Attachment 18�t.
i
HILLBROOK
SCHOOL
December 1, 2014
Marcia Jensen, Mayor
Members of the Town Council
Town of Los Gatos
110 E. Main Street
Los Gatos, CA 95030
RECEIVED
DEC 01 2014
TOWN OF LOS GATOS
PLANNING DIVISION
RE: Hillbrook School— Appeal of Planning Commission Decision
Dear Mayor Jensen and Members of the Town Council:
We are writing on behalf of Hillbrook School (Hillbrook) with respect to its request
for an amendment to its Conditional Use Permit (CUP) that the Planning Commission
approved with modified conditions on October 6, 2014 (Project). We are very grateful
that the Planning Commission approved the school's request for 99 additional students.
However, we remain deeply troubled by the consequences associated with the Planning
Commission's imposition of a maximum daily 880 vehicle cap with accelerated
penalties. We believe that the Planning Commission made a material, quantitative error
by imposing an 880 hard cap instead of an average. The error was based on
misunderstood and /or misinterpreted data points in the record.
Therefore, on October 8, 2014, Hillbrook appealed the Planning Commission
decision on the grounds that the Planning Commission erred or abused its discretion
because (1) the modified conditions were not supported by data or substantial evidence
in the record; (2) the modified conditions could abridge Hillbrook's vested right to 315
students; and (3) the modified conditions do not have the necessary nexus to the
project or its impacts, in violation of constitutional principles.
The following expands on the grounds for this appeal and establishes a fair,
appropriate path forward for the Town of Los Gatos (Town), the neighbors, and
Hillbrook.
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Background
A. Project Refinements
By way of background, in direct response to the neighbors' concerns about the
Project's potential impacts on the local streets, Hillbrook refined its proposal to include
the following key elements:
• Enrollment: Increase from 315 students to 414 students.
• Average Daily Count (ADT): 960 average daily vehicles (480 each way)
entering and exiting the campus.
• AM /PM Peak Periods: Reduction in our AMIPM peak period maximum of
outgoing vehicles from 165 to an average of 150 vehicles during drop- off/pick-
up periods.
• Summer: 480 average daily vehicles (240 each way), half of the regular
school year average and no summer evening events.
• TDM Program: Implement mandatory TDM program with a bi- annual
reporting requirement to the Town.
• Enforcement: The Town will engage a third party, independent consultant to
determine compliance with the trip cap averages based on the driveway
sensor data.
• Monitoring Periods: Three periods to reflect Hillbrook's terms, First Term,
Second Term, and Summer Term.
• Penalty: Escalated penalty system starting at $1,000 per trip in excess of the
daily, AM or PM average, with subsequent periods of non - compliance
increasing to $5,000 and then $10,000 per trip, with a reset to $1,000 per trip
after a return to compliance.
B. Planning Commission Modifications
During its deliberations, the Planning Commission made major modifications to
the CUP proposal, which are summarized here.
Enrollment: Increase from 315 to 414 students over the course of three
academic years, provided that Hillbrook meets the maximum daily count of
880 trips based on monthly monitoring and compliance for the first year, every
two months for the second year, and every three months thereafter.
• Maximum Daily Count: 880 maximum daily vehicles entering and exiting the
campus.
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• TDM Program: Implement all measures of the Final TDM program prepared
by Nelson /Nygaard.
• Enforcement: The maximum daily trips will be monitored by way of an
electronic, underground counter that transmits vehicle counts to a third party.
This third party shall send the data to the Town for each monitoring period to
determine compliance with the Maximum Number of Daily Vehicle Trips.
• Monitoring Periods: Every month for the first year, every two months for the
second year, and every three months thereafter.
• Penalty: Escalated penalty system starting at $1,000 per trip in excess of the
maximum daily trip cap, with subsequent periods of non - compliance
increasing to $5,000 and then $10,000 per trip and a 10% enrollment
reduction in the next academic year.
II. Project Impacts
The breadth of analysis undertaken by Town staff and its consultants to inform
the Planning Commission's deliberations was exhaustive and exceeded the required
reporting requirements. By way of history, after moving forward with an Initial Study and
a Mitigated Negative Declaration, the Town subsequently decided to conduct a fully
scoped Environmental Impact Report (EIR) in order to thoroughly analyze the potential
impacts triggered by the Project.
The Draft Environmental impact Report (DEIR), released in March 2014,
concluded that Hilibrook's increased enrollment would cause no significant Impacts to
the neighborhood. This conclusion is important because the California Environmental
Quality Act (CEQA) provides the Town with the State - mandated framework for
analyzing a project's physical effect on the environment. The DEIR found that the
Project triggers either no impacts or impacts that are less than significant under
CEQA.
The Town received several hundred pages of comments on the DEIR. The Final
Environmental Impact Report (FEIR) was released on August 29, 2014 and
meticulously responded to each and every comment submitted on the DEIR. It also
analyzed the Project refinements. The FEIR confirmed that the changes proposed to
the Project would reduce the Project's impacts identified in the DEIR, which already
were less than significant under the Town's CEQA significance thresholds.
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Hillbrook's Letter of Justification attached as Exhibit A summarized the substance
of the FEIR's "Master Responses' that were compiled in response to numerous, similar
comments on the DEIR. It deserves repeating here:
• TDM Effectiveness — Because Hillbrook now proposes a condition of approval
that requires implementation of the Final TDM Plan, as well as proposed daily
limits, reduced peak period limits, third -party compliance determination and
penalties for exceedances, the Project is expected to achieve further trip
reduction, as the school has successfully done in the past.
• Ann Arbor Access Alternative— Because the Project's traffic - related impacts
were determined to be less than significant and Section 15126.6(c) of the
CEQA Guidelines states that alternatives should be able to "avoid or
substantially lessen one or more of the significant effects," the Town
exercised its discretion and determined that there is no justification for a
CEQA evaluation of the Ann Arbor Drive Alternative, especially when
considering that the Town identified two other alternatives that satisfy CEQA's
"rule of reason" with respect to a Lead Agency's choice of alternatives.
Traffic Safetv— Traffic safety was evaluated for the Project by the Town's
traffic engineering consultant. Consistent with the Town's and standard
industry practice, TJKM collected traffic data, reviewed traffic volumes and
pedestrian /bicycle counts, reviewed traffic conditions,, observed roadway
conditions and site line visibility along routes to the school, observed
pedestrian /bicycle traffic, and reviewed accident reports. After this exhaustive
analysis, TJKM determined there are no unsafe conditions and the
existing roadways are performing in a satisfactory manner, which led to
the conclusion that the Project would not cause an increase in traffic that
would result in any significant traffic safety impacts.
The DEIR concluded and the FEIR confirmed that the Project will not exceed any
CEQA thresholds, resulting in no impacts or less than significant impacts across the
board, requiring absolutely no mitigations to ameliorate any impacts. Importantly,
the DEIR and the Traffic Impact Analysis evaluated the Project's traffic impacts in
accordance with the Town's Traffic Impact Policy, VTA Transportation Impact Analysis
Guidelines, and standard traffic engineering professional practice. Both determined that
the Project will not exceed CEQA significance criteria.
In the eyes of the governing law, therefore, this Project has no significant impacts
that would require any mitigation when measured against the Town's thresholds of
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significance —the same thresholds applied to all other applicants seeking project
approvals in Town. Consequently, these documents reflect the Town's independent
judgment and thorough analysis, and the Planning Commission appropriately certified
these documents in accordance with CECA.
III. Planning Commission Parameters
Prior to the Planning Commission hearings beginning in September, numerous
sources emphasized the legal parameters that applied to the Planning Commission
proceedings. As shown below, the record reflects complete unanimity with respect to
the fact that the Planning Commission did not enjoy unfettered discretion when
modifying Hillbrook's conditions. Unfortunately, the legal advice of the Town Attorney
was ignored by the Planning Commission on the evening of October 6, 2014 when they
imposed excessive conditions that bear no reasonable relationship to the public interest.
First, in its Letter of Justification dated September 17, 2014, Hillbrook set forth its
reasoning for the very specific modifications sought to its existing CUP, namely an
increase in enrollment from 315 to 414 students, with an average daily traffic count to
address neighborhood concerns. In that letter, Hillbrook reiterated the Town's direction
to the Planning Commission as to the rules and legal principles applicable to the
Hillbrook decision. That letter stated:
"...Section 29.20.305 of the Town's Code provides that these CUP
modifications are "heard anew and the deciding body may impose
new conditions or modify previous conditions." However, as noted in
the [FEIR] for the Project, the Town's discretion is limited by
constitutional principles requiring that there be a nexus between the
impacts of the Project and its conditions of approval, such that any
conditions imposed must ameliorate the actual amount of harm that
would result from the Project. As stated in the FEIR, "[a]lthough the
Town may impose new conditions pursuant to Section 29.20.305,
such an action does not permit the Town to revisit the wisdom of prior
decisions to grant the existing [CUP] in the first place. Town staff is
unaware of any potential harm that the proposed [CUP] amendment
would cause that would support many of the [neighbors'] proposed
conditions." (FEIR, page 8.5 -18.) Consequently, it is important that
the Planning Commission recognize these important legal principles
during its deliberations."
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Second, the FEIR concluded that nothing in CEQA supports the imposition of the
more stringent conditions of approval proposed by a small faction of neighbors, and the
Town only has the authority or "police power" to impose conditions that address the
actual effects of the Project —they cannot be excessive (FEIR, 8.5 -17 -18 and 8.5-
64).
Third, in the Staff Report for the Planning Commission's September 24, 2014
hearing, Subsection E established the legal parameters for the Planning Commission's
action.
F. Action.,; Allowed by the Deciding, Cigdy
Substantial reliance by a property owner on file issuance ot'a CUP creates a constitutionaliv
protected property right to conduct the permitted activity in confirrmnnce with the expre'
prop isions in the permit. Town Code Section 29.20.310 contain% it process where the
Planning C taninissicm on its own motion or by recommendation of the Planning Director
may 1101(1 It hcaring to consider modifying or revoking it Conditional Use Permit (CUP). In
addition, procedural as well as substantive protections must he tbllowed when the Town
decides whether grounds exist to revoke or modih a CLIP. This process is seldom used as
the Yown tries to work with the violator to rectify the problem as long as they respond and
work towards cumpliance at a reasonable pace.
With this hcanng. the applicant has voluntarily requested approval to modify a Conditional
Use Pennit w increase school enrollment and modify operations of an existing private
school. Bused upon rite requirements of 'Town Code Section 29.20.310 and State and
Federal law, the Planning Commission is not allowed to revoke the existing CUP or
remove permitted uses front the existing CUP at this hearing since the appropriate
notification and hearing was not set pursuant to Town Code 29.20.310. However, Planning
Commission is allowed to modify conditions to the CUP so long as findings can he made
that the conditions substantially further n legitimate public purpose that is related to the
project and its impacth.
Lastly, when queried by the Planning Commission about the legal parameters of
the proceeding, Robert Schultz, the Town Attorney, reiterated the Town's position:
ROBERT SCHULTZ: But a CUP does have some constitutional
protected rights that are vested, and in this case you have an
existing CUP, so they do have constitutionally protected
rights. There is a process that you could go through where the
Town initiates a modification or a revocation that allows you
to provide procedural notice of what you're going to change
and what you're going to do. In this case, it's the Applicant
has come forward with a modification. Certainly that opens up
anything that with the project to modify any of the conditions
that exist for that project as long as you can show there's a
substantial nexus or a —the wording is —a further legitimate
QS
purpose for that condition. Certainly when we get into those
conditions we'll have to take a look at that on what the
project is and what you're looking at to make certain that
we're not stepping on any of the constitutional protected
rights that the Applicant does have.
(Los Gatos Planning Commission transcript, 9/24/2014 Item #3, page 11)
IV. The Appeal
Notwithstanding these directives as to the legal limits of the Planning
Commission's discretion, the Planning Commission decided to impose a maximum cap
of 880 daily vehicles with penalties that could accelerate into hundreds of thousands of
dollars within months —a decision which not only treads on Hillbrook's constitutional
rights but would financially cripple the school. Hillbrook believes that the Planning
Commission unknowingly erred when making this decision. We ask the Town Council
to uphold Hillbrook's appeal and instead impose an 880 average daily count based on
the following three pillars: (A) sound Traffic Engineering Principles; (B) avoidance of
Bad Precedent; and (C) Legal Implications.
A. Traffic Enaineerina Principles
As the record reflects, Hillbrook developed an average daily traffic (ADT)
approach to respond to the neighbors' concerns about traffic outside of the AM /PM peak
periods. Hillbrook proposed an ADT count of an average of 960 vehicles per day (or
480 vehicles each way), which was derived in collaboration with the Town's Engineering
Department, who blended rates for private K -8 and K -12 schools, which are based on
averages.
Hillbrook proposed and Town staff supported this averaging methodology
because the number of average daily vehicle trips is the standard industry
measurement used in the Town, the County of Santa Clara, the entire Bay Area, the
State of California, and nationally. Specifically, with respect to Hillbrook, this averaging
methodology forms the basis for every traffic metric used to analyze the Project in the
DER and FEIR:
• The DEIR's traffic baseline of 880 is an average.
• The Institute of Traffic Engineering's (ITE) Trip Generation Handbook uses
averages for every land use analyzed in its data set to establish trip
generation rates.
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• The Traffic Intrusion on Residential Environments (TIRE) index relies on
averages to determine qualitative impacts to residential streets.
Importantly, the Town of Los Gatos utilizes the ITE rates for all of its traffic impact
analysis and, therefore, every land use decision in Town is based on an averaging
methodology by virtue of the Town's reliance on the ITE Trip Generation Handbook.
With respect to Hillbrook, this methodology is fair because the averaging evens out
unusual fluctuations and margins of error in order to accurately capture representative
trips for a typical school day. Consequently, the Planning Commission fundamentally
erred in its deviation from this widely accepted engineering principle.
In this same vein, the Planning Commission erred in its interpretation /application
of the TIRE index to support the imposition of a 880 maximum daily cap. The DEIR
included the TIRE analysis for informational purposes to assess the Project's qualitative
traffic impacts to nearby residential streets. The DEIR concluded and the FEIR
confirmed that the implementation of the Final TDM Plan would be sufficient to reduce
Project- related traffic increases to below the TIRE index's noticeability threshold levels,
which would be triggered at an ADT of 1,114 trips (557 each way).
Nevertheless, this finding was misunderstood by the Planning Commission in
favor of a distorted data point advanced by a few select neighbors —that 890 daily
vehicles would "severely impact the neighborhood." This is fundamentally wrong. The
TIRE index was manipulated by the Project's opponents to overstate impacts and the
Planning Commission mistakenly relied on this misrepresentation to support the
concept of the 880 maximum daily cap. There is absolutely no evidence in the record to
support the Planning Commission's reliance on this data point as a rational basis for the
decision, nor is the TIRE index a legitimate tool used by the Town to determine any
project's impact significance. Regrettably, the Planning Commission was misled as to
the applicability of this "890" number and, as a consequence, made a quantitative error
in judgment that resulted in an unfair and potentially devastating result for Hillbrook.
Hillbrook asks the Council to correct this error and find in favor of the averaging
approach.
As explained before, Hillbrook's proposal for an ADT fell well below the
applicable industry standard metrics and relevant equivalents, which means that
Hillbrook's traffic is not excessive for the neighborhood. The opponents' hyperbole
does not disprove this fact. In every land use circumstance, the Town relies on
objective tools and standards to make determinations about any project's actual traffic
impacts. These metrics ensure that the Town's decision- makers have objective,
reasonable means by which to assess impacts. The fact that Hillbrook causes no
significant impacts nor the need for any mitigation shows that the Planning
10
Commission overstepped its bounds by imposing an arbitrary maximum cap with an
extremely punitive penalty system.
B. Bad Precedent
Hillbrook is asking the Council to intervene in this situation and consider the
implications of the Planning Commission's decision as an important policy matter. As
previously described, the Town's traffic engineers necessarily rely on averages to
understand traffic impacts because averages provide a realistic, typical picture of traffic
patterns by evening out fluctuations that occur. Averaging is the industry-wide standard,
which is why the Town universally relies on the averaging approach to assess traffic
impacts, thus making the imposition of a maximum cap on Hillbrook a radical departure
from Town policy.
This departure from the norm not only is unsupported by evidence in the record,
but it would set a bad precedent from both a fairness and an enforcement standpoint. A
maximum trip cap is not at all in line with previous Council decisions regarding traffic
enforcement. Furthermore, this metric could open the door for excessive scrutiny —and,
by extension, excessive enforcement —of every use permit application in Town. Such a
result would fall well outside the bounds of the nationwide body of work that informs the
Town's standard traffic analysis protocols.
As such, Hillbrook asks the Town Council, as a matter of good public policy, to
overturn the Planning Commission's imposition of an 880 maximum cap in favor of an
average daily cap of 880 vehicles. This approach aligns with the EIR's baseline (a hard
cap does not), the approach is supported by staff because it is common industry
practice, and it is consistent with long- standing Town precedent.
Significantly, an 880 average provides the same protections to the neighbors that
were intended by the Planning Commission. By holding to the 880 baseline as an
average, Hillbrook would add 99 students with no additional trips. Moreover, the Town
Council can apply a maximum cap on top of the 880 average in order to give the
neighbors the predictability they seek. It also gives the Council the assurance that the
Town's best interests are protected because the system is set up to succeed, not
overburden the Town's fragile resources, and not disproportionately penalize the
applicant.
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C. LeaalImplications
For the reasons discussed briefly below, Hillbrook believes that the Planning
Commission overstepped its legal bounds. Hillbrook also believes, however, that the
conversion to an 880 average overcomes these legal infirmities and protects the Town
from unnecessary risk.
1. Vested Right
Hillbrook has a vested right to 315 students. The "opening up"
of the CUP does not diminish this right. However, the imposition of the 880 hard cap by
the Planning Commission in effect could diminish Hilibrook's vested right because the
Town would be subjecting Hillbrook to possible penalties for trips generated under the
school's existing, vested right of 315 students. This would be unlawful because the
Town does not have the authority to penalize the school for the total number of
students —only the net, new students above 315.
2. Nexus
The imposition of escalated and now accelerated penalties demonstrates a lack
of nexus between the maximum cap and impacts resulting from the Project.' When
considering the totality of the Project's circumstances, there is a complete absence of
proportionality between the "impact" and the "penalty." Since this Project has no
impacts in the eyes of the law, the penalty system, as modified by the Planning
Commission, is excessive, punitive, and threatens the fundamental viability of the
school. Put simply, the punishment does not fit the crime here, and the penalty system
devised by the Planning Commission violates the constitutional principles that require
conditions to bear a "rough proportionality" to a project's adverse impacts. (See e.g.
Nollan v. California Coastal Comn (1987) 482 U.S. 825; Dolan v. City of Tigard (1994)
512 U.S. 374; Ehrlich v. City of Culver City (1996) 12 Cal.4'" 854.
'Attached as Exhibit B is an example of how the 880 maximum cap and penalty system would apply to
Hillbrook's 2014 Spring semester. The example is based on Hillbrook's real trip data with 315 students
enrolled and corresponds to information that was submitted to the Planning Commission on September
30, 2014. This hypothetical applies 5 of the 10 annual exceptions approved by the Planning Commission
and omits minor overages (seen in italics) based on the assumption that Hillbrook would ensure these
trips were reduced. With these assumptions, the hypothetical shows how quickly the penalties escalate
over the course of the 2014 Spring semester. For illustrative purposes, the hypothetical also includes a
penalty scenario that assumes noncompliance in April, which then would trigger the $10,000 /trip penalty.
As shown, even with a handful of overages in only two consecutive months, the penalties accelerate to
over $1 million. These penalties are so excessive they would have the practical effect of shutting down
the school —an outcome that runs afoul of the "rough proportionality" rule.
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V. Clean -Ups
In addition to converting the 880 maximum cap to an average, Hillbrook requests
that the Town Council address the following "clean ups" to the conditions of approval
adopted by the Planning Commission:
Condition #3:
Grounds and facilities maintenance: Modify hours to 8:00 a.m. to 9:00
p.m. to allow for janitorial services to occur in classrooms after students
have left the campus.
Hillbrook Faculty /Administrator Weekday Work: Modify hours to 6:30 a.m.
to 9:00 p.m. so that faculty and staff can arrive on campus before students
arrive and deliveries occur.
• Condition #22:
• A provision should be added to the penalties section that re- establishes the reset
to $1,000 per trip after Hillbrook's return to compliance.
• A provision also should be added that expressly acknowledges the grace period
for the applicability of penalties prior to Hillbrook's addition of any additional
students in the Fall of 2015/2016.
VI. Conclusion
Based on the foregoing, Hillbrook requests that the Town Council uphold
Hillbrook's appeal, overturn the Planning Commission decision, and convert the 880
vehicle maximum cap to an 880 average daily count. This approach is, above all else,
fair. it also is supported by sound traffic engineering principles, represents good public
policy, and cures serious legal deficiencies.
As you consider this appeal, recall that Hillbrook has been a part of the Los
Gatos community for 79 years and has contributed to the wonderful, small town culture
that makes the Town such a special place. Hillbrook has listened and responded to
neighborhood concerns. And the record shows that the Project has no significant
impacts on the environment, nor does it cause unsafe traffic conditions on neighboring
streets. The Planning Commissioners clearly expressed their desire to see Hillbrook
thrive. Let Hillbrook thrive.
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Hillbrook looks to this Council for its leadership, independence, thoughtfulness,
and sense of fairness. It is time for closure so that the parties can move forward and
heal.
Thank you for your consideration.
Sincerely,
Mark Silver, Ph.D.
Head of School
Attachments
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Chuck Hammers
Chair of the Board of Trustees
EXHIBIT A
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SCH 0 0 L
September 17, 2014
Margaret Smith, Chair
Members of the Planning Commission
Town of Los Gatos
110 E. Main Street
Los Gatos, CA 95030
RE: Hillbrook School Letter of Justification
Dear Chair Smith and Members of the Planning Commission:
We are writing on behalf of the Hillbrook School (Hillbrook) with respect to our
request for a modification to our Conditional Use Permit ( "CUP ") that the Planning
Commission will be considering at its hearing on September 24, 2014 ( "Project ").
Executive Summary
In direct response to our neighbors' concerns about Project impacts on the local
streets, we have refined our proposal. The following provides an overview of its key
elements:
• Enrollment: Increase from 315 students to 414 students.
• Average Daily Count (ADT); 960 average daily vehicles (480 each way)
entering and exiting the campus.
• AMIPM Peak Periods: Reduction in our AM /PM peak period maximum of
outgoing vehicles from 165 to an average of 150 vehicles during drop- off/pick-
up periods.
• Summer: 480 average daily vehicles (240 each way), half of the regular
school year average and no summer evening events.
• TDM Program: Implement mandatory TDM program with a bi- annual
reporting requirement to the Town.
• Enforcement: The Town will engage a third party, independent consultant to
determine compliance with the trip cap averages based on the driveway
sensor data.
• Penalty: Escalated penalty system starting at $1,000 per trip in excess of the
daily, AM or PM average, with subsequent periods of non - compliance
increasing to $5,000 and then $10,000 per trip, with a reset to $1,000 per trip
after a return to compliance.
Background
A. Hillbrook History
Hillbrook was founded more than 75 years ago and offers an extraordinary
educational experience that prepares students for school and for life. Originally known
as The Children's Country School, the school served as a boarding school forwards of
the state throughout the 1930s and 1940s. In the early 1950s, the school evolved into
an independent day school and, in 1960, changed its name to the Hillbrook School.
Hillbrook now educates children between the ages of 4 and 14 from Junior
Kindergarten to 8" grade. Hillbrook is non - sectarian, accredited by the California
Association of Independent Schools, and a member of the National Association of
Independent Schools. Since the 1950s and 1960s, the school has evolved into one of
the leading independent schools in the Bay Area.
During the past 13 years, the school campus has been rebuilt and modernized,
retaining its historical look and feel while bringing the school facilities up to date. The
campus itself is 14 -acres and bisected by a creek that divides the lower and middle
school sides of campus. (See Exhibit 1.) The school's program also has evolved and
expanded, balancing rigorous academics with a focus on social emotional learning and
service to the community. The school is a vital part of the Los Gatos community, not
only providing an education to many families who live in Los Gatos and surrounding
communities, but also through the service efforts of our students and families.
B. CUP History
Hillbrook's original CUP was approved in the late 1980s when the school sought
to build Founder's Hall, the school's gymnasium. To address neighborhood concerns
that the Hall might be used for weddings and similar social activities, Hillbrook agreed to
limit Founder's Hail usage to school activities and to build a new access road and gate
off of Ann Arbor to provide emergency vehicle and limited construction equipment
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access to the middle school side of campus. This gate remains locked at all times and
has never been used for student ingress or egress to the campus. The school also
agreed to limit enrollment to 315 students.
In 2001, the Town approved the Hillbrook School Master Plan and Architecture
and Site Approval application (PRJ -99 -063) for the rebuilding of certain campus facilities
that had become dilapidated and were not earthquake safe. As part of this approval,
new CUP conditions were added to address neighborhood concerns about traffic
backing up along Marchmont Drive. The school agreed to adopt a voluntary carpool
program and to limit car counts to 165 outbound vehicles during the AM /PM peak
periods (7:30 -8:30 am and 2:30 -3:45, respectively). Since these conditions were
adopted, the Town has undertaken bi- annual traffic counts and Hillbrook has been in
complete compliance with the 165 outbound limit.
The Hillbrook School Master Plan allowed for a total of 55,715 square feet of
buildings. Since obtaining that approval, Hillbrook has renovated, rebuilt or replaced
most of the buildings on site, for a total of 52,683 square feet (with 5.4% of allowable
square feet remaining). Hillbrook, therefore, has ample capacity on its 14 -acre campus
to accommodate the additional students.
III. Why Increase Enrollment?
As noted above, since 1987, our enrollment has been capped at 315 students.
However, philosophies as to how best to educate elementary and middle school
students have changed dramatically in the past 27 years. As a result, Hillbrook cannot
meet the demands of a 21St century, nationally recognized, independent school if it is
not permitted to grow and thrive. Specifically, the current 315 student cap does not
allow Hillbrook to: 1) enroll enough children to have uniform classes of 18 -20 students
across all grades, which is optimal; 2) enroll enough children to meet the current
demands of academic differentiation and to optimize sociallemotional development; and
3) have the financial flexibility to continue to expand and grow its curricular offerings
and tuition assistance program. We merely are seeking the flexibility and agility in our
enrollment process that is critical to address our students' educational needs. At
present, Hillbrook turns away applicants, many from Los Gatos, every year. Los Gatos
public schools currently are bursting at the seams and will be even worse with the
anticipated growth in Town over the next few years. Consequently, leaving empty seats
in a local school with space to fill does not make sense given the Town's current
circumstances.
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A. Uniform Class Sizes of 18 -20 Students
We believe, as do many other independent schools and the State of California,
that the ideal size for our classes is 18 -20 students. This size has been found to be
small enough to ensure that students receive individual attention, while still allowing for
collaboration, teaming, and the stimulation that is critical to young children's emotional
and intellectual development. Currently, with two sections per grade, Hillbrook finds
itself with many classes that are too small. The problem is that the current enrollment
cap does not correspond to a logical enrollment model, resulting in grade levels that
wildly fluctuate in size. Last year, for example, because of the enrollment cap and a
lack of attrition in other grades, we ended up with only 23 students in Kindergarten.
While other schools in our area are over - crowded, we ended up with an empty
classroom for the entire year. This year, that Kindergarten class will be two sections of
1 st grade at 11 and 12 students each, which is not a desirable class size for students to
have adequate academic and social peers. And, due to the current enrollment cap, this
class will be confined to this size all the way through 8'" grade. The result is that
teachers and classroom space are underutilized, and parents are concerned that their
children will not have a sufficiently active and challenging environment for 1st grade and
beyond. This enrollment constraint does not benefit the school, the children, or the
Town of Los Gatos. (See Exhibit 2.)
B. Programmatic Differentiation and Social /Emotional Development
First, an increase in students will allow for Hillbrook to diversify its programmatic
options. A significant change we have seen in education over the past quarter century is
the ability to provide curricular innovations that achieve a more effective and desirable
program for middle school students. Today, public, private and parochial schools across
the country offer far greater course selection than has ever been seen before. Hillbrook,
with its current constraints, struggles to effectively provide this curricular variety to
students. In the past, Hillbrook offered one or (at most) two levels of math in the middle
school, allowing the class to split into two sections. For example, a 7t" grade with 36
students would be divided into two sections of 18 students for math classes. Now, to
better meet the evolving educational needs of students and the increasing expectations
of families, Hillbrook offers at least three levels of math, ending with pre - algebra,
algebra and geometry in 8u' grade. With only 36 students in the grade, this can lead to a
math section with only 6 or 7 students. By way of another example, foreign language is
even more challenging. Like other leading independent schools, Hillbrook currently
offers the option of Mandarin and Spanish in middle school. Increasingly, we are seeing
a need to create advanced sections in both languages yet, given our overall enrollment,
we may have only 3 or 4 students who are prepared for the advanced courses.
me
Regrettably, it is both economically and academically infeasible to offer an advanced
course, whether math or language, to only a handful of students.
Second, it is well- recognized that middle school students need a rich and varied
social environment in order to thrive. Therefore, the tiny classes noted above do not
provide the opportunities for the adequate collaboration or sufficient peer interaction that
is necessary for students to reach their full developmental potential. Other leading
independent schools in the Bay Area, including St. Andrews School and the Harker
School in San Jose, have recognized the need for a larger critical mass of middle
school students and have grown to better meet the needs of their students.
These are just two examples of the struggles we face resulting from the 315
student enrollment cap, with many other examples in the core curriculum, arts, athletics,
and electives. With an additional section of middle school students, Hillbrook can better
meet the evolving academic needs of students by providing more robust and effective
course offerings, while providing the necessary critical mass of peers to enrich students'
social experiences, as well.
C. Financial Health and Diversity
An increase in students will ensure our program remains affordable, accessible
and inclusive to a socioeconomically diverse community. Since 1935, Hillbrook School
has served students from all different socioeconomic backgrounds. The school deeply
values being accessible to families with diverse economic circumstances and does
everything in its power to remain affordable to these families for whom tuition is a
stretch. For example, about twenty percent of Hillbrook families receive tuition
assistance, with some families receiving up to 90% of the overall cost. In total, Hillbrook
is providing nearly $1 million in financial assistance to families this academic year. Yet,
the current enrollment cap, coupled with the evolving demands required to provide an
extraordinary educational program, is driving Hillbrook's tuition higher and higher. We
strive to attract top teaching and administrative talent to further our educational mission.
This requires being competitive in the marketplace. Consequently, an increase in
enrollment for the school would allow Hillbrook to keep tuition manageable, stay
accessible, and offer a robust program that meets the current demands of families and
students.
Two important facets of our request must be emphasized. First, the additional
students can be accommodated in existing classrooms and buildings on campus. We
will continue to be good stewards of our 14 -acre campus and protect the resources we
enjoy; therefore, we are not seeking any additional building square footage to
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accommodate this enrollment increase. Our campus has the capacity to educate
many more students than our enrollment cap allows. We have a plan in place to utilize
the existing square footage to accommodate the entirety of a 414 student population. By
way of illustration, Exhibit 3 shows the excess classroom capacity for grades 5 -8.
Second, our request does not mean that we would immediately add 99 students
in the next school year. We will spend 3 to 5 years carefully adding students so that our
school can continue to provide the community aspect that has always been a cultural
hallmark at Hilibrook.
Put simply, we are seeking the flexibility and agility in our enrollment process that
is critical to address our students' educational needs. Allowing Hilibrook to add an
additional section of students in grades 61" through 81" means that, for the first time,
local families would enjoy the option of enrolling in Hillbrook for just the middle school
years, instead of starting at Junior Kindergarten. This flexibility will provide a better
learning environment for our current students by allowing for more robust academic
choices, more co- curricular activities, and better social interactions between students. It
also will provide another excellent option for middle school students in the Town. Our
proposed enrollment cap of 414 makes sense educationally and
programmatically, and it will allow our nonprofit institution to be sustainable over
the long term.
IV. Our Project
A. CUP Amendment
As discussed above, Hilibrook seeks a very specific modification to its existing
CUP to increase enrollment from 315 to 414 students, with proposed conditions of
approval to address neighborhood concerns. Section 29.20.305 of the Town's Code
provides that these CUP modifications are "heard anew and the deciding body may
impose new conditions or modify previous conditions." However, as noted in the Final
Environmental Impact Report ( "FEIR ") for the Project, the Town's discretion is limited by
constitutional principles requiring that there be a nexus between the impacts of the
Project and its conditions of approval, such that any conditions imposed must
ameliorate the actual amount of harm that would result from the Project. As stated in
the FEIR, "[a]tthough the Town may impose new conditions pursuant to Section
29.20.305, such an action does not permit the Town to revisit the wisdom of prior
decisions to grant the existing [CUP] in the first place. Town staff Is unaware of any
potential harm that the proposed [CUP] amendment would cause that would support
many of the [neighbors'] proposed conditions." (FEIR, page 8.5 -18.) Consequently, it is
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important that the Planning Commission recognize these important legal principles
during its deliberations.
B. Prolect Consistency
Zoning
Hillbrook is located on a 14 -acre parcel in a Hillside Residential (HR -1) zone. HR
zones allow for a number of permitted uses, as well as some conditional uses. Hilibrook
operates as a conditional use under the HR zoning and, as such, is an appropriate use
under the Town's Code pursuant to its CUP.
2. General Plan
A project is consistent with a general plan if it is compatible with the plan's
objectives, policies, general land uses, and programs and will not obstruct their
attainment. Hillbrook is located within the General Plan's Hillside Residential
designation and, as such, the school use is consistent with and allowed under this
designation. In addition, the Project is consistent with a number of key General Plan
goals and policies, including, but not limited, to:
Human Services Element
• Goal HS -4 To offer a wide range of youth programs and services within the
Town.
• Policy HS-4.2 Coordinate with public and private schools, local nonprofits,
service clubs, and other agencies to provide opportunities for youth to explore
and enjoy sports,creative and performing arts, and future career paths.
• Policy HS -7.2 Promote the Safe Routes to School program, which supports
safety improvements that encourage safe walking and bicycling to school,
• Policy HS -7.3 Coordinate with local businesses, organizations and school
districts to develop innovative programs, such as "Walking School Buses" and
"Bicycle Trains" that encourage youth to commute to and from school in
groups.
d!
Transportation Element
• TRA -1.1 Development shall not exceed transportation capacity.
• TRA -9.6 Require development proposals to include amenities that encourage
alternate forms of transportation that reduce pollution or traffic congestion as
a benefit to the community.
• TRA -9.2 Encourage bicycling and walking as energy conserving, non-
polluting alternatives to automobile travel.
• TRA -5 School Pool Program. Implement a School Pool Program that helps
match parents to carpool students to school.
Open Space, Parks, and Recreation Element
• Goal OSP -2 To preserve open space in hillside areas as natural open space.
• OSP -2.1 Preserve the natural open space character of hillside lands,
including natural topography, natural vegetation, wildlife habitats and
migration corridors, and viewsheds.
• Goal OSP -5 To create and maintain open space areas and parks that
enhance and blend into existing natural habitats, residential neighborhoods,
and other Town features.
V. Our Refinements
A. Overview
Buoyed by the DEIR's findings of our Project's less than significant impacts, we
worked with our neighbors, traffic engineers, and the Town to refine a set of conditions
that allows the school to increase its enrollment while ensuring that we control our traffic
on neighboring streets. We have developed a system based on three equally important
prongs that function together to guarantee our compliance with an amended CUP —
monitoring, TOM, and penalties. We call it the "three- legged stool." The first leg is
comprised of the proposed trip caps for the AM /PM peak periods and daily trips, which
the Town will monitor through an independent, third party vendor. The second leg is
comprised of the mandatory TDM program, which will require parental commitment in
the form of carpooling, shuttling, walking or biking. Lastly, the third leg provides the
"teeth" in the way of penalty protocols for non - compliance. Attached as Exhibit 4 is a
memorandum from Nelson \Nygaard that further discusses the mechanics of our
proposal, as well as other traffic-related issues.
IN
B. Average Daily Traffic (ADT) Count
The most important new element of our CUP proposal is the addition of an ADT
count. Certain neighbors have expressed concern about solely relying on AM /PM peak
period controls because of the traffic that can occur throughout the whole of the day. In
direct response to this concern, we developed an ADT count of an average of 960
vehicles per day (or 480 vehicles each way). This ADT count was derived in
collaboration with the Town's Engineering Department, who blended the ITE rates for
private K-8 and K -12 schools. When this blended rate is multiplied by 414 students
(2.68 x 414), the result is an ADT of 1,108 trips, making Hillbrook's proposed ADT count
of 960 vehicles a 13% decrease from the blended ITE number calculated by the Town.
As one can see, our 960 ADT count falls below numerous metrics relied upon or
discussed for informational purposes in the DEIR. First, the DEIR includes analysis for
informational purposes that relies on the Traffic Intrusion on Residential Environments
index (TIRE ) to measure the Project's qualitative traffic impacts to nearby residential
streets. Based on the analysis done by the Town's traffic consultants, the DEIR
concludes that, and the FEIR confirms, the implementation of the Final TDM Plan would
be sufficient to reduce Project - related traffic increases to below the TIRE index's
noticeability threshold levels. The noticeability threshold is triggered at an ADT of 1,114
trips (557 each way); thus, Hillbrook's proposed ADT count of 960 is significantly lower.
Second, Table 4.3 -11 in the DEIR indicates that the Project would generate 276
daily trips, which is equivalent to a trip generation rate of 2.79 trips per student. The
application of this rate to the proposed 99 student increase would result in 1,155 daily
trips, almost 200 more trips than the proposed 960 ADT count or a 17% difference.
Third, pursuant to the Town's Traffic Calming Policy, total traffic volumes on a
local residential street would have to exceed the established daily traffic volume
threshold of 1,500 trips to justify the Town's consideration of traffic calming measures.
This 1,500 daily trip threshold is 540 trips or 56% higher than our proposed 960 ADT
count.
In sum, Hillbrook's proposal of a 960 ADT falls well below the applicable industry
standard metrics and relevant equivalents, which means that Hillbrook's traffic is not
excessive for the neighborhood. We do not trigger anything close to a significant
traffic impact based on the Town's LOS standards. We fall well below the Town's
calculation for a blended ITE rate, below the TIRE index threshold for noticeability on a
residential street, and far below the Town's Traffic Calming threshold for local
residential streets. These are the objective tools that the Planning Commission and
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Town Council must rely on to make determinations about any project's actual traffic
impacts. These tools do not change because a street is a "dead end" or if a school is a
conditional use. These metrics ensure that the Town's decision - makers have objective,
reasonable means by which to assess impacts. The fact that Hillbrook causes no
significant impacts and the 960 ADT count is well -below industry standards
should serve as compelling justification that our proposal is rational and
achievable, especially when considering the ongoing success of our trip reduction
strategies.
C. Transportation Demand Management (TDM)
The next critical component of our proposal is the implementation of a mandatory
TOM program that will allow Hillbrook to manage its traffic impacts by requiring parents
to commit to trip reduction in a number of different ways. (See Exhibit 5.) This Final
TOM Plan prepared by NelsonlNygaard recommends a menu of strategies that will
reduce peak hour vehicle trips and daily trips in accordance with our proposed trip caps.
TOM strategies work as a package, with options and incentives working together to
control behavior. For the past couple of years, we have piloted shuttles, which include
kiss & ride stops, created a transportation coordinator role, placed a transportation
person in the streets each morning to ensure bikers and walkers arrive safely to school,
and partnered with Safe Routes to Schools to continually seek new ways to encourage
people to bike, walk, shuttle, and carpool to school. We continue to refine our system to
make it more effective and efficient. As described by Nelson \Nygaard, the largest
contributors to trip reduction are the shuttle system and the expanded carpooling
program. Our commitment to a successful TOM program is evidenced by our proposed
penalty protocols, which subject the institution to significant financial consequences if
we fall short of our trip reduction goals. We are confident that, as is NelsonlNygaard
and the Town as stated in the FEIR, we will be able to satisfy this commitment and
increase enrollment with a corresponding decrease in neighborhood trips.
D. Penalties
As noted above, the final prong of our proposed compliance system is the
penalty protocols. We have proposed three monitoring periods for which Hillbrook's
trips would be analyzed for compliance —First Term, Second Term, and Summer Term.
For example, if the Town's independent, third party vendor analyzes the Sensys
driveway data and determines that, after taking into account typical school days',
' Pursuant to widely accepted traffic engineering standards, the averaging of typical school days would
exclude all days that are less representative of typical school conditions, such as weekends, holidays,
special nighttime events. and minimum days.
Hillbrook has exceeded the ADT on a given day during the First Term of an academic
year, the Town can assess a $1,000 per trip penalty for those trips over the average
960 ADT, if Hillbrook fails to make the necessary adjustments and exceeds a trip cap
again in the Second Term (AM, PM or ADT), then the penalty escalates to $5,000 per
trip over the average. The penalty could go as high as $10,000 per trip if Hillbrook is
out of compliance for three consecutive monitoring periods. Once Hillbrook comes back
into compliance in a subsequent monitoring period, the penalty resets to the $1,000 per
trip amount, which is standard with respect to these kinds of penalty protocols.
VI. Our Impacts
A. Draft Environmental Impact Report
We have long recognized that our desire to increase enrollment needs to be
done sensitively with respect to increased traffic in our neighborhood. We were very
pleased that the Draft Environmental impact Report ( "DEIR ") concluded that our
increased enrollment would cause no significant impacts to the neighborhood. This
conclusion is important because the California Environmental Quality Act (CEQA)
provides the Town with the widely accepted framework for analyzing a project's physical
effect on the environment. The DEIR found that our project triggers either no impacts
or impacts that are less than significant under CEQA.,
B. Final Environmental Impact Report
The FEIR, which was released on August 29, 2014, responds to all of the
comments submitted on the DEIR and analyzes the refinements to our Project proposal.
The FEIR confirms that the changes we have proposed to the Project would reduce the
Project's impacts identified in the DEIR, which already are less than significant under
the Town's CEQA significance thresholds.
The FEIR contains a number of "Master Responses" that were compiled in
response to numerous, similar comments on the DEIR, which we briefly summarize
here:
TDM Effectiveness — Because Hillbrook now proposes a condition of approval
that requires implementation of the Final TDM Plan, as well as proposed daily
limits, reduced peak period limits, third -party compliance determination and
penalties for exceedances, the Project is expected to achieve further trip
reduction, as the school has successfully done in the past.
• Ann Arbor Access Alternative— Because the Project's traffic - related impacts
were determined to be less than significant and Section 15126.6(c) of the
CEQA Guidelines states that alternatives should be able to "avoid or
substantially lessen one or more of the significant effects," the Town
exercised its discretion and determined that there is no justification for a
CEQA evaluation of the Ann Arbor Drive Alternative, especially when
considering that the Town identified two other alternatives that satisfy CEQA's
"rule of reason" with respect to a Lead Agency's choice of alternatives.
• Traffic Safety— Traffic safety was evaluated for the Project by the Town's
traffic engineering consultant. Consistent with the Town's and standard
industry practice, TJKM collected traffic data, reviewed traffic volumes and
pedestrian /bicycle counts, reviewed traffic conditions, observed roadway
conditions and site line visibility along routes to the school, observed
pedestrian /bicycle traffic, and reviewed accident reports. After this exhaustive
analysis, TJKM determined there are no unsafe conditions and the
existing roadways are performing in a satisfactory manner, which led to
the conclusion that the Project would not cause an increase in traffic that
would result in any significant traffic safety impacts.
We draw your attention to a number of other important conclusions in the FEIR.
First, the FOR concludes that nothing in CEQA supports the imposition of the more
stringent conditions of approval proposed by a small faction of neighbors, and the Town
only has the authority or "police power" to impose conditions that address the actual
effects of the Project —they cannot be excessive (FEIR, 8.5 -17 -18 and 8.5 -64). Second,
Town staff has determined that Hilibrook currently operates within its CUP
conditions /limits and, therefore, is not in violation of its CUP as some neighbors keep
suggesting (FEIR, 8.5 -45). Third, the Town stands by the traffic analysis and believes it
to be legally adequate under CEQA, as the data used for the traffic analysis constitutes
substantial evidence sufficient to support the DEIR's conclusions (FEIR, 8.5 -20 and 8.5-
107).
In sum, the DER concludes and the FEIR confirms that the Project will not
exceed any CEQA thresholds, resulting in no impacts or less than significant
impacts across all Appendix G topics. Importantly, the DER and the Traffic Impact
Analysis evaluated the Project's traffic impacts in accordance with the Town's Traffic
Impact Policy, VTA Transportation Impact Analysis Guidelines, and standard traffic
engineering professional practice and both determined that the Project will not exceed
the CEQA significance criteria resulting in the Project's less than significant traffic
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impacts. These documents reflect the Town's independent judgment and
thorough analysis and deserve certification under CEQA.
VII. Conditions of Approval
In September 2012, Hillbrook submitted a Letter of Justification that explained
the original rationale for the school's proposed CUP modifications (See Exhibit 6).
Since then, Hillbrook has clarified the conditions of approval to reflect the refinements
discussed above. For ease of reference, attached as Exhibit 7 is a matrix that
compares Hillbrook's proposed conditions to the conditions in the existing CUP. Some
of this clarifying language is highlighted below.
• Condition #4— Carpooling: This condition is replaced with a parking
restriction for neighboring streets, and carpooling is discussed in Condition
#14.
• Condition #5— Enrollment: Hillbrook shall submit the student enrollment
roster annually to the Town's Planning division for verification two months
from the first day of the school year,
• Condition #7(B) -- Nighttime Hours: No nighttime activities shall be allowed
during the Summer.
• Condition #7(C)— Weekend Activities: Weekend use shall be limited to an
Open House event in October and volleyball and basketball toumaments
between Hillbrook and other schools only.
• Condition #8— Neighborhood Coordination: This is a new condition that
establishes regular neighborhood outreach protocols.
• Condition #9— Neighborhood Committee: This also is a new condition that
establishes a Neighborhood Committee comprised of Hillbrook Trustees, the
Head of School, the Traffic Coordinator, and representatives from the
neighborhood.
• Condition #12— Lease /Rentals: No lease or rental of the campus facilities
shall be permitted to third parties, except for those providers of educational
programs, which shall be executed in strict accordance with Condition #14,
Traffic Conditions.
• Condition #14— Traffic Conditions: The majority of these conditions are
discussed above in Section V. Condition #14(G) establishes a Traffic
Coordinator to oversee the TDM program and facilitate outreach and
Condition #14(I) establishes exclusions for Hilibrook's ten (10) special
nighttime events, which allows for exceedances of the ADT trip limitation
without violation.
• Condition #15— Commercial Traffic: No commercial traffic shall be permitted
before 7:00 AM on weekdays.
Vlll. Community Engagement and Benefits
A. Enoagement
Hillbrook applied back in 2012 for a modification to our CUP to allow for a student
enrollment increase from 315 to 414 students. Since that time, we proactively engaged
our neighbors by holding dozens of meetings —large and small —in an effort to
understand their concerns so that we may be responsive to them. Last Fall, we set out
on an ambitious outreach program with the goal of reaching out to as many neighbors
as possible to hear their concerns and emphasize our commitment to being a good
neighbor. These 2013 meetings included:
• October 28:
• November 6:
• November 14:
• November 17:
• November 21:
• December 2:
• December 4:
• December 9:
Longmeadow Neighbors
Topping Neighbors
Englewood Neighbors
Ann Arbor Neighbors
Hilow Neighbors
Lower Marchmont Neighbors
Cardinal Lane Neighbors
Upper Marchmont Neighbors
We also held a neighborhood -wide meeting on May 27, 2014 to re- engage with
the community before the summer so we could present the refinements to our proposal
that we submitted to the Town. We have made sincere, meaningful efforts to address
the neighbors' concerns, and we are committed to remaining fully engaged with our
neighbors going forward.
B. Benefits
Hillbrook has provided immeasurable benefits to the Los Gatos community for
over 75 years by providing an exceptional educational option for Los Gatos families
and beyond. Prior to August 2014, the Town's Traffic Impact Policy required that any
project generating five or more new trips provide a "community benefit" offering.
Because the Town's Traffic Impact Mitigation Fee now charges at full cost recovery, the
community benefit requirement was eliminated. Consequently, Hillbrook is no longer
required to provide a "community benefit" pursuant to the Traffic Impact Policy and,
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instead, the school will be charged $854 for each net, new trip, which will translate to
approximately $68,000 in traffic impact fees.
We emphasize here that the Project and its recent refinements offer a community
benefit by providing access for more Los Gatos students (current Los Gatos enrollment
is roughly 50 %) to educational alternatives, while easing some of the pressure on the
local schools and minimizing traffic impacts.
IX. Conclusion
Hilibrook has been a part of the Los Gatos community for 79 years and has
contributed to the wonderful, small town culture that makes the Town such a special
place. Hilibrook seeks a modest increase in student enrollment so that we can be a
better school for our families and more sustainable as a non -profit institution over the
long term. We have listened to the neighborhood concerns and we have adjusted our
proposal in response with an all -day traffic count, mandatory TDM, and penalties. The
DER and the FOR confirm that our Project has no significant Impacts on the
environment and does not cause unsafe traffic conditions on neighboring streets.
We request, therefore, that the Planning Commission certify the DER and FEIR
pursuant to CEQA and approve our Project as proposed. Thank you for your
consideration.
Sincerely,
Mark Silver, Ph.D. Chuck Hammers
Head of School Chair of the Board of Trustees
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