Los Gatos City Council
December 2, 2025

ITEM NO. 8.

11.0 Noise
11-4 EMC Planning Group Inc.

Construction Noise Impacts
Construction activities, which are anticipated to last approximately 30 months, would result in temporary, short-term noise increases due to the operation of heavy equipment on the project site. Construction-related noise can range from about 76 to 85 dBA at 50 feet for most types of construction equipment with slightly higher levels of about 88 to 91 dBA at 50 feet for certain types of earthmoving and impact equipment (Federal Highway Administration 2015).

Construction of the proposed project would take place near existing hillside residences as close as 100 feet from the boundaries of the project site. Most residences in the vicinity are located north toward Broadway. Rural, hillside residences and estates are located south and west uphill from the project site. These sensitive receptors may be affected by constructionrelated noise.

The Town Noise Ordinance (Chapter 16) restricts construction activities to the hours of 8:00 am to 6:00 pm on weekdays and 9:00 am to 4:00 pm on Saturdays. Construction activities are prohibited on Sundays and holidays. No individual piece of equipment shall produce a noise level exceeding 85 dBA at 25 feet. The General Plan EIR states that adherence to the Town’s Noise Ordinance would reduce construction-related noise impacts to a less-than-significant level (General Plan EIR, page 4.10-16).

Noise generated by construction activities would temporarily elevate noise levels at adjacent noise sensitive areas (single-family residences) during the anticipated 30 months of construction. However, based on the distance to adjacent residences, construction noise would not be anticipated to exceed 60 dBA Leq at adjacent noise sensitive outdoor use areas.

Construction on the project site would not occur during nighttime hours, when occupants of the residences would be expected to be most sensitive to noise.

As a result, construction noise generation from the proposed project would be considered a less-than-significant impact, assuming that construction activities are conducted in accordance with the implementation of the following construction best management practices, as identified in the Town’s Noise Ordinance:
 Pursuant to the Municipal Code, restrict noise-generating construction activities to the hours of 8:00 a.m. to 6:00 p.m., weekdays and 9:00 a.m. to 4:00 p.m. on Saturdays. Construction activities are prohibited on Sundays and holidays.  Pursuant to the Municipal Code, construction activities meet at least one of the following noise limitations:

IMPACT
11-1
Construction Activities Could Cause a Substantial Temporary Noise Increase Less than Significant

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 11-5
 No individual piece of equipment shall produce a noise level exceeding 85 dBA at 25 feet. If the device is located within a structure on the property, the measurement shall be made at distances as close to 25 feet from the device as possible.  The noise level at any point outside of the property plane shall not exceed 85 dBA.  All gasoline-powered construction equipment shall be equipped with an operating muffler or baffling system as originally provided by the manufacturer, and no modification to these systems is permitted.
 Unnecessary idling of internal combustion engines should be strictly prohibited.  Located stationary noise generating equipment such as air compressors or portable power generators as far as possible from sensitive receptors.  Utilize “quiet” air compressors and other stationary noise sources where technology exists.
 Control noise from construction workers’ radios to a point where they are not audible at existing residences bordering the project site.

With the incorporation of noise ordinance requirements, the construction noise impact resulting from construction of the proposed project and other site improvements would be less than significant.

Construction Groundborne Vibration Impacts
According to the Federal Transportation Administration (FTA), a significant impact would be identified if the construction of the project would generate groundborne vibration levels at adjacent structures exceeding 0.3 in/sec PPV because these levels would have the potential to result in “architectural” damage to normal buildings.

Construction activities include demolition of existing structures, site grading and excavation, underground garage construction, new building construction, and paving. The applicant has indicated that pile driving would not be needed for project construction. Project construction activities, such as drilling, the use of jackhammers, rock drills and other high-power or vibratory tools, and rolling stock equipment (tracked vehicles, compactors, etc.) may generate substantial vibration in the immediate vicinity of the work area. Vibration levels would vary depending on soil conditions, construction methods, and equipment used.

Table 11-1, Vibration Source Levels for Construction Equipment, presents typical vibration levels that could be expected from construction equipment at a distance of 25 feet (Federal Transit Administration 2006).

IMPACT
11-2 Groundborne Vibration during Construction Activities Less than Significant

ITEM NO. 8.

11.0 Noise
11-6 EMC Planning Group Inc.

Table 11-1 Vibration Source Levels for Construction Equipment Equipment PPV at 25 ft. (in./sec.) Approximate Lv at 25 ft. (VdB)
Pile Driver
(impact)
Upper range 1.518 112
Typical 0.644 104
Pile Driver (sonic) Upper range 0.734 105
Typical 0.170 93
Clam shovel drop (slurry wall) 0.202 94
Hydromill (slurry
wall)
In soil 0.008 66
In rock 0.017 75
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large bulldozer 0.089 87
Caisson drilling 0.089 87
Loaded trucks 0.076 86
Jackhammer 0.035 79
Small bulldozer 0.003 58
SOURCE: Federal Highway Administration 2006b (Table 12-2, p. 12-12) The California Department of Transportation (Caltrans) provides further guidance on vibration issues associated with construction and operation of project in relation to human perception and structural damage in its 2020 Transportation and Construction Vibration Guidance Manual. Recommendations are provided for levels of vibration that could result in damage to structures exposed to continuous vibration. 0.2 in/sec PPV is Caltrans’ recommended vibration level where the risk of architectural damage could occur to normal dwelling houses (Caltrans 2020, Technical Advisory, Table 2).

Operation of construction equipment can cause ground vibrations that diminish in strength with distance from the source. Buildings founded on the soil in the vicinity of a construction site may be affected by these vibrations, with varying results ranging from no perceptible effects at the lowest levels, low rumbling sounds and perceptible vibrations at moderate levels, and slight damage at the highest levels. Typically ground vibration does not reach a level where it damages structures unless the structure is extremely fragile.

Maximum ground vibration levels would be associated with the potential use of large bulldozers during construction activities. According to FTA, vibration levels associated with large bulldozers are 0.089 in/sec PPV and 87 VdB at 25 feet. Vibration levels from large bulldozers could exceed Caltrans recommended level of 0.2 in/sec PPV with respect to the structural damage within 15 feet of large bulldozer activities (Caltrans 2020) and could

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 11-7
exceed FTA’s maximum acceptable level of 80 VdB with respect to human response within 43 feet of large bulldozer activities (FTA 2006). The nearest existing structures to project construction areas include single-family residences located as close as approximately 60 feet from the property line to the north, and commercial structures located as close as approximately 75 feet east of the site, along S. Santa Cruz Avenue. Therefore, ground vibration levels from potential large bulldozer activities would not result in levels that could damage nearby structures or result in human disturbance. Project impacts associated with construction-related ground vibration and vibration noise would be less than significant.

ITEM NO. 8.

11.0 Noise
11-8 EMC Planning Group Inc.

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ITEM NO. 8.

EMC Planning Group Inc. 12-1

12.0 Wildfire Hazards
Information is this section is derived from the following sources, as well as sources noted herein:
 Town of Los Gatos 2020 General Plan (Town of Los Gatos 2011);  Town of Los Gatos 2020 General Plan Draft Environmental Impact Report (Town of Los Gatos 2010);
 Town of Los Gatos Emergency Operations Plan (Town of Los Gatos 2015); and  Town of Los Gatos 2040 Background Report (Town of Los Gatos 2019).

The Town of Los Gatos did not receive any comments regarding wildfire hazards in response to the notice of preparation.

12.1 ENVIRONMENTAL SETTING
The project site consists of approximately 10.84 acres of heavily vegetated hillside property and is located in the southwestern portion of Los Gatos. Site topography varies and includes slopes that average 24 percent but are as steep as 40 percent. The upslope (western) section of the parcel is undeveloped and consists primarily of native oak woodland with small, scattered patches of chaparral. The oak woodland is dominated by coast live oak and California bay. Semi-rural, single family residences are located north, south, east, and west of the property along with commercial uses to the east along S. Santa Cruz Avenue.

The project site is located in a very high fire hazards area, within a state-mandated Local Responsibility Area (LRA) (Town of Los Gatos 2011, Figure SAF-3, “Wildland-Urban Interface Fire Area”). Figure 12-1, Fire Hazard Severity Zones, presents the project site within the context of very high fire hazard areas as identified in the Town’s General Plan.

The wildfire risk in Los Gatos and in the Santa Cruz Mountains above it to the south and west is seasonal in nature. Because of the types of vegetation and typically high moisture content this risk is usually small. Wind patterns in the Santa Clara Valley are influenced greatly by terrain, resulting in a prevailing wind flow roughly parallel to the Valley’s northwest-southeast axis. However, during years of drought there are occasions when winds blowing east to west dry out the hillsides and cause wildfire concerns (Town of Los Gatos

ITEM NO. 8.

12.0 Wildfire Hazards
12-2 EMC Planning Group Inc.
2010). The Lexington Fire in 1985, which burned 42 buildings and 13,000 acres, the 1997 Cats Fire that threatened downtown and burned 15 acres immediately south of the project site, the Stevens Canyon Fire in 2007 and the Summit Fire of June 2008 are examples of fires that do threaten the area (Town of Los Gatos 2015). The 2020 CZU August Lighting Fire burned over 86,500 acres in the Santa Cruz Mountains and its eastern perimeter was located approximately 10.25 miles southwest of the project site (InciWeb 2020).

12.2 REGULATORY SETTING
Section 3.0, Environmental Setting includes a consistency evaluation of the relevant environmental policies of the Town of Los Gatos 2020 General Plan, the Los Gatos Sustainability Plan, and the Los Gatos Hillside Specific Plan. In addition to those relevant policies, the following regulations may also apply to the proposed project.

State
California Building Code
The California Building Standards Code (CBC) (California Code of Regulations, Title 24) provides minimum standards for the design and construction of buildings and structures in California. Minimum standards are organized under Part 1 to 12 and include code standards for buildings, mechanical, plumbing, energy, historical buildings, fire safety, and green building standards. State law mandates that local government enforce these regulations, or local ordinances, with qualified reasonably necessary and generally more restrictive building standards than provided in the CBC. Title 24 is applicable to all occupancies, or structures, throughout California, whether or not the local government takes an affirmative action to adopt Title 24.

California Fire Code
The California Fire Code (CFC) is Chapter 9 of Title 24 of the California Code of Regulations (CCR). It was created by the California Building Standards Commission and is based on the International Fire Code created by the International Code Council. It is the primary means for authorizing and enforcing procedures and mechanisms to ensure the safe handling and storage of any substance that may pose a threat to public health and safety. The CFC regulates the use, handling, and storage requirements for hazardous materials at fixed facilities. The CFC and the California Building Code use a hazards classification system to determine what protective measures are required to protect fire and life safety. These measures may include construction standards, separations from property lines, and specialized equipment. To ensure that these safety measures are met, the CFC employs a permit system based on hazard classification. The CFC is updated every three years and was most recently updated in 2019.

ITEM NO. 8.

N SANTA CRUZ AV

E MAIN ST

ATOGA RD

W MAIN ST

LOS GATOS BL

N CREEK TRAIL

UNIVERSITY AV

TAIT AV

VILLA AV

BACHMAN AV

S CREEK TRAIL

LOMA ALTA
ALLEY

JOHNSON AV

COLLEGE AV

ALPINE A

BELLA VISTA AV

VICTORY LN

WOOD RD

BEAN AV

JACKSON ST

MILES AV

HERNANDEZ AV

KIMBLE AV

BROADWAY

HIGHLAND AV

CENTRAL AV

GLEN RIDG

OAK HILL WY

PENNSYLVANIA AV
APR

PROSPECT AV

EDELEN AV

WILDER AV

MANZANITA AV

NICHOLSON AV

NEW YORK AV

JONES RD

OVERLOOK RD

OAK KNOLL RD

CLELAND AV

DITTOS LN

REEDHEAD LN

EUCLID AV
DRA AV
WRA

WOODLAND AV

PARK AV

MADRONE AV
C

BAYVIEW AV
ELM ST

CHURCH ST

WISSAHICKON AV

PALM AV
B

LAUREL AV

SHELDON DR

BOYER LN
ELLENW
WAL
NUT AV

PLEASANT ST

ROGERS ST

ALBERTO WY

GROVE ST

WADSWORTH AV

PERALTA AV

OAK GROVE AV

GRAYS LN

HIGHLAND TR

ROYCE ST

STATION WY

CHESTNUT AV

FAIRVIEW PZ

VILLAGE LN

FAIRVIEW AV

RIDGE RD

LA MIRADA DR

W MAIN ST

MAGGI CT

MAPLE AV

MULLEN AV

LUNDY LN

FIESTA WY

MILL ST

PANIGHETTI PL

HIGH SCHOOL CT

CLIFTON AV

SIMONS WY

PAGEANT WY

CENTRAL CT

MONTEBELLO WY

W CENTRAL AV

MASSOL CT

BAYVIEW CT

UNKNOWN
ALLEY

MILL ST

UNKNOWN
ALLEY

N SANTA CRUZ AV

E MAIN ST

LOS GATOS-SARATOGA RD
N ST

LOS GATOS BL

KENNEDY RD

N CREEK TRAIL

UNIVERSITY AV

TAIT AV

VILLA AV

BACHMAN AV

NINO AV
L

LOMA ALTA AV
ALLEY

JOHNSON AV
COLLE
AL

MASSOL AV

HARDING AV
T

VISTA DEL MONTE

BELLA VISTA AV

SAN BENITO AV

PINE AV

VICTORY LN
N AV

JACKSON ST

ENGLEWOOD AV

MILES AV

KIMBLE AV

OAK HILL WY

CAUSEY LN

FERRIS AV

EDELEN AV

WILDER AV

STACIA ST

TOWNE TR

WHITNEY AV

MONTEREY AV

ROBIE LN

RIVIERA DR
AV

NEW YORK AV

CLELAND AV

JARED LN

DITTOS LN

LOMA ST

REEDHEAD LN

FILLMER AV

ALMENDRA AV

WRAIGHT AV

WOODLAND AV

PARK AV

ALBERT D

CHESTER ST

CALDWELL AV

CHARLES ST
ELM ST

CHURCH ST

BIRD AV
GEM AV

BOYER LN

PLEASANT ST

ROGERS ST

ALBERTO WY
VE ST

WHEELER AV

AVERY LN

MONTGOMERY

HOLLYWOOD AV

GRAYS LN

ROYCE ST

VISTA DEL MAR

STATION WY

LITTLEFIELD LN
NINO W

RAMEL WY

VILLAGE LN

ANDRE CT

MAGGI CT

SPENCER AV

MAPLE AV

SPRECKLES AV

MULLEN AV

WORCESTER LN

ALBERT CT

LUNDY LN

FIESTA WY

VISTA DEL CAMPO

MILL ST

PANIGHETTI PL

HIGH SCHOOL CT

YOSEMITE WY

SIMONS WY

CALFHILL CT

CERRO CHICO

PAGEANT WY

HUBBEL WY

NTRAL CT
BRIC

MONTEBELLO WY

ALTA HEIGHTS CT

MILL ST
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BRANHAM LN

CAMDEN AV

LEIGH AV

HARWOOD RD

LOS GATOS-ALMADEN RD

BRANHAM LN

ROSSWOOD DR

ALAN AV

RUDY DR

LEIGH AV

HARWOOD RD

SANDY LN

LAURINDA DR

RAFTON DR

CLOVIS AV

ELROSE AV

WESTHILL DR

MICHON DR
LP

MERRILL DR

LITTLE BRANHAM LN

DRYSDALE DR

BELGATOS RD

CANNA LN

BELGATOS L

CARTER AV

CARM AV

WILLOW DR

HERSHNER DR

HYACINTH LN

NOELLA WY

TONY AV

MARY JO WY

GILDA WY

CHEVALIER DR

RUCKER DR

ALMOND BLOSSOM LN

COPELAND LN

CONRAD AV

ANNA DR

LONE HILL RD

ZINNIA LN

ALBERT AV

BELVUE DR

DEL ORO DR

REGENT DR

EMILINE DR

BELHAVEN DR

GREGG DR

ROXANNE DR

VINTNER WY

HARLOW WY

BELRIDGE DR

TRENT DR

BACIGALUPI DR

BEGONIA DR

MUIR DR

LAURA DR

BELBLOSSOM WY
KAY DR

BELWOOD GATEWAY

FERN DR

LENORA AV

BELCREST DR

HOWES LN

TILDEN DR

ROMFORD DR

BELVALE DR

SALLY DR

CARDEL WY

BELGLEN WY

SELINDA WY

MIRASSOU DR

SHARON WY

CORDOY LN

KENTFIELD DR

HOLDEN CT

REBEL WY

IXIAS CT

PETRI PL

LAUREN DR

PEONY LN

DALTON DR

ADELAIDE WY

CLARINDA WY

GABLE LN

CANTO DR

CORALEE DR

MEADOWBROOK DR

BRENDA AV

CAROLINE WY

MILLIGAN DR

SELINDA LN

MARY JANE WY

ROSS AV

GATTUCIO DR

LOBELIA LN

DALTON PL

IXIAS LN

OLD ORCHARD DR

BOBBYWOOD AV

NORA WY

BANBERRY WY

FORREST HILL DR

STANDISH DR

BELBLOSSOM DR

GEMINI CT

MAITLAND DR

HERBERT DR

JAMIE CT

HYDRANGEA LN

ASPEN CT

THURESON WY

ACTON CT
HS

SURMONT DR
T

ANNE CT

MORNING GLORY LN

MERRITON CT

DEL ORO CT

EMLINE DR

COPELAND PL

SWAIN WY

AGAPE CT

DEL ORO PL
O PL

HEINTZ CT

TROY PARK PL

MICHON CT

REGENT CT

RUDY CT

CAMPOS VERDES

ALMOND BLOSSOM CT

BACIGALUPI DR

GEMINI CT

BEGONIA DR

HARWOOD RD

CARTER AV

BELVUE DR
Legend
Buildings
Parcels
Original Hazardous Fire Area (OHFA)
LosGatos
Very High Fire Hazard Areas
State Mandated LRA (VHFHA)
Town of Los Gatos Designated (WUIFA)
State Mandated Pre-Zone (VHFHA)
Pre-Zoned Town Designated (WUIFA)
)LUH$UHD

BRANHAM LN

CAMDEN AV

LEIGH AV

HARWOOD RD

LOS GATOS-ALMADEN RD

BRANHAM LN

ROSSWOOD DR

ALAN AV

RUDY DR

LEIGH AV
D

RAFTON DR

CLOVIS AV

ELROSE AV

WESTHILL DR

MICHON DR

MERRILL DR

LITTLE BRANHAM LN

DRYSDALE DR

BELGATOS RD

CARTER AV

CARM AV

WILLOW DR

NOELLA WY

MARY JO WY

GILDA WY

CHEVALIER DR

RUCKER DR

ALMOND BLOSSOM LN

COPELAND LN

CONRAD AV

ANNA DR

LONE HILL RD

ALBERT AV

BELVUE DR

DEL ORO DR

EMILINE DR

GREGG DR

ROXANNE DR

VINTNER WY

HARLOW WY

TRENT DR
DR

BEGONIA DR

MUIR DR

LAURA DR

BELBLOSSOM WY
KAY DR

BELWOOD GATEWAY

FERN DR

LENORA AV

HOWES LN

TILDEN DR

ROMFORD DR

BELVALE DR

SALLY DR

CARDEL WY

BELGLEN WY

SELINDA WY

MIRASSOU DR

SHARON WY

CORDOY LN

HOLDEN CT

REBEL WY

PETRI PL

LAUREN DR

PEONY LN

DALTON DR
IDE WY
DA WY

GABLE LN

CANTO DR

CORALEE DR

BRENDA AV

CAROLINE WY

MILLIGAN DR

SELINDA LN

MARY JANE WY

ROSS AV

GATTUCIO DR

LOBELIA LN

DALTON PL

OLD ORCHARD DR

BOBBYWOOD AV

NORA WY

BANBERRY WY

BELBLOSSOM DR

GEMINI CT

MAITLAND DR

JAMIE CT

HYDRANGEA LN

ASPEN CT

THURESON WY

ACTON CT

SURMONT DR

ANNE CT

MORNING GLORY LN

MERRITON CT

DEL ORO CT

EMLINE DR

COPELAND PL
Y

AGAPE CT

DEL ORO PL

TROY PARK PL

MICHON CT

CAMPOS VERDES

ALMOND BLOSSOM CT

BACIGALUPI DR

GEMINI CT

HARWOOD RD

CARTER AV

BELVUE DR
Legend
Buildings
Parcels
Original Hazardous Fire Area (OHFA)
LosGatos
Very High Fire Hazard Areas
State Mandated LRA (VHFHA)
Town of Los Gatos Designated (WUIFA)
State Mandated Pre-Zone (VHFHA)
Pre-Zoned Town Designated (WUIFA)
UHD
Legend
Project Site
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR Fire Hazard Severity Zones
Figure 12-1
Source:
0 2700 feet

ITEM NO. 8.

12.0 Wildfire Hazards
12-4 EMC Planning Group Inc.

This side intentionally left blank.

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 12-5
CFC Chapter 49 provides minimum standards to increase building resistance to the intrusion of flame or burning embers projected by a vegetation fire and identifies performance and prescriptive requirements. Section 4906 provides hazardous vegetation fuel management requirements for buildings and structures located on land in a Very High Fire Hazard Severity Zone (VHFHSZ) in Local Responsibility Areas (LRAs) and land in a Moderate Fire Hazard Severity Zone (MFHSZ), High Fire Hazard Severity Zone (HFHSZ), or VHFHSZ in State Responsibility Areas (SRAs). In addition, Section 4907 requires the local entity with jurisdictional authority over areas designated VHFHSZ in LRAs to maintain defensible space near buildings and structures.

County and Local
Santa Clara County Operational Area Hazard Mitigation Plan (2017) The Santa Clara County Local Planning Team with representatives from the Town of Los Gatos identified 25 possible hazard threats within the county boundary. Santa Clara County’s Office of Emergency Services is collaborating with incorporated cities to update the countywide local hazard mitigation plan. This plan outlines mechanisms for increasing the county’s resiliency to natural hazard events, including wildfire.

Santa Clara County Hazardous Brush Abatement Program
The Santa Clara County Fire Department manages and implements a hazardous brush abatement program for hillside areas within its jurisdictional boundaries including the Town of Los Gatos. In January of each year, homeowners are reminded that they must remove native brush and vegetation from around their home to create defensible space. The brush abatement program entails inspections of hillside properties by fire crews beginning early April each year. If properties are found to not be in compliance with the regulations found in the California Fire Code relative to vegetation clearance, they are given notice of the violation. If compliance is still not achieved by approximately the end of June each year, a contractor is authorized to perform the necessary work. The costs associated with the abatement work are then placed on the property tax bill for that parcel (Santa Clara County Fire Department 2021).

Town of Los Gatos Emergency Operations Plan (2015)
The Emergency Operational Plan (EOP) for the Town of Los Gatos is a joint effort between the Town of Los Gatos and the Santa Clara County Fire Department. The Santa Clara County Fire Department promotes a regional approach to the service provided. Emergency management staff from the Santa Clara County Fire Department have developed the Emergency Operations Plans for the cities of Campbell, Cupertino, Monte Sereno, Saratoga, and the Town of Los Gatos. By doing so all of the emergency plans of the West Valley cities have a common format and inasmuch as possible standardized procedures and protocols.

ITEM NO. 8.

12.0 Wildfire Hazards
12-6 EMC Planning Group Inc.

This approach ensures compliance with planning requirements and mandates. By planning this way, the partnered cities are able to participate in joint training programs, conduct joint exercises, and manage disasters with the same approach.

The Town of Los Gatos’ responsibility within the framework of the EOP is to decide when this plan and the Emergency Operations Center will be activated, coordinate volunteer response efforts, deploy personnel and resources to address disaster caused needs, issue emergency proclamations when needed, and coordinate response and recovery efforts with the County Emergency Operations Center. Town Council members will approve emergency proclamations, maintain public contact, conduct interviews in conjunction with the Public Information Officer, and utilize political connections with their counterparts at the State and Federal levels to ensure response and recovery processes are followed and sustained (Town of Los Gatos 2015).

Town of Los Gatos Code Chapter 9 (Fire Prevention and Protection) The Town Code sets forth provisions and requirements for fire prevention and protection systems for all new buildings through adoption of the 2019 California Fire Code and 2018 International Fire Code. The Town Code also sets requirements for Wildland-Urban Interface Fire Areas (Chapter 49 of the 2019 California Fire Code) and sets requirements for maintenance of defensible space including maintaining 100 feet from each side, from the front, and rear of any building or structure, maintaining overhanging tree limbs and shrubs, removing combustible vegetation and clearing areas along fire apparatus access roads and driveways.

Town of Los Gatos Roadside Vegetation Management Plan (2020) The Town of Los Gatos Roadway Vegetation Management Plan (vegetation management plan), adopted in 2020, requires removing hazardous vegetation and creating defensible space around approximately 31.09 miles of Town-owned hillside roadways that have been identified by the Town and Town residents as roadways of high concern. These Townowned roadways include evacuation routes and other collector, neighborhood, and hillside collector roads that are located within the wildland urban interface (WUI) and/or are have been identified by the Town and Town residents as having inadequate access for emergency response during a wildfire. Under the plan, work will focus on removing roadside vegetation to create a clear space that is 20 feet wide and 13 feet, 6 inches above roadways, as well as clearance of non-fire-resistant vegetation within 10 feet of the roads. Clearing these areas will not only improve emergency vehicle access and evacuation safety, but will also reduce the amount of heat that evacuating residents might be exposed to during a fire, improve visibility, and expand the usable width of roadways on narrow hillside streets.

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 12-7
The Town has identified three priority levels of roadways where vegetation management for fire safety is of utmost concern. These levels are based on Vegetation Management Action Levels (VMAL) which are defined by the amount of vegetation encroachment into and along the edges of the roadway. In the vegetation management plan, Wood Road is identified as “VMAL 2” which is identified as moderate encroachment of roadside vegetation; some areas of dense native woodland as in VMAL1; additional areas of native scrub vegetation on open hillsides with non-native annual grasses, and pockets of dense flammable non-native invasive vegetation (e.g., acacia, broom) in the understory on hillslopes adjacent to roadways.” Wood Road is further identified as a “Priority Level 1,” an evacuation route, and is essential to ensuring emergency vehicles can access locations along these roads and ensuring the safety of residents as they evacuate in the event of a wildfire (Town of Los Gatos 2020).

12.3 THRESHOLDS OR STANDARDS OF SIGNIFICANCE
CEQA Guidelines Appendix G is a sample initial study checklist that includes a number of factual inquiries related to the subject of wildfire, as it does on a whole series of additional topics. Lead agencies are under no obligation to use these inquiries in fashioning thresholds of significance on the subject of public services impacts, or on any subject addressed in the checklist. Rather, with few exceptions, CEQA grants agencies discretion to develop their own thresholds of significance. Even so, it is a common practice for lead agencies to take the language from the inquiries set forth in Appendix G and to use that language in fashioning thresholds. The Town of Los Gatos has done so here. Therefore, for purposes of this EIR, a significant impact would occur if implementation of the proposed project (if located in or near state responsibility areas or lands classified as very high fire hazard severity zones) would:
 Substantially impair an adopted emergency response plan or emergency evacuation plan;
 Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
 Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; and
 Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

ITEM NO. 8.

12.0 Wildfire Hazards
12-8 EMC Planning Group Inc.

In addition, CEQA Guidelines Appendix G includes a question under “IX. Hazards and Hazardous Materials,” which states a project would result in a significant impact if it would:
 Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

12.4 ANALYSIS, IMPACTS, AND MITIGATION MEASURES
This section includes information and data regarding wildfire that are relevant to the proposed project based on the threshold of significance described above. The information and data are used as a basis for determining impact significance and for the mitigation measures.

Compatibility with Adopted Emergency Response and
Evacuation Plans
As noted previously, the Town of Los Gatos has, in conjunction with the County of Santa Clara and several other neighboring cities, an adopted EOP, which comprises, along with the 2017 Santa Clara County Operational Area Hazard Mitigation Plan, the entirety of emergency planning activities that governs emergency response and evacuation on and around the project site. Implementation of the proposed project would not interfere with an adopted emergency response or evacuation plan, but construction activities associated with the proposed project could result in short-term, temporary impacts on street traffic because of roadway improvements and potential extension of construction activities into the right-ofway. This could result in a reduction in the number of lanes or temporary closure of certain roadway segments near the project site. While any such impacts would be limited to the construction period and would affect only adjacent streets or intersections, the impact would be potentially significant. Implementation of the following mitigation measure would reduce this impact to a less-than-significant level.

Mitigation Measure
12-1 In order to adequately address any potential conflicts with emergency access or evacuation routes during construction, the applicant shall prepare and implement a site-specific construction traffic management plan for any construction effort that would require work within existing roadways. The traffic management plan IMPACT
12-1
The Proposed Project Would Result in Short-Term
Construction-Related Traffic Activity That Has the Potential to Impair an Adopted Emergency Response Plan or Emergency
Evacuation Plan
Less-than-Significant
Impact with
Mitigation

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 12-9
shall be prepared and submitted to the Town prior to issuance of demolition permit(s) and shall be prepared to the satisfaction of Town Public Works and County Fire Department staff.

Preparation and implementation of a construction traffic management plan, as required by Mitigation Measure 12-1, would adequately address any potential conflicts with emergency access or evacuation routes during construction by communicating proposed lane and road closures to first responders and allowing first responders to plan accordingly to ensure that emergency response times are met and maintain adequate emergency access. As a result, with mitigation this impact would be less than significant.

Exposure to Pollutant Concentrations from a Wildfire
The project site and much of the surrounding area is mapped as a very high fire hazard severity zone in either a LRA or SRA (CAL FIRE 2008). The project site sits on a heavily wooded hillside with slopes that average 24 percent but are as steep as 40 percent. Prevailing winds flow roughly parallel to the Santa Clara Valley’s northwest-southeast axis. The project sits at the far western edge of Santa Clara Valley. The upslope (western) section of the project site features native oak woodland with small, scattered patches of chaparral. The oak woodland is dominated by coast live oak and California bay. In addition, a drainage descends form the upslope oak woodland and flows towards the project site though only during rain events and flows to existing storm drain lines to Wood Road.

The proposed senior living community would involve indoor activities, and outdoor activities would be limited to vehicles driving on paved surfaces and people walking on paved surfaces and landscaped areas. The proposed senior living community buildings would be constructed of fire-resistant materials, including stone tiles, metal and concrete panel siding, brush stainless steel window frames, railings, and secondary structures, and standing seam metal roofing (see Sheet A204 of the project plans found in Appendix B for additional material descriptions), in compliance with Chapter 7A of the California Building Code (CBC) which specifies the building materials, systems and/or assemblies that must be used in the exterior design and construction of new buildings located within a Fire Hazards Severity Zone. The proposed project would be required to adhere to all fire prevention and protection requirements and regulations including Chapter 9 (Fire Prevention and Protection) of the Town Code and applicable sections of the California Fire Code, including requirements for the maintenance of defensible space around the buildings on the property.

Compliance with these regulations would reduce the potential of the structures on the IMPACT
12-2
The Proposed Project Could, Due to Slope, Prevailing Winds, and Other Factors Exacerbate Wildfire Risks, and Thereby Expose Project Occupants to Pollutant Concentrations from a Wildfire or the Uncontrolled Spread of a Wildfire.

Less than Significant

ITEM NO. 8.

12.0 Wildfire Hazards
12-10 EMC Planning Group Inc.
project site to catch fire during a wildfire, which in turn would reduce wildfire risk. In addition, as discussed in Section D.9, Hazards and Hazardous Materials, of the initial study, the transport, storage, and use of hazardous materials, including flammable materials, on the project site would be required to comply with existing State and local regulations as enforced by the Santa Clara County Environmental Health Department. This would minimize the potential for the occurrence of a fire due to improper handling of flammable materials.

The Santa Clara County Fire Department has reviewed the proposed project and identified significant wildfire hazards particular to this site. The County Fire Department provided conditions of approval regarding fire flow, vegetation and fuel modification, and sprinkler and fire alarm requirements, which are to be incorporated into the permit approvals. Based on the Fire Department’s review, the implementation of the conditions of approval would provide a sufficient fire protection system. Therefore, compliance with local and State requirements related to wildfires would reduce the potential of the proposed project to exacerbate wildfire risks and thereby expose project occupants to wildfire pollutants or the uncontrolled spread of a wildfire to a less-than-significant level.

Installation or Maintenance of Associated Infrastructure That May Exacerbate Fire Risk
The project site would be accessible via the existing 22-foot-wide Wood Road and a new 20- foot-wide secondary access (Farwell Lane) which is accessed at both the west and eastern boundaries of the facilities and connects to Broadway to the north of the site. Project plans show full fire access circulation around building perimeter. Additional bump-outs and widening lanes to 26 feet have been included as well (see sheets C108.1, C108.2, and C108.3).

In addition, a new fire engine turn-around is proposed at the western edge of the property along the dedicated fire access road to provide adequate turn radius for County Fire Department equipment in case of emergency.

The project site is currently served by at least two fire hydrants located along Wood Road and new fire hydrants are proposed near the entrance to Villa H and Villa B, outside Villa D at the north end of the project site, and at the western edge of the project site near Villa E.

Hydrant spacing has been dimensioned on sheet C108 and meets the 500-foot maximum as required by the County Fire Department and the California Fire Code. An additional Preliminary Hose Pull Plan has been broken out with dimensions to show all exterior parts of buildings are within 600 feet of a fire hydrant (see sheet C109). The water line serving the IMPACT
12-3
The Project Would Not Require the Installation or Maintenance of Associated Infrastructure (such as Roads, Fuel Breaks, Emergency Water Sources, Power Lines or Other Utilities) that May Exacerbate Fire Risk or That May Result in Temporary or Ongoing Impacts to The Environment.

No Impact

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 12-11
fire hydrants are shown on sheet C106. A revised fire flow analysis was provided by San Jose Water for the existing fire hydrant across Wood Road east of the project site. The revised fire flow analysis shows a gallons per minute of 650 at 20 pounds per square inch which is below the required 1,500 gallons per minute at 20 pounds per square inch as required in the California Fire Code. This will necessitate improvements to fire flow systems at this fire hydrant to ensure adequate fire-fighting capabilities at and around the project site. These improvements to fire flow will be implemented through conditions of approval through the Santa Clara County Fire Department.

These required infrastructure improvements are intended to enhance and improve the firefighting capabilities of County Fire personnel on and around the project and would not result in additional infrastructure that could exacerbate fire risks or result in other impacts to the environment.

Exposure to Significant Risks as a Result of Runoff, PostFire Slope Instability, or Drainage Changes As noted in Section 13.0, Effects Not Addressed Further in this EIR, the 2007 Draft Preliminary Geologic and Geotechnical Evaluation for Los Gatos Meadows prepared by Cornerstone Earth Group (Appendix F), the project site and surrounding areas are moderately steep to steep slope with slope inclination up to 40 degrees and noted that portions of the site are located within a State of California Earthquake-Induced Landslide Hazard Zone. However, the 2020 Geotechnical Investigation and Geologic Hazards Evaluation (geotechnical report) (Appendix F) also prepared by Cornerstone Earth Group, conducted site-specific subsurface explorations which revealed soil characteristics (alluvial fan deposits underlain by shallow bedrock) that would not suggest the existence of previous landslides through the project site. As noted in the geotechnical report, the proposed project would create relatively deep vertical, retained cuts into the terrace that encompass the developed portion of the site. Localized groundwater seepage may be encountered where the cuts intersect the bedrock surface and installing a network of subdrains and water proofing would address this. The geotechnical report also found the proposed grading plan for the project to be acceptable from a safety standpoint with the exception of a lower slope (below proposed structures) area that may experience a lack of stability with the existing alluvial fan deposit soils there. The geotechnical report recommends removal of these alluvial fan deposits at this location down to bedrock to be replaced by engineered fill. Compliance with this recommendation as IMPACT
12-4
The Project Could Expose People or Structures to Significant Risks, including Downslope or Downstream Flooding or
Landslides, as a Result of Runoff, Post-Fire Slope Instability, or Drainage Changes.

Less-than-Significant
Impact with
Mitigation

ITEM NO. 8.

12.0 Wildfire Hazards
12-12 EMC Planning Group Inc.
incorporated in Mitigation Measures 13-1 and 13-2 found in Section 13.0 of this EIR (under discussion of “Geology and Soils”) would ensure this potentially significant impact would be reduced to a less-than-significant level.

The project site is located within a Federal Emergency Management Agency (FEMA) Flood Zone X, described as “areas of 0.2 percent annual chance flood hazard; areas of one percent annual chance flood with average depth less than one foot or with drainage areas of less than one square mile; and areas protected by levees from one percent annual chance flood” (FEMA 2021). However, as noted in the geotechnical report, the topographic characteristics of the project site and its location on a high hilltop far above any nearby bodies of water precludes it from being impacted by flooding from any stream sources or bodies of water.

The nearest waterway is Los Gatos Creek, which is located about 0.20 miles southeast from the project site across State Route 17. At this distance and given the elevation of the project site, the project site is unlikely to experience any risk of flooding from this stream.

A drainage descends from the upslope oak woodland and flows towards the project site.

These drainages are likely ephemeral and only flow during rain events. Water collecting within the drainage likely flows to existing storm drain lines that currently direct and store water within the development footprint, conveying storm water to the Wood Road storm water system. Currently, several catch basins collect surface runoff water from Wood Road and South Santa Cruz Avenue east of the property line (Cornerstone Earth Group 2020). The proposed project would ensure stormwater would be retained onsite through several bioretention basins/planters (Kimley-Horn 2021). These bio-retention basins would be required to be constructed in compliance with Town Engineering requirements for stormwater retention facilities. Therefore, post-fire slope instability, increased runoff, or drainage changes in areas surrounding the project site would not expose people or structures at the project site to increased risk of flood or landslides. This impact would be less than significant.

Expose People or Structures to a Significant Risk of Loss, Injury or Death Involving Wildland Fires
The proposed project is located in a very high fire hazards area. The project area is surrounded by forested hillsides and includes redevelopment of the site with a new senior living community to replace the existing, closed senior living facility. While the use of the project site would remain the same, due to the proximity of this new senior living community to forested hillsides, and because of the high fire severity zone rating of the area, the potential to expose people and structures to risk from wildland fires is high and could expose people or structures to significant risks associated with wildland fires.

IMPACT
12-5
The Project Could Expose People or Structures to Significant Risks Associated with Wildland Fires Less than Significant

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 12-13
The proposed project includes design features and infrastructure improvements that are discussed throughout this section help further reduce the overall risk of the project site to wildfire hazards. Conditions of approval and mitigation measures identified throughout this section further reduce risks associated with wildfire hazards and reduce potentially significant impacts to a less-than-significant level.

To further mitigate the existing fire safety issues, the applicant submitted a Tree Management Plan and request for Tree Removal Permit to the Town on September 26, 2019.

The tree management recommendations are based on fire safety, sudden oak death, species invasiveness and tree risk. Phase 1 of the Tree Management Plan identified recommendations for removal of 44 trees based on the following criteria: (1) they disproportionately contribute to fire risk or are invasive and (2) based on their health, structure and condition, they do not contribute to site screening between properties. Fire risk and invasive trees are the most imminent risk for the site. Los Gatos Meadows has been closed, in part, due to fire risk. Limiting the spread of invasive species to other portions of the site and neighboring sites is time sensitive as well. Additionally, vegetation management and operational activities on the project site would be required to comply with defensible space requirements found in the Town Code to further reduce wildfire risk.

Each of the measures described above and proposed or already implemented by the applicant are intended to comply with both Santa Clara County Fire Department and California Fire Code requirements and improve overall fire-fighting capabilities of fire personnel on and around the project site. The Santa Clara County Fire Department has reviewed the project and provided conditions of approval regarding fire flow, vegetation and fuel modification, and sprinkler and fire alarm requirements, which are to be incorporated into the permit approval. Compliance with these conditions of approval would help further ensure the proposed project would not result in significant exposure of people or structures to wildland fire risk. Therefore, this impact would be less than significant.

ITEM NO. 8.

12.0 Wildfire Hazards
12-14 EMC Planning Group Inc.

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ITEM NO. 8.

EMC Planning Group Inc. 13-1

13.0 Effects Not Addressed Further in this EIR
As noted in Section 1.0, Introduction, this draft EIR focuses on the significant effects on the environment in accordance with CEQA Guidelines section 15143. The significant effects are discussed with emphasis in proportion to their severity and probability of occurrence. Effects dismissed in an initial study as clearly insignificant and unlikely to occur need not be discussed further in the EIR unless the lead agency subsequently receives information inconsistent with the finding in the initial study.

CEQA allows a lead agency to limit the detail of discussion of the environmental effects that are not considered potentially significant (PRC Section 21100, CCR Sections 15126.2[a] and 15128). Environmental issue areas scoped out of the EIR are listed below with a brief explanation of why a) there would not be an impact to these resource areas, b) there would be a less-than-significant impact, or c) there would be a less-than-significant level with mitigation, as detailed in the initial study prepared for this project (see Appendix A).

13.1 NO IMPACT
Per the findings of the initial study prepared for the proposed project, no impacts were identified in the following areas:
 Agriculture and Forest Resources;
 Land Use and Planning;
 Mineral Resources;
 Population and Housing;
 Public Services;
 Recreation; and
 Utilities and Service Systems.

Refer to the initial study included in Appendix A for additional information for each of the environmental issues noted above.

ITEM NO. 8.

13.0 Effects Not Addressed Further in this EIR
13-2 EMC Planning Group Inc.

13.2 LESS-THAN-SIGNIFICANT IMPACT
Hydrology and Water Quality
As noted in Section D.10, Hydrology and Water Quality, of the initial study, the State Water Resources Control Board has implemented a National Pollutant Discharge Elimination System (NPDES) Program to control and enforce storm water pollutant discharge reduction per the Clean Water Act. In accordance with the requirements of this program, the project applicant would be required to obtain a State NPDES Construction General Permit for redevelopment of the 10.84-acre project site.

Further, Section 22.30.035 of the Town Municipal Code outlines requirements for storm water management on new development and redevelopment projects. Every new development or redevelopment project is required to identify the potential for stormwater to be discharged from the project site following completion of construction activity and demonstrate that the plans, drawings, or specifications for such project include the installation of management techniques, practices, and control measures designed to mitigate the potential adverse impacts of storm water that may be discharged from the project site on an ongoing basis, including storm water treatment measures.

By complying with the Construction General Stormwater Permit and the Town’s stormwater management requirements, the proposed project would not violate any water quality standards or degrade water quality and would not exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Transportation
The Los Gatos Meadows – Transportation Analysis (dated January 21, 2020) was prepared for the proposed project by Kimley Horn, the applicant’s consultant. TJKM, the Town’s transportation consultant, conducted a peer review of the Kimley Horn analysis, which was documented in a memo dated November 24, 2020. Kimley Horn subsequently prepared a revised transportation analysis dated December 9, 2020, as well as a response to comments memo dated December 10, 2020. TJKM then provided further comments based on the revised traffic analysis dated December 14, 2020, concluding that the analysis was acceptable.

All of these documents are included in Appendix A of the initial study, in chronologic order.

As detailed in Section D.17, Transportation, of the initial study, the proposed project was determined to not result in significant transportation impacts as the proposed project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. In addition, a vehicle miles travelled (VMT) analysis was conducted both with and without the proposed autonomous vehicle alternative transportation solution. With autonomous vehicles, the proposed project would result in no transportation impact; without the autonomous vehicles, the proposed

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 13-3
project would result in a less-than-significant impact as the project would be projected to result in a net increase in 10 vehicle trips per day, which is considerably less than the screening threshold of 110 vehicle trips per day as established by the Office of Planning and Research ‘s Technical Advisory on Evaluating Transportation Impacts in CEQA (2018).

Additionally, the proposed project would not increase hazards due to a design feature or result in inadequate emergency access.

13.3 IMPACTS REDUCED TO A LESS-THAN-SIGNIFICANT

LEVEL WITH MITIGATION
Geology and Soils
This section addresses potential impacts associated with geologic hazards. The applicant submitted Draft Preliminary Geologic and Geotechnical Evaluation for Los Gatos Meadows, prepared by Cornerstone Earth Group dated September 17, 2007, which was prepared for a previous owner/operator of the Los Gatos Meadows senior living community. In January 2020, the applicant submitted a Geotechnical Investigation and Geologic Hazards Evaluation (draft report) prepared by Cornerstone Earth Group, Inc., dated January 17, 2020; and Phase I Environmental Site Assessment and Preliminary Soil Quality Evaluation, also prepared by Cornerstone Earth Group, Inc., dated December 13, 2019, as part of the original application submittal. The Town’s consulting geologist, Cotton, Shires and Associates, Inc. reviewed all previous geotechnical and soils reports and prepared a peer review letter dated November 25, 2020. This peer review letter recommended submittal of a signed and stamped, final draft of the geotechnical report with clarifications, supplemental laboratory testing, and associated supplemental analysis results. The applicant then submitted a final version of Geotechnical Investigation and Geotechnical Evaluation (geotechnical report), prepared by Cornerstone Earth Group, Inc., dated December 30, 2020, in January 2021. A final peer review was prepared by Cotton, Shires and Associates, Inc., dated February 24, 2021, and concluded that that the geotechnical design recommendations contained in the December 2020 geotechnical report appear to be generally consistent with the prevailing standard of practice in the area. All previous and current geotechnical and soils reports along with peer review letters are included in Appendix F. The Town did not receive any responses to the notice of preparation regarding geologic hazards.

The geotechnical report noted several potential geologic impacts that are to be addressed through several design recommendations for the proposed project. These recommendations include, but are not limited to, providing a 25-foot setback from a mapped surface trace of a fault along the eastern edge of the property; underlaying the foundation by ground improvement or deepening the foundation to bedrock to avoid soil instability; removing alluvial fan deposits down to bedrock and replacing with engineering fill along the proposed

ITEM NO. 8.

13.0 Effects Not Addressed Further in this EIR
13-4 EMC Planning Group Inc.
retaining wall along the eastside of Farwell Lane for a minimum of 15 feet; removing and replacing all undocumented fill; and designing for sufficient reinforcement for slabs-ongrade. Implementation of the following mitigation measures, as articulated in the February 2021 geotechnical peer review conducted by the Town’s geotechnical consultant, would ensure potential geologic impacts are reduced to a less-than-significant level.

Mitigation Measures
13-1 The applicant's geotechnical consultant shall review and approve all geotechnical aspects of the development plans, ground improvement plans, shoring design criteria from a geotechnical perspective, and supporting structural details and calculations (i.e., site preparation and grading, site drainage improvements and design parameters for foundations, etc.,) to ensure that their recommendations have been properly incorporated. The project geotechnical consultant should review and approve appropriate performance testing for proposed ground improvement measures.

The results of the geotechnical plan review should be summarized by the project geotechnical consultant in a letter and submitted to the Town Engineer prior to issuance of building permits.
13-2 The geotechnical consultant shall inspect, test and approve all geotechnical aspects of the project construction. The inspections should include, but not necessarily be limited to:
 Site preparation and grading;
 Ground improvement;
 Shoring measures and design;
 Site surface and subsurface drainage improvements; and  Excavations for foundations prior to placement of steel and concrete.

In addition, the project engineering geologist shall inspect opened excavations to confirm bedrock conditions are consistent with those anticipated.

The results of these inspections and the as-built conditions of the project, including ground improvement measures and placement of engineered fill, should be described by the geotechnical consultant in a letter and submitted to the Town Engineer for review and approval prior to final (as-built) project approval.

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 13-5
Specialty/design-build consultants and contractors (shoring, ground improvement, etc.) shall also submit construction reports confirming satisfactory construction of the specific aspects of the project that they are responsible for.

Hazards and Hazardous Materials
As noted in Section D.9, Hazards and Hazardous Materials, in the initial study prepared for the proposed project, Phase I Environmental Site Assessment and Preliminary Soil Quality Evaluation (“environmental site assessment”) was prepared for the proposed project by Cornerstone Earth Group, Inc., dated December 13, 2019 (included as part of Appendix G).

This environmental site assessment identifies, to the extent feasible, the presence or likely presence of any hazardous substances in and around the project site. The proposed project includes demolition of the existing senior living community that was constructed in 1971.

Based on the age of the existing structures, building materials may contain asbestos.

Airborne asbestos fibers pose a serious health threat and the demolition, renovation, or removal of asbestos-containing building materials could result in exposure to these materials. If the existing on-site buildings contain asbestos, demolition could result in the release of asbestos into the air. This is a potentially significant impact.

According to the environmental site assessment, lead-based paint was banned in 1978. The existing senior community was constructed prior to 1978; therefore, lead-based paint may be present in the existing structures on the project site. Lead is a known carcinogen and its release during grading or other ground disturbing activities could pose hazards to public health and safety. This is a potentially significant impact.

Implementation of the following mitigation measure would ensure potential impacts from the release of asbestos and lead-based paint into the environment as a result of demolition activities are reduced to a less-than-significant level.

Mitigation Measure
13-3 The applicant shall consult with Bay Area Air Quality Management District to determine permit requirements. Removal of asbestos-containing building materials is subject to Bay Area Air Quality Management District’s Regulation 11, Rule 2: Asbestos Demolition, Renovation and Manufacturing. Release of lead into the atmosphere is subject to Bay Area Air Quality Management District’s Regulation 11, Rule 1: Lead.

Prior to the commencement of demolition activities on the site, the applicant shall provide evidence of meeting the permitting requirements of the Bay Area Air Quality Management District, to the satisfaction of the Town of Los Gatos Community Development Department.

Exposure to wildland fire risk as a result of the proposed project is addressed in Section 12.0, Wildfire Hazards, of this draft EIR.

ITEM NO. 8.

13.0 Effects Not Addressed Further in this EIR
13-6 EMC Planning Group Inc.

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ITEM NO. 8.

EMC Planning Group Inc. 14-1

14.0 Growth Inducing Impacts

14.1 CEQA REQUIREMENTS
Public Resources Code Section 21100(b) (5) and CEQA Guidelines Section 15126.2(d) require a discussion in the EIR of the growth-inducing impacts of a proposed project. The EIR must discuss the ways in which the project may directly or indirectly foster economic or population growth or additional housing in the surrounding environment, remove obstacles to growth, tax existing community services facilities, or encourage or facilitate other activities that cause significant environmental effects, either individually or cumulatively. Direct growth-inducing impacts result when the development associated with a project directly induces population growth or the construction of other development within the same geographic area.

The analysis of potential growth-inducing impacts includes a determination of whether a project would remove physical obstacles to population growth. This often occurs with the extension of infrastructure facilities that can provide services to new development. In addition to direct growth-inducing impacts, an EIR must also discuss growth-inducing effects that will result indirectly from the project, by serving as catalysts for future unrelated development in an area. Development of public institutions and the introduction of employment opportunities within the same geographic area are examples of projects that may result in growth-inducing impacts.

An EIR’s discussion of growth-inducing effects should not assume that growth is necessarily beneficial, detrimental, or of little significance to the environment. An EIR is required to discuss the ways in which the proposed project could foster growth.

14.2 THRESHOLDS OF SIGNIFICANCE
CEQA Guidelines Appendix G indicates that a project may have significant growth-inducing impacts if the project would induce substantial population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure).

ITEM NO. 8.

14.0 Growth Inducing Impacts
14-2 EMC Planning Group Inc.

14.3 GROWTH INDUCING IMPACT ANALYSIS
The approval of the proposed project would not represent a new commitment of land for development. Development of the project site for residential uses, in the form of a senior living community, has been envisioned by the Town since at least 1968, as the project site has a General Plan land use designation of Medium Density Residential and a zoning designation allowing for “Residential Planned Development (R:PD),” as proposed by the project. The General Plan land use designation of Medium Density Residential allows for a maximum density of 12 dwelling units per acre. However, consistent with density bonus laws in California, General Plan Action HOU-1.3 provides up to a 100 percent density bonus for developments that include housing for the elderly. The project proposes a density of 16 dwelling units per acre, which is within the maximum allowed for the site under the existing General Plan land use designation and PD permit conditions. The existing site and surrounding vicinity are located within Town limits and adjacent areas are developed with hillside residential uses as well as commercial development to the east along South Santa Cruz Avenue. Roads and water infrastructure already exist on the project site.

The proposed project’s utility infrastructure would be sized to accommodate the proposed project only. The proposed project’s infrastructure would not be sized to accommodate additional growth outside of the project site. Adjacent open space areas, Town General Plan land use designations, and Town limits will prevent any significant expansion beyond the project site. Construction and implementation of the proposed project would not remove physical obstacles to population growth. Therefore, the proposed project would not represent direct or in-direct growth-inducing impacts.

ITEM NO. 8.

EMC Planning Group Inc. 15-1

15.0 Cumulative Impacts

15.1 CEQA REQUIREMENTS
CEQA Guidelines Section 15130 requires a discussion of cumulative impacts when the project’s incremental effect is cumulatively considerable, as defined in section 15065(a)(3), which states, “The project has possible environmental effects that are individually limited but cumulative considerable. Cumulatively considerable means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” Where a lead agency is examining a project with an incremental effect that is not “cumulatively considerable,” a lead agency need not consider that effect significant, but shall briefly describe its basis for concluding that the incremental effect is not cumulative considerable. A cumulative impact consists of an impact that is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts. An EIR should not discuss impacts that do not result in part from the project evaluated in the EIR. When the combined cumulative impacts associated with the project’s incremental effect and the effects of other projects is not significant, the EIR shall briefly indicate why the cumulative impact is not significant and is not discussed in further detail in the EIR. A lead agency shall identify facts and analysis supporting its conclusion that the cumulative impact is less than significant.

A lead agency may determine that a project’s contribution to a significant cumulative impact will be rendered less than cumulatively considerable and therefore, is not significant.

A project’s contribution is less than cumulatively considerable if the project is required to implement or fund its fair share of a mitigation measure or measures designed to alleviate the cumulative impact. The lead agency shall identify facts and analysis supporting its conclusion that the contribution will be rendered less than cumulatively considerable.

The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by the standards of practicality and reasonableness and should focus on the cumulative impact to which the other identified projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact.

ITEM NO. 8.

15.0 Cumulative Impacts
15-2 EMC Planning Group Inc.

CEQA requires a cumulative development scenario to consist of either a list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency, or, a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact.

15.2 CUMULATIVE DEVELOPMENT SCENARIO
Geographic Scope
The geographic scope of the area affected by cumulative impacts can vary with the specific environmental topic being evaluated. Generally, the geographic scope of the area affected by cumulative projects impacts is larger than the boundary of the project site itself, which encompasses 6,216 acres within the Town limits and 5,260 acres outside the Town limits, for a total of 11,476 acres (Town of Los Gatos 2011, pages LU-6 to 7). For purposes of analyzing cumulative projects impacts, the geographic scope of the area affected ranges from development within the Town of Los Gatos to much broader areas such as Santa Clara County or the air basin. For example, aesthetic impacts are evaluated within the context of buildout of the Los Gatos General Plan; the entire air basin is the geographic boundary used in the cumulative air quality analysis; and the proposed project effect on climate change is evaluated at a state scale. Identification of the geographic scope is included in each cumulative impact discussion, and is summarized in Table 15-1, Cumulative Impact Analysis Geographic Scope.

Plans Projections and Projects Contributing to Cumulative Development Conditions in the Town
As allowed by CEQA Guidelines section 15130 (b)(1)(B), this EIR includes a summary of projections contained in the Town of Los Gatos 2020 General Plan to form the cumulative projects scenario; i.e., build-out of the General Plan. The General Plan provides an estimate of about 1,600 new residential units, 419,000 square feet of new retail, 516,000 square feet of new office, and 8,000 square feet of new industrial uses through 2020 within the Town limits and sphere of influence.

A summary of the impacts discussed in the General Plan EIR is presented and is supplemented by new data regarding development projections and impacts, as appropriate.

For each topic area, an evaluation and determination as to whether the proposed project’s impacts are cumulatively considerable is presented.

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
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Table 15-1 Cumulative Impact Analysis Geographic Scope
Resource Area Geographic Area
Aesthetics Los Gatos General Plan Buildout
Air Quality Los Gatos General Plan Buildout
Biological Resources Los Gatos General Plan Buildout and Santa Clara Valley Region Cultural, Paleontological, and Tribal Resources Los Gatos General Plan Buildout Energy State of California
Geology and Soils Los Gatos General Plan Buildout
Greenhouse Gases State of California
Hazards and Hazardous Materials Los Gatos General Plan Buildout Hydrology and Water Quality Los Gatos General Plan Buildout Noise Los Gatos General Plan Buildout
Transportation Los Gatos General Plan Buildout
Wildfire Hazards Los Gatos General Plan Buildout
SOURCE: EMC Planning Group 2021

15.3 CUMULATIVE ANALYSIS
The following sections include an evaluation of the cumulative scenario’s impacts, and addresses whether the proposed project’s contribution is considerable.

Aesthetics
Proposed Project Impact Summary
Aesthetic impacts are discussed in Section 5.0, Aesthetics. The proposed project would result in the following aesthetic impacts:
 Impact 5-1. The proposed project would have an effect on a scenic vista (less than significant);
 Impact 5-3. The proposed project would alter the existing visual character or quality of the site and its surroundings but would not conflict with applicable zoning and other regulations governing scenic quality (less than significant); and  Impact 5-4. The proposed project would introduce new sources of light or glare (less than significant).

ITEM NO. 8.

15.0 Cumulative Impacts
15-4 EMC Planning Group Inc.

Geographic Scope
The geographic scope for aesthetics impacts of the proposed project is the buildout of the Town General Plan.

Cumulative Impacts
The General Plan EIR concluded that build-out of the General Plan would result in less-thansignificant aesthetic impacts (Town of Los Gatos 2010), with implementation of the General Plan goals, policies, and actions. Build-out of the General Plan would not result in cumulative aesthetics impacts due to design criteria and policies included in the General Plan, Hillside Development Standards and Guidelines, and Hillside Specific Plan requirements, and zoning standards contained in the Town Code.

Project Contribution to Cumulative Impacts
No significant aesthetic impacts were identified for the proposed project and cumulative aesthetic impacts were determined to be less than significant in the General Plan. Therefore, the proposed project contribution to cumulative projects’ aesthetic impacts would be less than cumulatively considerable.

Air Quality
Proposed Project Impact Summary
Air quality impacts are discussed in Section 6.0, Air Quality. The proposed project would result in the following air quality impacts:
 Impact 6-2. Criteria air pollutant emissions during project construction would degrade air quality, but would not exceed the air district thresholds (less than significant);
 Impact 6-3. Criteria air pollutant emissions during project operations would degrade air quality (less than significant);
 Impact 6-5. Construction activity would expose sensitive receptors to toxic air contaminants (less than significant with mitigation); and  Impact 6-6. Construction of the proposed project would generate odors that could affect sensitive receptors (less than significant).

Cumulative Impacts
Construction Impacts – Criteria Air Pollutants
New emissions would be generated from construction activities associated with development allowed under the 2020 General Plan. Varying amounts of construction would likely occur over time until buildout of the 2020 General Plan is achieved. Constructionrelated emissions would result from excavation, grading, demolition, vehicle travel on paved and unpaved surfaces and vehicle and equipment exhaust. Individual projects would vary in

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 15-5
size and have the potential to generate significant construction emissions. BAAQMD emphasizes the implementation of effective and comprehensive control measures rather than detailed quantification of construction emissions. BAAQMD has identified a set of feasible particulate matter control measures for construction activities.

Operational Impacts – Criteria Air Pollutants
The General Plan EIR concluded that build-out of the General Plan would be inconsistent with applicable clean air planning efforts of the air district, as projected vehicle miles traveled that could occur under the General Plan would increase at a greater rate than population growth. The General Plan includes extensive goals, policies, and actions that aim to reduce vehicle reliance and vehicle miles travelled within the Town. However, the projected growth in vehicle travel could still lead to an increase in regional vehicle miles travelled beyond that anticipated in the then-current clean air plan. As a result, development in Los Gatos consistent with the General Plan would contribute to the on-going violations of ozone ambient air quality standards in the air basin (Town of Los Gatos 2010). Therefore, buildout of the General Plan would result in a significant cumulative impact on air quality.

Toxic Air Contaminants and Sensitive Receptors
The General Plan EIR concluded that operations associated with buildout of the General Plan would result in less-than-significant impacts associated with toxic air contaminants (TAC) on sensitive receptors. The General Plan EIR did not include an evaluation of constructionrelated TAC from buildout of the General Plan.

Project Contribution to Cumulative Impacts
Construction Impacts – Criteria Air Pollutants
Construction of the proposed project would result in criteria air pollutants, but the volumes would be significantly below the air district’s threshold (Table 6-6) in Section 6.0. Therefore, the proposed project’s contribution to cumulative project criteria air pollutants during construction activities would not be considerable.

Operational Impacts – Criteria Air Pollutants
In developing thresholds of significance for air pollutants, the air district considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions (Bay Area Air Quality Management District 2017).

The proposed project operations would result in fewer operational criteria pollutant emissions than the existing facility, resulting in a beneficial impact over baseline conditions.

Refer to the detailed discussion in Section 6.0, Air Quality. Therefore, the proposed project would not contribute to the cumulative operational air quality impacts of General Plan buildout.

ITEM NO. 8.

15.0 Cumulative Impacts
15-6 EMC Planning Group Inc.

Toxic Air Contaminants and Sensitive Receptors
The HRA concluded that cumulative community health risks would be less than cumulatively considerable. The cumulative community risk impacts at the MEI are summarized in Table 15-2, Cumulative Heath Risks at Construction MEIs.

Table 15-2 Cumulative Health Risks at Construction MEIs Source Cancer Risk
(per million)
Annual PM2.5
Concentration (μg/m3) Hazard Index
Project Construction (Mitigated)1,2 3.70 (infant/child) <0.3 0.06 State Route 17 (80,000 ADT) 13.84 0.262 <0.01
Santa Cruz Avenue (6,800 ADT) 1.26 0.024 <0.01
No permitted sources within 1000 feet 0 0 0
Cumulative (Mitigated)2 18.80 <0.586 <1.0
Air District Cumulative-Source Threshold 100.0 0.80 10.0 Exceeds Thresholds? (Mitigated) No No No
SOURCE: EMC Planning Group 2021.

NOTES:

1. Results have been rounded, and may, therefore, vary slightly.

2. Includes reductions due to use of Tier III diesel engines and alternative fuels in other construction equipment (Mitigation Measure AQ-2).

Table 15-1 shows the mitigated health risk for cumulative sources. The resulting mitigated cumulative cancer risk is 18.80 per million, a PM2.5 concentration of less than 0.3 μg/m3, and a hazard index less than 1.0. The project’s contribution to community health risks would not exceed the air district’s cumulative thresholds and are less than cumulatively considerable.

Biological Resources
Proposed Project Impact Summary
Biological resource impacts are discussed in Section 7.0, Biological Resources. The proposed project would result in the following biological resource impacts:
 Impact 7-2. Potential Effect on Candidate, Sensitive, or Special-Status Species (San Francisco Dusky-Footed Woodrat) (less than significant with mitigation);  Impact 7-3. Potential Effect on Candidate, Sensitive, or Special-Status Species (Pallid Bat, Townsend’s Big-Eared Bat) (less than significant with mitigation);  Impact 7-4. Potential Effect on Candidate, Sensitive, or Special-Status Species (Nesting Raptors and Migratory Birds) (less than significant with mitigation);  Impact 7-5. Effect on Federally- and State-Protected Wetlands or Waters of the U.S. (Intermittent or Ephemeral Drainage) (less than significant with mitigation);

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
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 Impact 7-6. Damage or Removal of Regulated Trees (less than significant with mitigation);
 Impact 7-7. Interference with Movement of Wildlife Species or with Established Wildlife Corridors (less than significant); and
 Impact 7-8. Effect on Sensitive Natural Communities (less-than-significant with mitigation).

Geographic Scope
The geographic distribution ranges for special-status species vary greatly depending largely on environmental factors such as habitat suitability criteria (e.g., some species may only occur locally while others may range throughout large geographic areas such as the western U.S.). For the purposes of cumulative analysis for special status species and other biological resources, including jurisdictional wetlands and waterways, the geographic boundary for cumulative impacts is generally defined as the Santa Clara Valley region, particularly the Los Gatos General Plan growth boundary and immediate vicinity. An analysis at this level is considered adequate for determining whether impacts could affect the sustainability of special status species and their habitats. Within this area, regulatory agencies and conservation organizations including U.S. Fish and Wildlife Service, the California Department of Fish and Wildlife, and California Native Plant Society, work to establish and update critical distribution range information for species thought to be declining within their geographic ranges due to habitat loss and degradation.

Cumulative Impacts
The General Plan EIR identified potentially significant impacts to candidate, sensitive, and special-status species, riparian and sensitive natural communities, protected wetlands, and wildlife corridors and nursery sites. The EIR concluded that build-out of the General Plan would not result in significant cumulative impacts to biological resources (Town of Los Gatos 2010), with implementation of the applicable goals, policies, and actions in the General Plan.

Project Contribution to Cumulative Impacts
This EIR addresses all of the issues identified in the General Plan EIR, and implements the applicable goals, policies, and actions in the General Plan. All of the proposed project’s biological impacts (potential loss or reduction of the following: sensitive plant species, San Francisco dusky-footed woodrat, pallid bat and Townsend’s big-eared bat, protected nesting birds, and regulated trees) would be mitigated to a less-than-significant level with the implementation of the mitigation measures presented in Section 7.0, Biological Resources.

Therefore, as mitigated, the proposed project impacts on biological resources would not be cumulatively considerable.

ITEM NO. 8.

15.0 Cumulative Impacts
15-8 EMC Planning Group Inc.

Cultural, Paleontological, and Tribal Resources
Proposed Project Impact Summary
Cultural and tribal resource impacts are discussed in Section 8.0, Cultural and Tribal Resources. The proposed project would result in the following cultural and tribal resource impacts:
 Impact 8-1. Potential Adverse Change to Historic Resources and/or Unique Archaeological Resources During Construction (less than significant);  Impact 8-2. Potential Destruction of a Unique Paleontological Resource or Site During Construction (less than significant); and
 Impact 8-3. Potential Adverse Impact to Native American Human Remains During Construction (less than significant).

Geographic Scope
The geographic scope for cumulative impacts on cultural resources is the Town’s planning area as identified in the General Plan. This scope boundary was selected because it identifies the limits within which the Town exercises control over activities with potential to impact cultural resources, including the proposed project. The cultural resources effects of the proposed project are common to land use projects over which the Town has discretionary authority.

Cumulative Impacts
The General Plan EIR identified potentially significant impacts to historical resources, archaeological resources, paleontological resources, and disturbance of human remains associated with historical and pre-contact archaeological deposits associated with general plan buildout. The General Plan EIR concluded that build-out of the General Plan would not result in significant cumulative impacts associated with cultural resources (archaeological and historic resources) with implementation of General Plan goals, policies, and actions (Town of Los Gatos 2010).

Project Contribution to Cumulative Impacts
An EMC Planning Group archaeologist conducted a site reconnaissance and a records search, and concluded that there was no record or surface evidence of significant cultural or tribal resources on the project site. The potential that unknown buried cultural resources could be disturbed during construction is mitigated through protocols consistent with policies in the General Plan, as presented in Section 8.0, Cultural, Paleontological, and Tribal Resources.

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
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Additionally, although there is no evidence of buried paleontological resources, there is a possibility that these resources could be accidentally discovered during earth-moving activities. Implementation of a mitigation measure in Section 8.0 would ensure this potential impact would be mitigated to a less-than-significant level.

Therefore, the proposed project would not result in a cumulatively considerable impact on sensitive cultural, paleontological, and tribal resources.

Energy
Proposed Project Impact Summary
Energy impacts are discussed in Section 9.0, Energy. The proposed project would result in the following energy impact:
 Impact 9-1. Consumption of Energy Resources (Less than Significant).

Geographic Scope
The geographic scope for this effect is cumulative development in California. This broad scope is reflective of the rigorous state effort, as expressed through multitude of legislative acts and regulations, to reduce energy consumption across energy consumptive uses and sectors. The state effort has and continues to focus on the benefits of energy conservation with specific regard to addressing climate change and natural resource conservation.

Cumulative Impacts
The General Plan EIR concluded that energy impacts from buildout of the General Plan would be less than significant with implementation of General Plan policies and implementing actions. However, since 2010 when the General Plan EIR was certified, the Town and state have continued to advance energy conservation and efficient initiatives that create greater expectations of land use projects and local jurisdictions.

There is no codified or single CEQA analysis practice standard for determining what constitutes a significant impact relative to guidance provided in Appendix G of the CEQA Guidelines regarding wasteful or inefficient use of energy. However, it can be assumed that past cumulative projects have been less energy efficient with regard to electricity and natural gas use and that older transportation technologies have been less efficient with regard to fuel use than would be current and future projects and technologies. As California continues to implement more and more rigorous legislation and regulations to reduce energy use through improved energy efficiency and transportation technology changes, it can be assumed that current and future projects, particularly land development projects, will not be sources of wasteful or inefficient energy use.

ITEM NO. 8.

15.0 Cumulative Impacts
15-10 EMC Planning Group Inc.

Project Contribution to Cumulative Impacts
The General Plan EIR found energy impacts to be less than significant when evaluated in the context of cumulative impacts within the state, based on the information available at that time. Relative to conditions in 2010 when the General Plan EIR was certified, proposed project energy would be further reduced for several reasons. The proposed project includes several renewable energy and energy efficiency features. As described in Section 4.0, Project Description, the proposed project would include a centralized building heating and cooling system that would operate at efficiencies that exceed code requirements. In line with the Town’s prioritization of passive and active solar energy measures, and in keeping with state energy code requirements, a minimum of 15 percent of the total roof areas would be provided as “solar ready” surface. Per CALGreen requirements, 10 percent of all parking spaces would be designed with capacity to install electric vehicle charging stations. In addition, the overall project would be designed to meet the minimum requirements to certify the project through the GreenPoint Rated system. Relative to 2010, state building energy efficiency standards are now more stringent – this will result in reduce electricity and natural gas consumption than projected in 2010. Further, as quantified in Section 9.0, transportation fuel energy demand and natural gas demand are projected to be similar to or lower for the proposed project than for the existing baseline use.

Given these considerations, the proposed project contribution to energy wasteful or inefficient energy consumption would be less than cumulatively considerable and the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Geology and Soils
Proposed Project Impact Summary
The geotechnical report prepared for the proposed project noted several potential geologic impacts associated with fault surface rupture, expansive soils, and land sliding and slope instability.

Geographic Scope
The geographic scope for geologic impacts of the proposed project is the buildout of the Town General Plan.

Cumulative Impacts
The General Plan EIR identified potentially significant impacts related to seismic hazards, expansive soils and unstable geologic units, erosion, and placement of septic tanks in inadequate soils associated with General Plan buildout. The General Plan EIR concluded that build-out of the General Plan would not result in significant impacts associated with geology, soils, or seismicity (Town of Los Gatos 2010).

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 15-11
Project Contribution to Cumulative Impacts
The proposed project would not have significant geologic or soils impacts with implementation of the mitigation measures (13-1 and 13-2) presented in Section 13.0, Effects Not Addressed Further in this EIR. Therefore, as mitigated, the proposed project would not result in a cumulatively considerable impact to geology or soils.

Greenhouse Gas Emissions
Proposed Project Impact Summary
The GHG impacts of the project are discussed in Section 10.0, Greenhouse Gas Emissions.

The proposed project would result in the following GHG impacts:
 Impact 10-1. Generation of Greenhouse Gas Emissions (Less than Significant).

Geographic Scope
Because climate change is a global phenomenon, it is highly unlikely that any one development project located anywhere in the world would have a significant individual impact on climate change. It is the sum total of contributions of development around the world that contribute to the problem. Individual land use projects that generate GHGs inherently contribute to the cumulative effect. However, the precise indirect effects of that contribution are difficult if not impossible to identify due to the complexity of local, regional, and global atmospheric dynamics and the broad scale at which global warming impacts such as sea level rise, increase in weather intensity, decrease in snowpack, etc. are known to occur.

While the true geographic scope of the area affected by GHG emissions is global, for purposes of this EIR, the geographic scope is considered to be the state. This scope is selected because the broad array of state legislation and regulatory requirements for reducing GHGs includes direction for local agency actions needed to reduce GHGs for the purpose of helping to meet statewide GHG reduction goals.

Cumulative Impacts
The General Plan EIR concluded that build-out of the General Plan would make a significant unavoidable contribution to the cumulative impact of climate change (Town of Los Gatos 2010c, page 2-7). The General Plan EIR states the implementation of policy measures contained in the General Plan would result in an approximate 25 percent reduction in annual GHG emissions by 2020. However, the General Plan EIR concludes that it is uncertain whether this level of reduction will be achieved and therefore, it is uncertain if the AB 32 Scoping Plan target reduction level of 20 percent would be met by 2020.

ITEM NO. 8.

15.0 Cumulative Impacts
15-12 EMC Planning Group Inc.

Project Contribution to Cumulative Impacts
Because the potential impact of the proposed project is inherently also its cumulative contribution to climate change, the analysis in Section 10.0, Greenhouse Gas Emissions, is also a cumulative impact assessment. That analysis found that GHGs from mobile sources would be essentially the same for the proposed use as for the existing baseline use, while GHG emissions from electricity demand would be lower for the proposed use than the existing baseline use. As these two GHG emissions sources commonly comprise a significant majority of the emissions inventory of land use projects such as the proposed project, it was concluded that the proposed project would result in little to no increase in GHG emissions relative to the existing, baseline use of the project site. Consequently, the proposed project would not likely result in an increase in GHG emissions and its contribution to cumulative impacts on climate change would be less than cumulatively considerable.

Hazards and Hazardous Materials
Proposed Project Impact Summary
According to the environmental site assessment prepared for the proposed project site, asbestos and lead-based paint may have been used during construction of the existing facilities onsite and may result in a potentially significant impact if released during demolition activities.

Geographic Scope
The geographic scope for cumulative hazardous materials conditions is the Town’s planning area as described in the General Plan. This scope boundary was selected because it identifies the limits within which the Town exercises control over hazards and hazardous materials conditions that could pose risk to the public. The hazards and hazardous material conditions associated with the proposed project are common to land use projects over which the Town has discretionary authority.

Cumulative Impacts
The General Plan EIR identified potentially significant impacts to the transport, use, or disposal of hazardous materials, hazardous materials accidents, hazardous materials near schools, and hazardous materials sites associated with General Plan buildout. The General Plan EIR concluded that build-out of the General Plan would not result in significant cumulative impacts associated with hazardous materials and safety (Town of Los Gatos 2010).

Project Contribution to Cumulative Impacts
The proposed project would not result in the transport and use of significant quantities of hazardous materials. There are no proposed uses for the proposed project that pose a heightened risk of exposure to or upset of hazardous materials. There would not be a cumulatively considerable effect on associated with hazardous materials.

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 15-13
Hydrology and Water Quality
Proposed Project Impact Summary
As noted in Section D.10, Hydrology and Water Quality, of the initial study, the proposed project has the potential to result in significant impacts related to erosion or siltation on or off-site and the creation of runoff water that would exceed the capacity of existing or planned storm water drainage systems or create additional sources of polluted runoff. By complying with the Construction General Stormwater Permit and the Town’s stormwater management requirements, the proposed project would not violate any water quality standards or degrade water quality and would not exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Geographic Scope
The geographic scope for assessment of cumulative hydrology and water quality impacts is the Town’s planning area, including the project site, as described in the General Plan. This scope boundary was selected because it identifies the limits within which the Town exercises control over water hydrology and water quality conditions. The hydrology and water quality conditions associated with the proposed project are common to land use projects over which the Town has discretionary authority.

In addition, the San Francisco Bay Regional Water Quality Control Board regulates surface water and groundwater quality in the San Francisco Bay region under the guidance of the San Francisco Bay Region Basin Plan. The basin plan uses a watershed management approach focused on the particular needs of each watershed. The Town and the regional board have programs in place to minimize the introduction of pollutants and sediment into water bodies.

Cumulative Impacts
The General Plan EIR identified potentially significant impacts to construction of new stormwater drainage facilities, violation of water quality standards or discharge requirements, depletion or interference with groundwater supplies, as well as impacts related to erosion, siltation and flooding associated with General Plan buildout. The General Plan EIR concluded that build-out of the General Plan would not result in significant cumulative impacts associated with hydrology and water quality (Town of Los Gatos 2010).

Project Contribution to Cumulative Impacts
With the proposed project and other development within the Town constructed in accordance with General Plan policies, Town erosion control and grading regulations, and regional board regulations, there would not be any significant cumulative water quality impacts, and the project’s contribution would not be considerable.

ITEM NO. 8.

15.0 Cumulative Impacts
15-14 EMC Planning Group Inc.

Noise
Proposed Project Impact Summary
Noise impacts are discussed in Section 11.0, Noise. The proposed project would result in the following noise impacts:
 Impact 11-1. Construction activities associated with the proposed project could cause a substantial temporary noise increase (less than significant); and  Impact 11-2. Groundborne vibration during construction activities (less than significant).

Geographic Scope
The geographic scope for cumulative noise and vibration impacts is the Town’s planning area as described in the General Plan.

Cumulative Impacts
The General Plan EIR identified potentially significant impacts due to exposure of noise levels in excess of local standards for construction noise impacts and operational noise impacts, exposure to excessive groundborne vibration or noise, and increases in ambient noise levels associated with General Plan buildout. The General Plan EIR concluded that build-out of the General Plan would not result in significant cumulative impacts associated with noise (Town of Los Gatos 2010).

Project Contribution to Cumulative Impacts
Cumulative Construction Noise and Groundborne Vibration Impacts Construction activities associated with the proposed project, which are anticipated to last approximately 30 months, would result in temporary, short-term noise and groundborne vibration increases due to the operation of heavy equipment on the project site. These shortterm construction-related noise and groundborne vibration increases would contribute to cumulative construction noise and vibration impacts addressed in the General Plan EIR. For the significant cumulative impact to be reduced to less than significant and the proposed project contribution to that impact to be reduced to less than considerable, construction activities associated with the proposed project shall be required to comply with construction best management practices, as identified in the Town’s Noise Ordinance and listed in Section

11.0, Noise, of this draft EIR. Therefore, project impacts associated with construction-related ground vibration and vibration noise would not be considerable.

Cumulative Operational Noise Impacts
As noted in the initial study included as Appendix A, operational noise levels associated with the proposed project would be similar to the existing development while it was operational. Since the proposed project would not result in an increase in noise over baseline

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 15-15
conditions, there would be no impacts associated with operational noise. Operational activities are also not expected to result in any vibration impacts at nearby sensitive uses. As a result, the proposed project’s contribution to operational noise would not be considerable.

Wildfire Hazards
Proposed Project Impact Summary
Wildfire hazard impacts are discussed in Section 12.0, Wildfire Hazards. The proposed project would result in the following wildfire hazard impacts:
 Impact 12-1. The proposed project would result in short-term construction-related traffic activity that would has the potential to impair an adopted emergency response plan or emergency evacuation plan (less than significant with mitigation);  Impact 12-2. The proposed project could, due to slope, prevailing winds, and other factors exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire (less than significant);
 Impact 12-4. The project could expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes (less than significant with mitigation); and
 Impact 12-5. The project could expose people or structures to significant risks associated with wildland fires (less than significant).

Geographic Scope
The geographic scope for cumulative wildfire hazard conditions is the Town’s planning area as described in the General Plan. This scope boundary was selected because it identifies the limits within which the Town exercises control over wildfire hazard conditions that could pose risk to the public. The wildfire hazards associated with the proposed project are common to land use projects over which the Town has discretionary authority.

Cumulative Impacts
The General Plan EIR identified potentially significant impacts due to wildland fires and emergency preparedness associated with General Plan buildout. The General Plan EIR concluded that build-out of the General Plan would not result in significant cumulative impacts associated with wildfire hazards through the implementation of the 2020 General Plan goals, policies and actions (Town of Los Gatos 2010).

ITEM NO. 8.

15.0 Cumulative Impacts
15-16 EMC Planning Group Inc.

Project Contribution to Cumulative Impacts
The project site is located in a Very High Fire Severity Zone as are all of the properties within the general vicinity. Therefore, the proposed project would increase the potential for wildfires within this area of Los Gatos, and this increase could be cumulatively considerable.

Redevelopment of the project site with a new senior living community would be required to comply with all of the Town requirements for construction, as well as the requirements of the Santa Clara County Fire Department. The County Fire Department is reviewing the project for fire department apparatus access roadways, wildland-urban interface, fire hydrant availability and fire flow adequacy, emergency access and driveways, fire engine driveway turnaround requirements, construction site fire safety, and fire sprinklers in structures. Approval by the fire department is required prior to issuance of building permits (Santa Clara County Fire Department 2020). A mitigation measure is included in Section 12.0, Wildfire Hazards, requiring preparation and implementation of a site-specific construction traffic management to address potential impacts as a result of construction-related traffic impacts and emergency access to and around the project site. In addition, compliance with all conditions of approval required by the County Fire Department and implementation of mitigation measures identified in Section 13.0, Effects Not Addressed Further in this EIR, related to geotechnical recommendations to address the threat of wildfire-induced landslides. Compliance with this recommendation as incorporated in Mitigation Measures 13-1 and 13-2 would ensure this potentially significant impact would be reduced to a lessthan-significant level. With implementation of these mitigation measures, the proposed project’s contribution to the potential for wildfires would not be cumulatively considerable.

ITEM NO. 8.

EMC Planning Group Inc. 16-1

16.0 Alternatives

16.1 CEQA REQUIREMENTS
CEQA Guidelines section 15126.6(a) requires a description of a range of reasonable alternatives to the proposed project, or to the location of the project, which could feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project. It also requires an evaluation of the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project, but must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation.

CEQA Guidelines section 15126.6(b) further requires that the discussion of alternatives focus on those alternatives capable of eliminating any significant adverse environmental impacts or reducing them to a level of insignificance, even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly. The EIR must present enough information about each alternative to allow meaningful evaluation, analysis and comparison with the proposed project. If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed.

16.2 PROJECT OBJECTIVES AND SIGNIFICANT IMPACTS
As discussed above, alternatives must be able to meet most of the basic objectives of the project and avoid or substantially lessen any of the significant effects of the project.

Therefore, the proposed project objectives and significant effects are summarized here.

Objectives
 Consistent with the Town’s General Plan goals and policies and density allowed by the existing site zoning, rebuild the Los Gatos Meadows site into a contemporary, full-service senior living community (Life Plan Community) that provides seniors 62 years and over an opportunity to age in place and live successfully in the Los Gatos Community;

ITEM NO. 8.

16.0 Alternatives
16-2 EMC Planning Group Inc.
 Revitalize the site with a request for a new (updated) Planned Development (PD) that would allow the same number of apartments permitted under the existing PD entitlement in a manner responsive to market demand and financially feasible for Covia Communities (property owner) to implement & operate;  Revitalize the site with intent of minimizing overall building site coverage, integrating the apartments with the natural topography, minimizing visual impacts and substantially improving fire safety;
 Assist in the implementation of the Town’s 2015-2023 Housing Element by furthering the Goals and Policies specific to providing housing opportunities, lifestyle living and assisted living facilities for seniors;  Further the Town’s Human Services Element by revitalizing Los Gatos Meadows into a healthy, contemporary independent senior living community that connects seniors with existing resources in the community, encourages social interaction, improves mobility and ensures a safe environment for Los Gatos seniors;  Provide seniors with an alternative mode of transportation by incorporating autonomous vehicle technology into the project to assist in enhanced connectivity between Los Gatos Meadows and proximate Town services such as the Library, Civic Center and retail/entertainment uses;
 Utilize architectural design principles and techniques that incorporate the Town’s Sustainable Design strategies and materials to promote a healthy living environment;
 Provide a mix of different unit sizes and varying levels of care that respond to the needs of an active, aging community;
 Improve the integration of the site with the broader Los Gatos Community by closing Farwell Lane to through traffic and transitioning the Lane from Los Gatos Meadows to Broadway into a naturally landscaped, pedestrian-friendly connection to Downtown Los Gatos;
 Use the project as an opportunity to integrate the site design & architecture with existing topography and natural landscape in a manner that more harmoniously reflects the site’s natural beauty than exists today; and  Integrate and evoke the experience of nature by utilizing natural building materials, finishes, forms, patterns and colors that reflect the character of the surrounding hillside setting.

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-3
Significant and Unavoidable Impacts
No significant and unavoidable impacts were identified. All identified significant impacts can be mitigated to a less-than-significant level.

Significant Impacts
Significant Impacts Reduced to Less-than-Significant with Mitigation Measures
 Impact 6-5. Construction activity would expose sensitive receptors to toxic air contaminants (Mitigation Measures 6-5a and 6-5b);
 Impact 7-2. Potential Effect on Candidate, Sensitive, or Special-Status Species (San Francisco Dusky-Footed Woodrat) (Mitigation Measure 7-2);  Impact 7-3. Potential Effect on Candidate, Sensitive, or Special-Status Species (Pallid Bat, Townsend’s Big-Eared Bat) (Mitigation Measure 7-3);  Impact 7-4. Potential Effect on Candidate, Sensitive, or Special-Status Species (Nesting Raptors and Migratory Birds) (Mitigation Measure 7-4);  Impact 7-5. Effect on Federally- and State-Protected Wetlands or Waters of the U.S. (Intermittent or Ephemeral Drainage) (Mitigation Measure 7-5a and 7-5b);  Impact 7-6. Damage or Removal of Regulated Trees (Mitigation Measure 7-6);  Impact 7-8. Effect on Sensitive Natural Communities (Mitigation Measure 7-8);  Impact 12-1. The proposed project would result in short-term construction-related traffic activity that would has the potential to impair an adopted emergency response plan or emergency evacuation plan (Mitigation Measure 12-1);  Geologic Impacts (Mitigation Measures 13-1 and 13-2); and  Hazards and Hazardous Materials Impacts (Mitigation Measure 13-3).

16.3 ALTERNATIVES CONSIDERED BUT REJECTED
Alternative Project Location
CEQA Guidelines section 15126.6(f)(2) identifies considerations for evaluating an alternative project location. Among these are whether any of the significant effects of the project would be avoided or substantially lessened and whether feasible alternative locations exist.

Feasibility is described in section 15126.6(f)(1) and includes factors such as site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.

ITEM NO. 8.

16.0 Alternatives
16-4 EMC Planning Group Inc.

An “alternate site” alternative for the proposed project was investigated. The consultant reviewed similarly sized, vacant sites within the Town limits with a similar general plan land use and zoning designation that could accommodate a senior living community at the size, scale, and capacity of the proposed project. Several vacant, agricultural parcels were reviewed near the State Route 85 and 17 interchange that were of a similar size and land use designation (Low and Medium Density Residential), including the northern portion of the North Forty Specific Plan as well as several parcels to the west of State Route 17 between Lark Avenue to the south and State Route 85 to the north.

However, these alternative locations were rejected for further consideration for the following reasons:
 The project at the proposed location would not result in any significant and unavoidable impacts;
 The project at the proposed location is the replacement of an existing on-site senior community with a new senior community, built to current standards;  Development of the project at one of these alternative locations would result in conversion of unique or prime farmland to urban uses (Department of Conservation 2016), an impact which does not occur with implementation of the project at the proposed site; and
 The proposed project site is in proximity to one major highway (State Route 17); however, these alternative sites are located in proximity to two major highways (State Route 17 and State Route 85), resulting in potentially greater air pollutant impacts to the project.

Therefore, although development of the project at one of these alternative locations would meet the basic objectives of the proposed project, development of any these parcels could result in greater environmental impacts than would development of the project at the proposed project site.

Convert Project Site to Open Space or Park
Converting the project site to open space and/or a park was considered. Although nearly all of the proposed project’s environmental impacts would be reduced or eliminated, this alternative would require an amendment to the General Plan, and would not meet any of the project objectives. Therefore, this alternative was rejected for further consideration.

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-5

16.4 ALTERNATIVES CONSIDERED
The following alternatives to the project are considered:

1. Alternative 1: No Project – Existing (Closed) Senior Living Community;

2. Alternative 2: No Project – Residential Project Consistent with the Project Site’s General Plan Designation; and

3. Alternative 3: Reduced Scale (Removal of Villas B and C from Proposed Site Plan).

Per CEQA Guidelines section 15130, the no project alternative must be evaluated. CEQA Guidelines section 15126.6 (e) requires the “No Project” alternative be evaluated along with its impacts. The “No Project” alternatives (Alternative 1 and Alternative 2) analysis must discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. The other reduced scale alternative (Alternative 3) was selected based on its ability to substantially reduce or avoid one or more of the significant mitigable impacts as summarized in Section 16.2 above. The descriptions of each alternative identify the significant mitigable impacts which each alternative is intended to further reduce or avoid.

Each of these alternatives is described below, followed by an analysis of how each may reduce significant mitigable impacts associated with the proposed project.

Alternative 1: No Project – Existing (Closed) Senior Living Community
Alternative Description
This no project alternative investigates if the proposed project were not approved and the existing senior living community facilities were left in place though closed and vacant. As noted in Section 3.0, Environmental Setting, the project site is currently developed with 10 residential buildings ranging from one to four stories, which include a total of 205 independent residential apartments and supporting health care units. The existing facility includes a dining and commons building, an infirmary, garage and services building, a multi-purpose building, and two cottages.

No Project – Existing (Closed) Senior Living Community Alternative Attainment of Project Objectives
This alternative does not meet any of the basic project objectives, as it would not allow redevelopment of the project site with a revitalized and enhanced senior living community consistent with the density allowed under the site’s existing PD entitlement.

ITEM NO. 8.

16.0 Alternatives
16-6 EMC Planning Group Inc.

No Project – Existing (Closed) Senior Living Community Alternative Impacts Comparison
This analysis identifies potential impacts associated with this alternative and compares it with the significant, mitigable impacts of redeveloping the site with a new senior living community. The environmental effects of this alternative as compared to the proposed project are summarized by topic area below.

Aesthetics
The “no project alternative” would not result in visual impacts as there would be no change in the existing visual setting.

Air Quality
The “no project alternative” would not result in air quality impacts as demolition of the existing facility and construction of the proposed project would not occur.

Biological Resources
The “no project alternative” would not result in biological resource impacts as there would be no tree removal and disturbance of the native habitat.

Cultural, Paleontological and Tribal Resources
The “no project alternative” would not result in potential cultural and tribal resource impacts, as there would be no ground disturbance.

Energy
The “no project alternative” would not result in energy impacts as there would be no construction or operation of a new facility.

Geology and Soils
The “no project alternative” would not result in geologic hazard impacts, as there are currently no residents at the existing facility.

Greenhouse Gas Emissions
The “no project alternative” would not result in greenhouse gas emissions impacts, as demolition of the existing facility and construction of the proposed project would not occur.

Hazards and Hazardous Materials
The “no project alternative” would not result in potential hazards and hazardous materials impacts, as demolition of the existing buildings with the potential to release asbestos would not occur.

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-7
Noise
The “no project alternative” would not result in noise impacts, as demolition of the existing facility and construction of the proposed facility would not occur.

Wildfire Hazards
The “no project alternative” would not result in an increase in wildfire hazard impacts, as demolition and construction activities would not occur, and there would be no increase in the number of residents occupying the project site.

Alternative 2: No Project - Residential Project Consistent with the Project Site’s General Plan Land Use Designation This no project alternative investigates what could be reasonably expected to occur on the project site in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. The project site has a General Plan designation of Medium Density Residential. Under this designation, the project site could be developed with a multi-family, duplex, and/or small single-family residential project with a density range of 5 to 12 dwelling units per net acre with up to 24 persons per acre. Conceivably, such a project could include a range of home product types including townhomes, condominiums, and/or apartments. This alternative project considers the site constraints of the 10.84-acre site, much of which is steep, heavily wooded hillside that could not reasonably accommodate residential buildings. To determine a probable number of Medium Density Residential dwelling units that the site could accommodate, this alternative utilizes approximately 50 percent of the total net acreage or approximately 5.42 acres.

Therefore, a Medium Density Residential project with a maximum of 65 units would be possible. Assuming an average of 2.51 persons per household (U.S. Census 2021), such a project would result in 163 new residents, substantially less than the 233 total residents anticipated as part of the proposed project.

No Project - Residential Project Consistent with the Project Site’s General Plan Land Use Designation Alternative Impacts Comparison This alternative does not meet any of the basic project objectives, as it would not allow redevelopment of the project site with a revitalized and enhanced senior living community consistent with the density allowed under the site’s existing PD entitlement. This analysis identifies potential impacts associated with this alternative and compares it with the significant, mitigable impacts of the proposed project. The environmental effects of this alternative as compared to the proposed project are summarized by topic area below.

Aesthetics
This alternative would generally require the same footprint as the proposed project, but would be limited to 30 feet, consistent with the regulations in the zoning code for R-M or

ITEM NO. 8.

16.0 Alternatives
16-8 EMC Planning Group Inc.

Multiple-Family Residential Zone. The existing structures are predominately two-stories.

This alternative assumes that the proposed tree removal would also be likely, and that the trees would need to be replaced per the Town’s requirements.

This alternative would generally be developed on the same footprint and at the same height as the existing facility, and any trees removed would be replaced. Therefore, this alternative would not result in significant visual impacts.

The proposed project would also be developed on generally the same footprint and include the removal and replacement of trees. However, the proposed project’s building would be up to 85 feet high, significantly higher than the 30-foot height of this alternative. Therefore, although both the proposed project and the alternative would result in less-than-significant adverse visual impacts, this alternative’s visual impact would be less than the proposed project’s visual impact.

Air Quality
Construction Impacts. This alternative could result in significant demolition and construction related impacts. These impacts can be reduced to a less-than-significant level with implementation of standard conditions of approval and mitigation measures. However, the proposed project’s impacts would likely be somewhat greater because the proposed project’s square footage (at up to five stories) is greater than the alternative’s square footage.

Although the construction-related impacts for both this alternative and the proposed project would be less than significant, this alternative would result in fewer impacts that the proposed project.

Operational Impacts. Refer to the transportation section below for additional information regarding trip generation. This alternative would result in approximately 354 trips per day, which is significantly lower than the 708 trips per day from the existing baseline facility (Kimley-Horn 2020, page 9). Therefore, this alternative would result in fewer air quality impacts from vehicle use than the baseline conditions.

The proposed project would result in 718 trips per day (Kimley-Horn 2020, page 11), only 10 more than the baseline conditions. This is a less-than-significant impact. Therefore, although both the proposed project and this alternative would result in less-than-significant adverse operational air quality impacts, this alternative’s impact would be less than the proposed project’s impact.

Biological Resources
This alternative would have no change in biological resources impacts when compared to the proposed project, because the same development area would be disturbed.

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-9
Cultural, Paleontological and Tribal Resources
This alternative would have no change in cultural, paleontological, and tribal resources impacts when compared to the proposed project, because the same development area would be disturbed.

Energy
This alternative would likely result in somewhat less energy impacts associated with construction energy consumption as demolition would be the same, but the construction activities would be less, as this alternative would not be as dense as the proposed project.

Additionally, operational energy impacts would be less because there would be fewer units and fewer people living at the site, as well as fewer energy associated with transportation fuel. See Transportation/Traffic discussion below explaining how this alternative would result in fewer vehicles trip generated.

Geology and Soils
This alternative would have no change in geologic hazard impacts when compared to the proposed project, because the same development area would be disturbed and Medium Density Residential homes would generally be located in the same building footprints.

Greenhouse Gas Emissions
This alternative would result in fewer operational greenhouse gas emissions impacts when compared to the proposed project, as Medium Density Residential uses would result in fewer traffic generation that would result in increased operational greenhouse gas emissions as compared to the proposed project. Construction greenhouse gas emissions for this alternative would be expected to be less than the proposed project because this alternative is less dense than the proposed project.

Hazards and Hazardous Materials
This alternative would have no change in hazards impacts when compared to the proposed project as the same level of demolition activity and potential for encountering hazardous materials would occur.

Noise
This alternative includes a similar level of demolition and construction activities as compared to the proposed senior living community, thus creating a similar level of construction noise impacts. Operational noise impacts would likely be slightly increased as well due to the presence of Medium Density Residential homes, which would exhibit greater day-to-day noise from traffic and activities than a senior living community. Therefore, this alternative would have greater noise impacts when compared to the proposed project.

ITEM NO. 8.

16.0 Alternatives
16-10 EMC Planning Group Inc.

Transportation/Traffic
Multi-family housing projects generate about 5.44 trips per day per unit, according to the Institute of Transportation Engineers Trip Generation Manual. Therefore, this alternative, with 65 multi-family units, would result in approximately 354 trips per day, which is significantly lower than the 708 trips per day from the existing baseline facility (Kimley-Horn 2020, page 9). The proposed project would result in 718 trips per day (Kimley-Horn 2020, page 11). Therefore, although both the proposed project and the alternative would result in less-than-significant adverse transportation impacts, this alternative’s transportation impact would be less than the proposed project’s transportation impact.

Wildfire Hazards
This alternative would slightly reduce wildfire hazard impacts when compared to the proposed project as a Medium Density Residential project would likely result in smaller population generation as compared to a senior living community and therefore expose fewer future residents to wildfire hazards.

Alternative 3: Reduced Scale - Removal of Villas B and C from Proposed Site Plan
Alternative Description
The reduced scale alternative (“reduced scale alternative”) consists of a reduction in development capacity sufficient to avoid or reduce significant, but mitigable, impacts associated with grading and removal of trees required to accommodate Villas B and C and a corresponding area of the grade level below on the northwestern corner of the proposed site plan. The reduced scale alternative would reduce the number of living units by 20 units (Villa B) and 29 units (Villa C), for a total reduction of 49 units, and would result in the reduction of approximately 98,374 square feet of floor space in Villas B and C, approximately 26,000 square feet of floor space from the grade level including portions of the health center, and approximately 26,000 square feet of developed area (building footprints). In addition, this alternative could result in removing approximately 62 fewer trees. Removal of Villa B (70.5 feet in height) and Villa C (81.5 feet in height) would also help reduce visual impacts associated with scenic views from downtown Los Gatos towards the project site and scenic hillside areas beyond as these two buildings would be two of the most publicly visible buildings from multiple vantage points.

Reduced Scale Alternative Impacts Comparison
This analysis identifies potential impacts associated with this alternative and compares it with the significant, mitigable impacts of redeveloping the site with a new senior living community. The environmental effects of this alternative as compared to the proposed project are summarized by topic area below.

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-11
Aesthetics
This alternative could reduce the developed area footprint of the proposed project by approximately 26,000 square feet and could result in removal of 62 fewer trees, which may be noticeable from some viewing locations. This alternative would also result in a less-thansignificant, adverse impact on the existing visual character and quality of the project site as this alternative would still result in development of a large portion of the site that could still impact views towards and beyond the project site; however, removing Villas B and C and a corresponding area of the grade level below from the site plan would preserve at least some of the trees planned for removal, increase conservation of existing open space areas, and would result in reduced visibility as compared to the proposed project. Therefore, the reduced scale alternative is also superior to the proposed project relative to these effects.

Air Quality
This alternative would result in reduced operational and construction-related air quality impacts when compared to the proposed project; however, the air quality impact would not avoid the potentially significant but mitigable impacts of the proposed project. Therefore, the reduced scale alternative is superior to the proposed project relative to these effects.

Biological Resources
By reducing the developed area footprint of the proposed project and reducing the number of trees required to be removed by 62 trees, this alternative would reduce the area of disturbance within which sensitive biological resources may be located. This alternative would lessen the significance of, but not avoid, potentially significant but mitigable impacts of the proposed project on biological resources. Therefore, it would be superior to the proposed project from a biological resource perspective.

Cultural, Paleontological and Tribal Resources
By reducing the developed area footprint of the proposed project, this alternative would reduce the area of disturbance within which unknown cultural and tribal cultural resources could be accidentally damaged or destroyed. Therefore, this alternative would reduce the potential cultural and tribal resources impacts of the proposed and would be superior to the proposed project from a cultural and tribal resources perspective.

Energy
This alternative would result in slightly reduced operational and construction-related energy impacts when compared to the proposed project.

Geology and Soils
As discussed in Section 13.0, Effects Not Addressed Further in this EIR, the proposed project could be affected by significant ground shaking and unstable soils impacts, but the possible

ITEM NO. 8.

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16-12 EMC Planning Group Inc.
impacts would be less-than-significant level with implementation of mitigation measures.

Impacts associated with liquefaction were determined to be less than significant. This alternative would result in reduced geologic hazard impacts when compared to the proposed project, because the removal of Villas B and C and a corresponding area of the grade level below would not necessitate the level of grading required to safely accommodate those two buildings and grade level area.

Greenhouse Gas Emissions
This alternative would result in slightly reduced operational and construction-related greenhouse gas emissions impacts when compared to the proposed project as both the overall developed area and associated construction activities would be reduced. Therefore, although both the proposed project and the alternative would result in less-than-significant adverse greenhouse gas impacts, this alternative’s greenhouse gas emissions impact would be less than the proposed project’s greenhouse gas emissions impact.

Hazards and Hazardous Materials
As discussed in Section 13.0, Effects Not Addressed Further in this EIR, the release of asbestos and lead-based paint into the environment as a result of demolition activities associated with the proposed project would be reduced to a less-than-significant level through implementation of mitigation measure 13-3. This alternative would result in similar impacts as both existing buildings occupying the site of the proposed Villas B and C and a corresponding area of the grade level below would still be removed as part of this alternative and associated hazardous material impacts would still occur. This alternative would be similar to the proposed project from a hazardous materials perspective.

Noise
The reduced scale alternative would have potentially significant noise impacts that are similar to the proposed project. Though the area over which construction activity would occur is reduced relative to the proposed project, construction would still occur in the vicinity of sensitive receptors. This alternative would be similar to the proposed project from a construction noise perspective. Operational noise impacts, however, would be expected to be reduced as the overall development area and activity would be reduced with the reduction in living units, residents, and the associated noise-generating facility operations.

Transportation/Traffic
This alternative, with 49 less units than the proposed project, would result in a reduction of 197 trips per day or 477 total daily trips, which is significantly lower than the 718 trips per day expected for the proposed project (Kimley-Horn 2020, page 11). Therefore, although both the proposed project and the alternative would result in less-than-significant adverse transportation impacts, this alternative’s transportation impact would be less than the proposed project’s transportation impact.

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-13
Wildfire Hazards
This alternative would result in slightly reduced wildfire hazard impacts when compared to the proposed project as the overall development footprint would be reduced and the number of residents exposed to wildfire risk would be reduced.

16.5 COMPARISON OF ALTERNATIVES
The alternatives are summarized and compared in a matrix format in Table 16-1, Comparison of Project Alternatives to the Proposed Project.

Alternative 1, the No Project – Existing (Closed) Senior Living Community, would not result in adverse environmental impacts. Alternative 1 is the environmentally superior alternative but would not meet any of the proposed project objectives. Alternative 2, the No Project – Residential Project Consistent with the Site’s General Plan Land Use Designation, would result in similar, but somewhat reduced, environmental impacts. Alternative 3, the Reduced Scale Alternative - Removal of Villas B and C from Proposed Site Plan, would also result in reduced environmental impacts.

Table 16-1 Comparison of Project Alternatives to the Proposed Project Environmental
Impact
Proposed
Project
Alternative 1:

No Project -
Existing
(Closed) Senior
Living
Community
Alternative 2: No
Project - Residential
Project Consistent
with the Project Site’s
General Plan Land
Use Designation
Alternative 3:

Reduced Scale -
Removal of
Villas B and C
from Proposed
Site Plan
Aesthetics
Impact 5-1. Effect on a
Scenic Vista
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project
Impact 5-3. Alter the
Existing Visual
Character or Quality of
the Site and its
Surroundings
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project
Impact 5-4. Introduce
New Sources of Light
and Glare
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project
Air Quality
Impact 6-2. Criteria Air
Pollutant Emissions
During Project
Construction Would
Degrade Air Quality
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project

ITEM NO. 8.

16.0 Alternatives
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Environmental
Impact
Proposed
Project
Alternative 1:

No Project -
Existing
(Closed) Senior
Living
Community
Alternative 2: No
Project - Residential
Project Consistent
with the Project Site’s
General Plan Land
Use Designation
Alternative 3:

Reduced Scale -
Removal of
Villas B and C
from Proposed
Site Plan
Impact 6-3. Criteria Air
Pollutant Emissions
During Project
Operations Would
Degrade Air Quality
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project
Impact 6-5.

Construction Activity
Would Expose Sensitive
Receptors to Toxic Air
Contaminants

LTSM NI
Avoids Impact
LTSM
Less than Proposed Project
LTSM
Less than Proposed
Project
Impact 6-6. Generate
Odors that Could Affect
Sensitive Receptors
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project
Biological Resources
Impact 7-2. Potential
Effect on Candidate,
Sensitive, or SpecialStatus Species (San
Francisco Dusky-Footed
Woodrat)

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Less than Proposed
Project
Impact 7-3. Potential
Effect on Candidate,
Sensitive, or SpecialStatus Species (Pallid
Bat, Townsend’s BigEared Bat)

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Less than Proposed
Project
Impact 7-4. Potential
Effect on Candidate,
Sensitive, or SpecialStatus Species (Nesting
Raptors and Migratory
Birds)

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Less than Proposed
Project
Impact 7-5. Effect on
Federally- and StateProtected Wetlands or
Waters of the U.S.
(Intermittent or
Ephemeral Drainage)

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Less than Proposed
Project
Impact 7-6. Damage or
Removal of Regulated
Trees

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Less than Proposed
Project

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-15
Environmental
Impact
Proposed
Project
Alternative 1:

No Project -
Existing
(Closed) Senior
Living
Community
Alternative 2: No
Project - Residential
Project Consistent
with the Project Site’s
General Plan Land
Use Designation
Alternative 3:

Reduced Scale -
Removal of
Villas B and C
from Proposed
Site Plan
Impact 7-7. Interference
with Movement of
Wildlife Species or with
Established Wildlife
Corridors
LTS NI
Avoids Impact
LTS
Similar to Proposed Project
LTS
Less than Proposed
Project
Impact 7-8. Effect on
Sensitive Natural
Communities

LTSM NI
Avoids Impact
LTS
Similar to Proposed Project
LTS
Less than Proposed
Project
Cultural, Paleontological, and Tribal Resources
Impact 8-1. Potential
Adverse Change to
Historic Resources
and/or Unique
Archaeological
Resources During
Construction
LTS NI
Avoids Impact
LTS
Similar to Proposed Project
LTS
Less than Proposed
Project
Impact 8-2. Potential
Destruction of a Unique
Paleontological
Resource or Site During
Construction
LTS NI
Avoids Impact
LTS
Similar to Proposed Project
LTS
Less than Proposed
Project
Impact 8-3. Potential
Adverse Impact to
Native American Human
Remains During
Construction
LTS NI
Avoids Impact
LTS
Similar to Proposed Project
LTS
Less than Proposed
Project
Energy
Impact 9-1. Proposed
Project Results in the
Consumption of Energy
Resources
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project
Geology and Soils
Geologic impacts
associated with fault
surface rupture,
expansive soils, and
land sliding and slope
instability.

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Less than Proposed
Project
Greenhouse Gas Emissions
Impact 10-1. Generate
Greenhouse Gas
Emissions
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project

ITEM NO. 8.

16.0 Alternatives
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Environmental
Impact
Proposed
Project
Alternative 1:

No Project -
Existing
(Closed) Senior
Living
Community
Alternative 2: No
Project - Residential
Project Consistent
with the Project Site’s
General Plan Land
Use Designation
Alternative 3:

Reduced Scale -
Removal of
Villas B and C
from Proposed
Site Plan
Hazards and Hazardous Materials
Hazardous materials
impacts associated with
exposure or release of
asbestos and/or leadbased paint associated
with demolition of
existing structures.

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Similar to Proposed
Project
Noise
Impact 11-1.

Construction Activities
Could Cause a
Substantial Temporary
Noise Increase
LTS NI
Avoids Impact
LTS
Similar to Proposed Project
LTS
Similar to Proposed
Project
Impact 11-2.

Groundborne Vibration
during Construction
Activities
LTS NI
Avoids Impact
LTS
Similar to Proposed Project
LTS
Similar to Proposed
Project
Transportation
Traffic and Vehicle Miles
Traveled Increase
LTS NI NI (or Beneficial Impact) NI (or Beneficial
Impact)
Wildfire Hazards
Impact 12-1. ShortTerm ConstructionRelated Traffic Activity That Has the Potential
to Impair an Adopted
Emergency Response
Plan or Emergency
Evacuation Plan

LTSM NI
Avoids Impact
LTSM
Similar to Proposed Project
LTSM
Similar to Proposed
Project
Impact 12-2. Due to
Slope, Prevailing Winds,
and Other Factors
Exacerbate Wildfire
Risks, and Thereby
Expose Project
Occupants to Pollutant
Concentrations from a
Wildfire or the
Uncontrolled Spread of
a Wildfire.

LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project

ITEM NO. 8.
110 Wood Road – Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 16-17
Environmental
Impact
Proposed
Project
Alternative 1:

No Project -
Existing
(Closed) Senior
Living
Community
Alternative 2: No
Project - Residential
Project Consistent
with the Project Site’s
General Plan Land
Use Designation
Alternative 3:

Reduced Scale -
Removal of
Villas B and C
from Proposed
Site Plan
Impact 12-4. Expose
People or Structures to
Significant Risks,
including Downslope or
Downstream Flooding or
Landslides, as a Result
of Runoff, Post-Fire
Slope Instability, or
Drainage Changes.

LTSM NI
Avoids Impact
LTSM
Less than Proposed Project
LTSM
Less than Proposed
Project
Impact 12-5. Expose
People or Structures to
Significant Risks
Associated with
Wildland Fires
LTS NI
Avoids Impact
LTS
Less than Proposed Project
LTS
Less than Proposed
Project
Project Objectives Met Not Met Not Met Partially Met
SOURCE: EMC Planning Group 2021
NOTE: NI – No Impact; LTS – Less Than Significant; LTSM – Less-Than-Significant with Mitigation; SU – Significant and Unavoidable

16.6 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
The no project alternative is the environmentally superior alternative. It would avoid all of the project’s less-than-significant impacts, and significant but mitigable impacts.

CEQA Guidelines section 15126.6(e)(2) states that if the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. Alternative 3, the Reduced Scale alternative, is considered to be the environmentally superior alternative among the remaining alternatives.

It is the only alternative that could accomplish some of the basic project objectives while minimally reducing some of the less-than-significant and/or significant and mitigable environmental impacts identified for the proposed project.

ITEM NO. 8.

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ITEM NO. 8.

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17.0 Document and Web Sources
This section provides the document and web sources referenced in the EIR. Sources are provided by section.

17.1 INTRODUCTION
No sources.

17.2 SUMMARY
No sources.

17.3 ENVIRONMENTAL SETTING
Town of Los Gatos. 1978. Los Gatos Hillside Specific Plan. Accessed January 8, 2021. https://www.losgatosca.gov/1146/Los-Gatos-Hillside-Specific-Plan ———. March 10, 2010a. Town of Los Gatos 2020 General Plan Draft EIR. Accessed January 8, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2058/Los_Gatos_2020_General_ Plan_Draft_EIR
———. June 16, 2010b. Town of Los Gatos 2020 General Plan Final EIR. Accessed January 8, 2021. https://www.losgatosca.gov/DocumentCenter/View/2065/LosGatos2020-FEIR_Complete-Report ———. January 7, 2011. Town of Los Gatos 2020 General Plan. Accessed January 8, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=
———. October 15, 2012. Los Gatos Sustainability Plan. Accessed January 8, 2021. https://www.losgatosca.gov/DocumentCenter/View/8122/LosGatosSustainabilityPlan_October-2012

ITEM NO. 8.

17.0 Document and Web Sources
17-2 EMC Planning Group Inc.

17.4 PROJECT DESCRIPTION
Kimley-Horn. January 15, 2021. Response to Staff Technical Review (110 Wood Road Planned Development Application PD-20-001).

Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets.

San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA. ———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

17.5 AESTHETICS
Kimley-Horn. January 15, 2021. Response to Staff Technical Review (110 Wood Road Planned Development Application PD-20-001).

Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets.

San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA. ———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

17.6 AIR QUALITY
American Lung Association. April 21, 2020. “State of the Air.” https://www.lung.org/media/press-releases/state-of-the-air-california . July 26, 2017. Plan Bay Area 2040: Regional Transportation Plan and Sustainable Communities Strategy for the San Francisco Bay Area 2017-2040. San Francisco Bay Area, CA. https://mtc.ca.gov/sites/default/files/Final_Plan_Bay_Area_2040.pdf Bay Area Air Quality Management District. April 19, 2017a. 2017 Clean Air Plan: Spare the Air, Cool the Climate. San Francisco, CA. http://www.baaqmd.gov/~/media/files/planningand-research/plans/2017-clean-air-plan/attachment-a_-proposed-final-cap-vol-1- pdf.pdf?la=en

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 17-3
. May 2017b. California Environmental Quality Act Air Quality Guidelines.

San Francisco, CA. http://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en . December 2016. BAAQMD Air Toxics NSR Program Health Risk Assessment Guidelines. https://www.baaqmd.gov/~/media/files/planning-and-research/permitmodeling/hra_guidelines_12_7_2016_clean-pdf.pdf?la=en . Air Quality Standards and Attainment Status. Accessed February 17, 2021. https://www.baaqmd.gov/about-air-quality/research-and-data/air-quality-standardsand-attainment-status.

California Air Resources Board. “AB 1807 – Toxics Air Contaminant Identification and Control.” Accessed February 17, 2021a.
https://ww2.arb.ca.gov/resources/documents/ab-1807-toxics-air-contaminantidentification-and-control . “Air Toxics Hot Spots Information and Assessment Act (AB 2588).” Accessed February 17, 2021b. https://ww2.arb.ca.gov/resources/documents/air-toxics-hot-spotsinformation-and-assessment-act-ab-2588 . May 4, 2016. “Ambient Air Quality Standards.”
https://www.arb.ca.gov/research/aaqs/aaqs2.pdf
California Building Standards Commission. 2016. Title 24 including Part 11, 2019 California Green Building Standards Code (CALGreen).
https://codes.iccsafe.org/content/chapter/15761/
California Energy Commission. March 2018. 2019 Building Energy Efficiency Standards:

Frequently Asked Questions.
https://ww2.energy.ca.gov/title24/2019standards/documents/Title_24_2019_Building_ Standards_FAQ_ada.pdf.

DieselNet. “United States: Nonroad Diesel Engines.” Last modified December 2017. https://www.dieselnet.com/standards/us/nonroad.php
EMC Planning Group. March 16, 2021. 110 Wood Road Criteria Air Pollutant Emissions Modeling Methodology and Assumptions. Monterey, CA.

Google, Inc. 2020. Google Earth.

Newell and Rogers. June 2003. The U.S. Experience with the Phasedown of Lead in Gasoline.

Washington D.C: Resources for the Future.
https://web.mit.edu/ckolstad/www/Newell.pdf
Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.

ITEM NO. 8.

17.0 Document and Web Sources
17-4 EMC Planning Group Inc.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets.

San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA. ———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

Town of Los Gatos. September 20, 2010. Town of Los Gatos General Plan 2020. Accessed January 2021. https://www.losgatosca.gov/27/General-Plan.

United States Environmental Protection Agency. “Criteria Air Pollutants.” Last modified March 8, 2018. https://www.epa.gov/criteria-air-pollutants . “Basic Information about Lead Air Pollution.” Last modified November 29, 2017. https://www.epa.gov/lead-air-pollution/basic-information-about-lead-air-pollution . “Diesel Fuel Standards and Rule Makings.” Last modified August 5, 2019. https://www.epa.gov/diesel-fuel-standards/diesel-fuel-standards-and-rulemakings

17.7 BIOLOGICAL RESOURCES
California Department of Fish and Wildlife (CDFW). 2020. California Natural Diversity Database. Records of occurrence for Cupertino, San Jose West, San Jose East, Castle Rock Ridge, Los Gatos, Santa Teresa Hills, Felton, Laurel, and Loma Prieta quadrangle maps. Sacramento, CA. https://wildlife.ca.gov/data/cnddb California Invasive Plant Council (Cal-IPC). 2020. Invasive Plant Inventory. https://www.calipc.org/plants/inventory/ California Native Plant Society (CNPS). 2020. Inventory of Rare and Endangered Plants.

Records of occurrence for Cupertino, San Jose West, San Jose East, Castle Rock Ridge, Los Gatos, Santa Teresa Hills, Felton, Laurel, and Loma Prieta quadrangle maps.

Sacramento, CA. http://www.cnps.org/inventory.

EMC Planning Group. 2021. Los Gatos Meadows Focused Survey Report.

Gates and Associates. 2020. Response to Los Gatos Meadows Arborist Peer Review Letter dated July 6, 2020. November 20, 2020.

HortScience | Bartlett Consulting. 2020 Arborist Report Update, Los Gatos Meadows, Los Gatos, CA. October 12, 2020.

HortScience Bartlett Consulting. 2018. Arborist Report, Los Gatos Meadows.

August 28, 2018.

Monarch Consulting Arborists. 2020. Arborist’s Review, 110 Wood Road. July 6, 2020.

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 17-5
U.S. Fish and Wildlife Service (USFWS). 2020a. Endangered Species Program. Species list for Santa Clara County. Washington, D.C. http://www.fws.gov/endangered/. ―――. 2020b. National Wetlands Inventory Wetland Mapper. https://www.fws.gov/wetlands/data/mapper.html.

17.8 CULTURAL RESOURCES
California Office of Historic Preservation. Accessed March 17, 2021. https://ohp.parks.ca.gov/ National Conference of State Historic Preservation Officers. Accessed March 17, 2021. https://ncshpo.org/resources/national-historic-preservation-act-of-1966/ National Park Service. Accessed March 17, 20210.
https://www.nps.gov/subjects/nagpra/index.htm
Town of Los Gatos. March 2019. Town of Los Gatos 2040 General Plan Background Report (Public Draft). Accessed March 17, 2021. http://www.losgatos2040.com/documents.html . 2011. Town of Los Gatos 2020 General Plan. Accessed January 8, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=

17.9 ENERGY
Kimley-Horn. 2020. Los Gatos Meadows Transportation Analysis.

Town of Los Gatos. 2012. Town of Los Gatos Sustainability Plan. https://www.losgatosca.gov/DocumentCenter/View/8162/LosGatosSustainabilityPlan_October-2012_201308121810582238?bidId=

17.10 GREENHOUSE GAS EMISSIONS
American Lung Association. April 21, 2020. “State of the Air.” https://www.lung.org/media/press-releases/state-of-the-air-california Association of Bay Area Governments and Metropolitan Transportation Commission.

July 18, 2013. Plan Bay Area: Strategy for a Sustainable Region.

San Francisco Bay Area, CA.
http://files.mtc.ca.gov/pdf/Plan_Bay_Area_FINAL/Plan_Bay_Area.pdf . July 26, 2017. Plan Bay Area 2040: Regional Transportation Plan and Sustainable Communities Strategy for the San Francisco Bay Area 2017-2040. San Francisco Bay Area, CA. https://mtc.ca.gov/sites/default/files/Final_Plan_Bay_Area_2040.pdf

ITEM NO. 8.

17.0 Document and Web Sources
17-6 EMC Planning Group Inc.

Bay Area Air Quality Management District. April 19, 2017a. 2017 Clean Air Plan: Spare the Air, Cool the Climate. San Francisco, CA. http://www.baaqmd.gov/~/media/files/planningand-research/plans/2017-clean-air-plan/attachment-a_-proposed-final-cap-vol-1- pdf.pdf?la=en
. May 2017b. California Environmental Quality Act Air Quality Guidelines.

San Francisco, CA. http://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en Cal-Adapt. “Extreme Heat.” Accessed March 14, 2021. https://cal-adapt.org/tools/extremeheat/ . “Snowpack.” Accessed March 13, 2021. https://caladapt.org/tools/snowpack/#climatevar=swe&scenario=rcp45&lat=36.78125&lng=- 121.34375&boundary=locagrid&units=inch
. “Annual Averages.” Accessed March 14, 2021. https://cal-adapt.org/tools/annualaverages/#climatevar=pr&scenario=rcp45&lat=36.90625&lng=-121.71875&boundary= locagrid&units=inches%20per%20day
California Air Resources Board. “Summary: Diesel Particulate Matter Health Impacts.” Accessed September 29, 2020a. https://ww2.arb.ca.gov/resources/summary-dieselparticulate-matter-health-impacts . “Portable Equipment Registration Program (PERP).” Accessed September 29, 2020b. https://ww2.arb.ca.gov/our-work/programs/portable-equipment-registrationprogram-perp . “AB 1807 – Toxics Air Contaminant Identification and Control.” Accessed September 29, 2020c. https://ww2.arb.ca.gov/resources/documents/ab-1807-toxics-aircontaminant-identification-and-control . “Air Toxics Hot Spots Information and Assessment Act (AB 2588).” Accessed September 29, 2020d. https://ww2.arb.ca.gov/resources/documents/air-toxics-hotspots-information-and-assessment-act-ab-2588 . “GHG Current California Emission Inventory Data.” Accessed September 28, March 13, 2021e. https://ww2.arb.ca.gov/ghg-inventory-data . May 4, 2016. “Ambient Air Quality Standards.”
https://www.arb.ca.gov/research/aaqs/aaqs2.pdf
. May 2014. First Update to the Climate Change Scoping Plan. https://www.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_ scoping_plan.pdf

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 17-7
California Building Standards Commission. 2016. Title 24 including Part 11, 2019 California Green Building Standards Code (CALGreen).
https://codes.iccsafe.org/content/chapter/15761/
California Department of Finance. January 2020a. Table P-1: Total Estimated and Projected Population for California and Counties: July 1, 2010 to July 1, 2060 in 1-year Increments; Accessed November 23, 2020.
http://www.dof.ca.gov/Forecasting/Demographics/projections/ California Department of Finance. May 2020b. Report E-5: Population and Housing Estimates for Cities, Counties, and the State, January 1, 2011-2020, with 2010 Benchmark; Accessed September 29, 2020. http://dof.ca.gov/Forecasting/Demographics/Estimates/e-5/ California Employment Development Department. July 2020. 2018-2028 Occupational Employment Projections California; Accessed November 23, 2020. https://www.labormarketinfo.edd.ca.gov/data/employment-projections.html California Energy Commission. March 2018. 2019 Building Energy Efficiency Standards:

Frequently Asked Questions.
https://ww2.energy.ca.gov/title24/2019standards/documents/Title_24_2019_Building_ Standards_FAQ_ada.pdf
DieselNet. “United States: Nonroad Diesel Engines.” Last modified December 2017. https://www.dieselnet.com/standards/us/nonroad.php
EMC Planning Group. July 16, 2020. 110-150 Charter Street – Emissions Modeling Methodology and Assumptions. Monterey, CA.

G. Hartfield, J. Blunden, and D. S. Arndt. August 2018. A Look at 2017: Takeaway Points from the State of the Climate Supplement.
https://www.ametsoc.net/sotc2017/SoC2017_ExecSumm.pdf
Google, Inc. 2020. Google Earth.

NASA. “The Effects of Climate Change.” Last modified September 28, 2020. https://climate.nasa.gov/effects/
Newell and Rogers. June 2003. The U.S. Experience with the Phasedown of Lead in Gasoline.

Washington D.C: Resources for the Future.
https://web.mit.edu/ckolstad/www/Newell.pdf
Office of Planning and Research, California Energy Commission, and California Natural Resources Agency. January 16, 2019. California’s Fourth Climate Change Assessment:

Statewide Summary Report. https://www.energy.ca.gov/sites/default/files/2019- 11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_ Report_ADA.pdf

ITEM NO. 8.

17.0 Document and Web Sources
17-8 EMC Planning Group Inc.

Town of Los Gatos. 2011. Town of Los Gatos 2020 General Plan. Accessed January 8, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=
United Nations Framework Convention on Climate Change. “Global Warming Potentials.” Accessed September 28, 2020. https://unfccc.int/process/transparency-and-reporting/ greenhouse-gas-data/greenhouse-gas-data-unfccc/global-warming-potentials United States Environmental Protection Agency. “Criteria Air Pollutants.” Last modified March 8, 2018. https://www.epa.gov/criteria-air-pollutants . “Basic Information about Lead Air Pollution.” Last modified November 29, 2017. https://www.epa.gov/lead-air-pollution/basic-information-about-lead-air-pollution . “Diesel Fuel Standards and Rule Makings.” Last modified August 5, 2019. https://www.epa.gov/diesel-fuel-standards/diesel-fuel-standards-and-rulemakings . “Overview of Greenhouse Gases”.

Last modified September 8, 2020. https://www.epa.gov/ghgemissions/overviewgreenhouse-gases

17.11 NOISE
California Department of Transportation (Caltrans). April 2020. Transportation and Construction Vibration Guidance Manual. Sacramento, CA. Accessed March 16, 2021. https://dot.ca.gov/programs/environmental-analysis/noise-vibration/guidancemanuals Town of Los Gatos. March 10, 2010a. Town of Los Gatos 2020 General Plan Draft EIR. Accessed February 18, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2058/Los_Gatos_2020_General_ Plan_Draft_EIR
———. June 16, 2010b. Town of Los Gatos 2020 General Plan Final EIR. Accessed February 18, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2065/LosGatos-2020- FEIR_Complete-Report
———. January 7, 2011. Town of Los Gatos 2020 General Plan. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 17-9
U.S. Department of Transportation, Federal Highway Administration. January 2006a. Federal Highway Administration Roadway Construction Noise Model User’s Guide. Accessed February 18, 2021.
https://www.fhwa.dot.gov/Environment/noise/construction_noise/rcnm/rcnm.pdf ———. May 2006b. Transit Noise and Vibration Impact. Assessment. Accessed February 18, 2021.
https://docs.vcrma.org/images/pdf/planning/ceqa/FTA_Noise_and_Vibration_ Manual.pdf
———. 2015. Construction Noise Handbook. Accessed February 18, 2021. https://www.fhwa.dot.gov/environment/noise/construction_noise/

17.12 WILDFIRE HAZARDS
California Board of Forestry and Fire Protection. June 24, 2019. California Vegetation Treatment Program Draft Program Environmental Impact Report (State Clearinghouse #2019012052).

Accessed January 13, 2021. https://ceqanet.opr.ca.gov/2019012052/2 California Department of Forestry and Fire Protection (CAL FIRE). November 2007.

Santa Clara County (State Responsibility Area Map). Accessed January 13, 2021. https://osfm.fire.ca.gov/media/6766/fhszs_map43.pdf
———. October 2008. Santa Clara County (Local Responsibility Area Map). Accessed January 13, 2021. https://osfm.fire.ca.gov/media/6764/fhszl_map43.pdf Cornerstone Earth Group. September 17, 2007. Draft Preliminary Geologic and Geotechnical Evaluation for Los Gatos Meadows. Sunnyvale, CA.
———. December 30, 2020. Geotechnical Investigation and Geologic Hazards Evaluation Los Gatos Meadows. Sunnyvale, CA.

Federal Emergency Management Agency (FEMA). 2021. FEMA Flood Map Service Center website. Accessed January 22, 2021. https://msc.fema.gov/portal/home InciWeb (Incident Information System). 2020. CZU August Lightning Complex. https://inciweb.nwcg.gov/incident/7028/
Kimley-Horn. January 2021. Los Gatos Meadows Preliminary Stormwater Control Plan.

Pleasanton, CA.

Kimley-Horn. January 15, 2021. Response to Staff Technical Review (110 Wood Road Planned Development Application PD-20-001).

Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.

ITEM NO. 8.

17.0 Document and Web Sources
17-10 EMC Planning Group Inc.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets. San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA. ———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA.

Santa Clara County Fire Department. 2021. Fire Prevention web page. Accessed January 8, 2021. http://www.sccfd.org/fire-prevention/fire-prevention-overview.

State of California. California Fire Code 2019. Accessed January 8, 2021. https://up.codes/viewer/california/ca-fire-code-2019
Town of Los Gatos. March 10, 2010a. Town of Los Gatos 2020 General Plan Draft EIR. Accessed January 13, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2058/Los_Gatos_2020_General_ Plan_Draft_EIR
———. June 16, 2010b. Town of Los Gatos 2020 General Plan Final EIR. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/2065/LosGatos2020-FEIR_Complete-Report ———. January 7, 2011. Town of Los Gatos 2020 General Plan. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=
———. 2015. Emergency Operations Plan. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/15967/Los-Gatos-EOP-final1-21-2016 ———. March 2019. Town of Los Gatos 2040 General Plan Background Report (Public Draft).

Accessed February 26, 2021. http://www.losgatos2040.com/documents.html ———. September 2020. Town of Los Gatos Roadside Vegetation Management Plan and Environmental Exemption Analysis. Accessed February 26, 2021. https://www.losgatosca.gov/VegetationManagement

17.13 EFFECTS NOT ADDRESSED FURTHER IN THIS EIR
Kimley Horn. January 21, 2020. Los Gatos Meadows – Transportation Analysis. Pleasanton, CA. ———. December 9, 2020. Memorandum re: Los Gatos Meadows –Transportation Analysis.

Pleasanton, CA.

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 17-11
———. December 10, 2020. Response to TJKM Traffic Comments (110 Wood Road).

Pleasanton, CA.

Kimley-Horn. January 15, 2021. Response to Staff Technical Review (110 Wood Road Planned Development Application PD-20-001).

Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets.

San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA. ———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

TJKM. November 24, 2020. Technical Memorandum Subject: TJKM Peer Review of 101 Wood Road. Pleasanton, CA.
———. December 14, 2020. Technical Memorandum Subject: TJKM Review of 101 Wood Road Peer Review Responses. Pleasanton, CA.

Town of Los Gatos. March 10, 2010a. Town of Los Gatos 2020 General Plan Draft EIR. Accessed January 13, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2058/Los_Gatos_2020_General_ Plan_Draft_EIR
———. June 16, 2010b. Town of Los Gatos 2020 General Plan Final EIR. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/2065/LosGatos2020-FEIR_Complete-Report ———. January 7, 2011. Town of Los Gatos 2020 General Plan. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=

17.15 GROWTH INDUCING IMPACTS
Kimley-Horn. January 15, 2021. Response to Staff Technical Review (110 Wood Road Planned Development Application PD-20-001).

Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets. San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA.

ITEM NO. 8.

17.0 Document and Web Sources
17-12 EMC Planning Group Inc.
———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

Town of Los Gatos. March 10, 2010a. Town of Los Gatos 2020 General Plan Draft EIR. Accessed January 13, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2058/Los_Gatos_2020_General_ Plan_Draft_EIR
———. June 16, 2010b. Town of Los Gatos 2020 General Plan Final EIR. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/2065/LosGatos2020-FEIR_Complete-Report ———. January 7, 2011. Town of Los Gatos 2020 General Plan. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=

17.16 CUMULATIVE IMPACTS
Bay Area Air Quality Management District. May 2017. California Environmental Quality Act Air Quality Guidelines. Accessed March 4, 2021.
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_ guidelines_may2017-pdf.pdf?la=en
Kimley-Horn. January 15, 2021. Response to Staff Technical Review (110 Wood Road Planned Development Application PD-20-001).

Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets.

San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA. ———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

Town of Los Gatos. March 10, 2010a. Town of Los Gatos 2020 General Plan Draft EIR. Accessed January 13, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2058/Los_Gatos_2020_General_ Plan_Draft_EIR
———. June 16, 2010b. Town of Los Gatos 2020 General Plan Final EIR. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/2065/LosGatos2020-FEIR_Complete-Report

ITEM NO. 8.
110 Wood Road - Los Gatos Meadows Senior Living Community Draft EIR
EMC Planning Group Inc. 17-13
———. January 7, 2011. Town of Los Gatos 2020 General Plan. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=

17.17 ALTERNATIVES
California Department of Conservation. September 2018. Santa Clara County Important Farmland 2016. Sacramento, CA.
———. 2021. California Important Farmland Finder website. Accessed March 30, 2021. https://maps.conservation.ca.gov/DLRP/CIFF/
Kimley Horn. January 21, 2020. Los Gatos Meadows – Transportation Analysis. Pleasanton, CA. ———. January 15, 2021. Response to Staff Technical Review (110 Wood Road Planned Development Application PD-20-001).

Perkins Eastman. October 13, 2020. Los Gatos Meadows Planning Submittal (Project Plans).

San Francisco, CA.
———. January 12, 2021. Los Gatos Meadows Resubmittal Architectural Sheets.

San Francisco, CA.

Rockwood Pacific. June 2020a. “Los Gatos Meadows Project Description.” Orinda, CA. ———. June 2020b. “Letter of Justification – Rebuild of Los Gatos Meadows.” Orinda, CA.

Town of Los Gatos. March 10, 2010a. Town of Los Gatos 2020 General Plan Draft EIR. Accessed January 13, 2021.
https://www.losgatosca.gov/DocumentCenter/View/2058/Los_Gatos_2020_General_ Plan_Draft_EIR
———. June 16, 2010b. Town of Los Gatos 2020 General Plan Final EIR. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/2065/LosGatos2020-FEIR_Complete-Report ———. January 7, 2011. Town of Los Gatos 2020 General Plan. Accessed January 13, 2021. https://www.losgatosca.gov/DocumentCenter/View/1725/Los_Gatos_2020_General_ Plan?bidId=
U.S. Census Bureau. 2021. “Quick Facts – Los Gatos, California.” Accessed March 27, 2021. https://www.census.gov/quickfacts/losgatostowncalifornia

ITEM NO. 8.

17.0 Document and Web Sources
17-14 EMC Planning Group Inc.

17.18 REPORT PREPARERS
Teri Wissler Adam, Senior Principal
Principal-in-Charge and Project Manager
Stuart Poulter, AICP, MCRP, Associate Planner
Report Preparation and Assistant Project Manager
Ron Sissem, MRP, Principal
Report Preparation
Polaris Kinison Brown, MS, Principal Planner
Report Preparation
Sally Rideout, EMPA, Principal Planner
Report Preparation
David Craft, Senior Planner/Air Quality and Greenhouse Gas Emissions Specialist Report Preparation
Gail Bellenger, MA, Registered Professional Archaeologist Report Preparation
Janet Walther, MS, Principal Biologist
Report Preparation
Patrick Furtado, MS, Associate Biologist/Regulatory Specialist Report Preparation
Evan Jacques, Office Assistant/Graphics
Graphics Preparation
Tiffany Robinson, Production Manager
Document Production

ITEM NO. 8.

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ITEM NO. 8.

Proposal for Environmental Consultant Services
The Town of Los Gatos
Attn: Community Development Department
Corporate Office:
1501 Sports Drive, Suite A
Sacramento, CA 95834
Office: (916) 372-6100
[email protected]
Nick Pappani
Vice President
[email protected]
Angela DaRosa
Division Manager/Air Quality Specialist
[email protected]
ENVIRONMENTAL | PLANNING | PUBLIC FACILITATION | HOUSING

EXHIBIT A

ITEM NO. 8.
i

TABLE OF CONTENTS
Cover Letter
I. Certification Forms
II. Review of Scope of Services................................................................................... 1 III. Experience and Expertise ...................................................................................... 4 IV. Qualifications of Key Personnel............................................................................ 9 V. Timeline ................................................................................................................. 13 VI. Samples.................................................................................................................. 16 VII. Disclosure of Litigation/Discipline ...................................................................... 17 VIII. References ............................................................................................................. 18 IX. Insurance Coverage.............................................................................................. 21 X. Preliminary Fee Schedule .................................................................................... 22 Appendix A: Raney Resumes
Appendix B: Certificate of Insurance

ITEM NO. 8.

October 3, 2025
Community Development Department
Town of Los Gatos
110 E. Main St.

Los Gatos, CA 95030
(408) 354-6874
[email protected]
Re: Request for Proposal (RFP) for Environmental Consultant Services Dear Los Gatos Community Development Department:

On behalf of Raney Planning & Management, Inc., I am pleased to submit our proposal in response to the Town of Los Gatos Request for Proposal (RFP) for Environmental Consultant Services. Over the past 26 years, Raney has completed numerous California Environmental Quality Act (CEQA), planning, air quality-related, and National Environmental Policy Act (NEPA) projects. Raney is committed to ensuring successful management of the environmental review and planning process and has the experience needed to efficiently complete the CEQA process, alleviate the Town’s workload, and ensure the needs and expectations of the Town are satisfied. Raney is proud to be an independent and privately-owned small business entity in Sacramento, California, providing environmental and land use planning services. Raney is an S Corporation and a State of California certified Small Business Enterprise (SBE).

Raney has completed numerous CEQA projects throughout California. This proposal will highlight a select number of projects, including the Twin Oaks/Surrey Farms IS/MND, 14915 Shannon Road Subdivision Initial Study, 15349 Los Gatos Boulevard Modified Initial Study Checklist, and Winchester Assisted Living Initial Study located in the Town of Los Gatos, as well as the Tuscan Ridge EIR located in Butte County, the Palomino Place Subsequent EIR located in the City of Davis, the SMP 39/SMP 40 EIR located in the City of Livermore, and the Sand Creek Focus Area Projects in the City of Antioch.

To meet the needs of the Town of Los Gatos, we have provided a summary of Raney’s relevant experience and expertise in the CEQA process, as well as Air Quality and Greenhouse Gas Impact Analyses. Thank you for the opportunity to submit our proposal for your consideration. If you have any questions regarding our submittal or would like additional information, please feel free to contact Division Manager/Air Quality Specialist, Angela DaRosa or myself. Raney accepts the Town of Los Gatos’ contract template for the Consulting Services Agreement with no exceptions. Raney acknowledges and accepts all published addenda for this RFP.

Thank you,
Nick Pappani, Vice President
1501 Sports Drive, Suite A, Sacramento, California 95834

ITEM NO. 8.

I. CERTIFICATION FORMS

ITEM NO. 8.

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ITEM NO. 8.
1 Wildfire • REAX Engineering
Raney Planning & Management, Inc. was established in 1999 by Company President, Tim Raney, AICP, and has built a reputation as one of the most trusted, experienced, and highly regarded small planning and environmental firms in northern California. Raney brings a unique perspective on the environmental review and planning process to every project, providing insight into efficient and cost-effective management strategies that will alleviate the workload of Town staff, smooth the review and planning process, and promote the positive growth of the Town.

Raney is confident in fulfilling the Scope of Services outlined by the Town of Los Gatos and is familiar with the Town’s specific environmental concerns. While this proposal focuses on CEQA services, a full Statement of Qualifications for all of Raney’s services is available upon request.

CEQA SERVICES
Raney has completed numerous California Environmental Quality Act (CEQA) and air quality related projects for public and private clients, including documentation for standard residential, commercial, mixed-use, industrial, roadway, and infrastructure projects. Raney’s approach is to serve as an extension of lead agency staff, tailoring our services to meet the unique needs of each jurisdiction and unique project. Raney will assign the management core of the company to head every Town of Los Gatos project, ensuring clients receive the greatest level and depth of experience, a direct line of communication to decision-makers, and specialized services. The following is a general list of Raney’s CEQA and air quality services:

APPROACH
Raney provides clients with a direct, communication-focused approach that has been shaped by decades of experience successfully guiding projects through both the planning and environmental review processes. Raney will work closely with Town staff at the beginning of the environmental review process to clarify action items within Raney’s scope of work and identify which issues are of greatest concern to the Town and the public to ensure that those issues are adequately addressed. • CEQA Documents
o Categorical Exemptions;
o Initial Studies and Mitigated
Negative Declarations;
o Initial Studies and Negative
Declarations;
o CEQA Addendums;
o Environmental Impact Reports;
o CEQA Streamlining using
Appendix N and Public Resources
Code (PRC) Sections 21155, and
CEQA Guidelines Section 15183
and 15182; and
o Assembly Bill (AB) 130
Consistency Memorandums.
• Air Quality and Greenhouse Gas
(GHG) Studies
o Stand-alone Air Quality Impact
Studies;
o Operational Air Quality Mitigation
Plans;
o GHG Analyses;
o GHG Reduction Plans;
o Climate Action Plans, including
GHG inventory and identification
of GHG reduction requirements;
and
o Health Risk Assessments.

II. REVIEW OF SCOPE OF SERVICES

ITEM NO. 8.
2 Raney emphasizes communication and coordination with the lead agency and project stakeholders to identify, mitigate, and/or resolve potential project roadblocks as early as possible, and will immediately contact the Town to discuss and address any project issues and concerns that arise during the review process.

Raney’s experienced staff have over 60 years of collective experience working on projects throughout northern California and are able to adapt to any project-specific circumstances. Should unforeseen complications arise, Raney can advise the Town on creative methods to meet the project timeline, mitigate any increase in project budget, and meet project-specific needs without compromising the accuracy and defensibility of the environmental review documentation. For example, if a project requires additional analysis following a public review comment, Raney would immediately coordinate with the Town to determine next steps, contact the appropriate subconsultant if required, and work with the Town to act on any creative methods of keeping the project timeline on track.

Raney understands the legal risk of inadequate records and maintains a comprehensive administrative record of documents and personal communications associated with the preparation of all environmental and planning-related documents. Raney will be able to promptly assist the Town with any request for project-related information, ensuring the Town can meet the public’s needs in a timely and efficient manner.

Barring unexpected circumstances, Raney will electronically deliver (Word, PDF) relevant documentation, materials, data, etc. to the Town by the deadline within Raney’s scope of work or in an otherwise timely manner.

CEQA TECHNICAL REPORTS
The CEQA review process typically involves the preparation of various technical reports to ensure the document is as comprehensive and defensible as possible. Raney will conduct all air qualityrelated studies in-house. If necessary, Raney contracts with technical experts to prepare projectspecific technical reports. A full list of proposed sub-consultants is included further in this section.

AIR QUALITY AND GREENHOUSE GAS ANALYSIS
Raney has completed numerous Air Quality Assessments and GHG Analyses for public and private sector clients throughout California, from affordable housing projects and large-scale specific plans to unique and complex projects such as mining, industrial, and infrastructure projects. Raney has developed excellent working relationships with local air quality management districts including, but not limited to, the following:
• Bay Area Air District (BAAD);
• Northern Sierra Air Quality Management District (NSAQMD); • Placer County Air Pollution Control District (PCAPCD); • Sacramento Metropolitan Air Quality Management District (SMAQMD); • San Joaquin Valley Air Pollution Control District (SJVAPCD); and • Yolo-Solano Air Quality Management District (YSAQMD).

ITEM NO. 8.
3 Unlike other air quality firms, Raney’s understanding of the CEQA review process allows us to prepare reports to be seamlessly incorporated into stand-alone and other environmental review documents, such as EIRs. Raney has also prepared many Health Risk Assessments (HRAs) for projects that would expose nearby sensitive receptors, such as residential communities, to increased health risk impacts from toxic air contaminants associated with gas dispensing facilities, diesel truck trips, construction equipment, and more. All air quality and GHG studies are prepared to be consistent with the regulations and requirements of CEQA, the local air district, and the lead agency.

PEER REVIEWS OF APPLICANT-PROVIDED TECHNICAL REPORTS
As the prime environmental consultant, Raney’s experienced staff can effectively review technical reports prepared by the project applicant team. For every report, Raney will ensure that all relevant CEQA topics are adequately addressed according to current industry standard practices. Raney considers this type of peer review to be a “CEQA-level” peer review.

SUB-CONSULTANTS
If necessary, Raney contracts with technical experts to prepare project-specific technical reports.

Rather than preparing all technical reports in-house, Raney has found that relying on experienced, established technical experts and specialists leads to a smoother, more efficient process. The following is a list of sub-consultants Raney would propose to contract with to provide necessary technical reports, technical peer reviews, and other tasks determined on a project-specific basis.

CEQA Issue Area Sub-Consultant
Biological Resources Live Oak Associates
Cultural and Tribal Cultural Resources Eileen Barrow and Associates Geology and Soils and
Hazards and Hazardous Materials
Geocon
Noise Bollard Acoustical Consultants
Transportation Hexagon Transportation Consultants
Wildfire REAX Engineering

ITEM NO. 8.
4 Raney is an expert CEQA practitioner and typically serves as the prime environmental consultant for contracts. Similar to the work being requested by the Town of Los Gatos, Raney has assisted public agencies with CEQA services for many types of projects, including new development/improvement projects as well as modified projects, the latter of which can often be reviewed under the provisions of Public Resources Code (PRC) 21166 and CEQA Guidelines 15162, in the form of an Addendum, Subsequent EIR, or Supplemental EIR. Raney is proficient in preparing all types of CEQA documents, including categorical exemption memorandums/assessments, initial study/mitigated negative declarations (IS/MNDs), programlevel EIRs, project-level EIRs, program/project level EIRs, Addendums, Supplemental EIRs, and Joint CEQA/National Environmental Protection Act (NEPA) documents. Raney currently provides on-call environmental services to various jurisdictions including but not limited to the Town of Los Gatos, the cities of Antioch, Brentwood, Galt, Livermore, Morgan Hill, Oakley, Pacifica, Woodland, and Wheatland, as well as El Dorado County, Placer County, and Yolo County.

In addition to the Air Quality and Greenhouse Gas (AQ/GHG) analyses that Raney conducts as part of CEQA documents, Raney also prepares standalone (AQ/GHG) analyses and documents.

For example, Raney has completed several Air Quality Management Plans (AQMP) and Greenhouse Gas Reduction Plans (GHGRP), such as the Upper Westside Specific Plan AQMP and the NewBridge Specific Plan AQMP and GHGRP. In addition, Raney has prepared qualified Climate Action Plans (CAPs) for the cities of Galt and Wheatland, and a Climate Action Plan/Sustainability Action Plan (CAP/SAP) for Cosumnes Community Service District. Raney is also currently preparing the City of Manteca CAP and the GHG Inventory/Sustainability Plan Update in the City of Pittsburg.

Town of Los Gatos Specific Issues
Raney is familiar with the unique environmental issues and concerns associated with the Town of Los Gatos, such as development on the Town’s scenic hillsides, cumulative impacts associated with SB 330 and/or Builder’s Remedy projects within the Town, and wildfire risk posed by the very high and high fire hazard severity zones along the Town’s southern boundary. Raney has experience in analyzing projects relevant to all three of the Town’s unique concerns.

Twin Oaks/Surrey Farms IS/MND – Cumulative Impacts
Raney prepared the Twin Oaks/Surrey Farms IS/MND, which is now under public review. The approximately 17.55-acre project site, identified by APN 532-16-006, is located on an undeveloped hillside at 178 Twin Oaks Drive. The proposed project would subdivide the project site into 12 residential lots, ranging in size from approximately 0.1-acre to 5.48 acres. The eastern portion of the project site would remain undeveloped. The western slope would be developed with 11 residences, comprised of eight market-rate single-family residences and three below marketrate detached row houses. An additional single-family residence would be developed on the hillside’s northeastern slope. Given public concerns expressed about the number of SB 330 and/or Builder’s Remedy projects being processed by the Town since the adoption of the General Plan, Raney worked with the Town to prepare an expanded cumulative impacts discussion within the III. EXPERIENCE AND EXPERTISE

ITEM NO. 8.
5 Mandatory Findings of Significance section of the IS/MND. Careful consideration was given to whether the combined effects from both the proposed project and other projects would be cumulatively significant. As is appropriate pursuant to CEQA Guidelines Section 15130, if the agency answers this inquiry in the affirmative, the second question is whether “the proposed project’s incremental effects are cumulatively considerable.” (Communities for a Better Environment, supra, 103 Cal.App.4th at p. 120 [emphasis added]) It is not necessarily true that, even where cumulative impacts are significant, any level of incremental contribution must be deemed cumulatively considerable. (Communities for a Better Environment, supra, 103 Cal.App.4th at p. 120.) Raney found that the project’s incremental contribution to cumulative impacts, was less-than-significant.

Tuscan Ridge EIR – Wildfire and Cumulative Wildfire Risk Butte County
The Tuscan Ridge Project is located in unincorporated Butte County, west of the Town of Paradise.

The project included subdivision of the project site to develop a total of 165 single-family residences across approximately 36.9 acres; 15.9 acres of commercial development, including a gas station/convenience store and a mini-storage facility; a sanitary waste disposal station; approximately 36.7 acres of open space areas; and 49 acres of special utility district. Raney prepared an extensive EIR to evaluate the potential environmental effects of the project. Given that wildfire and emergency evacuation were critical concerns for the project, Raney retained REAX Engineering to prepare a Fire Risk Reduction Plan with support from Fehr & Peers to conduct an Evacuation Study with associated traffic modeling for evacuation time. Raney coordinated with CAL FIRE to review the Fire Risk Reduction Plan and Evacuation Study.

Following completion of the public review period on the Draft EIR, Raney prepared the Final EIR, as well as the Planning Commission and Board of Supervisors staff reports, inclusive of all requisite resolutions and ordinances. Raney supported County staff at the public hearings. The EIR was certified and the project entitlements were approved.

Palomino Place Subsequent EIR – Builder’s Remedy
City of Davis
The approximately 25.8-acre project site is located north of the East Covell Boulevard/Monarch Lane intersection on an existing property known as the Wildhorse Ranch and/or Duffel Horse Ranch in the City of Davis, California. The project site was originally evaluated in the 2009 Wildhorse Ranch Project EIR, prepared by Raney. The City Council approved the Wildhorse Ranch project and certified the EIR, but the project was rejected by the voters. A new applicant submitted an application for a modified project on the same site in 2023, known as Palomino Place.

The proposed project would include demolition of the two on-site duplex buildings and barn, followed by development of a residential community, comprised of up to 175 new units, including 19 new cottages, 29 half-plex townhomes, 82 single-family residences, and up to 45 affordable multi-family apartments. The existing ranch home would be retained and renovated. In addition, the proposed project would include land anticipated to be developed with recreational uses, including a USA Pentathlon Training Facility, pool complex, and obstacle course. The project would also consist of new on-site roadways and associated utility improvements, as well as open space, landscaping, and trails. The proposed project would require approval of a Vesting Tentative

ITEM NO. 8.
6 Subdivision Map to subdivide the project site and develop the residential units, Site Plan and Architectural Review to determine compliance with City development standards for the USA Pentathlon Training Facility and pool complex, and an Affordable Housing Plan to comply with the City’s Affordable Housing Ordinance. The proposed project was submitted under Builder’s Remedy, a provision of California's Housing Accountability Act that prevents jurisdictions without a substantially compliant housing element from denying certain housing projects, even if such projects do not comply with the jurisdiction's general plan or zoning ordinance.

Raney prepared a Subsequent EIR pursuant to CEQA Guidelines Section 15162 to evaluate the environmental effects of the modified project. The Subsequent EIR determined that the modified project would substantially increase certain significant impacts previously identified in the 2009 EIR. Raney worked closely with the City Attorney regarding how to address Builder’s Remedy within the EIR and the fact that the project was not required to comply with the City’s General Plan. The Subsequent EIR was certified and the project approved.

Town of Los Gatos Experience
Raney has completed the following projects for the Town of Los Gatos alongside the previously listed Twin Oaks/Surrey Farms IS/MND and 14915 Shannon Road Subdivision Initial Study. 15349 Los Gatos Boulevard Modified Initial Study Checklist/15168 Checklist The 15349 Los Gatos Boulevard Project is located on an approximately 1.56-acre project site at 15349 and 15367 Los Gatos Boulevard and identified by APNs 424-19-048 and -049. The project included the demolition and removal of all existing on-site structures and a majority of the existing on-site trees. The project would include the development of a 55-unit townhome community consisting of five, three-story residential buildings. The units would be a mix of studios, twobedroom units, and three-bedroom units. On-site amenities would include a 4,220-sf community courtyard with a fire pit and turfed recreation area; a 1,207-sf meditation garden, and a 1,097-sf citrus grove recreation area. In addition, the proposed project would also include new sidewalks, landscaping, and frontage improvements along Garden Lane and Los Gatos Boulevard. The Modified Initial Study Checklist found that the project and its potential effects on the physical environment are within the scope of activities evaluated in the Town of Los Gatos 2040 General Plan EIR; thus, additional CEQA review was not required.

Winchester Assisted Living Initial Study/Mitigated Negative Declaration The Winchester Assisted Living Project is located on an approximately 1.31-acre project site at 15860, 15880, and 15894 Winchester Boulevard and 17484 Shelburne Way and is identified by APNs 529-11-013, -038, -039, -040. The project would include demolition of the nine existing onsite structures to develop a two-to-three story assisted living and memory care facility. The assisted living and memory care facility would consist of 107 assisted living units and 18 memory care units, for a total of 125 units. The Initial Study/Mitigated Negative Declaration determined that all project impacts could be reduced to a less-than-significant level with implementation of mitigation measures.

ITEM NO. 8.
7 14915 Shannon Road Subdivision Initial Study/Mitigated Negative Declaration The 14915 Shannon Road Subdivision Project, identified by Assessor’s Parcel Number (APN) 537-27-047, is located on the southern slope of a hillside at 14915 Shannon Road in the Town of Los Gatos, California on an approximately 27-acre project site. The project would subdivide the project site into nine residential lots, ranging in size from 1.538 acres to 10.414 acres. As discussed above, the project site consists of approximately 27 total acres; however, due to the site being located on a hillside, only approximately 11.7 acres of the project site would be suitable for development. The Initial Study/Mitigated Negative Declaration found that the project would cause a less-than-significant impact.

Bay Area Experience
Raney has completed numerous projects within Bay Area jurisdictions, a few of which are highlighted here.

SMP 39/SMP 40 Project EIR
City of Livermore
The SMP 39/SMP 40 project site consisted of six separate parcels over approximately 105.34 acres, including the SMP 39 site, SMP 40 site, and four additional parcels identified in the EIR as Additional Annexation Only Parcels. The SMP 39/SMP 40 Project consisted of development of the SMP 39 site with up to approximately 755,500 square feet (sf) for six light industrial buildings, and the SMP 40 site with two industrial buildings consisting of up to 759,275 sf. The SMP 39/SMP 40 Project required a number of approvals and agreements by the City of Livermore and Responsible Agencies, including Alameda County and the City of Pleasanton, such as a Sphere of Influence (SOI) Amendment from the City of Pleasanton SOI for SMP 39, General Plan Amendment, Pre-zoning and Annexation, Zoning Map Amendment/Planned Development, Vesting Tentative Subdivision Maps, a Pre-Annexation Agreement, and Development Agreement.

The project’s complexity and shifting scope required Raney to be flexible throughout the preparation of the EIR. Raney extensively coordinated with the City of Livermore, City of Pleasanton, Alameda County, Alameda County LAFCo, Alameda County Airport Land Use Commission, and various other agencies throughout the EIR process.

Sand Creek Focus Area Projects – EIRs and Planning Services City of Antioch
Raney has served as contract planning staff and environmental consultants for almost all of the development applications in the Sand Creek Focus Area of the City of Antioch, including the Aviano Addendum, Promenade/Vineyards at Sand Creek EIR, The Ranch EIR, Creekside/Vineyards at Sand Creek EIR, Albers Ranch EIR, and the ongoing Leung EIR. The Sand Creek Focus Area of the City of Antioch General Plan is located in southern Antioch and is designated for open space, residential, commercial, and mixed-use. The Sand Creek Focus Area projects have received significant public scrutiny, and Raney has coordinated extensively with the City to ensure the environmental review and planning processes went as smoothly as possible.

Creekside/Vineyards at Sand Creek Project – EIR and Planning Services The Creekside/Vineyards at Sand Creek Project consisted of a 220 single-family residential unit development, parks, and associated infrastructure on approximately 58.9 acres. Requested project entitlements included a General Plan Amendment from Open Space/Senior Housing and Hillside;

ITEM NO. 8.
8 Estate and Executive Residential/Open Space to Medium Low Density Residential/Open Space; Rezone from Open Space to Planned Development District with a Master Development Plan; Development Agreement; Vesting Tentative Subdivision Map; Use Permit; Resource Management Plan; and Design Review. Raney provided planning assistance in the review and processing of the project application and prepared an EIR for the project, which addressed all CEQA topics included in Appendix G of the CEQA Guidelines. Raney prepared the staff reports for, and presented at, the Planning Commission and City Council hearings. Raney also assisted with the preparation of the necessary ordinances and resolutions. The EIR was certified and the project approved. Subsequent to the approval, Raney reviewed Improvement Plans and Building Permit plans for compliance with conditions of approval.

West Hills Community Church Project IS/ND
City of Morgan Hill
The West Hills Community Church Project is located on an approximately 1.8-acre project site at 16695 DeWitt Avenue in the City of Morgan Hill, California, and identified by APN 773-09-011.

The project would include demolition of the three existing on-site temporary classroom buildings and the portable restroom building, the remodeling of the existing worship center building to add 2,334 sf of building space, and the development of a Community Life Center (CLC) building. The CLC building would include a fellowship hall, classrooms, a toddler room, a disability room, and storage rooms, as well as lobbies and a kitchen. As a result of the proposed project, the overall onsite building square footage would increase by a total of 4,336 sf, from 14,064 sf to 19,114 sf.

Raney prepared an IS/ND for the project and found that it would result in a less-than-significant impact.

ITEM NO. 8.
9 Since the firm’s establishment, Raney has maintained the same key management staff for over a decade. Vice President, Nick Pappani, has been with Raney for 23 years, Vice President/Air Quality Specialist, Rod Stinson, has been with Raney for 20 years, Division Manager/Air Quality Specialist, Angela DaRosa, has been with Raney for 15 years, and Senior Planner, Kevin Valente, AICP, has been with Raney for 12 years. Together, the management team oversees a talented staff of writers and administrative personnel. Raney is comprised of 27 employees, all of whom operate out of the Sacramento office. Unlike many larger firms, Raney assigns the management core of the company to each project. This provides our clients with the greatest level and depth of experience, a direct line to decision makers, and the expertise to adapt to client needs.

Vice President, Nick Pappani, will serve as the Project Director for California Environmental Quality Act (CEQA) services and will be responsible for overseeing the environmental review process and providing quality control. Mr. Pappani would be assisted by Division Manager/Air Quality Specialist, Angela DaRosa, who would serve as the Project Manager. Project support will be provided by President, Tim Raney, AICP, Vice President/Air Quality Specialist, Rod Stinson, and Raney’s Associate staff.

Barring unforeseen circumstances, Raney Planning and Management, Inc. will assign the key personnel listed in this section to every Town of Los Gatos Project for the duration of our engagement with the Town.

NICK PAPPANI – VICE PRESIDENT
2002-Present
Role: Project Director
Mr. Pappani brings 23 years of environmental and planning experience to the Raney team. As Raney’s Vice President, Mr.

Pappani has served as the Project Manager for numerous CEQA and NEPA documents for jurisdictions throughout northern and southern California. Mr. Pappani has worked on a broad variety of projects, including residential, commercial/hotel, and industrial projects, as well as unique projects such as solar generating facilities and vineyard plans involving timberland conversion. As Raney’s Vice President, Mr. Pappani takes pride in serving various public sector clients and helping them navigate the complex milieu of CEQA legislation and related case law to ensure that each environmental document is legally defensible and reflects current CEQA practice.

In addition to being a CEQA practitioner, who is respected in his field, Mr. Pappani has a background in wildlife biology, having received a Bachelor of Science degree in Wildlife Biology (cum laude) from Humboldt State University, Arcata, California. Prior to joining the Raney team, Mr. Pappani worked with a private consulting firm, as well as the federal government, conducting avian and vegetation surveys for Threatened species in a variety of habitats. Mr. Pappani is also an articulate speaker, having given hundreds of presentations before decision-makers and the public, including answering questions related to Raney’s environmental and planning documents.

IV. QUALIFICATIONS OF KEY PERSONNEL

ITEM NO. 8.
10 Mr. Pappani is also comfortable and competent when it comes to working on controversial projects, subject to intense public scrutiny. For example, Mr. Pappani has served as the Project Manager for several EIRs in the City of Davis. Such situations require not only an expert-level understanding of the regulations of CEQA and recent case law, but also a diplomatic and objective approach to responding to public concerns and comments.

ANGELA DAROSA – DIVISION MANAGER/

AIR QUALITY SPECIALIST
2010-Present
Role: Project Manager/Air Quality and GHG Technical Analysis Ms. DaRosa brings 15 years of environmental experience to the Raney team with a background in CEQA, air quality, and
engineering. Ms. DaRosa graduated from California Polytechnic State University, San Luis Obispo, with a Bachelor of Science degree in Environmental Engineering. Ms. DaRosa’s background in engineering and technical writing allows her to analyze complex technical studies and integrate them into each project.

As Division Manager with Raney, Ms. DaRosa provides project management and assists in the preparation and processing of various environmental and planning documents, such as EIRs, Initial Studies, NEPA compliance documents, and environmental land use and planning documents. Ms.

DaRosa has successfully management several envionrmental review projects, including, but not limited to, the Creekside Vineyards EIR and East and West 18th Street Warehouse Initial Studies for the City of Antioch; Lippi Ranch EIR for the City of Galt; the Mace Ranch Innovation Center EIR and UMall Redevelopment Consistency Checklist for the City of Davis; and the Brady Vineyard Subdivision EIR for Placer County. As an Air Quality Specialist, Ms. DaRosa works closely with Raney’s in-house Air Quality Technician to prepare air quality and greenhouse gas analyses, including Health Risk Assessments, for Initial Studies and EIRs, as well as stand-alone analyses for various private-sector clients.

In addition, Ms. DaRosa has prepared CAPs for the cities of Wheatland and Galt and a CAP/SAP for the Cosumnes CSD, and is in the process of preparing a CAP for the City of Manteca. Ms.

DaRosa prepared analyses for projects located within the jurisdictional boundaries of a number of air districts throughout the State including, but not limited to, the YSAQMD, BAAQMD, SMAQMD, PCAPCD, and SJVAPCD. Ms. DaRosa is proficient in the use of current air quality models, including CalEEMod, AERSCREEN, AERMOD, and HARP RAST.

ITEM NO. 8.
11 TIMOTHY RANEY, AICP – PRESIDENT
1999-Present
Role: Project Support
As the President of Raney Planning & Management, Inc., Mr. Raney serves as the leader of the Raney team. Mr. Raney specializes in CEQA processing, planning, and public facilitation, bringing 36 years of experience to each project. Mr. Raney currently serves as the Community Development Director to the City of Wheatland and, together with Raney staff, has been providing contract planning services to the City since 2004. In addition, Mr. Raney previously served as the Interim Community Development Director for the City of Oakley while the City was completing its General Plan Update.

Since establishing the firm in 1999, Mr. Raney has successfully processed numerous CEQA, NEPA, and planning projects, including Initial Studies, Environmental Impact Reports, Environmental Assessments, and special planning projects such as the APA Award-winning Community Vision for the City of Wheatland. Mr. Raney’s diverse experience includes unique and complex projects such as marinas, military base conversions, mining, and solar to large-scale specific plans, master plans, zoning code updates, and numerous private development projects for residential, commercial, mixed-use, industrial, and infrastructure/roadway.

Mr. Raney also has diverse experience in local government, including being Councilmember and Mayor of the City of Citrus Heights, Planner in the City of Sacramento’s Planning Department, and previously serving on the Board of the Sacramento Metro Chamber Metro PAC and the Sacramento Tree Foundation. Mr. Raney has been involved in local government issues with the League of California Cities, the Commission on Local Governance for the 21st Century, and the Citrus Heights Chamber of Commerce. This experience gives Mr. Raney a better understanding of the needs and requirements of local government. Mr. Raney has a Bachelor of Science degree in Agricultural Economics from the University of California, Davis.

ROD STINSON – VICE PRESIDENT/AIR QUALITY

SPECIALIST
2005-Present
Role: Project Director/Air Quality and GHG Technical Analysis Mr. Stinson brings 20 years of environmental experience to the Raney team with a background in CEQA, air quality, and water resources. As Raney’s Vice President, Mr. Stinson has served as the Project Manager in the preparation of numerous environmental and planning projects, including CEQA Initial Studies and EIRs as well as NEPA Categorical Exclusions and Environmental
Assessments. Mr. Stinson has managed projects ranging from complex mining, solar, and infill projects to large-scale specific plans and general plans as well as standard residential, affordable housing, mixed-use, commercial, industrial, and infrastructure projects. In addition, Mr. Stinson serves as Raney’s in-house Air Quality Specialist, with over ten years of experience in preparing air quality analyses for a variety

ITEM NO. 8.
12 of development projects. Mr. Stinson has completed numerous air quality impact and greenhouse gas analyses, working closely with lead agencies and local air districts throughout northern and southern California. In addition, Mr. Stinson has prepared CAPs for the cities of Wheatland and Galt and a CAP/SAP for the Cosumnes CSD, and is in the process of preparing a CAP for the City of Manteca. Mr. Stinson holds a Bachelor of Science degree in Forestry and Natural Resources Management with a concentration in Environmental Management from California Polytechnic State University, San Luis Obispo.

Assigned Projects
Of the projects listed under Section III. Experience and Expertise, Raney’s key personnel were assigned to each project under the following role:

Project Name Nick Pappani,
Project Director
Angela DaRosa,
Project Manager
Rod Stinson,
Project Director
Twin Oaks/Surrey Farms X X
14915 Shannon Road Subdivision X X
Tuscan Ridge X X
Palomino Place X X
15349 Los Gatos Boulevard X X
Winchester Assisted Living X X
SMP 39/SMP 40 X X
Sand Creek Focus Area Projects X X
West Hills Community Church X X
President, Tim Raney, AICP provided project oversight and expert advice on all projects as needed.

ITEM NO. 8.
13 Raney has included estimated timeframes for CEQA services. The estimated timeframes are representative of typical project timelines and assume the timely delivery of all materials from the Town, applicant team, technical consultants, stakeholder agencies, and other project stakeholders.

Project schedules may vary depending on various factors including, but not limited to, project complexity, additional analyses required to address project updates or agency needs, and additional analyses to address comments from the public. For each project, Raney will provide a schedule based on experience preparing similar documents and consideration for unique project circumstances identified by the Town, applicant, or preliminary review of project materials.

The project management team will be responsible for maintaining the project schedule. Raney maintains a tracking system for each project, including a list of key tasks and milestones, team members responsible for each task, and the budget allocated for each task. Raney monitors project milestones to ensure that deliverables are produced on time and within budget. The management team will maintain continuous communication with Town staff and the project team to identify and resolve barriers to completion before they arise. If complications arise, Raney can be more nimble than larger consulting firms and work with the Town to determine creative methods for meeting project timelines.

Service Key Project Milestones Estimated Timeline
EIR Project Initiation/Kick-off Meeting Week of Notice to Proceed (NTP)
Project Description (includes draft
and final reviews and revisions)
Three Weeks from NTP
Peer Review of Applicant-Provided
Reports
Three Weeks from Receipt
of All Applicant-Provided
Reports
Receipt of All Final Technical
Reports
Eight to Ten Weeks from
Final Project Description
Notice of Preparation (includes
draft and final reviews and
revisions)
Two Weeks from
Finalization of Project
Description
Public Review Period of NOP
(includes an NOP public scoping
meeting during this time)
30 Days
Administrative Draft EIR Eight Weeks from Close of
NOP Public Review Period
Screencheck Draft EIR Three Weeks from Receipt
of Town Comments on
Administrative Draft EIR
Public Review Draft EIR 1 ½ Weeks from Receipt of
Town Comments on
Screencheck Draft EIR
Public Review Period of Draft EIR 45 days
V. TIMELINE

ITEM NO. 8.
14 Administrative Final EIR and

FOF/SOC
Five Weeks from Close of
Draft EIR Public Review
Period
Screencheck Final EIR and

FOF/SOC
Two Weeks from Receipt of
Town Comments on
Administrative Final EIR
Final EIR and FOF/SOC One Week from Town
Comments on Screencheck
Draft EIR
Public Review Period of Final EIR
(10 Days)
10 Days
Public Hearings 1-3 Months Following the
Final EIR
Total estimate 1-1.5 Years
IS/MND Public Review Draft IS/MND
(includes administrative,
screencheck, and final reviews and
revisions)
10 Weeks from Receipt of
All Final Technical Reports
Public Review Period 20-30 Days
Prepare Mitigation Monitoring
Reporting Program (MMRP) and
Responses to Comments, if needed
Two Weeks from Close of
Public Review Period
Public Hearings 1-3 Months Following the
Close of the Public Review
Period
Total estimate 6 Months
Categorical Exemption
Memorandum
Categorical Exemption
Memorandum (CatEx Memo)
(includes administrative,
screencheck, and final reviews and
revisions) and Notice of Exemption
(NOE)
Five weeks from Receipt of
All Final Technical Reports
Public Hearing(s) 1-2 Months Following
Completion of CatEx Memo
Total estimate 3-4 Months
CEQA Addendum CEQA Addendum (includes
administrative, screencheck, and
final reviews and revisions)
Six Weeks from Receipt of
All Final Technical Reports
Public Hearing(s) 1-2 Months Following
Completion of CEQA
Addendum
Total estimate 3-4 Months
Air Quality/Greenhouse
Gas Analysis
AQ/GHG Analysis Report
(includes completion of all
modeling efforts, as well as draft
and final reviews and revisions)
5-10 Weeks

ITEM NO. 8.
15 Health Risk Assessment HRA Analysis Report (includes completion of all modeling efforts,
as well as draft and final reviews
and revisions)
6-10 Weeks

ITEM NO. 8.
16 Raney has included three Environmental Impact Report samples for the Town’s review. Each project included and summarized under Section III. Experience and Expertise. Please follow the CEQANet links below to view and/or download Raney’s examples.

Subsequent Environmental Impact Report – Palomino Place Project Environmental Impact Report – Creekside/Vineyards at Sand Creek Project Environmental Impact Report – Tuscan Ridge Project
If the Town encounters any difficulty accessing the documents using the links provided, Raney can send any required documents through the Town’s preferred method.

VI. SAMPLES

ITEM NO. 8.
17 Raney has never filed a claim nor had a claim filed in court against them. However, Raney has prepared several CEQA documents for highly controversial projects where the lead agency has been subject to CEQA lawsuits. Raney has provided a summary of lawsuits filed against the lead agencies for the documents prepared by Raney in the last five years and associated findings below:

Wine Country Inn IS/MND, City of Livermore
Raney prepared the IS/MND for the Wine Country Inn project in the City of Livermore. The IS/MND was adopted and the project approved. A lawsuit was filed; however, the trial court denied the petition.

Vista Mar IS/MND, City of Pacifica
Raney prepared the IS/MND for the Vista Mar project in the City of Pacifica. The IS/MND was adopted and the project approved. A lawsuit, however, was filed in December 2021. In 2023, the judge ruled that the applicant presented a fair argument that the IS/MND did not sufficiently address the project’s significant environmental impacts. All City approvals were set aside and the project was placed on hold pending the completion of an EIR. The application has not moved forward to date.

Bridle Gate EIR, City of Brentwood
Raney prepared the Draft and Final EIR for the Bridle Gate project in the City of Brentwood. The EIR was certified and the project approved. A lawsuit, however, was filed in February 2025.

Raney has not paid any claims or settlements within the last five years.

VII. DISCLOSURE OF LITIGATION/DISCIPLINE

ITEM NO. 8.
18 Raney has included Attachment 3 – References on the following page. Please note that the listed costs are representative of the total contract amount, not the total costs billed to the client.

A detailed project description for each referenced project is viewable in Section III. Experience and Expertise.

VIII. REFERENCES

ITEM NO. 8.

ITEM NO. 8.

ITEM NO. 8.
21 Raney has attached their current Certificate of Insurance for the Town of Los Gatos’ review under Appendix B.

IX. INSURANCE COVERAGE

ITEM NO. 8.
22 Please find the most up-to-date billing rates for Raney below. Raney will provide the Town of Los Gatos with a complete scope of services, including schedule and cost estimate by task based on hours for each project. The tasks will be summarized in the Technical Scope of Services and costs by task will be included in a cost spreadsheet. The costs will be based on the estimates of time for each task provided in the chart. Costs will be billed on a time and materials basis up to the maximum established budget for each phase, following Raney standard billing rates as outlined below. It should be noted that hourly rates quoted at the commencement of any specific project shall remain valid throughout the duration of a particular project. Raney reserves the right to update our billing rates annually, which will be reflected in the scopes of services for individual projects.

RANEY 2025 BILLING RATES
The following is a summary of Raney, a division of Raney Planning & Management, Inc., billing rates for the provision of environmental review and planning services. Please note that Raney will provide a complete scope of services and cost estimate by task based on hours, upon request.

Tim Raney, AICP, President $235/hour
Nick Pappani, Vice President $215/hour
Rod Stinson, Vice President $215/hour
Angela DaRosa, Division Manager $195/hour
Jesse Fahrney, Assistant Division Manager $175/hour
Kevin Valente, Senior Planner $175/hour
Senior Associate $155/hour
Associate $135/hour
Administrative $85/hour
AIR QUALITY AND GHG ANALYSIS 2025 BILLING RATES
The following is a summary of the billing rates for the provision of air quality and GHG analysis services. Please note that Raney will provide a complete scope of services and cost estimate by task based on hours, upon request.

Rod Stinson, Air Quality Specialist $175/hour
Angela DaRosa, Air Quality Specialist $175/hour
Jesse Fahrney, Air Quality Specialist $175/hour
Air Quality Technician $155/hour

OTHER COST INFORMATION
• Overhead charges for technical sub-consultants, travel, and copying/printing: 10% • Travel: Billed at cost
o Raney charges mileage at the Federal Standard Mileage Rate provided by the IRS. • Copying and Printing: Billed at cost
o Black & White (8.5” x 11”): 15¢ per page
o Color (8.5” x 11”): 30¢ per page
X. PRELIMINARY FEE SCHEDULE

ITEM NO. 8.
23 o Oversized prints (11” x 17”): 30¢ per page

ESTIMATED COST BY SERVICES
The following is a list of rough cost estimates based on the average cost of Raney’s general CEQA services.

CEQA Addendum..............................................................................................$10,000 – $20,000 Categorical Exemption Memorandum ..............................................................$7,500 – $12,000 Initial Study/Mitigated Negative Declaration (IS/MND) ...............................$15,000 – $25,000 Environmental Impact Report (EIR)...........................................................$125,000 – $200,000 Air Quality/Greenhouse Gas (AQ/GHG) Technical Analysis ............................... $4,000-8,000 AQ/GHG Health Risk Assessment (HRA)............................................................. $8,000-12,000 The cost estimates outlined above do not include costs associated with the preparation of technical reports, which are often required for comprehensive environmental analysis. Raney may contract with sub-consultants to prepare the technical reports if not provided by the applicant or Town.

Should it be necessary for Raney to contract with a sub-consultant, the sub-consultant’s cost to prepare the technical report and Raney’s 10% administrative fee would be additive to the cost estimates outlined above.

Factors that could potentially increase the scope of work and estimated costs include:
• Analysis of additional issues above those discussed in a proposal or a more detailed level of analysis than described in a proposal;
• Printing of additional copies of reports;
• Changes in the project requiring reanalysis or rewriting of report sections; • Collection of data required for the environmental documents beyond that described in a proposal;
• Tribes requesting in-person consultation pursuant to AB 52 or SB 18; • Attendance at additional virtual or in-person meetings beyond those budgeted; and • Excessive comments from the public on environmental documents.

Raney would propose to renegotiate these items, if required, or charge on a time-and-materials basis.

ITEM NO. 8.
24 EXAMPLE BUDGET SPREADSHEETS
The RFP requests a fee schedule inclusive of all potential work. Raney has included sample cost estimate spreadsheets for a robust EIR, IS/MND, and an Air Quality/Greenhouse Gas Analysis including Health Risk Assessment to give the Town a reasonable expectation of costs by task and person for these products. Please note that it may be possible to address more than one CEQA topic in an Effects Not Found to Be Significant chapter (see Task 4.3), further reducing the cost of an EIR. For each project proposal, Raney includes a cost estimate spreadsheet and a not-to-exceed budget. Other sample budget spreadsheets are available upon request.

SAMPLE EIR *

COST ESTIMATE
Project
Director
Project
Manager
Senior
Associate Associate Cost Per Task
Task 1 Project Initiation 2 4 $ 1,210
Task 2 Project Description 2 6 4 12 3,840 $
Task 3 Prepare NOP 1 4 2 8 $ 2,385
Task 4 Prepare Administrative Draft EIR 6 8 12 14 6,600 $ Technical Sections
Task 4.1 Introduction, Executive Summary, and PD 2 4 2 8 $ 2,600 Task 4.2 Environmental Setting, Impacts, Mitigation Measures a Aesthetics 2 4 5 32 6,305 $
b Agricultural and Forestry Resources 2 4 5 32 6,305 $
c Air Quality & GHG Emissions (including Energy) 2 5 4 32 6,345 $ d Biological Resources 2 4 4 36 6,690 $
e Cultural Resources 2 4 4 28 5,610 $
f Geology and Soils (including Mineral Resources) 2 4 4 30 5,880 $ g Hazards and Hazardous Materials 2 4 4 30 5,880 $
h Hydrology and Water Quality (including Drainage) 2 5 4 34 6,615 $ i Land Use and Planning 2 4 5 36 6,845 $
j Noise 2 4 4 34 6,420 $
k Population and Housing 2 4 4 28 5,610 $
l Public Services and Recreation 2 4 4 32 6,150 $
m Transportation 3 5 5 34 6,985 $
n Tribal Cultural Resources 2 4 4 32 6,150 $
o Utilities and Service Systems 2 5 4 36 6,885 $
p Wildfire 2 5 4 30 6,075 $
Other Sections
Task 4.3 Effects Not Found to Be Significant 1 2 3 8 $ 2,150 Task 4.4 Statutorily Required Sections 2 3 4 12 3,255 $ Task 4.5 Alternatives 2 5 6 32 6,655 $
Task 5 Prepare Screencheck Draft EIR 4 7 8 23 6,570 $
Task 6 Prepare Public Review Draft EIR 2 4 6 14 4,030 $ Task 7 Prepare Administrative Final EIR 4 6 8 40 8,670 $ Task 8 Prepare MMRP 2 4 8 $ 2,290
Task 9 Prepare Screencheck Final EIR 1 5 4 14 3,700 $
Task 10 Prepare Final EIR 1 2 3 10 2,420 $
Task 11 Prepare FOF/SOC and NOD 2 8 20 4,690 $
Task 12 Project Management, Meetings, and Hearings 30 60 $ 18,150 Total Hours 97 201 130 739
Hourly Rate $ 215 $ 195 $ 155 $ 135
Total EIR Labor $ 20,855 $ 39,195 $ 20,150 $ 99,765 $ 179,965 `
Sub-Consultant/Expenses $ 1,100
Copying/Printing* $ 1,000
10% administrative fee $ 100
Total Budget $ 181,065
* The scope of services assumes the document will be a full EIR. Costs associated with preparation of technical reports are not included. **Estimate only, To Be Billed at Cost

ITEM NO. 8.
25 Vice
President
Air Quality
Specialist
Air Quality
Technician
Cost Per
Task
Task 1 Project Initiation 2 $ 430
Task 2a Prepare Draft AQ/GHG Impact Analysis 2 6 30 6, $ 130 Task 2b Health Risk Assesment 4 12 38 8, $ 850
Task 3 Prepare Submittal Draft AQ/GHG Impact Analysis 1 4 $ 795 Task 4 Prepare Final Draft AQ/GHG Impact Analysis 1 3 $ 640 Task 5 Project Management 2 4 $ 1,130
Total Hours 10 24 75
Hourly Rate $ 215 $ 175 $ 155
Total Labor $ 2,150 $ 4,200 $ 11,625 $ 17,975
Expenses $ 110
Copying/Printing/Travel/Postage/Etc* $ 100
10% administrative fee $ 10
Total Budget $ 18,085
*Estimate only and will be billed at cost.

Sample AQ/GHG Technical Analysis Including Operational HRA Cost Estimate
SAMPLE IS/MND *

COST ESTIMATE
Project
Director
Project
Manager
Senior
Associate Associate Cost Per Task
Task 1 Project Initiation/Kick-Off Meeting 4 $ 780
Task 2 Prepare Administrative Draft Initial Study 2 5 7 40 7, $ 890 Task 4 Prepare Screencheck IS/MND and Public Review IS/MND 2 4 4 8 $ 2,910 Task 5 Prepare MMRP (if needed) 1 2 $ 465
Task 6 Response to Comments (if needed) 2 2 4 $ 1,240
Task 7 Project Management, Meetings, and Hearings 6 12 $ 3,630 Total Hours 10 28 13 54
Hourly Rate $ 215 $ 195 $ 155 $ 135
Total Labor $ 2,150 $ 5,460 $ 2,015 $ 7,290 $ 16,915
`
Sub-Consultant/Expenses $ 385
Copying/Printing/Travel/Postage/Etc.** $ 350
10% administrative fee $ 35
Total Budget $ 17,300
*Costs associated with preparation of technical reports, other than AQ/GHG, are not included. **Estimate only, To Be Billed at Cost

ITEM NO. 8.

APPENDIX A: RANEY RESUMES

ITEM NO. 8.

NICK PAPPANI
Vice President

EDUCATION
B.S., Wildlife Biology, cum laude
California State University, Humboldt

AFFILIATIONS
The Wildlife Society, Western Section
Urban Land Institute
Mr. Pappani has been part of Raney Planning & Management’s team since 2002. As current Vice President, Mr. Pappani is part of the management core of Raney, working directly with Senior Vice President Cindy Gnos and President Tim Raney to provide hands-on planning and CEQA services to a variety of clients.

VICE PRESIDENT
Raney Planning & Management, Inc. (2002-Present)
Mr. Pappani focuses on client interaction and business marketing, given his network of satisfied clients within the industry. Mr. Pappani also manages the preparation of CEQA documents and regularly attends meetings with lead agency staff to identify and problem-solve environmental issues so that the EIR process can be streamlined and simplified to the greatest extent feasible. In addition, Mr. Pappani works with Division Manager Rod Stinson, in the day-to-day coordination of the Raney team and its efforts. Since his arrival at Raney, Mr. Pappani has been involved in the writing and managing of numerous environmental documents and has served as the project manager for over 550 CEQA and NEPA projects. In addition to his project management experience, Mr. Pappani has provided contract planning services for various jurisdictions during his time at Raney, including serving as an extension of lead agency staff in reviewing development and use permit applications, preparing staff reports and conditions of approval, and presenting before boards, commissions, councilmembers, and the general public.

WILDLIFE TECHNICIAN
Grand Canyon National Park, Arizona (May to August 1999 and 2000) Mr. Pappani utilized his field research skills obtained at Humboldt State University to collect pertinent wildlife data for the Park Service. In addition to conducting numerous field studies for special-status species and keeping detailed records of all collected data, Mr. Pappani was appointed as crew leader in the absence of the acting crew leader, which involved appointing tasks to other staff and managing their workload.

FIELD TECHNICIAN
LBJ Enterprises, Eureka, California (May to August 1998) Mr. Pappani conducted research for an environmental consulting firm located in Eureka, California. Mr.

Pappani’s primary duties included conducting detailed plant and animal surveys throughout Six Rivers National Forest. The animal surveys focused on detecting the presence/absence of the Federally Threatened Marbled Murrelet within Six Rivers National Forest.

ITEM NO. 8.

ANGELA DAROSA
Division Manager/Air Quality Specialist

EDUCATION
B.S., Environmental Engineering
California Polytechnic State University, San Luis Obispo Ms. DaRosa graduated from California Polytechnic State University, San Luis Obispo, with a Bachelor of Science degree in Environmental Engineering. Ms. DaRosa’s background in engineering and technical writing allows her to analyze complex technical studies and integrate them into each project. As Division Manager with Raney, Ms. DaRosa provides project management and assists in the preparation and processing of various environmental and planning documents. As an Air Quality Specialist, Ms. DaRosa works closely with Raney’s in-house Air Quality Technician to conduct detailed air quality analyses.

DIVISION MANAGER/AIR QUALITY SPECIALIST
Raney Planning & Management, Inc. (2010-Present)
Since joining Raney, Ms. DaRosa has been involved in the writing of numerous EIRs, including the Johnson Rancho and Hop Farm Annexation EIR in Wheatland, CA; the Newman Ridge EIR in Amador County, CA; the Brentwood Boulevard Specific Plan Recirculated EIR in Brentwood, CA; and the Terra Ranch Subdivision EIR in Manteca, CA. Ms. DaRosa has also written numerous Initial Studies for cities including, but not limited to, Wheatland, Woodland, Sacramento, Pinole, Brentwood, Kings County, and Lathrop. In addition to CEQA documentation experience, Ms. DaRosa has also been involved in the preparation of NEPA compliance documents including Environmental Assessments for projects such as Kingsburg Senior Village in Kinsburg, CA; Heritage Commons in Dixon, CA; Las Palmeras Apartments in Imperial, CA; and North Biggs Estates in Biggs, CA. Ms. DaRosa has also provided environmental and land use planning services for various jurisdictions, most prominently the City of Wheatland, including preliminary coordination and preparation of city planning documents such as the City of Wheatland Bikeway Master Plan, and use of GIS and other mapping tools for the analysis and presentation of data.

Ms. DaRosa contributes her environmental engineering background by working closely with Raney’s inhouse Air Quality Technician to prepare air quality and greenhouse gas analyses for Initial Studies and EIRs, as well as stand-alone air quality and greenhouse gas impact assessments for various private-sector clients. Ms. DaRosa has prepared air quality and greenhouse gas analyses for projects located within the jurisdictional boundaries of a variety of air districts throughout the State. Ms. DaRosa is proficient in the use of current air quality models, including CalEEMod, AERSCREEN, AERMOD, and HARP RAST.

PROJECT ENGINEER
RMC Water and Environment (2008-2009)
Ms. DaRosa worked at RMC Water and Environment as a key member of the design team on various projects. Ms. DaRosa was able to contribute her specialized knowledge of wastewater treatment by acting as an affiliate of the company’s internal Wastewater Treatment Technical Committee. While at RMC, Ms.

DaRosa was able to expand her AutoCAD skills by preparing basic infrastructure and design drawings, and was trained in GIS to prepare supportive plans and diagrams. During her time at RMC, Ms. DaRosa honed her technical writing skills through the preparation of a variety of design technical memoranda and reports, design specifications, environmental permits, and EIR sections.

ITEM NO. 8.

TIM RANEY, AICP
President

EDUCATION
Graduate Studies, Agricultural Economics
University of California, Davis
B.S., Agricultural and Managerial Economics
University of California, Davis

AFFILIATIONS
American Institute of Certified Planners (AICP)
American Planning Association (APA)
Sacramento Metro Chamber
Mr. Raney has over 30 years of local government, planning, and CEQA/NEPA experience, during which he has actively managed many of the region’s most controversial projects.

PRESIDENT
Raney Planning & Management, Inc. (1999-Present)
As President of Raney, Mr. Raney provides a wide range of planning, management, and economic development services to public and private sector clients. Mr. Raney specializes in project coordination and management, CEQA processing and documentation, land use analysis, business district information, and public facilitation. With over twenty-five years of planning experience, he has developed a diverse and expanding network of clients, including developers, agency representatives, and state and local decisionmakers. His diverse background enables him to advise his clients on effective strategies regarding government permitting processing, public involvement, and agency coordination. Mr. Raney provides quality client services, ensuring legally and procedurally accurate documentation while strictly adhering to all schedules and budgets.

COMMUNITY DEVELOPMENT DIRECTOR
City of Wheatland (2004-Present)
As the Community Development Director for the City of Wheatland, Mr. Raney provides professional guidance and technical assistance to the City Manager, City Council, Planning Commission, and the public regarding immediate and long-range planning while working extensively with the development community, local business owners, and community residents. Mr. Raney monitors City growth and oversees implementation of the City’s General Plan, processing of development applications, and makes recommendation to City Council regarding applications and development projects. Over the past 18 years, Mr. Raney has been instrumental in developing the City’s Infrastructure Work Program, Community Vision, and Capital Improvement Program as well as developing and implementing the City’s General Plan.

COUNCILMEMBER/MAYOR
City of Citrus Heights, CA (1997-2002)
Elected to serve on the first City Council, Mr. Raney was instrumental in creating the initial government structure of the City of Citrus Heights. While on City Council, Mr. Raney participated in the preparation and adoption of the City’s first General Plan as well as developing a city staff to be responsible for its implementation. Mr. Raney served as Mayor of Citrus Heights in 2000 winning numerous awards for his exceptional leadership skills. This experience behind the dais has given Mr. Raney the ability to understand projects from a variety of perspectives, thereby allowing him to provide a unique skill set to Raney’s clients.

ITEM NO. 8.

ROD STINSON
Vice President/Air Quality Specialist

EDUCATION
B.S., Forestry and Natural Resources
California Polytechnic State University, San Luis Obispo

CERTIFICATIONS
Certified in River Restoration and Natural Channel Design

AFFILIATIONS
Sacramento Metro EDGE
Urban Land Institute
Mr. Stinson brings to Raney Planning & Management, Inc. his technical writing and project management skills to every project. As Vice President with Raney, Mr. Stinson assists Senior Vice President Cindy Gnos and President Tim Raney in the day-to-day management of the office, which includes overseeing the processing of various environmental and planning projects, management of office staff, and coordination with agency personnel and project applicants. In addition, Mr. Stinson serves as Raney’s in-house Air Quality Specialist.

VICE PRESIDENT/AIR QUALITY SPECIALIST
Raney Planning & Management, Inc. (2005-Present)
As Vice President, Mr. Stinson is responsible for assisting Senior Vice President Cindy Gnos and company President Tim Raney in the day-to-day coordination of the Raney team and its efforts. Since arriving at Raney, Mr. Stinson has been involved in the writing and managing of numerous environmental and planning projects and has served as the project manager for over 350 CEQA and NEPA projects. In addition, Mr. Stinson has managed numerous special planning projects as well as provided environmental and land use planning services for various jurisdictions during his time at Raney, including extensive use of GIS in the analysis and presentation of data.

Mr. Stinson also serves as Raney’s in-house Air Quality Specialist, preparing air quality and greenhouse gas analyses for Initial Studies and Environmental Impact Reports as well as air quality and greenhouse gas studies and health risk assessments for various private-sector clients. Mr. Stinson trained under Donald Ballanti, Certified Consulting Meteorologist for several years and has prepared over thirty air quality analyses for various public and private sector projects. Through his work with various air districts in the region, Mr. Stinson has become a leading expert in preparing air quality and greenhouse gas analyses.

ESTIMATOR/ENVIRONMENTAL SPECIALIST
Thunder Mountain Enterprises, Inc. (2003-2005)
Mr. Stinson began at Thunder Mountain Enterprises, Inc. preparing Stormwater Pollution Prevention Plans utilizing erosion and sediment control Best Management Practices. In this position Mr. Stinson was trained in AutoCAD and expanded his knowledge of hydrology and fluvial processes. After four months with the company Mr. Stinson was promoted to department head of the Estimating Department where he developed and managed procedures for the department. Mr. Stinson was tasked to develop new markets for the company while maintaining their existing workflow market. In addition, Mr. Stinson set the budgets for the 2004 and 2005 fiscal years as well as secured over $600,000 of revenue in the first year of existence. As Estimator, Mr. Stinson performed sales, estimating, project management, and contract administration.

PROFESSIONAL DEVELOPMENT
Mr. Stinson is also actively involved in the Sacramento Metro Chamber as a graduate of the Leadership Class of 2012. As a part of the 2012 class project, Mr. Stinson participated in fundraising and outreach activities for the design and construction of the new Soil Born Farms outdoor classroom.

ITEM NO. 8.

APPENDIX B: CERTIFICATE OF INSURANCE

ITEM NO. 8.

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.

INSURER(S) AFFORDING COVERAGE
INSURER F :

INSURER E :

INSURER D :

INSURER C :

INSURER B :

INSURER A :

NAIC #
NAME:

CONTACT
(A/C, No):

FAX
E-MAIL
ADDRESS:

PRODUCER
(A/C, No, Ext):

PHONE

INSURED
COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

OTHER:
(Per accident)
(Ea accident)
$
$
N / A
SUBR
WVD
ADDL
INSD

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS

CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. $
$
$
$ PROPERTY DAMAGE
BODILY INJURY (Per accident)
BODILY INJURY (Per person)

COMBINED SINGLE LIMIT
AUTOS

AUTOS AUTOS

NON-OWNED HIRED AUTOS

ALL OWNED SCHEDULED

ANY AUTO

AUTOMOBILE LIABILITY
Y / N

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY
OFFICER/MEMBER EXCLUDED?
(Mandatory in NH)
DESCRIPTION OF OPERATIONS below
If yes, describe under

ANY PROPRIETOR/PARTNER/EXECUTIVE
$
$
$
E.L. DISEASE - POLICY LIMIT
E.L. DISEASE - EA EMPLOYEE
E.L. EACH ACCIDENT
ER

OTH- STATUTEPER
(MM/DD/YYYY) LIMITS POLICY EXP (MM/DD/YYYY)

POLICY EFF LTR TYPE OF INSURANCE POLICY NUMBER INSR
DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

EXCESS LIAB
UMBRELLA LIAB EACH OCCURRENCE $
AGGREGATE $
$
OCCUR

CLAIMS-MADE
DED RETENTION $
PRODUCTS - COMP/OP AGG $
GENERAL AGGREGATE $
PERSONAL & ADV INJURY $
MED EXP (Any one person) $
EACH OCCURRENCE $

DAMAGE TO RENTED
PREMISES (Ea occurrence) $

COMMERCIAL GENERAL LIABILITY

CLAIMS-MADE OCCUR
GEN'L AGGREGATE LIMIT APPLIES PER:

POLICY PROJECT LOC

CERTIFICATE OF LIABILITY INSURANCE DATE (MM/DD/YYYY)

CANCELLATION

AUTHORIZED REPRESENTATIVE
ACORD 25 (2014/01)
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CERTIFICATE HOLDER
The ACORD name and logo are registered marks of ACORD
12/27/2024 Pacific Unity Insurance Solutions, Inc. 2241 Douglas Blvd. #250 Roseville CA 95661 Bridgette Francis 916-846-9555 916-846-9558 [email protected] Raney Planning and Management, Inc. 1501 SPORTS DR Unit A SACRAMENTO CA 958342035 Hartford Underwriters Ins Co 30104 Hartford Accident & Ind Co 22357 Employers Preferred Ins Co 10346 Gemini Ins Co 10833 ACE American Insurance Company 22667 A ✖
✖
✖
Y Y 57SBABG7ML7 12/22/2024 12/22/2025 2000000 1000000 10000 2000000 4000000 4000000 Data Breach Defense And Liability250,000 B ✖
Data Breach Defense And Liability Y Y 57UECBA9824 12/22/2024 12/22/2025 1,000,000 A ✖
✖ 10,000 Y Y 57SBABG7ML7 12/22/2024 12/22/2025 2,000,000 2,000,000 C Y Y EIG514956202 12/22/2024 12/22/2025 ✖ 1,000,000 1,000,000 1,000,000 D Professional Liability VNPL017718 12/22/2024 12/22/2025 Each Claim/Agg $2M/$2M Evidence of Insurance
Evidence of Insurance 1501 Sports Dr Ste A Sacramento CA 95834 E Cyber Incident Response Fund D98378005 12/22/2024 12/22/2025 Ded. $5,000 Each Cyber Inc/Agg $2M/$2M

ITEM NO. 8.

Form SL 00 00 10 18 Page 1 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission)

BUSINESS LIABILITY COVERAGE FORM
Various provisions in this Policy restrict coverage. Read the entire Policy carefully to determine rights, duties and what is and is not covered.

Throughout this Coverage Part the words "you" and "your" refer to the Named Insured shown in the Declarations. The words "we", "us" and "our" refer to the insurance company shown in the Declarations. "Policy period", as used in this Coverage Part, means the period from the effective date of this Coverage Part to the expiration date of the Coverage Part as stated in the Declarations or the date of cancellation, whichever is earlier.

The word "insured" means any person or organization qualifying as such under Section C. Who Is An Insured.

Other words and phrases that appear in quotation marks have special meaning. Refer to Section F. Liability And Medical Expenses Definitions.

A. COVERAGES

1. Business Liability Coverage (Bodily Injury, Property Damage, Personal And Advertising Injury) Insuring Agreement
a. We will pay those sums that the insured becomes legally obligated to pay as damages because of "bodily injury", "property damage" or "personal and advertising injury" to which this insurance applies. We will have the right and duty to defend the insured against any "suit" seeking those damages. However, we will have no duty to defend the insured against any "suit" seeking damages for "bodily injury", "property damage" or "personal and advertising injury" to which this insurance does not apply.

We may, at our discretion, investigate any "occurrence" or offense and settle any claim or "suit" that may result. But:
(1) The amount we will pay for damages is limited as described in Section D. Liability And Medical Expenses Limits Of Insurance; and
(2) Our right and duty to defend ends when we have used up the applicable limit of insurance in the payment of judgments, settlements or medical expenses to which this insurance applies.

No other obligation or liability to pay sums or perform acts or services is covered unless explicitly provided for under Coverage Extension - Supplementary Payments.
b. This insurance applies:
(1) To "bodily injury" and "property damage" only if:
(a) The “bodily injury” or “property damage” is caused by an “occurrence” that takes place in the “coverage territory”;
(b) The "bodily injury" or "property damage" occurs during the policy period; and (c) Prior to the policy period, no insured listed under Paragraph 1. of Section C. Who Is An Insured and no "employee" authorized by you to give or receive notice of an "occurrence" or claim, knew that the "bodily injury" or "property damage" had occurred, in whole or in part. If such a listed insured or authorized "employee" knew, prior to the policy period, that the "bodily injury" or "property damage" occurred, then any continuation, change or resumption of such "bodily injury" or "property damage" during or after the policy period will be deemed to have been known prior to the policy period. (2) To "personal and advertising injury" caused by an offense arising out of your business, but only if the offense was committed in the "coverage territory" during the policy period. c. "Bodily injury" or "property damage" will be deemed to have been known to have occurred at the earliest time when any insured listed under Paragraph 1. of Section C. Who Is An Insured or any "employee" authorized by you to give or receive notice of an "occurrence" or claim:
(1) Reports all, or any part, of the "bodily injury" or "property damage" to us or any other insurer; (2) Receives a written or verbal demand or claim for damages because of the "bodily injury" or "property damage"; or
57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 2 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) (3) Becomes aware by any other means that "bodily injury" or "property damage" has occurred or has begun to occur.
d. Damages because of "bodily injury" include damages claimed by any person or organization for care, loss of services or death resulting at any time from the "bodily injury". e. Incidental Medical Malpractice
(1) "Bodily injury" arising out of the rendering of or failure to render professional health care services as a physician, dentist, nurse, emergency medical technician or paramedic shall be deemed to be caused by an "occurrence", but only if:
(a) The physician, dentist, nurse, emergency medical technician or paramedic is employed by you to provide such services; and
(b) You are not engaged in the business or occupation of providing such services. (2) For the purpose of determining the limits of insurance for incidental medical malpractice, any act or omission together with all related acts or omissions in the furnishing of these services to any one person will be considered one "occurrence".

2. Medical Expenses
Insuring Agreement
a. We will pay medical expenses as described below for "bodily injury" caused by an accident:
(1) On premises you own or rent;
(2) On ways next to premises you own or rent; or
(3) Because of your operations;
provided that:
(1) The accident takes place in the "coverage territory" and during the policy period; (2) The expenses are incurred and reported to us within three years of the date of the accident; and (3) The injured person submits to examination, at our expense, by physicians of our choice as often as we reasonably require.
b. We will make these payments regardless of fault. These payments will not exceed the applicable limit of insurance. We will pay reasonable expenses for:
(1) First aid administered at the time of an accident;
(2) Necessary medical, surgical, x-ray and dental services, including prosthetic devices; and (3) Necessary ambulance, hospital, professional nursing and funeral services.

3. Coverage Extension - Supplementary Payments
a. We will pay, with respect to any claim we investigate or settle, or any "suit" against an insured we defend:
(1) All expenses we incur.
(2) Up to $1,000 for the cost of bail bonds required because of accidents or traffic law violations arising out of the use of any vehicle to which Business Liability Coverage for "bodily injury" applies. We do not have to furnish these bonds.
(3) The cost of appeal bonds or bonds to release attachments, but only for bond amounts within the applicable limit of insurance. We do not have to furnish, finance, arrange for, guarantee, or collateralize these bonds, whether the collateralization is characterized as premium or not. (4) All reasonable expenses incurred by the insured at our request to assist us in the investigation or defense of the claim or "suit", including actual loss of earnings up to $500 a day because of time off from work. (5) All court costs taxed against the insured in the "suit". However, such costs do not include attorneys’ fees, attorneys’ expenses, witness or expert fees, or any other expenses of a party taxed against the insured. (6) Prejudgment interest awarded against the insured on that part of the judgment we pay. If we make an offer to pay the applicable limit of insurance, we will not pay any prejudgment interest based on that period of time after the offer.
57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 3 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) (7) All interest on the full amount of any judgment that accrues after entry of the judgment and before we have paid, offered to pay, or deposited in court the part of the judgment that is within the applicable limit of insurance.

Any amounts paid under (1) through (7) above will not reduce the Limits of Insurance. b. If we defend an insured against a "suit" and an indemnitee of the insured is also named as a party to the "suit", we will defend that indemnitee if all of the following conditions are met:
(1) The "suit" against the indemnitee seeks damages for which the insured has assumed the liability of the indemnitee in a contract or agreement that is an "insured contract"; (2) This insurance applies to such liability assumed by the insured; (3) The obligation to defend, or the cost of the defense of, that indemnitee, has also been assumed by the insured in the same "insured contract";
(4) The allegations in the "suit" and the information we know about the "occurrence" are such that no conflict appears to exist between the interests of the insured and the interest of the indemnitee; (5) The indemnitee and the insured ask us to conduct and control the defense of that indemnitee against such "suit" and agree that we can assign the same counsel to defend the insured and the indemnitee; and (6) The indemnitee:
(a) Agrees in writing to:
(i) Cooperate with us in the investigation, settlement or defense of the "suit"; (ii) Immediately send us copies of any demands, notices, summonses or legal papers received in connection with the "suit";
(iii) Notify any other insurer whose coverage is available to the indemnitee; and (iv) Cooperate with us with respect to coordinating other applicable insurance available to the indemnitee; and
(b) Provides us with written authorization to:
(i) Obtain records and other information related to the "suit"; and (ii) Conduct and control the defense of the indemnitee in such "suit".

So long as the above conditions are met, attorneys' fees incurred by us in the defense of that indemnitee, necessary litigation expenses incurred by us and necessary litigation expenses incurred by the indemnitee at our request will be paid as Supplementary Payments.

Notwithstanding the provisions of Paragraph 1.b.(b) of Section B. Exclusions, such payments will not be deemed to be damages for "bodily injury" and "property damage" and will not reduce the Limits of Insurance.

Our obligation to defend an insured's indemnitee and to pay for attorneys' fees and necessary litigation expenses as Supplementary Payments ends when:
(1) We have used up the applicable limit of insurance in the payment of judgments or settlements; or (2) The conditions set forth above, or the terms of the agreement described in Paragraph (6) above, are no longer met.

B. EXCLUSIONS

1. Applicable To Business Liability Coverage
This insurance does not apply to:
a. Expected Or Intended Injury
(1) "Bodily injury" or "property damage" expected or intended from the standpoint of the insured. This exclusion does not apply to "bodily injury" or "property damage" resulting from the use of reasonable force to protect persons or property; or
(2) "Personal and advertising injury" arising out of an offense committed by, at the direction of or with the consent or acquiescence of the insured with the expectation of inflicting "personal and advertising injury". 57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 4 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) b. Contractual Liability
(1) "Bodily injury" or "property damage"; or
(2) "Personal and advertising injury"
for which the insured is obligated to pay damages by reason of the assumption of liability in a contract or agreement.

This exclusion does not apply to liability for damages because of:
(a) "Bodily injury", "property damage" or "personal and advertising injury" that the insured would have in the absence of the contract or agreement; or
(b) "Bodily injury" or "property damage" assumed in a contract or agreement that is an "insured contract", provided the "bodily injury" or "property damage" occurs subsequent to the execution of the contract or agreement. Solely for the purpose of liability assumed in an "insured contract", reasonable attorneys' fees and necessary litigation expenses incurred by or for a party other than an insured are deemed to be damages because of "bodily injury" or "property damage" provided:
(i) Liability to such party for, or for the cost of, that party’s defense has also been assumed in the same "insured contract"; and
(ii) Such attorneys' fees and litigation expenses are for defense of that party against a civil or alternative dispute resolution proceeding in which damages to which this insurance applies are alleged.
c. Liquor Liability
"Bodily injury" or "property damage" for which any insured may be held liable by reason of:
(1) Causing or contributing to the intoxication of any person; (2) The furnishing of alcoholic beverages to a person under the legal drinking age or under the influence of alcohol;
(3) Providing or failing to provide transportation with respect to any person that may be under the influence of alcohol; or
(4) Any statute, ordinance or regulation relating to the sale, gift, distribution or use of alcoholic beverages.

This exclusion applies even if the claims allege negligence or other wrongdoing in the supervision, hiring, employment, training or monitoring of others by an insured, if the “bodily injury” or “property damage” involved that which is described in Paragraph (1), (2), (3) or (4) above.

However, this exclusion applies only if you are in the business of manufacturing, distributing, selling, serving or furnishing alcoholic beverages. For the purposes of this exclusion, permitting a person to bring alcoholic beverages on your premises, for consumption on your premises, whether or not a fee is charged or a license is required for such activity, is not by itself considered the business of selling, serving, or furnishing alcoholic beverages.
d. Workers' Compensation And Similar Laws
Any obligation of the insured under a workers' compensation, disability benefits or unemployment compensation law or any similar law.
e. Employer’s Liability
"Bodily injury" to:
(1) An "employee" of the insured arising out of and in the course of:
(a) Employment by the insured; or
(b) Performing duties related to the conduct of the insured’s business; or (2) The spouse, child, parent, brother or sister of that "employee" as a consequence of (1) above.

This exclusion applies:
(1) Whether the insured may be liable as an employer or in any other capacity; and (2) To any obligation to share damages with or repay someone else who must pay damages because of the injury.
57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 5 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) This exclusion does not apply to liability assumed by the insured under an "insured contract". f. Pollution
(1) "Bodily injury", "property damage" or "personal and advertising injury" arising out of the actual, alleged or threatened discharge, dispersal, seepage, migration, release or escape of "pollutants":
(a) At or from any premises, site or location which is or was at any time owned or occupied by, or rented or loaned to any insured. However, this paragraph does not apply to:
(i) "Bodily injury" if sustained within a building and caused by smoke, fumes, vapor or soot produced by or originating from equipment that is used to heat, cool or dehumidify the building, or equipment that is used to heat water for personal use, by the building's occupants or their guests; (ii) "Bodily injury" or "property damage" for which you may be held liable, if you are a contractor and the owner or lessee of such premises, site or location has been added to this Coverage Part as an additional insured with respect to your ongoing operations performed for that additional insured at that premises, site or location and such premises, site or location is not and never was owned or occupied by, or rented or loaned to, any insured, other than that additional insured; or (iii) "Bodily injury" or "property damage" arising out of heat, smoke or fumes from a "hostile fire"; (b) At or from any premises, site or location which is or was at any time used by or for any insured or others for the handling, storage, disposal, processing or treatment of waste; (c) Which are or were at any time transported, handled, stored, treated, disposed of, or processed as waste by or for:
(i) Any insured; or
(ii) Any person or organization for whom you may be legally responsible; (d) At or from any premises, site or location on which any insured or any contractors or subcontractors working directly or indirectly on any insured's behalf are performing operations if the "pollutants" are brought on or to the premises, site or location in connection with such operations by such insured, contractor or subcontractor. However, this paragraph does not apply to:
(i) "Bodily injury" or "property damage" arising out of the escape of fuels, lubricants or other operating fluids which are needed to perform the normal electrical, hydraulic or mechanical functions necessary for the operation of "mobile equipment" or its parts, if such fuels, lubricants or other operating fluids escape from a vehicle part designed to hold, store or receive them. This exception does not apply if the "bodily injury" or "property damage" arises out of the intentional discharge, dispersal or release of the fuels, lubricants or other operating fluids, or if such fuels, lubricants or other operating fluids are brought on or to the premises, site or location with the intent that they be discharged, dispersed or released as part of the operations being performed by such insured, contractor or subcontractor;
(ii) "Bodily injury" or "property damage" sustained within a building and caused by the release of gases, fumes or vapors from materials brought into that building in connection with operations being performed by you or on your behalf by a contractor or subcontractor; or (iii) "Bodily injury" or "property damage" arising out of heat, smoke or fumes from a "hostile fire"; or (e) At or from any premises, site or location on which any insured or any contractors or subcontractors working directly or indirectly on any insured’s behalf are performing operations if the operations are to test for, monitor, clean up, remove, contain, treat, detoxify or neutralize, or in any way respond to, or assess the effects of, "pollutants".
(2) Any loss, cost or expense arising out of any:
(a) Request, demand, order or statutory or regulatory requirement that any insured or others test for, monitor, clean up, remove, contain, treat, detoxify or neutralize, or in any way respond to, or assess the effects of, "pollutants"; or
(b) Claim or “suit” by or on behalf of a governmental authority for damages because of testing for, monitoring, cleaning up, removing, containing, treating, detoxifying or neutralizing, or in any way responding to, or assessing the effects of, "pollutants". 57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 6 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) However, this paragraph does not apply to liability for damages because of "property damage" that the insured would have in the absence of such request, demand, order or statutory or regulatory requirement, or such claim or "suit" by or on behalf of a governmental authority. g. Aircraft, Auto Or Watercraft
(1) Unmanned Aircraft
"Bodily injury" or "property damage" arising out of the ownership, maintenance, use or entrustment to others of any aircraft that is an "unmanned aircraft". Use includes operation and "loading or unloading".

This Exclusion g.(1) applies even if the claims against any insured allege negligence or other wrongdoing in the supervision, hiring, employment, training or monitoring of others by that insured, if the "bodily injury” or “property damage” arises out of the ownership, maintenance, use or entrustment to others of any aircraft that is an "unmanned aircraft".
(2) Aircraft (Other Than Unmanned Aircraft), Auto or Watercraft "Bodily injury" or "property damage" arising out of the ownership, maintenance, use or entrustment to others of any aircraft (other than “unmanned aircraft”), "auto" or watercraft owned or operated by or rented or loaned to any insured. Use includes operation and "loading or unloading".

This Exclusion g.(2) applies even if the claims against any insured allege negligence or other wrongdoing in the supervision, hiring, employment, training or monitoring of others by that insured, if the "bodily injury" or "property damage" arises out of the ownership, maintenance, use or entrustment to others of any aircraft (other than “unmanned aircraft”), "auto" or watercraft that is owned or operated by or rented or loaned to any insured.

This Exclusion g.(2) does not apply to:
(a) A watercraft while ashore on premises you own or rent; (b) A watercraft you do not own that is:
(i) Less than 51 feet long; and
(ii) Not being used to carry persons or property for a charge; (c) Parking an "auto" on, or on the ways next to, premises you own or rent, provided the "auto" is not owned by or rented or loaned to you or the insured;
(d) Liability assumed under any "insured contract" for the ownership, maintenance or use of aircraft (other than “unmanned aircraft”) or watercraft;
(e) "Bodily injury" or "property damage" arising out of:
(i) The operation of any of the machinery or equipment listed in Paragraph f.(2) or f.(3) of the definition of "mobile equipment"; or
(ii) The operation of machinery or equipment that is attached to, or part of, a land vehicle that would qualify under the definition of “mobile equipment” if it were not subject to a compulsory or financial responsibility law or other motor vehicle insurance or motor vehicle registration law where it is licensed or principally garaged; or
(f) An aircraft (other than “unmanned aircraft”) that is not owned by any insured and is hired, chartered or loaned with a paid crew. However, this exception does not apply if the insured has any other insurance for such "bodily injury" or "property damage", whether the other insurance is primary, excess, contingent or on any other basis.
h. Mobile Equipment
"Bodily injury" or "property damage" arising out of:
(1) The transportation of "mobile equipment" by an "auto" owned or operated by or rented or loaned to any insured; or
(2) The use of “mobile equipment” in, or while in practice or preparation for, a prearranged racing, speed or demolition contest or in any stunting activity.
57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 7 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) i. War
"Bodily injury", "property damage" or "personal and advertising injury", however caused, arising, directly or indirectly, out of:
(1) War, including undeclared or civil war;
(2) Warlike action by a military force, including action in hindering or defending against an actual or expected attack, by any government, sovereign or other authority using military personnel or other agents; or (3) Insurrection, rebellion, revolution, usurped power, or action taken by governmental authority in hindering or defending against any of these.
j. Professional Services
"Bodily injury", "property damage" or "personal and advertising injury" arising out of the rendering of or failure to render any professional service. This includes but is not limited to:
(1) Legal, accounting or advertising services;
(2) Preparing, approving, or failing to prepare or approve maps, shop drawings, opinions, reports, surveys, field orders, change orders, designs or drawings and specifications; (3) Supervisory, inspection, architectural or engineering activities; (4) Medical, surgical, dental, x-ray or nursing services, treatment, advice or instruction; (5) Any health or therapeutic service treatment, advice or instruction; (6) Any service, treatment, advice or instruction for the purpose of appearance or skin enhancement, hair removal or replacement or personal grooming;
(7) Optical or hearing aid services including the prescribing, preparation, fitting, demonstration or distribution of ophthalmic lenses and similar products or hearing aid devices; (8) Optometry or optometric services including but not limited to examination of the eyes and the prescribing, preparation, fitting, demonstration or distribution of ophthalmic lenses and similar products; (9) Any:
(a) Body piercing (not including ear piercing);
(b) Tattooing, including but not limited to the insertion of pigments into or under the skin; and (c) Similar services;
(10)Pharmaceutical services including but not limited to:
(a) The administering, prescribing, preparing, distributing or compounding of pharmaceutical drugs, vaccinations, immunizations or any of their component parts; (b) The providing of or failure to provide home health care or home infusion products or services; and (c) Advising and consulting customers;
(11)Computer consulting, design or programming services, including web site design.

This exclusion applies even if the claims allege negligence or other wrongdoing in the supervision, hiring, employment, training or monitoring of others by an insured, if the “bodily injury”, “property damage”, or “personal and advertising injury” arises out of the rendering of or the failure to render any professional service.

Paragraphs (4) and (5) of this exclusion do not apply to the Incidental Medical Malpractice coverage afforded under Paragraph 1.e. in Section A. Coverages.
k. Damage To Property
"Property damage" to:
(1) Property you own, rent or occupy, including any costs or expenses incurred by you, or any other person, organization or entity, for repair, replacement, enhancement, restoration or maintenance of such property for any reason, including prevention of injury to a person or damage to another's property; (2) Premises you sell, give away or abandon, if the "property damage" arises out of any part of those premises;
57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 8 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) (3) Property loaned to you;
(4) Personal property in the care, custody or control of the insured; (5) That particular part of real property on which you or any contractors or subcontractors working directly or indirectly on your behalf are performing operations, if the "property damage" arises out of those operations; or
(6) That particular part of any property that must be restored, repaired or replaced because "your work" was incorrectly performed on it.

Paragraphs (1), (3) and (4) of this exclusion do not apply to "property damage" (other than damage by fire) to premises, including the contents of such premises, rented to you for a period of 7 or fewer consecutive days. A separate limit of insurance applies to Damage To Premises Rented To You as described in Section D. Limits Of Insurance.

Paragraph (2) of this exclusion does not apply if the premises are "your work" and were never occupied, rented or held for rental by you.

Paragraphs (3) and (4) of this exclusion do not apply to the use of elevators.

Paragraphs (3), (4), (5) and (6) of this exclusion do not apply to liability assumed under a sidetrack agreement.

Paragraphs (3) and (4) of this exclusion do not apply to "property damage" to borrowed equipment while not being used to perform operations at a job site.

Paragraph (6) of this exclusion does not apply to "property damage" included in the "products-completed operations hazard".
l. Damage To Your Product
"Property damage" to "your product" arising out of it or any part of it. m. Damage To Your Work
"Property damage" to "your work" arising out of it or any part of it and included in the "products-completed operations hazard".

This exclusion does not apply if the damaged work or the work out of which the damage arises was performed on your behalf by a subcontractor.
n. Damage To Impaired Property Or Property Not Physically Injured "Property damage" to "impaired property" or property that has not been physically injured, arising out of:
(1) A defect, deficiency, inadequacy or dangerous condition in "your product" or "your work"; or (2) A delay or failure by you or anyone acting on your behalf to perform a contract or agreement in accordance with its terms.

This exclusion does not apply to the loss of use of other property arising out of sudden and accidental physical injury to "your product" or "your work" after it has been put to its intended use. o. Recall Of Products, Work Or Impaired Property
Damages claimed for any loss, cost or expense incurred by you or others for the loss of use, withdrawal, recall, inspection, repair, replacement, adjustment, removal or disposal of:
(1) "Your product";
(2) "Your work"; or
(3) "Impaired property";
if such product, work or property is withdrawn or recalled from the market or from use by any person or organization because of a known or suspected defect, deficiency, inadequacy or dangerous condition in it. p. Personal And Advertising Injury
"Personal and advertising injury":
(1) Arising out of oral, written, electronic, or any other manner of publication of material, if done by or at the direction of the insured with knowledge of its falsity; 57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 9 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) (2) Arising out of oral, written, electronic, or any other manner of publication of material whose first publication took place before the beginning of the policy period; (3) Arising out of a criminal act committed by or at the direction of the insured; (4) Arising out of any breach of contract, except an implied contract to use another’s "advertising idea" in your "advertisement";
(5) Arising out of the failure of goods, products or services to conform with any statement of quality or performance made in your "advertisement";
(6) Arising out of the wrong description of the price of goods, products or services; (7) Arising out of:
(a) Any actual or alleged infringement or violation of any intellectual property rights, such as copyright, patent, right of publicity, trademark, trade dress, trade name, trade secret, service mark or other designation of origin or authenticity; or
(b) Any injury or damage alleged in any claim or “suit” that also alleges an infringement or violation of any intellectual property right, whether such allegation of infringement or violation is made against you, or by you or by any other party involved in the claim or “suit”, regardless of whether this insurance would otherwise apply.

However, this exclusion does not apply if the only allegation in the claim or “suit” involving any intellectual property right is limited to:
(i) Infringement, in your “advertisement”, of:
a. Copyright;
b. Slogan; unless the slogan is also a trademark, trade dress, trade name, service mark or other designation of origin or authenticity; or
c. Title of any literary or artistic work; or
(ii) Copying, in your “advertisement”, a person’s or organization’s “advertising idea” or style of “advertisement”.

Paragraph (7)(b)ii above shall not apply to claims or “suits” alleging infringement or violation of trademark, trade dress, trade name, service mark or other designation of origin or authenticity. (8) Arising out of an offense committed by an insured whose business is:
(a) Advertising, broadcasting, publishing or telecasting; (b) Designing or determining content of web sites for others; or (c) An Internet search, access, content or service provider.

However, this exclusion does not apply to Paragraphs a., b. and c. under the definition of "personal and advertising injury" in Section F. Liability And Medical Expenses Definitions.

For the purposes of this exclusion, the placing of frames, borders, or links, or advertising, for you or others anywhere on the Internet, is not by itself, considered the business of advertising, broadcasting, publishing or telecasting;
(9) Arising out of an electronic chat room or bulletin board the insured hosts, owns, or over which the insured exercises control;
(10)Arising out of the unauthorized use of another's name or product in your e-mail address, domain name or metatags, or any other similar tactics to mislead another's potential customers; (11)Arising out of the violation of a person's right of privacy created by any state or federal act.

However, this exclusion does not apply to liability for damages that the insured would have in the absence of such state or federal act;
(12)Arising out of:
(a) Advertising content for others on your web site;
(b) Placing a link to a web site of others on your web site; 57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 10 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) (c) Content from a web site of others displayed within a frame or border on your web site. Content includes information, code, sounds, text, graphics or images; or (d) Computer code, software or programming used to enable:
(i) Your web site; or
(ii) The presentation or functionality of an "advertisement" or other content on your web site; (13)Arising out of a violation of any anti-trust law;
(14)Arising out of the fluctuation in price or value of any stocks, bonds or other securities; (15)Arising out of any access to or disclosure of any person's or organization's confidential or personal information, including patents, trade secrets, processing methods, customer lists, financial information, credit card information, health information or any other type of nonpublic information.

This exclusion applies even if damages are claimed for notification costs, credit monitoring expenses, forensic expenses, public relations expenses or any other loss, cost or expense incurred by you or others arising out of any access to or disclosure of any person's or organization's confidential or personal information; or
(16)Arising out of the ownership, maintenance, use or entrustment to others of any aircraft that is an "unmanned aircraft". Use includes operation and "loading or unloading".

This exclusion applies even if the claims against any insured allege negligence or other wrongdoing in the supervision, hiring, employment, training or monitoring of others by that insured, if the "personal and advertising injury" arises out of the ownership, maintenance, use or entrustment to others of any aircraft that is an "unmanned aircraft".

However, this exclusion does not apply if the only allegation in the claim or "suit" involves an intellectual property right which is limited to:
(a) Infringement, in your "advertisement", of:
(i) Copyright;
(ii) Slogan; or
(iii) Title of any literary or artistic work; or
(b) Copying, in your "advertisement", a person's or organization's "advertising idea" or style of "advertisement".
q. Access Or Disclosure Of Confidential Or Personal Information And Data-Related Liability (1) Damages because of “bodily injury” or “property damage” arising out of any access to or disclosure of any person’s or organization’s confidential or personal information, including patents, trade secrets, processing methods, customer lists, financial information, credit card information, health information or any other type of nonpublic information; or
(2) Damages arising out of the loss of, loss of use of, damage to, corruption of, inability to access, or inability to manipulate "electronic data".

This exclusion applies even if such damages are claimed for notification costs, credit monitoring expenses, forensic expenses, public relations expenses or any other loss, cost or expense incurred by you or others arising out of that which is described in Paragraphs (1) or (2) above.

However, unless Paragraph (1) above applies, this exclusion does not apply to damages because of “bodily injury”.
r. Employment-Related Practices
"Bodily injury" or "personal and advertising injury" to:
(1) A person arising out of any:
(a) Refusal to employ that person;
(b) Termination of that person's employment; or
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ITEM NO. 8.

Form SL 00 00 10 18 Page 11 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) (c) Employment-related practices, policies, acts or omissions, such as coercion, demotion, evaluation, reassignment, discipline, defamation, harassment, humiliation, discrimination, malicious prosecution or false arrest directed at that person; or
(2) The spouse, child, parent, brother or sister of that person as a consequence of "bodily injury" or "personal and advertising injury" to that person at whom any of the employment-related practices described in Paragraphs (a), (b), or (c) above is directed.

This exclusion applies:
(1) Whether the injury-causing event described in Paragraphs (a), (b), or (c) above occurs before employment, during employment or after employment of that person; (2) Whether the insured may be liable as an employer or in any other capacity; and (3) To any obligation to share damages with or repay someone else who must pay damages because of the injury.
s. Asbestos
(1) "Bodily injury", "property damage" or "personal and advertising injury" arising out of the "asbestos hazard".
(2) Any damages, judgments, settlements, loss, costs or expenses that:
(a) May be awarded or incurred by reason of any claim or “suit” alleging actual or threatened injury or damage of any nature or kind to persons or property which would not have occurred in whole or in part but for the "asbestos hazard";
(b) Arise out of any request, demand, order or statutory or regulatory requirement that any insured or others test for, monitor, clean up, remove, encapsulate, contain, treat, detoxify or neutralize or in any way respond to or assess the effects of an "asbestos hazard"; or (c) Arise out of any claim or “suit” for damages because of testing for, monitoring, cleaning up, removing, encapsulating, containing, treating, detoxifying or neutralizing or in any way responding to or assessing the effects of an "asbestos hazard".
t. Recording And Distribution Of Material Or Information In Violation Of Law "Bodily injury", "property damage", or "personal and advertising injury" arising directly or indirectly out of any action or omission that violates or is alleged to violate:
(1) The Telephone Consumer Protection Act (TCPA), including any amendment of or addition to such law; (2) The CAN-SPAM Act of 2003, including any amendment of or addition to such law; (3) The Fair Credit Reporting Act (FCRA), and any amendment of or addition to such law, including the Fair and Accurate Credit Transaction Act (FACTA); or
(4) Any federal, state or local statute, ordinance or regulation, other than the TCPA, CAN-SPAM Act of 2003 or FCRA and their amendments and additions, that addresses, prohibits or limits the printing, dissemination, disposal, collecting, recording, sending, transmitting, communicating or distribution of material or information.

Damage To Premises Rented To You – Exception For Damage By Fire, Lightning Or Explosion Exclusions c. through h. and k. through o. do not apply to damage by fire, lightning or explosion to premises rented to you or temporarily occupied by you with permission of the owner. A separate limit of insurance applies to this coverage as described in Section D. Liability And Medical Expenses Limits Of Insurance.

2. Applicable To Medical Expenses Coverage
We will not pay expenses for "bodily injury":
a. Any Insured
To any insured, except "volunteer workers".
b. Hired Person
To a person hired to do work for or on behalf of any insured or a tenant of any insured. 57SBABG7ML7

ITEM NO. 8.

Form SL 00 00 10 18 Page 12 of 22
© 2018, The Hartford
(May include copyrighted material of Insurance Services Office, Inc., with its permission) c. Injury On Normally Occupied Premises
To a person injured on that part of premises you own or rent that the person normally occupies. d. Workers' Compensation And Similar Laws
To a person, whether or not an "employee" of any insured, if benefits for the "bodily injury" are payable or must be provided under a workers' compensation or disability benefits law or a similar law. e. Athletics Activities
To a person injured while practicing, instructing or participating in any physical exercises or games, sports or athletic contests.
f. Products-Completed Operations Hazard
Included with the "products-completed operations hazard". g. Business Liability Exclusions
Excluded under Business Liability Coverage.

C. WHO IS AN INSURED

1. If you are designated in the Declarations as:
a. An individual, you and your spouse are insureds, but only with respect to the conduct of a business, other than that described in b. through e. below, of which you are the sole owner. b. A partnership or joint venture, you are an insured. Your members, your partners, and their spouses are also insureds, but only with respect to the conduct of your business. c. A limited liability company, you are an insured. Your members are also insureds, but only with respect to the conduct of your business. Your managers are insureds, but only with respect to their duties as your managers.
d. An organization other than a partnership, joint venture or limited liability company, you are an insured. Your "executive officers" and directors are insureds, but only with respect to their duties as your officers or directors. Your stockholders are also insureds, but only with respect to their liability as stockholders. e. A trust, you are an insured. Your trustees are also insureds, but only with respect to their duties as trustees.

2. Each of the following is also an insured:
a. Employees And Volunteer Workers
Your "volunteer workers" only while performing duties related to the conduct of your business, or your "employees", other than either your "executive officers" (if you are an organization other than a partnership, joint venture or limited liability company) or your managers (if you are a limited liability company), but only for acts within the scope of their employment by you or while performing duties related to the conduct of your business.

However, none of these "employees" or "volunteer workers" are insureds for:
(1) "Bodily injury" or "personal and advertising injury":
(a) To you, to your partners or members (if you are a partnership or joint venture), to your members (if you are a limited liability company), or to a co-"employee" while in the course of his or her employment or performing duties related to the conduct of your business, or to your other "volunteer workers" while performing duties related to the conduct of your business; (b) To the spouse, child, parent, brother or sister of that co-"employee" or that "volunteer worker" as a consequence of Paragraph (1)(a) above;
(c) For which there is any obligation to share damages with or repay someone else who must pay damages because of the injury described in Paragraphs (1)(a) or (b) above; or (d) Arising out of his or her providing or failing to provide professional health care services.

If you are not in the business of providing professional health care services, Paragraph (d) does not apply to any nurse, emergency medical technician or paramedic employed by you to provide such services. (2) "Property damage" to property:
57SBABG7ML7