,916 $ 160,770,870 $ 192,260,046

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GP Lark/Los Gatos Intersection Improvements - Add Third Left Turn Lanes for Eastbound and Northbound Approaches $ 1,200,000 90.00% $ 1,080,000 GP Complete Street Improvements - Lark from Garden Hill to Los Gatos Blvd $ 2,100,000 50.00% $ 1,050,000 GP Complete Street Improvements - SR 9 from University to Los Gatos Blvd $ 650,000 50.00% $ 325,000 GP Complete Street Improvements - Blossom HillRoad from Old Blossom Hill Road to Regent Drive $ 3,000,000 50.00% $ 1,500,000
GP Complete Street Improvements - Knowles from Pollard to Winchester $ 2,000,000 50.00% $ 1,000,000 GP Complete Street Improvements - Winchester from Blossom Hill to Lark $ 1,500,000 50.00% $ 750,000 GP Blossom Hill Road widening over Highway 17 $ 2,000,000 50.00% $ 1,000,000 GP LocalBikeway Improvements $ 750,000 50.00% $ 375,000 Notes: Total $ 47,950,000 $ 22,799,000
VTP = Valley Transportation Plan, 2035 by Santa Clara Valley Transportation Authority.

Town CIP = Town of Los Gatos, Capital Improvement Program and pending construction project list.

Source: Town of Los Gatos.

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ATTACHMENT 2
Attachment 3 - VMT REDUCTION STRATEGIES
For projects that would generate Vehicle Miles Traveled (VMT), one or more VMT reduction strategies shall be required to reduce VMT of the project. Examples of VMT reduction strategies are provided below. The VMT reduction strategies are organized by their relative scale for implementation (i.e., individual site level, Town-wide level, and regional level).

INDIVIDUAL SITE LEVEL
 Encourage Telecommuting and Alternative Work Schedules: This strategy relies on effective internet access and speeds to individual project sites/buildings to provide the opportunity for telecommuting. This strategy would reduce commute VMT but also result in a change in VMTfor other travel purposes; thus, this strategy should consider the net change in the Town’s project-generated VMT.
 Provide Ride-Sharing Programs: This strategy focuses on encouraging carpooling and vanpooling by project site/building tenants.
 Implement Car-Sharing Program: This strategy reduces the need to own a vehicle or reducesthe number of vehicles owned by a household by making it convenient to access a shared vehicle for those trips where vehicle use is essential. Examples include programs like ZipCar,Car2Go, and Gig.
 Provide Employer-Sponsored Vanpool/Shuttle: This strategy relies on employers purchasing orleasing vans or shuttles, and often subsidizing the cost of at least program administration, if notmore. Vanpools typically service employee’s commute to work, while shuttles service nearby transit stations and surrounding commercial centers.

Scheduling and rider charges, if any, are within the employer’s purview. A supplemental strategy may include facilitating or enhancing the service by improving the shuttle stops and biking/walking paths to the stops.

TOWN-WIDE LEVEL
 Provide Bicycle and Pedestrian Network Improvements: This strategy focuses on creating a comprehensive bicycle and pedestrian network within the project and connecting to nearby destinations. Projects in Los Gatos tend to be smaller so the emphasis of this strategy would likely be the construction of network improvements that connect the project site directly to nearby destinations. Alternatively, implementation could occur through an impact fee programor benefit/assessment district based on regional or local plans such as the Bicycle and Pedestrian Master Plan.  Provide Local Transit or Microtransit Solutions: This strategy focuses on providing transit solutions that serve the local circulation needs and connections to key regional destinations. The service would connect to transit hubs, schools, commercial centers, and residential areas to improve transit connectivity and address the “first/last mile”

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problems. The service may be in the form of a local shuttle, microtransit service using dynamic routing and scheduling, fare subsidies to private transportation network companies (TNCs) or taxi companies, or other service delivery methods. The service may be open to all or target a special population, such as seniors, disabled or students. The implementation of this strategy may require regional or private partnership.  Provide Transit Signal Priority: This strategy would upgrade the Town’s traffic signals along transit corridors to provide transit signal priority to improve transit bus travel time.
 Improve Biking and Walking Paths to Bus Stops and Transit Amenities: This strategy improves the biking and walking paths to bus stops, enhances amenities at bus stops such as shelters, benches, and ADA accessible loading areas.  Provide Traffic Calming Measures: This strategy combines the California Air Pollution Control Officers Association (CAPCOA) research focused on traffic calming with new research on providing a low-stress bicycle network. Traffic calming creates networks with low vehicle speeds and volumes that are more conducive to walking and bicycling.

Building a low-stress bicycle network produces a similar outcome. One potential change in this strategy over time is that ebikes (and e-scooters) could extend the effective range of travel on the bicycle network,which could enhance the effectiveness of this strategy.
 Limit Parking Supply: When combined with companion TDM measures, reduced parking supplydiscourages driving by limiting easy and convenient parking options.

Implementation of this strategy may require reducing (or removing) minimum parking requirements and allowing developers to use shared parking strategies.  Unbundle Parking Costs from Property Cost: Unbundling separates parking costs from propertycost, for instance by not including a parking space in a residential unit’s rent, or by requiring employers to lease each parking space separately from the building owner.

This strategy ensures that the user understands that the cost of driving includes parking and can encourage people to use an alternative mode to save money.  Implement Market Price Public Parking (On-Street): This strategy focuses on implementing a pricing strategy for parking by pricing all on-street parking in central business districts, employment centers, and retail centers. Priced parking would encourage “park once” behaviorand may also result in area-wide mode shifts.

REGIONAL LEVEL
 Increase Density: This strategy focuses on increasing density of land uses, where allowed by the General Plan and/or Zoning Ordinance, to reduce distances people travel and provide more travel mode options. This strategy also provides a foundation for many other strategies. For example, densification increases transit ridership, which justifies enhanced transit service.
 Increase Diversity of Urban and Suburban Developments: This strategy focuses on

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inclusion of mixed uses within projects or in consideration of the surrounding area to minimize vehicle travelin terms of both the number of trips and the length of those trips.  Increase Transit Accessibility: This strategy focuses on encouraging the use of transit by locating a project with high density near transit. A project with a residential/commercial center designed around a bus station is referred to as a transit-oriented development (TOD).
 Integrate Affordable and Below Market Rate Housing: This strategy provides greater opportunities for lower income families to live closer to job centers since income effectsprobability that a commute will take transit or walk to work.  Increase Transit Service Frequency/Speed: This strategy focuses on improving transit service convenience and travel time competitiveness with driving. Given existing land use density in LosGatos, this strategy may be limited to traditional commuter transit where trips can be pooled at the start and end locations, or it may require new forms of demand-responsive transit service. Note that implementation of this strategy would require regional or local agency implementation, substantial changes to current transit practices, and would not likely be applicable for individual development projects.  Implement Area or Cordon Pricing: This strategy focuses on implementing a cordon (i.e., boundary) pricing scheme, where a cordon is set around a specific area to charge a toll to enterthe area by vehicle. The cordon location is usually the boundary of an area with limited points of access. The cordon toll may be constant, applied during peak periods, or be variable, with higher prices during congestion peak periods. The toll can also be based on a fixed schedule or be dynamic, responding to real-time congestion levels. Note that implementation of this strategy requires alternative modes of travel that are available and reliable, such as high-qualitytransit infrastructure.

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ATTACHMENT 2
Attachment 4 - DEFINITIONS
Land use entitlements shall mean entitlement changes in use requiring discretionary approval by Los Gatos, which include General Plan amendments, specific plans (and related amendments), zoning changes, use permits, planned developments, and tentative subdivision maps.

Land Use Projects or Development shall mean residential or nonresidential improvements on a site.

Existing development shall mean any already existing habitable residential or nonresidential building or projects which rebuild or remodel the existing development without increasing the trips generated. No fee shall be charged for development already existing.

Expansion of use, to determine traffic increases, shall include any increase in the number of living units, gross floor area in a nonresidential development and/or any intensification of use which increases trips generated.

Transportation improvements shall mean those improvements to the transportation facilities and related actions necessary to implement the transportation element of the Town's general plan and any applicable specific plan.

Site shall mean a plot of ground consisting of one (1) or more lots or parcels on which a common improvement is proposed or exists.

Trip generation rate shall mean the number of vehicle trips over a weekday twenty-four-hour period generated by a particular type of land use and shall be expressed in terms of the number of acres or square feet of land for each land use category. The Town Engineer may exercise reasonable discretion to establish recommended trip generation rates for land use categories consisting of groupings of land uses having similar use and functional characteristics. When the trip generation rate is multiplied by the amount of land, the number of trips, both incoming and outgoing, shall be estimated.

Average Daily Trips (ADT) shall mean the total number of trips, both in-bound and out-bound, within a 24-hour weekday period, generated by a particular use or development.

Pass-By Trip: Trips generated by the proposed Project that would be attracted from traffic passing the proposed project site on an adjacent street that contains direct access to the Project.

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Peak Hour Trips shall mean vehicle trips, both in-bound and out-bound, occurring during a 60- minute period either during the A.M. Peak (7 A.M. to 9 A.M.) or the P.M. Peak (4 P.M. to 6 P.M.), generated by a particular use or Project.

Specialty Retail. Specialty Retail uses are defined as walk-in and impulse businesses such as juice bars, yogurt shops, coffee shops, donut shops, and similar uses which do not generally serve meals and have limited or no seating. Specialty Retail uses are defined under this policy for purposes of establishing trip generation data and this definition does not provide any land use or zoning guidance.

Use shall mean the purpose for which a site or structure is arranged, designed, intended, constructed, erected, moved, altered or enlarged or for which either a site or a structure is or may be occupied or maintained.

Vehicle Trip End shall mean an incoming or outgoing trip going to or coming from anywhere within the Town or outside the Town.

CEQA shall mean the California Environmental Quality Act. These terms are reserved for definitions per the CEQA Guidelines: significance criteria, significant impact, and mitigation measures.

Local Transportation Analysis shall mean analysis to assess potential mobility deficiencies caused by new developments on the local roadway performance, following the Town’s transportation policies. These terms are reserved for Local Transportation Analysis: threshold or performance standard, deficiency, and mitigation improvement.

Vehicle Miles Traveled (VMT) is a metric that accounts for the number of vehicle trips generated times the length or distance of those trips. VMT is an accessibility performance metric that evaluates the changes in land use patterns, regional transportation systems, and other built environment characteristics.

Level of Service (LOS) is a metric that assigns a letter grade to network performance. The typical application is to measure the average amount of delay experienced by vehicle drivers at an intersection during the most congested time of day and assign a report card range from LOS A (fewer than 10 seconds of delay) to LOS F (more than 80 seconds of delay). Vehicle level of service is used to measure vehicle mobility.

ITEM NO. 14.

PREPARED BY: Chris Constantin
Town Manager
Reviewed by: Town Manager, Assistant Town Manager, Town Attorney, and Finance Director 110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6832 www.losgatosca.gov

TOWN OF LOS GATOS

COUNCIL AGENDA REPORT
MEETING DATE: 09/16/2025
DATE: September 16, 2025
TO: Mayor and Town Council
FROM: Chris Constantin, Town Manager
SUBJECT: Councilmember Request to Discuss E-Bike Safety and Consider Direction Related to Education, Registration, Legislation, and Enforcement.

RECOMMENDATION: Discussion of E-bike safety and consideration to direct a future item being agendized regarding a proposal to enhance e-bike safety.

STRATEGIC PRIORITIES:

N/A
FISCAL IMPACT:

None. This is a discussion only requested by two Councilmembers.

BACKGROUND:

During the Town Council meeting of September 2, 2025, Vice-Mayor Rob Moore and Councilmember Maria Ristow requested the Town Council agendize a discussion of a plan to address E-bike safety.

In coordination with the Mayor, the item is being agendized under Council Matters.

DISCUSSION:

Attachment 1 provides the proposal submitted by Vice Mayor Rob Moore and Councilmember Maria Ristow.

CONCLUSION:

The item is being heard in accordance to the Town Council’s policy addressing agendizing matters before the Town Council.

PAGE 2 OF 2
SUBJECT: Councilmember Request for Agenda Item – E-bike Safety DATE: September 16, 2025
COORDINATION:

This report was coordinated with the Town Manager’s Office and the Mayor.

ENVIRONMENTAL ASSESSMENT:

The proposed project does not qualify as a project under CEQA.

Attachments:

1. E-Bike Safety Proposal

ATTACHMENT 1
Memorandum
To: Mayor Hudes and Los Gatos Town Council
CC: Town Manager, Chief of Police, Town Attorney, Town Clerk From: Vice Mayor Rob Moore and Councilmember Maria Ristow Subject: E-Bike Safety
Background:

Over the past few years, the use of e-bikes and e-motorcycles in Los Gatos has risen significantly, especially among younger riders. Residents in Los Gatos have observed students behaving in unsafe ways and sometimes engaging in anti-social behavior while riding two-wheeled electric vehicles. While there has not been a dramatic increase in juvenile injuries locally, the risk of a serious injury is substantial. National Institutes of Health data shows that e-bike riders have 2.4 times greater odds of severe injury than traditional cyclists. Furthermore, many minors don’t understand the rules of the road and their brains are not fully developed. Marin County has reported that 35% of e-bike crashes between October 2023 and March 2024 involved riders under 16 years old. Tragically, riders aged 10 to 15 have five times the crash rate of adults. Recent statistics show cyclist deaths continue to rise in the US, with ebikes representing an increasing percentage of these incidents, particularly among younger riders.

Even legal Class 2 e-bikes present safety challenges over Class 1 and solely human-powered bicycles.

Class 2 e-bikes can reach speeds of 20 MPH using throttle power alone (no pedaling required) and many can be modified to exceed their legal speed limits. Due to the throttle, they are easier for inexperienced riders to operate at high speeds and they don't require the same physical effort as Class 1 e-bikes, potentially leading to less cautious operation.

Contributing to the increased risk to riders and bystanders, is the recent proliferation of e-motorcycles.

While traditional e-bikes (Class 1, Class 2, and Class 3) are legal and well regulated by the State of California and in the Town of Los Gatos, e-motorcycles are unregulated, throttle-operated electric vehicles that are not street legal. They often don’t have pedals, can travel up to 60 MPH, and can be purchased online from sites like Alibaba. These e-motorcycles usually cost between $3,000 and $7,000, meaning that most of the time, teenagers are not purchasing these vehicles themselves: their parents are purchasing them for their children. There are a variety of quality educational resources available to students and parents in Los Gatos, but oftentimes they are not made to guide purchasing decisions.

The Los Gatos-Monte Sereno Police Department (LGMSPD) has made significant efforts to safely enforce the law and curb dangerous e-bike and e-motorcycle behavior in Los Gatos. Recently, during the start of the school year, the Police Department increased its visibility at local schools to promote safety among Los Gatos students. Additionally, Los Gatos School Resource Officers continue engaging in proactive education including bike rodeos happening in fall in partnership with Safe Routes to School. Several dozen citations were issued during the first week of school, however the problem persists.

The Town of Los Gatos has an obligation to ensure that the children of our community don’t

ATTACHMENT 1
inadvertently make a life-altering decision.

Recommendation:

To increase the safety for all road and trail users in Los Gatos, we recommend a four pronged approach: education, registration, legislation, and enforcement.

1. Education - Buyer’s Guide: Education is a critical aspect of limiting the prevalence of illegal emotorcycles in Los Gatos. To accomplish this, the Town of Los Gatos should create a “buyer’s guide” specifically targeted at parents, but accessible to all. This buyer’s guide should have specific recommendations about the kinds of e-bikes that are safe and legal, and where you can buy these legal e-bikes in town. It should also specifically give examples of the common brands of e-bikes/ e-motorcycles that are illegal such as Surron and Talaria with photos, as well as flagging legal class 2 e-bikes that can be hacked to exceed 20 mph. ○ The Town of Los Gatos should work with Los Gatos’ three local bike shops (Summit Bikes, Mike’s Bikes, and Specialized Bikes) to promote these shops as where to buy legal e-bikes in Los Gatos. These bike shops have also demonstrated an interest in doing more to promote safe, legal bike riding behavior in Los Gatos.

2. Registration Program: Decreasing the quantity of illegal e-motorcycles going to and from local schools could make a significant difference in curbing their prevalence. The Town of Los Gatos should work with Los Gatos High School, Los Gatos middle schools, and Los Gatos Safe Routes to Schools to create an e-bike registration program. Only legal Class 1, 2, and 3 would be eligible for registration. This program should require that all e-bikes ridden by students to Los Gatos schools are registered, and registered riders could receive a large, colored sticker for their e-bike. The registration could utilize the Town’s existing online registration resources. ○ After this program has been put in place, school staff and Los Gatos School Resource Officers will be able to begin enforcing only allowing registered e-bikes to be parked on campus. Illegal e-motorcycles would not be able to be registered, and could therefore be banned from campus.

3. Support Legislation: Part of the challenge with addressing hazards from e-bikes and emotorcycles in Los Gatos is limited state regulations from the State of California. Accordingly, the Town of Los Gatos should support statewide legislation to better address this issue. ○ First, the Town of Los Gatos should work with our state legislators to expand the Marin County e-bike pilot to Santa Clara County. AB 1778 allows Marin County to enact a pilot program that bans anyone under 16 years old from riding Class 2 e-bikes, thus putting the same regulations in place for both Class 2 and 3 e-bikes. ○ Second, the Town of Los Gatos should support AB 875. AB 875, authored by Assemblymember Al Muratsuchi, would provide law enforcement officers more latitude to remove and impound illegal e-motorcycles. This legislation is supported by the California Police Chiefs Association.
○ Further legislation efforts could include expansion of AB 2234, the San Diego Electric Bicycle Safety Pilot Program, that prohibits a person under the age of 12 from operating any electric bicycle.

4. Enforcement: The Town of Los Gatos should explore taking legislative action to align an E-bike Ordinance with the Town’s Social Host Ordinance.

ATTACHMENT 1
○ Doing so would allow for the Town to issue up to a $1,500 administrative citation for parents of a juvenile found in violation of e-bike laws. *Simplistic example of how to structure a Buyer’s Guide:

Illegal Can be converted to be illegal Legal
● All Surron e-motos
● All Talaria e-motos
● Segway Xyber
● Super73 ● Electra
● Trek
● Specialized
● Gazelle
Note: The three bike shops in Los Gatos only sell street-legal e-bikes. Shop locally, shop legally!