Scotts Valley City Council
December 17, 2025

Project Description
The 2025 Plan covers a 58-acre area bounded by Mt. Hermon Road, Skypark Drive, Blue Bonnet Lane, and includes commercial areas east of Kings Village Road. The Town Center Core comprises mostly vacant land from the former Skypark Airport.

The project (the 2025 Plan) anticipates new development and changes over an approximate 20-year period through 2045. The goal is to create a community-oriented Downtown, with new streets, retail areas, residential developments, and community gathering places. To do so, it would allow for up to 657 residential units as specified in the Housing Element, as well as up to 82,000 square feet of commercial uses and up to 35,000 square feet of public/civic uses. The 2025 Plan distinguishes between the City-owned and controlled lands that make up the “Town Center Core” (where a minimum of 300 housing units will be developed in order to satisfy Surplus Lands Act requirements), and the other surrounding parcels within the 2025 Plan boundary. Differing land use and development standards apply to lands within the Core versus outside of the Core, as well as different review and permitting procedures.

The 2025 Plan will be followed by adoption of amendments to the City’s General Plan and Zoning Ordinance, which will include changing certain existing land use designations in the Plan Area, creating new zoning district(s), and updating existing or establishing new development standards to replace some of the current zoning provisions applicable to the Plan Area.

The 2025 Plan includes land use and zoning standards, and comprehensive utility, transportation, and landscaping/plaza/public realm improvements for the Town Center. The 2025 Plan includes:
• Land use definitions which have been updated and expanded to reflect current market conditions and contemporary zoning approaches;
• Updated design and development standards to reflect the new Preferred Vision, including Objective Development Standards (ODS) applicable to new residential development as prescribed by State Law;
• Streetscape design standards for Complete Streets that accommodate pedestrians, bicyclists, vehicles, and parking;
• Traffic and utilities improvements necessary to implement the Plan supported by technical analyses including a Water Supply Assessment (WSA) as required by State Law; and
• Implementation actions to provide direction towards the development of the Town Center.

Implementation Process
As described above, the City owns several parcels which collectively comprise the “Town Center Core.” The boundary for the Town Center Core area is shown below and contains five whole parcels (with APNs 022-721-07, 022-721-08, 022-721-09, 022-601-01, 022-212- 19), and portions of others (APN 022-721-02 and a public right-of-way). In accordance with the Surplus Lands Act, after adoption of the 2025 Plan, the City will declare these parcels

exempt surplus land, prepare an RFP for these City-owned parcels and select a developer to partner with on the construction of the Town Center Core horizontal development (roads, utilities, streetscape amenities, and parks/open spaces) and vertical development (commercial, mixed-use, and residential buildings). The RFP will lay out the City’s requirements for land use (including ground-floor retail, public open space, and at least 300 residential units including a minimum percentage of affordable units), public streets, streetscape and public plaza improvements, provisions related to parking, and civil utility improvements. The City shall specify an allowed amount of time for responses, and upon close of RFP, shall select a preferred developer. After initial selection, according to Surplus Lands Act policies, the City will negotiate with the selected developer for at least 90 days to negotiate the lease or sale of the Town Center Core parcels with the selected developer.

This process will ensure a timely implementation of new development in the Core area.

Figure 6-1 in Chapter 6 of the 2025 Plan identifies the parcels that constitute the Town Center Core (outlined in red), as well as several others that could be added depending on the interest of the property owners and/or the developer that will be selected (shown with a red hatch):

DISCUSSION
2025 Specific Plan Overview
The 2025 Plan is organized into the following chapters:
• Chapter 1 (Introduction) contains background on the project setting and details the purpose and authority of the Specific Plan.
• Chapter 2 (Community Vision and Principles) describes and illustrates the community’s vision for the Plan Area and the community engagement process that occurred through the planning effort.
• Chapter 3 (Land Use, Development, and Objective Design Standards) outlines the allowable uses in the Plan Area and the development standards and guidelines for future construction.
• Chapter 4 (Circulation and the Public Realm) deals with the circulation pattern throughout the Plan Area for all transportation modes, including walking and biking.

The Plan emphasizes pedestrian circulation, consolidated parking, and a connection to surrounding uses. This chapter also includes street sections depicting the required street improvements in the Area, and describes public realm, landscaping, and streetscape policies and standards for the Town Center. • Chapter 5 – Reserved chapter for Plan updates or additional material if needed in the future.
• Chapter 6 (Implementation) explains the requisite physical and programmatic improvements needed to assist with implementing the Town Center Specific Plan and ensure that its objectives are completed effectively. Provides a blueprint for the necessary transportation, public open space, water, sanitary sewer, storm drain, and dry utility/power infrastructure improvements for the Town Center. Also describes potential funding opportunities and financing strategies for improvements recommended by this Plan.

The 2025 Plan includes three appendices containing further background and underlying analyses:
• Appendix A defines each of the allowed land uses in the Specific Plan (per Chapter 3 Table 3-1).
• Appendix B provides a summary of the study of market conditions for future retail development.
• Appendix C analyzes the existing and future traffic operations from a Level of Service (LOS) perspective.

Chapter 2: Community Vision & Principles
Chapter 2 establishes the community’s overarching vision and guiding principles for creating a vibrant, pedestrian-oriented downtown that functions as the “Heart of the City.” The chapter describes the desired outcome of a mixed-use Town Center that integrates retail, dining, housing, civic uses, and public gathering spaces within a connected and walkable environment. It identifies design objectives and strategies focused on promoting economic vitality, high-quality architecture, diverse housing options, multimodal circulation, and phased, market-feasible implementation. Figure 2.3 in Chapter 2 (shown below) illustrates

the Preferred Conceptual Vision for the Town Center Core:

This chapter also summarizes the public engagement process that informed development of the updated Plan, including community pop-ups, an open house, online surveys, stakeholder interviews, and Council Subcommittee meetings.

Chapter 3: Land Use and Development Standards
Chapter 3 establishes the regulatory framework to guide development within the Plan Area, providing land use designations, development standards, and objective design standards.

The chapter defines land use goals and policies that promote mixed-use development, community connectivity, economic vitality, design quality, and sustainable building practices.

Land Use and Zoning Designations
Two new land use designations/zones would be created to allow mixed-use development:
• Mixed Use – Town Center (MU-TC), shown in dark purple. This land use designation applies to all five of the vacant, City-owned parcels that comprised the former Skypark Airport, as well as two parcels south of the Post Office. This land use designation is intended to support a pedestrian-friendly mixture of shopping, dining, health and wellness, and residential uses that become a destination at the heart of

Scotts Valley. It accommodates standalone retail, standalone residential, or mixeduse configurations. The ground floors of buildings fronting certain key street segments in the Town Center Core (Main Street, portions of Park Street and Mt Hermon Road) would be required to contain and provide visibility, access and active frontages to support retail and commercial uses.
• Mixed Use – Neighborhood (MU-N), shown in light purple. This land use designation applies to the existing shopping centers in the Plan Area (Target and Nob Hill) as well as the properties containing the mini-storage business, the Cavallero Transit Center, and the vacant land at the corner of Skypark Drive and Mt Hermon Road. It is intended to accommodate the ongoing operations of existing shopping centers while also guiding the potential future redevelopment of these uses into a more mixed and walkable built environment. This land use designation allows standalone retail or office, standalone residential, or mixed-use configurations. Compared to the Town Center, MU-N allows larger commercial uses, and development standards in MU-N permit a somewhat more suburban character compared to the Town Center.

Figure 3.1 in Chapter 3 (shown below) shows the proposed land use designations for the parcels within the Plan Area. Land Use tables are attached to this staff report (in Attachment 1) comparing the land uses permitted under current zoning regulations to the proposed land use regulations in the updated Specific Plan. See Table 3.2 in the draft Plan for details on the allowed densities within each zone (50 du/acre in the MU-TC and 32 du/acre in MU-N).

Existing developments (such as the movie theater, the Scotts Village Shopping Center, and the Cavallaro Transit Center) could expand their existing uses and increase development intensity under the 2025 Plan, or be redeveloped with newly allowed uses. The allocation of future development would be determined by project-specific applications and approvals but would not exceed the total land use buildout evaluated in the EIR.

Development and Design Standards
There are detailed standards governing height, setbacks, floor area ratios, parking, active frontages, and open space. Objective design standards address building form, massing, circulation, landscaping, lighting, and frontage design to ensure high-quality, human-scaled development consistent with State housing laws and local design expectations. Collectively, these provisions provide a predictable and implementable framework for achieving the Town Center’s intended character and functionality. Proposed heights are similar to those allowed under the 2008 Specific Plan – see Table 3.3 in the draft Plan for more detail on allowed heights.

Chapter 4: Circulation
Chapter 4 establishes the circulation and public realm framework that will guide the design and function of streets, sidewalks, and public spaces throughout the Plan Area. The chapter defines the Town Center’s multimodal circulation system, emphasizing safe, walkable, and interconnected streets that accommodate all modes of travel while reinforcing the area’s pedestrian-oriented character. It identifies key street types and provides detailed standards for cross-sections, block lengths, connectivity, and access. Figure 4-2 in Chapter 4 (shown below) illustrates the Public Circulation Network:

Core Circulation Streets
At the heart of the Town Center is a compact, interconnected street network designed to attract and prioritize pedestrians, support multimodal access, and promote vibrant public spaces. The three primary “core circulation streets” — Main Street, Park Street, and Theater Walk — work together to structure the district, define its urban character, and connect its key destinations:
• Main Street. Main Street is the front door to the Town Center. It should be designed for slower traffic and include wide sidewalks, street trees, and active storefronts.

Outdoor dining and public gathering should be supported through generous pedestrian zones and curb extensions. The preferred design for Main Street is 36 feet from curb-to-curb with two travel lanes and two parking lanes, with a total public ROW width of 63 feet including public sidewalks.
• Park Street. Intersecting most of the Town Center Streets, Park Street is the primary spine for the Town Center. Park Street links Skypark to Kings Village Road with Hangar Square and Tower Point plazas. These connections, combined with destination public spaces make this street the social center of the City. Park Street

should be designed for occasional street closures and events, with a strong pedestrian orientation. Park Street may be suitable for traffic calming elements. Park Street will be framed by mixed-use buildings and key public plazas. The preferred design for Park Street is 36 feet from curb-to-curb with two travel lanes and two parking lanes, plus a protected bicycle lane or “cycle track” on either side of the landscape zone for a total public ROW width of 76 feet including public sidewalks. An alternative design for Park Street is the section described above for Main Street.

Sidewalks on Park Street shall be at least 13 feet wide to offer a pleasant strolling and shopping experience.
• Theater Walk. This narrower corridor should be lined with a mix of retail and residential frontage and provide space for outdoor seating. The preferred design for Theater Walk is a shared-surface or curbless design, where the roadway is at the same grade (elevation) as the landscaping and sidewalks/pedestrian zones, which would be highly adaptable for closures, public events, and civic life. The public rightof-way width for Theater Walk is 57 feet.

Figures 4.3 - 4.5 in Chapter 4 of the Specific Plan provide typical street section diagrams for the three core circulation streets.

Beyond the Core Streets, an additional street, Aero Lane, is a planned new local connector that frames the southern edge of Skypark, offering low-speed, park-adjacent access for residents and trail users. Aero Lane is designed with perpendicular parking spaces to support use of Skypark as well as provide additional overflow parking for the nearby Town Center shops and restaurants.

Required Roadway Improvements
The 2025 Plan specifies a new signalized intersection at Main Street and Mt. Hermon Road, which serves as the primary gateway into the Town Center from the regional road network.

The intersection would align with an existing driveway access to the Safeway/CVS shopping center across Mt. Hermon Road. This intersection will clearly signal arrival into the Town Center, with design strategies such as high-visibility crosswalks, special paving or signage, and landscape treatments that frame the approach. It will be the most visible point of entry for visitors arriving by vehicle, on foot, or bike, and should reflect the Town Center’s identity and quality of place.

Optional Roadway Improvements
The 2025 Plan also describes optional future roadway improvements at the Kings Village Road / Mt. Hermon Road intersection to incorporate an additional left turn lane along southbound Kings Village Road turning onto Mt. Hermon Road. The decision whether and when to implement this improvement will be made by the City Council as part of the negotiation or approval of the Development Agreement and during the review/approval of the Planned Development permit process for the Town Center Core.

Pedestrian and Bicycle Improvements
Chapter 3 includes comprehensive pedestrian and bicycle improvement strategies designed to establish an all-ages-and-abilities active transportation network throughout the Town Center. The Plan requires continuous sidewalks on both sides of all streets, pedestrian

paseos on long blocks, and wide sidewalks with shade trees, furnishings, and outdoor seating to encourage walking and social interaction.

Bicycle infrastructure is integrated into every street type, including protected cycle tracks along Park Street, shared Class III routes on Theater Walk, and buffered lanes connecting to Skypark, Kings Village Road, and Mt. Hermon Road. These facilities are coordinated with the City’s Active Transportation Plan to ensure connectivity to regional bikeways and transit.

Public Open Space Concept
Chapter 3 establishes a comprehensive framework for publicly accessible open spaces designed to create a vibrant and cohesive public realm that supports community gathering, recreation, and civic identity.

The Plan identifies two key public plazas – Tower Point Plaza and Hangar Square – as signature destinations within the Town Center. Tower Point Plaza serves as a welcoming gateway and visual landmark, featuring a viewing tower inspired by Scotts Valley’s aviation history, event space, and shaded seating. Hangar Square, adjacent to “The Hangar” retail development, is envisioned as the City’s main public plaza, accommodating outdoor dining, and family-friendly amenities such as interactive art or water features. Both spaces are required to incorporate shade, furnishings, lighting, and active building frontages to ensure year-round usability and safety.

Beyond the two key plazas, the 2025 Plan outlines standards for publicly accessible open space within the Town Center Core (MU-TC zone) and the surrounding parcels within the Plan Area (MU-N zone), requiring minimum plaza sizes (measured by square footage), tree canopy coverage, accessibility, and visibility from public rights-of-way. All public open spaces must include seating, landscaping, and a mix of sun and shade.

The chapter also calls for strong connections to Skypark, encouraging shared programming such as concerts, farmers markets, and outdoor events to reinforce the Town Center’s role as the civic heart of Scotts Valley. The Plan also suggests improvements to Skypark, particularly where it interfaces with the town center, though such planning would be done as a separate effort from the Specific Plan.

Chapter 6: Implementation
Chapter 6 outlines the framework for implementing the City’s vision for the Town Center through coordinated public and private actions. It establishes the administrative, permitting, and development review procedures for projects within the Plan Area, including specific processes for both the City-owned Town Center Core parcels and for privately owned sites.

The chapter details the steps for preparing and negotiating a Development Agreement with a master developer, identifies phasing and infrastructure requirements, and provides an Implementation Action Plan with short- and long-term priorities. The chapter further specifies capital improvements related to circulation, utilities, and public spaces, along with associated timing and responsible parties.

Finally, the chapter presents potential funding mechanisms to support infrastructure and public realm investments. These include an Enhanced Infrastructure Financing District (EIFD), development agreements, and state and federal grants. Collectively, these measures ensure the orderly, feasible, and timely realization of the Town Center consistent with the community’s adopted goals and policies.

CALIFORNIA ENVIRONMENTAL QUALITY ACT REVIEW (CEQA)
CEQA Process
CEQA is the State’s primary environmental protection and disclosure law and requires that public agencies disclose when a project that would have a physical change on the environment will result in significant environmental impacts. CEQA requires the lead public agency to identify ways to avoid or reduce potential impacts through mitigation measures or alternatives. It does not mandate that projects with significant impacts cannot be approved, but rather that environmental impacts be disclosed, avoided or mitigated where possible, and when impacts are unavoidably significant, that they are considered in the decisionmaking process, and that the decision-makers go on record with their reason(s) for approving the project despite the significant environmental impacts that would result.

EIR Process Undertaken
CEQA’s primary mechanism for analyzing the environmental impacts of a project is the preparation of an Environmental Impact Report (EIR), which is the type of document that was prepared for the 2025 Plan. The EIR is the most extensive, thorough level of environmental review available, and the process which provides for the most public review and participation.

The EIR:
• Discloses information about the effects a project could have on the environment, but NOT that the environment could have on the project.
• Identifies mitigation measures to reduce significant impacts. • Describes feasible alternatives to the proposed project that are designed to reduce any environmental impacts while achieving identified project objectives. • The EIR must be certified prior to approval of the Town Center Update.

It is important to note that the information contained in the EIR does not approve or deny a project or a plan, its purpose is to provide information regarding the project’s impacts.

Key Findings
The DEIR identified significant or potentially significant effects associated with the Plan’s implementation in the following environmental topics: air quality, biological resources, cultural resources, geology and soils, hazards and hazardous materials, greenhouse gas emissions, noise and vibration, and transportation. The DEIR analyzed 20 environmental subjects, responding to the checklist questions from Appendix G of the CEQA Guidelines to assess impacts for each environmental subject. The impact conclusions are summarized below:

• The DEIR finds no impacts or less than significant impacts through required policies, standards and programs to the following environmental subjects: Aesthetics, Agriculture and Forestry Resources, Energy, Hydrology, Land Use and Planning, Mineral Resources, Population and Housing, Public Services, Recreation, Tribal Cultural Resources, Utilities and Service Systems, and Wildfire. • The DEIR finds less than significant impacts with mitigation incorporated into the following environmental subjects: Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, and Noise. • The DEIR finds that the 2025 Plan would produce significant and unavoidable impacts to Greenhouse Gases, even with mitigation incorporated. The DEIR also finds the 2025 Plan would produce significant and unavoidable cumulative impacts to Transportation.
• The City Council would need to reject the environmentally superior alternative and adopt a statement of overriding considerations, supported by substantial evidence in the record to move forward with the 2025 Plan. These are impacts that are commonly generated by major developments of scale in the Bay Area and the impacts are not related to the Plan’s location within the City, i.e., this amount of development occurring elsewhere in the City would result in similar impacts due to the magnitude of development, and it is not unusual for city councils to find that specific economic, legal, social, technological, or other benefits, of a proposed project outweigh the unavoidable adverse environmental effects.

PUBLIC NOTICE AND COMMENT
Copies of the DEIR and public hearing notices were posted at City Hall (Planning Department), Scotts Valley Branch Library, and the Senior Center. Written comments for this DEIR will be accepted during the public review period from October 10, 2025, to November 24, 2025. Written comments should be submitted to City of Scotts Valley Planning Department, for the attention of Taylor Bateman ([email protected]).

NEXT STEPS
The following list describes the intended timeline and upcoming meetings to adopt the 2025 Plan and certify the accompanying DEIR:
• The public comment period for the DEIR closes on November 24; • A Planning Commission meeting to provide a recommendation on the 2025 Plan and the EIR is tentatively scheduled for December 4;
• A City Council meeting to consider adoption of the 2025 Plan and certification of the EIR is tentatively scheduled for December 17;
• Follow-up meetings with the Planning Commission and City Council will be held in January 2026 to consider associated ordinances amending the City’s General Plan and updating the Zoning Code to align with the 2025 Plan.

TABLE OF CONTENTS

1. Attachment 1: Allowed Land Use Comparison Table

2. Attachment 2: Draft 2025 Specific Plan (https://www.scottsvalley.gov/525/The-TownCenter)

3. Attachment 3: Public Draft EIR (https://www.scottsvalley.gov/525/The-Town-Center)

“Improving lives and communities through transportation.” CALTRANS DISTRICT 5
50 HIGUERA STREET | SAN LUIS OBISPO, CA 93401-5415
(805) 549-3101 | FAX (805) 549-3329 TTY 711
www.dot.ca.gov
November 24, 2025 SCH #2025050499
SCR-17-4.096
Taylor Bateman, Community Development Director
City of Scotts Valley
1 Civic Center Drive
Scotts Valley, CA 95066
Dear Taylor Bateman:

The California Department of Transportation (Caltrans) appreciates the opportunity to review the Draft Environmental Impact Report (DEIR) dated October 2025, for the 2025 Scotts Valley Town Center Specific Plan (Plan). The Plan area consists of approximately 58-acres within the City and allows for up to 657 residential units (consistent with the City’s 2023-2031 Housing Element); up to 82,000 square feet of commercial uses; and up to 35,000 square feet of public/civic uses. Caltrans offers the following comments in response to the DEIR:

General Comments:
 Caltrans supports local development that is consistent with State planning priorities intended to promote equity, strengthen the economy, protect the environment, and promote public health and safety. We accomplish this by working with local jurisdictions to achieve a shared vision of how the transportation system should and can accommodate interregional and local travel and development. Projects supporting smart growth principles, including improvements to pedestrian, bicycle, and transit infrastructure (or other key Transportation Demand Strategies) are supported by Caltrans and are consistent with our mission, vision, and goals.

Traffic Operations and Safety:
 The State Route (SR) 17 and Mt. Hermon Road interchange does not appear to have been included in the DEIR. The additional 657 residential units and additional commercial and public uses will most likely impact this interchange.  Please indicate how the impacts on the regional transportation network will be mitigated to address safety and operational concerns.

Taylor Bateman, Community Development Director
November 24, 2025

“Improving lives and communities through transportation.”  Any mitigation measures and conditions of approval related to the State Highway System (SHS) should be coordinated with Caltrans. Please contact Caltrans for early coordination.

System Planning:
 The Scotts Valley Transit Center is located within the Specific Plan area and the proposed improvements should encourage further usage of that facility.  Mt. Hermon Road interchange at SR 17 would be the primary egress for this facility. Please coordinate with Caltrans on any impacts to the SHS.

Permits:
 Please be aware that if any future work is completed in the State’s right-of-way it will require an encroachment permit from Caltrans and must be done to our engineering and environmental standards, and at no cost to the State. The conditions of approval and the requirements for the encroachment permit are issued at the sole discretion of the Permits Office, and nothing in this letter shall be implied as limiting those future conditions and requirements. For more information regarding the encroachment permit process, please visit our Encroachment Permit Website at: https://dot.ca.gov/programs/traffic-operations/ep.

Thank you for the opportunity to review and comment on the proposed project. We look forward to continued coordination with the City on this effort. If you have any questions, or need further clarification on items discussed above, please contact me at (805) 835-6555 or [email protected]
Sincerely,
Ingrid McRoberts
Development Review Coordinator
District 5, LDR North Branch

State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
November 18, 2025
Taylor Bateman, Community Development Director
City of Scotts Valley
1 Civic Center Drive
Scotts Valley, CA, 95066
[email protected]
Subject: 2025 Scotts Valley Town Center Specific Plan, Draft Environmental Impact Report, SCH No. 2025050499, City of Scotts Valley, Santa Cruz County Dear Taylor Bateman:

The California Department of Fish and Wildlife (CDFW) received a Notice of Availability of a Draft Environmental Impact Report (EIR) from the City of Scotts Valley (City) for the 2025 Scotts Valley Town Center Specific Plan (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW previously submitted comments in response to the Notice of Preparation of the draft EIR.

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a).) CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species. (Id., § 1802.) Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381.) CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

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City of Scotts Valley
November 18, 2025

proposed, for example, the Project may be subject to CDFW’s Lake and Streambed Alteration (LSA) regulatory authority. (Fish & G. Code, § 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the project proponent may seek related take authorization as provided by the Fish and Game Code.

REGULATORY REQUIREMENTS
California Endangered Species Act
A CESA Incidental Take Permit (ITP) must be obtained from CDFW if the Project has the potential to result in “take” of plants or animals listed under CESA, either during construction or over the life of the Project. Under CESA, “take” means “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” (Fish & G.

Code, § 86). CDFW’s issuance of an ITP is subject to CEQA and to facilitate permit issuance, any project modifications and mitigation measures must be incorporated into the CEQA document analysis, discussion, and mitigation monitoring and reporting program. If the Project will impact CESA listed species, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain a CESA Permit.

CEQA requires a mandatory finding of significance if a project is likely to substantially impact threatened or endangered species. (Pub. Resources Code, §§ 21001, subd. (c) & 21083; CEQA Guidelines, §§ 15380, 15064 & 15065.) In addition, pursuant to CEQA, the Lead Agency cannot approve a project unless all impacts to the environment are avoided or mitigated to less-than-significant levels, or the Lead Agency makes and supports Findings of Overriding Consideration (FOC) for impacts that remain significant despite the implementation of all feasible mitigation. FOC under CEQA, however, do not eliminate the Project proponent’s obligation to comply with the Fish and Game Code.

Lake and Streambed Alteration
CDFW requires an LSA Notification, pursuant to Fish and Game Code section 1600 et seq., for Project activities affecting rivers, lakes or streams and associated riparian habitat. Notification is required for any activity that may substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank (including associated riparian or wetland resources); or deposit or dispose of material where it may pass into a river, lake, or stream. Work within ephemeral streams, drainage ditches, washes, watercourses with a subsurface flow, and floodplains is generally subject to notification requirements. In addition, infrastructure installed beneath such aquatic features, such as through hydraulic directional drilling, is also generally subject to notification requirements. Therefore, any impact to the mainstems, tributaries, or Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

Taylor Bateman
City of Scotts Valley
November 18, 2025

floodplains or associated riparian habitat caused by the proposed Project will likely require an LSA Notification. CDFW may not execute a final LSA Agreement until it has considered the final EIR and complied with its responsibilities as a responsible agency under CEQA.

Migratory Birds and Raptors
CDFW has authority over actions that may result in the disturbance or destruction of active bird nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include section 3503 (regarding unlawful take, possession, or needless destruction of the nests or eggs of any bird), section 3503.5 (regarding the take, possession, or destruction of any birds-of-prey or their nests or eggs), and section 3513 (regarding unlawful take of any migratory nongame bird).

Migratory birds are also protected under the federal Migratory Bird Treaty Act.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Scotts Valley
Objective: The objective of the Project is to create a vision, policies, and objective standards to guide new development within the Scotts Valley Town Center Specific Plan area (Plan area) in a way that supports existing and new businesses, residents, and the overall community. The Project will allow for up to 657 residential units, up to 82,000 square feet of commercial uses, and up to 35,000 square feet of public/civic uses. The Project will include adoption of amendments to the City’s General Plan and Zoning Ordinance, changing certain existing land use designations in the Plan Area, creating new zoning districts, and updating existing or establishing new development standards to replace some of the current zoning provisions applicable to the Plan Area. Primary Project activities include demolition of existing commercial buildings and construction of residential and commercial buildings within the Plan area.

Location: The Project is located in the City of Scotts Valley in southeast portion of Skypark, which is now a public park and open space. The Plan area is roughly bound by Blue Bonnet Lane and Kings Village Road to the north, an existing residential neighborhood (Hidden Oaks Condominiums) to the east, Mt. Hermon Road to the south, Skypark Drive to the west, and Skypark to the northwest.

Timeframe: 2045

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

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City of Scotts Valley
November 18, 2025

Editorial comments or other suggestions may also be included to improve the document.

I. Environmental Setting and Related Impact Shortcoming Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or U.S. Fish and Wildlife Service (USFWS)?
COMMENT 1: Special-Status Plant Species
Section 3.4.2.1, Page 94
Issue: The draft EIR proposes to implement General Plan Policy OSC-1.16, which requires new development within areas of native plants to prepare a site-specific survey which identifies the location and type of species present. However, the draft EIR does not specify how surveys will be performed or the level of survey effort to ensure special-status plant species will be detected. Additionally, if any rare plants are found, General Policy OSC-1.16 relies on a biologist to recommend mitigation at a later time and relies on agency requirements, if any. Therefore, the Project has potential to result in significant impacts to rare plants because: 1) Rare plant occurrences may be un-detected and 2) If rare plants are detected, biologist recommended mitigation may not be implemented or sufficient if there are no agency requirements.

Specific impact, why the impact would occur, and evidence the impact would be significant: CEQA Guidelines §15125(a) requires an EIR to be based on current, accurate, and site-specific data. Without current surveys, it is foreseeable that project buildout could remove, alter, or fragment remaining microhabitat patches that may still support special-status plant species in the Zayante/Santa Cruz Sandhills and/or Ponderosa Pine habitat.

A reconnaissance-level biological field survey was last conducted in July 2014 outside of the bloom season. Additional botanical surveys are necessary because there is insufficient data to determine whether rare or special-status plants are present within the Project area, surveys did not occur at the appropriate times of year, and surveys were not conducted for a sufficient number of years to detect plants that may not be evident and identifiable every year. Surveys over consecutive seasons may be necessary for annual or short-lived special-status plants to increase the likelihood of detection. Variances in weather and other disturbances from year to year may affect presence or accurate identification of special-status plants on-site.

Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

Taylor Bateman
City of Scotts Valley
November 18, 2025

Recommendation: CDFW recommends revising the draft EIR to require focused botanical surveys consistent with Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Natural Communities (CDFW 2018) including at least two consecutive years of appropriately timed blooming-season surveys prior to any site disturbance or grading.

Recommended Special-Status Plant Survey BIO-Measure: An experienced botanist, familiar with the native plant communities of Santa Cruz County, including Zayante/Santa Cruz Sandhills and Ponderosa Pine habitat shall conduct a minimum of two focused rare plant surveys over two consecutive seasons. The surveys shall occur throughout the entire Project area and at each construction site, prior to the initiation of construction. Surveys shall be conducted according to: Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Natural Communities (CDFW 2018), available at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline.

In the event rare, threatened or endangered plants are discovered, If rare or special-status plant(s) cannot be avoided, the Project proponent shall submit to CDFW a rare or special-status plant mitigation plan for CDFW review, comment, and written approval prior to construction. Depending on the site-specific details, additional measures may be needed, which may include work stoppage, flagging and avoidance of occurrences, collection of propagation material, site restoration and/or obtaining an ITP (Fish and Game Code section 2081, subd., (b).).

Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any speciel identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or USFWS?
COMMENT 2: Nesting Birds
Section 3.4.2.1, Page 95
Issue: The draft EIR proposes to implement mitigation measure MM-BIO 2.1: Avoid Nesting Birds to mitigate for impacts to nesting birds. The measure does not completely consider all life history timing needs of some bird species potentially impacted by the Project.

Specific impact, why the impact would occur, and evidence the impact would be significant: The nesting seasons for passerines (Passeriformes), owls (Strigiformes), and raptors range from February 15 - August 30, January 15 - September 15, and February 15 - September 15, respectively.

Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

Taylor Bateman
City of Scotts Valley
November 18, 2025

Recommendation 2: To evaluate and avoid potential impacts to nesting bird species, CDFW recommends incorporating the following mitigation measure into the Project’s draft EIR existing measure.

Recommended Nesting Bird Mitigation Measure: If Project grading or construction is scheduled to take place between January 15 – September 15, a preconstruction survey of the Project vicinity for nesting birds shall be conducted by a qualified biologist experienced with the nesting behavior of bird species of the region. The survey shall determine if active nests are present within the planned area of disturbance or within 250 feet for passerines, 500 feet for accipiters and 1,000 feet for buteos. The survey shall be performed no more than 7 days prior to the commencement of construction activities, and a second focused survey shall be conducted within 48 hours prior to construction activities that would occur during the nesting/breeding season. If ground disturbance activities are delayed following a survey, then an additional preconstruction survey shall be conducted such that no more than two weeks will have elapsed between the last survey and the commencement of ground disturbance activities.

If a lapse of Project-related activities of seven days or longer occurs, another focused survey will be conducted before Project activities can be reinitiated.

If an active bird nest is found within the survey radii, species-specific measures shall be prepared by a qualified biologist and implemented to prevent abandonment of the active nest. A protective buffer distance shall be established by a qualified biologist based on the site conditions such as whether the nest is in a line of sight of the construction and the sensitivity of the birds nesting. Typical protective buffers are as follows: 1) 250 feet for passerines, 2) 500 feet for accipiters, and 3) 1,000 feet for buteos. No Project personnel or equipment shall be allowed to enter the protective buffer until the qualified biologist determines that the young have fully fledged and will no longer be adversely affected by the Project.

The qualified biologist shall observe any identified active nests prior to the start of any construction-related activities to establish a behavioral baseline of the adults and any nestlings, and the nest site(s) shall be monitored by the biologist periodically to see if the birds are stressed by the construction activities and if the protective buffer needs to be increased. The perimeter of the nest setback zone shall be fenced or adequately demarcated with stakes and flagging at 20-foot intervals, and construction personnel and activities restricted from the area. A survey report by the qualified biologist verifying that no active nests are present, or that the young have fledged, shall be submitted prior to initiation of grading in the nest-setback zone. The qualified biologist shall serve as a biological monitor during those periods when construction activities occur near active nest areas to Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

Taylor Bateman
City of Scotts Valley
November 18, 2025

ensure that no inadvertent impacts on these nests occur. All buffers shall be shown on all sets of construction drawings.

Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or USFWS?
COMMENT 3: San Francisco Dusky-Footed Woodrat
Section 3.4.2.1, Page 93
Issue: The draft EIR identifies San Francisco dusky-footed woodrat (Neotoma fuscipes annectens) to have “reasonable potential to occur within the Project area” but does not identify species specific surveys, time to dismantle San Francisco dusky-footed woodrat midden or include midden relocations as a minimization measure. The Project has potential to result in significant impacts to San Francisco dusky-footed woodrat without revised mitigation measure(s).

Specific impact, why the impact would occur, and evidence the impact would be significant: The San Francisco dusky-footed woodrat is listed as a species of special concern found throughout the San Franciso Bay area in grasslands, scrub, and woodland areas (Hall 1981). The Project site includes oak woodland, riparian, and shrub habitats which provide suitable habitat for this species. The draft EIR does not include species-specific mitigation measures for San Francisco duskyfooted woodrat requiring focused preconstruction surveys, avoidance buffers, or relocation (specific timing, methods, or performance standards).

Recommendation: CDFW recommends that if San Francisco dusky-footed woodrat middens cannot be avoided, the middens shall be relocated out of the Project area to minimize impacts to San Francisco dusky-footed woodrat. CDFW also recommends that middens are relocated and/or dismantled during the month of July and August to avoid impacts to young and to allow San Francisco dusky-footed woodrat to store food prior to winter, when food sources are limited.

Recommended San Francisco Dusky-Footed Woodrat Mitigation Measure: A pre-construction survey for San Francisco dusky-footed woodrat shall be conducted by a qualified biologist within seven days prior to Project activities. If an active San Francisco dusky-footed woodrat midden is found during surveys, the active midden site shall be designated as “Ecologically Sensitive Areas” (ESA) and protected during Project construction with establishment of flagging or a fence barrier surrounding the nest site. CDFW recommends that the minimum distance of 25 feet is used for the protective buffer protecting the nest. If a San Francisco dusky-footed woodrat midden(s) cannot be avoided, the Project proponent shall submit to CDFW Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

Taylor Bateman
City of Scotts Valley
November 18, 2025

a San Francisco dusky-footed woodrat Midden Relocation Plan for CDFW review, comment, and written approval prior to construction.

Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or USFWS?
COMMENT 4: Mount Hermon June Beetle and Zayante Band-Winged Grasshopper Section 3.4.2.1, Page 76
Issue: The Project site includes areas mapped as Zayante/Santa Cruz Sandhills habitat and mixed woodland that may support Mount Hermon June beetle (Polyphylla barbata) and Zayante band-winged grasshopper (Trimerotropis infantilis), both of which are federally listed as endangered under the Endangered Species Act. These two insect species are known only from the Zayante/Santa Cruz Sandhills, including adjacent transitional soils in Santa Cruz County. The Project has potential to cause significant impacts to Mount Hermon June beetle and Zayante band-winged grasshopper because it would disturb the sandy soils, mixed woodland, and undeveloped areas that support habitat functions for both species.

Although some areas are developed and degraded, the soil remains intact and are important for both of these species as they are restricted to sandy soils (USFWS 1998).

Specific impact, why the impact would occur, and evidence the impact would be significant: The draft EIR does not include focused surveys for Mount Hermon June beetle and Zayante band-winged grasshopper. It is unclear if the reconnaissance-level biological field survey conducted in July 2014 followed the USFWS protocol survey methods. The EIR acknowledges that portions of the Project area are mapped as Zayante/Santa Cruz Sandhills habitat and currently developed with soil underlaying the developed area that could meet the requirements for Zayante/Santa Cruz Sandhills habitat. Mount Hermon June beetles are fossorial, and individuals may be present year-round (USFWS 2009). Both species are vulnerable to habitat disturbance, including grading, vegetation removal, and soil compaction.

Recommendation: A focused protocol-level survey should be conducted during the appropriate activity periods to determine presence or absence. If suitable habitat is confirmed, avoidance and mitigation measures should be developed in coordination with the USFWS.

Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

Taylor Bateman
City of Scotts Valley
November 18, 2025

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNDDB field survey form can be filled out and submitted online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)

CONCLUSION
CDFW appreciates the opportunity to comment on the draft EIR to assist the City in identifying and mitigating Project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Alexis Harrison, Environmental Scientist, at (707) 815-2779 or [email protected]; or Wesley (Wes) Stokes, Senior Environmental Scientist (Supervisory), at (707) 339-6066 or [email protected].

Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
ec: Office of Land Use and Climate Innovation (SCH No. 2025050499) Craig Weightman, CDFW Bay Delta Region – [email protected] Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

Taylor Bateman
City of Scotts Valley
November 18, 2025

REFERENCES
California Department of Fish and Wildlife (CDFW). 2024. Special Animals List.

California Natural Diversity Database (CNDDB).

Carraway, L. N., and B. J. Verts. 1991. Neotoma fuscipes. Mammalian Species 386:1-

10. Hall, E.R. 1981. Mammals of North America. John Wiley and Sons, 1181 pp. [USFWS] U.S. Fish and Wildlife Service. 1997. Determination of Endangered Status for Two Insects from the Santa Cruz Mountains of California. Federal Register 62:3616–3628.
[USFWS] U.S. Fish and Wildlife Service. 1998. Recovery Plan for Insect and Plant Taxa from the Santa Cruz Mountains of California. Portland, Oregon. 83 pp. [USFWS] U.S. Fish and Wildlife Service. 2009. Zayante band-winged grasshopper (Trimerotropis infantilis) and Mount Hermon June beetle (Polyphylla barbata) 5- Year Review: Summary and Evaluation. 33 pp.

U.S. Fish and Wildlife Service. 2020. Endangered and Threatened Wildlife and Plants; Initiation of 5-Year Status Reviews of 66 Species in California and Nevada.

Federal Register 85:4692–4694.
[USFWS] U.S. Fish and Wildlife Service. 2021. Zayante band-winged grasshopper (Trimerotropis infantilis) and Mount Hermon June beetle (Polyphylla barbata) 5- Year Review: Summary and Evaluation.

Docusign Envelope ID: 682DC5CF-4AE0-4E16-A61A-1DF628372C75

To: Taylor Bateman, Community Development Director
[email protected]
Date: November 24, 2025
Re: Scotts Valley Town Center Specific Plan Update – Draft Environmental Impact Report
Dear Director Bateman,
On behalf of Santa Cruz YIMBY, thank you for the opportunity to comment on the City of Scotts Valley’s ongoing Housing Element implementation efforts, including the rezonings tied to the Housing Element and the Town Center Specific Plan Update.

1. The City continues to undercount the amount of housing it must plan for under its certified Housing Element.

As we described in our prior comments on the Town Center EIR NOP, the City’s current Rezone Program and Specific Plan work continue to rely on unit counts that are substantially below what the Housing Element itself requires. In the Housing Element, the City clearly committed to both:

1. Implementing Program H-1.1, which requires adopting a Specific Plan amendment that supports the full buildout scale in Appendix F; and

2. Implementing Program H-1.10, which requires the three City-owned Town Center parcels—APNs 022-721-06, 022-212-19, and 022-601-01—to be declared surplus and developed as a mixed-use project with a minimum of 300 residential units, at least 25% affordable, with the City expressing its intent that these parcels be 100% affordable.

Our previous comments explained that the City’s use of a “realistic capacity” figure of 188 units on these three parcels is inconsistent with its own Housing Element. Program H-1.10 makes clear that 300 units is the minimum, not 188. And the 100% density-based capacity in Appendix F yields 235 units, not 188. When all Town Center parcels are evaluated at 100% capacity—as required for consistency—the total is 898 units, increasing to 963 units when the additional Program H-1.10 requirement is applied (the additional 65 units reflects the gap between 300 committed units and the 235 in Appendix F).

Given this statutory and internal inconsistency, we reiterate:The City must plan, analyze, and zone for the actual level of housing capacity its Housing Element already obligates it to accommodate. Continuing to plan for sub-capacity figures Santa Cruz YIMBY Input - Town Center EIR Page 1 of 3

would render subsequent rezonings and the Specific Plan non-compliant with state law and expose the City to substantial legal risk.

2. The City should treat all Housing Element–related rezonings as CEQA-exempt under the new statewide rezoning exemption enacted in SB 131 (2025).

The Legislature adopted SB 131 earlier this year to eliminate unnecessary procedural barriers that historically delayed implementation of certified Housing Elements. SB 131 creates a statutory CEQA exemption for rezonings that jurisdictions are required to adopt to implement their Housing Elements, provided they meet the statute’s procedural conditions.

Under SB 131:
● Rezoning actions required by a certified Housing Element—including density increases, height increases, mixed-use allowances, and objective standards necessary to make Housing Element sites viable—
● are categorically exempt from CEQA;
● No EIR, MND, or addendum is required;
● The exemption applies to rezonings adopted to meet statutory rezoning deadlines or Housing Element implementation programs.

Scotts Valley’s Housing Element explicitly relies on Town Center rezonings, increased densities, and new mixed-use allowances to meet its RHNA allocation. These rezonings are not discretionary “optional” legislative actions—they are mandated by Government Code §§ 65583, 65583.2, and the certified Housing Element itself.

Accordingly:All Housing Element–required rezonings—whether inside the Town Center Specific Plan area or citywide—qualify for the CEQA exemption under SB 131.

The City should acknowledge this exemption publicly and apply it consistently to expedite timely Housing Element implementation. Conducting unnecessary CEQA review for mandated rezonings is not only unnecessary, but risks delaying compliance with the City’s committed program deadlines. It opens the door for delays if the EIR for the housing component of the rezoning is challenged.

Santa Cruz YIMBY Input - Town Center EIR Page 2 of 3

3. Scotts Valley should evaluate higher housing capacity broadly across the Town Center.

Our earlier letter also documented that the Town Center Planning Area is significantly underutilized relative to its development potential. The approximately 15 acres of centrally located vacant land could, on their own, support 600+ units, and the full 58-acre area could support well over 1,000 units at modest urban infill densities.

This is especially critical given that Scotts Valley lies within one of the highest-cost rental markets in the nation. Under-planning in the Town Center would directly undermine Housing Element compliance, future RHNA cycles, and the City’s progress toward fulfilling its state-mandated duty to accommodate its share of regional housing needs.

In conclusion, we respectfully request that Scotts Valley:

1. Correct the unit-count methodology used for Town Center and other Housing Element sites, ensuring that rezoning reflects the actual capacity required by Programs H-1.1 and H-1.10;

2. Acknowledge and apply the CEQA exemption for Housing Element-required rezonings under SB 131 to avoid unnecessary environmental review and delays; and

3. Plan for significantly higher capacity in the Town Center area, consistent with both state law and the City’s own Housing Element commitments.

Thank you for your attention and for the opportunity to provide comments.

Sincerely,
Rafa Sonnenfeld
Janine Roeth
Ryan Meckel
Jocelyn Wolf
Leads, Santa Cruz YIMBY
Santa Cruz YIMBY Input - Town Center EIR Page 3 of 3

October 23, 2025,
Updated November 24th, 2025
To: Planning Commission and City Council
From: Corbett Wright
SVTC Specific Plan Comments
Chapter 3. Approved Uses
The stated goal of the specific plan is to allow the phased construction within the plan build out. This could include multiple developers vs a single developer. Therefore, the City must retain approvals as to the Tenant and use Mix or else the standards as proposed will not provide adequate parking. The concept of making it easier for the development of the specific plan to move forward without additional approvals is fine, with appropriate guardrails.

For example, a max density of 30% percent restaurants would not require a CUP, anything beyond that would require a CUP. This only works with a minimum 4.5/1000 ratio though.

Case Study of Issue. 1420, 1430, and 1440, 41st Ave. Different owners. Common parking at 3.5/1000. Second generation space; a health and wellness use, (yoga) and an intense Verizon wireless were placed into 1430. The uses take up nearly all of the common parking.

The building located at 1420 has had chronic vacancy. The building located at 1440, has been vacant for years. There is no parking.

Case Study of Issue. Hangar. Use within the parking lot works, (sort of – there are issues), with 4.5/1000 parking on gross, effective 7.82/1000 on food use on gross, with corresponds to 10/1000 on service area, with restrictions on employee parking, with a dynamic mixture of uses precisely because the lease regulates the hours of operation. For example, Madabolic, a health and wellness use, (which as prosed in the specific plan as an unregulated approved general use) can only be included in the tenant mix because of the restrictions. There was a CUP required for Madabolic.

Without restrictions, the use could easily take a disproportionate amount of the parking, which would damage the interests of the surrounding uses.

Without restrictions of approved uses at the city level, there would be no control over the mix of tenancy within the specific plan. This could be even more acute on second generation space. Therefore, there must be changes, guardrails, put in place or existing

parking will be cannibalized, tenants will be damaged economically, buildings will sit vacant, or simply never be constructed because the design is not financially feasible.

Chapter 3.

1. Pg. 7 Approved Uses
Use MU-TC PU-N
Restaurants* Over 30% max density -CUP Over 30% max density -CUP Banks and Financial P P
Commercial Daycare P or CUP P or CUP
Food Prep/Catering P with Related Restaurant P with related Restaurant Medical/Dental CUP CUP
Massage P – with Hotel P – with Hotel
Theater Live CUP CUP
Theater Movie CUP CUP
Health and Wellness* CUP CUP
Note:
*What about entertainment permits? The inclusion of 100% restaurant approval would be a disaster for parking and competition. It is not a sustainable model **Use not defined on Appendix A

2. Page 13. SFD, Attached, TH Density should be excluded from SVTC. The town center is where density should be approved. The lesser density residential uses should be excluded or severely limited to a max 10% or similar density. This inclusion of higher density would allow for more open space and more parking, both public and servicing the commercial. This is the main design issue for the specific plan model proposed by Good Cities. The plan tries to cut back on parking and open space, so that lesser density housing can use more of the site. This does not serve the interest of the public.

3. Page. 17. All Minimum setbacks should be 15’-20’. Future Internal Connections of 8’ is ridiculous. Can you imagine a 8’ setback for a town house off of the Laughing Monk Parking area? This is where amplified music is being played at night under the CUP/entertainment permit. The current plan shows a row of townhouses that are 50’ +/- from the current live music location.

4. Page 18. No Zero Lot lines permitted at side interior. This could potentially place a TH on the lot line next to the Laughing Monk Parking Lot. This should be prohibited.

It prevents adequate landscape.

5. Page 19. Parking

General Comment. A maximum parking within the commercial district should have posted regulation of 2 hour maximum guideline.
a. 3.5/1000 ratio should be increased to a minimum of 4.5/1000 b. 10/1000 sf good for seating area
c. Office 4/1000 minimum, including 2nd story. Office that is not properly parked should not be built. This is designing in a parking problem. The current office vacancy rate is 32.8% in the scotts valley submarket. Adding office parked at 2/1000 will lead to more vacancy.
d. Standard 2. Sharing of Public/Private should be prohibited. On-Street Parking should absolutely not be counted in the commercial parking requirements. If any consideration is given, a max 50% should be allotted as credit, and that is only if the public parking is expanded. There is not enough parking at sky park now. If this standard is allowed, then the public frequenting sky park will take the commercial parking, and the commercial uses will not be successful. e. Standard 3. Ratio. 4.5/1000 minimum. Proximity of Parking to Commercial facility entrance should be 150’ maximum. The definition should include all parking spaces attributed to the approved use, not just the entry of the parking lot.
f. Each and every project, every building, ever building permit must be approved by a stand alone parking analysis or a documented shared parking program Agreement.

6. Page 46. Add new Standard. Garbage Enclosures should be integrated into the individual building design vs freestanding in parking lot. Service roads will need to be wide enough to accommodate trash vehicles. Current design does not illustrate wide enough ingress/egress/circulation and can not be constructed as illustrated.

7. Page 20. 3.5.1. Item #3. Reduce to 40.’ Provide flexibility.

8. Page 22. 3.6.1. MU-N zone Modifications and improvement to and existing building should not be an approval of a change in use.

9. Page 22. Under no circumstances should minor exceptions to standards include a reduction to parking ratios and proximity.

10. Page 33. Item 7. B. Please consider reducing the height of tree requirement form 20” down to 15’. This improves retail visibility. Retail that can not be seen is not successful.

11. Page 34. Item 4. Should be required. Where there are multiple adjacent parking lots, they should be designed to have vehicular connectivity, both entries and exits, to adjacent parking lots. Suggested to redraft language to include all new major roadways, excluding new curb cuts to Mt. Hermon.

Note. Chapter 2. Figure 2.1 illustrates connectivity from hangar parking lot to main street.

Chapter 4.

1. 4.7.1. Item 2. Strike item, and require a minimum of 15,500 sf. with a minimum of 12,000 sf at Hangar Plaza as currently shown on figure 4.9. and a minimum of 3,500 sf at Tower plaza. These are absolute minimums. There should be more open space on plazas. Why trade townhomes for public open space? Not in the public’s interest.

2. Sidewalk - pedestrian friendly design should be encouraged. A minimum of 20’ walkway standard should be preserved around the buildings on the Plaza(s).

3. The 3,500 sf tower plaza should not be decreased in size by the public walkway. It should be a net minimum. Really it is too small…

4. Page 105. ” Hangar Square is intended to be the main plaza for Scotts Valley.” It is simply too small as designed. Minimum plaza area 12,000 sf. net of all dining space. Standard 4. Strike. Plaza Space. The restaurants on the plaza should be designed to include seating area for adjacent restaurants, but the Plaza should not be reduced in size by the encroachment of the individual restaurants. Cohesion yes. But inclusion of the patio dining should not reduce the public space minimum requirements.

The actual effective size of the plaza is far less than the proposed is 9,000 sf. With the removal of 15’ for dining on both sides of the plaza, 2,900 – 3,000 sf total, the plaza is only 6,000 sf. This is not large enough to accommodate any of the envisioned public gatherings.

NOTE: The hangar building provides it’s own private patio space. Why should the new project skimp on open space? To provide for townhomes? SVTC needs more work force housing, apartments, not more single familiy.

5. Page 105 Guidelines: Use of tree canopy should not impede vision of storefront retail signage.

6. Page 106. Top image. Building to the north boundary. +/- 3,500 sf free standing.

Bottom line is that that building can not be parked without the removal of the Town House residential to the north with a parking field installed in it’s place. The building as represented has no parking lot. This use as shown is a restaurant with 10/1000 sf for dining and 2.5/1000 sf back of house. Minimum parking would require 28 parking spaces for that building alone. This is excluding the patio dining in front of the building. It is disingenuous to represent to the public a building that can not be

built. Remove the town Homes and replace with a parking lot. It does no good to design inadequate parking that puts the Hangar tenants out of business.

Note:

1. The circulation as proposed can not be constructed. There is a private open space patio in front of penny ice cream that is existing. It will not be removed.

The illustrated plan should include circulation that is buildable.

2. The design of the square should not negatively impact the east elevation of the Hangar Building. Nearly the entire Hangar building mass is blocked from Park Street. The south building should be moved south, such that the entrance of the massing frames the Hangar Building, with an alignment matching the Hangar Building south façade. Meaning move it back 30’ and increase the size of the Hangar Plaza to 12,000 sf minimum.

Appendix C: Traffic: Hexagon Report dated October 1, 2025 Improvements to proposed intersections 3 & 4 are critical to avoiding undesired internal (service road and parking lot cross traffic) as well as sending increased traffic up Blue Bonnet/Bean Creek.

1. Figure 14. Intersection: Main St. @ Mt. Hermon. Please consider additional Direction. Exit from Main Street to Mt. Hermon.

Options:
a. Add a lane. Rt, ST/LT, LT
b. RT/ST/LT, LT – as discussed. This is probably the best balanced solution.

2. Figure 15. Great design. Please consider extending stacking lanes north to the entrance of the Post Office/Kings Village intersection.

Figure 8 & 9.

Intersection 2. The additional of 2 SB Trips onto Mt. Hermon might not be accurate, and should be reconsidered. Related Table 5. This indicates that the traffic will actually be improved by the addition of the town center. Please reconsider.

Internal Circulation Reliance.

The report and design seems to include the reliance on the service ally located between the Hangar and Target Center. Please note that this ally is frequently impacted by

truck/delivery, and trash pick up, which frequently blocks the traffic flow entirely. Any reliance on this internal parking lot connection without planning for peak flow to Main street and King’s village is not accurate. Please reconsider impact assumptions.

Robert Gibbs Analysis in Appendix B is so outdated it is no longer accurate. Not that it was accurate in the first place. The report provides little to no benefit and should be excluded from the TCSP references.

There is currently over 20,000 sf of retail that is vacant in the scotts valley submarket.

There is vacant retail that there are no tenants for because it is underparked.

There is vacant restaurant space that there are no tenants for because it is underparked.

Yes, the town center can support more highly curated, experiential related shopping and dining, but it is not accurate to indicate that the market is deep, and providing an out dated, unrealistic market analysis to the public should not be included because it provides a false sense of lease ability.

The only way that the town center commercial will be built is if it is adequately designed.

Parking, Circulation, open space, mix, cross traffic with detailed highly curated intent; design that will not fail because it will generate the sales per foot in order to be successful.

Without exceeding the minimum standards demonstrated in successful project examples, the town center will fail or simply never be built.

EIR.

Hexagon.Figure 2. Existing Public Street Network. Coding in yellow showing internal streets is not accurate. Not all yellow is public.

Implementation:

Construction Management plan that does not put existing Tenants out of business should be part of all future approvals.

Current Conceptual Design Analysis:

1. New Parking lot near hangar, supports only 42 spaces max vs 60 as shown. No landscape on western boundary, easement not plotted correctly, no handicap, no EV charging, not enough trash enclosure. Acute Radius does not work for truck delivery or trash pickup. Supports 9,300 sf @ 4.5/1000

2. Lot near post office. 33 existing spaces are to be shared with post office vs 45, plus 12 on street, as shown. 57 in count but only 24 new. No landscape on western boundary, easement not plotted correctly, no handicap, no EV charging, not enough trash enclosure. Acute Radius does not work for truck delivery or trash pickup.

Supports 5,300 sf @ 4.5/1000.

3. New lot behind tower supports only 28 spaces vs 36 as shown. No landscape on east, no handicap, no EV charging, no trash closure. Acute Radius Doesn’t work for truck delivery or trash pickup. Supports, 6,200 sf @ 4.5/1000 Current Design Parking Totals: The Current Layout only supports a Total sf. 25,111 sf with 113 spaces vs the actual 28,725 sf as illustrated on the plan which requires 130 minimum.

However, that is with the following assumptions:
• zero shared public private, and
• adequate guest parking on residential parcels, and
• at 30% max restaurant density.

Minimum Parking Changes Suggested:

1. Commercial: 4.5/1000 minimum commercial parking with maximum restaurant at 30% with all parking in close proximity. (preferably including of the Parking Ratio/Mix Schedule. please see below)
Solution: CUP governance of increase beyond 30% max restaurant space to increase parking ratio.

2. Guest Parking for Residential:

Solution: 100% Guest Parking on-site within the residential. Existing City of Scotts Valley Guest Parking standard should be maintained.

3. Inadequate Public Parking:

Solution: Add a parking garage at the metro site as a requirement of the specific plan.

4. Effective Commercial Parking Proximity: all parking count, per the approved schedule, to be within 150’ radius maximum of business entry.

Parking Ratio/Mix Schedule
Please consider regulating the specific plan as the Parking Ratio must match relative intensity of restaurant space as follows:
• At 30% max restaurants 4.5 with Optimal mix
• At 40% max restaurants 5.5 with Optimal mix
• At 50% max restaurants 6.5 with Optimal mix
Optimal Mix: a dynamic mixture of food service boutiques, cafes, and restaurants, which have diverse peak parking requirements (Breakfast, Lunch, Dinner) This concept should be used by the PC/CC in the parking study analysis for all future CUPs.

For example: With 113 parking stalls shown on the current plan with current restaurant/café design as shown at 50% max restaurant use, the maximum buildable commercial sf would be 17,380 sf
Or roughly 40% fewer commercial buildings than currently shown.

In other words, there is 40% less parking than needed for the project to be minimally successful. Importantly, this is with zero shared public/private parking.

If shared parking is allowed as currently proposed in the specific plan guidelines, then the project as shown is 50% under parked.

Existing Parking:

None of the existing sky park parking should be used to support the new town center commercial. There isn’t enough public parking as it is to support existing skypark events.

Please consider adding a parking garage to the metro lot as a specific requirement of the Specific Plan.

Outdoor Dining Space:

In the restaurant guest dining space, there is no provision for the consideration of the total outdoor dining space in the parking ratio analysis. The specification is 10/1000 for indoor dining only. Meaning, this current plan is further deficient by the outdoor patio space shown at 10/1000.

There is nearly 5,000 sf of patio shown as dining area. That is another 50 parking stalls.

Shared Parking Condition of Approval:

The Hangar development has a condition of approval which was intended “…to assist in the future of an orderly development of the town center specific plan core.” “The property owner shall work with the City and future town center developers on a shared parking program when development of the town center core area occurs.” This statement does not provide the City of Scotts Valley the right to design a specific plan that has a structural parking deficiency which cannibalizes the Hangar project parking.

The Hangar is parked at 4.66/1000. The Specific Plan should maintain this as an absolute minimum design standard with a 30% restaurant mix.

The City should seek to exceed the design standards so that the commercial within the core can generate the per sf sales required to support the high cost and maintenance of new construction, or else the project will simply yet again, not be built, or worse yet, have the commercial portion of the project be an economic failure because that which was not economically feasible was subsidized by the townhomes, “just to get it built.” This does not serve the Citizens interests.

King’s Village Shopping Center
230 Mt. Hermon Road #200
Scotts Valley, CA 95066
November 19, 2025
City of Scotts Valley Planning Department
Attention: Taylor Bateman
1 Civic Center Drive, Scotts Valley, CA 95066
Email: [email protected]
Re: 2025 Scotts Valley Town Center Specific Plan
Dear Scotts Valley Planning Commission,
We are writing regarding the draft 2025 Scotts Valley Town Center Specific Plan and EIR.  We are the owners and operators of King’s Village Shopping Center, which is Scotts Valley’s longtime retail anchor and within the Specific Plan’s boundaries.  We are, and have been for decades, greatly supportive of the City’s attempts to modernize the City’s zoning and planning codes to help get the Town Center developed.  With our many decades of commercial real estate experience in Scotts Valley and the local community, we write to respectfully request some edits to the Specific Plan to help improve it.  Most of our requests fall within two major categories: please (1) make the Specific Plan sufficiently flexible to be a valuable document for the Town Center for many decades to come and (2) revise provisions that needlessly make development more expensive, making the desired Town Center less likely to be built.

As longtime commercial real estate professionals, we have seen many changes in commercial real estate uses and trends over the years.  Commercial uses have changed drastically due to the decline in brick‐and‐mortar retail, rise of Amazon and e‐commerce, ability to work remotely, and increased popularity in fitness and service related uses.  One thing we have learned is that change is constant.  Please allow the Specific Plan to be nimble enough to accommodate whatever changes come, even (perhaps, especially) the ones we cannot predict.  Please change the General Land Use Standards in the Specific Plan to be inclusive instead of exclusive.  Please remove “All uses not permitted by right or CUP are prohibited.”  Please make more uses permitted by right; uses that are not permitted by right should be permitted by CUP.  If a future planning department or city council believes that a use is appropriate for the Town Center area, it should be allowed by CUP rather than banned by a document that may be decades old.  Specifically, for the Neighborhood Mixed Use district please make Night Clubs allowable by CUP, Bars, Tasting Rooms Tap Houses and Taverns Permitted (not CUP), Boutique Alcohol Sales Store Permitted (not CUP), Commercial Cannabis Business CUP, Auto and Light Truck CUP (like a small Rivian Dealership, not just a tiny showroom), grandfather existing Drive Through facilities so they do not have to be removed even if the tenant changes; it is safer/more healthy for sick patients to pick up prescriptions at Walgreens via the drive through; Laboratories (Restricted R&D) make CUP, Warehousing and Logistics CUP, minor repair and maintenance CUP, vehicle rental (not including onsite fleet) should be permitted, hostels should be CUP, SRO should be P or at minimum CUP, Wireless Telecommunication Facilities should be Permitted.

Many of the “active retail uses” that are required on the ground floor of the Town Center Core (like hot yoga, Pilates, coffee shops,  bars, etc.), have real world parking needs that far exceed the required 3.5 spaces per 1,000sf, especially if street parking is allowed to be counted towards the total.  Further, the customers of these active retail businesses should have access to parking within close proximity. The real world parking needs and location of the provided parking must be considered or the customers of the active retail businesses will try and poach parking at neighboring properties with more parking.

We also believe that there should be more flexibility in possible residential redevelopment projects within the Neighborhood Mixed Use area.  Please allow for more density in the Neighborhood Mixed Use district; the density range of 20‐32 units per acre is too narrow and provides little flexibility to adapt to the needs of the community and market conditions.  Make density 15‐50 units per acre and adjust the commercial floor area maximum to 2.5 accordingly.  We

have seen narrow development standards like these stymie projects that communities want because old specific plans were not flexible and didn't foresee what would be wanted and needed in the future.  Also, please allow more broad building heights and don't rely on state law to supersede local height limits.  Increase the current height limit to 60 feet (this may be desired 20+ years from now).  Similarly, allow more flexibility and eliminate the maximum 20 foot setback from Kings Village Road (it may be desired to have buildings farther from the street; especially with 1,000+ new residents making the street busier).  Likewise, please make the parking requirements for residential development more flexible; 20+ years from now car ownership could be very different than it is today.

We also respectfully request that any new public art program only apply to the development of new buildings.

Any such public art program should be able to be satisfied via a project’s own inclusion of art that meets certain basic requirements or by paying a reasonable fee (under .5% of the development cost).  Existing buildings, especially those in shopping centers like King’s Village, which have numerous large scale murals, should not be forced to deal with significant expenses when making repairs or upgrades for new or existing local businesses.

We also ask that the Specific Plan specify that property owners of existing buildings shall not be charged any fees, taxes, or be forced into a Property and Business Improvement District (or any similar association or improvement districts) for Town Center related improvements; especially infrastructure improvements.  Existing property owners have already paid impact fees and constructed the necessary infrastructure for their properties so the responsibility for new infrastructure and improvements should be the sole responsibility of the Town Center core developers.

Please have the Specific Plan specify that any redevelopment of the METRO site will have to honor its agreement with the Ow Family and provide as much accessible parking as is currently provided.  We have partnered with the City and other local governmental agencies for many, many years and we would like our cooperative relationship to be respected and upheld.

Thank you all so much for your hard work on this very important document, which has the ability to make or break Town Center development and city prosperity for future generations.  Please ensure that the Specific Plan has the requisite flexibility to ensure it’s beneficial to the community for many decades.  We really appreciate your service to this great City!
Sincerely,
George Ow, Jr.; David Ow; Terry Ow; Karen Ow; William Ow; Jasmine Ow‐Hurst; Matthew Turner; Benjamin Ow; Andrew Ow; and Kyle Winterhalder on behalf of
King’s Village Shopping Center
CC: [email protected]; [email protected]

CyAs Tech
From: Juliana Maggio
To: Scotts Valley Planning Department
Subject: Taylor Bateman 1 Civic Center Drive, Scotts Valley, CA 95066 Date: Wednesday, November 19, 2025 9:59:34 PM
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The proposed plan for the town center appears to have an excessive amount of house units and we are concerned about the traffic that this will create in such a small area.

The town center we imagine is a place for gathering where there’s outdoor and indoor space to hang out with friends, family and neighbors, outdoor space for sport games, pump track, skate park and space for music events, arts fairs, and food tracks. We do not envision any of those key parts of sky park to dissapear! We envision more restaurants, cafes and shops where we can buy clothes, and shoes and gives these town a more cohesive look and feel. Buildings is not a town center. Apartment is not a town center. That is not what residents of this town are looking for.

Many issues with creating a denser population in his small town with such limited roads and resources, and especially limited roads in case of need for evacuations, Please give this town what it deserves
Juliana

From: Kate Halper
To: Scotts Valley Planning Department; City Council
Subject: Attention: Taylor Bateman - Public Comments on the Town Center EIR Date: Wednesday, November 19, 2025 2:43:18 PM
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Hello -
I am writing in response to the EIR for the new Town Center project, submitting my public comments within the timeframe. I am seeking detailed response to these comments, as I am unable to attend the meeting tomorrow night. I don't see the following items addressed in the available documentation.

How will the City address current traffic congestion on Mt. Hermon Rd once it's amplified by the addition of new community space and more than 650 new residences? As you are aware, traffic currently backs up onto the 17 off-ramp in the afternoons.

How do adequate bike lanes and safe bike parking/lockers factor into the Town Center? That doesn't appear to be referenced anywhere
In the EIR, it appears we will lose several existing community features at Sky Park - mainly the pump track, skate park, and dog parks. Is that accurate? Will those amenities be relocated? As a parent with two kids and a dog raising my family in Scotts Valley, these safe and accessible community features are essential.

I understand there are plans for a dog park on the other side of town, but what about this current side of town? Surely many of the residents of the new 657 homes, all of whom will not have a yard of their own, will have dogs that need daily exercise. If even 20% of those homes have dogs, that's more than 100 dogs with no place to play There does not seem to be adequate parking for the new homes or the retail spaces; what formula is used to calculate how much parking is required to serve retail, gathering, and residential space? There are many mentions of being "pedestrian-friendly", but folks still need to park somewhere to enjoy walking around.

For those not living in the town center, where will parking be for community events, like the Art & Wine and Food Truck Fridays?
Questions aside, this plan seriously lacks in planning for residents who already live in Scotts Valley. Inadequate plans for traffic flow on Mt. Hermon, safe bike access and parking, auto parking, kid-friendly features, and removing the pump track and dog park demonstrate a significant lack of judgment from the planning department. Without updating our infrastructure and adding improved amenities rather than removing them, we can't serve existing community members, let alone those that move into the new units. For a plan that has taken so long to develop, this one is an overall disappointment.

I look forward to understanding the answers to the questions I've posed. And, I hope the planning department and city council will take into account the many community members who are concerned about these issues as well.

Thank you for your time.
-Kate Halper

From: Renee Inlow
To: Scotts Valley Planning Department
Subject: Town Center - EIR Comments
Date: Wednesday, November 5, 2025 1:50:28 PM
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Hello SV Planning Department,
I write to you with concerns about the Town Center proposal. After reviewing the documents posted online I found an error in the upload of Appendix E - Water Supply. That link directs you to the transportation analysis. Water supply is a critical component of this project and impacts all current and future Scotts Valley Residents. We depend completely on ground water in our community. Please provide this document to me via email or post to the website correctly.

I was also not able to determine how many housing units are actually proposed. Within various documents, I see numbers ranging from a minimum of 300 units and a maximum of 657 units! This is a massive range and will greatly impact Skypark community use, the existing Skypark neighborhood, and surrounding shopping centers.

Reviewing the transportation study I did not see any mention of parking. How can we propose over 600 homes + new shops without a clear parking proposal? What is the current proposed number of parking spaces? The drawings show 3 tiny parking lots that will be terribly insufficient for even the residents of this new development, little alone the customers of the shops and restaurants.

Already the events held at Skypark are well attended (without an additional 1200 residents added to the mix). Finding parking during the art and wine fest, and even simple soccer games and food truck events is already challenging. Often these events depend on the dirt lot for parking. The dirt lot will soon be developed.

How will the existing residents of Scotts Valley (not living in the new development) access the park and its events? Will all of these fun community gatherings stop? Thank you for your consideration. I am not against the development of this area, I simply want the proposal to be realistic in size and scope. I do not think that the area can accommodate the current proposal.

Renee Inlow
831-278-0655

From: Nesh Dhillon
To: Scotts Valley Planning Department
Subject: Town Center-comments/SCCFM
Date: Friday, November 21, 2025 11:30:22 AM
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City of Scotts Valley Planning Department
1 Civic Center Drive, Scotts Valley, CA 95066
PROPOSED PROJECT DESCRIPTION: 2025 Scott's Valley Town Center Specific Plan (State Clearinghouse #2025050499)
Attn: Taylor Bateman
This is an exciting development for both the community and City of Scott's Valley and I look forward to seeing it come to fruition.

After some review, I could not locate any mention of space for a farmers' market which has unique needs. The proposed project has many references to civic activities, events and other community engagement objectives. However, there is no specific designation for a certified farmers market (CFM) or consideration as far as I can tell in this proposal. Santa Cruz Community Farmers' Markets (SCCFM) understanding was the future development would not only include the necessary infrastructure (utilities,weather protection,etc) to operate an effective year round market in the heart of the development but also have the opportunity to participate in those discussions. I think our feedback and experience in the region would be valuable to the discourse. We encourage the planning department to consider the positive impact of a year round farmers' market as both an incubator for new food ideas, access to locally grown produce and a time tested community engagement tool that can be leveraged for a variety of needs to enhance the community cohesion.

Presently, we are looking for another site for the seasonal Scott's Valley FM. The current location is slated for redevelopment (Boys and Girls Club) and the footprint is not going to work to have an event. Additionally, after 16 years, operating at multiple locations in Scott's Valley, we are convinced that Mount Herman Road is where we need to be and ultimately part of the fabric work of the future town center. Space is limited but we are on the search.

Please considering the following in your discussions concerning the Town Center:

1. Specific mention for the need of a "certified farmers' market" in the design plans and permanent site for the Scott's Valley FM.

2. Consultation with SCCFM on "best" design concept/options and infrastructure basics.

3. Efficient and effective layout/design integration of CFM and new retail, civic events and

entertainment.

4. Consideration of Santa Cruz County Agriculture and its regional economic impact and importance.

5. Strong consideration of the relationship between local food production and restaurants (farm to table). A local year round market would be the source for restaurants and cafes that prioritize locally farmed goods, value added products and unique cuisines.

6. CFM's represent a distribution point for CAL FRESH (EBT) and food assistance programs like "Market Match" (https://santacruzfarmersmarket.org/campaigns/market-match/). SCCFM distributes over 600K in Cal Fresh through the five markets we operate in the county.

7. CFM's serve as emergency food distribution points (farmed goods, food boxes,etc) and were determined to be an "essential business" during the Covid-19 lock down.

Please let me know how SCCFM can assist in this project and thank you for considering our suggestions.

Thank youNesh Dhillon
Executive Director
Santa Cruz Community Farmers' Markets

CyAs Tech
From: Sue Draper
To: Scotts Valley Planning Department
Subject: Town Center question for EIR
Date: Monday, November 24, 2025 4:40:20 PM
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Regarding the current EIR for the proposed Town Center please address the following questions:
1) Where in the report does it address the recharge of water to our aquifer? Scotts Valley currently uses its open space to collect and recharge the aquifer. Every additional business and residence has a direct impact on our water usage.

Please explain the measures taken to mitigate the loss of open space (12.5 acres) of recharge down to 2.68 acres of recharge space. This appears to be an Irreversible Use of Nonrenewable Resource
Is that really (Less than Significant Impact? What exactly is the Mitigation Incorporated) 2) Traffic impacts Every resident and business owner using Mt Hermon as an access to Hwy 17, getting children safely to and from school, and day to day operations of vital business for the residents they support. I see several New streets in the Town Center Plan but no alternative routes are proposed. With our current volume of traffic, residential neighborhoods are already experiencing the impact from inadequate flow, Estrella Drive has had to implement speed bumps to try and detour "cut through" traffic. Baja Sol and Whispering Pines are also being negatively affected by additional "cut through" traffic as we speak.

Please explain how the hundreds of additional housing units, all using Mt Hermon as their access to work, schools, and business will have a (Less than Significant Impact? What exactly is the Mitigation Incorporated)
3) Parking for residents and business owners appears to be adequate. ALL of our schools, shopping/ restaurants, and many residential neighborhoods are currently impacted by not planning for necessary parking. Did anyone drafting this report try parking in Victor Sq on an afternoon in order to get groceries, a meal, or a beer. Try finding a space at Nob Hill since the EV conversion of the parking lot during the afternoon. Try parking even remotely close to Chase Bank any time of the day. Honestly the huge missing link in the Town Center for success is inadequate parking. I predict the overflow will end up using existing parking intended and paid for by our current business owners.

These are my biggest concerns.

I look forward to hearing from you,
Sue

YIMBY Law
2261 Market Street STE 10416
San Francisco, CA 94114
[email protected]
12/04/2025
City of Scotts Valley
Planning Commission
1 Civic Center Drive
Scotts Valley, CA 95066
Re: Scotts Valley FEIR and Town Center Specific Plan
YIMBY Law is a 501(c)3 non-profit corporation, whose mission is to increase the accessibility and affordability of housing in California. YIMBY Law sues municipalities when they fail to comply with state housing laws, including the Housing Element Law.

Today we write with concerns regarding the proposed insufficient zoning of the Specific Plan. The Housing Element’s Programs committed to zoned capacity that the program does not meet, which threatens the continued certification and compliance with state law. Programs H-1.1 and H-1.10 required Town Center parcels to support at least the level of development assumed in the site inventory. Full zoned capacity on city-owned parcels amounts to 963 units and 898 on others as listed within the sites inventory. However, the proposed capacity is only 657 units.

Government Code § 65583 requires each jurisdiction’s housing element to include “a program which sets forth a schedule of actions” that the city “is undertaking or intends to undertake” to implement the goals, policies, and objectives of the housing element.

Once adopted and certified by HCD, these programs are not optional. They are enforceable commitments, and jurisdictions are required to follow through. Government Code § 65583(c) uses mandatory language: programs “shall” identify actions, timelines, and responsible agencies. The Legislature’s intent is clear—cities must not simply adopt programs as aspirational statements but must carry them out in good faith.

Beyond the insufficient capacity, specific City-owned parcels may be downzoned from the capacity as represented in the Housing Element. If APN# 022-721-06 is designated as Public/Quasi-Public, they will be subject to a designation that does not allow residential uses. This action would violate § 65863 No Net Loss provisions and § 65583.2(h)(2) requirements that at least 50% of a jurisdiction’s lower-income housing need be accommodated on sites designated exclusively for residential use, where non-residential or mixed uses are not permitted.
1

Every low income site in the proposal would be rezoned to allow non-residential uses.

Under California Court of Appeal’s recent decision in New Commune DTLA LLC v. City of Redondo Beach, Housing Element rezoning programs cannot lawfully allow exclusively non-residential development on sites designated to accommodate lower-income housing. Such a rezoning does not meet legal requirements under Housing Element law.

Scotts Valley may only remain compliant if the low income sites allow residential uses by right and do not permit non-residential units.

The current zoning plan does not comply with the Scotts Valley Housing Element or California rezoning requirements. Without going through this process, Scotts Valley cannot ignore or abandon the programs it committed to in its adopted housing element.

Failure to comply with Housing Element law exposes the City to significant legal risk.

This includes potential litigation under Government Code § 65587, enforcement actions by the California Attorney General, loss of state funding eligibility, and the risk of being subject to Builder’s Remedy projects. Alternately, the Specific Plan must allow for the Housing Element capacity, correct the proposed downzoning and non-residential uses, and ensure that all parcels referenced in the sites inventory allow 100% residential uses by right.

I am signing this letter both in my capacity as the Executive Director of YIMBY Law, and as a resident of California who is affected by the shortage of housing in our state.

Sincerely,
Sonja Trauss
Executive Director
YIMBY Law
YIMBY Law, 2261 Market Street STE 10416, San Francisco, CA 94114 2

Date: December 3, 2025
To: Scotts Valley Planning Commission
[email protected]
Re: Comments on the Proposed Scotts Valley Town Center Specific Plan – Compliance with Housing Element Commitments and State Housing Law Dear Commissioners:

Santa Cruz YIMBY appreciates the opportunity to provide comments on the City of Scotts Valley’s proposed Town Center Specific Plan (“TCSP”). As we have explained in our prior comment letters, the City’s Housing Element establishes clear, binding rezoning obligations for the Town Center area—obligations the current draft Specific Plan does not satisfy.

1. The Specific Plan Continues to Under-Zone the Town Center Relative to the Housing Element
As detailed in our June 10, 2025 and November 24, 2025 comment letters, the Housing Element commits the City to planning for significantly more housing capacity in the Town Center than is reflected in the current draft Specific Plan. The Housing Element’s Programs H-1.1 and H-1.10 require the City to implement the full Appendix F capacity methodology and ensure that the Town Center parcels support at least the level of development assumed in the site inventory—approximately 898 units at full zoned capacity, or 963 units when accounting for the City’s obligation to achieve at least 300 units on the three City-owned parcels.

Your own Housing Element and our comments make clear that these are not optional policy preferences; they are legally binding Housing Element implementation commitments. Despite this, the draft TCSP maintains a significantly reduced total capacity of 657 units, contrary to the commitments the City made when HCD certified the Housing Element.

2. The Proposed Downzoning and Mixed-Use Zoning of
Lower-Income Housing Element Sites Violates State Law Unless the City First Amends Its Housing Element
We are deeply concerned that one of the three City-owned parcels identified in the Housing Element as accommodating 64 lower-income units, the parcel with APN# 022-721-06, is proposed to be redesignated to Public/Quasi-Public (P) under the draft Specific Plan. The current Land Use element of the Scotts Valley general plan indicates that the P designation does not permit residential uses, resulting in a de facto downzoning of a site the City explicitly relied upon to meet its lower-income RHNA obligations.

This action is unlawful for two independent reasons:

1. Government Code section 65863 (the No Net Loss Law) prohibits any reduction in the density or residential capacity of a Housing Element site unless the City simultaneously identifies equivalent replacement sites that fully maintain the Housing Element’s lower-income capacity by income category. A jurisdiction may not downzone, redesignate, or otherwise reduce realistic capacity on an inventory site unless it makes the required findings and secures replacement capacity at the time of the action.

2. Government Code section 65583.2(h)(2) requires that at least 50% of a jurisdiction’s lower-income housing need be accommodated on sites designated exclusively for residential use, where non-residential or mixed uses are not permitted. It allows use of mixed-use sites for lower-income RHNA only if those sites (a) allow 100% residential use, and (b) require that residential uses constitute at least 50% of the floor area of any mixed-use development.

By redesignating an inventory site to a non-residential Public/Quasi-Public zone and by rezoning the remaining lower-income sites to mixed-use districts that allow stand-alone commercial or civic uses, the draft Specific Plan both:

A. reduces lower-income capacity in violation of section 65863, and B. fails to meet the section 65583.2(h)(2) requirement that lower-income need be sited on parcels that function as bona fide residential or residential-dominant sites.

Under state law, Scotts Valley has only one lawful path if it wishes to proceed with this downzoning:

The City must first amend its Housing Element to remove the site from the inventory, subject the amendment to HCD review, and simultaneously identify equivalent replacement lower-income capacity elsewhere in the City.

Only after completing that Housing Element amendment—and demonstrating continued compliance with section 65583.2(h)(2) and section 65863—could the City legally redesignate the parcel to Public/Quasi-Public.

The City has not taken these steps. Adopting the TCSP as currently drafted would simultaneously (1) violate state law, (2) jeopardize the validity of the Housing Element, and (3) expose the City to HCD enforcement and litigation risk.

3. The Specific Plan Must Ensure That Lower-Income Sites Allow 100% Residential Use and May Not Permit Exclusively
Non-Residential Development on Those Parcels
The California Court of Appeal’s recent decision in New Commune DTLA LLC v. City of Redondo Beach has clarified that a Housing Element rezoning program cannot lawfully allow exclusively non-residential development on sites designated to accommodate lower-income housing (see §65583.2(h)(2) above). The court held that a city fails to implement its Housing Element if its rezoning allows commercial-only or otherwise non-residential projects on parcels the Housing Element relies on to satisfy lower-income RHNA.

Yet, the TCSP draft proposes that every lower-income Town Center site listed in Scotts Valley’s Housing Element—including the City-owned parcels and the METRO and Kings Village parcels—is proposed to be rezoned to allow non-residential uses as permitted stand-alone uses, such as retail, restaurants, offices, hotels, or public facilities.

In the TCSP use tables (Draft Chapter 3), both MU-TC and MU-N allow a broad array of commercial uses by right or by CUP, including uses that could occupy the entirety of a parcel without any housing. This directly conflicts with state law and with the New Commune precedent.

To comply with state law, the City must ensure that:
● All Housing Element lower-income sites must allow 100% residential uses by right, and

● Non-residential uses may occur only as part of a mixed-use project that also includes the required level of residential capacity, not as a stand-alone use that displaces required housing.

The TCSP does not currently include these safeguards.

4. The City Must Ensure That the Rezoning Fully Implements the Housing Element Before Plan Adoption
Finally, state law requires that all rezoning programs included in a certified Housing Element be fully and faithfully implemented. Scotts Valley’s TCSP is clearly a Housing Element “shortfall” rezoning program, and therefore the City must ensure:
● Consistency with all Housing Element programs and site inventory assumptions;
● Full preservation of lower-income site capacity;
● Zoning that facilitates (not merely nominally permits) the quantities of housing required; and
● No downzoning or reduction of capacity without a prior Housing Element amendment and HCD review.

The City’s staff acknowledges that the TCSP rezoning program is being adopted specifically to satisfy Housing Element Program H-1.1 and the City’s RHNA commitments.

Given this, the TCSP must be corrected to reflect the City’s legal obligations.

Request
For the reasons above, Santa Cruz YIMBY respectfully requests that the Planning Commission:

1. Direct staff to revise the Town Center Specific Plan to provide the full housing capacity required under the Housing Element, consistent with Programs H-1.1 and H-1.10.

2. Remove the proposed downzoning of the City-owned 64-unit lower-income site, or alternatively, require a Housing Element amendment identifying a replacement site before adoption.

3. Revise zoning for all lower-income Housing Element sites subject to a rezoning so that exclusively non-residential projects are not permitted, consistent with New Commune DTLA LLC v. Redondo Beach.

4. Ensure that all lower income Housing Element parcels included in the TCSP allow 100% residential development by right and support realistic, feasible multifamily development at the required densities.

We strongly support a vibrant, mixed-use Town Center. However, Scotts Valley must also comply with its Housing Element and state housing law. Santa Cruz YIMBY urges the Commission to adopt a legally compliant plan that fully meets the City’s obligations to plan for, accommodate, and facilitate desperately needed lower-income housing.

Thank you for your attention and for the opportunity to comment.

Sincerely,
Rafa Sonnenfeld
Janine Roeth
Gavin Roth
Ryan Meckel
Jocelyn Wolf
Leads, Santa Cruz YIMBY
Santa Cruz YIMBY Mission: We envision a community where our neighbors of all ages, cultures, abilities, and incomes, can make Santa Cruz County their home. In response to the ever-increasing cost of living, we advocate for more affordable housing to meet the needs of our growing population.

Santa Cruz YIMBY is a chapter of YIMBY Action, a 501(c)(4) nonprofit organization.

From: Trent C <[email protected]>
Sent: Friday, December 5, 2025 1:09 PM
To: Cathie Simonovich <[email protected]>
Subject: Scotts Valley Town Center
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I am a resident of Scotts Valley, living near the middle school. I live there with my 2 children and their mother. We very much love Scotts Valley for the unique small town feeling, and community. Along with the sense of safety and close to nature conditions, that is none existent in cities like Santa Cruz, and even Felton. I am very much against this property development. It will be the beginning of a process that robs us residents of everything that make Scotts Valley unique and the most desirable area to raise a family in. All I see that will result from this is; traffic, less open space, degradation of community, schools and teachers overwhelmed, increase in crime, drain on city resources, becoming more like Santa Cruz, and many other second/third order consequences. This will not end well for the community of Scotts Valley. The only individuals that will truly benefit from this project moving forward are the developers/realtors, and the politicians that get to pat themselves on the back for "achievements" that look great on paper but are a slow poison for the once thriving close-knit community.

Best Regards
Trent Cates

December 9, 2025
To: City of Scotts Valley Planning Department
Re: Town Center Proposal
Dear Friends:

I am writing in opposition to the proposed Town Center development.

Over the years, the members of the Scotts Valley City Council have been actively exploring and promoting the idea of a town center to be built on the grounds of the former airport property. And, over the years, a few out of town developers have prepared different mixed use housing (stack and pack) with retail space proposals.

Have the council members ever asked the good citizens of Scotts Valley if they want or need a town center made up of mixed use buildings surrounded by asphalt and concrete “landscaping”? Do we want every square inch of bare land in the city to be built up for the profit of others?
I propose that the city leadership explore a green space option for our town center. We have a sports field, skate park and dog park. Let’s join that together with a town center public garden made up of greenery, paths, fountains, benches, and a playground for children?
We have lived for many years without building on the proposed space. Let’s go with a scenic, green and enjoyable park for our citizens and visitors, and call that our town center.

Thank you,
David Jones
109-B Bluebonnet Ln. Scotts Valley
831 234-6704