Los Gatos City Council
August 11, 2026

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reviewed by the environmental consultant, so how do we
remedy that?
ERIN WALTERS: These were the plans that were
provided to the consultants to review as a part of that, and you can see the dashed line on ephemeral drain, that’s the 10’ buffer, and it looks like there’s a segment that’s near Lot 8 that isn’t showing that dash line.

DIRECTOR PAULSON: I think what Ms. DaRosa tried
to explain, but maybe it wasn’t caught, was some of these wider sections that have the 10’ buffer around them, maybe there was some vegetation, if I recall, and where this
other is, there really isn’t. It’s really just part of the channel, so that buffer is not as wide at that point. You have all been out to the site. Even the grey area isn’t what you see on the ground. So, if Ms. DaRosa could provide just a little more clarification on that for the Planning Commission, please.

ERIN WALTERS: If I could interject. Mr. Mullin,
on Exhibit 15, sheet 6, the erosion control plan, that
shows that delineation.

ANGELA DaROSA: Just to clarify, the biologist
analyzed the site plan as proposed, so where there are 10’ buffers shown, they analyzed that and assumed that.

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CHAIR THOMAS: I have a question about what the
process is if a species of concern is found on this site, what ends up happening?
ANGELA DaROSA: Just to clarify, you’re asking if
a species that wasn’t addressed in the MND?
CHAIR THOMAS: Yes, an additional one, if
something comes up, because I did see in the biological report there were a couple that were like this; the closest one is these many miles away, for example. So, there were a few, but I know that I’ve seen them, and other people have seen them closer than three miles to that site, so just wondering.

ANGELA DaROSA: Sure. The species that were
identified as potentially occurring onsite were based on the biologist expert’s opinion and the conditions of the site from their surveying. Of course, if they’re out there doing the preconstruction surveys that are required for the special status species that were identified by the
biologist as potentially being there, the qualified
biologist that would be doing that survey would follow
protocol to address any other special status species that they see while they’re out there.

CHAIR THOMAS: Then just quickly, just for the
public’s understanding, can someone clarify in general, I

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know that it is in here, but what is the general protocol when a species of special concern is found? Just because I think that there is a misunderstanding about what happens next.

DIRECTOR PAULSON: I can say, I don’t recall that
ever occurring in town, because most of those species are already known with rats, and the bats, and the raptors, but we would defer, again, as Ms. DaRosa said, to the
biologist. There is standard protocol for whether you’re encountering that, or your encountering Native American artifacts, or skeletal remains, or any of those things; we would follow the required protocol.

CHAIR THOMAS: Sorry, I meant if anything, even
included, happened. In general, just the general protocol for when a species of special concern is on a site. It
doesn’t mean that everything ceases to stop, there are a couple of different…
DIRECTOR PAULSON: Again, when something like
that happens, then we would defer to the expert, whether it’s a biologic issue or some other issue that also has the potential for creating a situation where something unknown is found, and then we would follow that generally State or Federal required protocol, but I do not have that with me.

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CHAIR THOMAS: Okay, thank you. I had a question
about the geologic hazard appendix, so in Appendix D, just again wondering on the timing of when this was done. Then, I also could not find a map of where the boreholes that were being described actually were. It’s probably in here, but again, this was a giant packet, so if someone could just refer me to where I should be looking for that.

ANGELA DaROSA: The geology study was attached to
the IS/MND; it was included as Appendix D to the IS/MND, and it was prepared in October 2024. We’re trying to pull up the map for you.

CHAIR THOMAS: Okay, thank you. Go for it while
they’re looking.

COMMISSIONER SORDI: Just a quick follow-up on
the geotechnical report and the indications of slide areas on the site. From reading the report, it appears that there are no mapped known slides on the site, and I guess what I was curious about was what was used as rationale for
identifying areas in the slide zone versus not slide zone.

Is this strictly based on slope, or is it soil
characteristics? And hopefully I’m right about the map
slide zone. If I’m wrong, let me know.

ANGELA DaROSA: Santa Clara County maps the site
as being in a landslide hazard area, but as part of the geo

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study, they did a number of test pits and actually looked at the soils on the site in some of those sloped areas.

What they found was no evidence of landslide deposits, no field features indicative of slope failure and instability, so they found that landslide hazards were to be considered low to moderate, and the majority of the proposed
residences are outside of the steep slope areas.

COMMISSIONER SORDI: There’s one particular map
that shows I think it’s most (inaudible) with Lot 8 as
being kind of painted yellow, and I thought it was
indicating that it was in a slide zone, but maybe I’m not getting that right. Here we go. It’s in the packet, page 1,092. It’s Lot 9, Architecture and Site review, and I’m just noticing that the area… It just says, “(inaudible) Slide Hazard Zone,” and it maps it in yellow. It looks like a significant portion of it is on Lot 9 and Lot 8.

I don’t know if I’m asking the same question, but
I guess I’m just wondering what led to the characterization of that area to be in a slide zone versus not the rest of it, and if it’s just based on slope or if it’s also just based on the civil borings and the characteristics.

ANGELA DaROSA: I think those shaded areas, I
believe, are from the County maps that are showing that landslide hazard area.

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COMMISSIONER SORDI: So, the County map shows it,
but we’re not really sure why? I don’t want to draw
unnecessary conclusion or unsupported conclusion, but if there were borings done it sounds like there were no mapped actual landslides found, and that way we’re not looking at a hazard that severe, we’re just looking at a resource and constraint map that looks at things from like a 10,000’ level. Is that correct?
ANGELA DaROSA: Yes, it’s definitely based off
the borings, and there is a mitigation measure included in the MND that requires compliance with the recommendations of the geostudy, so there are some recommendations to
ensure that slope stability is addressed.

COMMISSIONER SORDI: Okay, thank you.

ANGELA DaROSA: And we found the map of the test
borings. It’s an attachment to the geotechnical report, the second figure. There are no figure numbers on it.

COMMISSIONER SORDI: That’s all I had on geo.

VICE CHAIR BURCH: While she’s looking for the
document she’s trying to find, I have a non-geotechnical question.

We received a couple letters from the Sierra Club
and the Santa Clara Valley Bird Alliance. I have one dated October 17th, and in this letter they state a few concerns

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around the document and that they feel that it doesn’t
properly address certain concerns, some of them that we’ve talked about tonight, but one them, which was kind of the biggie I thought, was the statement that says, “Procedural deficiencies under CEQA, including reliance on deferred mitigation, absence of required agency consultation, and disregard of substantial evidence submitted by responsible agency.”
Have you guys taken a look at this document, and
is there a way that you would answer to confirm for us that in fact those things have been done?
ANGELA DaROSA: Yes, I think included in your
packet is detailed responses to that exact letter.

DIRECTOR PAULSON: Those might have been in
Addendum 2 or the Desk Item, Ms. Walters?
ERIN WALTERS: It was in Addendum 2; it was part
of the attachment there.

ANGELA DaROSA: And I think that comment in
particular was related to the Water Board’s comments. They were referring to the Water Board’s comment letter.

CHAIR THOMAS: You said that the geology report
was done in October 2024?
ANGELA DaROSA: That’s correct.

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CHAIR THOMAS: I have a follow-up question,
because we’ve been out to the site, and obviously we
haven’t had a lot of rain as of now but it’s wet out there and those boreholes would have been done when the water table is presumably the lowest, because it’s in October. It does explicitly say in this part of the groundwater report that that’s likely not represented at the stabilized
levels. They can be higher than initial levels encountered, etc., so how is that taken into account? It just is a very wet area, so how can we make sure that there isn’t water… Really, like the water table isn’t at the surface in some of these spots?
DIRECTOR PAULSON: I can start, and then if
anyone else has any other questions, but ultimately if the project gets approved and development plans come forward there will be additional geotechnical work that will have to be done for the specific foundations and soils work, but as you mentioned, the water table can fluctuate, and so we’re not going to have them go out every week and test the soil, and if they do encounter water, this happens all the time in Town, especially when folks do cellars. Then they end up having to get a system to make sure they’re
dewatering that, obviously in the appropriate manner, so that it doesn’t impact the site or offsite properties.

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Do you have Exhibit D with you? I think page 37
is the last page of the geotech report, so the second page after that is, I believe, what Ms. DaRosa was… Yes, so that shows the borings.

CHAIR THOMAS: Okay, thank you. Commissioner
Burnett.

COMMISSIONER BURNETT: Thank you. I’d like to ask
a question representing CEQA. What did you base your
findings on to believe that the Mitigated Negative
Declaration was all that was needed, and any concerns were less than significant and that could be mitigated on this complex project? This is a very involved project.

And then, did you rely at all on an outdated,
uncertified EIR in 2017? At that time that was based on a 55,000 square-foot area, and it did cite potential
significant impacts. So, my question to you is did you rely at all on that report? It was uncertified and it was an EIR report. I’m just finding that there is a lot of areas here that I think seem to have a lot of unanswered questions, so that’s my question to you.

ANGELA DaROSA: The general answer is no; we
didn’t rely on the prior EIR. As you know, it was
uncertified and it was from multiple years ago, so this IS/MND is a full independent analysis with new projectPage 1478 ITEM NO. 1.

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specific reports conducted, so we did not rely on prior reports prepared for that EIR.

COMMISSIONER BURNETT: Thank you.

DIRECTOR PAULSON: I’d be curious, you mentioned
potential significant impacts. All of these reports,
whether it’s EIR or MND, have potential significant
impacts, but it’s my recollection that even though that’s many moons ago, that even though that project did an EIR, they were able to mitigate all of those impacts to less than significant. There were no significant, unavoidable impacts even with the EIR.

COMMISSIONER BURNETT: I believe I read that they
did cite in that EIR report that there were some potential significant impacts.

DIRECTOR PAULSON: Correct. Every one of these
looks at potential significant impacts, but if it can’t be mitigated, it becomes significant and unavoidable. That’s when you absolutely have to do an EIR. We have had in the past—and so the Planning Commission and Council have seen that before—a number of projects that have decided even though they don’t have any significant unavoidable impacts and could be CEQA clearance through a Mitigated Negative Declaration, they have chosen to do an EIR, because that has a higher bar from a lawsuit perspective for the

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Applicant, but in this case the Applicant didn’t choose to go down that path, and it’s not necessary to go down that path, because there aren’t significant unavoidable impacts at this point, but I’ll go back and look, because I don’t remember any that were from the previous project either.

CHAIR THOMAS: Should we move on to the next? If
we have any more environmental questions, we can come back to it. Next, I think we should discuss the State Density Bonus Law and all of the incentives, concessions, waivers, walking through some of that.

I think before I open it up to everyone else, I
would like a clarification again from the Town Attorney about the identifiable and actual cost reduction, the
language and the findings that we need to make to grant these incentives.

ATTORNEY WHELAN: I think I remember what part of
the presentation you’re referring to. The burden is on the Town to demonstrate that their requested concession or
incentive would not result in a cost reduction, and the way that we normally determine that information is we ask the Applicant to give us a general explanation of how the
concession or incentive results in a cost reduction.

There is a case out there saying that public
agencies can’t require proformas, and so the Town doesn’t

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require a proforma, but we do require an explanation of what the cost reduction consists of.

CHAIR THOMAS: And then, “…to provide for
affordable housing.” What does that mean?
ATTORNEY WHELAN: That language comes from the
statute. It’s hard to interpret, and so our position has been does this incentive or concession result in a cost reduction to the project overall. Because the project, by definition, has to include a component on affordable
housing in order to even qualify.

CHAIR THOMAS: I’m just curious, because this is
one of the findings that we have to make to the concessions or incentives for the open space conservation trails
situation, and in the Staff Report it just says to provide affordable housing costs. I clearly understand how
expensive sidewalks can be, and it’s very clear that that would significantly change the project financially, but I’m not sure that I personally have enough information about the actual cost reduction by avoiding having an easement for open space, but I’m curious to see what other
Commissioners have to say about that.

DIRECTOR PAULSON: I would just remind the
Planning Commission; Staff wasn’t able to make the finding from our perspective for the open space component. We

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25 actually were for the trails, so you might want to discuss that one as well. Obviously, the initial installation of that, you’ve been out to the site, it basically comes into the site, traverses their perimeter, and goes all the way up to Cerro Vista. Obviously, there will be a cost
associated with that, but I just wanted to throw out that little bit of background for your discussion.

CHAIR THOMAS: Thank you.

VICE CHAIR BURCH: Can you expand on the trails?
DIRECTOR PAULSON: Expand on them? Make them
bigger?
VICE CHAIR BURCH: Aside from maybe saying we
have to do physical trails, could we do an easement for trails?
DIRECTOR PAULSON: I think you could request that
be part of your recommendation to move forward, that at a minimum, trails. We heard tonight from Planning
Commissioners that they don’t necessarily have enough
information on the monetary impact to the project for even going to the level of doing the trails, so that could
definitely be part of any recommendation moving forward.

CHAIR THOMAS: As a follow-up to that, if there
was an easement, if a land trust or community group or
something came along down the line to fund and maintain and

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25 set up a situation for that, is that how that would legally work?
ATTORNEY WHELAN: The condition could be openended. It could require the easement be dedicated, and then it could specify that either the Town would make
improvements later, or as you mentioned, another group
might come along and make improvements.

CHAIR THOMAS: Thank you. Commissioner Raspe.

COMMISSIONER RASPE: Thanks, Chair. I’m looking
at our Staff Report starting at page 14 and going to page 15, and it has a list of both the incentives and the
waivers, so maybe a good way to do it would be to attack those in order.

Looking at the incentives, beginning with the
story poles and not providing sidewalks, I understand the cost savings with those, and perhaps we can be with the developer on that.

Going to trails on the open space easement,
again, I think Conditions of Approval for Lots 2, 7, 8, 9, and 10—that’s already part of our packet—I would recommend that we incorporate that as part of any approval if we were going to have an approval.

I would also encourage us to include the trail
system. To me, if cost really is an issue to the developer,

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25 it could be foisted back to the homeowners by way of making it an HOA cost for maintenance, for initial building,
divided over 12, or even if you wanted to take the BMPs out of it, to a lesser (inaudible), would be an inconsequential (inaudible). I think we can find that it’s not an
insurmountable burden to (inaudible) the incentives.

CHAIR THOMAS: I think that we’re all on the same
page with regard to that. Then with the waivers, does
anyone have any questions or want to discuss? I would just say that the LRDA is something that we see very often
obviously in the hillsides, so I don’t think that’s even something that…
DIRECTOR PAULSON: I think, again, Mr. Mullin, if
you can bring up the finding, because that one has a little bit different than the monetary, and it really gets back to anything that’s going to impact the project as it is
proposed.

CHAIR THOMAS: Yes. Most of the time when we’ve
been looking at these projects and everything it’s just about obviously making sure that these waivers are
necessary for these projects, and then just making sure that if there is anything that the Applicant team is still willing to address in a different way, which I think they stated that they want feedback on, I just want to give them

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25 an opportunity to hear if we have any concerns with any of these. Even though we know that we would still not be able to make this finding, we would not be rejecting the project because of that, but if they’re going to be providing us more information, making any additional changes, or
prioritizing things. Commissioner Burnett.

COMMISSIONER BURNETT: The question to Staff
would be regarding the below market program that we have.

There are concerns over the size and location, and I know this is a waiver but under the State Density Bonus Law. I wonder if Staff has any concerns over that, the below
market.

ATTORNEY WHELAN: We debated it internally,
because it is a question as to whether that physically
precludes the development as proposed. Where I landed is that I think requiring a different configuration of the BMR units would physically preclude the development as
proposed.

Then, internally, we also looked at it from the
fair housing angle, like is this violating any State Fair Housing laws. We did not locate any State laws that were being violated. That said, nothing prevents the Commission from asking an Applicant if they would be able to
reconfigure the BMP units.

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25 DIRECTOR PAULSON: I think the other challenge
that we ran across was that the language of our guidelines related to that area is not objective, from what I recall.

We’ll go back and look at that language as well, but that’s part of my recollection as well, so you can impose it
anyway.

COMMISSIONER BURNETT: Thank you.

CHAIR THOMAS: Assuming that the Applicant is
perhaps amenable to some of our feedback, is there anything else related to any of the waivers that we feel like could be addressed in another way? Vice Chair Burch.

VICE CHAIR BURCH: I think the one that I had
highlighted was actually the swimming pools on slopes
greater than 30%, but I saw that was addressed in the
proposed Conditions of Approval; that was the one I had highlighted. And the location of the BMPs, which
Commissioner Burnette asked about. Aside from that, no, I don’t think so.

CHAIR THOMAS: Then lets move on to the site
plans, starting out with Commissioner Sordi.

COMMISSIONER SORDI: I think this falls into the
realm of site plans, so this may be a question for Public Works, City Engineer. I think the Conditions of Approval require CC&Rs but not an HOA, right? And so, right now

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25 presumably the CC&Rs would be written in such a way to put the onus and the responsibility on the individual lot owner to maintain the stormwater facilities, and I’m interested to hear feedback from Public Works, the City Engineer, on that. I know from time-to-time the Regional Board audits these things, and it would be kind of a shame if we ended up getting fined, because I think the fines get directed into the public agency and not to the individual, and you just simply can’t control who is going to own those lots and how they’re going to treat those facilities, so I would just be interested in your feedback on whether that’s a practical solution.

DIRECTOR PAULSON: I’ll start, and then Parks and
Public Works can correct me when I’m wrong. Ultimately, yes, it would be in the CC&Rs. It is on the property
owners. There are yearly inspections that are done to
address that. These are all over town, they’re all over single-family lots, so this is not a unique practice, this is just something that we have to do as part of our
Stormwater Permit. If there is anything else that needs to be added, I turn to Mr. Sparks or the Town Engineer.

COMMISSIONER SORDI: A quick follow-up. If
something is in disrepair or just destroyed or ruined in the property, what is the remedy? You fine the property

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25 owners? Does it become a code enforcement issue? How do you impose the fix on them?
DIRECTOR PAULSON: We have both an engineer that
does inspections, and we also have building inspectors that do some different inspections, so it’s kind of split, from what I recall, but I imagine there are enforcement
capabilities associated with that permit. Let me just look to Mr. Heap for a nod. So, yes, there are enforcement
provisions that we, when necessary, will handle.

COMMISSIONER SORDI: Thanks. Then it leads me to
disclosures, I guess. CC&Rs are one thing. A new homeowner that buys a lot, you can presume they read the CC&Rs, but the way to really make sure they know that there are
additional budgetary restrictions associated with owning a lot and having to maintain a storm facility would be like a recorded… Maybe recording something would go pretty far, but having a disclosure, which I know is typically provided by the seller—I guess it’s just a suggestion—so that it calls it out, it makes it really crystal clear that
somebody is going to have to dip into their pocket and
maintain this thing from time to time.

DIRECTOR PAULSON: Yes, and we can work with
Parks and Public Works. They’re generally not going to see the recorded subdivision map either, but I could see that

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25 as being a note. We could definitely look into that
recommendation and see what options are out there.

COMMISSIONER SORDI: Okay, thank you.

VICE CHAIR BURCH: This might be for Staff, or it
might be for the consultants, actually, I’m not sure. Was there any study done on stormwater being drained into Ross Creek?
DIRECTOR PAULSON: We definitely have Parks and
Public Works Staff here. Our planning application checklist requires that preliminary grading and drainage plans be submitted. You’ve seen the plans; they go far beyond that, but there still are things that need to be ironed out, and so that will happen again.

It’s one of those things where once we get down
to it, if the project gets approved and they’re getting construction drawings, then they’ll have to get final
signoff for C-3 and other components. If any of those
trigger any significant modifications to what was, if
approved by the Town Council, then they may be subject to coming back through for modification, which I don't know what, but there may be ramifications there. I know Parks and Public Works has done some work on that, but we’re not in a final grading and drainage plan, for instance.

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25 VICE CHAIR BURCH: Can I actually ask a follow-up
question of that, because that was going to be one of my questions? What we actually have says it’s a preliminary grading plan. When do you guys typically see a more
thorough grading plan?
DIRECTOR PAULSON: The process is after you go
through the Architecture and Site. There’s an additional Grading Permit that you go directly to Park and Public
Works for, and they have a completely separate process
where they are nailing down all of those details, so that’s when that is going to get handled. Some of these
requirements, and we heard a lot from architects and
applicants who said, “I don’t even know if I’m going to get to build my house. Why are you going to make me spend tens of thousands of dollars?” getting even to the level we
request them to get to, so it’s a very significant risk from their perception for an applicant that comes through our process.

CHAIR THOMAS: Commissioner Burnett.

COMMISSIONER BURNETT: How can the Planning
Commission recommend this to the Town Council if we don’t have all the evidence, especially regarding the drainage? If we’re still waiting for reports…

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25 DIRECTOR PAULSON: If you’re not comfortable with
what has been proposed, then you can always recommend
denial.

COMMISSIONER BURNETT: Thank you.

CHAIR THOMAS: Any other questions or anything
about the site plans? No. The last thing is Conditions of Approval to look at, discuss, and go through. Are there any questions specifically about the Conditions of Approval, changes, or additions? Vice Chair Burch.

VICE CHAIR BURCH: I have one that I wanted to
bring up that has to do with the residential street. Since this is a rather large lot, can I request that we add a Condition of Approval that there be conditions made to
where construction vehicles and parking would be on the property, not on the street, and not have construction
trucks parked or idling on the street for longer than five minutes or something? Okay. He nodded at me.

DIRECTOR PAULSON: I’m sure there is already
something in there that discusses that, but you are
potentially going to be recommending more specificity when they look through that construction management plan moving forward.

VICE CHAIR BURCH: Yes, I just added a couple of
things on top of what he has in here already.

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25 DIRECTOR PAULSON: I think the other two I heard
was something to handle the trails, and then also the open space easements. Those were two other topics.

CHAIR THOMAS: Yes.

DIRECTOR PAULSON: And then the other might have
been related to trees.

CHAIR THOMAS: Yes, the trees. Okay, yes.

COMMISSIONER RASPE: If I can follow up on the
trees, then. I’m looking in the area of Lots 11, 12, or 13.

You heard our prior discussion about coming to some
accommodation with respect to privacy that would satisfy neighbors. If we could incorporate some of those ideas into a Condition of Approval, probably in one of those numbered areas.

DIRECTOR PAULSON: I think, as you heard from the
landscape architect, it does get to be a challenge when— actually, I think there was a speaker this evening—they’re technically currently in the high fire hazard severity
zone, but because they vested to the previous maps prior to the recent modifications they were in very high, and
they’re still being subject to the very high requirements.

Many of Fire’s requirements that are currently in there, if they came in today they wouldn’t have to do. That’s an
aside, but again, it was getting to that balance of how

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25 many trees can we plant, how dense can they be based on the defensible space requirements that are out there, but to the maximum extent feasible, sure.

COMMISSIONER RASPE: Understood. We all agree on
the point, to the extent allowed by applicable law. Thank you.

VICE CHAIR BURCH: This may be in the Conditions
of Approval, but again, this is a lot of paperwork. Don’t we have something in here about the type of fencing that can be allowed in open space like this so that it maintains wildlife corridors?
ERIN WALTERS: It’s not specific in the
conditions, but that is a part of the Town Code, and so they would be subject to the Town Code requirements. The Town Code does specify what is allowed in the hillside
area.

VICE CHAIR BURCH: I did have one other one,
which I know is going to be like weirdly specific, but what was said and what is on the plans are different. If you look on the plans at Lots 4 and 5, between the lowest
retaining wall and the property behind them the landscape architect actually said that there was hydroseed and
plantings that would void erosion, that actually isn’t on the plans; it’s shown on the upper tiers of the retaining

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25 walls. I just want to make sure that there are plantings between those properties and the properties behind them, because of elevation change that avoid that type of soil erosion.

COMMISSIONER RASPE: If I can just ask my fellow
commissioners, one of the issues has been the open space easement, and I’m just curious as to what lots you think (inaudible) 10 and 8, perhaps 9? I want to make sure we all kind of (inaudible).

COMMISSIONER SORDI: In the conditions though,
right?
COMMISSIONER RASPE: It’s not in there yet.

COMMISSIONER SORDI: It is.

VICE CHAIR BURCH: Yes, see page 40.

COMMISSIONER RASPE: Oh, you’re right. Okay. And
so Lots 2 and 7 also.

VICE CHAIR BURCH: It includes Lots 2, 7, 8, 9,
and 10.

CHAIR THOMAS: Two already.

COMMISSIONER RASPE: Yes, I think that’s right.

CHAIR THOMAS: So, like 2, and then 7 and 8…
VICE CHAIR BURCH: Eight, 9, and 10.

CHAIR THOMAS: …9 and 10, yes. Those, yes.

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25 COMMISSIONER BURNETT: Chair, when would be the
appropriate time to bring up a different point of view on the subject?
CHAIR THOMAS: Of the open space, or of anything?
COMMISSIONER BURNETT: Of the project.

CHAIR THOMAS: I just have a follow-up question
about the open space, and then… Actually, it’s okay. Never mind, you can bring up whatever you want.

COMMISSIONER BURNETT: Okay, so I’m coming from a
different direction. I went to a Planning Commission
seminar and it brought up the idea of fair argument
standard. I really believe this project qualifies for that, because you have documents from the Coast Ridge Ecology Report; you have the documents from the Sierra Club; the Loma Prieta chapter; documents from the Santa Clara Bird Alliance; and all the neighbor concerns. You have San
Francisco Bay Regional Water Quality Control Board. I mean, these are sophisticated reports and have a lot of issues, you know, strong reports, and that is why I feel we really need an EIR.

And when you talk about a fair argument standard,
you ask when must an EIR be prepared, and when it can be prepared, when it can be fairly argued based on substantial evidence in light of the whole record that a project may

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25 have a significant environmental effect; and when you read all these documents, and you read maybe the past EIR, even though it wasn’t certified, the residents and their
explanations and their lifelong experiences with this
hillside, I think that fairly argued means that there is evidence of the potential for impact in the administrative record before the agency.

So, I think there is enough evidence, fair
argument standard, which is CEQA, that it really deserves to have a full EIR report. I think there are too many
questions regarding the water basins, the trees, the
hillside slides, and we have questions after questions.

We’ve gone over where does the water end? Is it going into Ross Creek? Where are the basins? For me, one of the
Commissioners, those would be my comments, so that would be the direction I would go. I’m just one Commissioner here.

DIRECTOR PAULSON: Through the Chair, I think we
talked about this a little bit earlier. I didn’t go as in depth as Commissioner Burnett, but the fair argument is the legal standard I was mentioning that is much lower, so if this goes to court it’s very easy to prove. It’s not as, I think Ms. Quintana used, “bulletproof,” which everyone
wishes existed even with an EIR, but it doesn’t. But it’s a far lower bar to overturn a Mitigated Negative Declaration

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25 than it is an EIR, which is one of the things we discussed.

So, if there was a court case following any approval
related to CEQA, then that would be the argument.

COMMISSIONER BURNETT: Okay, so then if we didn’t
go that road, then I would request a follow-up meeting—we have a total of five—and I would like some more of these in-depth answers to some of these serious questions for the neighbors and for the fellow commissioners. I don’t feel like a lot of the questions were answered, so that would be my second. If you feel that way about litigation or
whatever, then my next Plan B would be to have a second meeting, because we have a total of five, with some of our questions answered, and visiting to the site where the
wetlands are; I’d like to see that as well.

CHAIR THOMAS: Commissioner Sordi.

COMMISSIONER SORDI: I just wanted to respond to
that a little bit and maybe get into a little more detail.

I am hesitant to require more process just for the sake of process, so I think what we really need to do is focus on which questions haven’t been answered, and to what extent an IS/MDN is or is not the document appropriate to do that.

If you think you’re going to find more analysis and it’s going to come to a different conclusion just by virtue of changing the process and moving to an EIR from an IS/MND, I

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25 think you need to go into detail about what it is that you’re going to uncover by adding process that is going to be a different conclusion from a technical standpoint and environmental standpoint.

DIRECTOR PAULSON: Going back to what we
discussed before, I think its Initial Study checklist, it’s the same checklist whether you do a Mitigated Negative
Declaration—we’ve even done them for categorical
exemptions—as it is for an EIR. All the same topics are studied, all the same impacts, all the same thresholds and criterion for the various impacts, so the reality, my
opinion is—and Ms. DaRosa can speak up if she thinks I’m speaking out of turn—that it would be the same, exact
conclusions. There would be no different conclusions. We would be including alternatives to the project, and we’ve seen this with other projects where they don’t have to do an EIR, because they have no significant unavoidable
impacts, but we have to do alternatives so it has, “less less than significant,” impacts, so, it doesn’t really hit that threshold.

The other thing that it looks at, I believe, is a
little more different cumulative impact perspective, but we’re talking about 12 lots here: that’s not going to rise to a cumulative impact, so just a little more background

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25 from a planning perspective. Ms. DaRosa, anything else to add?
CHAIR THOMAS: I have a question just about the
mitigation and monitoring. Obviously, a project like this takes a while, and so a lot of these, like the
implementation schedule is like for the big eared bat, for example, it just is like up to one year prior and then
within seven days prior to the start of construction. What happens if there is a delay in construction because of
weather, or another pandemic, or we can’t get parts and the site is sitting there un-path developed for a while? How does that factor into it?
ERIN WALTERS: Folks try to get it done really
quick to get construction, because they have to have those letters prepared by a certified biologist per the
mitigation direction. Those would have to be redone if
there is a delay, and so there is a specific timeframe
that’s attached to that through those conditions.

DIRECTOR PAULSON: That one we do have a
protocol, and we run into that sometimes where if they
don’t hit those timelines they have to start that clock back over, get the biologist back out there for that
specific one you mentioned.

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25 CHAIR THOMAS: I hear what Commissioner Burnett
is saying, and I agree with Commissioner Sordi that I don't know what… I need more information to make a motion and to vote on this project as of now, but I think that it’s
important for us to explain what additional information and questions we have so that Staff, consultants, Applicant team can provide that information so that we can move
forward with the project in whatever way, shape, or form that’s going to happen, so I would like Commissioners to express what additional information they would need or
like, and then open questions they still have.

Before that though, I do have a question about
site visits. As we said, it was a little bit difficult when we went out there, because of the lack of story poles,
etc., which I understand why that is happening and it’s expensive. Is there a way that we could do some sort of site visits and be able to better understand lot
delineations and/or where structures are going? Also,
possibly, is it normal to be able to go out with any
consultants to be able to ask some questions and get some answers about some of the space?
DIRECTOR PAULSON: Going out with consultants
would be unique from my perspective. This is a challenging site. You guys have all been out there. We went out there

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25 once or twice recently, or I did. I think the Applicant heard your request about the difficulty of trying to orient yourself in the different levels and capabilities, from kind of orienting yourself while you’re out there without any real landmarks other than trying to identify, okay, I see this tree, the general idea.

We can also work with the Applicant to see if
they are willing to put just some kind of staking or some general area, generally delineating the roadway, maybe
corners where the lots hit the roadway, and then you can get a general idea of where that faces to see where those are. Ultimately, that will be up to the Applicant to get that site access.

Those are what come to mind at this point, but I
think that could be part of your direction, depending on your decision this evening. And Staff definitely can go back out there, and more Staff can go out there as well to just kind of help with the effort. We can have Staff stand at the corners of lots.

CHAIR THOMAS: Thank you. Okay, yes, so as a
follow-up to that, the reason I was asking about the
consultants is because the biologist has been out there a couple of time, obviously, and done some surveying. When we were just out there I saw some very specific plants that

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25 grow in very specific conditions, and it was hard for me to tell if that was fully captured on what has been mapped, and so that is my main concern, I guess, with regard to understanding where the water is, the soil saturation,
where the actual edge of this area is. That’s something, I guess, from the environmental review and your team over there, if I could get a better understanding of that.

DIRECTOR PAULSON: We can definitely look. I’m
sure we’re probably past budget already, so we’re going to have to request additional funds from the Applicant, but at a minimum we can probably get some additional information and/or conversations with the biologist in this instance.

CHAIR THOMAS: Okay. Also, if we have access to
some of the GPS or CAD data and stuff, if that doesn’t
require like use from… Some of us can use that information too, ourselves, if we don’t have the budget or we can’t (inaudible) any more money for any of that kind of thing, if there are ways for us to access it in that regard. Vice Chair Burch.

VICE CHAIR BURCH: I agree that it does sound
like a lot of people up here feel like there should be more information. For me, specifically, it still has to do with Ross Creek. I understand what you were saying, but having heard that it does flood rather regularly, and knowing now

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25 that there’s a decent amount of stormwater that’s going to be dumped into that that probably was not before, I would like a little bit more information on that, what that’s going to look like, and what the impact on the creek would be.

I also would probably like to know from you your
experience with pervious concrete and its ability to handle the kind of weight required. I guess my experience has not been good, so maybe if we could look into that a little bit and just have a reassurance that this isn’t going to become like a horrible maintenance nightmare that could not
withstand 75,000 pounds if an emergency vehicle has to
drive through.

CHAIR THOMAS: Commissioner Raspe.

COMMISSIONER RASPE: Thank you, Chair. I agree
with Commissioner Burnett’s concerns about making a
decision when we don’t have all the information and her desire to have a full CEQA analysis, but I’m going to lean into Mr. Paulson’s comments. He’s got far more expertise (inaudible).

I believe that the EIR process probably doesn’t
land us in a significantly different place. I think I am satisfied to go through with the Negative Declaration
subject to containing more information. I would echo my

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25 fellow Chair and Vice Chair’s request for a site visit with some delineation, a better understanding of the hydrology issues, especially the creek, especially flooding into the neighboring properties.

I would add, too, that the trails and open space
issues, whether they are available to the development, and if the position is going to be that they are cost
prohibitive I’d like a discussion of what those costs are so we can evaluate if those are serious prohibitions to doing those.

Lastly, I would like a further discussion or
analysis of the trees, plus privacy issues (inaudible).

Those would be the open issues I would add.

CHAIR THOMAS: I just want to add onto that with
the trees with the request to update to as many native
species as possible. Most of those species are less
flammable, or at least a little bit. They are fire adapted at least, and so I think that that ties into that also.

I did have a question about the noise as brought
up by one of the residents with regard to something I think related to Hillbrook. Can you just quickly explain what the baseline… Like, it’s not cumulative. Now there is a new baseline, and then how we mitigate the noise beyond that.

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25 DIRECTOR PAULSON: We’ll definitely bring that
back as well. I believe there is also discussion of that in the MND, if I remember correctly, but we also have Town Code that deals with it, but a single-family home is not going to generate a noise that is going to be more than the school. I know a lot of work went into the Hillbrook issue, but typically that’s not going to be an issue from another single-family home, but we’ll get you that information as well.

CHAIR THOMAS: No, it is in the MND, but it’s
just that there’s a new baseline because the Hillbrook
situation already exists, so the current conditions are what is the baseline for then the next… Like a new project doesn’t have to take into account that Hillbrook is there and loud.

DIRECTOR PAULSON: That’s correct, and there will
also be other noise impacts, but they’re going to be shortterm, related to construction typically.

CHAIR THOMAS: Yes, and there are restrictions on
that, too, in town. Okay, thank you. Commissioner Burnett.

COMMISSIONER BURNETT: Thank you, Chair. My other
concerns then, if we’re moving in this direction, would be concerns for the buffer zones around the homes. I also
would wonder if the Applicant would look at maybe doing

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25 extra effort for the homes that are really impacted by Lot 5, the lots that are really impacted by, if water, in just an overwhelming amount; if you could do some extra kind of basins, or work with the homeowners just to ease their
fears, which are reasonable, so that would be my suggestion as well.

CHAIR THOMAS: Commissioner Sordi.

COMMISSIONER SORDI: If we are going in the
direction of continuing the item, I would support that. I think that it’s always a challenge when we’re thrown like a 2,000-page packet just a few days in advance, so I support my colleagues’ desire to get more information on the items discussed.

I would encourage the Applicant on the trails
item to maybe consider some options, and maybe be prepared to speak more in detail about what might be on the table. I know you don’t want to negotiate in a vacuum, but if we’re going in that direction I just want to take note of the fact that I think the existing alignment of a trail, if I understand it right, would pass through Lots 4, 5, 6, and 7 and make its way up to the top of the hill to Cerro Vista, and that might be a little bit troublesome and possibly pretty expensive considering the slope you have to cover and then lots that you have to cross.

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25 Then there is a possibility that you’d have to
secure an onsite easement versus the potential ease of
coming through Brooke Acres and possibly placing a
pedestrian bike easement right over the top of the EVE and connecting. Anyway, just wanted to put a little more detail to that. That’s it.

CHAIR THOMAS: Is there anything else that we
would like to say before we move on? Okay, so it looks like we’re in favor of a continuance of this item. I think that the goal would be to do that as soon as everyone is ready to come back with information, but not with a date certain, because we have no idea how long any of this is going to take any of you. Well, I think we’ll decide that.

I know it’s a little unconventional, but I do
want to ask the Town Attorney if we can open up public
comment just to ask the Applicant if there are any
additional things that they want us to provide guidance or feedback on before we close this, so that they can get
clarification on the additional information that we’re
seeking.

ATTORNEY WHELAN: Yes, if the Commission does
that, I recommend opening up public comment for everybody if it’s not a specific question, if you’re just getting feedback.

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25 CHAIR THOMAS: Can I ask just a yes or no?
ATTORNEY WHELAN: Do you have a specific question
for the Applicant? Because you could open up the comment period just to get an answer to that specific question.

CHAIR THOMAS: Yes, I just wanted a specific yes
or no on if we were able to provide enough information and details going forward for them to answer some of our
questions more in depth at the continuance meeting.

ATTORNEY WHELAN: So, is the question does the
Applicant have enough information to provide Staff for the following meeting?
CHAIR THOMAS: Yes.

ATTORNEY WHELAN: Yes.

CHAIR THOMAS: I will open up public comment just
to ask yes or no.

JIM FOLEY: Yes.

CHAIR THOMAS: Thank you. Okay, thank you very
much. I am reclosing the public comment. Do we have anyone that wants to make a motion to continue? Vice Chair Burch.

VICE CHAIR BURCH: I will make a motion to
continue this item, not to a date certain, but until Staff feels they have the information gathered based on the
conversation they heard here tonight.

COMMISSIONER RASPE: Second.

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25 CHAIR THOMAS: Thank you. Any discussion? I’ll
call the question. All those in favor, please raise your hand. The motion passes unanimously, and there are no
appeal rights because it’s a continuance.

DIRECTOR PAULSON: That’s correct.

CHAIR THOMAS: Okay, thank you.
(END)

ITEM NO. 1.

PREPARED BY: Erin M. Walters
Senior Planner
Reviewed by: Planning Manager, Community Development Director, Town Attorney 110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6872 www.losgatosca.gov

TOWN OF LOS GATOS

PLANNING COMMISSION
REPORT
MEETING DATE: 06/11/2026
ITEM NO: 1
DATE: June 5, 2026
TO: Planning Commission
FROM: Joel Paulson, Community Development Director
SUBJECT: Consider a Request for Approval for the Subdivision of One Lot into Twelve Lots with a Vesting Tentative Map, Construction of a New Single-Family Residence on Each Lot, Site Work Requiring a Grading Permit, and Removal of Large Protected Trees Under Senate Bill 330 (SB 330) on Vacant Property Zoned RC. Located at 178 Twin Oaks Drive. APN 532-16-006. Architecture and Site Applications S-24-023 through -032 and S-24-059, Vesting Tentative Map Application M-24-013, and Mitigated Negative Declaration Application ND-25-001. A Recirculated Initial Study and Mitigated Negative Declaration Have Been Prepared. Property Owner/Applicant: Larry Dodge. Project Planner: Erin Walters.

BACKGROUND:

On December 17, 2025, the Planning Commission considered the project, received public testimony, and continued the item to a date uncertain to allow the applicant and staff additional time to respond to questions raised at the meeting which are discussed in the following sections of this report (Exhibit 32).

DISCUSSION:

A. Applicant’s Responses to Planning Commission Questions The applicant provided written responses to the following Planning Commission questions (Exhibit 33). The questions from the Planning Commission are provided on the following page, followed by the applicant’s response in italics.

ATTACHMENT 7

ITEM NO. 1.

PAGE 2 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
• Is the applicant willing to stake the site and delineate the roadway and/or property corners prior to a site visit?
Applicant’s Response: “Yes, the applicant is currently scheduling a survey crew in the beginning of January 2026 to provide construction staking for locations of pertinent relevance for the proposed project.”
Staff’s Note: The applicant’s team staked the site on February 6, 2026. Stakes denote the proposed property line’s at the edge of the proposed road, proposed edge of the road, and proposed front building corners for Lots 1, 2, 3, 4, 5, 6, 8, 9, and 11. • Plans indicate stormwater discharge into Ross Creek. What are the anticipated impacts to the creek, and how are they being mitigated? Applicant’s Response: “The existing conditions of the site are currently draining to Ross Creek. The proposed site design measures do not delineate from draining to Ross Creek.

With that said, the proposed site design measure improves the drainage pattern with a series of C3-mandated stormwater treatment measures (i.e. biotreatment basins, underground storm drain system and pervious pavers – with check dams) and hydromodification measures that capture, treat, detain, and release stormwater at postdevelopment levels no greater than pre-development levels. In summary, the proposed improvements do not impact Ross Creek more than the existing condition. There will be no negative impacts to Ross Creek because of the proposed design. As previously noted, the existing site drains to Ross Creek. Proposed site design measures will not increase the stormwater drainage to Ross Creek from pre-development levels. The proposed C3 and hydromodification measures for the project will have a positive impact to Ross Creek.” • Provide experience with pervious concrete.

Applicant’s Response: “The design team has incorporated pervious pavers/concrete into numerous successful projects, including in the City of San Jose, City of Santa Clara, and Town of Los Gatos as it is an acceptable common practice to achieve C3 compliance (stormwater treatment) per SCVURPPP standards. Additionally, pervious paver/concrete is widely accepted by local fire agencies including the City of San Jose, City of Santa Clara, and Town of Los Gatos. Santa Clara County Fire Department has provided approval for pervious paver use for this project.”
• Demonstrate the pervious concrete’s ability to support weight loads, including emergency vehicles.

Applicant’s Response: “As noted on our Fire Access Plan sheet in all our submittals, all Fire Department access roadways including the private street, driveways and emergency

ITEM NO. 1.

PAGE 3 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
access shall be an all-weather surface designed to support the imposed load of 75,000 pounds. This weight is widely acceptable to local Fire Department agencies, including Santa Clara County Fire Department. A manufacturer specification sheet is included as a product sample that meets the weight load requirements. A pervious paver detail – with check dams - is also included in our plan sets. A supplemental spec showing pervious pavers compliant to the required loading is has been provided to the Town staff.” See Exhibit 34.
• Address long-term maintenance requirements for pervious concrete.

Applicant’s Response: “Per the SCVURPPP C3 Guidelines, a Routine Maintenance Activity Schedule is to be followed for the pervious pavers/pavement. This schedule is included in our plan set (Stormwater Control Hydromodification Details sheet). The specific maintenance action items will be done by the owners of the individual lots for not only their lots but also the private street where pervious pavers are being proposed.

Enforcement of said activities will be conveyed through project CC&R documents as well as the Operations and Maintenance Agreement with the Town.” • Provide additional information on existing flooding of neighboring properties.

Applicant’s Response: “It is our understanding from the project topography that the existing site surface drains down the hill ultimately into the ephemeral creek or will continues downhill to an existing earth swale that directs storm drain runoff to existing storm drain inlets.”
• Explain how the proposed drainage design addresses the flooding issues, particularly along Lots 4 and 5.

Applicant’s Response: “The proposed drainage design introduces multiple measures strategically located throughout the project site. Bioretention basins are located on each Lot and pervious pavers/concrete is being proposed for some Lot driveways and a portion of the private street. These proposed design measures capture the downhill surface drainage, detain it, provide water quality treatment, and provide flow-duration control (as described in the BAHM report prepared by Balance Hydrologics) which addresses the hydromodification management for the project site. Overall, these proposed measures drastically reduce the amount of surface drainage for the site which will greatly benefit the downhill adjacent property owners by capturing the stormwater runoff sooner and directing it to and underground storm drain system. A series of proposed terraced retaining walls along the west side of Lots 4 & 5 will provide additional remediation measures for the said property owners. The small area of landscape between the western-most retaining wall and the property line will be hydroseeded per guidelines to provide a binding measure of the soil to reduce runoff.

ITEM NO. 1.

PAGE 4 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
Due to Fire Department requirements pertaining to tree density, adding more trees in this area is not allowable.”
• Applicant to clarify whether open space easements and/or trails or trail easements can be implemented in the proposed project. If the applicant’s position is that open space easements and/or trails or trail easements are cost-prohibitive, provide detailed cost estimates so the Planning Commission can evaluate that position.

Applicant’s Response: “Please see new exhibit depicting proposed open space and trail easements.” See Exhibit 35.

Staff’s Note: The applicant is no longer seeking the incentives to waive the requirement for private open space easements or requirement for trail easements. Instead, the applicant now proposes Private Open Space Easements and Trail Easements for Lots 1, 4, 5, 6, 8, 9, 10, 11, and 12 as depicted in Exhibit 35. Conditions of Approval #8 and #9, Exhibit 42, have been revised to reflect this modification. • Address privacy concerns through tree placement and buffering with native species.

Applicant’s Response: “HMH (Applicant’s Landscape Architecture Consultant) can add shrubs and propose trees to create a stronger vegetative buffer in the area discussed.

Please reference updated Lots 5 and 6 planting plan.” See Exhibit 36.

Staff’s Note: The proposed tree planting plan provides additional privacy screening through the placement of oak trees between the neighboring rear properties and Lot 6; however, the plan provides minimal screening between the neighboring rear properties and Lot 5 (Exhibit 36).
• Encourage the applicant to consider alternative trail options. The existing trail alignment may be challenging and costly due to lot crossings, slope, and the need for off-site easements. Consider alternatives such as: Routing through Brook Acres and/or adding a pedestrian easement over the EVA and providing a connection to Twin Oaks Applicant’s Response: “Please see new exhibit depicting proposed open space and trail easements.” See Exhibit 35. “There are two trail easement areas that overlap with open space easements as depicted in the exhibit. One goes from Cerro Vista to the EVA that ties to Brook Acres. The other goes from the new private road to Hillbrook School property line. The applicant will not build the trail, and the HOA will not maintain the public trails.”

ITEM NO. 1.

PAGE 5 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
Staff’s Note: Exhibit 35 identifies areas shaded in green on Lots 1, 4, 5, 6, 8, 9, 10, 11, and 12 as public trail easements. Condition of Approval #9 in Exhibit 42 has been revised to reflect this change.

The subdivision proposes dedication of public trail easements, but does not include construction of the trails as required by the Hillside Development Standards and Guidelines (HDS&G) and the Hillside Specific Plan. The project site is also located within the County and Town of Los Gatos Trails Plan area.

The applicant is no longer requesting incentives to waive the requirement to provide trail easements. Instead, the applicant is requesting an incentive from the requirement to construct and maintain the trails.

The applicant has requested an incentive under State Density Bonus Law (Government Code Section 65915) to waive the requirement to construct and maintain public trails.

Justification for this request is provided in the applicant’s Project Description and Letter of Justification (Exhibit 5), and additional justification is provided in Section E of this report.

B. Town’s Environmental Consultants Responses to Planning Commission Questions The project’s Initial Study/Mitigated Negative Declaration (IS/MND) was circulated by the Town of Los Gatos for public review from September 19, 2025, through October 8, 2025 (Exhibit 1). Following the public review period, the Town prepared responses to comments (Exhibit 13), and the project was considered by the Planning Commission on December 17, 2025.

During the Planning Commission meeting, environmental concerns were raised by Commissioners and summarized by Town staff. Those comments are addressed by the Town’s environmental consultant, Raney, in the Responses to Planning Commission Comments document included as Exhibit 37. A Recirculated IS/MND was circulated for public review from April 17, 2026, through May 18, 2026. The responses in Exhibit 37 refer to the Recirculated IS/MND (Exhibit 38), which is the current version of the environmental document.

Under CEQA Guidelines Sections 15073 and 15074, the Town is required to consider all comments received on the IS/MND; however, written responses are not required for a Mitigated Negative Declaration. At the Town’s request, Raney prepared written responses to the Planning Commission comments for the record.

Raney’s responses to Planning Commission questions are included in Exhibit 37 and are provided on the following page, followed by responses in italics.

ITEM NO. 1.

PAGE 6 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
• A Commissioner observed specific plants in special conditions in the field. No specific species were provided.

Raney’s Response: “It is unclear which specific plants and special conditions are being referred to in the comment. The project site contains many species of common plants, which are not protected, nor required to be analyzed pursuant to CEQA; only specialstatus plants require review under CEQA (page 42 of the IS/MND defines special-status plants). Potential impacts of the proposed project on special-status species, including special-status plant species, are addressed in Section IV, Biological Resources, of the Recirculated IS/MND. As noted on page 45 of the Recirculated IS/MND (Exhibit 38), the site only provides marginally suitable habitat for Santa Clara red ribbons and bentflowered fiddleneck. Full rare plant surveys in 2012 and 2013 during the various blooming periods, along with the ongoing disturbance associated with annual mowing for fire abatement, confirms that the site lacks suitable habitat for special-status plants.

Thus, the proposed project is not anticipated to result in adverse effects to special-status species and the conclusions of the Recirculated IS/MND remain adequate.” • Did the biologists map the vegetation and when? Where are the areas of soil saturation? Where is standing or seasonal water present? Where is the edge/boundary of these areas?
Raney’s Response: “A field survey of the project site was conducted by Live Oak Associates (LOA) on December 19, 2024, as part of the Biological Evaluation, to identify on-site habitats and to determine the likelihood of any occurrences of special-status species. An additional site visit was conducted on May 14, 2025, to confirm the characteristics of the on-site ephemeral feature. Further, as stated on page 7 of the Recirculated IS/MND (Exhibit 38), in response to public comments and input at the Planning Commission hearing, LOA conducted additional on-site field investigation of the ephemeral feature located on the project site on February 12, 2026, after a storm event when water was flowing in the on-site ephemeral feature. LOA’s follow-on assessment resulted in the determination that the northerly limits of the ephemeral feature extend into the proposed internal driveway and Lot 5 development footprint.” Also see responses to Comment 10 below. “Figures 15 and 16 of the Recirculated IS/MND show the on-site habitats, including on-site aquatic resources, as well as the 15-foot buffer (Exhibit 38, Figures 15 and16),” as mentioned in response to Comment 10 below. “Page 52 of the Recirculated IS/MND (Exhibit 38) states that the USACE jurisdiction only extends to the 342-square-foot (sf) concrete-lined drainage considered a seasonal wetland in the northwestern corner of the project site, and that the ephemeral stream is considered a water of the State under the jurisdiction of the RWQCB. The “ephemeral” classification indicates that the stream flows with water during or shortly after a rain event. The lack of a clear incised channel along the entire length of the ephemeral stream is a clear indication of the limited water flow most of the year.”

ITEM NO. 1.

PAGE 7 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
• Explain the origin and rationale for the proposed 10-foot buffer at the ephemeral swale. Identify and justify any areas where the buffer is less than 10 feet, including the criteria used and any supporting analysis.

Raney’s Response: “The 10-foot buffer shown on the project plans is proposed by the applicant and assumed to be based on Mitigation Measure 4.3-8 identified in the Draft EIR previously prepared for the project site, but was never certified by the Town.

Mitigation Measure 4.3-8 in the uncertified Draft EIR required a minimum riparian setback of 10 feet from the top of bank of the incised portion of the ephemeral swale and outer oak canopy edge. The buffer is inaccurate and unrelated to the updated analysis of biological resources, as presented in the Biological Evaluation prepared for the project by LOA and Recirculated IS/MND. As discussed on page 52 of the Recirculated IS/MND (Exhibit 38):

The on-site ephemeral feature historically supports water only during and shortly after storm events. The Town of Los Gatos follows the Guidelines and Standards for Land Use By Streams document (“Guidelines and Standards”).

The Town Council adopted a resolution implementing the Guidelines and Standards at its meeting on February 20, 2007. What had previously been identified in this IS/MND as an “ephemeral drainage” has portions with an incised channel and portions without. According to the definition of a stream in the Guidelines and Standards (Chapter 2, subsection E), only the portions of the feature having a channel meet the definition of a stream, and therefore, only those portions need a buffer. Notwithstanding, for purposes of this recirculated environmental document, the entire on-site feature will be referred to as an ephemeral stream.

Given that there is no riparian habitat associated with this ephemeral stream, the buffer is from the “top of bank” of the sections of the ephemeral stream where it has an incised channel. The Guidelines and Standards does not identify a stream or riparian setback per se; the only setback identified is a “Slope Stability Protection Area”, which is 10-15 feet for ephemeral streams with the addition of 5 feet for properties over 10,000 square feet. Although the Guidelines and Standards does not identify a stream or riparian setback, it is reasonable to use the Slope Stability Protection Area as a proxy. The habitat value of the ephemeral stream is low, as it only flows during and just after storms and does not support any wetlands; therefore, LOA has determined that a buffer of 15 feet would be reasonable to reduce the potential for impacts to this feature.

As further stated on page 53 of the Recirculated IS/MND (Exhibit 38) and shown on Figure 16 therein, the majority of the proposed project would be designed to avoid the

ITEM NO. 1.

PAGE 8 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
ephemeral stream and comply with the required 15-foot buffer from the “top of bank” of the incised channel sections of the ephemeral stream. The exception to this consists of the northerly extent of the ephemeral stream, which would be impacted by proposed construction activities associated with the internal roadway and the residential development on Lot 5. Such construction activities would require fill of the northern extent of the ephemeral stream, which is presumed to be a water of the State.

Therefore, the Recirculated IS/MND includes Mitigation Measures IV-10 and 11 to reduce the associated impact to a less-than-significant level.” • Explain the baseline used for the noise analysis.

Raney’s Response: “Under CEQA, the baseline is generally defined as the physical environmental conditions as they exist at that the time the Notice of Preparation for an EIR is published, or when the environmental analysis begins. Although the lead agency has the discretion to use a different baseline for a CEQA analysis, such as a defined historical condition of the site or where the existing conditions at a site are unrepresentative or tend to fluctuate, use of the physical conditions occurring at the time the environmental analysis begins is common practice. Thus, the baseline condition used throughout the analysis within the Recirculated IS/MND, including for the noise analysis, is the existing physical environmental conditions at the site.” • Describe how noise impacts will be mitigated if required.

Raney’s Response: Project impacts related to noise are addressed under Section XIII, Noise, of the Recirculated IS/MND. As discussed therein, the proposed project would not result in any significant impacts related to project operational noise. However, noise levels associated with project construction at the nearest existing single-family residences could exceed the applicable noise level standards. Thus, Mitigation Measure XIII-1 requires the implementation of construction equipment staging areas to create distance between construction-related noise sources and noise-sensitive receptors: use electric tools, which create less noise than non-electric; and use mobile construction equipment with smart back-up alarms, which automatically adjust their volume instead of using a fixed volume. Such measures are consistent with Mitigation Measure N-1 in the Town’s General Plan EIR and would reduce potential impacts related to construction noise to a less than-significant level.”
• Commissioners raised questions regarding the riparian habitat on-site. “According to LOA, riparian habitat is not present along the ephemeral stream based on the traditional definition from the U.S. Fish and Wildlife Service (USFWS), which is the standard definition for ecologists. The Regional Water Quality Board (RWQCB) uses an atypical and distinct, more inclusive definition of riparian vegetation. As noted on page

ITEM NO. 1.

PAGE 9 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
51, the Recirculated IS/MND relies on a more typical definition of riparian vegetation sourced from the USFWS. The full definition is as follows:

Riparian areas are plant communities contiguous to and affected by surface and subsurface hydrologic features of perennial or intermittent lotic and lentic water bodies (rivers, streams, lakes, or drainage ways). Riparian areas are usually transitional between wetland and upland. Riparian areas have one or both of the following characteristics:

1. Distinctly different vegetative species than adjacent areas.

2. Species similar to adjacent areas but exhibiting more vigorous or robust growth forms.

While a small area of the ephemeral stream (approximately 100 to 150 feet) at the terminus of the stream would be impacted by the project, no shrubs or trees along the length of the on-site ephemeral stream would be impacted. In other words, only upland herbaceous vegetation, away from the ephemeral stream, within the proposed development areas, would be impacted by the project. Therefore, even under the RWQCB’s more inclusive riparian definition, the conclusions presented in the Recirculated IS/MND would not change, as all of the shrubs and trees (e.g., RWQCB riparian) along the ephemeral stream would be retained after project buildout.

The ephemeral stream has previously been disclaimed by the U.S. Army Corps of Engineers (USACE) and under the new Water Rule based on the Supreme Court’s May 2023 Sackett Decision, will clearly disclaim it as a water of the U.S. in the future, as it lacks a continuous surface flow to a downstream navigable water. Accordingly, page 52 of the Recirculated IS/MND (Exhibit 38) states that the USACE jurisdiction only extends to the 342-square foot (sf) concrete-lined drainage considered a seasonal wetland in the northwestern corner of the project site, and that the ephemeral stream is considered a water of the State under the jurisdiction of the RWQCB and, as such, discharge of fill into the ephemeral stream is regulated by the RWQCB.

The following describes the additional on-site field investigation of the ephemeral feature and the revisions made to the IS/MND as a result as provided by Raney:
“The ’ephemeral’ classification indicates that the stream flows with water during or shortly after a rain event. The lack of a clear incised channel along the entire length of the ephemeral stream is a clear indication of the limited water flow most of the year.

Nonetheless, as stated on page 7 of the Recirculated IS/MND (Exhibit 38), in response to public comments and input at the Planning Commission hearing, LOA conducted additional on-site field investigation of the ephemeral feature located on the project site on February 12, 2026, after a storm event when water was flowing in the on-site

ITEM NO. 1.

PAGE 10 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
ephemeral feature. This follow-on assessment resulted in the determination that the northerly limits of the ephemeral feature extend into the proposed internal driveway and Lot 5 development footprint. As a result, consistent with CEQA Guidelines Section 15073.5, the IS/MND was revised and recirculated to identify a new potentially significant impact related to having a substantial adverse effect on aquatic features, and included new mitigation measures under question IV-b,c to reduce the newly identified impact to a less-than-significant level (Mitigation Measures IV-10 and -11).

The “Compensation” portion of Mitigation Measure IV-10 requires that the project mitigate impacts through the creation, restoration, and/or enhancement of habitat at one or more appropriate locations near impacted areas at a 1:1 minimum replacementto-loss ratio. Mitigation Measure IV-10 further notes that it is anticipated that all compensation measures can be accommodated on-site within the existing ephemeral stream, for which an important consideration is to remove the existing culvert in the upper area of the stream.”
• Commissioners raised questions regarding the study methodology and number of field visits for the Biological Evaluation. Questions were raised on whether the report relied on prior reports done by others over 10 years ago and if the report relied on the partial recirculated DEIR by Kimley-Horn in 2017.
“While the prior reports were considered as part of the preparation of the Biological Evaluation, contrary to the comment, LOA did in fact conduct their own, separate surveys of the site. A field survey of the project site was conducted on December 19, 2024, as part of the Biological Evaluation, to identify on-site habitats and to determine the likelihood of any occurrences of special-status species. An additional site visit was conducted on May 14, 2025, to confirm the characteristics of the on-site ephemeral feature, and in response to public comments and input at the Planning Commission hearing, including this comment, LOA conducted additional on-site field investigation of the ephemeral feature located on the project site on February 12, 2026, after a storm event when water was flowing in the on-site ephemeral feature. Additional surveys are not needed; the objective of a biological survey for CEQA review is not to compile a comprehensive list of every wildlife or plant species that occurs or may occur on a site.

Instead, the goal is to provide a description of existing biological resources (e.g., common and special-status plant and wildlife species, and waters of the U.S./State) and to identify potentially suitable habitats that may be impacted, and, thus, lead to impacts that could affect sensitive biological resources as a result of the proposed project, which is what was done in the IS/MND and is appropriate for the purpose of CEQA.”

ITEM NO. 1.

PAGE 11 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
C. Requested Incentives, Waivers, and Exceptions
The applicant was originally seeking the following four incentives under SDBL, as described below:

Requested Incentives
Not Installing Story Poles and Netting per the Visibility Analysis requirements of the Hillside Development Standards and Guidelines Project wide
Not Providing Sidewalks Project wide
Not Providing Trail Easement and Constructing Trail Project wide Not Providing Open Space Easements Project wide
The applicant is no longer seeking the incentives to waive the requirement to provide a private open space easement or to waive providing a trail easement. Instead, the applicant now proposes open space and public trail easements for Lots 1, 4, 5, 6, 8, 9, 10, 11, and 12, as depicted in Exhibit 35.

The applicant continues to request an incentive from constructing the trails. The applicant provides, “The project is overbudget already. So any dollar impact beyond where we stand today could prevent the project from being developed at the density proposed and the subsequent loss of three affordable units that are a part of the project. The design and construction of trails were never contemplated in the budget therefore under state housing law we are protected from this requirement being imposed. Because the Planning Commission asked us to look at it again and stated they would be satisfied with reserving area for future trails to be funded and built by other agencies, we undertook the effort and cost to design the trail easements per the exhibit.”
The applicant is now requesting three incentives under SDBL, where state law would allow up to five.

The legal framework for Senate Bill 330, Housing Accountability Act (HAA), SDBL, Builder’s Remedy and applicant’s requests for incentives, waivers, and exceptions are described in December 17, 2025, Planning Commission staff report.

The applicant submitted a Project Description Letter and Letter of Justification (Exhibit 5) describing the project and requested entitlements. Proposed development plans are included in Exhibits 15 through 27, as well as new Exhibits 35 (Open Space Easements and Future Trail Easements) and 36 (Lots 5 and 6 Vegetation Buffer).

ITEM NO. 1.

PAGE 12 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
D. CEQA Determination
The project’s Initial Study/Mitigated Negative Declaration (IS/MND) was circulated by the Town for public review from September 19, 2025, through October 8, 2025.

Following the public review period, the Town prepared responses to comments, and the project was considered by the Planning Commission on December 17, 2025.

In response to public comments and input at the Planning Commission hearing, LOA conducted an additional on-site field investigation of the ephemeral feature located on the project site on February 12, 2026, after a storm event when water was flowing in the on-site ephemeral feature. This follow-on assessment resulted in the determination that the northerly limits of the ephemeral feature extend into the proposed internal driveway and Lot 5 development footprint. As a result, consistent with CEQA Guidelines Section 15073.5, the IS/MND was revised and recirculated to identify a new potentially significant impact related to having a substantial adverse effect on aquatic features, and included new mitigation measures under question IV-b,c to reduce the newly identified impact to a lessthan-significant level (Mitigation Measures IV-10 and -11).

A Recirculated IS/MND was circulated for a 30-day public review from April 17, 2026, through May 18, 2026 (Exhibit 38).

Under CEQA Guidelines Sections 15073 and 15074, the Town is required to consider all comments received on the IS/MND; however, written responses are not required for a Mitigated Negative Declaration. At the Town’s request, Raney prepared written responses to comments received during the public review period as found in Exhibit 40.

The Recirculated Initial Study and Mitigated Negative Declaration concluded that the project will not have a significant impact on the environment with adoption of the Recirculated MND and Revised MMRP to mitigate potential impacts to a less-thansignificant level.

Each of the 21 mitigation measures identified in the Recirculated MND (III-1, IV-1, IV-2, IV-3, IV-4, IV-5, IV-6, IV-7, IV-8, IV-9, IV-10, IV-11, IV-12, V-1, V-2, V11-1, X-1, X111-1, X111-2, XVII1, and XVIII-1) are included in the Revised MMRP (Exhibit 39) and Revised Conditions of Approval (Exhibit 42).

PUBLIC COMMENTS:

Project identification signage was installed on the Twin Oaks Drive, Brooke Acres Drive, and Cerro Vista Court frontages by September 17, 2024, consistent with Town policy. Visual simulations were completed by the Town’s consultant and posted to the Town’s website by September 1, 2025 (Exhibit 10). Written notice was sent to property owners and tenants within

ITEM NO. 1.

PAGE 13 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
1,000 feet of the subject property and notice of public hearing signage was installed on the street frontages by May 29, 2026, in anticipation of the June 11, 2026, Planning Commission hearing.

Staff conducted outreach through the following media and social media resources, for the availability of the visual simulations; public review of the Recirculated Initial Study and MND; and notice of the public hearing:
• The Town’s website home page, What’s New;
• The Town’s Facebook page;
• The Town’s Twitter account;
• The Town’s Instagram account; and
• The Town’s NextDoor page.

Public comments received between 11:01 a.m., Wednesday, December 17, 2025, and 3:00 p.m., Friday, June 5, 2026, are included as Exhibit 43.

As part of the public comments, staff received a question regarding vector control review of the project’s proposed bio-retention ponds (Exhibit 43). Public Works staff provided the following response:
“The Town does not coordinate with Vector Control during review of bio-treatment basins, as they are designed to fully drain within 72 hours and therefore should not pose a significant mosquito risk. However, once constructed, the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) will coordinate with Vector Control as part of the annual reporting process to notify them of these new facilities. The Town of Los Gatos will include all newly installed bio-treatment areas in its Annual Stormwater Report, and SCVURPPP will share that information with Vector Control.” CONCLUSION:

A. Summary
The applicant is requesting approval for the subdivision of one lot into 12 lots with a Vesting Tentative map, construction of a new single-family residence on each lot, site work requiring a grading permit, and removal of large protected trees under SB 330 on a vacant property zoned RC, located at 178 Twin Oaks Drive.

As detailed above, the application was submitted and is being processed under SB 330. The applicant seeks approval for the proposed residential project utilizing both SDBL (CA Gov.

Code § 65915) and the Builder’s Remedy provisions under the HAA [CA Gov. Code § 65589.5

ITEM NO. 1.

PAGE 14 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
(d)(5)]. The project qualifies for five incentives and unlimited waivers under SDBL. The application meets the definition of a Builder’s Remedy project and the applicant has requested a number of exceptions to Town standards pursuant to Builder’s Remedy. The deviations from the Town’s standards included in the project are requested through both SDBL and Builder’s Remedy for which the applicant has provided justification summarized in the body of this report and in Exhibit 5.

B. Recommendation
With the revisions described in the staff report, Staff recommends that the Planning Commission consider the request and, if merit is found with the proposed project, forward a recommendation that the Town Council approve the Architecture and Site applications, Subdivision application, and Mitigated Negative Declaration application by taking the following actions:

1. Adopt the Recirculated Mitigated Negative Declaration (ND-25-001) and Recirculated Mitigation Monitoring and Reporting Program (Exhibits 38 and 39) and make the finding that the project, with adoption of the Recirculated Mitigated Negative Declaration and Recirculated Mitigation Monitoring and Reporting Program, will not have a significant effect on the environment per CEQA;

2. Make the finding that the project is consistent with the General Plan with the incentives and waivers requested pursuant to State Density Bonus Law and granting of the requested exceptions to the maximum allowed density pursuant to the Builder’s Remedy provision of the Housing Accountability Act (Exhibit 41);

3. Make the finding that the proposed project complies with Section 66474 of the State Subdivision Map Act with granting of the requested exceptions to Town standards pursuant to the Builder’s Remedy provision of the Housing Accountability Act and make affirmative findings to approve the subdivision (Exhibit 41);

4. As required for tentative or parcel maps approved in state responsibility areas (SRA) or very high fire hazard severity zones (VH), findings are required to be made to the State Board of Forestry and Fire Protection (Board) pursuant to 14 CCR Section 1266.02 (Exhibit 41);

5. Make the finding that the project meets the objective standards of Chapter 29 of the Town Code (Zoning Regulations) with the incentives and waivers requested pursuant to State Density Bonus Law and granting of the requested exceptions to Town standards pursuant to the Builder’s Remedy provision of the Housing Accountability Act (Exhibit 41);

6. Make the finding that the project complies with the Hillside Development Standards and Guidelines with granting of the requested exceptions to Town standards pursuant to the Builder’s Remedy provision of the Housing Accountability Act (Exhibit 41);

7. Make the finding that the project complies with the Hillside Specific Plan with the incentives and waivers requested pursuant to State Density Bonus Law and granting of

ITEM NO. 1.

PAGE 15 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026
the requested exceptions to Town standards pursuant to the Builder’s Remedy provision of the Housing Accountability Act (Exhibit 41);

8. Make the affirmative findings as required by State Density Bonus Law for granting an incentive pursuant to California Government Code Section 65915 (d) and for granting waivers pursuant to California Government Code Section 65915 (a)(2) (Exhibit 41);

9. Make the finding that, as required by California Government Code Section 65589.5 (d) of the California Housing Accountability Act, none of the findings for denial of a Builder’s Remedy project can be made (Exhibit 41);

10. Make the considerations as required by Section 29.20.150 of the Town Code for granting approval of an Architecture and Site application (Exhibit 41); and

11. Approve Architecture and Site Applications S-24-023 through S-24-033 and S-24-059, Subdivision Application M-24-023, and Recirculated Mitigated Negative Declaration Application ND-25-001 with the recommended revised conditions contained in Exhibit 42 and the development plans in Exhibits 15 through 27, Exhibit 35, and Exhibit 36.

C. Alternatives
Alternatively, the Planning Commission can:

1. Continue the matter to a date certain with specific direction; or

2. Approve the applications with additional and/or modified conditions; or

3. Deny the applications.

EXHIBITS:

Previously Received with the December 12, 2025, Staff Report:

1. Initial Study and Mitigated Negative Declaration with Appendices A through E (available online at https://www.losgatosca.gov/178TwinOaksDr)

2. Required Findings and Considerations

3. Recommended Conditions of Approval – M-24-013, S-24-023 to -033 and S-24-059

4. Location Map

5. Project Description and Letter of Justification

6. Consulting Architect’s Report

7. Applicant’s Response to Consulting Architect’s Report

8. Final Arborist Report

9. Consulting Arborist’s Peer Review

10. Visual Renderings

11. Public comments received by 11:00 a.m., Friday, December 12, 2025

12. Mitigation Monitoring and Reporting Program

13. Public Comments and Responses Regarding the Mitigated Negative Declaration

14. Initial Study/ Mitigated Negative Declaration Errata Sheet

ITEM NO. 1.

PAGE 16 OF 16
SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001
DATE: June 5, 2026

15. Development Plans – Subdivision

16. Development Plans – Lot 1

17. Development Plans – Lot 2

18. Development Plans – Lot 3

19. Development Plans – Lot 4

20. Development Plans – Lot 5

21. Development Plans – Lot 6

22. Development Plans – Lot 7

23. Development Plans – Lot 8

24. Development Plans – Lot 9

25. Development Plans – Lot 10

26. Development Plans – Lot 11

27. Development Plans – Lot 12
Previously Received with the December 15, 2025, Addendum Report:

28. Public comments received between 11:01 a.m., Friday, December 12, 2025, and 11:00 a.m., Monday, December 15, 2025
Previously Received with the December 16, 2025, Addendum 2 Report:

29. Responses to the Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter

30. Public comments received between 11:01 a.m., Monday, December 15, 2025, and 11:00 a.m., Tuesday, December 16, 2025
Previously Received with the December 17, 2025, Desk Item Report:

31. Public comments received between 11:01 a.m., Tuesday, December 16, 2025, and 11:00 a.m., Wednesday, December 17, 2025
Received with the June 11, 2026, Staff Report:

32. Planning Commission Meeting Minutes, December 17, 2025

33. Applicant’s Response to December 17, 2026, Planning Commission Comments

34. Technical Note, Belgard Pavers Fire Truck Loading

35. Open Space Easements and Future Trial Easements

36. Lots 5 and 6 Vegetation Buffer

37. Raney’s Response to December 17, 2026, Planning Commission Comments

38. Recirculated Initial Study and Mitigated Negative Declaration with Appendices A through F (available online at https://www.losgatosca.gov/178TwinOaksDr)

39. Recirculated Mitigation Monitoring and Reporting Program

40. Public Comments and Responses Regarding the Recirculated Mitigated Negative Declaration

41. Revised Required Findings and Considerations

42. Revised Recommended Conditions of Approval – M-24-013, S-24-023 to -033 and S-24-059

43. Public comments received between 11:01 a.m., Wednesday, December 17, 2025, and 3:00 p.m., Friday, June 5, 2026

ITEM NO. 1.
110 E. Main Street Los Gatos, CA 95030 ● 408-354-6832
www.losgatosca.gov

TOWN OF LOS GATOS

PLANNING COMMISSION
REPORT

MINUTES OF THE SPECIAL PLANNING COMMISSION MEETING
DECEMBER 17, 2025
The Planning Commission of the Town of Los Gatos conducted a Special Meeting on Wednesday, December 17, 2025, at 7:00 p.m.

MEETING CALLED TO ORDER AT 7:00 PM

ROLL CALL

Present: Chair Emily Thomas, Vice Chair Kendra Burch, Commissioner Susan Burnett, Commissioner Steve Raspe, Commissioner Joseph Sordi

Absent: Commissioner Jeffrey Barnett (recused), Commissioner Rob Stump Chair Thomas indicated that Commissioner Barnett was recused from participation in the public hearing regarding Item 1, 178 Twin Oak Drive, due to his residence’s proximity to the subject site.

PLEDGE OF ALLEGIANCE

VERBAL COMMUNICATIONS
Anonymous
Touched on potential legal issues pertaining to projects on the hillside.

PUBLIC HEARINGS

1. 178 Twin Oaks Drive
Architecture and Site Applications S-24-023 through -032, and S-24-059 Vesting Tentative Map Application M-24-013
Mitigated Negative Declaration Application ND-25-001
APN 532-16-006
Property Owner/Applicant: Larry Dodge
Project Planner: Erin Walters
Consider a request for approval for the subdivision of one lot into twelve lots with a Vesting Tentative Map, construction of a new single-family residence on each lot, site work requiring a Grading permit, and removal of large, protected trees under Senate Bill 330 (SB 330) on vacant property zoned RC. An Initial Study and Mitigated Negative Declaration have been prepared.

EXHIBIT 32

ITEM NO. 1.

PAGE 2 OF 6
MINUTES OF PLANNING COMMISSION SPECIAL MEETING OF DECEMBER 17, 2025 Chair Thomas disclosed that she is familiar with the area and has friends who live in the neighborhood, but it would not prevent her from making an impartial decision on the matter.

Erin Walters, Senior Planner, presented the staff report.

Gabrielle Whelen, Town Attorney, provided a presentation on the regulatory framework.

Opened Public Comment.

Jim Foley
- A similar project came before the Town Council in 2018 that was denied because the property was in the Williamson Act, but that expired in January 2025 and the project is now before the Planning Commission. This project would bring some of the first new affordable units for sale to Los Gatos since Bellaterra at North Forty, and every unit counts toward Los Gatos’ Housing Element. We could have proposed a much denser project and abused the Builder’s Remedy, but that is not the Dodge family’s intent. We have strived to comply with as many of the various potentially applicable development standards that could have been in place for the project zoning. We also considered many public comments including road alignment, home orientation, headlight pollution, etc. There was tremendous additional study and updating of the technical reports and studies that added to the anticipated application preparation time.

Cindy Clark
- I live at 16326 West La Chiquita Avenue. I will make two points in opposition to the development plans: 1) Builder’s Remedy and SB 330 are about building more housing, yet the developer is asking to use 17 acres of rare, wooded land to build three token below market homes, and nine giant homes. These are homes for the very rich to be used as second or third homes and an investment opportunity; and 2) If the development proceeds, the Town should deny permits to remove the 223 protected trees that are not at all replaceable, are considered keystone species, and are vital to a healthy ecosystem in Los Gatos.

Gus Who
- The public would want a road connected, because there is a lot of traffic, so it would be better to have a loop in the two roads instead of the one. Another thing was when I built, I designed a 3,500-square foot house and it was too small for the neighborhood and I had to double it. You can probably limit the size of the house. It’s 14 acres, so you can probably up it a couple houses, but a loop around there for safety reasons would be the most important thing. Even if nobody builds there, you should have a road connecting that high up, to try to work a deal with the builders. A road between the two for safety issues is my biggest concern.

ITEM NO. 1.

PAGE 3 OF 6
MINUTES OF PLANNING COMMISSION SPECIAL MEETING OF DECEMBER 17, 2025 John Witkin
- I live at 188 Twin Oaks Drive, next door to the development. That hillside, with an oak forest and a Ross Creek feeder stream at the base, is not feasible for a subdivision for multiple home tracts. Similar developments in California have all had issues, because when we cut down 250 trees, move 200 loads of dirt, and pave over a riparian corridor, what can we anticipate? Last year the hillside was recategorized as a high fire danger zone, and eventually we will have a flood, earthquake, or fire and these altered landscapes will fail and we will experience landslides, massive property damage, and a major safety hazard. It is not safe to build these structures and it will not reduce any of the housing crisis in California. We need existing open space to remain in order to keep Los Gatos beautiful.

Bill Meleyco
- I live at 189 Longmeadow Drive, adjacent to the proposed project at the border with Hillbrook School. Our major concern is privacy, trees, noise, and the drainage. These new homes would look down into our backyard and windows. There is a discrepancy between the applicant’s rendering that shows 35 new trees being installed, but the plans show them installing only seven trees. They are removing six protected trees along the properly line with Hillbrook that do not interfere with the construction, or anything. From a privacy standpoint, we request the Planning Commission to require the developer to add these 35 trees. Hillbrook’s noise studies, done for it to receive a CUP, stated the sound level at our home was at the threshold of unacceptable. The cumulative effect of Hillbrook and the proposed houses would put the sound above an unacceptable level. This hillside drains entirely towards our property, and the catch basin at the corner will overflow with the drainage created by the project.

Monica Herzi
- I live at 185 Longmeadow Drive, three houses from the proposed development and facing Twin Oaks Drive. Proposals like this one tend to keep people from retiring here. From my home I have seen owls, coyotes, deer, rabbits, foxes, turkeys, hawks, etc., and that will all go away with this project. California needs affordable housing, but I agree with the former speakers who asked if these houses will be second homes. Will they produce ADUs on each site, or will they be subdivided and sold as individual lots? I also worry about safety and the limited access to the site.

Jill Fordyce
- I live at 191 Longmeadow Drive. When we bought our property in 1999 the Town staff told us the subject site was resource conservation space that would not likely be developed in our lifetimes. Now we face a new reality, it is no long resource conservation space, there are Builder’s Remedy laws, and loss of the Williamson Act protection. I request the project be denied, because it would result in adverse impacts such as wildfire and evacuation; erosion causing mudslides and landslides on the project site; and flooding, water quality degradation and pollution; and harms associated with the proposed bioretention plan.

ITEM NO. 1.

PAGE 4 OF 6
MINUTES OF PLANNING COMMISSION SPECIAL MEETING OF DECEMBER 17, 2025 These risks are acknowledged in the Negative Declaration, but the mitigation of each is vague, uncertain, deferred, and potentially unenforceable.

Craig Fordyce
- I also live at 191 Longmeadow Drive. In our opinion, an EIR is required, as we have not been given necessary information to understand the environmental impact of the proposed development. The Mitigated Negative Declaration approach suggests environmental review is secondary to entitlement, which is legally incorrect. The MND relies on an outdated, uncertified EIR from 2017. The proposal is not the same as the one considered in 2018, with a key difference being the 13 percent increase of the scope of development, as well as different lots, number of homes, home sites, and ingress and egress. An uncertified EIR cannot legally be relied upon for the adoption of an MND. The Sierra Club, the Santa Clara Valley Bird Alliance, and the San Francisco Regional Bay Regional Water Control Board each site multiple issues not addressed by the MND that may have significant environmental impacts.

Chris Bayoric
- I live at 120 Clover Way near the proposed development. My main concern is the development exceeds the drainage capability of that land. The mitigating requests are to build at least three bioretention basins, basically wetlands, or ponds, to catch the effluence from that drainage of that property, and ponds are a health concern with the presence of West Nile Virus in our community and the fact that ponds breed mosquitos that transfer the virus. My second concern is the proposal is vague regarding who is going to be responsible for maintaining those wetlands, the Town or owner. The scope of this development must be downsized to avoid dependence on these wetlands.

Lee Quintana
- I am here not to speak on the project, but to speak on the environmental review, relying on 15 years of experience working for the City of San Jose doing environmental review. Two things paramount in project review: 1) Provide decision makers with information to make informed decisions as to significant impacts and mitigation to those impacts; and 2) Make documents bulletproof, meaning to achieve the first purpose and provide all the studies and information before a document is released. In this case, there is an incompleteness in those studies, deferred mitigation, and lack of consultation with agencies having jurisdiction over Los Gatos lands. Conducting studies and consultations after approving a project limits what can be done, and full mitigation may not be achieved, so it is important to have those studies up front, and for that reason I would not support approving the Mitigated Negative Declaration.

Jan Schwartz
- I live at 15966 Cerro Vista Drive on the other side of the hill. We will have one or two houses on our side, more will be on the other side, and I am concerned for my neighbors regarding flooding, landslides, and mosquitoes, which are significant risks. My concern is

ITEM NO. 1.

PAGE 5 OF 6
MINUTES OF PLANNING COMMISSION SPECIAL MEETING OF DECEMBER 17, 2025 also for the abundant wildlife we have here that will disappear. I love Los Gatos, but I know progress moves on with the North Forty and other developments, but I hope we can maintain the wildlife and riparian corridor near the property that we have right now.

Anne Griffin
- I have had the back yard of my home flooded by Ross Creek twice, and I live up the road from the subject site. My concern is safety. Twin Oaks Drive, Clover Way, and Blueberry Hill Drive travel onto Longmeadow to exit. We would be adding two cars to every home, most of which will go through Longmeadow. During the day there are service trucks and cars parked on the street, as well kids riding bikes, and people walking dogs. I am concerned about safety because I would like an emergency vehicle to be able to come to my home if I should need it.

Jim Foley
- There is extensive language in the conditions of approval regarding best practices for safety, access during construction, etc. The bioretention areas are engineered and widely accepted, have all gone through the process. There are many requirements in the conditions of approval for who is going to manage CC&Rs, ongoing access review, and proactive reporting to the Town, so how we created that and the drainage for the neighborhood was well thought out. Regarding wildlife concerns, we still have the ephemeral swale through the site. It is the main feature where you will find wildlife and protected areas, and there is still a lot of that being preserved with this project. A lot of effort went into the EIR. Raney Planning Management took prior and new information, updated, and ensured all the technical studies were adequate.

Reopened Public Comment
Question to applicant followed.

Reclosed Public Comment.

Commissioners discussed the matter.

MOTION: Motion by Vice Chair Burch to continue the public hearing for 178 Twin Oaks Drive to a date uncertain. Seconded by Commissioner Raspe.

VOTE: Motion passed unanimously.

ITEM NO. 1.

PAGE 6 OF 6
MINUTES OF PLANNING COMMISSION SPECIAL MEETING OF DECEMBER 17, 2025

ADJOURNMENT
The meeting adjourned at 10:42 p.m.

This is to certify that the foregoing is a true
and correct copy of the minutes of the
December 17, 2025 meeting as approved by the
Planning Commission.
_____________________________
/s/ Vicki Blandin

ITEM NO. 1.

SUCCESS BUILT ON SERVICE, QUALITY, & COMMITMENT
SINCE 1976
1570 OAKLAND ROAD SAN JOSE, CA 95131 | 408-487-2200 | HMHCA.COM | HMHLASTUDIO.COM planning ● civil engineering ● public works ● landscape architecture ● land surveying February 21, 2026
Re: Surrey Farms – Planning Commission Hearing Comments – Narrative Response HMH Project Number: 4185.10
The following is a narrative response to the 2025-12-17 Planning Commission Hearing comments:
• PC Hearing Comment: Site Visit - Is the applicant willing to stake the site and delineate the roadway and/or property corners prior to a site visit? o Response: yes, the applicant is currently scheduling a survey crew the beginning of January 2026 to provide construction staking for locations of pertinent relevance for the proposed project.
• PC Hearing Comment: Ross Creek & Stormwater
o Plans indicate stormwater discharge into Ross Creek
 Response: The existing conditions of the site are currently draining to Ross Creek. The proposed site design measures do not delineate from draining to Ross Creek. With that said, the proposed site design measure improves the drainage pattern with a series of C3-mandated stormwater treatment measures (i.e. biotreatment basins, underground storm drain system and pervious pavers – with check dams) and hydromodification measures that capture, treat, detain and release stormwater at postdevelopment levels no greater than pre-development levels. In Summary the proposed improvements do not impact ross creek more than the existing condition.
o What are the anticipated impacts to the creek, and how are they being mitigated?  Response: There will be no negative impacts to Ross Creek because of the proposed design. As previously noted, the existing site drains to Ross Creek. Proposed site design measures will not increase the stormwater drainage to Ross Creek from pre-development levels. The proposed C3 and Hydromodification measures for the project will have a positive impact to Ross Creek.
• PC Hearing Comment: Pervious Concrete
o Provide experience with pervious concrete.
 Response: The design team has incorporated pervious pavers/concrete into numerous successful projects, including City of San Jose, City of Santa Clara and Town of Los Gatos as it is an acceptable common practice to achieve C3 compliance (stormwater treatment) per SCVURPPP standards. Additionally, pervious paver/concrete is widely accepted by local fire agencies including City of San Jose, City of Santa Clara and Town of Los Gatos. Santa Clara County Fire Department has provided approval for pervious paver use for this project o Demonstrate its ability to support weight loads, including emergency vehicles.

ITEM NO. 1.
 Response: As noted on our Fire Access Plan sheet in all our submittals, “All Fire Department access roadways including the private street, driveways and emergency access shall be an all-weather surface designed to support the imposed load of 75,000 pounds”. This weight is widely acceptable to local Fire Dept. agencies, including Santa Clara County Fire Department. A manufacturer specification sheet is included as a product sample that meets the weight load requirements. A Pervious paver detail – with check dams - is also included in our plan sets. A supplemental spec showing pervious pavers compliant to the required loading is has been provided to the town staff.
o Address long-term maintenance requirements.
 Response: Per the SCVURPPP C3 Guidelines, a Routine Maintenance Activity Schedule is to be followed for the pervious pavers/pavement. This schedule is included in our plan set (Stormwater Control Hydromodification Details sheet). The specific maintenance action items will be done by the owners of the individual lots for not only their lots but also the private street where pervious pavers are being proposed.

Enforcement of said activities will be conveyed through project CC&R documents as well as the Operations and Maintenance Agreement with the Town.
• PC Hearing comment: Flooding and Drainage
o Provide additional information on existing flooding of neighboring properties. • Response: It is our understanding from the project topography that the existing site surface drains down the hill ultimately into the ephemeral creek, or will continues down hill to and existing earth swale that directs storm drain runoff to existing storm drain inlets.
o Explain how the proposed drainage design addresses these issues, particularly along Lots 4 and 5.
 Response: The proposed drainage design introduces multiple measures strategically located throughout the project site. Bioretention basins are located on each Lot and pervious pavers/concrete is being proposed for some Lot driveways and a portion of the private street. These proposed design measures capture the downhill surface drainage, detain it, provide water quality treatment, and provide flow-duration control (as described in the BAHM report prepared by Balance Hydrologics) which addresses the hydromodification management for the project site. Overall, these proposed measures drastically reduce the amount of surface drainage for the site which will greatly benefit the downhill adjacent property owners by capturing the stormwater runoff sooner and directing it to and underground storm drain system. A series of proposed terraced retaining walls along the west side of Lots 4 & 5 will provide additional remediation measures for the said property owners. The small area of landscape between the western-most retaining wall and the property line will be hydroseeded per guidelines to provide a binding measure of the soil to reduce runoff. Due to Fire Department requirements pertaining to tree density, adding more trees in this area is not allowable. • PC Hearing comment: Open Space Easement and Trails- Feasibility and Cost o Applicant to clarify whether open space easement and/or trails or trail easements can be implemented in the proposed project.

ITEM NO. 1.
• Please see new exhibit depicting proposed open space and trail easements.
o If the applicant’s position is that open space easement and/or trails or trail easements are cost-prohibitive, provide detailed cost estimates so the Planning Commission can evaluate that position
 Please see new exhibit depicting proposed open space and trail easements.
• PC Hearing comment: Trees and Privacy
o Address privacy concerns through tree placement and buffering with native species.
 Response: HMH can add shrubs and propose trees to create a stronger vegetative buffer in the area discussed. Please reference updated lot 5 & 6 planting plan.
• PC Hearing comment: Trails – Alternative Options
o Encourage the applicant to consider alternative trail options. o The existing trail alignment may be challenging and costly due to lot crossings, slope, and the need for off-site easements.
o Consider alternatives such as:
o Routing through Brook Acres
o Adding a pedestrian easement over the EVA and providing a connection to Twin Oaks
 Please see new exhibit depicting proposed open space and trail easements.

Additionally, please review the HMH memorandum illustrating our narrative responses to the last comments received from the third-party C3 reviewer as well as the BAHM report prepared by Balance Hydrologics, which addresses hydromodification management for the proposed site. Site runoff will be directed to one of nine proposed bioretention basins that provide both water quality treatment and flow-duration control. Each bioretention area has been designed in accordance with the standard design criteria outlined in the SCVURPPP C.3 Stormwater Handbook.

Each facility is modeled with 6 inches of surface ponding, 18 inches of biotreatment soil media, and 12 inches of drain rock. A 4-inch underdrain will collect the treated water, which will then be metered through a 2-inch orifice integrated into the storm drain overflow structure. The 2-inch orifice is required to meet the hydromodification management criteria. Again, for additional details, refer to the “Summary of BAHM Modeling for the Surrey Farms Project, Town of Los Gatos” report dated July 31, 2025.

End of Narrative Response

ITEM NO. 1.

This Page
Intentionally
Left Blank

ITEM NO. 1.

Technical Note
A common question posed by design professionals is the ability of interlocking concrete pavers (ICPs) and permeable interlocking concrete pavers (PICPs) to withstand fire truck loading. This is due to the relatively large axle weights they exert along with the fact that fire trucks are critical service vehicles that must be able to access sites in emergency situations.

In terms of structural design for entry, access lane and roadway applications, pavements must be designed to resist rutting, bearing capacity of the supporting pavement system and resistance to repeated axle load applications. Pavement design procedures typically utilize information which describe the strength of the subgrade soils, axle loadings and frequency, and strength of the various layered pavement components. The actual design procedures for flexible and rigid pavements are well documented in Civil Engineering texts with ICPs & PICPs well recognized to behave and follow the design procedures set forth for “flexible” pavement design. References for ICP and PICP pavement design are provided in this Technical Note (AASHTO 1993, ASCE 2016 & 2018, Caltrans 2016).

While not a comprehensive primer on pavement design, the focus of this report is to demonstrate that ICP and PICPs are not adversely affected by heavily loaded vehicles and are suitable for use in vehicular areas exposed to fire truck loadings. The primary discussion herein will focus on fire truck loadings on ICP/PICP systems as they relate to:
• Design ESALs applied to the pavement system.
• Fire truck wheel and axle loads relative to the strength of the paver • Point loads that may occur when the stabilizer outriggers are in place.

Because this document focuses on fire truck loading, data on a typical heavily loaded fire truck was obtained for a “ladder truck” used by the City of Scottsdale, AZ. The vehicle chosen is one of the heaviest vehicle in a typical Fire Department’s fleet and is considered on the upper end of the fire vehicle loading spectrum. A few images of the vehicle and its characteristics are provided below:

Ladder Engine: Pierce Manufacturing ID Decal; GVWR - 76,800 lbs.

GAWR – Front = 22,800 lbs. = 11,400 lbs./tire:

GAWR - Rear = 54,000 lbs. = 27,000 lbs./axle; 6750 lbs./tire Cold Tire Inflation Pressure – 120 psi (single and dual) Max Load per Single Tire – 11,400 lbs.

DESIGN CONSIDERATIONS FOR CONCRETE

PAVER SURFACED ACCESS LANES -

SUBJECTED TO FIRE TRUCK LOADING
DESIGN ESALs
Structural Pavement Section function of
Subgrade Strength, Traffic Loadings and
Strength of Pavement Section Components
Design references have been developed by
several credible organizations including
AASHTO, ASCE and Caltrans as shown below.

In almost all cases, the design guidelines for
the structural aspects of the pavements are
based on the 1993 AASHTO Guide for Design
of Pavement Structures (AASHTO 1993). As
with the design references for ICP and PICPs,
the 1993 AASHTO document calculates the
thickness of a roadway cross section required
to withstand the applied loads for the given
lifespan based on the native soils strength and
traffic loading. The supporting soil strength is
typically described by a CBR value (California
Bearing Ratio), Mr (Resilient Modulus), R-value
or some other geotechnical measurement
describing the strength of the supporting soil.

The traffic loading is typically described by
TI (Traffic Index), ESALs (Equivalent Single
Axle Loads) or other measurement to express
the traffic type and equivalent damage (VLF,
Vehicle Load Factor) created by each type
of vehicle as compared to the passage of
a “standard” 18,000-pound axle load (one
18,000 lb. ESAL provides a unit value of 1.0).

For perspective on ESALs, passenger cars
have a Vehicle Load Factor (VLF) of 0.0004
EXHIBIT 34

ITEM NO. 1.

Technical Note

DESIGN CONSIDERATIONS FOR CONCRETE PAVER SURFACED

ACCESS LANES - SUBJECTED TO FIRE TRUCK LOADING
whereas a fully loaded fire truck as shown above would have a VLF of about 10. Hence, it would take over 20,000 cars to affect the same level of deterioration on the pavement as 1 pass of a fire ladder truck. It should be noted that not all fire trucks exhibit this same degradational effect on pavements as most are lighter and exhibit considerably lower axle loads than the Ladder Truck which has a GVWR (Gross Vehicle Weight Rating) of 76,800 lbs.

Although it is evident by the VLFs shown above that fire trucks can exert high ESALs on the pavement surface, it is important to note that typical roads are designed around hundreds of thousands of ESALs, so the impact of the occasional fire truck is relatively small on those pavements. Notable in the design procedure is that the axle/tire loads applied to the completed pavement system is transferred through the pavement to the subgrade via a series of structural layers which distribute the vehicle loads to a relatively large area of the subgrade. The distribution of the loads through the pavement system enables relatively weak subgrades to support very high concentrated axle/wheel loads much like a snowshoe or wide tracks of low ground pressure vehicles to traverse low strength materials which would otherwise not support the weight of applied loads.

Along those same lines, pavement design isn’t so much about how much a vehicle weighs but rather the load transfer of axle loads through the pavement system and how many passes can be achieved prior to development of unacceptable rutting or excessive pavement deterioration.

To further expand on this subject, pavement sections for standard asphaltic concrete (AC) and aggregate base systems and interlocking concrete pavement (ICP) systems are essentially identical in thickness with the wearing course being the primary difference in the systems. In essence, an 80mm (3-1/8”) thick paver laid on 1” of bedding sand provides a structural number of 1.82 for the pavement layer which is the same as 4-1/8” of asphaltic concrete having a layer coefficient of 0.44/inch (0.44 x 4-1/8 = 1.82). Therefore, a 101.6 mm (4”) thick paver laid on 1” of bedding sand provides a structural number of 2.20 for the pavement layer, which is comparable to 5” of asphaltic concrete. The aggregate base and subbase section used to distribute the wearing course loads provide the same support to either an AC or ICP system. The above analogy can be verified by comparing section thicknesses for designs done in accordance with AASHTO (AASHTO 1993) and ICPI (ICPI 2011) or ASCE (ASCE 2016) methods.

Permeable Interlocking Concrete Pavement systems (PICPs) employ essentially the same wearing surface (typically an 80mm paver underlain by 2” of No. 8 stone) and open graded load transfer/water storage/
conveyance layer aggregate (No. 57 and No. 2
stone). Because of the introduction of water
and the somewhat less dense structure of
the base layers, a somewhat lower structural
coefficient is employed for the components
that make up the PICP system than what is
used for conventional ICP systems, but the
design concept is identical.

TIRE CONTACT PRESSURES
In terms of being able to withstand the
surface pressure exerted by fire truck tires,
the gross axle weight rating (GAWR) on a
two tire (steering) axle and tandem axle
(rear axles) for the 76,800 lb. fire truck
referenced above is 22,800 lbs. and 54,000
lbs., respectively. Each tire is rated at a max
load rating of 11,400 lbs. at a cold inflation
tire pressure of 120 psi. By definition, the
maximum applied contact pressure is then
120-psi.

Any concrete paver offered under the
Belgard line is made in accordance with
ASTM C936, which requires an average
compressive strength of 8,000 psi with
no individual unit being less than 7,200
psi. So, simply put, the pavers are on
average 8000/120 > 60 times stronger in
compression than required to withstand
the surface pressure that would be exerted
under the extreme loading conditions
imposed by a fire truck.

POINT LOADS
When the stabilizer outriggers are in place,
a point load of as much as 45,000 pounds
can be applied to the pavement surface.

Although significant, when distributed over
an “un-factored” stabilizer plate surface
area of 0.97 square feet (area of 10x14
inches), this equates to a surface pressure
of 322 psi, which again is well within the
compressive strength capabilities of
Belgard pavers.

PAVER DAMAGE
As a final thought, should one or more
pavers become damaged, individual units
can be removed and replaced without
compromising the structural integrity of
the system (instruction manual available
ICPI -Permeable Interlocking upon request). Concrete PavementsCaltrans – Porous Pavement Design Guidance

ITEM NO. 1.

Technical Note

DESIGN CONSIDERATIONS FOR CONCRETE PAVER SURFACED

ACCESS LANES - SUBJECTED TO FIRE TRUCK LOADING

EXAMPLE PROJECTS
In order to demonstrate the acceptance of Belgard pavers in the local market, a sample list of permeable interlocking concrete paver (PICP) installations is provided. The list includes project from CA which are in fire access lanes and subject to heavy vehicle loadings. Similar lists are available for ICPs upon request.
• Shearwater Creek Townhomes 72,000 SF | Pujol St, Temecula / Entrances and interior streets – Fire Truck rated • Villa Catalina Condos 4,100 SF | 616 Catalina Ave, Redondo Beach – Entrance and shared motor courtyard – Fire truck rated • Villa Catalina Condos 5,600 SF | 618 Catalina Ave, Redondo Beach – entrance and shared motor courtyard – Fire truck rated • Hilton Garden Inn 5,700 SF | 4216 El Camino Real, Palo Alto – Entrance Fire truck rated • Buffalo Wild Wings 7,900 SF | 845 East Ave, Chico – parking Fire truck rated • Tahizzle Communities 7,600 SF | Truckee, Tahoe
• San Jose Downtown Health Center 12,000 SF | 777 E Santa Clara St, San Jose – Drive Entrance/Parking areas/Travel Lanes • Wisdom Way 8,900 SF | 1898 Wisdom Way, Modesto – Parking Lot with Heavy Vehicle Access • Avanti 64,000 SF | 23600 Park Sorrento Calabasas – Entrances and interior streets – Fire Truck rated • Wren Avenue & Byer St. Pedestrian Crosswalk 9,000 SF | Wren Ave. & Byer St, Gilroy – Street crosswalks – Fire truck rated • Vista Rio Apartments 46,000 SF | 3901 Briggs St, Jurupa Valley – Entrances and interior streets – Fire truck rated • Siena Apartments 69,000 SF | 7801 Juniper Ave, Fontana – Entrances and interior streets – Fire truck rated. • 4100 Del Rey Apartments 7,600 SF | 4100 Del Rey Ave, Marina Del Rey – Parking areas – Fire truck rated. • Fountain Valley Town Center 6,500 SF | Fountain Valley – Parking/Fire Truck Rated • Aldi Store #19 6,200 SF | 112 Lakewood Blvd, Downey – Parking Lot/Drive Entrances • Chick Fil A Restaurant 3,200 SF | 3771 E Thousand oaks Blvd, Thousand Oaks – Parking areas – Fire truck rated • ColRich Camel Row 24,000 SF | Camel Country Rd & Camel Mtn. Rd, San Diego – Community Roadways – Fire Truck Rated • San Leandro Tech Campus 10,000 SF | 1333 Martinez, San Leandro – Entrance to University Parking Lot/Heavy Traffic/Entrance to Parking Garage
• Gateway Shopping Center / Sprouts Market 20,000 SF | 1300 Pinole Valley Rd, Pinole – Shopping Center Entrance/Parking/Drive Aisles • Bardis Homes – 60,000 SF | Sacramento, CA – Entrances, Streets all pavements through-out new residential development – Fire Truck Rated. • Northwest Land Park – 90,000 SF | Sacramento, CA – Community Entrances, streets and drive lanes of new housing development – Fire Truck Rated.
• Calvin Christian Church – 6,000 SF | Escondido – Fire Lane access to rear of building.

REFERENCES

1. AASHTO 1993. Guide for Design of Pavement Structures, American Association of State Highway and Transportation Officials, Washington, DC.

2. ASCE 2016. Structural Design of Interlocking Concrete Pavement for Municipal Streets and Roadways, ASCE/T&DI/ICPI Standard 58-16, American Society of Civil Engineers, Reston , VA.

3. Caltrans 2016. Pervious Pavement Design Guidance, California Department of Transportation, Division of Design, Office of Storm Water Management, Sacramento, CA.

4. ICPI 2011. Permeable Interlocking Concrete Pavements, Fourth Edition, interlocking Concrete Pavement Institute, Herndon, VA.

5. UC Davis 2010. Research Report – Laboratory Testing and Modeling for Structural Performance of Fully Permeable Pavements Under Heavy Traffic: Final Report, U.C. Davis, Department of Civil and Environmental Engineering (CTSW-RT-10-249.04), Davis, CA. © Copyright 2021 Oldcastle APG, Inc. All Rights Reserved. BELCOMM21-016 The information set forth herein is for general informational purposes only. All such information is provided in good faith, however Oldcastle APG, Inc. and its affiliates make no representation or warranty of any kind, express or implied, regarding the accuracy, adequacy, validity, reliability, availability or completeness of any of the information and shall have no liability to any party for loss or damage incurred as a result of the use or

ITEM NO. 1.

This Page
Intentionally
Left Blank

ITEM NO. 1.

KITCHEN

KITCHEN

KITCHEN

KITCHEN

GYM/OFFICE KITCHEN

GYM/OFFICE
DR. WA.

LINEN
MEP WC
BED #5
BED #4
BED #3

JUNIOR MASTER
WA.

DR.

LINEN
MEP WC
BED #5
BED #4
BED #3

JUNIOR MASTER
DR. WA.

LINEN
MEP WC
BED #5
BED #4
BED #3

JUNIOR MASTER
DR. WA.

LINEN MEP WC
BED #5
BED #4
BED #3

JUNIOR MASTER

TWIN OAKS DRIVE

SURREY FARMS HILL (P)

ROAD ESMT (E)
311 OR 381

APPROXIMATE RIPARIAN
LIMIT (TYP.)
10' BUFFER FROM
TREE CANOPY (TYP.)

EXISTING STORMDRAIN

CULVERT STRUCTURE

EXISTING WETLAND AREA

TO REMAIN

EXCLUSION FENCE
LOT 1
S-24-023
LOT 2
S-24-024
LOT 3
S-24-025
LOT 4
S-24-026
LOT 5
S-24-027
LOT 6
S-24-028
LOT 7
S-24-029
LOT 8
S-24-030
LOT 9
S-24-031
LOT 10
S-24-032
L1
L2
L3
L4
L5
C1
L6
L7
C2
L8
L9
C3
L10
L11
L12
L13
532-18-039

LANDS OF BERTOLOTTI

EXISTING RESIDENTIAL
532-18-038

LANDS OF INO

EXISTING RESIDENTIAL
532-18-034

LANDS OF DUGGINS

EXISTING RESIDENTIAL
532-16-005

LANDS OF DODGE

EXISTING RESIDENTIAL
532-16-002

LANDS OF WITKIN

EXISTING RESIDENTIAL
532-16-003

LANDS OF WITKEN

EXISTING RESIDENTIAL
532-16-007

LANDS OF FORDYCE

EXISTING RESIDENTIAL
532-16-008

LANDS OF MELEYCO

EXISTING RESIDENTIAL
532-11-011

LANDS OF HILLBROOK

SCHOOLS

EXISTING SCHOOL
537-30-010

LANDS OF LIU

EXISTING RESIDENTIAL
537-30-007

LANDS OF TFR

MANAGEMENT GROUP INC

EXISTING RESIDENTIAL
537-30-013

LANDS OF SMITH

EXISTING RESIDENTIAL
537-30-006

LANDS OF URALSKY

EXISTING RESIDENTIAL
20' PSDE(P)
10' PSDE (P)

PSDE (P)
11' PUE (P)
LOT 11
S-24-033
LOT 12
S-24-059

CERRO VISTA COURT
EAST ROSS CREEK IN EX 36-INCH RCP

REQUIRED YARD (TYP) -

SEE INDIVIDUAL PACKAGES
L42
L36
L40
L39
L45
L46
L38
L33
L43
L41
L44
L27 L29 L47 L54 L30L31
C10
C9
L20
L19
L18
L16
L17
L14
VALLEY WATER'S 110'

FLOODPLAIN EASEMENT
15' SDE (E)
10' SSE (E)
20'
EAE
(P)
24'
16'
R40'
L15
L21
C11
11' PUE (P)
L35
C13
C12
L34
L32
L37
L22
L23
L24
C7 L25
C8
20'
25'
20'
25'
20'
20'
20'
25'
20'
20'
30'
20'
25'
20'
C4 L26
C6
11' PUE (P)
20' ST-219 DWY
20' EAE, IEE,

PSDRE, PWE,

PRUE, PSSE
(P)
C5
18'
18'
24'
18'
18'
18'
18'

37.8'
18'
18'
30'
30'
R15'
R15'
R50'
R74'
R35'
R197' R173'
R248'
R272'
R232'
R208'
20'
20'
25'
20'
25'
20'
20'
118.5'

79.4'
20'
25' 25'
20'
20'
30'
20'
25'
20'
30'
20'
20'
25'
30'
20'
20'
25'
25'
30'
20'

20.1'

58.7'
30'
25' RIPARIAN SETBACK
4' PAE (P)
30'
30'
30'
30'

EAST ROSS CREEK IN
EX 36-INCH RCP
20'

EXISTING ROCK WALL

TO REMAIN
5' SDE
(P)
10' SSE (P)
5' JTE
(P)

26.0' ACCESS

EASEMENT (E)

RECORDED
DOCUMENT 25880870

SHANNON RD

BLOSSOM

UNION AVE

LEIGH AVE

VASONA ALMADEN RD

LAKE COUNTY
PARK

LOS GATOS LOS GATOS BLVD

HILL RD
85 17

WINCHESTER BLVD

PROJECT SITE

VICINITY MAP

NOT TO SCALE

LINE TABLE
LINE
L1
L2
L3
L4
L5
L6
L7
L8
L9
L10
L11
L12
L13
L14
L15
L16
LENGTH
732.09' 1165.83' 149.91' 52.98' 185.71' 235.64' 7.83' 125.07' 56.06' 93.26' 21.53' 307.67' 921.11' 108.65' 13.00' 12.91'

BEARING
S8°53'22"W
N79°26'52"W
N15°25'52"E N53°00'00"W
N80°25'52"W
S80°25'52"E
S3°56'05"E N64°33'25"E N53°34'10"E N17°04'10"E N29°11'49"E N12°28'26"E S77°35'36"E N66°32'45"W
N83°19'02"E N29°11'49"E

LINE TABLE
LINE
L17
L18
L19
L20
L21
L22
L23
L24
L25
L26
L27
L29
L30
L31
L32
L33
LENGTH

8.62' 143.56' 139.44' 130.71' 13.00' 13.00' 13.00' 13.00' 13.00' 139.48' 203.33' 132.91' 138.72' 144.07' 13.00' 118.33'

BEARING
N29°11'49"E
S34°48'31"E
S34°48'31"E
S34°48'31"E
S37°11'55"E
S39°01'24"E
S15°30'58"E
S26°30'34"E
S4°16'45"E N80°28'47"W
N79°26'51"W
N79°26'53"W
S10°34'40"W
N10°26'53"E N89°16'51"E
S46°50'36"E

LINE TABLE
LINE
L34
L35
L36
L37
L38
L39
L40
L41
L42
L43
L44
L45
L46
L47
L54
LENGTH

41.41' 31.44' 56.25' 113.81' 170.88' 276.84' 149.44' 163.21' 287.58' 267.79' 490.08' 675.44' 371.18' 327.18' 502.40'

BEARING
S60°46'24"W
N55°03'27"E N63°51'54"E N52°56'08"W
N72°35'51"W
N4°42'35"E
S11°48'10"W
S77°35'36"E
S30°07'48"E
S77°35'36"E
S77°35'36"E N35°05'14"W
S23°05'47"E N79°26'52"W
N79°26'52"W
CURVE TABLE CURVE C1 C2 C3 C4 C5 C6 C7 C8 C9 C10 C11 C12 C13 LENGTH

40.84' 41.65' 36.31' 106.66' 22.38' 18.46' 188.69' 41.13' 82.92' 66.40' 192.07' 89.51' 34.71' RADIUS
250.00' 21.40' 57.00' 221.62' 250.00' 249.11' 260.00' 260.00' 185.00' 100.00' 185.00' 62.02' 100.00' DELTA
9°21'37" 111°30'30" 36°30'00" 27°34'25" 5°07'42" 4°14'49" 41°34'49" 9°03'46" 25°40'54" 38°02'45" 59°29'03" 82°41'04" 19°53'20"

OVERALL SITE
PLAN
MD/AV

AS SHOWN
RH

ABBREVIATIONS

PROJECT BOUNDARY
LEGEND
DRAWN BY:

PROJECT NO:

CAD DWG FILE:

CHECKED BY:

DESIGNED BY:

DATE:

SCALE:

HMHC
NO DATE DESCRIPTION SURREY FARM ESTATES 178 TWIN OAKS DRIVE DEVELOPMENT REVIEW & TENTATIVE MAP M-24-013
S:\PROJECTS\418510\PL\PERMIT\_SITE\PERMIT\418510SP.DWG
418510SP.DWG

2.0 4185.10
AUGUST XX, 2025
PLOTTED: 10/23/2025 3:20 PM
Land Use Entitlements
Land Planning
Landscape Architecture
Civil Engineering
Utility Design
Land Surveying
Stormwater Compliance
1570 Oakland Road (408) 487-2200
San Jose, CA 95131 HMHca.com
2 01/08/25 PER CITY COMMENTS
3 04/18/25 PER CITY COMMENTS
4 07/25/25 PER CITY COMMENTS
5 09/15/25 PER CITY COMMENTS
6 10/24/25 PER CITY COMMENTS
1 INCH = 50 FEET
50250 100
(E) EXISTING
(P) PROPOSED

ESMT EASEMENT

SSE SANITARY SEWER EASEMENT (PUBLIC)

SDE STORM DRAIN EASEMENT (PUBLIC)

EAE EMERGENCY ACCESS EASEMENT

PSDE PRIVATE STORM DRAIN EASEMENT

PSE PUBLIC SERVICE EASEMENT

PAE PEDESTRIAN ACCESS EASEMENT

PUE PUBLIC UTILITY EASEMENT
RH

LOT LINE (EXISTING)

LOT LINE (PROPOSED)

EASEMENT (EXISTING)

EASMENT (PROPOSED)

RIPARIAN AREA

BIORETENTION AREA

WETLAND AREA
NOTE: SEE INDIVIDUAL SITE & ARCHITECTURE
REVIEW PACKAGES (S-24-023 THROUGH
S-24-033, -059) FOR SITE & BUILDING DETAILS

FOR EACH LOT

YARD (REQUIRED)

COVENANTS SHALL BE REQUIRED FOR MAINTENANCE OF THE PRIVATE

ROAD BINDING EACH LOT OWNER AND ALL SUBSEQUENT LOT OWNERS,

SUCH THAT BY ACCEPTANCE OF A DEED OR OTHER CONVEYANCE, IS

DEEMED TO COVENANT AND AGREE THAT IF AT ANY TIME THE TOWN OF

LOS GATOS CONCLUDES THAT MAINTENANCE OF THE ROADWAY

INCLUDED IN THE COMMON PROPERTY IS NECESSARY AND HAS NOT

BEEN DONE BY THE ASSOCIATION, THE TOWN OF LOS GATOS MAY

PERFORM SUCH MAINTENANCE AS AGENT FOR THE ASSOCIATION, AND

THE TOWN OF LOS GATOS WILL CHARGE THE ASSOCIATION FOR THE

COST OF ANY SUCH MAINTENANCE, WHICH CHARGE SHALL BE AN
OBLIGATION OF THE ASSOCIATION. SUCH REIMBURSEMENT SHALL BE A

COST SUBJECT TO ASSESSMENT, AND THERE SHALL BE A LIEN ON THE

PROPERTY, WHICH MAY BE PLACED ON THE TAX BILL AND COLLECTED AS ORDINARY TAXES BY THE TOWN.

STORMDRAIN CULVERT STRUCTURE
6 50 ft 125 ft
125 ft
50' OPEN SPACE AND FUTURE

TRAIL EASEMENT
12 ft
12 ft 12 ft
125' OPEN SPACE AND

FUTURE TRAIL EASEMENT

OPEN SPACE

EASEMENT

EARTH / CONCRETE

SWALE AT EDGE OF
PROPERTY.
5'

2.5' 2.5'
1 2
3 EARTHEN SWALE DETAIL

NTS TYP

ENKAMAT (OR APPROVED EQUAL) FOR EROSION
PROTECTION. SEE EROSION
CONTROL PLAN SHEETS 10 & 11 FOR LOCATION.

PROPOSED MASS GRADE

COMPACTED EARTHEN SWALE
(SLOPE 3:1 MAX)
3 2
1 PL

ITEM NO. 1.

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