Item 3 - Addendum and Attachment
PREPARED BY: JENNIFER ARMER, AICP
Senior Planner
110 E. Main Street Los Gatos, CA 95030 ● 408-354-6832
www.losgatosca.gov
MEETING DATE: 08/06/2020
ITEM: 3
ADDENDUM
TOWN OF LOS GATOS
GENERAL PLAN UPDATE ADVISORY COMMITTEE
REPORT
REPORT
DATE: August 5, 2020
TO: General Plan Update Advisory Committee
FROM: Joel Paulson, Community Development Director
SUBJECT: Review and Discussion of the Initial Draft of the Hazards and Safety Element.
BACKGROUND:
Attachment 3 contains comments from Committee Members.
ATTACHMENTS:
Attachments previously received with August 6, 2020 Staff Report:
1. Initial Draft of Hazards and Safety Element
2. Public Comment received by 11:00 a.m., Thursday, July 30, 2020
Attachment received with this Addendum Report:
3. Committee Member Comments
This Page
Intentionally
Left Blank
Kathryn Janoff comments
Hazards and Safety
After reading this element, I support the suggestion from the July 2 meeting (see
minutes, page 3 of 3, fourth bullet) to move Noise from this element and add it to
Environment and Sustainability.
General, a style comment: use a consistent format for bulleted lists. Some have end
punctuation periods, some have semi-colons. The convention (when I was editing)
typically is nothing after each, but a period after the last, UNLESS each item is a full
sentence, then use periods after each.
Page 2
Definitions:
100 yr flood: Change format of “one percent” to 1.0 percent which makes it readily
comparable to the 500 yr flood definition
Hazardous/Toxic Substances and Hazardous Waste.
Terms used should be the same: I don’t believe “chemical agent” is the same as an
“ignitable, corrosive, reactive, or toxic.” The later is more broad. Suggest using it in
place of chemical in the first def.
And be sure above two definitions are what OSHA would use.
Add definition for noise-sensitive
Add definition for WUI
Page 3
8.1 discussion, second paragraph. Does the EOP recognize hazards that might derive
from outside the Town? If so, replace “within” with “that affect” the Town.
HAZ-1.4: This element does not specifically say where, how or from whom the
community will be informed and educated. Seems to be generally missing from
implementation plans too. Is there a master communications plan?
Page 4
Last paragraph, use essential or critical but eliminate the parenthetic term
Page 8
HAZ-2.1, 2.2 and 3.2. 2.1 is seriously hard to parse as written. Use the same phrasing
for each by beginning with
“Require geotechnical reports by a qualified engineering geologist and/or geotechnical
engineer . . .” then adding the details. What is meant by “qualified?” If licensed, say
that instead.
ATTACHMENT 3
HAZ-2.5: agreement: Preserve . . . portions . . . that are . . .
HAZ-2.6: as a matter of style, do not repeat the same term: Require and required. Use
Require and needed
Page 9
HAZ-2.8 and 6.1: what is meant by “qualified?” (see comment above) use licensed?
Page 12
Haz-3.4: delete “is maintained” and perhaps add “no higher than pre-development”
Page 13:
(Semantics) “regular feature” sounds so benign . . .
This discussion could use more urgency. There should be a mention of how climate
change continues to exacerbate the fire danger. Also, perhaps, a brief discussion of
PG&E’s planned power shutoff.
Page 14
The map does not delineate the QUI boundary (or region), but references to WUI areas
are in the goals and policies (e.g., HAZ-5.2 and 5.5). If all areas are WUI, then state
that clearly on Figure 8-5.
Page 15:
HAZ-5.3: What is “adequate water supply”
Page 16:
How current are the numbers in the table? (I couldn’t get a reading, let alone an
average, within the normally acceptable where I live, even without traffic . . .)
NOISE (reiterating note at top of comments: Move Noise Element to Environment and
Sustainability Element)
Page 17
Future noise note: fix agreement: “These statements . . . require . . .”
Page 19
HAZ-6.2: convoluted. Try “The Ldn scale shall be used to evaluate outdoor noise . . .”
and delete all that follows after “long range aspirations.”
HAZ-6.3: what are these noise levels? Same as in Table 8 -1? If so, say so, if not,
specify.
HAZ-7: This seems to be written backward, or at least makes one stop to think about
that you are actually addressing. Say instead: “Ensure proposed new development is
not located in areas with existing higher-than-acceptable noise levels.” (this is a
component of environmental justice which should be noted)
HAZ-7.1: introduces an undefined term: “Noise-sensitive.” Please define using (and
then deleting) the phrase in this policy “when proposed . . .standards.”
HAZ-7.2: replace “Consider” with “Use”
In several places: noise level (e.g., 6.1) or noise levels (e.g., 6.3)
Page 20:
HAZ-8.2: What are roadway facilities?
Haz-8.3: Does LG have this authority?
HAZ-9.1: Better worded in original form, revert to original and insert “construction and
maintenance” and “state-of-the-art”
HAZ-9.2: Delete “that encourages or requires”
Page 21
HAX-10: insert “noise-” in front of sensitive, and be sure to hyphenate this term in all
instances
Page 22
Delete the sentence (at end of discussion) “This section provides . . .”
Implementation programs:
G: confusing as worded. How do continuously (online? Say so) and conveniently
(same) happen?
M: run-on. Try:
Work with building owners that house essential functions and uses to ensure structures
are earthquake safe.
O: has this actually NOT been created? If it hasn’t, don’t create it but use acceptable
regional or state standards.
Q: same comment. This is a ten-yr old plan. Has this not happened yet>
V: Move to other IPs related to Fire (P. 24-25). And due to the high level of interest and
urgency, the dates should happen sooner
CC: Define NOT in the IP, but for this element. Then delete sentence with “Examples”
EE: The program is not measurable, but the noise levels are. Try: The Town shall
establish a program to measure noise reduction, . . .”
HH: In addition to what the City of SJ or the county already provides at regio nal drop-off
sites?? This reads very broad and expensive.
From Committee Member Lee Quintana Page 1 of 5
To the General Plan Advisory Committee
August 4, 2020
COMMENTS ON THE HEALTH AND SAFETY ELEMENT
Page 8-2 Key Terms
Modification of terms:
Day/Night Average Sound Level (Ldn). The average A-weighted noise level ……
Essential Facilities. Delete the first sentence. Replace with: Structures, and buildings
housing services and equipment that are essential to a emergency response following a
natural or human-induced disaster . These facilities include: ….
Add the following definitions:
Earthquake Fault Zone
Seismic Hazards ( Primary): Grondshaking, Surface rupture/deformation
Seismic Hazard (Secondary):Liquefaction and Landslides (Earthquake related
Quaternary Faults
Landslides: other than secondary seismic
WUI
Page 8-3.
8.1 Emergency Preparations, Response, and Recovery
Page 8-3. 8.1 Emergency Preparations, Response, and Recovery:
Introduction: The Town of Los Gatos Emergency Operations Plan (EOP) that i dentifies
the existing hazards within the Town, provides guidance and education for effective and
skillful emergency response techniques, and the most effective allocation of resources
for protection of people and property in the event of an emergency.
Goal HAZ-1 : Ensure the community is prepared for natural and manmade disaster s and
can respond quickly and efficiently. I think this is a policy rather than a Goal. I suggest
combining HAZ-1 and HAZ-2.
HAZ-1.1: Coordinate and incorporate emergency preparedness into all Town Planning
efforts, including plans for communications, providing adequate access for emergency
equipment and for evacuation in the case of emergency .
HAZ-1.2: Policies 1 & 3: These policies overlap. I suggest combining them into one policy
HAZ-1.3: Participate in local and regional emergency preparedness planning. and response
efforts to present the Town needs and interests in regional emergency management
planning .
HAZ-1.4: Emphasize responsibility of residents and /businesses to mitigate potential
hazards.
Page 8-4: Siting of Essential Facilities:
HAZ-1.5: The Town shall not site essential facilities , public safety ,,,,,,,,or hazardous
materials storage facilities in areas ………. ( Essential facilities are defined under Key
Words)
Comments on Draft Health and Safety Element GP2040
2 of 5
Page 8-4: 8.2 Geological and Seismic Hazards
End the second sentence in the second paragraph after “.....and 1989 Loama Prieta
earthquakes being the largest”.
Delete the rest of the paragraph and delete the last paragraph and replace with the following
new paragraph: Implementation of applicable building codes and geotechnical investigations
will minimize potential loss of life and damage to property from primary and secondary
seismic hazards and siting essential structures and services outside high risk areas will
enable faster emergency response after an earthquake.
Pages 8-5, Fig. 8-l
Why the change in name from Major Faults to Regional Faults?
Label the San Andreas, Hayward and Calaveras faults.
Distinguished between Quaternary Faults that have been active within 10,000 years and 1,6
thousand years ago.
Add a figure, at a larger scale, of faults that run through Los Gatos. (i.e., the area outlined in
blue) This could be as a separate figure or a box within Figure 8-1)
Page 8-7, Page 8-11 and Page 8-14:
Figure 8-3 Seismic Hazards : T he introduction to 8.2 Geological and Seismic Hazards refers
to liquefaction and landslides as secondary hazards. Suggest amending title to Secondary
Seismic Hazards to be consistent with the definition.
Figures 8.3, Figure 8-4 and Figure 8-5: Increase the legibility of roadway networks which
overlays the colored portions of these figures.
HAZ-1.5: The Town shall not site essential facilities , public safety ,,,,,,,,or hazardous
materials storage facilities in areas ………. ( Essential facilities are defined under Key
Words)
Page 8-8: Goal HAZ-2 and the Policies that follow:
I find this section confusing:
What is the difference between a geological report, a geotechnical report and a report?
What is the difference between a geologic hazard, a geotechnical hazard and a seismic
hazard?
What type of hazards are erosion and sedimentation?
What defines a property or portion of a property unbuildable?
Does Figure 8-3 include all potential landslides or just those secondary to seismic shaking?
Is it possible to mitigate for fault rupture, other than moving the development outside of the
rupture zone?
Page 8-10 8.3 Flood and Inundation Hazards
Comment: The James J. Lenihan Dam, the third largest dam in Santa Clara County, is
located just south of Town parallel to Highway 17. While the potential dam failure may be
low, the Background Report states on Page 8-22: that the potential inundation zone in the
event of the failure of the Lenihan Dam would be significant. Over 3,000 people and over
1,000 structures could be potentially affected. The Town has installed signage directing
people to evacuation routes in the event of the dam’s failure.
3 of 5
I think the potential damage from the dam’s failure deserves mention in the General Plan
even if the potential for failure or overtopping is low.
Page 8-12:
Goal HAZ-3. Delete to the greatest extent possible. The goal already states “Reduce” not
eliminate.
Policy HAZ-3,4 Require tha t n ew development………………….to existing structure shall
meet…….
Policy HAZ-2.6 Comment: This is an overly broad statement. Respond how? Responds to
impacts of the increased hazard by improving emergency response; or to avoid or mitigate
for the potential for increased impacts?
Page 8-13: 8.4 URBAN AND WILDLAND FIRE HAZARDS
The entire section does not adequately incorporate the excellent input the GPAC has previously
received from the public on fire safety. (and emergency preparedness in general). It is a very weak
section and that I believe requires a total rewrite.
I made the following comments as I was reading this section in the order it was written, however I
stopped once I began to feel that at a whole it was not adequate.
Introduction:
First paragraph of the introduction : Does the WUI include all classifications shown on Figure
8-5? I think it is important to emphasize the link between fire hazards, especially wildland
fire, and air quality, greenhouse gas emissions and climate change.
I suggest, at a minimum, a new first paragraph to the introduction as follows:
Santa Clara County, including Los Gatos, has a high potential for devastating wildland
fires. As future climate change-related impacts increase, there will be greater potential for
more frequent and more intense wildfires, along with the potential for these fires to release
significant quantities of Greenhouse Gases and particulate matter into the atmosphere. .
Strong land use policies and mitigation measures are necessary to protect the health and
safety of residents, to minimize the lose of life, and to minimize property damage and
damage to infrastructure.
Incorporate in the introductions the tie between increasing fire hazard and Climate Change
(There is a short discussion in the Background Report Page 8-31.)
Is there anything mandatory in the OAHMP, the CWPP or Annex Nine or are they limited to
guidance?
Page 8-15: Other comments:
Goals HAZ-4 and HAZ-5: I think that HAZ-4 is a policy not a goal
HAZ-4.4: Secondary Emergency Access: Provide emergency access as required by the
Santa Clara County Fire Department . that will not increase traffic for homes in areas
identified as Very High Fire Hazard Areas on the Town’s Wildland Fire Severity Zone Map.
Reducing fire hazards, especially in the hillsides, affects the entire Town ,
Does the Town’s Wildland Fire Severity Zone Map refer to Fire Hazard Severity Zones,
Figure 8-5 on Page 8-4.?
4 of 5
8.5 NOISE
Comment:
I do not think that noise fits comfortably with Hazards. I think it works better as a
stand alone element. Since noise in Los Gatos is largely regenerated by vehicle use,
it could fit after the Mobility Element. 5
Page 8-16: Introduction
First paragraph: While N oise is frequently an integral part of daily living…….
Second paragraph, second sentence: Table 8-1 contains the land use noise compatibility
criteria established in 2010, representing the maximum acceptable noise in decibels t hat
may be received by for the listed land use category,
Second paragraph, last sentence: In addition t he Town of Los Gatos Municipal Code….
Page 8-21:
HAZ-10.1: Protect existing and proposed residential areas from noise by requiring
appropriate site and building design, sound walls, buffering landscaaping and or the
use of…..
Comment: It requires a minimum of 100 feet of dense landscaping to reduce noise by
1 db.
HAZ-10-2: What designated areas? Why only a “may”
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